The Internal Responsibility System: Phase Two

The Internal

Responsibility System:

Phase Two

Dr. Peter Strahlendorf

School of Occupational and Public Health Ryerson University

Phase Two ?

IRS Phase One:

The traditional approach where everyone looks for defects, contraventions and hazards and tries to get rid of these bad things.

IRS Phase Two:

Everyone thinks of better ways of doing what they’re doing using their local knowledge, and a reduction in risk comes as a side

The Dilemma

“We are doing very well. We have instituted various OHS programs and brought our lost time down to an acceptable level. We are better than ….X. Things have reached a

plateau. Can’t go any further. In fact, been some recent spikes and an upward trend…”

The Dilemma

The lost time statistics look like “surfing” along the bottom of the graph.

We go a month or so with zero lost time, and then have an incident or two. Then we go 2 or three months with zero, and then an

incident. Then another zero period and then another spike in accidents. Why can’t we stay at zero?

World Class Performance

performance” at a minimum of 2 years with zero lost time (if doing moderate to high

• Why do we get stuck at “pretty good”? • How do we get to world class levels?

Complacency and Motivation

workplace does not reveal obvious defects, hazards and contraventions. We get lulled into a false sense of security. We are by nature optimizers, not maximizers. When we have “enough” bananas we quit picking and do something else.

Complacency and Motivation

partial success, safety is notoriously

difficult to motivate people with. Safety was never “sexy” and fun. To motivate people to drive risk down to the lowest

levels it can reasonably go – we’re going to have to find some motivator other than

Complacency and Motivation

Once people feel safe, they do not experience a need for safety, and safety cannot

Complacency and Motivation

The more successful we are with safety, the less motivated we are to do anything about safety.

Complacency and Motivation

1. Move down the stairs by scaring people Or

2. Operate at a higher level, motivate

people with enhanced social involvement (friendship), recognition for achievement, or opportunities for “self-actualization”

Obliquity

Are there some things you can’t get by aiming at directly?

Obliquity

Aim at “A” and get “B” as a side effect, even though “B” may be what you really want. To be happy, you must aim at completing

challenging activities – result is satisfaction or happiness.

Obliquity

After a certain point you can’t get more safety by aiming at safety directly. You plateau.

To achieve world class status, an organization has to aim at individual creativity in improving the

processes individuals are involved with – and we get continued risk reduction as a side effect. The opportunity to be creative is what motivates.

IRS Phase Two

We shift away from aiming at safety directly to aiming at creative improvements in the work processes by everyone, and we get reduced risk as a side effect of the

IRS Phase Two

The motivation is the satisfaction people get when they use their talents, skills,

experience and knowledge to change their environment, particularly where we

recognize and reward this creativity, and where it is done in a team environment.

Two Ideas – Phase One

health and safety into his or her job, and should take every precaution reasonable in the circumstances to avoid losses.”

Two Ideas – Phase Two

measure reasonable to continuously

improve processes such that, among other benefits, the risk of occupational injuries

and illnesses is driven down as low as it can reasonably go.”

Getting to Zero

If you focus on defects and contraventions

alone, you will “surf along the bottom of the graph”.

But if you focus on creative improvements --risk is reduced as a side effect -- you can “suck” lost time down to zero and keep it there for a very long time.

To Reiterate …

Creative improvements continue to drive risk down, when you otherwise would have

gone on a holiday … you otherwise would have become complacent about safety. We switch to a new set of motivators to

continue to drive risk down, when the old motivators have gone cold.

The Internal Responsibility

System

• The philosophy behind the OHSA • The IRS is a way of allocating

responsibility, authority and accountability for safety that precedes law

• First named in the 1976 Ham Royal Commission Report

• Not mentioned directly in OHS legislation, except NS

James Ham

1. OHS should be integrated into production; it’s not a separate function.

2. Everyone should be doing OHS directly as part of his or her job.

The Internal Responsibility

System

• Followed across Canada • Often misdescribed

• An OHS Act may or may not be based on the IRS. It may inadequately portray the IRS. The Canada Labour Code is a good example of reform efforts going off the rails, and away from the true IRS.

Muddying the Waters

After Ham, some have gone to great lengths to muddy the message.

The True IRS versus Labour Relations View An individual coming to OHS from a labour

relations background finds it almost impossible to understand or agree with the true IRS model.

Power of the IRS

It is the only philosophy that captures the knowledge, experience, skill, insight,

observational position, initiative, creativity and enthusiasm of every human mind in the workplace.

It is the ultimate expression of respect for the human element in the workplace.

Power of the IRS

• The IRS is the “people framework” around which the management system is built.

• An OHS management system without the IRS is lifeless.

• Programs and techniques are built on top of and around the IRS.

• A weak IRS will sabotage any other OHS initiative.

MOL IRS Study

IRS audit in 6 Ontario mines showed that an IRS audit can measure the IRS and that a high IRS score goes with a low accident rate, while a low IRS score means more accidents.

The results from 4 of the mines (the other 2 didn’t have appropriate data) were:

LTI = 5.3 - 0.12("Score") r = 0.94 15 20 25 30 35 40 45 0 5 10 15 20

"Score" (Q1a*Q1b) of IRS effectiveness based on workers' responses

T M I a n d L T I fr eq u e n c ie s TMI = 31 - 0.53("Score") r = 0.99

Definition

“The IRS is a system, within an organization, where

everyone has direct responsibility for health and

safety as an essential part of his or her job.

An individual does health and safety in a way that is compatible with the kind of work that person does. Each person takes initiative on health and safety

issues and works to solve problems and make improvements on an on-going basis. A person

does this both as an individual and in co-operation with others.”

Nova Scotia

s. 2 The foundation of this Act is the Internal Responsibility System which

(a) is based on the principle that

(i) employers, contractors,

constructors, employees and self-employed persons at a workplace, and

NS Definition Continued …

(ii) the owner of a workplace, a supplier of goods or provider of an occupational

health or safety service to a workplace or an architect or professional engineer, all of whom can affect the health and safety of persons at the workplace,

share the responsibility for the health and safety of persons at the workplace;

NS Definition Continued …

(b)

assumes that the primary

responsibility for creating and

maintaining a safe and healthy

workplace should be that of

each of these parties, to the

extent of each party's authority

and ability to do so;

NS Definition Continued …

(c)

includes a framework for

participation, transfer of

information and refusal of

unsafe work, all of which are

necessary for the parties to

carry out their responsibilities

pursuant to this Act and the

NS Definition Continued …

(d) is supplemented by the role of the

Occupational health and Safety Division of the Department of Labour, which is not to assume responsibility for creating and

maintaining safe and healthy workplaces, but to establish and clarify the

responsibilities of the parties under the law, and to support them in carrying out their

responsibilities and to intervene

appropriately when those responsibilities are not carried out.

• There are many good things to be said about putting a definition of the IRS in OHS

legislation.

• One downside is that many people will view the IRS as something that comes from law and is expressed solely in terms of legal duties.

IRS

Internal – many meanings

Responsibility – it’s about obligations not rights

System – it’s a true system, requiring “systems thinking”

“Internal”

¾internal to the workplace

¾internal to the individual

¾internal to the job description of everyone

¾internal to routine decision-making

Internal to the Workplace

• OHS is the responsibility of the workplace parties (as individuals)

• OHS is “self-regulated”, “self-monitored” to a very large extent

• External Responsibility System not directly responsible for OHS

Internal to the Job Description

of Everyone

• Everyone, no exception • Staff and line

• Workers, supervisors, managers, officers and directors

• Personal, individual responsibility

• Do the kind of OHS work that fits with authority and control

Internal to Routine

Decision-Making

• OHS not an add-on, an afterthought • OHS not a separate function

• As you do your ordinary work you think

about risk, hazards, controls and adjust your work accordingly

• Easy to see with workers and supervisors • Hard to see with mid to senior managers

External Responsibility System

• Safety Councils

• Safe Workplace Associations • Compensation Boards

Set standards, enforce, educate, etc. but don’t do it for you

Wrong IRS Description

industry and government to ensure a safe and healthy workplace.”

Refers to a tripartite policy-making process (e.g. the development of WHMIS), but not the IRS.

Wrong IRS Description

1. To know about hazards 2. To refuse unsafe work

3. To participate (through committee)”

Missing the main element – personal duties of everyone

Wrong IRS Description

improve health and safety in the workplace”

Vague. Unhelpful … unless you want to slip the Titanic through the gap.

Wrong IRS Description

“Labour and management co-manage OHS through the Committee. The Committee IS the IRS.”

The “labour relations” version of the IRS. Missing personal contribution of

Wrong IRS Description

“The company/employer is responsible for OHS, not the government.”

Fails to raise the “corporate veil” and identify all individuals as personally responsible.

Wrong IRS Description

system.”

The IRS is part of the management system – not a competing idea, nor is it synonymous with it.

The IRS is NOT …

• An off-the-shelf program you buy • Something you don’t have

• A “partnership” between labour and management

The IRS is NOT …

• Labour relations

• The health and safety committee • Primarily about rights

• The same as due diligence • Regulatory compliance

The IRS is …

• An element of the OHS management system

• Something you already have • Individualistic

• About the personal responsibility of each individual

The IRS is …

• Is monitored and supported by the committee

• Is connected to due diligence (tells us who must be duly diligent)

• If it works well will ensure regulatory compliance

Where Does the IRS Come

From?

Accident Theory & IRS

Descriptive

1. Who can cause an accident? Anyone

2. Who can prevent an accident? Anyone

Prescriptive

3. Who SHOULD prevent accidents? Everyone

4. Who SHOULD be doing OHS here? Everyone

Origin of IRS

IRS isn’t true by definition or created out of thin air by policy.

IRS is based on physical causation of

accidents in the workplace by people – all people – in the organization.

IRS is “true” because of basis in accident theory.

Workers

• Following regulatory procedures • Following employer's procedures • Following supervisor's procedures

• Identifying defects, contraventions and dangers • Using initiative to reduce risk

• Applying discretion to solve OHS problems • Reporting unresolved problems

• Working cooperatively with co-workers, supervisors and others

Supervisors

• Applying discretion to solve OHS problems • Responding properly to reports

• Encouraging reports • Training

Supervisors

• Job planning

• Tailboard conferences, pre-job briefings • Coaching

Supervisors

• Enforcement of rules and regulations • Discipline

• Working cooperatively with workers, other supervisors, managers and others

• Taking unresolved problems to senior management

Managers

• Engaging in leadership activities for OHS • Applying discretion to solve OHS problems • Responding properly to reports

Managers

• Developing, implementing programs • Post-project/program assessment

• Properly allocating resources • Staffing decisions

Managers

• Considering system wide problems

• Taking unresolved problems to senior management

• Working cooperatively with workers, supervisors, other managers and others

Executives

• Ensuring the development of an OHS system

• Ensuring periodic "system audits"

• Responding properly to reports by managers • Ensuring that a proper IRS is functioning

• Ensuring that competent professionals are hired

Executives

• Leadership — taking initiative; inspiring others

• Holding subordinates accountable • Considering system wide problems

• Taking appropriate, unresolved problems to the directors

Directors

• Setting the broad vision for OHS performance • Ensuring that the officers are capable and

motivated to establish and maintain the IRS and the OHS management system

• Requiring evidence that in fact the IRS and OHS system are functioning well

• Responding properly to reports by officers

• Holding the officers accountable for their OHS performance

IRS and Teams

• IRS is not “command and control” –old fashioned.

• Teams with leaders, where individuals are empowered to both think and do...they are continuously improving the process

themselves...this IS the IRS in action. • A question of driving down authority

The IRS is a Dynamic Problem

Solving “Machine”

• Attempted resolution of problems within each level

• Attempted improvements within each level

• The upward flow of unresolved problems and opportunities for improvement

• Cooperative interaction between levels for problem-solving and improvements

• The number of problems flowing up decreases with each level

Problem Solving “Machine”

• The number of initiatives that could be taken at each level without waiting for an issue to come up from below does not necessarily decrease with

each level

• The nature of the problems and the opportunities will be different at each level

• Implication that people at lower levels need to be kept informed of what is happening to a problem or initiative that was sent up the system, or

frustration will set in

• Implication that weakness in the IRS can occur at any or all levels

IRS Phase One …. #1 in Decision Cycle: Everyone is looking for defects,

contraventions and hazards.

IRS Phase Two … #2 in Decision Cycle Everyone is thinking of ways they can

generically improve the processes they are involved with, and risk is driven down as a side effect.

Response Driven by

Reactive Due Diligence

When a person receives a “hot potato” from below, his due diligence position shifts. Now he KNOWS about hazard X or non-compliance Y. Proactive due diligence is

erased. Now what matters is response to the standard of the reasonable peer.

Initiative versus Response

• IRS at levels above the hands on worker is not just about responding to issues from

below.

• Individuals at all levels are in the best

position to see how their own processes can be improved.

In the IRS Phase One, it was always difficult to get people above the level of the

supervisor to do more than react, since they are not directly involved in work where they can see the “defects, contraventions and

IRS Activities

• Individual problem solving — identification of defects, anomalies, contraventions, hazards and risks and their resolution … Phase One

• Individual creative and continual improvement of work processes … Phase Two

• Reporting up when in need • Cooperative problem solving

IRS and Risk

We do not want risk assessment to be done solely in a staff function; done globally for the organization.

We want risk assessment to be done daily by individuals as they are routinely making decisions.

Risk

Personal assessment of risk allows an individual to figure out:

¾ what techniques to use

¾ when to use them

¾ how often to use them

¾ with what emphasis

Enemy of Zero

Complacency

By thinking that a lost time statistic is the goal, or an acceptable level of risk is the goal, we ease off (rarely intentional).

Solution

“Quality thinking” is the answer. Shift from finding “bad things” – defects, hazards,

contraventions – to improvements in processes.

IRS and Quality

We do not want quality to be done solely in a staff function; done globally for the

organization.

We want quality to be done daily by

individuals as they are routinely making decisions.

Due Diligence and Quality

circumstances to improve processes you are involved in.”

For world class OHS performance, we must incorporate quality principles into OHS decision-making.

Quality Thinking – Phase Two

“I don’t necessarily see any bad things – defects, contraventions and hazards – but I can see ways of:

¾ simplifying things

¾ automating things

¾ reducing the number of steps

¾ narrowing variation

¾ applying a new technology

¾ making it comfortable

IRS Phase Two and Obliquity

continuously improve the processes they are involved in, there will be many benefits:

¾ cost reduction

¾ environmental protection

¾ improved service to clients

¾ better product

Risk Reduction is one of several good things that come out of IRS Phase Two. The

others are also things that are hard to

motivate people about directly. IRS Phase Two allows for a closer integration of OHS and environment (and other things) in an integrated management system.

Example of the Miner’s

Wheelbarrow

Old Suggestion Box

• Months later, engineering looks at it

• Not enthusiastic if it’s not “engineering” • Not enthusiastic if it’s not big

• Someone with no “local knowledge” is judging whether an idea is good

Old Suggestion Box

• Worker never hears what happens or only hears long after it’s forgotten

• Program actually increases lethargy and cynicism • Can create suspicions of unfairness if $ payout

• Many good ideas with local benefit never adopted • Based on a few big ideas

New Creativity Program

• Team tests it out

• Company provides resources

• Engineers, OHS professional, Committee advise, but do not direct

• Adopt scientific method re proof

• Teamwork and collegiality enhanced (Maslow’s social motivator)

New Creativity Program

• Use of local knowledge is maximized

• People can go and learn new skills in order to complete project (Maslow’s self-actualization) • Ideas are publicised and team is recognized

(Maslow’s esteem motivator)

• Deeply satisfying taking an idea to completion • Not directly about safety, quality, cost,

New Creativity Program

• Send team to conferences, dinners, tours … other recognition rewards

• Not wrong to have some element of competition between teams

• Be careful about adding in monetary rewards

Benefits

• Fast

• Flexible

• Built-in motivators

• Uses local knowledge

• Increases “human capital” • Highly respectful of people

Evolution of $ and Safety

1. Safety is a cost. Safety is the opposite of production. Do as little safety as you can get away wit

2. Accidents cost money. It pays to invest some $ in prevention to reduce $ losses.

Evolution of $ and Safety

3. Total loss control philosophy – the losses are greater than we thought … 5-50 x

workers’ comp costs

4. IRS Phase Two … how your organization becomes world class and dominates the market.

“IRS Analysis”

Analyze every OHS issue in terms of the underlying IRS, e.g.: ¾ Inspections ¾ Investigations ¾ Complaints ¾ Orders ¾ Recommendations ¾ Work Refusals ¾ JHSC Activities

“IRS Analysis”

1. What went wrong with the IRS?...fix it.

2. What could go wrong with the IRS?...avoid it

“IRS Analysis”

We think of failures in the IRS as failures to raise problems about defects, contraventions and hazards.

IRS Phase Two:

We think of failures in the IRS as failures to be creative, to seek improvement.

OHS Driven by “Internal

Motivation”

• Difference between motivation from within the person and motivation from without

• External “rewards and sanctions”

• Internal “satisfiers” .... pride, sense of

achievement, self-development, control, curiosity, self-respect, morality, etc.

• Which works best for “out of sight short cuts”? • Which works best for obtaining creativity and

IRS Phase Two and Motivation

the Maslow model

• Individuals are unique, and so the mix of internal motivators will be different

• There will be some people who are not motivated by the satisfaction of being creative and inventive,

The Internal Responsibility

System is:

• A set of responsibilities for every individual in the organization

• A hierarchy of responsibility, authority and accountability

• A set of values and principles

• A system of processes and activities • A pattern of individual creativity

• A true “system”. It has built devices for monitoring, feedback and control

IRS Phase One …

• Gets you to “pretty good” • Is only about OHS

• Is essentially negative

• Is about preventing losses • Is about finding bad things

• Is closely associated with legal duties

• Runs out of motivation for safety after some success

IRS Phase Two …

• Gets you to world class status

• Is about years without lost time accidents • Is about creativity

• Is about using “local knowledge”

• Is about motivation for safety other than safety • Is about high performance for environment, cost

reduction, productivity as well as safety • More than pays for itself

IRS Audits

We “audit” the workplace and we do “system audits” of the OHS management system.

Can we directly audit the IRS?

IRS Audits

Surveys, interviews and observations to

measure the health of the IRS at each level of the organization; identifying strengths and weaknesses with a view to correction

IRS Audits

Ask questions about:

¾ understanding ¾ beliefs ¾ cooperation ¾ communication ¾ involvement ¾ response time

IRS Audits

¾ individual’s perception of how others are performing in the IRS

¾ whether “IRS analysis” is applied to problems

¾ whether internal failsafe devices are working

IRS Audits

• We can measure the climate for the IRS Phase Two

• We ask questions about being encouraged to come up with new ideas, about what

happens to new ideas, about senior

management’s perceived commitment to creativity.

IRS, Due Diligence, Risk and

Quality

If everyone in the IRS is personally taking every measure reasonable to continually

improve processes he or she is involved in, we can drive risk down as low as it can

reasonably go. Tomorrow, we drive it

down a little further. The lower the risk, the longer we can go with zero accidents.

Dr. Peter Strahlendorf