Chapter 7 - Discussion
CHAPTER 7 – DISCUSSION
Scope of Discussion
7.1
Upon review of the results of the survey, discussion is focused on the elements
related to the deficiencies in planning and implementation of OHSMS of the
XYZ Company with an aim to substantiate the hypothesis on the factors
affecting the planning and implementation of OHSMS. The scopes of discussion
include the following areas:

Management strategy, policy and commitment

Management structure and responsibilities

Participation, consultation and communication

Training and technical competence

Integrated management and operations

Performance benchmarking and Objectives

Best practice and safety culture

Planning for implementation
Management Strategy, Policy and Commitment
7.2
In the case study, the XYZ Company did set up their safety policy with the
policy statement endorsed by the CEO. However, numbers of defects were
identified in the XYZ’s policy statement, like health aspects, integration,
commitment to compliance of statutory requirements and OHS of
contractor and visitors. Inconsistence was also found in their incident-free
policy while they tolerated risk to a certain degree under the ALARP
principle of their Risk-based safety management system. Obviously, it was
found that the health surveillance programs and the contractor safety
control program of the XYZ Company have not been properly set up in the
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organization. Coincidently, they are the missed concerns in the policy
statement. A policy statement is a vehicle to convey management strategy
to all staff. It provides directions and guidelines for line management to
plan and execute their OHS programs. It proves that effective planning and
implementation of OHSMS relies very much on the policy setup which is
one of the essential inputs for formulation and implementation of OHS
processes. As highlighted in ILO Universal OHSMS model in Figure 3.6,
outputs are generated corresponding to necessary inputs. We cannot expect
to produce any output without provision of required input. Policy
deficiencies provide uncompleted management objectives and directions
for effective planning and implementation of OHSMS.
7.3
It has been identified that top management commitment to adequate
resources is significant for implementation of OHSMS. However, the XYZ
Company only demonstrated top-management commitment on paper
instead of physical commitment on resources allocation. In the
questionnaire analysis, it was identified that 4 out of 7 sections had linked
up the OHS management problems with inadequate resources or uncertain
resource support. XYZ management commitment did not equate with
planned resources. Inadequate resources identified on various areas.
Unclear functions and roles between line management and the Safety
Section also led to confusion in budget and funding preparation which
could be another reason for inadequacy of resources. Staff had expressed
their serious concern on the inadequate resources for execution of their
OHS responsibilities. Obviously, superficial management commitment
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without proper resources allocation cannot put OHSMS into effective
operation.
7.4
Funding for safety is always found to be a financial burden to the
management. Some companies resist treating it as part of their operational
overhead. Situations will become more critical under economic recession
since the management will concentrate their economic interest on the
improvement of economic opportunities rather than OHS. Market used to
trim down their safety standard and tolerate certain risk so as to provide
low costing environment for attraction of investment. Investors also take
such an opportunity for adjustment of their investment proportion on their
safety management. Cathay Pacific Airline is a typical case, which cut
down their running costs by eliminating the whole risk management
department in 1998 and only keeping three safety officers to look after the
safety of their worldwide business.
7.5
It is considered that resource allocation for safety is difficult to be secured
unless the top management realizes that safety funding forms part of
required overheads for company operations and commits to provision of
fixed percentage of operation cost as the baseline for funding to safety. It
would be more effective if it can be worked under a centralized safety
funding system for proper resource allocation and prioritization of safety
improvement initiatives. It can also release the financial burden of line
management in the modern cost-centered financial management approach
since it is treated as part of the corporate management overheads instead of
line operation overheads. Resource allocation forms the greatest barrier on
the planning implementation of OHSMS. It is not only on funding but also
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on adequacy and competence of safety professions in supporting the
planning and operation of OHSMS.
7.6
Another essential element that would serious affect the planning and
implementation of OHSMS is the appropriateness of management strategy
being adopted by the organization. The XYZ Company initially set up the
OHSMS on risk-based approach which came to dominate the entire safety
management establishment. However it is obvious that risk management
cannot cover all aspects of OHSMS. From the findings of the survey, it has
identified certain deficiencies of risk-based safety management approach.
Risk-based safety management strategy is an advanced safety management
concept that takes
proactive approach for eliminating and controlling
hazard. However it concentrates on preventive measures and sometimes
overlooks certain reactive and general safety management elements, like
emergency handling and accident investigation and safety promotion.
Obviously, the OHSMS setup of The XYZ Company described in Chapter
2 has not mentioned a reactive approach on accident investigation and root
cause analysis.
7.7
Risk management concentrates the consequence of hazard on injuries,
fatalities and damages. It cannot be applied for the risk of occupational
diseases which cause long-term ill health. There is no value justification
for long-term ill health in the cost-benefit analysis. It is also difficult to
define the likelihood of the risk as most of occupational diseases depend
on the length and frequency of exposure as well as cumulative damage. It
could be one of reasons why health surveillance was not included in the
XYZ’s policy.
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7.8
The risk management approach aims to justify cost-effective ways to
control and eliminate the identified hazards. However, it may not be cost
effective to conduct a full risk assessment including cost-benefit analysis
for a simple risk which can be easily identified by other means and
eliminated with minimal cost. Especially as the assessment is so
complicated and is required to be carried out by a group of well-trained
staff. In addition to the significant staff cost in assessment, it requires
expensive investment in training up certain number of staff in each line
department before adequate competent staff are available for carrying out
such complicated risk assessment. It may need further review to justify the
staff cost in this regard. Indeed, this can explain the reasons for the
inadequacy of resources for training and shortage of competent hazard
controllers for carrying out PHA in the XYZ Company. The survey found
that line management resisted to take up their responsibilities on PHA and
shifted them to the Safety Section. The resources for conducting PHA
were inadequate to cover all operation areas.
7.9
There are also certain limitations in risk assessment with cost-benefit
analysis approach. Value of life as well as injuries is difficult to be
quantified in monetary value. The XYZ Company as recommended by
their consultant adopted a “Value of Preventing a Fatality” up to HK$30
million per head which was originated from a railway safety plan (Railway
Group Safety Plan 1996/97, Railtrack PLC, London) in UK some years
ago. Obviously there is a great variation on this value from one country to
another and from time to time. It is due to different social perception of
different countries, which continuously change with time upon change of
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environment including economic and cultural. In the recent Corporate
Safety Committee Meeting, The XYZ Company ruled out the application
of cost-benefit analysis on the ground of uncertainty in the validity of the
value of preventing a fatality. Employee and trade union may also resist
accepting the justification of risk control by means of cost benefit analysis
as it only goes for employer rather than employees. Certain risk control
may be of great benefit to employees but is outweighed by cost benefit. It
will cause grievances on prioritization of risk control and toleration of risk
between the employer and the employee. Therefore toleration of risk is
most critical and may require extensive consultation to gain the acceptance
from the authority, the staff and the public. Yet the effort may be in vain as
different people have different perception of risk and different risk
acceptance level.
7.10
Indeed, a risk management approach was initially developed for hazardous
trade while it was recognized that risk could never be completely
eliminated. In hazardous trade, the tolerability of calculated risk is required
to go through an approval process by the local government with public
consultation. The toleration of risks deems to have public acceptance of
the community to a certain extent. However, the risk-based safety
management approach adopted by the XYZ Company was an indoor
process and the identified tolerable risks were not required to go through
any approval process of the local government. It is so risky that toleration
of the identified risk may not be agreeable by the authority as well as the
public or the staff. The company could face a serious liability on
negligence in duty of care when an accident occurred. Therefore, the
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Safety Maxim suggested by Kinney and Wiruth (1976) should be carefully
considered when it is applied for general risk issues. The XYZ Company
may have adopted an improper management strategy, which causes the
OHSMS to be ineffective and vulnerable. The management had relied too
much on the consultant and did not have adequate understanding of the
management principles of a proper OHSMS. This can be evidenced by
their revised Safety Policy Statement, in which the incident free policy is
contradictory to the toleration of risk. They may have misinterpreted the
risk-based safety management concept.
7.11
The application of a proactive approach in management strategy of OHS is
fully supported but it should not only concentrate on the risk management,
especially on the tolerability of risk, which may involve uncertainty in
legal liabilities. However important the determination of risk may be, it is
only one component of a safety management system. Other strategies, such
as training and performance monitoring through audits, will complement
the effective implementation of the OHSMS as a whole.
Management Structure and Responsibilities
7.12
Establishment of management structure coupled with clear responsibility
and accountability is one of the fundamental elements of generic
management. However, the XYZ company has demonstrated a serious
deficiency in this area.. For successful implementation of safety
management and achieving continual improvements in safety performance,
the senior management of The Company shall require strengthening of the
safety management structure and the organizational culture to ensure
understanding, acceptance, effective delegation of safety and health
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responsibilities and sustained implementation at every level of the
organization.
7.13
The study found that the XYZ Company intended to establish a two-tier
approach in their safety management structure. Such a management
approach is considered appropriate for such a complex organization as
corporate management can ensure integration of safety essences into
management while line management can ensure integration of safety
requirements into operations. Line departments can own their safety
management plans to ensure appropriateness to their operations while
corporate management issue corporate safety management plan as a policy
guidelines to line management for ensuring consistency. However, there
was no clear documentation available in The XYZ Company for such
amanagement approach. Notwithstanding the situation that the corporate
safety management plan was still under preparation, line departments
already issued their own safety management plans. There were serious
inconsistencies on the functions and roles between the Safety Section and
line management amongst individual safety plans of line management.
This can well explain the management problems of the XYZ Company on
implementation of OHSMS.
7.14
Indeed, confusion in responsibilities may lead to inadequacy in resource
allocation and ineffectiveness in utilization of resource since line managers
were unable to justify their funding application and budget while they
could not explain whether their safety initiatives fell within the areas of
their responsibilities. Unclear management structure and responsibilities
caused chaotic planning and implementation of OHSMS. On one side,
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resources could have been wasted by duplicated effort on similar tasks
carried out by different line departments. On the other side, safety
legislation could have been violated due to overlooking of essential safety
issues in grey areas of responsibilities by line departments.
7.15
Line management participation is vital for the successful implementation
of OHSMS. Line management should take up a major function in planning
and execution of OHSMS as it can ensure appropriateness of OHSMS for
their operation environment and proper integration. The unexpected high
response rate from the target group has demonstrated the enthusiasm of the
line management of The XYZ Company in participation of OHS matters,
but it could also imply their eagerness for improvement in certain areas
with serious OHS deficiencies. The availability of departmental safety
management plans further proved the line management participation.
However, the inconsistency of the plans showed that the safety
management structure was not strong enough to support horizontal
integration. The integration links amongst line departments are very weak.
In certain specialized safety areas, like risk assessment, the line
management have demonstrated their reservations in taking up their
responsibilities and shifted them to the Safety Section. Some even
admitted to full reliance on the Safety Section for OHS matters. The safety
responsibilities of the majority of the line department rested on one person.
It meant that the implementation of OHSMS was limited to line
management level and had not been extended to the frontline operation
staff. It was further substantiated by the failure of the line management in
ensuring the organization objectives and policy in OHS to be well
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understood by their staff. In fact, the most critical issue was the inadequate
resources for execution of duty. That was why the line management
demonstrated their positive attitude in participation of OHS management
on one side but resistance to take up OHS responsibilities on the other side.
These confusions and deficiencies were caused by the weak management
commitment and absence of proper management structure and clear
responsibilities and accountabilities.
7.16
For complex and dynamic organization, it may be an effective way to
provide a safety team at corporate level to assist senior management in
execution of their OHS policies and monitoring safety performance so as
to ensure consistency in planning and implementation amongst line
departments. Yet the safety management structure of the XYZ Company
displayed in Figure 2.5 showed that the Safety Section only took up the
supporting roles to the line management and did not necessarily to provide
support to the corporate management. It turned out that the Safety Section
was extensively involved in supporting OHS activities of line management.
The administration of the corporate safety management became rather
weak. The Corporate Safety Management Plan was still not yet completed
for safety manuals and guidelines. Therefore, the Safety Section should be
empowered with corporate safety function. However, safety executives
should only act as safety mentors rather than safety police so as to prevent
any resistance from the line management. The corporate safety function
should focus on:

Providing support and policy advice to senior management

Providing strategic or technical support to line management
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
Interpreting legislations and standards and developing user-friendly tools
for corporate-wide use

Lobbying external related-parties and the authority on behalf of the
company

Performing internal and external benchmarking

Providing safety training and arrange safety promotion

Administering safety performance.
7.17
For line management approach, each employee should be accountable to a
supervisor who is a member of the line management. Each member of line
management should be accountable to the next higher level of
management in their respective division/section. Ultimately, the head of
each division/section should be accountable to the Director. The Director
sets OHS policy, and provides direction on implementation strategies and
budgets.
Line supervisors should be responsible for planning and
conducting work safely; consistent with established policy and direction;
and assuring that worker training and qualifications are appropriate. Line
managers should have landlord responsibility for providing a safe
infrastructure to perform work. Line workers are responsible for the safe
performance of work.
7.18
It should be noted that it is generally accepted on a worldwide basis that
the CEO of any organization has the ultimate responsibility for safety and
health of all persons under his control. This does not absolve corporate or
line management from responsibility and accountability to the CEO. The
distance of the CEO from the decision making process that caused the
accident and the doctrine of due diligence and the extent to which he had
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control are factors to be determined by legal opinion. Notwithstanding
that, the responsibility and accountability in certain circumstances passes
down the management hierarchy through corporate management to line
management.
7.19
Other than responsibility and accountability, it is also important to
delegate staff with suitable authority. For avoidance of violation to safety,
it should be considered to empower all level of staff with appropriate stop
work authority. Every individual should have the authority and
responsibility to stop any work, which they feel is not safe. Every level of
supervision should be responsible to stop work for which they are
responsible that is not safe. Full stop work authority should rest with all
safety executives. Yet such authority had not been mentioned in the
OHSMS of the XYZ Company
7.20
Regarding the responsibility of contractors, the case study found that the
XYZ Company can contract away OSH responsibilities and potential
liabilities for specific work to a general contractor, but this applies only as
long as the general contractor undertakes the work fully, properly and
completely on behalf of the owner / occupier. However, there is a potential
financial loss arising from departmental prosecutions and as such this loss
could not be transferred to the insurer. The potential for common law
liability exists where injuries to contractor’s employees are involved. The
XYZ Company must be safeguarded against this loss by making sure that
all workers are in fact insured. This requires that their insurance
documents be checked and procedural documentation be provided to
ensure this is done. This is an important caveat: If the owner exercises any
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Chapter 7 - Discussion
control and responsibility along with the prime contractor, then the owner /
occupier remains liable for the proportion of the loss, no matter what the
contract between the owner and general contractor states.
7.21
Management should commit to implementing OHS requirements for
activities involving subcontractors, participating guests and visitors, while
maintaining an appropriate business relationship that does not result in
unnecessary assumption of liability for contractor operations. An accident
prevention clause should be inserted into subcontracts for service,
engineering and construction labour. It should specify that contractors
must have integrated safety into their business activities and follow all
applicable OHS requirements. All subcontracts contain provisions for
stopping work and terminating contracts for lack of OHS performance.
Certain subcontractor individuals may be excluded from the site for failure
to follow OHS requirements. A policy should be established to exclude
subcontractors from bidding if they have a record of poor OHS
performance.
Participation, Consultation and Communication
7.22
It is understood that safety cannot be imposed from above. The work will
be safe only if staff are involved in the process of developing safe work
procedures. Staff participation was critical to the success of all the
initiatives. On the other hand, management should provide support to the
participatory approach. Lack of necessary support from management or
staff will cause system breakdown in OHSMS and all people will be
exposed to unnecessary risk. It has been proven that the majority of line
departments of the XYZ Company rested their OHS responsibilities on
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only one person and OHS participation was limited to line management
level. Frontline operations staff have not been encouraged to take part in
OHS management. Therefore it was unable to ensure full integration of
OHSMS to line operations. It showed that inadequate participation of all
staff in OHS would render ineffectiveness in planning and implementation.
7.23
We need staff participation in joint employee effort to implement an
effective OHS policy. In the principles of participatory approach, the
people who do the work also participate in the planning for the work--i.e.,
analyzing the hazards, determining the controls and implementing the
controls.
This avoids disconnection between those planning and
implementing controls and those doing the work. It also makes good use
of worker knowledge in the planning process. The key issue on this
approach is the competence of workers. An incentive scheme may be used
to attract participation like an employee improvement scheme.
7.24
Communication is another essential elements for implementation of OHS
management system and development of safety culture. The extent to
which management genuinely wants to consult with employees and to
collaboratively manage OHS risks using a participative style of
management will greatly affect the effectiveness of the OHS management.
The XYZ Company demonstrated a serious deficiency in this area.
Communication breakdown was not only between corporate and line
management but also between line management and staff as well as
amongst line departments. Senior management has not provided proper
mechanism for dissemination of
their safety policy and performance
standards while line management have not ensured the safety management
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policy and standards were well understood by their staff. The safety
management structure together with roles and responsibilities were not
made known to all personnel. The management system was not open
enough to ensure effective communication. Mechanisms on feedback and
resolving disputes in OHS issues need to be enhanced.
7.25
One of the deficiencies in the XYZ policy statement was the absence of
consultative mechanism between management and employees for of
exchange their concerns on the occupational health and safety issues.
Besides, it also found that procedures and the manual of the XYZ
Company were not readily accessible by all staff. The communication
barrier greatly hindered the effectiveness in planning and implementation
of OHSMS in The XYZ Company. Ineffective communication will cause
misunderstanding and grievances between management and staff. An
effective communication system should be provided with suitable channel
to receive feedback from each other as well as from the external
environment together with a function to secure the information to be
received by the targeted recipient within the prescribed time frame.
Training and Technical Competence
7.26
It is recognized that training is essential to ensure competence of staff in
execution of OHS responsibilities. It is also an indicator of the top
management commitment to OHS. OHS training used to be a mandatory
requirement for staff under various OHS and Factory and Industry
Undertaking Legislations. However, there are common deficiencies in
identification of training needs for safety executives and senior
management. The situation was obvious in the XYZ Company where it
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was identified that the competence of senior management and safety
executives in certain safety areas was in doubt.
7.27
OHS practice in some area of operation in specialized industry required
specific expertise backed up by professional training in order to allow
problems to be measured and suggestions to be made. For the same
reasons, safety executives from the general safety field are facing
difficulties in execution of their duties, as they do not possess the required
knowledge in the operation as well as related engineering aspects of such
specialized industry, like aviation, marine and railway. The safety officers
of the XYZ Company were found have a lack of adequate knowledge on
the specialized operation of the carrier field. However, training still had
not been provided for enhancement of their competence in this area.
7.28
The policy defects on the XYZ Safety Policy Statement, especially on the
contradiction between incident-free policy and toleration of risk, has
proved that the perception of senior management in general management
principles of the safety system was not adequate enough for formulation of
a proper safety policy and setting up an appropriate management strategy
for safety. For effective planning and implementation of OHSMS,
managerial staff shall be trained up with adequate safety consciousness
and competence, especially for senior management, as they are the ones
taking the lead to establish positive safety culture. However, it is a
common problem on how to attract these busy managers to attend safety
training.
7.29
The competence problem was more serious for the Hazard Controllers of
the XYZ Company. They were not trained up to fully extend their
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Chapter 7 - Discussion
capability to conduct a PHA. As a deviation from the original intents, the
PHA was conducted by the Safety Section instead of by the line
management. Therefor the Safety Section tied up their limited resources in
PHA and updating the HRS. Hence their efficiency and performance in
setting up OHS policy and procedures was greatly affected, which was
more important for the planning and implementation of the overall
OHSMS.
7.30
The case study identified that resource constraints were again experienced
in the XYZ Company in this area. The Safety Section was faced with a
shortage of resources for the provision of safety training. Line
management were also faced with serious staff constraints under shift
operations and resisted the release of their duty staff for safety training.
Discouraging effects were identified on operations staff since they were
nominated to attend training during their off-duty time. The organization
establishment was not provided with training reserve to relieve staff on
training. Therefore, outsourcing of training could not solve the problem. In
fact, an external safety course could not provide tailored made training to
meet their training needs and was unable to cultivate tailored made safety
culture. It also reduced the means for safety executives to have face-to–
face feedback from frontline operation staff. The deterrent effects of
resources constraints on safety training adversely affected the competence
of staff in safety performance and in turn adversely affected the quality of
OHSMS management. Therefore, it can be concluded that staff
incompetence can fully defeat the effectiveness and efficiency in planning
and implementation of OHSMS.
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Chapter 7 - Discussion
Integrated Management and Operations
7.31
It is widely accepted that effective implementation of OHSMS required
full integration of the system into both management and operations. The
policy of the XYZ Company did not support this function. Obviously it
treated safety as a stand-alone adjunct. Communication between
divisions/departments was rather weak and cause a deficiency in sharing
information. Inconsistency of safety plans proved weakness in horizontal
integration. That was why the safety culture of the organization was not
strong enough for sustaining continual improvement and supporting
effective implementation of OHSMS.
7.32
Safety policies and programs should be designed to systematically
integrate OHS into the management and work practices at all levels so that
corporate mission is accomplished while protecting the public, the worker,
and the environment. In other words, the overall management of safety
functions and activities become an integral part of corporate mission
accomplishment. However, the line management approach in neglecting
the participation of frontline operation staff in OHS management of the
XYZ Company has refrained the OHSMS from proper integration into
operations. Obviously, the OHSMS of the XYZ Company was not unable
to be effectively integrated into management and operations both vertically
and horizontally. This proves the significance of proper integration for
effective planning and implementation of OHSMS.
7.33
Line management should implement the OHS program within their
divisions/sections in a way that makes the most sense for their operations.
In practice, there should be greater divisions/sections participation in the
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development of corporate safety programs and considerable effort should
be made to obtain consistency amongst different safety programs of line
departments, so implementation variations are few. Uniformity should
only be imposed where implementation by one division/section may have
a negative impact on another. Therefore, in nearly all cases, there would
be distinct variations in implementation at the division/section level or
activity level only when there is a need because of the nature of the
operations.
7.34
Vertical integration of the OHS program is facilitated by the downward
flow
of
information
regarding
expectations
for
OHS
program
implementation, from the top down through the organizational lines. At
the same time, vertical integration provides a mechanism for the upward
flow of information about problems in implementing the OHS program
including the need for support and resources from the worker and through
the organization to supervisors, and/or upper management, as appropriate.
7.35 Horizontal integration is needed to provide for normality and compatibility.
It can ensure similar controls for similar hazards and similar work within
an organization and avoid conflicting requirements among organizations
and technical disciplines. Horizontal integration of the OHS program
provides assurance that:

Peer organizations exchange ideas e.g. lessons learned & success stories,

OHS processes are similar in similar organizations
7.36
Integration into management need top management commitment while
integration into operations needs line management support and staff
participation. For broader vision in management, efficiency, productivity,
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quality, safety and environment should be integrated all together as the key
performance functions in the operation process.
Performance Benchmarking and Objectives
7.37
A performance monitoring system does not form one of the
implementation
processes.
However,
performance
indicators
and
benchmarking are essentials for planning and implementation of OHSMS.
Without these essentials performance targets cannot be established - hence
safety workplans cannot be properly prepared. However, it is a quite
common deficient item in the worldwide-recognized safety standards and
models. As observed in Table 3.1, nine out of twenty-four OHSMS do not
include a performance measures element. These almost match with another
related deficiency of these systems on the coverage of goals and objectives.
Seven of them also do not provide a goals and objectives element, which is
highlighted in the modern management theories of “Management By
Objective”.
7.38
Benchmarking was one of the deficiencies identified in the OHSMS of the
XYZ Company. In the absence of performance benchmarking and proper
performance indicators, XYZ faced difficulties in setting up proper
performance targets and goals for further improvement. Management
could not assess their safety performance level and was at a loss to make
management decisions on their way forward regarding safety management.
OHS benchmarking can help management to establish best-practice safety
culture in their organization. On one side, it provides a yardstick for line
management in their OHS performance. On the other side, it gives
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confidence to the senior management for continual improvement in OHS
management.
7.39
Managers often regard OHS as a barrier to their performance. To rectify
this concept, OHS should be integrated into their management and form
part of their performance appraisal. OHS should be regarded as part of
operation efficiency instead of the traditional consideration of taking
priority from operation efficiency, which would deter full integration. To
secure effective implementation of OHSMS, performance appraisal could
be one way to enhance the positive attitude of line management in
execution of their OHS responsibilities for meeting their agreed
performance targets.
Best Practice and Safety Culture
7.40
As mentioned before, one of the deficiencies of the XYZ Company in
implementation of OHSMS was failure in the establishment of a positive
safety culture throughout their organization. The negative attitude of line
management in promotion of staff participation had a discouraging effect
in the establishment of safety culture. Culture is the total way of life. It
represents people’s attitudes, thoughts, expectations, goals and values.
OHS culture is the system of shared values and beliefs about OHS, which
creates behavioural norms which guide OHS activities in the organization.
It directly relates to the effectiveness of the integration of OHS into the
organization.
7.41
There are two major types of safety sub-culture and they are the operationoriented culture and safety management oriented culture. The former
believes that safety culture is top-down approach, whereas the latter is
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work done through an effective communication network. In the XYZ
Company,
many
employees
were
transferred
from
government
departments and were old government officials. Some of them still
maintained certain bureaucratic attitudes and adopted the operationoriented approach. Furthermore, some of them, especially the senior
employees, were still adapting the traditional paternative management
approach. Staff were not allowed to gain free access to and participate in
formulation of the policy and procedures. To change the culture and the
behaviour of senior employees is not easy and is also time consuming, still
we should keep on educating them by introducing the new idea of OHS
policies and explaining the pros and cons of a safety management system.
There were many employees from different foreign countries working in
the XYZ Company and their business-related partners. This introduced the
problems of adaptation, communication and co-operation. In terms of OSH,
these were differences in the paces of work as compared to their own
countries; variation in OSH practice and standards; language ability
relating to daily operations and safety training; and the willingness to
report unsafe conditions or unsafe acts.
7.42
Positive OHS culture can promote employee participation and involvement
at all levels. It is far better to incorporate the OHS culture with corporate
management culture. Since everybody shares a common goal and objective,
OHS policy can be carried out smoothly and cost-effectively. To secure
excellence in planning and implementation of OHSMS and continual
improvement, it could be better to taking best-practice philosophy instead
of compliance base approach, which only provides minimum standards for
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safety. Obeying the law is regarded as a duty for which one receives little
recognition or credit.
Planning for Implementation
7.43
It is recognized that OHSMS concentrates on safety elements but is used to
overlook a key element on how to plan and manage the implementation of
OHSMS. Indeed, it comes to be a management issue rather a safety issue,
which may not be clearly realized by safety executives. It is quite a
common problem that certain organizations run “Safety” without
“Management”. The XYZ Company is one of the typical examples. They
concentrated on risk identification but were unable to manage the
identified problems with no prioritization of works. Their OHSMS only
highlighted the planning for various safety functions but missed one of the
major management functions on how to plan for implementation. A
corporate safety plan had not been well prepared. Procedures and manuals
were not made available to all staff. No structured mechanism had been
established for the implementation of OHSMS. Safety functions were
implemented without properly integration to management and operations.
In over two years of business operation, there were only two Executive
Committee papers endorsed for OHSMS; one for the RBSMS approach
and other for the Safety Policy Statement. Obviously, it had not full
utilized these mechanisms to gain policy support from the top management
for securing the management structure and resource allocation for various
safety initiatives.
7.44
This study has identified that planning is not only required for OHSMS but
also needed to establish a structured management approach for its
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Chapter 7 - Discussion
implementation. For assurance of proper implementation, an OHS
Implementation Plan is basically required in support of the integrated
safety management plan, including specific performance commitments.
The Plan should be updated annually to reflect progress made, changes in
mission and site budgets, and feedbacks aim at improved performance
objectives and measures. The OHS Implementation Plan shall include the
follow functions:
To identify the resources needed to fulfill OHS commitments and meet
OHS objectives, and to assure that adequate OHS skill levels and mixtures
are available to support the accomplishment of the corporate mission.

To set OHS performance objectives and commitments, responsive to the
safety expectations, consistent with mission, budget direction, and program
guidance and direction. Appropriate priority, key milestones and schedules
tied to commitments are identified.

For an on-going annual report, the Plan shall also report the performance
results compared against the previous year's Plan commitments, performance
objectives and measures, including the measures and commitments
negotiated for the previous year; and include specific description of how
risks were actually reduced.
The Plan shall be endorsed by the Executive Board so to secure proper allocation
of resources for implementation. Then the Plan shall be disseminated to all
working levels of the organization for full implementation.
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