A critical review, from an industrial relations perspective, recent Occupational Health and Safety (OH&S) policy, and a case study of policy implementation in the CSR organisation
Teresa Dwight
As a requirement of OH&S implementation within an organisation, the CSR policy objectives and implementation must comply with Commonwealth and State legislative goals and objectives (CCH Australia 1993:201). The National Occupational Health and Safety Commission (NOHSC) have been aiming for nationally uniform standards since it began in 1984. The differences in OH&S policy between states cause problems for implementation and enforcement (Industry Commission, Volume 2 1995:xxvii). However, so far the heads of government have been unable to agree on uniform objectives and strategies (Industry Commission, Volume 1 1995:xxviii). As a result of this, the new National Strategy (2002 – 2012) has taken active approaches in reducing problems associated with self-regulation such as the difficulties of individual organisations to effectively implement effective strategies due to lack of knowledge and resources (Gary Chaplin 2002:4). The NOHSC has developed a new scheme which aims at enabling simplified and more accessible OH&S information for business, including data, data analysis, and qualitative analysis of effective approaches (NOHSC 2002:3). The NOHSC hopes that this policy will enable more educated and effective policy and implementation strategies (NOHSC 2002:9).
National standards are legislated by the Occupational Health and Safety (Commonwealth Employment) Act 1991. The National Strategy (2002 – 2012), states that its new objective is to further minimise the incidence of workplace related injuries and deaths (Queensland government, Department of Employment and Training 2002:3). Although it can be noted that illness and disease do not appear to be included in these objectives, the NOHSC do include it as one of the five priority areas for active approaches (Queensland Government, Department of Employment and Training 2002:3). This new strategy aims to encourage a more thorough and proactive approach, by increasing the level of education and information available to managers and employees, lifting safety standards (NOHSC 2001:1). However, the NOHSC does not directly address the issue of forfeiting production levels for safety, as Gary Chaplin suggests (2002:40) is sometimes necessary.
In Queensland, OH&S law is set out under the Queensland Workplace Health and Safety Act 1995, and OH&S policy is managed by the division of Workplace Health and Safety. The state Act does not contain many innovative strategies to minimise or reduce workplace injuries and illnesses. The main guidelines are focused on concepts of enforcing general obligations and evaluating individual implementation strategies (Queensland Government Workplace Health and Safety 2002:1)). The values of state policy, “commitment to ensuring maximum compliance with health and safety standards” (Queensland Government Workplace Health and Safety 2002:1), implies that state policy tends to leave development of these standards and procedures to the Commonwealth and to individual industries. The Queensland Act’s emphasis on ‘responsibility’, as opposed to ‘duty of care’, as specified in the National Act (Queensland Government Workplace Health and Safety 2002:1), further suggests that the Queensland Act’s major function is of enforcement.
How well CSR policy complies with Commonwealth and State objectives is an important part evaluating its effectiveness and plausibility. CSR’s policy states that:
‘We recognise that Safety, Health and Environmental responsibility is a vital part of our business. We are all responsible for: not injuring people, not causing occupational illnesses, minimising the adverse impact of our activities on the environment, complying with all legal requirements.’
(CSR Policies and Management Systems 2002:1)
It can be inferred from this policy statement that it is an objective of the CSR to comply with Australian government and international standards. By being self-insured, CSR indicate that they have some degree of solid commitment toward their statement policy that OH&S is, “a vital part of our business.” (CSR Policies and Management Systems 2002:1). Furthermore, contrary to the National Strategy, CSR policy recognises illness and disease of equal importance to injury and death. According to Gary Chaplin (2002:2), it is estimated that there are approximately four times the amount of deaths by illness per year, than deaths by trauma. This implies that reducing illness and disease is just as much, if not more of, a priority in reducing the human costs of OH&S as reducing deaths and injuries. Within CSR there has been a change of policy basis in addressing the human costs of OH&S. The concept assumes that for every one fatality there are 30 recordable injuries, 300 medical treatments, 3000 near miss or first aid, 30,000 unsafe acts (CSR 2002:1). By addressing the unsafe acts rather than the fatalities, the CSR has taken a more thorough approach. This focus on addressing causes rather than effects, works well with the suggestion that illnesses and disease are just as important manifestations of problems with OH&S as injuries.
Policy development is strongly affected by underlying theory and the factors of the problem that the policy wishes to address. Traditional OH&S theory can be streamed toward an inevitable accident approach, a ‘careless worker’ approach or a multiple causation approach (Chaplin 2002:7). The inevitable accident approach basically implies that injuries are not preventable (Chaplin 2002:7). This approach means that many responsibilities can be negated and hazards that could have been avoided are not addressed (Chaplin 2002:5). The ‘careless worker’ approach implies that injuries and illnesses are the fault of the worker (Chaplin 2002:7). This can result in polices that cover overt manifestations of OH&S problems but increase problems with covert manifestations. The multiple causation approach is an approach to OH&S that the NOHSC is promoting now. It involves that theory that accidents have many causes (Chaplin 2002:7). For example, the equipment may need fixing, the person may not know how to use the equipment, or they may be tired or in a hurry. The aim of this policy is find the underlying causes and try to remove as many as possible.
The theory behind CSR policy is the best explained in terms of the ‘three P’s’ approach (CSR Managing Safety 2001:1). The ‘three p’s’ include people, plant and procedure, where importance is placed on all aspects of workplace safety implementation. The CSR reasons that all aspects must be equally maintained, otherwise, like a three legged-stool without one of its legs, the system will fall over (CSR Managing Safety 2001:1). This theory seems to comply with a multiple causation approach. According to Shaw, Chase Moore and Toohey (1994:77), this approach is the most effective approach as it addresses many aspects of the problem. Furthermore, CSR state in their policy theory that all accidents are preventable (CSR Policies and Management Systems 2001:1), which emphasises that the theory behind the policy is proactive and based on cost efficiency in minimising workplace injury. As a result of addressing the problem more laterally, implementation is more thorough.
Of major importance in OH&S policy is the standard of implementation and how well implementation strategies fit in with policy. An organisation cannot have effective OH&S policy if it is not properly implemented (Walsh and Russell 1974:41). The qualitative approach to OH&S implementation involves changes in traditional forms of implementation. Traditional forms of implementation are reactive and tackle problems with set procedures when they occur (Sutherland, Makin and Cox 2000:10). This means that injuries and diseases can never been prevented. It is also important to encourage the reporting of accidents (Sutherland, Makin and Cox 2000:10). The behaviour-based approach, which addresses cause rather than effect, is a form of policy, which assists in implementing this. CSR’s theory of 1 fatality and 30 000 unsafe acts is similar. There can be problems with budgeting when financial administrators cut back on OH&S procedures (Sutherland, Makin and Cox 2000:9). This only causes more long-term OH&S costs.
The implementation of CSR’s policy incorporates a wide range of forms of implementation. In regards to CSR’s theory of the three-legged stool, plant, procedure and people, the implementation appears to be just as thorough. CSR place emphasis on their commitment to communication and working together (CSR Managing Safety 2001:1). Communication is an important factor in effective implementation of policy, all people; workers as well as managers need to be aware and involved in the procedures (Sutherland, Makin and Cox 2000:6). Traditional methods of safety used by CSR include safety instructions, training, and thorough induction procedures to acquaint workers and visitors with procedures (CSR Policies and Management Systems 2001:3). CSR goes further than just having committees and meetings. They state that they are involved in implementation and evaluated progress yearly (Policies and Management Systems 2001:5).
A quantitative approach is also required in the evaluation of OH&S implementation. The CSR uses available data to measure its comparative progress in improving OH&S (CSR Health and Safety Performance 2001:1). This suggests that the CSR is one organisation that is working well with the National Strategy in its aim to improve an organisation’s ability to self-regulate. However, as Gary Chaplin (2002:4) points out, the problems with self-regulation mostly stem from the abilities of small business to keep up with OH&S standards. A traditional form of statistical measurement of workplace injury is the frequency rate, or the number of accidents and the severity rate, or the number of working days lost (Walsh and Russell 1974:41). CSR appears to continue this traditional approach by monitoring its safety performance by using lost time injury frequency rates and total recordable injury frequency rates as measurements (CSR Health and Safety Performance 2001:1). These forms of measurements indicate that a major incentive for CSR’s engagement in OH&S is the cost efficiency of reducing associated expenses involved in workplace safety. CSR claims that both these rates have fallen in the last year. Last year the lost time injury frequency rate fell 14% and the number of injuries decreased 26% (CSR Health and Safety Performance 2001:1). The types of injuries tend to be from accidents with machinery. Although the implementation of policy has not improved statistics greatly, there appears to be no increase in deaths and injuries in CSR. This reflects well on the policy because it will take time for improvements to manifest themselves (Quinlan 1993:4).
Conclusion
CSR policy objectives appear to be well in touch with current OHS legislative and theoretical standards. Furthermore, its implementation strategies appear to be thorough and interact appropriately with its own policy objectives as well as traditional and legislative OHS standards, procedures and theory. However, it does not appear that these strategies have had the affect required. It is likely that policy and implementation strategies have not had the chance to bring any solid results. In compliance with NOHSC strategies, this particular organisation appears to be working well. Despite the lack of results so far, it is hopeful that it is too early for any real affects to be shown and that OHS strategy, policy and implementation improve for the benefit of business in Australian industry.
References
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copyright, 2003