Write, Follow and Audit Your Procedures

Provincial, state and federal safety regulations all have some form of general duty clause that identifies the employer as responsible for maintaining a safe work place. When an injury occurs, the employer is automatically guilty of violating this clause. In addition, there are "specific duty clauses"; for instance, if a worker is injured in an arc flash accident, and the jurisdiction has a regulation stating "protect workers from arc flash", then this clause has also been violated. Health and safety infractions also usually violate clauses 219.1 and 217.1 of the Canadian Criminal Code.

To satisfy the requirements of these regulations organizations have a variety of administrative tools that they adopt as barriers to accidents.

These include policies, standards, programs, procedures, practices, hazard assessments, forms and other control documents. A procedure is a clear list of steps to perform a task that, when followed, will enable the worker to accomplish the task in a safe and efficient manner.

If it is a task that has been performed for some time it is merely a capturing of the steps that were already being performed. If there have been different ways to accomplish the task, then it is a choice of which steps to adopt as the standard for that procedure. It does not mean a different set of steps is always unsafe but when you follow the steps that have been prescribed, you will definitely be safe.

If a worker decides to follow an alternate set of steps and a serious injury occurs then they could be in an indefensible situation. If the supervisor knew this was happening then they and the organization are in an indefensible situation. The way you win a court case is to never go to court; you must make sure that your actions are bullet proof and legally defensible in all situations. I regularly see organizations with dozens or hundreds of procedures that are never referred to and haven't been reviewed perhaps for years. This is a poor situation for everyone and misses a great opportunity to improve safety, quality, productivity and cost control, at the same time improving team building and morale.

For experienced workers, reviewing a procedure prior to a task they do regularly is usually unnecessary because they have mastered the task. Most maintenance workers receive a work order without the procedure. It is highly unlikely they will print the procedure if they are confident they know the task or feel rushed. Two problems are created if this worker has a helper; the helper learns an unaccredited set of steps and worse, they learn they can deviate from procedures.

Fatal accident investigators will always check to see if you had a procedure in place, if the procedure you authorized was being followed, if your workers were trained in the procedure, if they demonstrated proficiency, if the training was being refreshed regularly and if a progressive discipline system was employed for anyone not following the procedure.

We advise our clients to have their teams review a portion of a procedure at every regular safety meeting. Take ten minutes in a daily meeting (they do not need to complete the entire procedure; one page can be enough as it is the process that is critical); twenty minutes if it is a weekly meeting and thirty or more in a monthly meeting.

For the implementation of this we recommend transferring ownership to the work team by enlisting the newest person on the team to take the initiative of starting with the first step of the first procedure. They are usually quite willing to step up and show themselves as enthusiastic. With the new person leading, their team mates are more than willing to jump in and provide feedback and advice. For subsequent meetings, delegate the process to the next most junior person so that each person carries the ball one day and then hands it off. Soon you will be through your team and you start the cycle over again. When you finally get through all of your procedures; start over again.

With this process a team can review several hundred pages of procedures in a year. You will be fulfilling your legislated responsibilities with due diligence and your teams will become experts in reviewing, and eventually writing, procedures.

The larger outcome to occur from this regular review, besides the auditing of your procedures, it is that there is a safety discussion actively involved and focused on an issue every day. Many good things will come out of it.

Until next time, be ready, be careful and be safe.