Petersen, Dan

Petersen, Dan

Address: 1909 E. La Vieve Lane, Tempe, AZ 85284

Country: United States

Phone: 1 (602) 838-8908

Fax: 1 (602) 831-8155

Past position(s): Professor, Arizona State University; Assistant Vice-President, Industrial Indemnity; Director, Loss Control, All State Insurance, Nationwide Insurance; Director of Training, Employees Insurance

Education: BS, 1952, Iowa State University; MS, 1972, University of Nebraska; EPD, 1980, Colorado University

Areas of interest: Safety management

Monday, 04 April 2011 20:32

Safety Services: Consultants

Occasionally, those responsible for safety in an organization—whether they be concerned with the behavioural system, the safety system or the physical environment—call upon external resources such as professional safety consultants for help. When this occurs, it is important to bear in mind that the responsibility for the successful completion of the task (as distinguished from the performance of the task itself) of analysing a given system and making improvements to it cannot be delegated to outside agencies. Internal analysts (as opposed to external consultants) studying a system can usually obtain more reliable data because of their close familiarity with the organization. Nevertheless, the help of an outside consultant who has a wide range of experience with analysing safety problems and suggesting appropriate remedies, can be invaluable.

Seeking Outside Help

If there is no one in an organization who is familiar with safety laws and standards on the national level, it might be helpful to call in a safety regulations expert for assistance. Often there is no one in the organizational structure who may be able to analyse the behavioural system, and in such an eventuality it would be advisable to obtain help from someone who can do so. Kenneth Albert (1978) suggests that there are six specific occasions when outside help should be obtained:

    • when special expertise is essential
    • for a politically sensitive issue
    • when impartiality is necessary
    • if time is critical and the internal resources are not immediately available
    • if anonymity must be maintained
    • when the prestige of an outsider would be helpful.

               

              Although Albert’s remarks were not made in connection with safety, the above points seem valid in determining the need for an outside safety consultant. Often a safety problem is intertwined with managerial personalities and is extremely difficult to solve internally. In such a situation a solution may be acceptable to all parties involved just because it came from an outsider. If an organization needs an analysis in a hurry it often can be done faster by an outside consultant, and often the outsider’s recommendation will carry more weight than the insider’s. In the field of safety, it appears that outside help is needed by many organizations with behavioural system analysis, some with safety system analysis and a few with physical condition analysis. However, with regard to the availability of safety consultants, supply and demand are inversely related, as there seems to be an ample supply of physical condition consultants, whereas there are fewer safety system analysts, and safety behavioural analysis experts are almost non-existent.

              Safety Consultants

              While the types of external safety consultant help will vary by country, they might generally be classified into these categories:

                • insurance company field safety engineers or consultants
                • government safety consultants (national, state, provincial and local)
                • private consulting firms and full-time professional safety consultants
                • part-time private consultants
                • safety council or safety association consultants
                • industry association consultants.

                           

                          Insurance consultants. Most of the safety consultants and safety engineers in the United States who do not work for government or industry are employed by insurance firms. Many other safety professionals started their careers working for insurance companies. Almost all companies, except the very large and self-insured, are helped routinely by insurance loss-control representatives.

                          Government consultants. The providers of government consulting services vary from country to country and as to their affiliation (national, state, provincial or local) and the sorts of tasks they are permitted and qualified to perform. In the United States, the stated goal of the onsite consultation programme offered by the Occupational Safety and Health Administration (OSHA) is to obtain “safe and healthful workplaces for employees”. Thus by stipulation, the consultations will pertain only to physical conditions. An organization seeking this kind of help should consider OSHA’s offering. If, however, consulting help is needed with the safety system or the behavioural system, OSHA is the wrong place to go.

                          The defined onsite responsibilities of OSHA consultants are as follows:

                            • to identify and properly classify hazards
                            • to recommend corrective measures (short of engineering assistance)
                            • to arrange abatement dates for serious hazards
                            • to report to their supervisors any serious hazards which the employer has not acted upon
                            • to follow up on employer actions.

                                     

                                    It is obvious that there are some aspects of receiving OSHA consulting service by this route that are unusual. The purpose of the consultants is to help improve physical conditions, but in two instances the consultants have additional duties:

                                      • In the case of serious violations of OSHA standards, they must set abatement dates and follow up on them.
                                      • In the case of imminent violations of the OSHA standards, they must refer them to either their supervisors (and thence to the Department of Labor hierarchy) or to the organization’s compliance staff for their immediate action.

                                         

                                        In other words, OSHA consulting is true consulting only when nothing seriously wrong is found. If anything serious or imminently hazardous is found, the “customer” loses control of the decision process as to how and when to correct it.

                                        Private consulting firms. A third source of external help is the (full-time) private consultant or the private consulting firms, who can provide help in any area—behavioural systems, safety systems or physical conditions—with none of the special limitations mentioned above. The only difficulty is ensuring that a consultant has been selected who has the necessary skills and knowledge to provide the desired work product.

                                        Part-time private consultation and others. The fourth place to locate a private consultant is among those individuals who consult on a part-time basis to supplement their incomes. These consultants are either retired safety professionals who remain active, or college or university professors who supplement their income and stay knowledgeable about the world outside the academy. Here again the problem is to locate these people and ensure that the person hired has the competencies needed. Additional sources include consultants who make themselves available through national or local safety councils, and consultants with trade associations.

                                        Locating a Consultant

                                        In the first two categories of external help listed above, government and insurance, finding a consultant is easy. For example, in the United States, one can contact the appropriate workers’ compensation insurance carrier or the local OSHA grant office and ask them to visit the organization. Many other countries provide similar governmental and insurance resources.

                                        Finding a consultant in the second two categories, private individual consultants and consulting firms, is more difficult. In the United States, for instance, several organizations publish directories of consultants. As an example, the American Society of Safety Engineers (ASSE) publishes a national directory, which includes some 260 names of consultants. However, there seem to be considerable problems using this directory. An analysis of the 260 people on the list shows that 56% are individuals who indicate that they are for hire but who have not stated whether they work for companies and seek additional income or are full-time consultants or part-time retired safety consultants. An additional 32% were identified as being connected with consulting firms, 5% were connected with universities, 3% were insurance brokers, 3% were connected with manufacturing companies and 1% were associated with state governments. Actually, this directory, while advertised as a document which tells the reader “where the occupational safety/health experts are”, is really a roster of those people who have paid their dues and are members of the consultants division of the ASSE.

                                        There is no easy way to find a consultant who has the expertise needed. Probably the best approaches other than insurance or government are to (1) network with other organizations with similar problems to see who they have used and whether they were satisfied with the results, (2) contact a professional organization at the national level, or (3) make use of professional directories such as the one above, keeping in mind the qualifications made concerning it.

                                        Insurance Consulting

                                        The most readily available of the outside consultants are insurance consultants. Since the beginning of the industrial safety movement, the insurance industry has been involved with safety. For many years. the only possible external help for most companies had been that available from the company’s insurance carrier. While this is no longer true, the insurance consultant is most often sought out.

                                        The safety services departments of typical large insurance companies are charged with three specific functions:

                                          • a sales assistance function
                                          • an underwriting assistance function
                                          • a customer service function.

                                           

                                          Only the third of these is of value to the customer needing safety assistance. The underwriting assistance function is carried out by a field representative who is the “eyes and ears” of the insurance company, observing what is going on at the policyholder’s place of business and reporting back to the desk-bound underwriter. The third function consists of assisting customers to improve their loss prevention and safety programmes and reducing the likelihood of those customers having accidents and suffering financial loss. The assistance offered varies considerably from company to company.

                                          Over the years, different philosophies have emerged which dictate the value of the service that the insurance company is able to provide. In some companies the safety services department is still very much a part of the underwriting function and their duties are to observe and report, while in others, the engineering department reports to the underwriting department. In some insurance companies, the loss-control department is independent, existing primarily to serve the customer and only secondarily to assist the sales and underwriting functions. When the primary mission of the service is to assist sales, customer service will suffer. If the loss-control department is part of underwriting, it may be difficult to get safety service from them, as they simply may not be staffed with trained, qualified people to provide that sort of service. If the loss-control department is not part of underwriting, then it may be able to provide good service to a customer. Conversely, it may also be quite ineffective, because numerous factors can intervene that can frustrate the effective provision of safety service.

                                          When the service is an inspection-only service, as is very prevalent, the safety system and the behavioural system will be totally overlooked. When the service consists of the delivery of safety aids and materials, and nothing else, it is a virtually meaningless service. When the service consists primarily or totally of holding safety meetings for a customer, such as delivering the “canned” safety programme that the carrier’s home office has devised for use at all insured companies, or merely ensuring that physical conditions are up to code, it is also a weak service.

                                          Depending upon the sort of philosophy that underlies the service of the carrier, additional services may be available over and beyond that provided by the representative that calls on the customer. Figure 1 outlines some typical additional services that can be particularly useful to customers, such as industrial hygiene, nursing and specialist (engineering and fire protection) services, depending upon the organization’s current needs. Training services are somewhat less common but are also valuable.

                                          Figure 1. Additional services of consultants

                                          PRO01FE

                                          Government Consultants

                                          As with the insurance consultants, certain considerations, such as the following, must be weighed by a company before deciding whether or not to request the assistance of government consultants.

                                            • whether the terms under which government assistance is offered are acceptable
                                            • the competence of the people
                                            • the limited scope of the consulting
                                            • the inability to direct the consulting focus.

                                                   

                                                  Probably the first consideration is whether or not a company wishes to become involved with a government at all. When using other kinds of consultants (either private or those provided by an insurance firm), whatever findings are obtained are strictly between the organization and the consultant. Whatever the company decides to do is a decision reserved to the company alone, which retains control over the disposition of the information. With government consultants this is not totally true. For example, if the consultants find one or both of two kinds of hazards—violations of the law and those immediately dangerous to life or health—the organization may not be able to retain the power of decision as to what to do about the hazard and when to do it.

                                                  Government consultants can provide assistance with determining whether or not an organization is in compliance with regulations and standards. This is an extremely narrow focus and has many weaknesses, as pointed out by Peters (1978) in his article “Why only a fool relies on safety standards”: “For those who know little about safety, it seems quite plausible and reasonable to expect that the existence of good safety standards and a sufficient conformance to those standards should be an adequate measure of safety assurance.” Peters suggests that not only is such an expectation in error, but also that reliance on standards will subvert professional activities that are needed to reduce loss.

                                                  Private Consulting

                                                  With the private consultant, whether an independent individual or an employee of a consulting firm, full or part time, there are no mandatory reporting requirements. The private consultant does not have to abide by the mandates of a required referral system; the relationship is strictly between the organization and the individual consultant. The scope of the consultation is limited, as the “customer” can very directly control the focus of the consultant’s activities. Thus the only thing the client has to worry about is whether or not the consultant is competent in the areas where help is needed and whether or not the fee is judged to be a fair one. Figure 2 lists some of the most basic functions of the management consultant.

                                                  Figure 2. Basic functions of the management consultant

                                                  PRO02FE

                                                  G. Lippit (1969), who has written extensively on the consulting process, has identified eight specific consultant activities:

                                                    1. helps management examine organizational problems (e.g., organizes a management meeting for problem identification in the problem relationships between home and field personnel)
                                                    2. helps management examine the contribution of the proper dialogue to these problems (e.g., in relation to home and field office problems, explores with management how a conference on communication blocks might lead to problem solving)
                                                    3. helps examine the long- and short-range objectives of the renewal action (e.g., involves management in refining objectives and in setting goals)
                                                    4. explores, with management, alternatives to renewal plans
                                                    5. develops, with management, the renewal plans (e.g., based on the objectives, works with a task force to develop a process with built-in evaluation rather than simply submitting an independently developed plan to management for approval)
                                                    6. explores appropriate resources to implement renewal plans (e.g., provides management with a variety of resources both inside and outside the organization; the renewal stimulator must help management to understand what each resource can contribute to effective problem solving)
                                                    7. provides consultation for management on evaluation and review of renewal process (e.g., evaluation must be in terms of problem solving; working with management; the renewal stimulator must assess the current status of the problem, rather than check whether or not certain activities have been conducted)
                                                    8. explores with management the follow-up steps necessary to reinforce problem solving and outputs from the renewal process (e.g., encourages management to look at implications of the steps taken so far, and to assess the current status of the organization in terms of other actions that might be necessary to follow up on implementation of the renewal process).

                                                                   

                                                                  Lippit (1969) has also identified five different positions which the consultants can adopt vis-à-vis their clients’ needs (Figure 3).

                                                                  Figure 3. Five consultant approaches

                                                                  PRO03FE

                                                                  Choosing a Consultant

                                                                  When choosing a consultant, a process such as that given by figure 4 is suggested.

                                                                  Figure 4. Choosing a consultant

                                                                  PRO04FE

                                                                  Whether or not to use a consultant, and which one to use, ought to be determined by the user’s defined needs and by what kinds of skills and knowledge the consultant must have to be of real help. Then, it would seem logical to look for individuals or groups that have those sorts of skills and knowledge. It may be determined that as a result of this process, the job can be done without external help; for example, to locate the needed skills internally and apply those skills to the defined safety problems. Conversely, it may be decided to go to the outside for the skills needed.

                                                                   

                                                                   

                                                                   

                                                                   

                                                                   

                                                                   

                                                                   

                                                                   

                                                                   

                                                                   

                                                                   

                                                                  Evaluating the Consultant’s Performance

                                                                  After having worked with consultants for a period of time, a company can judge their individual performance and worth to the organization much more accurately (figure 5). As a result of the analysis provided by the consultant, the conclusion may be made that perhaps the remainder of the job, or a similar job, can be done as well using internal resources. Many companies do this now, and more are turning to it, in both safety and nonsafety areas.

                                                                  Figure 5. Evaluating the consultant's performance

                                                                  PRO05FE

                                                                  Problem-Solving Approaches

                                                                  K. Albert, in his book, How to Be Your Own Management Consultant (1978), suggests that there are four different types of internal management problem-solving approaches:

                                                                    • to hire a full-time internal consultant
                                                                    • to put someone on a special assignment on a temporary basis
                                                                    • to create a task force to work on a problem
                                                                    • collaboration between an outside consultant and an internal consultant.

                                                                           

                                                                          Furthermore, Albert suggests that no matter which approach is chosen, these ground rules must be followed for success:

                                                                            • Get total support of top management.
                                                                            • Establish confidentiality.
                                                                            • Earn the acceptance of operation units.
                                                                            • Avoid company politics.
                                                                            • Report to a high level.
                                                                            • Start slowly and maintain objectivity.

                                                                                       

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                                                                                      Monday, 04 April 2011 19:35

                                                                                      Safety Policy, Leadership and Culture

                                                                                      The subjects of leadership and culture are the two most important considerations among the conditions necessary to achieve excellence in safety. Safety policy may or may not be regarded as being important, depending upon the worker’s perception as to whether management commitment to and support of the policy is in fact carried out every day. Management often writes the safety policy and then fails to ensure that it is enforced by managers and supervisors on the job, every day.

                                                                                      Safety Culture and Safety Results

                                                                                      We used to believe that there were certain “essential elements” of a “safety programme”. In the United States, regulatory agencies provide guidelines as to what those elements are (policy, procedures, training, inspections, investigations, etc.). Some provinces in Canada state that there are 20 essential elements, while some organizations in the United Kingdom suggest that 30 essential elements should be considered in safety programmes. Upon close examination of the rationale behind the different lists of essential elements, it becomes obvious that the lists of each reflect merely the opinion of some writer from the past (Heinrich, say, or Bird). Similarly, regulations on safety programming often reflect the opinion of some early writer. There is seldom any research behind these opinions, resulting in situations where the essential elements may work in one organization and not in another. When we do actually look at the research on safety system effectiveness, we begin to understand that although there are many essential elements which are applicable to safety results, it is the worker’s perception of the culture that determines whether or not any single element will be effective. There are a number of studies cited in the references which lead to the conclusion that there are no “must haves” and no “essential” elements in a safety system.

                                                                                      This poses some serious problems since safety regulations tend to instruct organizations simply to “have a safety programme” that consists of five, seven, or any number of elements, when it is obvious that many of the prescribed activities will not work and will waste time, effort and resources which could be used to undertake the pro-active activities that will prevent loss. It is not which elements are used that determines the safety results; rather it is the culture in which these elements are used that determines success. In a positive safety culture, almost any elements will work; in a negative culture, probably none of the elements will get results.

                                                                                      Building Culture

                                                                                      If the culture of the organization is so important, efforts in safety management ought to be aimed first and foremost at building culture in order that those safety activities which are instituted will get results. Culture can be loosely defined as “the way it is around here”. Safety culture is positive when the workers honestly believe that safety is a key value of the organization and can perceive that it is high on the list of organization priorities. This perception by the workforce can be attained only when they see management as credible; when the words of safety policy are lived on a daily basis; when management’s decisions on financial expenditures show that money is spent for people (as well as to make more money); when the measures and rewards provided by management force mid-manager and supervisory performance to satisfactory levels; when workers have a role in problem solving and decision making; when there is a high degree of confidence and trust between management and the workers; when there is openness of communications; and when workers receive positive recognition for their work.

                                                                                      In a positive safety culture like that described above, almost any element of the safety system will be effective. In fact, with the right culture, an organization hardly even needs a “safety programme”, for safety is dealt with as a normal part of the management process. To achieve a positive safety culture, certain criteria must be met

                                                                                      1. A system must be in place that ensures regular daily pro-active supervisory (or team) activities.

                                                                                      2. The system must actively ensure that middle-management tasks and activities are carried out in these areas:

                                                                                        • ensuring subordinate (supervisory or team) regular performance
                                                                                        • ensuring the quality of that performance
                                                                                        • engaging in certain well-defined activities to show that safety is so important that even upper managers are doing something about it.

                                                                                           

                                                                                          3. Top management must visibly demonstrate and support that safety has a high priority in the organization.

                                                                                          4. Any worker who chooses to should be able to be actively engaged in meaningful safety-related activities.

                                                                                          5. The safety system must be flexible, allowing choices to be made at all levels.

                                                                                          6. The safety effort must be seen as positive by the workforce.

                                                                                          These six criteria can be met regardless of the style of management of the organization, whether authoritarian or participative, and with completely different approaches to safety.

                                                                                          Culture and Safety Policy

                                                                                          Having a policy on safety seldom achieves anything unless it is followed up with systems that make the policy live. For example, if the policy states that supervisors are responsible for safety, it means nothing unless the following is in place:

                                                                                            • Management has a system where there is a clear definition of role and of what activities must be carried out to satisfy the safety responsibility.
                                                                                            • The supervisors know how to fulfil that role, are supported by management, believe the tasks are achievable and carry out their tasks as a result of proper planning and training.
                                                                                            • They are regularly measured to ensure they have completed the defined tasks (but not measured by an accident record) and to obtain feedback to determine whether or not tasks should be changed.
                                                                                            • There is a reward contingent upon task completion in the performance appraisal system or in whatever is the driving mechanism of the organization.

                                                                                                   

                                                                                                  These criteria are true at each level of the organization; tasks must be defined, there must be a valid measure of performance (task completion) and a reward contingent upon performance. Thus, safety policy does not drive performance of safety; accountability does. Accountability is the key to building culture. It is only when the workers see supervisors and management fulfilling their safety tasks on a daily basis that they believe that management is credible and that top management really meant it when they signed the safety policy documents.

                                                                                                  Leadership and Safety

                                                                                                  It is obvious from the above that leadership is crucial to safety results, as leadership forms the culture that determines what will and will not work in the organization’s safety efforts. A good leader makes it clear what is wanted in terms of results, and also makes it clear exactly what will be done in the organization to achieve the results. Leadership is infinitely more important than policy, for leaders, through their actions and decisions, send clear messages throughout the organization as to which policies are important and which are not. Organizations sometimes state via policy that health and safety are key values, and then construct measures and reward structures that promote the opposite.

                                                                                                  Leadership, through its actions, systems, measures and rewards, clearly determines whether or not safety will be achieved in the organization. This has never been more apparent to every worker in industry than during the 1990s. There has never been more stated allegiance to health and safety than in the last ten years. At the same time, there has never been more down-sizing or “right-sizing” and more pressure for production increases and cost reduction, creating more stress, more forced overtime, more work for fewer workers, more fear for the future and less job security than ever before. Right-sizing has decimated middle managers and supervisors and put more work on fewer workers (the key persons in safety). There is a general perception of overload at all levels of the organization. Overload causes more accidents, more physical fatigue, more psychological fatigue, more stress claims, more repetitive motion conditions and more cumulative trauma disorder. There has also been deterioration in many organizations of the relationship between the company and the worker, where there used to be mutual feelings of trust and security. In the former environment, a worker may have continued to “work hurt”. However, when workers fear for their jobs and they see that management ranks are so thin, they are non-supervised, they begin to feel as though the organization does not care for them any more, with the resultant deterioration in safety culture.

                                                                                                  Gap Analysis

                                                                                                  Many organizations are going through a simple process known as gap analysis consisting of three steps: (1) determining where you want to be; (2) determining where you are now and (3) determining how to get from where you are to where you want to be, or how to “bridge the gap”.

                                                                                                  Determining where you want to be. What do you want your organization’s safety system to look like? Six criteria have been suggested against which to assess an organization’s safety system. If these are rejected, you must measure your organization’s safety system against some other criteria. For example, you might want to look at the seven climate variables of organizational effectiveness as established by Dr. Rensis Likert (1967), who showed that the better an organization is in certain things, the more likely it will be successful in economic success, and thus in safety. These climate variables are as follows:

                                                                                                    • increasing the amount of worker confidence and managers’ general interest in the understanding of safety problems
                                                                                                    • giving training and help where and as needed
                                                                                                    • offering needed teaching as to how to solve problems
                                                                                                    • providing the available required trust, enabling information sharing between management and their subordinates
                                                                                                    • soliciting the ideas and opinions of the worker
                                                                                                    • providing for approachability of top management
                                                                                                    • recognizing the worker for doing a good job rather than for merely giving answers.

                                                                                                                 

                                                                                                                There are other criteria against which to assess oneself such as the criterion established to determine the likelihood of catastrophic events suggested by Zembroski (1991).

                                                                                                                Determining where you are now. This is perhaps the most difficult. It was originally thought that safety system effectiveness could be determined by measuring the number of injuries or some subset of injuries (recordable injuries, lost time injuries, frequency rates, etc.). Due to the low numbers of these data, they usually have little or no statistical validity. Recognizing this in the 1950s and 1960s, investigators tended away from incident measures and attempted to judge safety system effectiveness through audits. The attempt was made to predetermine what must be done in an organization to get results, and then to determine by measurement whether or not those things were done.

                                                                                                                For years it was assumed that audit scores predicted safety results; the better the audit score this year, the lower the accident record next year. We now know (from a variety of research) that audit scores do not correlate very well (if at all) with the safety record. The research suggests that most audits (external and sometimes internally constructed) tend to correlate much better with regulatory compliance than they do with the safety record. This is documented in a number of studies and publications.

                                                                                                                A number of studies correlating audit scores and the injury record in large companies over periods of time (seeking to determine whether the injury record does have statistical validity) have found a zero correlation, and in some cases a negative correlation, between audit results and the injury record. Audits in these studies do tend to correlate positively with regulatory compliance.

                                                                                                                Bridging the Gap

                                                                                                                There appear to be only a few measures of safety performance that are valid (that is, they truly correlate with the actual accident record in large companies over long periods of time) which can be used to “bridge the gap”:

                                                                                                                  • behaviour sampling
                                                                                                                  • in-depth worker interviews
                                                                                                                  • perception surveys.

                                                                                                                       

                                                                                                                      Perhaps the most important measure to look at is the perception survey, which is used to assess the current status of any organization’s safety culture. Critical safety issues are identified and any differences in management and employee views on the effectiveness of company safety programmes are clearly demonstrated.

                                                                                                                      The survey begins with a short set of demographic questions which can be used to organize graphs and tables to show the results (see figure 1). Typically participants are asked about their employee level, their general work location, and perhaps their trade group. At no point are the employees asked questions which would enable them to be identified by the people who are scoring the results.

                                                                                                                      Figure 1. Example of perception survey results

                                                                                                                      SAF200F1

                                                                                                                      The second part of the survey consists of a number of questions. The questions are designed to uncover employee ­perceptions about various safety categories. Each question may affect the score of more than one category. A cumulative per cent positive response is computed for each category. The percentages for the categories are graphed (see figure 1) to display the results in descending order of positive perception by the line workers. Those categories on the right-hand side of the graph are the ones that are perceived by employees as being the least positive and are therefore the most in need of improvement.

                                                                                                                       

                                                                                                                      Summary

                                                                                                                      Much has been learned about what determines the effectiveness of a safety system in recent years. It is recognized that culture is the key. The employees’ perception of the culture of the organization dictates their behaviour, and thus the culture determines whether or not any element of the safety programme will be effective.

                                                                                                                      Culture is established not by written policy, but rather by leadership; by day-to-day actions and decisions; and by the systems in place that ensure whether safety activities (performance) of managers, supervisors and work teams are carried out. Culture can be built positively through accountability systems that ensure performance and through systems that allow, encourage and get worker involvement. Moreover, culture can be validly assessed through perception surveys, and improved once the organization determines where it is they would like to be.

                                                                                                                       

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