Better results for voluntary compliance instead of enforcement

Many times we do things because we were told to do so. Else, there may be repercussions in the form of penalties or punishment. When we work in such an environment, at the slightest opportunity, we try to avoid, which otherwise the enforcing agency (parents/boss/regulator/police/court/etc) wants us to do. This way things will not yield good results in the long term because it is not coming from our heart. This is because either we did not understand why somebody is asking us to do in particular manner or we had wrong perceptions. If somebody asked us to do in a particular fashion, let us try to understand why? It is the experience of somebody, somewhere. We need not learn again by doing things in a wrong manner and get affected whatever the loss others suffered. This is called learning from history. Rules and regulations are nothing but experiences (bad and good) of so many over a long period.
When we make voluntary efforts without others saying so, we can see positive developments in our work atmosphere. Because we fail to do so, rules and regulations have come and this is the first stage in the line of growth. When we comply with all statutory requirements, we can set our own goals much better than statutes and improve further. This is the second stage. When we repeat this towards better workplace, we can become role model in our industry / region. This is the third stage. These three stages are discussed in detail in INSAG-15 document (International Nuclear Safety Advisory Group).
Many of us are in the first stage for so many decades. Though we obtain certifications for compliance with ISO/OHSAS/IS/BS/FDA, etc, still at heart, we like to bypass procedures and this does not augur well for us as individuals and the organization, as a whole. We think government organizations does not have any dearth of funds and thus they can implement this philosophy. Similarly, we think private organizations are profit oriented and thus do not like to spend. But both are wrong perceptions. There good and bad organizations both in government and private sectors.
It is 'I' who matters in implementation. This I is everybody from top to bottom. The top management should know about rules and regulations and a vision to ensure safety at the work place. And they should convey their intentions to down below and allocate required resources with rewards and punishments to ensure safety.
As long as I am not convinced, I try to do things other way and continue to suffer myself and as a consequence, I put the organization also in a fix not to grow. It is said that safety is not costly, but in fact it is free when implemented in full. It also fetches returns over a long period of time. Just we do not have enough patience to wait for and want to see the results immediately which is not possible. One year when we work with good production, no accidents, better profits, we claim that our work only fetched results and next year when it does not repeat, we blame all sundry instead of taking responsibility for the same. One should realize that our today's results are hard work of somebody in the past.

There are no exceptions. Follow the Rules, even if it is an emergency

In an incident, a coworker was assisting a crane operator in lifting the injured, by standing on a steel structure without a safety belt or any other protective gear. The employer was charged by OSHA for the violation.
This is an emergency case. But, many times, showing some reason or the other as emergency or important, people wilfully disobey the rules trading for short term gains. Even the experienced and senior colleagues preach such practices citing the urgent requirement. Funnily, the activities which were not attended for weeks will become suddenly urgent on the day they propose to take up and do not follow any safety procedure because they do not have time at that moment.
The example in the link below will serve as an eye opener to those who take chance by not following safety.
Lessons from a California Case

LINK

Number of safety officers in a hazardous plant - statutory and practical requirements

Safety officers in any hazardous installation are appointed as specified in statutes, which say that factories where 1000 or more persons are employed, safety officer should be appointed. When the employee strength exceeds 2000, for every additional 1000 employees, one safety officer should be employed with 500 or more employees rounded to 1000. For major hazard installations, factory inspector can specify the number of safety officers irrespective of employee strength. Accordingly, the number of safety officers for various employee strength will be as follows:

Employee Strength        No. of safety officers

Upto 1499                             1
1500-2499                            2
2500-3499                            3
3500-4499                            4
5499-6499                            6
8499-9499                            9 and so on.

In some states, rules are framed as one safety officer for every 3000 employees is to be engaged.
As per Maharashtra Safety Officers Rules, 1982; the no. of safety officers required is,
1000-2000    1
2001-5000    2
5001-10000  3
>10000         4

But, in reality safety professionals find it difficult to manage safety aspects with so many employees in a factory, particularly where the operations are varied and complex, and with a large number of departments. The duties of safety officers include carrying out / conducting,

• inspections if not every day but atleast once in a week
• issue of safe work permits
• permission for modifications, changes, erection/commissioning of new equipment/process, etc
• job hazard analysis
• safety meetings in every department
• apex safety committee meetings
• safety audits
• accident/incident investigation
• training
• safety awareness programmes
• safety seminars
• followup with departments for compliance with recommendations of various committees
• safety studies like HAZOP, ETA, FTA, HIRA, etc
• coordination with regulatory agencies
• preparation and filing reports as per statutory requirement
• updating and maintaining records
• PPE procurement
• office safety (of various departments)
• contractor safety
• and so on

In some factories, safety officer will be asked to manage fire safety and environment mangement also which will increase administrative work load.

The work load increases depending upon the number of departments / sections, safety officer has to deal with. For example, if the number of employees in a factory having 4-5 departments is 4000, the work load for 4 safety officers appointed as per statutory requirement will be somewhat less compared to the work when the number of department is, say 30-40 as the complexity will increase both in technical and administration. The problem multiplies for the safety officers when his colleague in the safety department proceeds on leave as they have to look after safety aspects temporarily during the leave period.

Technical difficulties are in the form of wide variety of operations and administration difficulties are in the form of dealing with a number of shop floor/section/department heads. As the number of employees and departments increase, the levels of officers will increase and accordingly safety officers have to deal from lower to top level in orderly fashion and this increases work load enormously. Shop floor person can say he is doing as per his next level supervisor instructions and if safety officer directly talks to top and next level person, he can say he is not aware or instruct the safety officer to talk to lower level in-charges.

Added to the above, is contractor workers and their safety. Normally, contractor workers are engaged for doing various petty jobs and sometimes for regular plant operations and civil works. The real difficulty is that they will be working at different places on same day or at different periods and therefore job hazard analysis for their jobs and ensuring their safety is a tough task.

Though there are safety coordinators in some factories who do production and safety coordination with the safety department, in practice these safety coordinators give importance to production activities and thus safety at workplace rests with the safety department.

Though, Factories Act and its Rules say the duty of safety officer is to advice and assist, in reality, safety officer ends up in doing the jobs and in some factories, he will be asked to eliminate the hazards also by engaging few contractor workers, i.e., he has to identify and eliminate. After sometime, this may lead to not doing the jobs even as per Factories Rules and cause a dangerous work place for employees.

In view of the above, I feel that the legislations regarding number of safety officers should be reviewed and revised taking into account of number of employees and number of departments as below:

• One safety officer for every 500 employees upto 2000 employees or every 5 departments and thereafter
• one safety officer for every 250 employees

With the above, the no. of safety officers can be as follows

Upto 500         1       2501-2750       7        4001-4250        13
501-1000        2       2751-3000       8        4251-4500        14
1001-1500      3       3001-3250       9        4501-4750        15
1501-2000      4       3251-3500      10       4751-5000        16 and so on.
2001-2250      5       3501-3750      11
2251-2500      6       3751-4000      12

The employee strength should be taken as maximum number (including contractor workers, casual workers, etc) supposed to work at any given time. To ensure safety, atleast one safety officer should be available in shifts other than general shift, including Sundays and holidays.

With the above, I feel that safety department can function effectively to ensure a safe work place.