Implementation of Life-Saving Safety Rules
Contributors: R. Scott Stricoff
"Life-saving rules" for safety are rules that are deemed to be safety-critical and for which there will be zero tolerance for violation. Adoption of life-saving rules can be a helpful approach to ensure ongoing focus on those protective measures most important for avoiding serious injuries. However, implementation of life-saving rules without using a carefully planned approach can result in serious problems that actually detract from an organization's safety objectives.
This document suggests the process that should be used for the implementation of life-saving safety rules, and explains the pitfalls that can occur if a well-designed implementation process is not followed.
The steps that should be followed in implementing life-saving safety rules are:
- Describe the compelling reason for change:
Senior leadership should articulate why this change is important and what benefits will be achieved through the change.
- Implementation team:
Form a cross-functional team to manage the development and implementation of life-saving rules. (Ideally this should be a management/labor team.) Implementing a life-saving rules program is a significant undertaking and requires considerable planning and development work. Having participation and input from varying perspectives is important to assure the program design and implementation are well designed.
- Initial selection of life-saving rules:
These must be a small number (ideally no more than eight to ten) of items that are selected based on them representing high risk. This may be due to them reflecting exposures with very high potential severity, or may be reflecting exposures with lower severity but very high frequency. The credibility of the life-saving rules depends on them being items that everyone would recognize as being important for worker protection. (It should be apparent to everyone that they would not want to be working with someone who violated these rules.) Study of the injuries with potential for serious injury or fatality can be a good source of data to support development of life-saving rules. In addition to identifying the life-saving rules, it is important to decide on two related issues:
- Decide whether life-saving rules will be enterprise-wide or department specific. Are the exposures in different departments sufficiently unique to require separate life-saving rules, and if so how will these be applied in locations where more than one department's personnel work?
- Decide whether variation in existing procedures must be eliminated before life-saving rules can be implemented. For example, there may be multiple versions of lock out/tag out procedures within the organization. Unless these are made consistent, a life-saving rule that said "follow lock-out/tag-out procedures" would be very difficult to validate (see step 5) and consistently enforce.
- Define consequences:
There must be clear and unambiguous definition of the consequences that will occur when a life-saving rule is violated. Because these rules must be enforced with 100% consistency, the organization must define consequences that it is willing to truly use. Of course these consequences must be consistent with any requirements or restrictions contained in labor agreements. The consequences may be progressive – that is, a different consequence for first offense than for subsequent violations – but the consequence at each step of progression must be applied consistency to anyone violating a life-saving rule.
- Union collaboration:
In organizations with labor unions, there should be early communication with the union leadership about the organization's reasons for implementing life-saving rules, the principles under which it is being done, and the approach planned to implement it. Input should be sought on both the draft rules and the implementation process so that hopefully the unions can support this endeavor, but if they are not willing to actively support it, at least they do not try to block it.
- Validate life-saving rules:
You must assure that if rules are going to be enforced with zero tolerance for violation that the rules can, in fact, be followed. For example, in some organizations we see a rule requiring tie-off for people working at heights, but people are assigned jobs in situations where there is nothing to which they can tie off. Every life-saving rule must require a behavior that is enabled. Rules should be validated by having them reviewed by employees who do the work in which the rules apply as these employees will best understand what barriers may exist to following the rules.
- Communication to employees:
There must be a well-designed communication plan that reaches all affected employees and explains why this change is being made, what the life-saving rules are and why these specific things were selected, how the rules were validated, and what consequences will occur in case of violation of life-saving rules. The plan should provide multi-level ongoing communication covering not only the compelling reasons for implementing life-saving rules but also what each level's (senior leaders, mid-managers, frontline supervisor and front-line worker) roles are and what they need to do to make the process successful. A "one and done" communication approach will not be sufficient.
- Train supervisors and managers:
All supervisors and managers must be trained to understand how to recognize life-saving rule violations and how to handle these violations. The training should involve both classroom and field training prior to implementation of the life-saving rules. For agreement workers, before going live with life-saving rules it is valuable to create "teachable moments" where no repercussions exist. This helps ensure both the supervisors and the front line workers understand what is expected and what good looks like. This may be done through an initial "grace period" during which life-saving rule violations will result in correction but not discipline.
- Provide method for barrier removal:
Even when you have tried to assure that a life-saving rule will always be enabled, there may be situations that are missed in which there is a physical or systems barrier preventing the rule from being followed. It is important that workers have a reliable mechanism to report any situation they know of or encounter where a life-saving rule will not be able to be followed. This mechanism should also provide feedback to the worker on how the situation is being addressed.
- Stop work authority:
If there is zero tolerance for violation of a life-saving rule, then workers must be allowed to refuse work that can't be done other than by violating a life-saving rule, and that refusal must have no adverse consequences for the worker. (In fact, a worker refusing to violate a life-saving rule should get positive feedback for doing so as this presumably avoided a high risk situation.)
- Monitor enforcement:
Implement a process to monitor the performance of supervisors and managers in enforcing the life-saving rules.
In following this process for implementing life-saving rules, there are several pitfalls that must be avoided:
Inconsistent enforcement: 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.)
Unclear 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 following 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.
Lack of specificity: 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.
Poor selection of life-saving rules: 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.)