Now that the holiday season has passed and the new year is here, many companies and worksites have shifted their attention to the annual tradition of OSHA record keeping.
With the deadline to post the OSHA Form 300A “...in a conspicuous place or places where notices to employees are customarily posted” now less than a month away, final reviews of OSHA 300 logs are in full swing to ensure that the data posted is accurate.
Voluntary Protection Programs Participants’ Association (VPPPA) members and, in my experience, most Gulf Coast industrial contractors, are better prepared than most for this annual event based on their participation in OSHA’s Voluntary Protection Program (VPP) or advanced EHS&S programs resulting from work in the oil and gas industry. Prior to the posting deadline, these companies analyze their incident datasets and identify trends and corrective actions to prevent future injuries.
This is a collaborative effort, rooted in the birth of VPP 40 years ago and spread by VPP sites to companies who, either through the high-risk nature of their work or positive influence of clients and peers, recognize the value of total safety culture. That is, a safety culture that isn’t driven by the C-suite, but by the combined efforts of management, front line workers and even the regulatory community to engage in long-term continuous improvement. A safety culture where achieving zero incidents or reaching the milestone of VPP Star status isn’t the end of the safety journey, but a point toward sustained, world-class leading and lagging indicator performance.
For any company, regular safety audits and self-evaluations are core components of its EHS&S program. The only way to paint a full picture of a company’s safety performance is to engage front-line workers in the process. This allows for objective, real world feedback — positive and negative — that management may not necessarily see on a day-to-day basis.
For years, these audits and self-evaluations have been conducted through individual observations which are compiled into an annual report. While effective, this process can produce disjointed analysis, with the risk of data overload creating a potential condition where critical observations may be overlooked or misinterpreted. Only recently has technology caught up to performance — allowing EHS&S managers to pivot from collecting individual, separate observations to a real-time collaborative environment where the full EHS&S team can input, collect, analyze and interpret observations together.
Document-sharing began this technology evolution, but only in the last few years have we seen true collaborative audit and self-evaluation tools come to market, like VPP Online by VPPPA and auditsoft.co. Tools like these allow teams to record observations in the standard VPP self-evaluation template in real-time, while removing the risk of overwrites and disjointed observations by recording user changes and lock- ing fields when another user is recording.
Even more important, these tools allow companies and sites to engage front-line workers and management together in year round observations and analysis. VPP sites, which are required to complete an annual self-evaluation as part of the program’s requirements, have found that platforms like VPP Online allow teams to create a year-round observation and analysis process, comparing observations year-over-year to identify trends in data such as nearmiss reporting, front-line worker training, JSA lessons learned and so on — trends that can be used to prevent the next incident, not just within the company, but with clients and other stakeholders working alongside.
As more companies begin to recognize the value in real-time collaborative observation platforms, their EHS&S self-evaluation processes will evolve to include multi-site, client and stakeholder participation. In turn, the lessons learned from these observations and analysis will reach more companies, ultimately helping achieve our ultimate goal of sending every worker home in the same — or better — condition than which they arrived. That is collaborative safety excellence.
Chris Williams leads VPPPA’s day- to-day operations in support of advancing safety and health excellence.
For more information, visit vpppa.org or call (703) 761-1146.
