Many safety professionals refer to their activities as a safety "program." I submit that these activities are not a program but a "system." More precisely, they are-or should be-a systematic amalgamation of programs. What's the difference between a program and a system? And what's the big deal about how we label things? Allow me to answer.

Safety Program Or Safety System?

What's in a name? Plenty, especially when you look at all the jargon that safety people have been fond of using over the years to demonstrate to others how much we (safety practitioners) know about safety and how much they (rank and file/management) don't.

All cynicism aside, the language that we use in our day-to-day dealings to describe what we do has a major impact on the success of our efforts. What we say and how we say it when speaking and writing very often mean the difference between understanding and confusion.

With this in mind, I'd like to point out that many still refer to their safety system as a "safety program." The safety program is actually a component piece of the larger system.

Defining the OHS System

What exactly is an OHS system? Let's first look at the general characteristics of any kind of system.

A system is defined by identifying all interrelated processes, and their associated interdependencies.
A system is managed as a series of interrelated processes.
A system is improved by continuous measurement and evaluation of all related processes.

As noted, in the context of safety, the system is made up of health and safety programs. OHS systems and their component programs can be expanded, contracted and altered as priorities change. So to define your own OHS system, you need to identify its component elements. Of course, systems vary depending on industry, related risks and regulatory environment. But many of the component program elements are common ones. Common programs include risk management, safety meetings and accident/incident investigation and reporting.

Once you identify the component programs of your system, you need to assign them appropriate system headings. For example, under the corporate heading of the XYZ Company's OH&S Management System, you can identify a Leadership and Administration section, an Investigation and Analysis section, a Compliance section, an Emergency Response section, etc.

An extremely useful practical exercise is to draw a plot or graph of the various program elements of your own OHS system. In addition to forcing you to grasp the big picture - literally - making a visual depiction of your OHS system will produce a great tool that you can use to explain to management exactly how the pieces of your system fit together.

Conclusion

I'll continue this series next week by introducing to the discussion an explanation of the management system and how it applies to the OHS system.

Systems approaches have been used for years in manufacturing processes. But only recently has the idea of management systems been applied to the field of occupational safety. Let's discuss the dynamics of the safety management system and its role in preventing liability for occupational health and safety violations.

A Safety Management System Model

If we were to apply a typical "closed loop" management system model to occupational health and safety, we could use the typical Plan, Organize, Direct and Control scenario found in so many management textbooks. To render the model, you simply draw a circle and place each of the management functions at each quarter of the outside of the circle.

The piece which would make this system complete from a safety management perspective is the prevention function. Place the prevention function in the middle of your circle and draw a broken line from the prevention function to each of the management functions.

The addition of a prevention function to a management system stabilizes the system and keeps it from being simply reactive. The prevention aspect facilitates root cause analysis and makes it an integral part of the problem solving and investigation process. This helps ensure that more than simply work behaviors get addressed as part of the problem solving model.

The Systems Approach & Due Diligence

Integrating a prevention aspect into your management system model also provides a sound means of developing your standards for due diligence, which will help you demonstrate compliance with regulatory requirements.

This is important because if you're ever charged with a serious OHS offense, you will be forced to prove due diligence, i.e., demonstrate that you took all steps reasonable under the circumstances to comply with legal requirements and prevent the violation. Courts in Canada have interpreted reasonable steps as including the implementation of necessary systems to prevent accidents, injuries and illnesses.

(Editor's Note: Although due diligence is a concept of Canadian OHS law, similar principles apply under U.S. OSHA rules. For example, demonstrating that you took reasonable steps to comply can help avoid liability or knock down an OSHA citation from willful to serious or other-than-serious.)

As with any approach to due diligence, you can follow two approaches:

You can do some "stuff" in safety, run some "safety programs" in the hope that they will address risks and hazards and hope that your efforts are meeting the mark; or
You can strategically plan how your OH&S system is to be structured, how it will roll out, how the pieces will fit together, and how all the pieces, taken together, will work synergistically to enhance and heighten your prevention efforts.

Conclusion

Next week, I'll finish the series by describing how to audit your safety management system.

Having a clearly defined, graphically represented safety management system offers a number of distinct benefits. One of these benefits becomes clear during the safety audit process. Let's discuss the auditing of the system.

Beware of Generic Auditing Methods

Using generic safety audits to monitor your system poses a problem. You need to ensure that whichever safety audit methodology you choose measures the effectiveness of your own safety system. It should reflect your own business patterns and risks. So if you manufacture chemicals, using an audit method tailored to measure the system deployed by an auto manufacturing plant, pulp and paper mill or fish plant will give you a less than an accurate picture of your safety system's strengths and weaknesses.

The reason is simple: One-size-fits-all management system audit fit no one. They tend to be so generic as the issues sometimes have little or no value to add to the organization. The more specific the audit methodology and protocol to your management system, the better your audit findings and opportunities for improvement can stand the test of the SMART acronym (SPECIFIC, MEASURABLE, ACTION-ORIENTED, REALISTIC AND TIME SENSITIVE). If objectives from your audit findings don't end up meeting the SMART acronym, you run the risk of having both nebulous and meaningless management system action.

The benefit in clearly defining your safety management system is that you can use the same pattern or 'template' to model your safety audit. One should compliment, and ideally enhance, the other. Safety system development need not be a complicated process. While the size of your system can be complex and comprehensive, depending on the size of your business or risks associated with its undertaking, it's simply a matter of defining:

The work to be done;
How the work is to be done;
Who's going to do it; and
How it's going to be managed.

Conclusion

To repeat the advice from Part 1 of this series, it's a good idea to create a graphic representation of your OH&S management system. Draw a diagram displaying the component parts of your system on a piece of paper. Then use the drawing to explain your system to senior management. After all, when it comes to winning backing and financial management for your program and goals, a picture is worth 1,000 words.