Some rules are mission-critical when it comes to preventing serious injuries. Whether they define procedures for working at heights, entering a confined space, or approaching another high-risk activity, life-saving rules demand special attention. We often know them as the “zero tolerance” rules. Violating these rules is not an option.
Life-saving rules (sometimes known as cardinal safety rules) help ensure ongoing focus on those protective measures most important for avoiding serious injuries. Despite their importance, implementing these rules does not always go smoothly. For example, not having a carefully planned approach can result in serious problems that actually detract from an organization’s safety objectives. Here are the four ways we see organizations undermine the implementation of life-saving rules:
- Enforcing the rules inconsistently – A life-saving rule must be enforced with 100% consistency based on the rule being followed, independent of whether there is an injury that occurs. The organization must be prepared to commit to 100% enforcement, and must be prepared to discipline anyone, whether agreement worker or supervisor or manager, who does not follow the life-saving rule. In addition, a supervisor or manager who does not enforce a life-saving rule with consistency must be disciplined. (That is, zero tolerance applies both to following and to enforcing the rule.)
- Being unclear about the consequences – There must be clear consequences for failure to follow a life-saving rule. This may already be specified in various labor agreements and/or HR policies, but the consequences should be reviewed to be sure they can be applied with 100% consistency of enforcement. Moreover, it is important to define what “zero tolerance” really means. For example, a life-saving rule might be using the fall protection procedure, and the fall protection procedure may require display of the completed work permit in a visible location close to the work being performed. If the person doing the work takes appropriate precautions, completes the permit perfectly, but puts it in his pocket, what action is taken? Without clear guidance and communication, some people would interpret this as a rule violation and apply discipline, while others would say the procedure is designed to control exposure for the most high-risk activities and the failure to post doesn’t warrant discipline. A team walking through as many of these types of potential scenarios as possible, agreeing on the desired approach, and communicating it is vital.
- Being vague in general – Each life-saving rule must be specific. That is, having a life-saving rule of “act safely” would be impossible to enforce consistently due to the subjectivity of interpretation involved. On the other hand, a life-saving rule of “no work between or under rail cars without blue flag protection” would be specific.
- Selecting rules poorly or for the wrong reasons – Life-saving rules should be selected for their ability to reduce high risk exposure, not for administrative issues. For example, attempting to address late reporting of injuries through a life-saving rule would potentially create two problems: First, it would make the life-saving rules appear to employees not to be focused on reducing exposure. Second, it could be seen by regulators as suppressing the reporting of injuries (since some injuries truly cannot be reported until sometime later and subjecting this to discipline could result in people not reporting legitimate injuries.)
For more information on ways to build effective life-saving rules in your organization, see our article here.
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[Photo “Laborer with Fall Protection-San Francisco, California” by gregor_y, available under a Creative Commons License]
