Ed Koch was the amiable mayor of New York City for 12 years. During his tenure, he was known for greeting his constituents on the street and asking them, “How’m I doing?”

Companies should develop a similar habit and openly solicit feedback from employees about whether safety programs are actually keeping them safe.

One mechanism for doing this is a safety audit. In an audit, a qualified person systematically examines a company’s declared safety rules and regulations along with its day-to-day practices and determines if the two are in sync.

For example, if employees are required to wear hard hats in certain areas of a plant or work site but the examiner discovers the hats generally are not worn, the discrepancy between theory and practice is red-flagged. Red flags signal changes need to be made. 

START INSIDE

Safety audits occur in three forms: internal, external and OSHA (sometimes jokingly referred to as eternal). The OSHA audit isn’t necessarily the most important. The earliest identification and elimination of a safety hazard is always the key one. But OSHA is where the buck stops. Failure to be compliant with OSHA’s preventive safety regulations leads to a citation or fine.

OSHA principally enforces regulations by conducting workplace audits or inspections. The inspectors look for violations of safe practices or the absence of safety equipment. The inspections can be conducted without giving a company prior notice, which seems furtive but keeps less ethical company leaders from playing games with employee safety.

Ethical leadership, on the other hand, is not into games. “I like to tell people that a safety management plan should be part of your overall company management system. If management is committed to doing the right thing, employees are going to do things the right way. It becomes a common culture,” says Kyle Irwin, founder of Irwin’s Safety. The Calgary, Alberta, firm teaches safety to company executives in western Canada and occasionally in the U.S.

While “doing the right thing” works the same on either side of the border, Irwin says the consequences of ignoring workplace safety often are more severe in the states. “We’re more regulated in Canada. We have more government agencies looking into it. The day-to-day standards are higher. However, the risk of litigation is much higher in the U.S. If you are a company in the U.S. and make some bad decision in respect to safety, you’re more likely to be litigated by the people affected by that decision.”

Neither of these two scenarios — more rigorous day-to-day regulation or greater legal risk — is welcomed by company owners. The happy alternative is for a company to self-regulate at a responsible level and thereby create a culture of safety as a first line of defense against unsafe behavior and work conditions. Internal audits are the way to develop that culture.

Usually conducted by a company’s safety manager, ongoing internal audits sometimes are informal, undertaken on the spur of the moment while passing through a workplace or visiting a job site. Or they are formal, with an inspection occurring on a day purposely set aside for it with a checklist as the inspection tool.

The list can be as long and detailed as your company wishes. Small companies that are just developing a health and safety program sometimes get by with a one-page checklist with a comments section at the bottom. The completed listing is filed for follow-up and future reference.

More rigorous internal inspections are longer and more nuanced. An informal short-form inspection might ask, “Is there a standby employee positioned outside the confined space to provide emergency assistance?” Whereas a more thorough inspection checklist might ask an additional question: “Is the standby employee trained and equipped to render assistance in case of an emergency?”

These internal audits sometimes catch dangerous situations and correct them. However, the hope is that they will discover few serious defects in safety and instead find areas where reasonably safe behavior can be made safer. The frequency of the internal audits and the fact that they are being conducted without coercion from outside entities makes them nonthreatening to a company and its employees. Therefore, they are less likely to cover up something unsafe.

EFFECTIVE MANAGEMENT

Irwin notes that the attitude of the person doing an audit goes a long way in determining how effective it will be. “I really think the No. 1 requirement for being an effective safety manager is to know your workplace and understand the different roles in the company and the hazards of each role.”

He gives the example of an engineer leaving his office two or three times a year to walk around a work site. “You wouldn’t go up to him during his walk-around and talk to him about the need to wear a hard hat.” Such a “gotcha” move would be officious. Rather, a safety manager should prioritize his time to deal with bigger workplace hazards.

Irwin recommends that safety leaders engage with employees rather than confront them. To effectively communicate the need for safety, a safety manager must first have a relationship. Failure to connect with people means the chance of influencing them is slim, he says.

“The attitude of the safety manager should not be ‘I am here and I’m going to change things.’ It should be ‘I am here and we’re going to learn things together.’ It’s the difference between being a safety cop and a safety advisor. If you’re a cop, you ask, ‘Where is your hat?’ An advisor asks, ‘Is there a reason you’re not wearing your hat?’ The attitude should be that the advisor is learning from the employees.”

Seasoned employees might be expected to be most responsive to safety counsel, having been around long enough to witness the consequences of unsafe behavior. Unfortunately, longtime employees can be the least coachable. “With a lot of people in the older generation, when you say, ‘Hey, we need to do this and this,’ they become defensive. They feel like you’re suggesting they weren’t doing something right.”

Once again, Irwin counsels engaging with the old hands so they understand their experience is respected. “You might say, ‘We know what you’re doing is working really well and you’re not injuring yourself. But someone newer on the job might not be as capable and could get hurt. We’d like to try a more systematic approach to doing this.’”

A safety manager needs to be something of a diplomat, in other words. However, diplomacy won’t always work. Irwin laughs about the time he confronted a longtime employee of a company working a railway project. “He was in a machine, and I walked up and said, ‘You need to wear that safety belt because some government inspector is going to come along and see you not wearing it and throw you off the work site.’ He looked at me, said, ‘Back off!’ and closed the door.”

You can’t win them all, even when you’re president of a safety management company. The larger lesson, though, is that rules apply to everyone. Irwin adds that the most frequent violators of company workplace safety rules are not hidebound employees, but younger generation workers who seem disinclined to follow safety regimens created for their own good.

INSURANCE TEAMWORK

Insurance companies can play a role in auditing a company’s safety. At Koberlein Environmental in northeast Pennsylvania, insurance agents have become real partners in policing and encouraging safety. Company owner Chris Ravenscroft says a Penn National Insurance representative, Jerry Kozich, is particularly involved.

Kozich attends half the company’s safety meetings. He also periodically performs impromptu external audits of work sites. “I get a call several times a year from Jerry who says he’s in the area and would like to see a job. That’s been very helpful. Some jobs he visits are being perfectly managed. Other jobs we need to do something a little different, things he’s identified. We get on top of it immediately.”

This working relationship between insurer and insured has persisted for 15 years. Ravenscroft believes it to be a valuable add-on feature of his insurance policy. “I’ve asked him if this kind of relationship is commonplace, and he says it isn’t, mostly because businesses are uncomfortable working with an insurance company at that level. Some insurance companies simply don’t offer the service. We feel it really adds value.”

Ravenscroft is his own safety manager, though he obviously has other responsibilities. He also has various team managers who spontaneously walk around jobs, looking for safety issues. That commitment from the top down establishes a strong safety culture.

SAFETY PAYS

Safety is its own reward, but other benefits flow to companies that do safety audits. Irwin notes that, in Canada, annual internal audits are required to document compliance and an external audit is conducted every two years by a certifying agency. It leads to public certification as a safe place to work, which tends to attract employees and business partners. The financial reward for certification is shaving of insurance premiums, typically by 10% to 20%.

Ravenscroft says a couple other benefits accrue to his wastewater management services company besides a lower insurance premium. One is a discounted rate on workers’ compensation when the Pennsylvania Department of Labor certifies the company’s safety committee. And because Koberlein has a documented lower-than-standard rate of lost-time injuries per hours worked, business partners are pleased.

“Some of our larger clients — energy companies and utility customers — feel good about working with a company that’s exceeding the safety standard. This is another way we receive the benefits of having a safe company.”