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From: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Subject: Re: [DCHAS-L] EXTERNAL EMAIL: Focusing on Meeting Regulations When the Focus Should BE On What Makes Sense
Date: Sun, 25 Oct 2020 17:28:43 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 0903272D-0E4B-44F7-AB69-79E5061FC5D3**At_Symbol_Here**keene.edu
In-Reply-To <1664100675.2289126.1603570011490**At_Symbol_Here**mail.yahoo.com>
>It is given that these regulations and rules must be followed.
Regulatory compliance is not a given in any workplace - it has to be managed. This is because government agencies write their regulations for an imaginary organization with complete knowledge of its worker roster and of the hazards and risks associated with their work. I have not seen any research organization that has all of that information in place. Even Hanford Nuclear Labs experiences ongoing safety management concerns (see for example
https://www.tri-cityherald.com/news/local/hanford/article246231755.html ).
This gap between regulatory aspirations and organizational realities means that safety professionals spend a lot of time exploring the nuances of government rules and regulations in order to prepare for both training opportunities and regulatory interactions.
> >Why does this group so often address a health and safety issue by first asking what are the government rules and regulations. Do the individuals asking the question not know what is the right thing to do?
>
I don't know of any safety professionals with significant experience that don't understand the difference between regulatory compliance and a safe workplace culture. However, there is no single "right thing" to do in complex organizations when it comes to safety. Upper management, regulators, front line workers and middle management all have different priorities and compliance requirements often left to the health and safety office to respond to. We are given specific set of resources and have to deploy those resources in a way to satisfy many different stakeholders. For this reason, there is a need to strike an ongoing balance between compliance and culture goals.
Sometimes it is possible to use training opportunities to leverage educational goals and vice versa. For example, in the summer of 2013, I provided in person training to about 1500 workers at a large research institution. This was because OSHA's incorporation of GHS into the haz comm standard caught the attention of many people on campus. The previous year, without the regulatory news hook, I had about 150 people attend chemical safety training on the same campus.
As Mike and Monona pointed out, training numbers by themselves do not tell us about the quality of the training provided and whether they impact either safety decisions or safety culture in organizations. But this is an important area for the safety profession to explore and that is why I am interested in discussing the successes and challenges all along the training - education spectrum. The academic literature on the role of the safety professional as discussed, for example, on the Safety of Work podcast
https://safetyofwork.com
suggests this is a cutting edge topic for the profession. I hope that the CHAS membership is open to being part of that discussion.
Let me know if you have any questions about this.
- Ralph
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859
ralph.stuart**At_Symbol_Here**keene.edu
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