4.2 Intuitive Approach
Perhaps more familiar to most, the intuitive approach relies on one's sense of right and wrong in a given situation. Rather than reasoning through possible options and outcomes, decisions are made based on gut feelings. Wachter provides a list of tests based on intuition for health and safety professionals, which include the “front page test” (how would you feel if your decision were publicized in the newspaper?), role model/parent test (how would you feel if someone whose opinion you valued greatly learned about your decision or actions?), and the “stench/gut level test” (do your actions make you uncomfortable or make you feel badly?) among others.
5 BUSINESS CASE FOR EHS ETHICS
In addition to the personal and societal benefits of ethical behavior, there are professional and commercial benefits to the individual and the organization of utilizing ethical approaches to health and safety. According to Wachter, these include building trust and loyalty among employees, shareholders, and the public; avoiding fines due to non‐compliance, and limiting government intervention. Obvious examples of the failure to operate ethically include the Enron financial scandal and the Bernie Madoff Ponzi scheme, and more recently, Wells Fargo's creation of millions of fake accounts, and Volkswagen cheating on emissions tests.
When scandals eventually come to light, as they did in the above‐mentioned examples, clients, consumers, and shareholders lose faith in the companies, share prices drop, fines are levied, and in some cases, individuals – including CEOs – go to jail. The examples provided are at one extreme, but one can imagine the same types of events on a smaller scale: a consulting company underbidding a contract and cutting corners to complete a project or a health and safety professional overstating their qualifications and missing an important violation in an internal audit resulting in a citation fromxs OSHA.
Health and safety is often considered a cost, one frequently framed as at odds with production. However, there is evidence that, in addition to the right thing to do and preventing major incidents that can result in the kind of reputational and/or economic insult that gets the attention of CEOs, good health and safety programs can result in savings and increased productivity.
According to OSHA's webpage on Business Case for Safety and Health, “In its 2017 Workplace Safety Index, Liberty Mutual estimated that employers paid more than $1 billion per week for direct workers' compensation costs for disabling, non‐fatal workplace injuries in 2014” (15). An article published by researchers at Liberty Mutual, Harvard University, University of Wisconsin, Oshkosh, and Colorado State University, showed that most executives said that for every dollar their company spent on workplace safety, they saved at least three dollars. The authors also stated that financial decision makers, on average, reported that for every dollar spent improving the workplace approximately $4.41 would be returned.8 One study, published in the American Society of Safety Engineers Journal of SH&E Research, showed improvements in operating performance in manufacturing (16) and another study showed Corporate Health Achievement Award winners outperformed the market (17).
5.1 Making Your Case
Multiple organizations have introduced frameworks and tools to demonstrate the importance of and value in investing in health and safety. Some resources that may be helpful include:
Safety Pays (OSHA): https://www.osha.gov/safetypays/
Safety Pays in Mining (NIOSH): https://www.cdc.gov/niosh/mining/content/economics/safetypays.html
Business Case for Process Safety (AIChE): https://www.aiche.org/ccps/business-case-process-safety-pdf
Construction Solutions Return on Investment Calculator (CPWR): https://www.safecalc.org/
Technical Framework: Business Value Presentation: https://www.aiha.org/education/frameworks/technical-framework-business-value-presentation
It may not be sufficient to demonstrate the monetary, reputational, or other benefits associated with a health or safety improvement to gain support from management, workers, human resources, finance, or other decision makers. John P. Kotter, an internationally recognized researcher and author of multiple books on leadership and change, outlines eight common errors made by those seeking to make change and eight steps for effectively achieving it. The eight steps are as follows (18):
1 Establishing a sense of urgency
2 Creating the guiding coalition
3 Developing a vision and strategy
4 Communicating the change vision
5 Empowering broad‐based action
6 Generating short‐term wins
7 Consolidating gains and producing more change
8 Anchoring new approaches in the culture.
Invoking the all‐to‐common situation of the “lone IH,” below is a sample approach more specific to a single issue in the field. In this example, the IH is advocating for an engineering control, such as installation of local exhaust ventilation, to remove the need for respirators in an operation. Note that Kotter specifies that the steps do not always proceed sequentially and often need to overlap, but skipping steps or skipping too far ahead is not recommended.
1 Present the concern and potential ramifications of maintaining the status quo – this might include concerns about respirators as a last line of defense, potential for citations for failing to implement feasible engineering controls, and the cost of maintaining a respiratory protection program, among others.
2 Build a team. Obtain buy in from and involve decision makers, influential leaders, and those affected by the change. This could be a task force or small committee.
3 Work with the team to research options, costs, and develop a plan for implementation.
4 Share the concern and proposed solution and plan with those who will be involved with and responsible for the implementation of the proposed solution. Involving the workers who will be using or affected by the engineering control is particularly crucial to ensuring it fits with their workflow and will be utilized.
5 Provide opportunities for others to take actions necessitated by the change, such as training for workers, supervisors, and management on their roles related to the engineering control. Remove barriers to utilizing the new engineering control, such as outdated operating procedures or interfering equipment. Confirm that the new control does not affect other aspects of operation. Rewrite existing procedures to reinforce use of the engineering control.
6 Implementation of an engineering control could be a short‐term win for a larger IH program or campaign, but small wins in the implementation will also be helpful for ensuring support for the work. “Plan for results,” as Kotter suggests. Include milestones in the installation plan, such as project approval, design completion, starting construction, testing (including air monitoring), and launch and removal of respirator requirements.
7 Using the momentum of the smaller gains, enlist additional help to meet the primary goals, in this case, the implementation of the engineering control. At this stage, Kotter recommends giving more agency and leadership to lower ranks, perhaps this could mean delegating some of the remaining key deliverables to members of the task force. Management's role, says Kotter, is to convey the shared purpose and urgency of change.
8 In order for any change to last, Kotter strongly suggests “grafting” some of the key new aspects or values of the chance onto the existing culture. This could mean something as simple as ensuring