• The occupational health and safety (OH&S) consequences of their work activities and behaviors
• Their roles and responsibilities for following OH&S policies and procedures
• The consequences of not following these policies and procedures

As anyone who has put together communication and training programs will tell you, trying to raise awareness can be a difficult undertaking.

Therefore, I was struck by an article in the August 2009 ABA Journal that discussed how a New York City ordinance for “raising awareness” to prevent obesity ended up the subject of a lawsuit.

In response to a report that showed that more than half of New York City adults were overweight, New York put in place a health code ordinance that required chain restaurants to post the calorie counts of the foods they served on menus and menu boards.  The New York State Restaurant Association sued to block this ordinance, claiming it either violated the restaurants rights to free speech or was preempted by federal law.  In early 2009, the 2^nd Circuit Court of Appeals rejected both arguments.

What I found particularly interesting about this article was the discussion of the results of customer surveys that were conducted both before and after the legislation went into effect of individuals leaving fast-food restaurants. 

Prior to posting the information on menus, only 23% of the people surveyed said they saw calorie information.  This information was available on posters, food packaging and websites – but not on the menu.  Afterward, 60% of those surveyed reported seeing the calorie information. More importantly, one in four of those who noticed the information said it affected their purchases.

What is the lesson for OH&S management systems?

Programs to increase awareness can impact individual behavior; however, the awareness information must be provided in a way and at a time that it can be used effectively.

OH&S “awareness” information should not be buried in safety procedures, on web sites or in training materials. It needs to be made available when the associated work activities are actually being performed –

• Embed it in your work instructions
• Include it in forms that need to be completed anyway
• Post it on signs in appropriate areas

If the information is important, make it available when it counts.

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

In this case, like many, many others, the training being provided was an on-line generic training video developed by an outside safety training company that had been turned into “web-based” training.  What struck me in reviewing this training was the complete and total disconnect between the operation being performed at the facility and the safety training being provided to the employees performing the work. 

They had almost nothing in common. 

For example -

• The facility using the flammable liquid was a clean room / laboratory operation; the training film was set in a “heavy industry” machine shop.
• The task involved handling of relatively small quantities of flammable liquids in glass beakers; the training video showed the handling of large quantities of flammable liquids in 55-gallon drums.
• No bonding and grounding is used during dispensing operations; the training video emphasized the importance of bonding and grounding.
• Employees used little PPE; the training video showed employees using respirators and face shields for protection.

Because I am currently in the process of developing several e-learning programs, I have been reviewing information on instructional design as it relates to creating web-based training programs.  One of the experts in this area is M. David Merrill, a professor of instructional technology at Utah State University.  One of the points he emphasizes is – simply providing information is NOT instruction.  Instead, when developing training, he suggests that you start by developing a task-centered instructional design strategy. 

Start with one of the tasks being performed and build training that is appropriate to performing that task.  Eliminate information that is irrelevant or misleading.  Focus on what is important and useful to the specific task.  Apply the information to case study situations that are consistent with the content being taught.  Ask students to apply the knowledge being taught to a scenario that is similar to their real-world experience.  Build your training by repeating each of these steps for any other relevant tasks.

Want more information? 

Go to M. David Merrill’s web site and download his paper that discusses using the use of these principles in developing an on-line first aid course in Australia.  It is really cool.

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

It seems that the appropriate definition of competence is now subject of some debate within ISO and may be subject to being “re-defined.”

Competency is a significant component of at least four standards currently under development within ISO –

• ISO 10018 – Quality management: Guidelines on people involvement and competencies
• ISO 14066 – Greenhouse Gases – Competency requirements for greenhouse gas validators and verifiers
• ISO 17021 Part B – Conformity assessment – Requirements for third-party certification auditing of management systems
• ISO 19011 (revision) – Guidelines for management system auditing

Interestingly, each of these standards has apparently rejected the dictionary definition, as well as the ISO 9000 definition, and each ISO Technical Committee appears to be in the process of developing its own concept of competence. 

ISO 10018 is apparently focusing on how “human factors” impact the effective functioning of management systems with the definition of competency being passed to a subcommittee.  ISO 14066 is structured to set out detailed lists of the skills and knowledge that must be possessed by GHG verification and validation teams – with the focus on team rather than individual competency.  The initial committee draft of ISO 17021 defined competence as “personal attributes and ability to apply knowledge and skills” with a heavy focus on personal attributes and generic audit skills but essentially no guidance as to the needed discipline-specific knowledge (e.g. quality, environmental, OH&S).  The revision of ISO 19011 has just begun; however, the issue of auditor competency has already been identified as one of the “hot-button issues” associated with revision of this standard.

A review of the various standards and other reference materials appear to set out three different, and distinct, attributes that underlie competency:

• Attitude and personality traits –who you are
• Knowledge – what you know
• Skills – what you can do

Where the ISO standards seem to diverge is in the relative importance to be given to each attribute (personality vs. knowledge vs. skill) as well as in the specifics of what is actually required and how it should be demonstrated.

What do you think?  What is competency?

© ENLAR^® Compliance Services, Inc. (2008)

What is the Difference Between Competence and Awareness?

Competence is the “demonstrated ability to apply knowledge and skills” (see 3.9.12 of ISO 9000-2000). Awareness is defined as “having knowledge.” Awareness is to know something; Competence is the ability to do something. For example, I “have knowledge” (awareness) concerning the installation of ceramic tile but I do not have the demonstrated skill or ability (competence) to do so (as demonstrated by a past home improvement project). I am, however, competent to install wood trim (again, as demonstrated by past performance).

Training to Competence

The primary focus of section 4.4.2 of OHSAS 18001 is competence — ensuring that individuals have the demonstrated skills and abilities needed to perform tasks that can impact occupational safety and health.

Training alone is often insufficient to establish competence. Most training programs do not include the needed demonstration of skills and abilities. Sign-in sheets documenting “seat time” in a training session do not verify competence. On the other hand, a training program is not needed if competence can be established in other ways — for example, by third-party certification or licensing.

So who needs to have demonstrated competence?

• Individuals with responsibility for establishing, implementing & maintaining the OHSMS
• OHSMS auditors
• Individual workers, including contractors, performing dangerous tasks
• Individuals responsible for workplace conditions that impact OH&S
• Top management

What competence these individuals need will be the subject of future blog posts.

Developing Awareness

OHSAS 18001 Section 4.4.2 requires that workers have the following types of awareness:

• The safety and health impacts of assigned tasks
• What needs to be done to do these tasks safely
• What will happen if the tasks are not done safely

Again, awareness does not require training. In fact, training may not be the most effective way of establishing awareness. Other methods — signs, e-mail notifications, hand-outs, etc. — are often more effective in communicating the information needed to establish awareness.

© ENLAR^® Compliance Services, Inc. (2008)

On one hand, there is the view that all tasks, especially important ones, need to be reduced to written work instructions.  After all, the person performing these tasks might “win the lottery” and never return to work.  On the other hand, there is the view that it is more important to have competent people performing critical tasks.  The example — “If you were going to have brain surgery, would you want a surgeon who is competent or an individual who is simply following a set of written work instructions?”

This conflict of views was recently brought into focus for me.  A senior manager in a company suggested that the work being done by the OH&S staff should be reduced to “work instructions that anyone can follow” for entry into the company’s preventive maintenance program.

This suggestion made me stop and ask myself the following questions –

Can OH&S professionals be replaced by a preventive maintenance (PM) program?

OH&S professionals are not the first, or only, ones that face being replaced by computer programs.  Accountants have faced it with the growth and acceptance of tax preparation software.  Lawyers have faced it with do-it-yourself wills and contracts programs.  Doctors are facing it with improved medical diagnosis software.  Every knowledge worker is facing the prospect that at least some aspect of their “professional practice” will be replaced by a computerized software system.  Therefore, at least in part, OH&S professionals likely can be replaced by a PM program.

Should they be?

This question is much more difficult to answer. It brings me back to the title of this post — “You will be assimilated.”  As Star Trek fans know, this quote is the message sent by the Borg when they targeted a new species for integration into “the collective.”  Once in the collective, individual independence was lost. Conformance replaced creativity.

The fundamental issue in determining whether professionals should be replaced by computer programs is whether there is value in the “independent creativity” that cannot be assimilated into a computerized system.  At least for now, I am much more comfortable relying on competent OH&S professionals than on work instructions entered into a PM program.

What do you think?

© ENLAR^® Compliance Services, Inc. (2008)