The previous articles in this series outlined the essential components of a strong safety management system (SMS). To achieve safety success, electric power organizations must ensure those components align with and support one another.
This article – the last in the series – addresses two final topics of importance: assessing an organization’s SMS performance and implementing a structured corrective action plan in response to identified performance gaps. We will use ANSI/ASSP Z10-2019, “Occupational Health and Safety Management Systems,” as a guide, focusing on performance measurements, incident analyses, audits and corrective actions.
Measuring Operational Safety Performance
To accurately measure SMS functionality and impact, organizations must take a comprehensive approach that goes beyond tracking incidents and OSHA rates. Understanding past issues can be helpful but is insufficient to assess a company’s overall safety effectiveness. As previously noted in this series, some organizations have accumulated thousands of man-hours without any OSHA recordables, yet they still exhibit poor, misaligned work practices in the field.
OSHA highlights the use of leading indicators to accurately measure safety performance; doing so helps the workforce identify and address potential risks. Organizations struggling to develop metrics for leading indicators can consult ANSI/ASSP Z16.1-2022, “Safety and Health Metrics and Performance Measures,” as well as Chapter 17 of ASSP GM-Z10.100-2024, “Guidance and Implementation Manual for ANSI/ASSP Z10-2019 Occupational Health and Safety Management Systems.”
Comprehensive metrics empower electric power organizations to gain deeper insight into their safety performance and identify areas for improvement. Leaders, armed with detailed understanding of this data, can make informed decisions that enhance workplace safety protocols. Additionally, fostering a culture that prioritizes continuous improvement encourages employees at all organizational levels to actively participate in safety initiatives.
Measuring Employee Safety Performance
Some companies have long relied on lagging indicators (e.g., vehicle accidents, personal injuries) to measure employee safety performance. However, using these indicators for performance evaluations and incentive programs can lead to serious problems, as ASSP GM-Z10.100-2024 points out.
In my consulting work, I have observed that employer incentive programs often reward employees for avoiding incidents and injuries. Some companies even tie bonus payments to an entire crew’s record of zero incidents. In rewarding employees this way, leaders risk creating an environment in which employees feel pressured to hide events that do occur. They may hesitate to report injuries, equipment failures or near misses – critical information to help prevent recurrences.
As part of ensuring a truly safe workplace, organizations must periodically reevaluate their incentive programs and performance evaluations, determining whether it is possible to adopt a more proactive approach to safety. It is also wise to promote active employee participation in safety initiatives rather than reward individuals for zero incidents. This requires working diligently to foster an environment in which open discussion of safety concerns is strongly encouraged, inviting employees to share their thoughts without fear.
Further, leaders should strongly consider using awards, public acknowledgments during meetings and even small incentives to recognize employees who report hazards. Organizations that establish comprehensive feedback systems enable employees to share their experiences and suggestions, promoting transparency and the quest for continuous improvement.
Incident Analyses
The primary objective of an incident analysis – a systematic process used to identify an event’s root causes – is to gain a thorough understanding of what happened and then identify and implement corrective measures to prevent a recurrence.
It’s important to remember that incidents often reveal underlying issues that require immediate, decisive action. While a proactive SMS aims to identify and mitigate risks before incidents occur, we must acknowledge that this is not always possible. Therefore, analyzing incidents is a crucial component of an effective SMS.
Both incidents and near misses provide valuable opportunities to identify and address SMS weaknesses. Near misses in particular should be viewed as valuable learning experiences, offering chances to address hazards before they escalate. Some companies mistakenly view incident analyses as opportunities to assign blame; however, their time should be spent
identifying causes and improving safety processes that support workers.
An organization’s response to an incident is revealing. Many companies have been stuck in a long process of analyzing a single incident. By the time they finish, employees often feel frustrated or have forgotten about the analysis. Leaders should act quickly and keep open communication with employees during the whole analysis process.
Audits
Audits play an important role in assessing how well an SMS works, with auditors reviewing safety processes to ensure they align with organizational goals and meet industry standards. Conducting a thorough audit enables leaders to identify opportunities for improvement, confirm regulatory compliance and foster a culture of continuous safety improvement.
When focused on the following items, an audit helps affirm and improve organizational safety performance:
- System performance verification: Audits confirm that SMS components – including hazard identification, risk assessments, training and incident investigations – are functioning as intended and achieving the desired outcomes.
- Conformance assessment: Do organizational activities align with the objectives, policies and procedures established under the SMS?
- Identification of gaps and opportunities: Well-done audits highlight deficiencies, nonconformance and areas for improvement – a solid foundation for corrective and preventive actions.
- Continuous improvement: Audit findings ideally feed into management review and corrective action processes, providing opportunities to fine-tune the SMS based on factual evidence.
- Objectivity: ANSI/ASSP Z10-2019 emphasizes that audits should be conducted by individuals who are completely uninvolved with the activities being examined.
- Documentation and follow-up: Audit results must be documented, communicated to management, and tracked until corrective actions are implemented and their effectiveness has been verified.
To establish proper oversight and accountability, organizations must create a strong auditing plan that includes both internal and external audits. It is critical to set clear deadlines for planning, conducting and reporting on these inspections. This organized approach promotes transparency and facilitates timely action based on audit results, typically improving organizational performance while building trust with stakeholders. Regularly scheduled audits that align with a company’s goals are key to identifying improvement areas and supporting sustainable growth.
Internal safety audits are a necessity to accurately assess the impact of an organization’s safety objectives, policies and procedures. Their findings can offer valuable insights for corrective actions and management reviews, aiding in performance enhancement and continuous improvement in workplace safety.
External audits, on the other hand, deliver objective findings from knowledgeable third parties. These auditors possess specialized, impartial knowledge, often identifying issues that company insiders cannot due to their familiarity with the organization’s everyday functions. Unbiased evaluations are imperative to align with industry best practices and regulatory requirements. Organizations can also use them as a guide to improve safety and efficiency.
In combination, internal and external audits create a strong framework for regular safety checks, providing a comprehensive approach to quality and compliance validation that helps organizations consistently meet high standards.
Corrective Actions
To effectively employ the corrective action process, a company must first create clear procedures to identify, document and resolve safety-related problems. This proactive approach includes several key steps.
Identification
When a safety issue is identified – whether through an audit, inspection, incident investigation or employee reporting – step one is determining its root cause followed by controlling or eliminating the hazard.
Prioritization
Ideally, organizations will prioritize corrective actions based on risk level, with critical safety issues at the top of the list. It is crucial to assess the impact of these measures; this could involve monitoring the situation, gathering employee feedback and making sure the original problem is resolved.
Documentation
To assist with ongoing learning, transparency and accountability, organizations will want to carefully document their audit findings, the actions they took and any relevant communications. Sharing lessons learned across teams promotes a culture of safety and continuous improvement.
Improvement
A structured corrective action process can resolve immediate safety problems, improving the overall SMS. By learning from past experiences and making informed changes, organizations are likelier to prevent recurrences of similar issues, enhancing safety for all employees.
Summary
A strong SMS depends on continuous evaluation and corrective action. Guided by ANSI/ASSP Z10-2019, organizations must monitor performance using leading and lagging indicators, investigate incidents to identify their causes, and verify compliance via regular audits. A well-structured corrective action process will include documenting safety issues, prioritizing them by risk and tracking progress to confirm their adequate resolution. Together, these practices aid electric power organizations as they build proactive safety cultures focused on prevention, accountability and continuous improvement.
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 25 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.
