Are We Safe Yet? How Do You Know?
How do you know your company is safe? You should already have some clues beyond your OSHA injury rates and other lagging indicators. A lack of recent (reported) injuries is a demonstrably poor indicator of overall safety – especially for serious injury and fatality potential. So hopefully you are also getting real-time input from both employees and managers as well as leading indicator data (e.g., observation input, overdue corrective actions, etc.). As valuable as this information is, it is never sufficient and requires analysis to give you an objective and realistic view of safety overall. Thus, the importance of periodic performance-based assessments (PBA).
What Is a Performance-Based Assessment?
Perhaps it is best to start with what they are not. Specifically, performance-based assessments (PBA) are not traditional compliance-based inspections. Performance-based assessments (PBA) do not search for non-compliances but rather analyze issues that materially impact safety in a demonstrable way. They are also not aimed at observing any specific worker behaviors but rather at the work as a whole. The goal of PBAs is not to modify the workers but to serve as a reality check and feedback mechanism to provide organizations with sufficient information, and analysis, to continually improve any aspect relevant to meeting its safety goals, objectives and programs. Unlike compliance inspections, PBAs need not have a regulatory basis for their findings. There is, however, a place for compliance inspections. For example, critical safety-related valve alignments in commercial nuclear plants must be inspected and verified that they are in the correct position. Some systems are so critical they may even require redundant (independent) inspections. But if you want to take the pulse of the effectiveness of your safety effort you won’t get there measuring compliance. Safety resources are finite, and we have a responsibility to use those resources wisely.
“In order to maximize value, limited resources must be applied where they will do the most good. Assessment resources should focus on how the work is actually performed rather than on requirements that may or may not be relevant.” Jim Loud Professional Safety, 1996.
“Assessments should be performed in a manner that emphasizes safety and reliability. Not trivia with no real impact on facility performance.” NRC Policy Issue (SECY-87-220).
“…a good audit (i.e., assessment) is about discussion and analysis. It is about continuous improvement instead of fixing non-compliances.” Carsten Bush, Safety Myths 101.
Performance-Based Assessment Essentials
While compliance inspections tend to examine spaces and individual behaviors, performance-based assessments (PBA) focus on the work, especially safety and mission critical work. PBAs use a variety of techniques to inform their analysis but these three are foundational:
- Observations – The observation of real-time work activities is considered the most effective technique for determining performance adequacy. The primary goal during observation is to obtain the most complete picture possible of performance vs. desired results and criteria identified prior to beginning the assessment.
- Document Reviews – Document reviews are used extensively in PBAs to substantiate the information obtained during interviews and observations. During the course of an assessment, questions may arise concerning what is seen and heard. A review of relevant documents (including logs, procedures, work-orders, and other data) provides a method for answering these questions and validating the PBA findings.
- Interviews – Interviews are often used to help determine where to focusother observation techniques and to identify problem areas requiring further review. Interviews also provide a means to verify the results of observation, document review and other techniques.
Other PBA techniques may include inspections or demonstrations (when activities of interest do not occur during an assessment visit) depending on how much additional information is needed to determine assessment issues.
Summary
Comprehensive feedback is necessary to truly understand where you are in your safety journey. Inspections can add value to the safety effort as well. But traditional compliance inspections targeting conditions and/or behavioral compliance can’t be the end of the story. In too many cases we’ve put too many resources and too much finite safety energy into compliance efforts at the expense of a more holistic and effective assessment process. We can and should do better. Subsequent articles will discuss how to drive continuous safety improvement via effective conduct of performance-based assessments (PBA).
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AUTHOR BIO
Mr. Loud’s over 40 years of safety experience includes 15 years with the Tennessee Valley Authority (TVA) where he served as the supervisor of Safety and Loss Control for a large commercial nuclear facility and later as manager of the corporate nuclear safety oversight body for all three of TVA’s nuclear sites. At Los Alamos National Laboratory he headed the independent assessment organization responsible for safety, health, environmental protection, and security oversight of all laboratory operations.
Mr. Loud is a regular presenter at national and international safety conferences. He is the author of numerous papers and articles. Mr. Loud is a Certified Safety Professional (CSP), and a retired Certified Hazardous Materials Manager (CHMM). He holds a BBA from the University of Memphis, an MS in Environmental Science from the University of Oklahoma and an MPH in Occupational Health and Safety from the University of Tennessee.
