In these unprecedented times, the attention of businesses is understandably focused on protecting the health of employees against the effects of COVID-19, but it is important to continue to remember and manage on-going health and safety risks that may be heightened during this crisis due to organizational changes, cost constraints, supply chain interruptions and the impact of human factors.
Over the next few weeks and months, companies may experience the loss of key personnel, or enact deliberate reorganization to separate the workforce. Employee illness combined with and the need for flexible working may lead to staffing shortages and gaps that could lead to increased workload.
Gaps in competency could also result in employees being redeployed to unfamiliar tasks. Limiting interactions also has the potential to degrade safety critical communications such as shift handover and normal processes of task briefing and job risk assessment/management.
The current situation and impact to the organization may also create gaps in supervision and sign-off of work and weaken the emergency response management and practice. Any deviations from previous safe systems of work will require more robust application of procedures and authorisation. This all has the potential to increase the frequency of situational and exceptional violations:
- Situational violation – due to workload or misidentification of equipment
- Exceptional violation – a compounding error following a misdiagnosis of a situation
The following mitigation measures and supporting guidance may be helpful.
Medical screening and tracking of personnel contacts
Your teams may be experiencing stress and anxiety over the current situation that could degrade human performance and promote human error. The most direct means to combat anxiety is to provide clear information and guidance to people. Reducing uncertainty restores confidence and alleviates stress. Most organizations are advancing with the implementation of systems of health monitoring and keeping a record of personnel contacts.
Within the limits permitted by General Data Protection Regulations (GDPR) (where applicable), organizations are developing corporate and business unit plans, establishing central repositories to track actions and deadlines and ensure a single source of guidance relating to employee health, safety and exposure risk. Where possible these efforts are digitally enabled and support identifying and tracking of employees that have been confirmed, suspected, or potentially at risk; and developing and embedding consistent company processes to protect them.
Keeping your staff informed of the risk and the precautions they should apply is a key step. Key global resources include the World Health Organization, the UK Government and US Occupational Safety & Health Administration COVID-19 advice
Management of change
As mentioned above, we may have to make significant changes to our operations to respond to the threat and impact of COVID-19. When there is a qualitative change to the planned mode of operation good practice demands a comprehensive risk assessment.
The change may arise from a reconfiguration of technology, or a temporary alteration to the work process. This may be due to changes in personnel, workforce complement or the introduction of a new working method or procedure. The purpose of the risk assessment is to fully understand the changes and how these will affect the normal systems of risk management that are relied upon to maintain safety.
In any organization the review and ultimate approval for any change should be conducted by a specified competent individual whose seniority is commensurate with the degree of risk involved. A thorough management of change process will seek assurance of the ongoing integrity of risk management controls.
If any of these are compromised, unavailable or impaired the decision to continue normal operation should be based on an appropriate technical and risk-based demonstration that safety can be managed within acceptable limits. The decision cannot be based on casual claims such as “…it will be OK, what are the chances of a problem.” The argument that something is safe merely because you think an accident is unlikely is not good enough. You must have evidence that the remaining risk management solution is sound. The following are some good practice sources on Management of Change.
- US Occupational Safety & Health Administration
- UK HSE: Human factors organizational Change
- OHSAS 18001 Expert
- Worksafe Australia
Technology enhanced training and inspection
Given that people will have to step in to fulfil critical operational roles it is essential that they are competent to do so. Many people may have historic competence from previous roles earlier in their career, and their knowledge may have faded or is now incomplete. Ideally people should be trained again before taking-up these roles. But obvious barriers are the lack of available training resource and the increased risk associated with the interaction normally necessary for training. Companies are now looking to innovate with technology and some have even employed simple video solutions where in a supervisor makes a round of the plant with a camera to highlight key tasks and interactions. Their commentary can be expanded by trainers and used as a briefing solution for redeployed workers.
This approach is being used in a live feed mode as well as a pre-recorded mode. Some companies are also using this approach for condition monitoring with the videos being shared with engineering teams who can review and support the outside operator’s observations of plant condition. The continued use of these techniques can also serve a role for live supervision and work approval to support in-field operators and reinforce human performance.
In addition to hand held and helmet mounted cameras or body cams, some companies are also using drones for certain types of inspection work. Altogether these approaches can help to make effective use of a depleted workforce and to improve human reliability through collaboration. They can also be used to maintain schedules of certification audits and inspections and some audit companies will work with their clients to manage audits supported by technology in this way. Two examples are Intel Drone Technology and GoPro, though there are many alternatives available locally around the world.
Reducing health and safety budgets
Companies may make cost based decisions that inadvertently compromise safety and integrity management. This might include reducing the number of employees responsible for managing health and safety management, reducing the frequency of internal and external auditing, not replacing Personal Protective Equipment (PPE), etc. Alternatively, some tasks that rely on specialist PPE may be delayed or postponed due to short supply. In addition, spares may be in short supply, meaning that some perishable items are forced into extended duty.
These are all factors that can erode the normal safety margins within our operations.
Supply chain interruptions
Key contractors that are normally relied upon to perform safety critical and specialist tasks may be depleted, or just unavailable. This may mean that critical maintenance and inspection work is delayed or postponed. This could mean drifting into operating safety critical controls and assets outside of normal safe operating parameters. Here too these influences should be recognised and treated through the robust management of change process mentioned above.
Impact on human behaviour
Heightened focus on COVID-19 is likely to stimulate stress and anxiety which will be significant distractors that could influence the quality of human performance. Stress and anxiety may include worries about personal health and the health of family members, worries about job security and worries about income security and financial distress.
Stress may also be compounded by being asked to work in unusual or unfamiliar working conditions. Fatigue caused by extended work hours, or poor quality rest at home, may also result in a loss of focus, attention and distraction. This increases the likelihood of lapses and mistakes that have the potential to increase the likelihood and severity of accidents and incidents.
Increased complexity and uncertainty in decision-making allows greater influence of cognitive biases and increased incidence of mental health conditions will affect and may delay rebound from the crisis.
To mitigate these potential impacts, you may look to consider the following:
- Take actions to manage and support people - In this respect the actions will be largely similar to what most companies are already doing. Manage contacts between people, implement health surveillance, increase communications and attempt to reduce uncertainty through allowing flexibility and answering the questions openly and honestly. Reducing anxiety means reducing uncertainty and enabling people to feel more in control. These measures will help to manage distraction but are only one step in managing the risk from human error.
- Separate the workforce into two (or more) non-mingling populations so that you can manage critical operations with reduced capacity. This may of course mean that you have to change operational demands commensurate with the smaller workforce deployed and could mean cutting back productivity in line with the new safe operating limits. This is prudent risk management.
- Reinforce supervision and collective decision-making and add layers of verification to the most risky decisions, draw on the pool of senior competent people. Use technology to enable communications and support to decision-making as described above.
- Shift to or reinforce risk-based decision making – Many companies already have something akin to an authority to operate process or a pre-start safety review process. In each case a specified competent individual will authorise a process or plant operation based on a satisfactory demonstration that all safety checks have been completed and passed.
These processes should be applied more robustly to consider how operations and production will be managed under a changed risk profile. This means understanding the new risk profile; recognising the critical activities required to maintain the risk at a stable level; and to be prepared to stop certain operations when risk parameters exceed tolerable criteria.
Avoid the temptation to promote agile/flexible decision making in the interests of doing things quickly. This often only dilutes the good practices of risk based decision making. Decision making needs to be based on redlines that are agreed in advance. The best organizations plan their operating rules in advance and stay firm to these decision points even under duress. This is being a resilient organization.
Finally think about the suitability of your facilities to manage spatial distancing practices at work. Where people have to be present in the workplace, can you enable your workers to maintain healthy distancing? Things to think about are:
- Separation of workstations, or provide enclosed office spaces
- Clean equipment that is used by more than one person
- Cleaning regimes – a Hong Kong company has been disinfecting lifts, handrails and door handles every hour
- Do you have sufficient toilet facilities, supplied with hand sanitizers and paper towels
- Are you managing contaminated waste (such as hand towels) from the premises
- Kitchen/break areas should be cleaned regularly too.
You should also be thinking about your technology capability. If you are using video conferencing more frequently does you system have the capacity to cope? Where you have people working at home have you provided advice to manage their exposure to ergonomic risk factors?
Some useful links include:
- A practical display-screen equipment checklist
- US Occupational Safety & Health Administration
- Worksafe Australia
- ErgPlus 10 Tips
Albeit that we appear still to be in the worsening phase of this pandemic it’s not too soon to turn our attention to planning for the recovery. Companies can start now to put themselves on a strong footing for the return. Continuing efforts to management health of employees now and as we manage the impact will be a major focus. Even as the peak passes and people can start to come back to work we must anticipate that the return will be staggered. Illness, personal circumstances and family demands will mean that workers will return piecemeal. A consequence of this will be that gaps in critical competencies may continue for some time and must be managed through effective management of change.
As people return it may be tempting to relax some special control measures too quickly. But doing so prematurely may spark a new wave of infections and so we must continue to seek and follow the best available public health advice.
Most importantly, we must maintain effective staff communications throughout the recovery phase. Not only to keep people informed but also to identify and respond where our colleagues still need help.
The practices outlined here are intended to assist you to identify and manage the impacts on human performance that may arise from COVD-19 and how these can affect the immediate and longer term operational integrity of your business.