safety management systems.

As described above, better safety performance doesn’t happen unless both employers operate from the same definitions and strategies to achieve safety. Prevention of serious illness like COVID-19 is much more effective when people work as teams, solve problems together and create learning environments for continual improvement. When it comes to management systems, noted engineer and management consultant W. Edwards Deming suggested that workers can perform no better than is possible under the management processes given to them. Anticipating error, teams solving problems, systems driving reliable and safe behavior are all benefits of an effective safety management system, as well as the basis for human/organizational performance. Add to that a leveraged learning environment for continual improvement. In addition, any performance improvements require planning, partnership, teamwork, communications, adequate resources and an effective system to allow for feedback, adjustments and resources. In other words, the things we need for great business to occur are required for safe work to happen.

According to the ISO 45001 Occupational Health/Safety Management System, it’s helpful to define management systems in the context of safety performance:

management system

A set of interrelated or interacting elements of an organization to establish policies, objectives and the processes needed to achieve those objectives. These include an organization’s structure, roles/responsibilities, planning and performance evaluation. (Pay attention to the word “planning” — it will come up again soon!)

safety management system (SMS)

Part of a management system used to achieve the occupational health and safety (OH&S) policy of the organization, its intended outcomes are to prevent injury and illness to workers and to provide safe and healthy workplaces.

Think about these definitions above regarding the relationship between the staffing agency and client. A few key words really begin to stand out:

• ”interrelated”
• “interacting”
• “roles/responsibilities”
• “planning”
• “intended outcomes”

How are the two employers who make up this joint-employer environment working together toward the illness and injury prevention outcomes they want? And could there be a better framework to better understand risk and communicate expectations and activities for a safer work environment?

Two very important things to consider as we learn about how safety management systems apply to joint employers:

• The term “worker” as defined by SMS standards includes: a person performing work or related activities under the control of the organization, including various arrangements such as: regular or temporary workers, seasonal and part-time employees.
• Emphasis on worker engagement:
• Participation: The measure of a worker’s involvement in decision-making, as appropriate for the worker/role and position, engaging in feedback systems (like an effective safety committee) to inform both leaders/workers of the current state of risk.
• Consultation: The act of seeking views prior to decisions, such as a client seeking feedback from their staffing agency on perceptions of safety communications, front-line safety efforts and ideas for improvement.

At the center of safety management systems, like the ISO 45001 or recently updated ANSI Z-10 standard is the process known as: Plan - Do - Check - Act (PDCA). The PDCA process is strongly connected to the continual improvement process, and while it has traditionally been thought of from the standpoint of only one employer, best practices and industry-leading methodologies have advanced to integrate employers in a joint-employer setting for the advancement of better safety. A critical component to this process is leader/worker participation, strongly leveraging the concepts of team and communication across organizational lines and inclusive for each employer.

Let’s take a closer look at the center of this safety management system from the context of joint-employers who are both focusing on illness/injury prevention.

plan: anticipating risks and opportunities for better safety

• Leadership commits time/resources to assess hazards and risks and evaluate opportunities for improvement and other considerations, like legal requirements.
• emphasis on setting both short- and long-term goals
• includes short- and long-term goals setting
• Cadence and commitment are established — (weekly/monthly/quarterly for teams to review goals, risks and progress).
• Define the factors that are critical to worker safety in your joint-employer environment. In the case of COVID-19, that includes workforce management alongside social distancing, hygiene/sanitation, screening/communications and confirming adherence to prevention practices (e.g., enabling feedback systems from temp workers to inform leaders).
• Establish KPIs and related performance metrics, including:
• the number of non-conformities identified as it relates to COVID-19 prevention best practices
• number of trainings or safety interventions/period
• KPIs related to serious injury/fatality prevention

do: activities accomplished together lead to better safety

• Eliminate hazards using the hierarchy of controls methods (see next section!).
• Evaluate your completion of the items identified during the "plan" phase, including:
• COVID-related trainings, communication and cleaning
• injury/illness-related risk assessments, floor walks/front-line feedback and safe/unsafe observations
• Serious Injury/Fatality (SIF) prevention efforts, like fall protection evaluations, forklift operations, dock safety, electrical, start-up procedures, machine guarding evaluations and ensuring safe assignments for temp workers
• Record successes, areas for improvement and course corrections related to your safety-planning activities. You should also be sure to record peripheral activities — like near hits, root-cause evaluation, compliance activities and creative items, like surveys from employees or front-line supervisors.
• Action items and target completion dates respective to each employer (both client and staffing), including:
• Staffing agency: Prepares data and provides numbers, like length of assignment, turnover rates, assignment activity and critical insights, like feedback from your temp workforce. May also contribute to appropriate risk assessments and evaluations as agreed by both employers
• Client: Schedules meetings and follow ups, leads risk assessment practice/review and enables feedback to leadership teams.
• These elements of ‘Do’ occur both inside/outside of the plant or production floor, but ensure contribution from each employer to a share safety strategy.

check: is what we’re doing working? adjust/refine

• Monitor the reliability, completion and results of safety activities.
• Includes hazard identification, reporting, audit processes and safety committee communications
• Have we had workers report to work with COVID-19 signs/symptoms? Check: our communications.
• Have workers bypassed known sanitation/hygiene practices for COVID-19 prevention?
• Check: communications across all employers, orientation and follow up and front-line supervisor practices and oversight.
• Is what we’re doing working? Have we encountered anything unexpected?
• Did we report non-standard practices?
• Do we need to escalate any serious risk/concerns?
• Did scheduling/rescheduling of critical safety activities happen?
• Verify knowledge and retention of items critical to safety.
• Identify and report hazards.
• Follow up on open safety items and corresponding actions, and ensure they’re reliable and match the level of risk (e.g., missing machine guards are ordered and machinery locked out/tagged out until replaced). 

act: we review results, adjust and continually improve

• This precedes and informs the next planning cycle.
• Identify and ensure resolution of any escalations related to items critical to safety.
• Celebrate wins, and be sure to communicate any risks removed.
• Align on goals and communication between employers.
• Communicate risk through an established hierarchy of leadership and controls.
• Ensure all items identified during the "check" phase are built into the next planning cycle.

By taking this structured approach, each employer contributes to safety in a joint-employer work environment. Alignment with short-term and long-term goals is critical to reset and define expectations, as well as support an established cadence around the PDCA process for the joint-employer team.

While the components of a safety management system (SMS) may be more broad, the PDCA process embedded within a SMS should serve as a simple yet powerful tool to keep both employers aligned on managing — and maintaining — acceptable levels of risk.

In light of the COVID-19 pandemic, a fresh assessment of the risks affecting your organization, together with a commitment to building and implementing a strong framework (like the ISO 45001 standard), should place you on the same path as many best-in-class organizations.