Corrective Actions
It’s important to divide your recommended corrective actions into the categories below:
- Immediate or short-term corrective actions to eliminate or reduce the hazardous conditions and/or unsafe behaviors related to the accident.
- Long-term system improvements to create or revise existing safety policies, programs, plans, processes, procedures and practices identified as missing or inadequate in the investigation.
High Priority Strategies that Eliminate the Hazards
1. Elimination: Totally eliminate the hazard. Why is this control strategy our top priority and considered by OSHA to be most effective? This control strategy has the potential to completely remove the hazard. We’re somehow changing a thing/condition in the workplace. And as we all know…
2. Substitution: Substitute the hazard with a less hazardous condition, process or method. Some basic examples are substituting a toxic chemical with a non-toxic chemical or replacing an old poorly-designed machine with a new model.
3. Engineering controls: See if any of the strategies below are used in your workplace.
- Design: Example – Design a tool so that it reduces the likelihood of a strain or sprain.
- Redesign: Example – Change the design of a machine so that dangerous moving parts or electrical circuits are out of reach.
- Enclosure: Examples – Place a hood over a noisy printer. Place a machine guard around a dangerous moving part.
These are the first to parts of the Hierarchy of Controls
Recommend System Improvements
The surface causes for accidents actually represent the symptoms of underlying safety management system weaknesses. This cause-effect relationship is so important to understand that I’ll say it again: the behaviors and conditions that caused the accident are, themselves, usually the effects of deeper root causes. This is a fact.
Consequently, your first assumption, as an accident investigator, should be that root causes have contributed to an accident, and your job is to find them. Your first basic assumption should never be that an accident is simply the result of surface causes. Once in a while, you’ll find that an accident was solely the result of a “personal failure,” but that won’t be often: in fact, it will be rare in most organizations.
Learn more about Root Cause Analysis
Therefore, make every effort to improve safety management system components to ensure long term workplace safety in your company. As we learned in the last module, the most successful accident investigator is actually a systems analyst. Making safety management system improvements might include some of the following examples:
- including “safety” in a mission statement;
- improving safety policy so that it clearly establishes responsibility and accountability;
- changing a work process so that checklists are used that include safety checks;
- including hands-on practice as part of the safety training program;
- revising purchasing policy to include safety considerations as well as cost; and
- changing the safety inspection process to include all supervisors and employees.
Check Out: Incident Investigation: Top 10 Mistakes
Answer the following six questions to help develop and justify recommendations.
1. What exactly is the problem?
- What are the specific hazardous conditions and unsafe work practices that caused the problem?
- What are system components – the inadequate design or implementation of safety management programs, policies, plans, processes, procedures and general practices that allowed the conditions and behaviors to exist?
2. What is the history of the problem?
Have similar accidents occurred previously? If so, you should be able to claim that the probability for similar accidents is highly likely to occur.
- What are previous direct and indirect costs for similar accidents?
- How have similar accidents affected production and morale?
- Describe how it has affected direct, budgeted or insured costs related to past injuries or illnesses.
- How has it affected indirect, unbudgeted or uninsured costs related to loss of efficiency and/or productivity and employee morale?
3. What are the solutions that would correct the problem?
- What are the specific engineering, administrative and PPE controls that, when applied, will eliminate or at least reduce exposure to the hazardous conditions?
- What are the specific system improvements needed to ensure a long term fix?
4. Who is the decision-maker?
- Who is the person who can approve, authorize, and act on the corrective measures?
- What are the possible objections that he/she might have?
- What are the arguments that will be most effective in overcoming objections?
5. Why is the decision-maker doing safety?
It’s important to know what is motivating the decision-maker. Is the decision-maker doing safety to fulfill one or more of the following imperatives?
- Fulfill the legal obligation? You may need to emphasize possible penalties if corrections are not made. Common in a fear-driven culture.
- Fulfill the fiscal obligation? You may want to emphasize the costs/benefits. Common in an achievement-driven culture.
- Fulfill the social obligation? You may want to emphasize improved morale, public relations. Common in a humane corporate culture.
6. What will be the cost/benefits of corrective actions and system improvements?
- What are the costs that might result if/when OSHA inspects? Answer this question to address the legal obligation your employer has.
- What is the estimated investment required to take corrective action, and how does that contrast with the possible costs if corrective actions are not taken? Answer this question to address the fiscal obligation your employer has.
- What is the “message” sent to the workforce and the community as a result of action or inaction? Answer this question to address the social obligation your employer has.