Beyond Compliance: Part 2

In my last post, I left off with why it's the right thing to do using the only retort I have available - "says me..."

And here is why I says that.  Lets look at two scenarios where "beyond compliance" makes perfect sense.

The first one involves a situation in which an employee is tasked to climb a very tall radio tower to replace the beacon bulb at the top.  As the guy put in charge of employee safety, I am tasked with making sure two things happen.

1. All employees are not injured or killed
2. OSHA compliance is met

So I show up at the tower and I tell the employee "you must climb using 100% fall protection."

The employee says "Don't have to, I'm a  qualified climber and OSHA does not require fall protection when I am climbing."

Because I'm a "beyond compliance" kind of guy, I say - "I don't care what OSHA says, you use 100% fall protection or you don't climb."

It is at this point where one of two paths present themselves.  Path one is a company that understands the benefits of a "beyond compliance" philosophy as the maximum standard, and Path two is a company that accepts a regulatory requirement philosophy as the maximum standard.

As the safety guy, I am now stuck in a position of - will my company's management support my "because I say so" line in the sand?

Scenario two is a little less black and white.  When a training requirement does not mandate a set number of hours, who gets to decide on how much time is needed to meet the requirements of the standard?  In other words, who decides on what is an adequate amount of time?  Who decides the degree of quality necessary to be put into the class and the training?  Adequate and Quality are such subjective terms and convey different things to different people. 

As a trainer, I say it is up to me to decide how much time is necessary to convey the knowledge and information needed for a particular task to be performed.  If I am going to train employees on how to protect themselves in an IDLH situation or to enter a confined space, it will be taught for the number of hours needed for me to feel comfortable having them perform the task.

So how is this comfortableness decided?  For me, and I am not alone in this methodology, it comes down to answering two questions:

1. Is the length of time for the objectives needing to be met similar to what other competent training providers are offering (what is the industry standard)?
2. Can I sit in front of a Jury and defend myself, my company, and my profession regarding the class that I taught?

Number two is the most important factor here for me.  Because when it is all said and done, it always comes back to training, which means it falls back on the person who stood in front of the individual who was harmed, killed, or messed up.  It is all subjective when it comes to how well the training met the objectives.  And if I am going to have to defend myself, then it needs to meet my definition of adequate.

So what happens when the client says, I can only spare my guys for eight hours and not the 24 you want?  Or  someone in your own management questions why you are putting employees through a 24 hour class when she saw on the Internet the same class provided in only five hours?

The question both will ask is "what does OSHA require?", and you will have to answer "there isn't a set time" which is then followed by "why does it have to be 24 then?"

Because I say so...because it is me that is tasked with answering the question "is it safe", "is it adequate", "will it stand up in court".  Being only OSHA compliant has nothing to do with answering those three questions.

So if you do not accept a beyond compliance philosophy - if all you will accept is regulatory compliance only - at least have the courtesy of telling your EHS guy that before you hire him or her.

If the employee screws up because of inadequate training or the "qualified climber" falls, it doesn't make us feel better because we can now say "I told you so."  And if you change your tune after we are employed - buy us out so we will not have to put our well being (employment) over the ones we have been charged to look out after.  The fact that I kept the company in compliance does not make up for the indignity of knowing it could have been prevented and I was not provided the support needed to do so.

Bottom line: Choose one.  Regulatory compliance or beyond compliance.

Next post:  How the EHS Manger looks at achieving balance in a zero risk world controlled by a bottom line mentality.  The economy of safety.


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