OH&S - Making Managers The Strongest Link

They exercise considerable leverage and operational influence, yet many workplace safety prosecutions can be traced back to their failings.

This paper discusses my "Top 10" reasons why managers are implicit in companies' failings and what practical steps can be implemented to make this employee class the strongest link - instead of the weakest.

A manager's legal responsibilities

Operational managers have two key responsibilities:

• To take reasonable care for the health and safety of people at their place of work who may be affected by their acts or omissions.
  
  
• To co-operate with his/her employer re: any requirement imposed in the interests of health, safety and welfare.
  
  

To protect against the risk of your managers being complicit in the compromise of your safety management system's integrity, I offer the following 10 practical suggestions:

1. Consider OHS skills and experience when assessing potential applicants for supervisor and management positions
   
   Employers can send the right message regarding the importance managers play in safety management systems, by building OHS requirements into advertised positions. After all, senior management is in effect delegating their own personal responsibilities to their managers.
   
   Delegation is far more effective if their reports have a demonstrated ability to deliver on safety outcomes. For internal appointments, it encourages persons lower in the hierarchical structure to develop those skills to improve their chances for career advancement.
   
   
2. Add more prescription to duty statements on particular OHS responsibilities under the safety management system and ensure those responsibilities feature in performance appraisals
   
   Examine duty statements for appropriate reference to each position's particular OHS requirements. If the extent of the reference is - "The manager shall comply with all prevailing OHS legislative and system requirements" then it is likely senior management are not willing or able to measure their OHS performance and managers may not have a proper handle on the employer's expectations.
   
   I would go further and suggest that Key Performance Indicators (KPIs) be developed for specific positions and that employers keep KPIs updated as the system matures and operational needs change.
   
   
3. Build more prescription into systems and procedures regarding responsibility and accountability
   
   Employers need to clearly define who is responsible for what. It is not uncommon for systems to simply say "Company ABC will do this" or "We will do that" - which of course limits the prospects of anything being done.
   
   After the inevitable incident, your managers will reasonably assert that "I thought it was someone else's job". Bearing in mind that telling someone what to do is actually the easy part of delegation, employers cannot really afford to get this wrong.
   
   Employers should be clear as to who will do what (and when) under the system and who will monitor and review the specified tasks to ensure that it is being done to the employer's expectations.
   
   
4. Invite managers to operate on the assumption that incidents will happen
   
   Managers, on behalf of their employer, must remain aggressive in the identification and control of all foreseeable risks to safety. Employers should highlight the key processes that are designed to identify hazards (inspections, job safety analyses, safety observations, permits to work, hazard reporting, toolbox talks etc) and ensure managers take some real ownership in their implementation and ongoing compliance.
   
   It is not difficult to develop some Positive Performance Indicators and associated reporting to create some transparency and accountability around these processes.
   
   
5. Invite managers to concentrate on the human factors most likely to jeopardise the integrity of the system. Employers owe a duty of care not only to the careful and competent employee, but also the careless and inadvertent
   
   What can managers do given that they cannot directly supervise employees all the time? I believe that the focus must remain on high risk work and significant processes under the system. Reference to statistics, audit findings, surveys or human failings contributing to risk must be identified and corrected.
   
   A hazard example could be the initiative shown by forklift drivers introducing a process that ensures the key to the ignition is removed and secured when the vehicle is parked or unattended.
   
   A process example could be introducing a provision on the checklist for "start/finish" times or "time taken". This will discourage the practice of certain employees not investing the time in accurately completing safety checklists (aka the "tick and flick").
   
   
6. Understand that on a day-to-day basis, managers maintain personal relationships with their subordinates and may have a stronger allegiance to their particular interests - not the employers
   
   Managers really are the "meat in the sandwich". They are forever trying to strike a balance between corporate expectations and the personal needs and interests of the staff. Unfortunately, what seems like a good idea at a corporate level, is not always embraced by the end-users. Even the best trained and intentioned manager will feel under pressure both professionally and personally when refereeing between "us and them".
   
   Managers, who have personal, direct relationships with their subordinates have quite often been in their very situation, can easily "side" with the employees, resulting in documented systems not being complied with or enforced.
   
   Employers need to understand these potential "weaknesses" in their systems before it is uncovered by the Regulator.
   
   
7. Ensure high levels of constructive feedback and encouragement to reports under your system. Recognition and showing a genuine interest in their work, will help motivate continuous improvement
   
   Reporting plays a key role in the due diligence process. The quality of the decisions senior management make is dependent upon the value, relevance and timeliness of the information they receive.
   
   From a manager's perspective, it is also very time consuming to collate, compile and write these reports.
   
   In recognition of these facts, senior management must be prepared to invest the time in not only reading the reports, but also providing constructive feedback and advice on what areas they need concentrated on in subsequent reports.
   
   
8. Make greater allowance in safety audits for site verification (rather than desktop reviews)
   
   Documented safe working systems are becoming increasingly sophisticated and mature. This is particularly the case with larger employers who have acknowledged the need for formalisation and "setting the goal posts" for their staff.
   
   Why nearly all companies are prosecuted, however, is their failure to maintain those systems.
   
   That being the case, additional provision needs to be made in verifying compliance during the audit process. This will better support the efforts of the managers who are often the custodians and enforcers of system requirements at an operational level.
   
   It is our experience that business's typically invest 50% of their time conducting desktop system examinations. I would suggest that this be scaled back (as a general rule) to just 25% so additional time can be invested looking at site activities.
   
   
9. Identify "high leverage" safety opportunities
   
   I have not met a manager that has not complained of being overworked! Safety can easily fall down the list of priorities if care is not taken. Managers need to think strategically about how to maximise their time when promoting safety requirements and benefits to their subordinates.
   
   Examples of when managers can be "easily noticed and felt" by employees may include:
   • Opening and sitting through selected training programs.
   • Accompanying employees on scheduled workplace inspections.
   • Accepting invitations from OHS committees to attend meetings.
   • Participating in incident debriefs.
   • Attending employee recognition events and personal feedback on good performance.
   • Attending project planning sessions at key milestones.
   • Speaking at toolbox talks and soliciting input on policies and procedures the workers are expected to know and comply with.
   • Raising safety issues / concerns at non-safety forums, such as production meetings.
   • Chairing the occasional focus group that has been established to solve complicated or recurring safety issues.
     
     
10. Find out what personally motivates them to take workplace safety seriously
    
    Company executives base many business decisions, including safety decisions, on productivity, cost reduction and risk (insurance / legal). Whilst these are legitimate issues to consider at arriving at the right solution, they are not factors that necessarily operate on the mind of the average employee or lower level manager on a day-to-day basis.
    
    Unfortunately, unless people take safety seriously every day complacency and inattention can creep into the business increasing the risk on an incident.
    
    Unless employers invest time in finding out what personally motivates employees, training, supervision and other types of administrative control need to be increased significantly to compensate. 
    

Conclusion

In an operational sense, supervisors and managers are directly responsible for the maintenance of these systems and need to be supported to address the problem. By strategically investing in managers, employers can expect to leverage greater efficiencies by positively influencing the attitudes and behaviours of employees who can make or break any system an employer chooses to implement.

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