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Beyond Compliance: Achieving Safety Excellence Through eLearning
By Ron Kirsch, PureSafety

At the end of the day, the goal of occupational health & safety professionals is not only to keep all employees safe, healthy, and on the job, but also to send them home safe and sound to their families and loved ones. Getting to that goal has sparked numerous debates and philosophical discussions over the years.

This article will compare and contrast the components of basic compliance with the elements of safety excellence and the benefits of reaching beyond compliance. We will discuss the use of technology for delivering online training, measuring the effectiveness of training, and eLearning's role in driving safety excellence.

Basic Compliance
So, what is basic compliance? Quite frankly, it's the bare minimum standard. Basic compliance as it pertains to safety is covered by a number of regulatory bodies like OSHA, MSHA, DOT and EPA. Within these agencies are rules and regulations in the form of standards, directives, interpretations, enforcement guidelines, etc. In addition to the federal regulations, there may be requirements at the local and state level to consider.

However, even if you are meeting the basic requirements of the OSHA regulations, you may in fact still be out of compliance. OSHA has a catch-all regulation called the "General Duty Clause". The General Duty Clause may be one of the most overlooked aspects of OSHA compliance, and yet it is the backbone of the OSHA standards. Section 5 (a)(1) of the OSH Act requires employers to furnish a workplace that is "free from recognized hazards that are causing or are likely to cause death or serious physical harm. Note the language "likely to cause" implies a level of risk assessment that is already beyond mere compliance.

Even if there isn't a specific standard on a safety hazard, an OSHA inspector, by way of the General Duty Clause, can cite your company for non-compliance due to an observation or opinion concerning a hazard that is not covered under any other standard. Remember, OSHA is performance oriented and results driven. Your organization will be evaluated based on the results of your programs. Basic compliance is just the first step towards safety excellence.

Beyond Compliance
Now let's compare the components of "basic compliance" with the components of "safety excellence".

Basic compliance begins with a safety culture driven from the safety department.In safety excellence, the safety culture is driven from top management down. You have management commitment, leadership and direction. As you start to weave safety as a value into the fabric of your organization you create a culture that expects zero accidents. Employees are involved in the process and continual improvement is in place.

Basic compliance includes written programs and job safety analysis (JSA's).
In an environment of safety excellence, written programs are active, living documents. JSA's are coupled with proactive risk assessments.

In basic compliance forms and processes are in place, accidents are investigated, inspections and audits are performed, and OSHA logs are kept. In safety excellence, retrospective and root cause analysis is used. This starts with your OSHA log information including the number of recordables and reportables, injuries, illnesses, frequency and severity. These are key indicators of your program's performance. However, looking at your OSHA logs and claims history is like looking in a rear-view mirror. In safety excellence, you look for leading indicators and opportunities for early intervention, as well as determining root cause and investigating incidences and near misses. You have appropriate performance metrics in place and use them to determine your opportunities for continual improvement.

Ask yourself - is your system/program working? Systems are designed to produce exactly what they're producing. So if you're not getting the desired results, you dig deeper and change the system. Examine your workplace environment, worker capabilities, and their motivation to perform. Examine how these elements are integrated and working together and where they are not.

Basic compliance programs have reactive safety management. Have you ever felt like a firefighter or the safety cop trying to enforce your safety department's standards? You end up doing triage and caring for your injured workers rather than preventing injuries.Safety excellence is proactive safety management. You track near misses and use the event as a learning opportunity. Once you have a solid foundation in place, you can work on behavioral-based initiatives and programs, and utilize peer to peer observations and interventions. You may also wish to consider an incentive-based program that encourages both reporting as well as the culture of zero accidents.

Basic compliance programs have adequate tools and PPE in place. In safety excellence you are constantly re-analyzing your systems and processes; engineering controls are sought first.

Basic compliance establishes the required training schedule and basic training materials are in place. In safety excellence, training is part of the corporate culture. Training materials are customized and kept fresh to keep employees engaged. Your compliance-driven training is running smoothly while your resources are focused on addressing risk management concerns and pro-active/just-in-time training events.

Training & Technology
Now let's zero in on the importance of training. In many ways, training reflects your corporate safety culture, creates awareness, and builds knowledge of your programs. It is a core component of any safety excellence program. However, training workers in a system that is broken will only produce better-trained injured workers. And if your employees are not engaged in training, they are not going to learn. Effective training programs can help change employee behavior and drive accountability outward in your organization. The use of technology in the form of eLearning can play an important role in managing your overall program.

In an independent study conducted by Management 21, a Nashville-based market research and consulting firm, in December 2004 on trends in safety training, 32% of 410 safety and risk management professionals responded that they use some form of eLearning. Five years ago that number was likely 5%. Five years from now, that number will likely be 80%.