Many organizations use the start of the year as a time to review their OH&S management system objectives and set new ones.  If their OH&S programs are lagging in their implementation, new approaches or new assignments are considered. 

This is also a good time to address all that PAPER – either physical paper or electronic paper.  This includes all those completed hazard evaluation forms, inspection checklists, excel spreadsheets, meeting notices and minutes, e-mails with various interested parties, incident investigations, corrective action reports,….

When I help develop record control processes and procedures for an organization, one of the concepts I try to incorporate is the inclusion of record schedules with record breaks and scheduled clean-out days. 

A record schedule is a document that defines how a record is to be kept, how long it needs to be maintained in an active storage location and when it should be destroyed.  U.S. EPA has an informative discussion of the purpose and use of record schedules on its web site. 

The first key to using a record schedule is organizing your records in a way that makes complying with your record retention requirements as easy as possible.  This usually means using record breaks – usually defined points in time when you start a new file. For example, rather than filing all of your records pertaining to a particular topic randomly in one file folder (physical or electronic), you file them by year so you can move an entire year’s worth of records to a different location (off-site storage or electronic archive) at one time. 

The second key to using a record schedule is actually setting aside a time for moving old records out of active storage locations and getting rid of unnecessary records in accordance with your organization’s record retention policies. 

Although this often appears to be an unimportant mundane task to “put off to another day” it is important to the smooth functioning of your OHSMS. 

So, schedule your record clean-out day today.  By the way, wear comfortable clothes and order a pizza.  It will make the job easier.

© ENLAR® Compliance Services, Inc. (2009)

This is not easy.  Often, the root cause investigation ends with a determination along the lines of “Joe screwed up.”  We play the blame game.

Why?

There have been a number of reasons advanced for this and most of them are probably true – at least in part.

Last week, a colleague lent me his copy of Dan Gano’s book – Apollo Root Cause Analysis.  This book sets out a different way of approaching root cause analysis by focusing on defining a problem in terms of both the action and the conditions that caused the particular effect you are analyzing.  For example, you don’t get a fire (an effect) unless you have an ignition source (an action) as well as two conditions (fuel and oxygen at the right concentrations).  Remove either condition (fuel/oxygen) or the action (ignition) and the effect (fire) does not occur.

What I liked most about the book, however, was not the root cause methodology advanced in the book but the explanation of why we so often fall into the blame game.

In a word – storytelling.

As humans, we have a long tradition of storytelling.  It comes naturally to us.  It is how we have transmitted information for generations.  Everyone likes a good story.

Integral to storytelling is identifying your actors – answering the question “who” is central to telling a good story.  As Gano points out in his book, most incident reports provide a prime example of storytelling.  The initial focus is typically on who did what.  Unfortunately, for purposes of root cause analysis, storytelling sets us up for failure because it keeps us focused on the story – who, what, where and when – rather than focusing our attention on identifying the causes of an incident. 

So when you are investigating an incident or nonconformity, tell your story.  It is, after all, human nature and likely irresistible.  But when you start your root cause analysis, put the story aside and take the “who” completely out of the analysis.  Remove the names and strike the identifiers.  Instead, focus your attention on the actions and conditions that lead to the situation (effect) that you are investigating.

© ENLAR® Compliance Services, Inc. (2009)

 I just got done reading an article in the October 2009 Quality Progress Magazine that sets out a nifty tool for making this decision – a 2 x 2 matrix for deciding whether or not to standardize a process.  Although the example given in this article – Building a Consensus – is  for a quality system process, it can be easily adapted to making standardization decisions in an OH&S management system.

Try it out for your OH&S management system and let me know – “Did it work?” - by posting your comments below.

© ENLAR® Compliance Services, Inc. (2009)

That is the wrong message and the wrong goal. 

To quote Peter Drucker – “There is nothing so useless as doing efficiently what should not be done at all.” 

The goal should not be to do more with less – it should be to do less.

What many OHS programs really need is a good pruning.  It is common for occupational health and safety management systems – particularly those driven by corporate mandates – to be filled with procedural “deadwood” and nonsensical “undergrowth”.

Want to start cutting back?  Try the following –

1.  Re-examine your Assumptions

Often OH&S programs are put in place because of so-called “good practice”.  These “good practices” are often characterized as requirements so the needed resources can be justified. 

Review your programs and procedures. For each program, procedure and form, re-examine the assumption that “we must do it this way”.   Do you need to do it at all?  Is there a more effective way?

2. Push Back on Busywork

It is a fact of life.  People like to tell other people how to do things. 

Evaluate the “busywork” quotient of your processes and procedures.  Avoid creating unnecessary work for others and “push back” when others attempt to do the same to you. 

• Don’t create a twenty page procedure if a one page form will do. 
• Don’t take on activities simply because they are “a nice idea” (often defined as something mentioned in a meeting by someone in senior management).
• Don’t add multiple layers of redundancy when it is not needed – especially if it is only to please some auditor.

3.  Keep Your Focus on Performance

Make sure you truly understand your OHSMS requirements – your OH&S risks and your legal obligations.  Focus your efforts on addressing these first – in as an efficient a manner as possible.  Say “NO” to suggestions that are not focused on improving your OHS performance.

4.  Be a Tortoise not a Hare

Focus each day on consistently moving forward.  It is easy to get discouraged when progress is slow and results are not readily apparent. Keep at it. 

Remain vigilant.  Resist the temptation to take on more than you have the resources to reasonably accomplish. If you have a plan and keep focused on doing what is important – rather than adding in additional activities that are new and exciting – you can accomplish your goals. 

Pruning is not easy. 

The status quo is often comfortable.  Change often meets with resistance. 

 You are very likely to hear – “We have always done it this way.  Why do we have to change?”

The answer – to survive when resources are scarce.

Need additional help? 

Check out the following –

• Abandoning the Obsolete and Unproductive - Column on Human Resources IQ website discussing why organizations need to prune their efforts.
• The Power of a Positive No by William Ury – Book offering concrete advice for saying No.

© ENLAR^® Compliance Services, Inc. (2009)