OHS Canada 25th Anniversary Best Editorial

Is Your Committee Effective?

January/February 2007

Oh&s committees are often assessed on their efficiency, not effectiveness. Could an individualist or collective approach set your committee on the right path? Will work and safety be integrated, or will an adversarial climate be created?

By: Dr. Peter Strahlendorf

How is your health and safety committee doing? Is your company at zero lost time and, if so, for how long? Surely that's the ultimate test of committee effectiveness. For too long, however, people have tended to assess the committee on the basis of its efficiency (number of meetings, attendance, number of complaints handled, inspections completed, and so on) rather than its effectiveness. It's a distinction made long ago by Peter Drucker, the management guru -- doing something well (efficiency) and doing the right thing (effectiveness). Obviously we want both: doing the right thing well. But is it possible your committee may be doing the wrong things well or, even, the wrong things poorly?

Everyone in concert

To find out, it's necessary to determine what a committee should be doing and its proper role. To start, consider what an occupational health and safety act (OH&S Act) says a committee's powers and duties are. But these sections should not be read in isolation. Rather, they must be considered in the context of the whole OH&S Act and its purpose.

Most OH&S Acts in Canada are expressly or implicitly based on the idea of the Internal Responsibility System (IRS). The IRS philosophy means that work and safety are not separate activities (as in, you work Monday to Friday and then on Friday at 3 pm you do a little "safety" before going home). Work and safety are integrated as "safe work" or "safe production." If this is achieved, then everyone working is also "doing" safety.

Each person is responsible for safety as part of his or her individual job, but different things need to be done for safety depending on the specific job in question. Presidents do presidential safety (policies, systems and leadership), managers do managerial safety (programs, staffing and resource allocation), supervisors do supervisory safety (training, task analysis, inspections, coaching, etc.) and operational workers do worker safety (applying training, identifying direct hazards and contraventions, inspections, procedures, reporting, etc.). This way, each person is not just looking out for his or her own safety, but constantly assessing the impact of individual decisions (or inactions) on the safety of others.

If an OH&S Act is based on the IRS philosophy, then each person -- not just the employer -- has legal duties. No one escapes potential legal liability.

Some across Canada may think IRS is a peculiar Ontario thing, since it was given a name by the Ontario government's Royal Commission on Health and Safety of Workers in Mines, the so-called Ham Commission, 30 years ago. But it's such a fundamental idea that we should say Dr. James Ham "discovered" but did not "create" the idea. The IRS philosophy arises out of accident theory -- if a model of how accidents happen can show that anyone can directly or indirectly cause an accident, then anyone can prevent accidents and, therefore, everyone should be acting to do so.

Decidedly different views

But the IRS has been described in different terms, resulting in misinterpretation of the committee's role. The original or "individualist" version of the IRS now has as its main competing view the "collectivist" version of the IRS. In the original version, every individual is personally and directly doing safety. Under the collectivist version, there are just two parties in the workplace, workers collectively and management collectively. The two parties work together to do safety which, though sounding very good, is very different from the individualist version of the IRS.

Under the collectivist view, workers and management send their representatives to the committee which, in turn, becomes the main vehicle for doing safety. Workers send their concerns through worker reps to the committee; management reps take committee solutions to the appropriate people in the management system. With this approach, the concern is often whether or not the committee has enough power and resources to get the job done.

The individualist view of the IRS means the committee is an advisor, consultant and watchdog -- though important, it is not doing safety for people. The committee's main job is to ensure the core of the IRS is working, from the president to the mailroom clerk.

Consider the consequences of these two views on how committees, in most jurisdictions, conduct monthly inspections. The OH&S Act may say worker reps do the monthly inspections. But because they are often accompanied by management reps, it then becomes a joint inspection. Under the collectivist view, the organization is counting on committee reps to do a good job on the monthly inspections (they are identifying hazards and contraventions on behalf of everyone). As a measure of efficiency, we ask how quickly and well the organization responds to the committee's findings. Under the individualist view, the workers, supervisors and managers are doing daily, weekly and monthly inspections of various types. The committee representatives are checking up, in effect auditing, how well these individuals have done their inspections.

The collectivist says: "We have found a hazard. Take action and control it." The individualist says: "We have found a hazard. Why didn't the main players find this as a matter of daily routine?"

"I" or "We"

The differences between the individualist and collectivist view of the committee are not benign. What happens to workplace risk if individuals believe the committee is the main player and is to be relied on?

Three bad things may happen under the collectivist view. First, in an extreme scenario, the committee becomes overburdened with hundreds of small issues that ought to have been dealt with immediately at the scene. Overworked and frustrated, the committee's efficiency begins to slide. Second, personal responsibility drops. For example, supervisors may ask why workers are coming to them with a concern, rather than to the committee rep. Third, a topic may languish on the committee's crowded agenda for months, meaning the identified hazard is not being addressed.

If this same thing is happening for a hundred other hazards, risk goes up.

Under the individualist view, the vast majority of issues raised by workers are addressed quickly by supervisors and managers. Only the most contentious issues -- or those where the IRS has failed -- actually get to the committee. With a few big, important issues, the committee can better control its agenda (and efficiency).

How can you tell if your committee is afflicted with the collectivist approach to the IRS? In general, an IRS perception survey can show if the committee is perceived as the main player or if all individuals are viewed as being directly and primarily responsible. The survey can determine if some workers are going directly to the worker rep (without first trying to solve the problem with the supervisor), if some supervisors are directing workers to their rep first, or if some worker reps are encouraging workers to come to them first.

A quick way to observe if the committee reflects an individualistic or collectivist view is to consider a typical committee meeting. In a collectivist committee, the table is likely to be rectangular. The two parties line up on opposite sides of the table, the meeting possibly following separate pre-meetings to clarify each side's "bargaining position." The atmosphere is adversarial. The assumption is that labour wants safety and management wants to avoid paying for it. There's no mutuality of interest in driving risk down.

The individualistic committee sits at a round table, with the atmosphere being consensual rather than adversarial. Management reps put forward issues, not just worker reps. There is a far greater sense that everyone's interest is in getting risk down as low as it can reasonably get.

A clear purpose

What sort of an entity is the committee? The committee is a statutorily empowered internal watchdog, auditor, motivator, educator and consultant -- but it is not part of the management system. While inside the organization, a committee is not directly part of the chain of command, even those committees with management representation. This is a key point as many people believe the committee is "managing" occupational health and safety or running the "oh&s management system."

Management manages the oh&s management system and management's performance is monitored by the committee (as well as monitored within the management system). The issue, however, is that the management system cannot do a truly objective and effective job auditing itself. Logically, the committee cannot both manage and reliably audit the oh&s system.

The committee and its representatives -- clearly vital to the overall design of the IRS -- are, nonetheless, not the main part of the system. They are a secondary or fail-safe feature of the IRS.

What makes the committee and reps so important -- even as a "secondary" element? The IRS implicitly assumes that people within the organization can never be perfect. They need motivation and encouragement. Being fallible, people may not see things clearly, can be biased, may not communicate well, are over-stressed, can sometimes be deceptive, may lack trust, have organizational obstacles in their way, and so on.

The committee is a bipartite, labour-management entity even though the main core of the IRS is all about individuals. Being bipartite, though a collectivist feature, helps to protect against conflicts of interest on the part of management. It improves openness, critical analysis and objectivity.

Some organizations that are badly managed (which is to say, all organizations, at least some of the time) would allow problems to be covered up, lies to be told, confusion about priorities, and so on. It is our dim view of human nature that necessitates the committee and its representatives. No matter how noble the individuals on a purely management oh&s committee, it would never function as well as a bipartite committee when under stress. A committee should be capable of being both an internal and external whistle-blower.

Confusion often arises when people assume that because the committee has a labour relations, bipartite flavour that all oh&s is done through the lens of labour relations. It's easy to see how people might take a collectivist view of the IRS if they believe oh&s to be a subset of labour relations. Though there are connections, oh&s is distinct from labour relations, having its own origin, philosophy, agenda and values.

Right, right, right

The "three rights" -- the rights to know, to refuse and to participate -- are part of the original vision of the IRS.

The right to know is the "grease" that makes the IRS function at its best. Individuals are in a much better position to make decisions with a free flow of information about hazards and controls, and the committee, though only a part of the information system, has a role to play in facilitating that information flow.

The right to refuse unsafe work is a fail-safe mechanism. If the IRS is working well, a worker shouldn't need to engage in a work refusal, a sign that the main part of the system has failed. Following a work refusal, the committee must ask that question: What went wrong with the IRS that the worker felt he had to engage in a work refusal?

The right to participate should not be confused with the duty to participate. Oh&s is not optional or voluntary; everyone has a duty to participate. The right to participate comes into play when others in the IRS are not doing their duties. The worker has the right to go to a worker rep to get a second opinion or to kick start the IRS. If the worker rep is unable to get a response informally, the problem moves formally, propelled by the worker representative, to the committee.

There may be a temptation on the part of the worker representative (similar to the temptations faced by oh&s coordinators or managers) to "beat the bushes" for business. The rep's role is not to regress into some kind of "Mr. Safety" who "hogs" all the oh&s issues so as to feel important and irreplaceable, but to encourage a positive interaction between workers and supervisors. If there is silence between workers and supervisors, limited "beating of the bushes" may be in order.

A major strength of the individualist view of the IRS is that it takes advantage of "local knowledge." Every individual in an organization is in possession of an enormous amount of unwritten information about materials, tools, processes, the environment and other people. Each individual is to use this local knowledge to identify hazards and contraventions and to take action -- first by doing what is in the individual's power to do and, then, by engaging the attention of someone with greater authority over the situation.

When the IRS moves to world-class levels of safety performance, all individuals -- supervisors, managers, executives and workers -- are required to think of ways of improving the processes with which they are involved.

Committee members, no matter how experienced, do not possess all or even most of this local knowledge. As such, when it comes to work procedures or improving elements of the oh&s management system, people directly involved are best suited to initially deal with the matter. The committee should not be supplanting this rich source of local knowledge. It has a consultative, harmonizing and mediating role for procedures and system elements.

Keep an eye out

What does it mean to say that the committee's primary and proper role is to monitor the IRS? Clearly, the committee should be vitally concerned with formal surveys and audits of the IRS. Some safety organizations provide such audits to their members, but, perhaps, more important is that "IRS analysis" serves as the lens through which the committee views almost all issues.

What is IRS analysis? Essentially, this is a more specialized subset of systems analysis in which the human element in the management system is being assessed. Unless you fix the "people problem" in the system, you will continue to see the problem reoccurring.

When faced with an oh&s issue, the analysis demands: What went wrong with the IRS that allowed this to occur? Looking for flaws in the IRS is similar to searching for root causes in the management system when conducting an accident investigation.

It means reviewing more deeply issues that historically have been handled superficially. For example, when an inspector issues an order, the organization kicks into gear and seeks to comply. The committee's involvement typically has been to see that there has been compliance. Under IRS analysis, the committee needs to ask how the IRS failed so that an order was necessary.

While the inspector is at the workplace for a few hours, individuals in the IRS, with all their rich local knowledge, are there all the time. An order is a symptom, a sign that someone (or some people) did not fulfill their responsibilities. Unless the reasons for the inaction are understood and obstacles cleared, further orders should be expected.

It's been a long, painful process getting accident investigation to move away from blaming workers to seeking the root cause in the management system. But a weakness has surfaced in that the personal factor often gets overlooked or ignored -- "the system caused the accident." IRS analysis seeks to locate the individuals in the management system who failed to plan, develop, implement or monitor the system element. Insofar as the committee is involved in accident investigation, or, at the very least, in reviewing accident investigation reports, IRS analysis helps to get to the human element beyond the individual worker.

Down the line

When it comes to the myriad small issues and complaints that burden the committee's agenda, IRS analysis provides a filtering mechanism. The committee should apply a litmus test to incoming issues, namely, Have the supervisor and manager been given an opportunity to resolve the issue? If not, the issue should be returned to the workplace parties.

Suppose there is a seemingly "mundane" worker complaint about wet paper towels on a washroom floor as a slip hazard. Committee members could take the problem as given, discuss it for a while and then recommend that the employer address the issue. The committee may take more time discussing it than a supervisor would have taken solving the problem (cleaning up the towels).

A slightly better approach is where the committee analyzes the issue in oh&s management system terms and recommends the housekeeping program be re-assessed with respect to washrooms.

A third approach, the IRS approach, would require that the committee not deal with the issue at all unless it passed the litmus test: Have the supervisor and manager been given an opportunity to resolve the issue? Assuming the answer is "Yes," the committee's questioning goes beyond the housekeeping program into the issue of who has been given the responsibility for developing, implementing and monitoring the housekeeping program (if system design, etc. is the issue). In this case, who (a supervisor) has geographic jurisdiction over the washroom, who has oversight regarding the supervisor's handling of the matter (i.e., a manager), and why have the particular individuals allowed the situation to exist?

It is tempting to say the IRS approach is just a more elaborate way of blame-fixing, but it is more constructive and positive than that. The analysis should proceed by identifying the relevant "people problems" of authority, jurisdiction, knowledge, stress, communication and so on.

In essence, health and safety is all about the people in the workplace. People cause accidents and exposures and they tend to cause them indirectly by failing to do what a reasonable person in their shoes would do. By saying "indirectly," the idea is to always delve into the management system beyond the worker, but to always be asking questions about system elements.

An IRS analysis allows questions to be asked of everyone, not just standard queries regarding the failures of workers and supervisors. The analysis often reveals that it is people in middle and senior management -- and quite frequently people in "staff" or "support" functions -- who are setting up workers and supervisors for failure in their interactions with each other.

Under the collectivist view of the committee, the claim is often made (since the committee is thought to be doing safety on behalf of everyone) that the committee needs more power -- that consultations and recommendation aren't enough.

Power divide

But what is the committee's real power? It lies in changing the legal vulnerability of the employer and of individuals in the IRS. When the committee or worker rep informs someone of a hazard or contravention, and that person has authority or control, that person now knows. That means the existing due diligence defence evaporates, leaving only how reasonable the response is to the new knowledge. This is particularly critical when the risk is very high and a lack of action moves matters out of the realm of the OH&S Act and into that of criminal negligence.

Where all individuals in the IRS have been properly trained in the subtleties of due diligence, they become more sensitive and responsive to what the worker representative and the committee have to say. Given that the proper role of the worker rep and committee, with respect to the oh&s inspector, is to act as a window on the IRS, non-response may become subject to the scrutiny of the inspector -- who carries a big stick.

With a collectivist view of the IRS, it may never become clear how powerful an incentive individual due diligence (as opposed to organizational due diligence) can be. Committees and worker reps have a tremendous amount of untapped power once individuals in the IRS are sensitized.

So how is your committee doing? How effective is it? Is it a reflection of a collectivist safety culture or an individualistic safety culture?

Over the years, workplaces operating under the individualist view of the IRS and the committee seem to have demonstrated a better track record for safety than workplaces subject to a collectivist philosophy. It's been 30 years since the Ham report described the IRS and established the critical need for "worker auditors," but it seems many workplaces still have a way to go to make committees as effective as they can be.

Dr. Peter Strahlendorf, CRSP, is an associate professor with the School of Occupational and Public Health at Ryerson University in Toronto. He can be reached at peter.strahlendorf@iqsem.ca.