When Regulation Improves Operating Performance

I had the good fortune to meet the forward-thinking Safety Director of a medium-size transit authority last week. We got into a discussion about the merits of the Public Transportation Agency Safety Plan (PTASP) rule for which compliance is mandatory for most transportation agencies by July 20, 2020.

Her agency was largely in compliance before the regulation became law, so finishing up was pretty easy. Now they are automating from their current paper-based program. A move that will save significant time and improve both accuracy and accountability in their continual improvement program.

PTASP, ISO 45001 & VPP – How They All Relate

While reviewing the PTASP Final Rule, I was struck by the similarities to ISO 45001 and OSHA’s VPP, but perhaps I shouldn’t have been. All three programs have evolved over the last decade(s). Driven by more or less the same goal of safer workplaces by reducing worker exposure to risks, and grounded from the same experience base.

Check out this side-by-side comparison of key explicit requirements of the three programs:

Clearly an organization that reduces worker injures will operate more profitably, but the benefits of embracing the standards imposed by any of these programs extend beyond injury reduction. The central theme of all three programs is:

1. visible, active participation of employees at all levels of an organization
2. supporting the involvement of all workers in an on-going program of hazard identification and mitigation
3. which supports on-going improvement of processes.

The employees of these organizations hold each other accountable for the continual improvement of their organizations. A discipline that ISO explicitly extends to operations generally. In my experience, this shows in the positive attitudes and effective operations of ISO and VPP compliant sites.

Setting the Safety Standard Bar

It is fair to ask whether organizations already had these disciplines, and implementing standards for safety performance was just an extension, or did embracing a defined safety management system drive general performance improvement. I actually have no hard evidence, but I suspect that it is not either/or. It is all about developing habits and increasing awareness about your environment. Create a pattern of looking for and reporting safety observations, and this easily extends to looking for and reporting general improvement opportunities.

An organization must have some kind of cultural inclination to strive for performance beyond “just acceptable” to embrace standards of performance that set them above their peers. I have never known a company whose approach to safety management is doing only the minimum required for OSHA compliance to be a top 1% performer in all other aspects of their industry.

Safety standards that set a bar for excellence in safety management may turn out to be a terrific, and manageable, place to start turning your company into a center of excellence. That certainly seems to me to be a great reason to embrace the program.