The Rand Corporation has published a study of California OSHA's prevention programs, which are mandated by state law. Despite enough caveats to sink a battleship, the study does illuminate, if only for brief glimpses, a path for establishing truly effective safety and prevention programs.
History and Ideology
First, a little background on California OSHA. In the 1970s, the state as big as a country implemented its own OSHA inspection program. In 1987 a Republican governor trimmed the budget by eliminating CAL/OSHA, leaving the feds to take over the program. Gee, guess how that worked out...Two years later, CA took back the program. Over the next few years, the legislation evolved, resulting eventually in a requirement that all CA employers implement an Injury and Illness Prevention Program (IIPP) with the following key elements:
- Identification of hazards and risks
- Training programs for employees in managing those risks
- Periodic hazard surveys to determine effectiveness of hazard mitigation
- Documentation of training and hazard surveys
IIPP being a state-sponsored program, state government had to train and disperse field inspectors to determine whether employers were in compliance. That raises two very big problems: first, the scale of the effort: with 700,000 employers in the state, inspectors can only perform about 8,000 inspections per year. Equally important, with limited time on site, inspectors lack the tools, training and time to measure the actual effectiveness of an employer's IIPP.
Elements in Good Safety Programs
IIPPs mandate that employers implement the key elements of good safety programs:
- Workers know the employer's point person for safety
- Workers know how to report hazards
- Workers with good safety records are rewarded
- workers with poor safety records are disciplined
- hazards and risks are analyzed on an ongoing basis
- identified hazards are mitigated in a timely manner
- training is ongoing
As any astute reader can surmise, there is a huge gap between developing a written program with the above elements and actually implementing it. A nice cottage industry arose in California, where employers could buy an IIPP program off the shelf - and promptly store the binder, unopened, on a shelf. A written program does not a safety program make.
Does the CAL/OSHA Program Work?
So what did the Rand researchers find? Does the CAL/OSHA program prevent injuries? Is it effective?
Well, sort of, kind of, not really, we're not sure...
By the time you sort through the caveats - the impact of an unstable economy, the under-reporting of injuries by small employers, the lack of specificity in inspection visits, etc - you have very little conclusive evidence one way or the other. When visiting employers for the first time, inspectors consistently found that they were out of compliance, lacking written plans and evidence of an effective safety program. When making a second visit, especially after an injury, the results improved; there is nothing better than a serious injury to revitalize a safety program. Alas, two years after an inspection, there is no measurable lasting benefit to the program. [It is important to note, however, that unionized workforces had a more sustained and effective focus on safety than non-union environments - fodder for the ideologues, for sure.]
The Role of Government in Safety
The Rand study raises a number of compelling issues and is well worth the reading. In the final analysis, the study points out the limits of any state intervention. To be sure, inspectors could spend more time on site; they could do more qualitative analysis of the written documentation and interview a good sample of the workers. But these steps would still likely result only in incremental and relatively minor improvements.
We would all probably agree that a commitment by a company's senior management is essential: safety must be a priority in all operations. We would also agree that the above key elements belong in any effective safety program. Finally, we all recognize that safety consciousness must be embedded into a company's standard operating procedures.But that's the ideal: what happens in the real world?
Where inspections reveal ineffective safety programs, where employers exploit workers and put them at risk, systematic fines and penalties are certainly in order. Such penalties are an effective means of getting an employer's attention. Once you have that attention, it is at least feasible that employers will see the benefits of making safety a priority and eliminating workplace hazards. Government cannot make it happen, but without government, far too many employers would lack the motivation to maintain a safe workplace.
In the long run, effective safety programs are cheaper and more efficient - more profitable! - than a workplace fraught with unnecessary and unacceptable risks. At least, that's the theory and a core belief of this blog. In practice these days, with predatory employment practices on the rise, one begins to wonder...