Safety Reporting in Safety Critical Industries

Employees in safety critical organisations should report both incidents and near misses. SCT’s Mario Pierobon reports.

Safety reporting has been implemented for several decades in a range of safety critical industries. Reporting serves to identify accidents, hazards and scenarios of possible accidents. The overarching aim is to ensure that organisations operating in safety critical industries are implementing the necessary measures to prevent accidents and limit their impact and consequences. In this article we will consider the need for reporting, incident management systems and best reporting practices at the operational level, the use of safety data analysis, and the ways employees can support safety reporting practices.

The Need to Report

In the United States, the Occupational Safety and Health (OSH) Act of 1970 assures safe and healthful working conditions in the workplace by authorising enforcement of the standards developed under the Act, by assisting and encouraging the States in their efforts to assure safe and healthful working conditions, and by providing for research, information, education, and training in the field of occupational safety and health. “Under the OSH Act, employers are required to provide a workplace free from serious recognised hazards and comply with standards, rules and regulations issued under the OSH Act”, says a US Department of Labor spokesperson. “Employees who believe their working conditions are unsafe or unhealthful may file a confidential safety and health complaint with the Occupational Safety and Health Administration (OSHA) and ask for an inspection. If possible, workers should tell their employer about their concerns”.

It is in this communication between workers and employers on safety matters that incident management systems come into play. An incident management system should clearly define how incidents will be reported, recorded, investigated, and shared within an organisation, observes the Australian Nuclear Science and Technology Organisation (ANSTO), a Commonwealth Agency. “It should have a holistic approach that defines what an incident is. Other incident types may also provide insight into emerging safety issues, for example, environmental or operational incidents may be an indication of failing controls”, says an ANSTO spokesperson. “This definition is critical as it will influence what is reported. It should not only cover an occurrence that has caused harm, but it should also cover occurrences that have the potential to cause harm and are perceived to cause harm, including an abnormal occurrence, i.e., something that was not expected - even if there were no consequences”.

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Main Elements

Indeed, safety incidents should not only include incidents that have caused actual harm to people, facilities, infrastructure, plant, or equipment. An incident management system should also be able to record near misses, hits, hazards, and safety observations. “An incident management system should define an investigation methodology with a primary focus of determining what happened and why but without the apportionment of blame”, says an ANSTO spokesperson. “The methodology ensures that not only direct and contributing causes are identified but more importantly the root causes. These can include the use of tools such as with the Ishikawa methodology. It should not only look at what went wrong but also at what went right, and it should identify effective actions for preventing the same or similar incidents reoccurring complying with the requirements or relevant legislation”.

An incident management system provides timely reporting of trends and emerging issues not only to senior management but to all employees and it clearly defines what type of incidents need to be notified to Safety Regulators, which provide definitions and reporting timeframes. “Some industries are required to have specific elements in their incident management systems, but if this is not required, the system should include elements that are related to the organisational risk profile and regulatory requirements”, says an ANSTO spokesperson. “The benefits that the organisation can have are numerous. Among them there is an improved user interface based on the feedback received. Safety reporting enhances traceability by identifying incident hot spots - which could be causes of incidents – as well as specific activities or areas. Real trend data analysis round where the same mistakes are being repeated puts effort into corrective actions, so that they may be eliminated. Data can also be used to drive and provide justification for change. Other benefits are that incident management systems are linked to risk management and confirm if controls are effective, they have access to databases of information and lessons learned reports, and they enable more accurate, effective and automated reporting abilities”.

Effective safety reporting practices in the line environment demonstrate whether adequate safety and reliability are incorporated in the design, construction, operation and maintenance of any installation, storage facility, equipment and infrastructure connected with its operation which may be linked to major accidents or hazards. In addition, effective safety reporting practices ensure that internal emergency plans are available and may also supply information as to the effectiveness of the emergency response plans of third parties. “A safety reporting system clearly defines the responsibility of employees, line managers, senior managers and other stakeholders. Generally, it is the responsibility of employees to report incidents as soon as possible. Management has a responsibility to investigate, identify improvements and ensure that they are implemented so as to prevent a reoccurrence”, says an ANSTO spokesperson. “While the organisations also have a responsibility to share lessons learnt, management has the responsibility to review the information and determine the impact to their areas”.

Data Analysis

OSHA’s Site-Specific Targeting programme uses injury and illness data submitted annually by employers to direct agency enforcement resources to establishments with the highest rates of injuries and illnesses. Additionally, OSHA implements national and local emphasis programs to target high-risk hazards and industries. “Existing and potential new emphasis programs are evaluated using inspection data, injury and illness data, National Institute for Occupational Safety and Health (NIOSH) reports, peer-reviewed literature, analysis of inspection findings, and other available information sources”, says the US Department of Labor.

Analytical tools can be used more broadly to analyse past performance in the perspective of preventing future safety events and to timely identify any trends or emerging issues, depending on the type of incident. “This data can then feed into safety interactions, safety initiatives or safety interventions that focus on the identified issues”, says an ANSTO spokesperson. “Safety reporting practices should include an incident reporting system that allows incident information and data to be collected, stored, analysed and reported. The system should be easily accessible and user friendly, e.g., online solutions readily available to all employees and that can be accessed by contractors, collaborators etc. By collecting data on near misses, hazards and observations one can analyse what has the potential to cause harm”.

It is necessary that the data collected be relevant to the organisation and linked to its risk profile. “Information that can be collected and can assist in trending includes location of incidents (by area and work group), date and time, actual and potential impact of the incident and lists of potential causes of incidents that can be analysed for trends”, says an ANSTO spokesperson. “These need to be based on the organisational risk profile and some regulators have these lists available. In addition, the types of incidents - e.g., injury, near miss, hazard, chemical/biological/radiological exposure etc. - also need to be collected”.

The incident management system should provide a uniform and transparent approach of how incidents are reported, investigated and information shared. “It should have the capability to record data on incident notifications, incident investigations as well as corrective actions and it should ensure that the data is easily accessible for analysis to identify trends and emerging issues”, says an ANSTO spokesperson. “Being able to identify the actual versus the potential impact of an incident is also important, as, for example, a hazard may have additional damaging potential on equipment damage and worker injuries. Analysis should not only trend the incidents that are commonly occurring but also have the potential to identify the high consequence low frequency incidents”.

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The Contribution of Employees

Employees play an important role in the effectiveness of the incident management system and they can help with safety reporting practices. Indeed, the human component of corporate health and safety is very important. OSHA recommends that employers implement a safety and health programme to prevent workplace injuries, illnesses, and deaths, as well as the suffering and financial hardship these events can cause for workers, their families, and employers. “Employers will find that implementing these recommended practices brings benefits. In fact, safety and health programmes help businesses prevent workplace injuries and illnesses, improve compliance with laws and regulations, reduce costs, including significant reductions in workers’ compensation premiums, engage workers, enhance their social responsibility goals, and increase productivity and enhance overall business operations”, notes the US Department of Labor.

In addition to encouraging workers to participate in the safety and health programme, employers should encourage workers to report safety and health concerns. “Workers are often best positioned to identify safety and health concerns and program shortcomings, such as emerging workplace hazards, unsafe conditions, close calls/near misses, and actual incidents. By encouraging reporting and following up promptly on all reports, employers can address issues before someone gets hurt or becomes ill”, says the US Department of Labor. “Workers must also feel that their input in a safety and health programme is welcome, their voices will be heard, and they can access reporting mechanisms. Workers may not participate if language, education or skill levels in the workplace are not considered”.

Establishing a process for workers to report injuries, illnesses, close calls/near misses, hazards, and other safety and health concerns, responding to reports promptly, and reporting back to workers routinely and frequently about action taken in response to their concerns and suggestions are part of the process that can be used to encourage workers to report safety and health concerns, according to the US Department of Labor. “Other points in this process are to emphasize that management will use reported information only to improve workplace safety and health and that no worker will experience retaliation for bringing such information to the attention of management and empower all workers to initiate or request a temporary suspension or shut down of any work activity or operation they believe to be unsafe”, says the US Department of Labor.

Employees may not participate if they fear retaliation or discrimination for speaking up, for example if reporting an incident or concern could jeopardize the award of incentive-based prizes, rewards, or bonuses. “Incentive programmes - such as point systems, awards, and prizes - should be designed in a manner that does not discourage injury and illness reporting; otherwise, hazards may remain undetected”, says the US Department of Labor.

Indeed, in the past targets and incentives have been used to motivate employees in reporting incidents. “These can have a negative impact on safety as employees modify the reporting to meet the target rather than openly reporting all incidents. Sharing of information, lessons learnt, and changes that have occurred due to incidents being report can motivate employees. If they see that things change because they report incidents, they will feel empowered”, concludes an ANSTO spokesperson.