Safety Management System Compliance: Understanding ISO 45001

On a recent ProcessMAP EHS Leadership Roundtable, we had the pleasure of hearing from Laurie Stewart, Director, Environment Health and Safety for CIRCOR International, a global manufacturer of large pieces of machinery used in large ships, including cruise liners and nuclear submarines. CIRCOR also makes valves used in oil refineries, medical centrifuges, and one of their pumps is used by a scotch distillery located in Scotland. This diverse business has operations around the world, with operations in the United States, Germany, France, Morocco, the United Kingdom, India, and China.

One of the challenges the safety team has faced in the past year has been increasing engagement with its employees regarding Proactive Safety Observations, which are leading indicators for risk and hazard awareness. Proactive Observations are intended to encourage employees on the plant floor, who are there at that moment, to identify and address safety issues. Proactive Observations are an essential component of any safety program that aims to track leading indicators. Proactive Observations help safety professionals to track goals, identify areas for improvement, and most importantly, hold management accountable. A Proactive Observation is an essential component of a safety program because it can help to identify issues that have been previously raised and determine why the issue has not yet been addressed.

In 2020, the CIRCOR safety team saw proactive observation rates decrease in 2020. The team attributes several reasons why COVID-19 was responsible for the decrease in proactive observations. First, there were fewer employees working on site, as more office-based employees were working remotely. Second, and even more importantly, the safety ream realized employees were suffering from what they called “Pandemic Fatigue.” Essential workers were coming to work at the CIRCOR plants every day, but they were managing additional stress due to social distancing requirements, the need for wearing masks and proper PPE, and other concerns. Employees were never able to get away from the stress that COVID-19 instilled in essential workers. The safety team recognized that employees were not documenting Proactive Observations because at the end of the day, it was just one more task that needed to get done. The data clearly showed that Proactive Observations were documented far less frequently than the safety team had hoped.

The safety team also observed that the physical number of recordable injuries decreased, but because there was also a decrease in the number of hours worked, the Total Recordable Injury Rate (TRIR) increased. The team recognized that as the number of proactive observations decreased, the TRIR increased, giving them cause for concern. Fearing that complacency could result in an increase in injuries, the team understood it was time to find a way to encourage employees to take a more active role in proactive observations.

Proactive Safety Observations

To create employee engagement, the safety team knew they needed to look at things a little bit differently. With the COVID-19 pandemic mandating social distancing in their facilities, some of the tried-and-true methods for engaging employees, such as a pizza party, would not be considered. So the team had to think more creatively and ask themselves how they could utilize the tools at their disposal and encourage employees to take a more active role in proactive observations.

In the United States, college sports fans have come to appreciate the annual men’s college basketball tournament known as “March Madness.” Over the span of four weeks, more than 60 teams compete in basketball games to determine the national champion. The safety team decided that rather than have individual competitions, they would find a way to create a competition that would pit facilities against each other for a four-week competition, awarding prizes to sites that advanced each week. CIRCOR awarded prizes to the teams that advanced each week.

CIRCOR March Madness Bracket

CIRCOR employees turned out to be highly competitive when it came to winning a competition for documenting proactive observations. In the span of four weeks, the number of observations recorded was more than double the number of proactive observations measured in the previous 14 months.

To fairly assess the success of the contest, the safety team measured the number of proactive observations reported per employee. The winning locations are in Cologne, Germany, Daman, India, and Sandy, Utah. The safety team calculated that the Daman, India team has 177 employees on-site and they recorded an average of 10.59 proactive observations per employee during the last week of the competition.

CIRCOR employees in Daman, India

The safety team learned several lessons staging this contest. First, while employees were excited to be competing against one another, the safety realized that it was important to recognize quality observations over quantity. They also understood that a language barrier prevented some reporting of proactive observations from happening, so they plan to work on translating the competition into local languages where the plants are located, to be able to increase engagement at the plant level.

Another takeaway from the competition is that people identified issues that they understood. So, from that point of view, it is important that the team look at what are the risks that employees can see, and how to expand upon what employees already know. For example, the safety team expected that they would receive lots of observations pertaining to housekeeping, particularly in the middle of a global pandemic. However, the most prevalent observations fell into categories like electrical safety and lockout/tag-out, and the actual issues were more of a misunderstanding of what the next steps should be.

The safety team learned valuable lessons from staging this first competition. To encourage more people to look at the Proactive Observations app, the team realized that it would be important to translate the reporting within the app to employees’ native languages. The majority of the reporting in the app is in a drop-down list format, which lends itself to translation much easier and more quickly. The language change will help increase the ability for employees to actually enter information into the Safety Observations app.

The safety team also recognized the importance of mobile access to entering these proactive observations from the plant floor. With the use of tablets on the plant floor, employees can enter the data, take a photo and upload it to the app, and identify both what the issue is, and how to go about fixing it.

The contest drew the attention of senior leadership team members and gave a great deal of visibility to the participating locations during the competition. Plans are already underway to conduct and expand the competition in the coming year. As the safety team gathers more proactive observations, they will be able to use the corresponding reports to track and report company-wide compliance metrics and closure rates. This information will allow Laurie and her team to establish true KPIs (Key Performance Indicators). 

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