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Safety Podcast: A Systems Approach Versus a Compliance Approach to Safety

By Alliant Specialty

Tim Leech and Mark Lillemon, Alliant discuss how focusing on strategies and solutions to address risk, rather than solely focusing on regulatory standards, not only ensures compliance but also reduces loss.

Intro (0:00):
Welcome to the Alliant Safety and Loss Control Podcast, dedicated to bringing you insightful tips, and strategies to help mitigate risk and help promote worksite safety one episode at a time.

Tim Leech (00:13):
Hello and welcome to the podcast today. My name is Tim Leech. I'm the Director of Risk Control for Alliant Insurance Services. And today we have Mark Lillemon on the line. Mark's going to be talking a little bit about the systems approach versus a compliance approach to safety. And we're doing these podcasts in celebration of National Safety Month. Mark, did you want to share a little bit about your background?

Mark Lillemon (00:37):
Yeah, sure. Thanks for inviting me today. I'm CSP. I've got about 34 and a half plus years in the Regulatory Safety Manager Loss Control career path. My work experience includes process safety management. I don't need to get into the details of that real-life experience, but it does have some relevance in today's topic, as far as a system-based approach. I've been with Alliant for a couple of years now, I'm in their Energy and Marine Specialty group. And then I'm also assigned to our Risk Control Services business unit, which is a consulting group within Energy and Marine. So yeah, that's a little bit about myself.

Tim Leech (01:17):
Mark as a fellow safety professional. You and I have had several conversations about process and procedure and what makes an effective safety program and what doesn't. And I know today you're going to talk about the systems approach, which back in the 1950s Edward Deming, basically developed a continuous quality improvement process that has like other aspects of safety evolved over the years and has kind of worked its way into safety management. I know that I've embraced it since the nineties, as you have as well. And can you give us a little bit about the framework of the process and what makes it different from the traditional and more compliance-based safety management practice?

Mark Lillemon (01:59):
The traditional of course, it's been around for a long time. That's the basis for most companies' and organizations' safety programs. We hear about that all the time referencing safety programs. It's been structured to comply with regulatory requirements. We have OSHA of course, is going to be in the occupational safety required elements. If you've got environmental exposures to your operations, CPA is going to kick in. And then of course we have DOT covers a lot of our trucking operations and pipeline operations and railroad, etc. But the essence of these regulatory compliance-based safety programs is that number one, it's really just going by the codes. And I know Tim, you've seen this as well. A lot of safety manuals, policies and procedures. I've seen a lot of them. It's almost word for word the safety standards themselves, thou shalt do this, thou shalt do that, thou shalt not do that. And these standards, I mean, they're slow to be and revised part of my career. I was a safety inspector compliance officer with that OSHA part of my background. So, I definitely understand how long these standard developments can get played out. And so, the companies, they're only going adjust their own safety programs to the issuance of the new standards as they come out. And they're really not grabbing onto progressive ideas and true safety and risk management. We're going to really speak to the system-based approach. The other thing is regulatory standards. They're the bare minimum, right? They don't incorporate best industry practices, just got to stick to the regulators that have determined is the essence of law, which establishes what those standards need to look at.

Tim Leech (03:44):
Yeah, I couldn't agree with you more. In fact, with organizations that are focused strictly on compliance, I've worked with both sides of the story, and I've always found that if I look at risk first and I look at strategies and solutions to address that risk, to reduce risk factors within an organization, which will have an impact on losses, I can gain compliance through doing that. But if I do the reverse and all I have to do is focus on compliance. I don't necessarily address all the risk factors and have an impact or an influence on the loss picture. Has that been your experience of the year?

Mark Lillemon (04:22):
Yeah, absolutely. Another side effect, I guess, of compliance-based is even how we measure our success, right? Tends to be the lagging indicator. It's amazing to me, quite frankly, that we still are so focused on total recordable incident rates. The TRIR and the dart rates, which we know are lagging indicators. Actually, I sat in on a recent webinar, there's a research group out of Colorado State University in Construction Safety Research Alliance, that has done a complete study on TRIR. It's invalidity to actual loss prevention, the effects of loss prevention and safety activities, etcetera. And yet we see so many vendors, for example, for contractor qualifications, like the IS Net and the PEC Safety, those kinds of organizations that operators like to get subscription services to. And they base their entire qualifications or contractors that perform work for them on lagging indicators of TRF, VRIR and EMR and that kind of stuff.

Tim Leech (05:32):
Right. I think as safety professionals, like a lot of professionals, sometimes we get lost in our own acronyms and our own language. And I know early on in my career, I was trying to create some metrics for an organization I worked for. And I had a guy with a Ph.D. working out the whole incidence rate on a whiteboard. And he was the General Manager. It was at Hughes aircraft actually. And he’s working this thing out. I'm like, “Man, you really made this a lot more difficult than it is.” I've actually gone away from personally using those metrics and going more to a metric that is looked at by say, analysts and underwriters. And so, because that seems to align better with the financial stakeholders and its language that people generally understand. If you say, “Hey, this is how many claims you had per million dollars of payroll.” That makes sense. But if I say, “Hey, this is your OSHA incidence rate. They're like, huh, what are you talking about?” And then you have the skewing effect. And then you also have an issue with when you have salary and hourly people, you don't have an exposure that is necessarily credible. So, it doesn't really demonstrate, like you say, it's a little bit, if somewhat invalid compared to the work that's being done.

Mark Lillemon (06:48):
It definitely doesn't have a direct correlation to the higher risk occupation, those that are in the field, for example, compliance-based programs, they are usually standalone. You typically will have your lockout tag out program and you have your PPE and your respiratory protection, etcetera. And none of them are integrated. They're all kind of referenced in the manual. It's all some tasks that might involve all three of those related programs. You've got to somehow kind of tie those pieces together. It just kind of fragmented in terms of that approach to compliance. And you definitely don't have processes that identify your organizational risks

Tim Leech (07:25):
When you're working with an organization, how would you get started? How would you advise, let's say I'm working for an energy company or for a logistics company, how would you recommend they get started with the process if they want to convert from a compliance-oriented to a more holistic risk management, say a systems-based approach?

Mark Lillemon (07:46):
Google search can be kind of your best friend, the systems-based approach, is just do a Google search on system safety. And you're going to get a ton of information. White papers links to some of the consensus standards that are often used as a framework for system-based safety management and this, you need to get educated. You need to understand sort of the framework of these standards is plan, do, check, act, that you referenced that came out of the 1950s, that was quality management focus but really resonates and works well for environmental and quality management, as well as safety management. And the beauty of that is now you have an integrated system that the organization across the enterprise, small organizations to very large organizations, they have the same processes that are modeled after that framework. And there's a few of them out there that are commonly referenced, but you don't have to go out and purchase these upfront.

I wouldn't recommend that as a starting point, but the ISO 45,001 that came out 2018, your occupational health and safety management systems that's really good, if you've got global operations, because it really suits that global business scene. OSHA actually has the recommended practices for safety and health programs. So, this is a 2016, I think, is when that came out and that you can get off of their website. And this was a revised document that OSHA originally issued like back in, I think it was 1989, but it has a lot of those elements that are in a system safety approach. And then of course there's the OHSAS 18,001. That's your British standard. The last one I think is most relevant is ANSI Z-10 occupational health and safety management systems document. Again, those you're going to have to pay for them. One thing I like about the ANSI Z-10, Tim, is that it has some, I don't know if you call them supplements, but they've got some really good sections on, for example, the severe injury fatality analysis and workplace violence is another section in that ANSI Z-10. I think it's just a really good resource. So, I guess that's my first advice. Get yourself educated, figure out what this is and what it entails and go from there.

Tim Leech (10:05):
We're kind of running out of time here, mark. But before we go, do you have any closing remarks?

Mark Lillemon (10:11):
My advice is really step out of your comfort zone. If you're a safety practitioner or manager coordinator, whatever your title and your role is in your respective organization and company. The first step is getting your senior management involved. You've got to have their support. That is a compelling message that has to be done with the senior executives, that this is a much more effective risk management approach, your safety program, significant returns of investment. The ROI are there. There's a lot of analytics that could be an entire another podcast for us, Tim. And again, emphasize that this can be integrated with other system-based management. It may already exist, in other parts of the organization, especially on the financial side and the operational side of delivering your services product or whatever may be. And the last is that think of this as a continuous improvement strategy, got this loop, this cycle. And that's really the essence of system-based approach is the continuous improvement. I think that's the icing on the cake.

Tim Leech (11:18):
Mark, this has been wonderful. It was a lot of great information, a lot of wealth of knowledge here. I want to just thank everybody that’s come on this podcast, taking the time to listen. It's just going to be one of several that we're doing throughout the month. We got a who's, who list of safety professionals that are, that are going to be on. And I think they'll be able to impart a lot of information that can help you in your various organizations as you look to reduce losses, protect employees and assets of the company. I'm happy to be a facilitator. If you're looking for information, you can email me And if you have a need, shoot me an email, I'll make sure that we get the right person in touch with you. And again, thank you for attending and have a very safe day.


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