Safety Management System:
A Practical Application
The Safety Management System (“SMS”) guidance documents that exist (OHSAS 18001/18002, ANSI Z10, and ISO 45001 draft) are all great starting points, and every company no matter the size or structure can benefit by developing a well-documented safety program using any of these guidelines. Your company specific SMS should become your RoadMap to achieving your company goals, whatever they may be. This model was recently used to help a rental company achieve their goal of a “World Class” safety program. As the focus of your company’s safety program evolves from “Compliance to Culture” 1, so too should your management system evolve.
When it comes to safety improvement it’s important to apply the right amount of pressure; in the right direction; and at the right time. The problem for the Safety Professional is first understanding exactly where the company is in their evolution so that you know what is the correct type, direction, and timing of your efforts.
Often company leaders will say, “We need a behavior based safety program”. That’s great! There is nothing wrong with introducing Behavior Based Safety (“BBS”) as an element of your overall safety program. But most company leaders do not understand what that means, or what it takes to implement a traditional BBS program. Does the company have the staffing levels to support it? Do they have the foundational programs in place? Is the company culturally ready for this type of commitment? Nine times out of ten the answers to these questions is, no. They just aren’t ready for it. Safety Professionals need to be armed with data and information to push back when that happens. Remember, it’s about applying the right amount of pressure; at the right time; and in the right direction. Your detailed Safety Management Plan is your strategic plan that will give you the ammunition to push back.
Knowing where a company is in its safety program evolution well help you develop a strategic plan. Using the elements of the Safety Management System, and breaking them down further will then help you prioritize. The over used adage always applies. How do you eat an elephant? One bite at a time.
If a company is just starting out, they need to focus on developing their “Foundational” programs first. No sense worrying about Compliance Assessment when you don’t have standard procedures in place. No need to have in depth Leadership Reviews, when you are not doing a good job of Incident Management. On the opposite side, a company that has a very mature safety program needs to be more focused on the “Cultural” aspects of their program. How do we make safety a core company value?
This Safe Workplace model (see Diagram 1 – Affective Safety Program) clearly differentiates between the Foundational (Lower Half) and Cultural (Upper Half) aspects of the program. The model is further broken down into the traditional Plan-Do-Check Act (“PDCA”) quadrants. Each quadrant is then broken down into separate elements.
Many companies with more mature safety programs, have management systems which go beyond the known guidance documents. Which is great. However, most still lack specifics, and place too much emphasis on the Foundational elements, when they should be focused on organizational Cultural “Check” and “ACT” portion of the model. Having reviewed the SMS for several large corporations, some considered to be “World Class” safety programs, I found most have vague references to “Taking Action”, but provide little detail to what exactly that might entail. This plan gives Safety Professionals very specific actions to further improve the organizational safety culture.
Lastly, I have rearranged many of the items of the traditional PDCA model to reflect the practical aspects of the program. For instance, most SMS guidance place the “Communications” in the “Do” step. There is certainly lots to do here, but company communications need to reflect the overall culture of the organization, and they need to be adjusted as part of the Actions that are taken following the Check process. Similarly, one could argue that Emergency Response also belongs in the Do phase. I could develop arguments either way, but most of Emergency Response is about the planning. When there is an incident you certainly need to execute on the plan, but this has more to do with Incident Management.
Most companies list the Leadership Review in the Act step. Based on how most companies function, I have identified this as part of the Check process. This differentiate between leaders who are reviewing and recommending, and those Subject Mater Experts (“SMA”) who are acting on the recommendations of the leadership. Nothing has been left out in this model from the traditional guidance documents. As you read through my definitions, you will see that many elements have just been re-positioned or incorporated into other elements. I have attempted, in those instances, to provide my reasoning and justification for doing so. Lastly, while I think many company leaders can benefit from this information, I have written this with Safety Professionals in mind, with what I hope are practical recommendations, and less theory.