Safety By Design: Safety Management System Planning

In the first two parts of this six-part series, I discussed the importance of creating and implementing a safety management system (SMS) that actively involves all employees. This part will focus on (1) identifying and prioritizing an organization’s safety needs based on specific hazards and risks and (2) developing a plan with clear objectives and targets to meet those needs. Without a solid plan, it’s difficult to assess whether the SMS is effective and adds value to your organization.

Early in my career, I didn’t fully grasp the significance of having a safety plan. I often experimented with new safety trends without understanding what the organization I worked for would gain from them or how success would be measured. Much like a New Year’s resolution, proclaiming you are going to create positive change in the workplace is far less challenging than designing and executing a plan to hold yourself accountable, measure your progress and adjust when things aren’t going well. Many New Year’s resolutions fail due to lack of measurable plans; the same is true with safety.

ANSI/ASSP Z10-2019, “Occupational Health and Safety Management Systems,” defines “planning” as identifying and prioritizing safety issues, establishing goals and objectives for improvement, and creating implementation plans with resource allocation. The planning process consists of four main steps:

1. Identifying occupational health and safety (OHS) issues within the organization, including hazards, risks, system deficiencies and improvement opportunities.
2. Prioritizing identified OHS issues based on their importance to the employer.
3. Establishing OHS objectives to improve the effectiveness of safety initiatives and reduce risk.
4. Creating an OHS implementation plan that specifies tasks and responsibilities to meet those objectives.

Identifying OHS Issues
A thorough assessment of your organization’s current safety performance is needed to uncover any gaps that require attention. This means identifying the resources and protocols in place, considering whether there are missing OHS elements that could enhance employee safety, and evaluating which initiatives will foster a safer work environment. These insights will help you make more informed decisions to better protect your workforce.

Lagging Indicators
Some organizations look to the absence of injuries and illnesses to measure their safety performance. However, OSHA recordable and lost-time rate charts (i.e., lagging indicators) will not directly correlate past performance to future outcomes. Further, when lagging indicators are used in meetings to illustrate an organization’s level of safety success, it can be tough to secure senior leader buy-in for required safety processes and initiatives. That’s because lagging indicators are weak metrics that shouldn’t be used as an organization’s only safety performance measure.

In my role as a consultant, I’ve encountered employers with thousands of man-hours and no lost-time incidents. Yet after completing field observations that included employee engagement, I’ve often been amazed that injuries and fatalities hadn’t occurred given the number of missing or misaligned safety initiatives that supported high-risk work. We must acknowledge that sometimes we’re simply lucky when nothing goes wrong – and we all know luck runs out eventually.

Safety Gap Analysis
Conducting a safety gap analysis is the first step in assessing an organization’s current state of safety. This systematic review compares existing safety measures and practices to desired or required standards, with the goal of identifying both gaps in the current system and opportunities for improvement. I recommend these resources to assist employers in the development of a gap analysis protocol that’s based on industry best practices:

• ASSP GM-Z10.100-2024, “Guidance and Implementation Manual for ANSI/ASSP Z10-2019 Occupational Health and Safety Management Systems.”
• ASSP GM-Z10.101-2019, “Guidance Manual: Keep Your People Safe in Smaller Organizations.”

An important part of the safety gap analysis is evaluating what I call the “look of safety,” which involves strategically identifying hazards, assessing their risk levels and implementing appropriate controls. Because hazards in electric power systems present great risk, they must be recognized based on the actual work performed rather than just planned or theoretical work. According to ASSP GM-Z10.100-2024, many organizations overlook that hazards are not static; rather, they’re dynamic and constantly changing. To identify gaps in any safety processes that were developed solely based on planned or theoretical work, it’s crucial to conduct field observations and maintain open communication with employees.

Understanding how work is performed in the field allows organizations to gain deeper insights into employees’ daily challenges, which can lead to innovations that enhance operational success. In the second part of this series, I explained how middle managers can hinder safety initiatives. These managers play a crucial role in understanding how work is planned versus how it is executed, as well as how employees’ decisions impact their work. Often, middle managers develop job plans based on a limited perspective that can become skewed if they don’t regularly visit job sites to observe work practices. This should be carefully considered during any safety gap analysis.

Prioritizing OHS Issues
Once gaps have been identified, they may indicate the need for changes in culture, resources, leadership styles, behaviors, systems and equipment, or other areas. To facilitate meaningful improvement, employees at all levels of the company must openly and honestly address the analysis results. One of my ongoing recommendations is to initially focus on operational improvement opportunities that will provide the greatest rewards in terms of risk mitigation.

Recently, while presenting the results of a gap analysis, a senior leader asked me, “Are we doing anything right?” The identification of safety gaps calls attention to organizational weaknesses. Acknowledging these weaknesses can feel challenging to leaders, yet doing so is essential to accurately assess risk levels. Senior leaders must define the organization’s risk tolerance and work with middle managers to develop implementation plans for operational improvements.

Systems Thinking
It’s also crucial to adopt a systems-thinking approach when prioritizing safety issues. This is a more comprehensive, effective way to manage risks as it focuses on how various system components interact with and influence one another to create a safe environment. The approach involves looking at the big picture, recognizing complex relationships and learning how decisions made in one part of the system can impact other system parts. Applying this approach can address operational challenges that don’t adequately support employee safety, helping to resolve numerous OHS issues.

Establishing OHS Objectives
Setting objectives that are specific, measurable, actionable, realistic and time-oriented (SMART) is an essential, powerful practice to improve organizational safety. Improvement occurs when company leaders track, monitor and evaluate these objectives. Chapter 8 of ASSP GM-Z10.100-2024 provides an excellent example of how to use SMART objectives when planning and setting goals.

Leading indicators promote ongoing improvement by highlighting deficiencies in the SMS and prompting necessary adjustments. Key performance indicators (KPIs), emphasized throughout this series, should be considered one of the most important elements of an effective SMS. KPIs are leading indicators that enable an organization to identify, measure and address issues within the OHS objectives before a significant injury or illness can occur. By monitoring KPIs and other leading indicators, organizations can uncover and correct weaknesses in procedures and unsafe employee behaviors before harm can happen.

Overall, tracking and addressing leading indicators is needed to create a safer work environment and enhance organizational effectiveness. Chapter 17 of ASSP GM-Z10.100-2024, “Metrics and Measurements,” is a good resource to learn more about using them.

Creating an OHS Implementation Plan
An OHS implementation plan outlines an organization’s strategy and process to create and maintain a safe work environment. Once SMART objectives have been established, the implementation plan should cover the following aspects at a minimum: strategy; communication of the plan; implementation of each objective; a timeline; an accountability process; assigned KPIs; and a method for tracking continuous improvement. Regularly evaluating and improving the plan is key to ensuring its effectiveness.

Summary
An effective SMS begins with a solid foundation: planning. Organizations must first perform a gap analysis to understand their current state of safety; then prioritize OHS issues based on risk; and finally establish realistic improvement objectives and an implementation plan supported by strong leadership and systems thinking.

Lagging indicators alone are insufficient to measure safety performance. Instead, leading indicators and continuous monitoring of key performance metrics should drive safety decisions. Implementation plans must be strategic, measurable, and integrated into the organization’s culture and operations.

Ultimately, achieving safety excellence requires more than regulatory compliance. With thoughtful planning and a commitment to continuous improvement, organizations can develop safer, more resilient work environments.

About the Author: Pam Tompkins, CUSP, CSP, is president and CEO of SET Solutions LLC. She is a 40-year veteran of the electric utility industry, a founding member of the Utility Safety & Ops Leadership Network and past chair of the USOLN executive board. Tompkins worked in the utility industry for over 20 years and has provided electric power safety consulting for the last 20-plus years. An OSHA-authorized instructor, she has supported utilities, contractors and other organizations operating electric power systems in designing and maintaining safety improvement methods and strategies for organizational excellence.