The benefits of compliance

Uncertain economic times, a rising Canadian dollar, thin profits — those are the headlines in today’s newspapers. People who run manufacturing facilities have to take the current economic situation into consideration. As a result, “How to reconcile slashing budgets with health and safety compliance issues?” is a commonly asked question these days.

Health and safety compliance issues can be very costly and time-consuming. They are usually legislated and thus require compliance. A system that would allow spreading the burden of compliance over time would probably make sense.

A combined system of downloading the costs of compliance issues to vendors who supply equipment may be the way to balance the budgets. So let’s look at each component in detail.

Spreading compliance over time

Just imagine a machine in your plant that has not received preventive maintenance in very long tine. This machine will break one day, probably during the most critical time. The cost of repair will be significant.

Most of us discovered a long time ago that preventive maintenance ensures that the machine will not break at the most critical time and the cost of repairs will be controlled as well.

The very same rationale could apply to the management of health and safety issues. In other words, do not wait until an accident happens or an inspector shows up. Do some proactive work. Doing the proactive work falls within what due diligence is about.

We all need to demonstrate due diligence in our day-to-day activities. Due diligence is the only form of defense we may claim in the case of an accident.

Courts determine whether due diligence steps have been taken based on the following:

Knowledge of legal obligations such as OHSA regulations, usually achieved through training

Knowledge of hazards, usually achieved through audits conducted by company staff and outside consultants

Action based on hazard assessment, usually achieved through the development of a corrective action plan

A written health and safety policy, usually achieved through up-to-date procedures

Training

Supervisory monitoring, usually achieved through monitoring of high-risk problems

Coordination and communication, usually achieved through communication with contractors, work crews, etc.

Enforcement, usually achieved through discipline

Documentation, usually achieved through lots of paper work.

Doing proactive work and spending a little bit of money on health and safety on a regular basis are equivalent to preventive maintenance. Once such a culture is established in an organization, health and safety issues will not have a significant effect on budgets.

Downloading compliance issues to venders when equipment is purchased

Just imagine that you have purchased a machine to meet your production needs. Section 7 of Reg. 851 under the Ontario Occupational Health & Safety Act mandates that a Pre-Start Health and Safety Review (PSR) is required to be conducted by a Professional Engineer.

Based on my personal experience, on many occasions this new machine may require additional protection. Since it is the responsibility of the owner to make sure that the equipment is in compliance, in many cases the cost to achieve compliance is borne by the owner. Not only does the cost of additional work have to be taken into consideration, but also the cost of the delays before the equipment starts to produce.

However, there is a better way. It’s called a purchasing specification approach.

Through an engineering firm specializing in PSRs, the purchaser can pass on the responsibility for PSRs to its suppliers of machinery before the shipment is accepted.

Engineering professionals will work with the suppliers and end users during the manufacture of the equipment. They will advise the supplier about the local compliance requirements, and co-ordinate any potential issues with the end users.

This approach will ensure that when equipment arrives at its final destination, it is immediately operational. The PSR will come with the equipment. An engineer will assume the liability associated with this process.

For example, S.A.F.E. Engineering Inc. enrols equipment suppliers in a program that enables them to save significantly on the expenses associated with PSRs for their equipment. The savings are usually passed on to the end user.

Having pre-PSRed equipment enhances its marketability. Many suppliers absorb the PSR expense so that it is, in effect, free to the end user. It is no different than equipment suppliers providing CSA electrical certification to their clients at no extra cost. It is just good for business.

In other words, if it is planned ahead of time and the purchasing specification approach is used, there is only a nominal cost to the end user. There are no delays and no huge expenses.

Safety is directly linked to productivity. Costs associated with safety compliance are usually well compensated by productivity increases. With proper planning, it certainly makes sense to be in compliance regarding health and safety.

Safety File columnist Simon Fridlyand, P.Eng., is president of S.A.F.E. Engineering of Toronto, a company specializing in industrial health and safety issues and compliance. He can be reached at 416-447-9757 or at simon@safeeingineering.ca.