When I teach JHSC certification courses, there is always a discussion about the importance of supporting the internal responsibility system, both directly through statutory obligations and through due diligence. In our course, we speak of the Five D's. These are: due diligence is demonstrated through documentation and discipline. Now documentation elements are pretty straightforward. What I would like to discuss here is how it is demonstrated and enforced in your workplace. Today, our question is: is there a disconnect between your floor supervisors and your company's health and safety policy?
This thought is a bit of an expansion from a previous post. I recently was asked to complete a distracted driving blog. This was prompted by an increase in participants attempting to take distance learning courses via their cell phone AND go for a drive simultaneously. Needless to say, not cool. In terms of legislation, the example given was OHSA S.28(2)(b). A citation was made from the Canadian Safety Magazine about forklift drivers and cellphones – how it is the employer's duty (through the supervisor) to enforce these policies.
So my question to you – is, how well does your health and safety program work? If I were to walk across your shop floor with my safety glasses on the top of my head – would I be stopped and reminded to put them on correctly? Or would I casually stroll the entire length of your facility unapproached by your supervisors?
As defined under the OHSA, it is the employer's responsibility to appoint a competent person as a supervisor. To meet this requirement, your employer must ensure the supervisors are trained and understand their duties and responsibilities.
At Industrial Safety Trainers, we recommend your supervisors:
- Ensure that an employee complies with the Act and regulations
- Ensure that any equipment, protective devices or clothing required by the employer is used or worn by the employee
- Advise an employee of any potential or actual health or safety dangers known by the supervisor
- If prescribed, provide an employee with written instructions about the measures and procedures to be taken for the employee's protection
- Take every precaution reasonable in the circumstances for the protection of employees.
Supervisors must know which laws apply to their workplaces - how else can they ensure they are being followed? If there is any uncertainty, the Ministry of Labour, Training and Skills Development may be contacted. If workers have any questions about workplace safety, they should be encouraged to contact their supervisor. A competent supervisor is dedicated to ensuring that you are safe, your concerns are heard, and, where attention is deemed necessary, have been addressed.
As part of your organization's health and safety program, the duties of the supervisor should include:
- Ensure employees are trained in proper work practices and job safety requirements associated with a particular job or process,
- provide introductory training to new employees and reinforcement training to regular employees
- Respond to and correct unsafe acts
- Report and investigate any and all incidents, such as those resulting in personal injury or property damage
- Implement an emergency plan when necessary and ensuring that employees have been appropriately trained to comply
- Regularly evaluate employee’s ability to work safely and providing feedback and corrective measures to the employee
- When contractors or visitors are in the facility or on our job sites, Supervisors will monitor their activities to ensure they are working safely and not putting themselves or others at risk
- Conduct regular inspections of the workplace, usually through their daily travels, to ensure hazards are identified and corrected
With all of that being said – you need to believe it is being done, but verification is imperative. Just because it is written in a program doesn't mean it actually occurs at the worker level. So for your supervisors, I have a few questions.
Starting off, let's cover the demonstrate aspect of the Five D's. Are you or your supervisors leading by example? Is this a "talk the talk and walk the walk" scenario – or a "do as I say, not as I do" situation? If a worker is expected to follow the rules in the workplace, they will often mimic the behaviours they see around them. Supervisors are the employer's representatives at the worker level. If they do not uphold the commitments made in the program, it is almost unreasonable to assume workers will comply without solid leadership. Examples of this behaviour: I have personally witnessed improper footwear, careless operation of equipment, cellphone use in hazardous areas, inappropriate language including racial slurs, giving instructions contrary to a standard operating procedure, and even instigating pranks in the workplace. I have seen these actions as an outside party – I would hate to see what happens behind closed doors. Doing what you're told even when you aren't being watched is called integrity – it is demanded from our workers; make sure it is also a set expectation of supervisors.
The other aspect of the Five D's that is important for preventing a disconnect between program commitments and their execution is discipline. Are your supervisors actually enforcing the rules, or are they trying to be everyone's friend? The responsibility of being a supervisor is a hefty burden, to begin with, I am aware, but being that employer representative at the worker level means you are also the first level of enforcement. In our JHSC training (JIUN INSERT LINK TO LANDING PAGE HERE), we cover the "ABCs of behavioural safety." These are the antecedent event (what triggers the behaviour), the behaviour (what the worker does), and the consequence (the ramifications of the chosen action). If positive actions are not acknowledged or negative actions not corrected – the worker operates without a consequence. Discipline is not bad in the workplace, but many supervisors are adverse to have difficult conversations with their workers. If that is the case, how can they ensure the employer's commitments in the program come to fruition? Well, they can't, and that's why discipline is such an essential part of the Five D's of due diligence. Think about how fast you personally would drive if the speed limits were NOT enforced. Some people would still respect them, while others would drive like they are on an episode of Top Gear. Unenforced controls are ineffective everywhere, not just in your workplace.
Remember that the underlying principle behind the Occupational Health and Safety Act is the internal responsibility system. All three parties, the Employer, the Supervisors and the workers, have to fulfill their roles for it to be successful. Ultimately the employer bears the most responsibility – but in most cases, they are just a corporation – a piece of paper. It is the supervisors appointed who can make, or break, the effectiveness of a written safety program and the safety culture it is trying to sustain.
Geoff Rowatt | CHRL
Industrial Safety Trainers Inc.