COMPASS NEWSLETTER SPRING 2017
Benefiting from the Hazard Assessment Process
I don’t know how many audits I have conducted over the last twenty years but I know it is in the hundreds. One of the areas that I have found hardest to assess as an auditor is the hazard assessment process. Why is this? Well, there are many reasons, first in order to truly know if all jobs and tasks have been assessed, one has to rely on and accurate company job/task inventory. No auditor can possible have an intimate knowledge of all tasks and hazards of all jobs. To help with this challenge I incorporated some additional questions into my audit interviews in order to flesh out some additional task and hazard information that may not otherwise be revealed. For example, I always ask interviewees, “What are the top two or three hazardous task that you do?” Then I ask if they felt there are currently good hazard controls applied to those tasks. This is one way an auditor can gain the important hazard assessment information needed to more accurately completed the hazard assessment section of the audit protocol.
Many audit protocols focus most on the existence of hazard assessment documents rather than on the quality of the documents. If the assessments are of poor quality they will be of little preventive benefit to the users. So many employers are so intent on meeting the audit hazard assessment document requirements, that they miss the great value assessment can offer as preventive tool. Here are some common mistakes I have noted employers make relative to this process:
-Hazards and or tasks are assessed as a group. For example, a task may contain three distinct hazards. If those hazards are then assessed as a group, it is almost impossible to properly assign risk to the hazards. In addition, grouping typically results in gaps in the controls identified. For these reasons, each hazard should be assessed individually.
-The hazard controls listed are ambiguous. Control statements should provide direction on prevention. Controls such as “be careful”, “keep safe”, “be aware”, “mind on task” are examples of controls that provide little direction. Specify the controls.
-Corrective actions, responsibility for action and completion dates are not fully documented. There is more to hazard assessment that the identification and documentation of hazards. The hazard assessment document should clearly identify who is responsible for preventive action and then it should help ensure actions have been completed.
-The assessment documents are not utilized. Here is a basic chart depicting possible uses of assessment documents:
Orientation – new employees should have the opportunity to review all assessment documents relative to their work. This is an excellent way to help a new employee get orientated to his or her job tasks and hazards.
Work Procedures – use assessments to update work procedures and practices. If the assessment documents are updated regularly, there is often new preventive information that should also be updated into the procedures. Employees may refer directly to a procedure for work direction and not the assessment document. The procedure, therefore should be complete and up to date.
Training – training opportunities are frequently identified in the hazard assessment process. Make sure these opportunities are incorporated into training needs assessments and then delivered to those in need.
Quality is key in ensuring there is value in the hazard assessment process. A key supervisory responsibility is to not just assign and oversee the assessment process but demonstrate to their workers the quality expectations. Supervisors should then work with employees to help them achieve the targets and hold those not meeting them accountable. Quality is a target we should strive to achieve in all aspects of our health and safety programs. In this case, the word “quality” is synonymous with value and benefit.
Compass Watchdog – Meeting with the Deputy Minister
In our last newsletter we reported on the millions of dollars that could be saved by making some basic improvements to the Alberta Government Partnership in Injury Reduction Program (PIR). In my previous Newsletter I reported on some waste and accountability issues relative to the PIR and Creative Sentencing programs. I expressed these issues to Brian Jean, leader of the Wildrose party in a letter but did not get a response back. I sent another letter to Dr. David Swan, Liberal Leader and he responded immediately and arranged to meet with me. We discussed the issues at length and he followed up with a letter of support to the Minister. I also sent a letter to Premier Notely who asked the Minister of the department to investigate. A meeting was subsequently arranged with the Deputy Minister, Bruce McEwan and PIR Director, Ian Hopper. The following is a brief summary of the outcome of this meeting.
We discussed the Creative Sentencing program first. In this program, employers convicted of occupational health and safety offences are required to fund projects that may reduce or eliminate the chance the offence(s) will recur. Many non-profit groups apply annually to benefit from these funds. It is not uncommon to see awards of one, two or three hundred thousand dollars per application. After reviewing a few of the funded projects I found one that awarded money to create a survey database. Anyone that has read any of our Newsletters knows that Compass has already developed a comprehensive survey database. The use of the Compass database has been offered to associations many times over the last ten or fifteen years. Funds were awarded in this case, to a develop a database that has already been developed. In addition, other funded projects appeared to duplicate other work that has already been carried out by other researchers (e.g. develop a hazard assessment training program). Further investigation determined the program contained no documents to guide applicants, project reviewers, or the courts in making their generous awards. Also it was noted that there was apparently little or no formal assessment of the project need, or a measurement of it’s success or failure upon completion. I am happy to report that the Deputy Minister promised to make the needed improvements to the Creative Sentencing program. I am confident we will see improved benefits from these awards in the future.
Discussions on the PIR program were less positive. The issues we discussed were on consistency in the PIR program such as with auditor qualifications and training, audit protocols, scoring (all or none versus range scoring), peer or no peer, as well as issues with the current safety perception survey standard. It was recognized that some changes take a great deal of time to evolve because the Certifying Partners seek unanimous agreement on proposed changes and therefore it can take a long time to come to a consensus decision. It was emphasized that the Certifying Partners have come to an agreement on a new audit protocol however, this is only one small change of the many needed. I came away from this discussion with little hope for significant improvement in this program for some years to come.
On a more positive note, there was some discussion about another survey database project that could not be completed because it ran short of funds. The government committed to exploring all options before supporting development of projects that may duplicate existing work.
Overall, I thought the meeting was productive. I didn’t come away with everything I had hoped for but I have some other avenues of change that will be explored (more on that in a future Newsletter). I am optimistic the government will come through with the promises they made but I am cautious because none of them were documented.