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Didn't you read the policy?

Posted 31-Jul-2008 by brian.nodwell  and filed under: Policy Acknowledgement, Safety Management System
...probably not.

Organizations spend countless hours preparing, editing, distributing and reviewing policies, yet they rarely get read.  Most employees will admit after some prompting that they really didn't read through the policy manual they were handed on their first day with a new company.  This is because:
    1.  There can be an awful lot of policies to read through.
    2.  The policies are long and often very dry.
    3.  Many of the policies do not seem to apply to the employee.
    4.  Employees have more pressing things to do.
    5.  Nobody seems to care whether they read the policy anyway.

Let's face it, many companies create policies simply to satisfy regulatory requirements or to obtain a safety Certificate of Recognition.  So what ends up happening is countless policy binders get printed, only to collect dust on bookshelves.  This creates a culture of indifference toward policies that will ultimately hurt the company when a policy violation leads to a compromising situation for the company.

For example, imagine that a company implements a speeding policy.  The stated objective is to reduce the risk of an accident, but more likely than not, it is at the request of a customer or industry group.  According to the new policy, management is required to monitor speeding in company vehicles and discipline employees accordingly.  Yet employees, indifferent to the policy, speed regularly while driving company vehicles.  Managers, vaguely aware of the policy, are more interested in getting workers to the job site on time than in preventing speeding.  Then the unthinkable happens; an employee is involved in a serious accident, and speed is determined to be a contributing factor.  Will the fact the company had a speeding policy help their defense in court?  Or will it expose them to additional risk, for not exercising the care and attention the policy required?  My guess is the latter.

Policy binders are about to get much larger too.  Many large energy and construction companies in the US (and now Canada) require their contractors to join ISNetworld and comply with the safety policy Review and Verification Service, or RAVS for short.  The policy requirements are based on Occupational Health and Safety regulations in each jurisdiction.  Here in Alberta, there can be as many as 39 different protocols, depending on the type of work a company performs.  And it's not enough to have a policy, it must match the criteria set out in the regulations.  The policies are so complex in fact, that consulting companies (like Workforce Compliance Safety here in Calgary) do a fine business simply helping their clients through the process of becoming RAVS compliant.

Policies are an integral part of a company Health and Safety Program, but we're "improving" them to the point that they're becoming almost ineffective.  I am writing this post to open a dialog on how to increase the size and complexity of policies, while still keeping them relevant and interesting for employees to read.

My personal opinion is that the largest challenge lies in effectively disseminating the policies to employees.  We've created a policy management tool that allows safety administrators to load their policies into our portal, then assign the policies to various positions within the company.  As employees log onto the SafetySync safety management system, they are prompted to individually review and accept (or decline) the various outstanding policies.  The tool has been designed to track and manage minor and major modifications.  Major changes are saved as a new version, which employees are required to accept a second time in order to remain "compliant".  The policy component is in Beta testing at the moment, so clients are encouraged to try it out and provide feedback.

If you don't have an account, feel free to sign up for our software and try it out (as well as the other safety management components we offer).

Comments

Comment by Murray Sunstrum on 18-Feb-2009

"...And it's not enough to have a policy, it must match the criteria set out in the regulations. ...."

This is one of the depressing findings of the ISN RAVs review process: many companies do not have policies to meet the minimum requirement of regulation.

I find this is why ISN in combination with a COR can be so powerful. It combines the 'paper' requirements with a living, breathing system.

Keep up the blogging!

Comment by Nattalie Cabay on 05-Feb-2010

ISNetworld costing contractors in lost employment for companies and employees.

I'm not convinced this is the way of the future!!!! I have run into multiple problems with ISN and their grading. For example, rejecting my insurance when all the required information was on the certificate of insurance. I had to call and talk to a supervisor to only be told that they didn't know why it had been rejected, so they then accepted it. Again, I was sitting with all "A's", all was good on my part. I received my W.C.B. rate sheet for 2010, and submitted it. It was verified, then two days later I check the grading system and I was now a "D" with some companies. I called the help desk to find out what was the problem. They told me that it was because my 2009 WCB rate sheet had been bumped, even thought it had been in the system for over a year. I once again called the help desk to only be on the phone for an hour, to be told that they once again don't have any explaining on why it had been bumped and that my grading should be all "A"'s in the morning. Guess what, it wasn't. I then again was on the phone with ISN for another hour waiting to see what they were doing. I requested to speak to a supervisor as the help desk employees don't know much. They have put a team on it. They can see that all the requirements (documents submitted and questionairs are answered. Because of their incompetence, we are unable to work for these companies, thus loosing company income and employees not being able to go to work, thus loosing money in their pockets as well. These are just a few of the problems that I'm running into. We pay their annual fee expecting performance on their end as well, and we are not receiving it. It is only creating headaches for the safety person, and costing office personal their time. If I was not as diligent with checking ISN throughout the day. I would just assume that all my stuff is good & that they know what they are doing on their end. But as it turns out, they don't!!!!!! To eveyone else out there, make sure you check your grading and documents daily. THEY MAKE LOSTS OF MISTAKES IN TEXAS AND IT ONLY COSTS US!!!! Don't assume they are always right. I told the supervisor that I really didn't think that they would like an invoice for lost income or a law suit against them. Still waiting to hear from the ISN team on correcting this error for me.

Comment by CanadaNorth on 24-Aug-2010

Compliance with ISN did not do any thing to prevent the deaths of 11 workers in the Gulf of Mexico and the resulting injuries to the other workers. Where was ISN's vaunted safety protocol then. ISN is a backstop to prevent executives from being prosecuted for lack of due diligence and to also help prevent executives from being personally sued for monetary liability. The convoluted way ISN is set up proves it to me anyway.

CanadaNorth

Comment by M. Sherwood on 21-May-2012

Getting safety programs approved through ISNetworld is a very tedious task. My recommendation is to go through each requirement and bold it. I also suggest making sure that you put the exact page number where the particular requirement is located. This usually makes the process smoother because if the ISN staff can find the requirement easily, they are less likely to reject the document. Also, your company knows that the requirement has been met and exactly where it is too.

The biggest mistake people make is they just submit whatever safety program that they have without really putting the necessary time in to review it for compliance.

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