Wednesday, September 17, 2014

A Better Way To Be Compliant

We are currently on our way back from the National Safety Council Congress & Expo, where we presented on the topic of HumanPerformance. The session went very well with the room literally packed, with some having to be turned away. We were surprised at the interest in the topic, but very encouraged nonetheless. Even still during and after the presentation we got some of the typical (and understandable) responses from those who have not yet bought into the ideas we’re espousing, such as questions about personal responsibility.

One question that came up a couple times (in a couple different ways) is how the ideas related to human performance relate to compliance. One attendee said that at some point we have to deal with the fact that there are laws that must be complied with, so no matter what we’d like to do in terms of empowering employees and removing unnecessary constraints, at which time we will hit the wall of compliance that we cannot cross. Another attendee questioned whether these ideas would not be best suited for those companies that have already achieved the stability of compliance but who then want to move to higher levels of safety performance.

These are both very good questions, and so, in addition to answering them during the session, we thought we’d address them here so we could explain our perspective to a wider audience. First, we do have to say that, at some level, the questions hint at a slight misunderstanding of the point we’re trying to make. It is true that at some level we do advocate the stance that behavioral controls, such as regulations, are overused in safety practice. However, on a different level what we’re saying is that if there are problems you face in your organization (regulatory compliance just being one of many) that you should not think of your employees as part of the problem, but rather as part of the solution.

Let’s use an example to illustrate what we’re talking about. A common problem in any warehouse where forklifts are operated is how you get your employees to wear their seatbelt. Wearing a seatbelt while driving a forklift is a good idea, but even if it wasn’t, it doesn’t matter because the regulations almost always require that if a seatbelt is present your employees need to wear that seatbelt. That’s a hard and fast rule and there’s no leeway.

But just because such a rule exists doesn’t mean that we need to put all the focus on the individual employee to comply with that rule. We can take a systems-approach and engage in a discussion with employees why they do not wear the seatbelts. We’ll often find answers such as the fact that they are too busy, they don’t see the point, the belts are uncomfortable, etc. If we then level with employees and tell them that we have to do it because it’s the law and ask them for ways to help them comply more we may be surprised with the solutions we find. Sometimes it involves finding a new piece of equipment that makes the belts more comfortable. Sometimes it involves changing of the work processes or accountability structures, to make following of the rules more consistent across the board. You might even find that the simple act of engaging with employees activates a team spirit within your employees, who then take ownership to simply hold each other accountable to comply with the rule.

And you can think of other examples where taking a systems-based, human performance approach can help achieve multiple competing goals, such as compliance, safety, and production. Additional examples of common compliance problems, with some potential systems-based questions you could ask are below:
  • Employees not using ladders appropriately. Are the proper ladders readily available in a way that doesn’t require a lot of effort? Are there other tools available that make the use of ladder unnecessary? How do the employees perceive their job load (heavy versus light) and how does that affect their ability to pre-plan jobs and make adjustments during a job?
  • Blocked equipment (fire extinguishers, electrical panels, etc.). Is there adequate, convenient storage in the area? Is the equipment stationed in a bad place? Is the equipment adequately marked for the purposes of identification?
  • Chemicals stored without labeling. Is there an easy way for employees to create compliant temporary labels on containers? Do employees have adequate training in labeling requirements and how to identify hazards that need to go on a label (from their perspective, not yours)? Is there a way to have labels pre-printed on containers that are commonly used for certain types of chemicals?

We’ve also talked an approach regulatory-required permits utilizing this mindset in a previous blog.

The bottom line is by incorporating the idea that your organization is a complex system and that your people are a solution to harness, rather than a problem to control, you might find some innovative solutions to your compliance problems. These ideas are not just for those organizations that have already achieved 100% compliance are looking to go to the “next level” (we’re not sure that any such organization really exists). These ideas are for any organization that has people in it and has competing pressures, such as production, scarce resources, complicated regulations they must comply with (that sometimes contradict each other), and the need to work safely. Does that sound like your organization?

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