Home Work

Question 1

In the article “Stepping Up to Operational Safety Excellence,” by L. L. Hansen, the author outlines four stages on the safety excellence continuum: SWAMP, NORM, EXCELLENCE, and WORLD CLASS. Where is your current organization, or one you worked for previously, on this continuum? Discuss the evidence that led to your conclusion. What efforts are needed to raise it to the next level? If you feel that your organization has achieved WORLD CLASS status, what is needed to ensure that the level is maintained? Your response must be at least 300 words in length. You are required to use at least your textbook as source material for your response. All sources used, including the textbook, must be referenced; paraphrased and quoted material must have accompanying citations.

Question 2

Since risk cannot be reduced to zero, the ALARP concept is often applied. What might be some pitfalls to applying this concept? In your response, include how ALARP might be affected by an organization’s financial considerations, as well as how ALARP and “acceptable risk” are related. Your response must be at least 300 words in length. You are required to use at least your textbook as source material for your response. All sources used, including the textbook, must be referenced; paraphrased and quoted material must have accompanying citations.

Unit III Assignment

Safety Policy Statement

Compose a safety policy statement for your current organization (or an organization for which you previously worked), following the guidelines in the course textbook. Be certain it is specific to the organization, and not just a series of generic statements.

On a new page at the end of your policy statement, briefly propose how the statement should be distributed to the organization. You may also add additional comments or explanations as needed. If you use any sources other than your own experience, you must include a reference list and in-text citations.

You may choose any format for the layout of your policy statement. For this assignment, APA formatting is required only for references and citations. A title page is not required. Be sure to include your last name in the name of the uploaded file, e.g., last name_safety policy (500 words)

Read:

 Chapter 5: Management Leadership and Employee Participation – Section 3.0

 Chapter 6: Achieving Acceptable Risk Levels: The Operational Goal

 Hansen, L. L. (2005). Stepping up to operational safety excellence. Occupational Hazards, 67(5), 43-47. (Available in the Business Source Complete database of the CSU Online Library)

 Manuele, F. A. (2010). Acceptable Risk. Professional Safety, 55(5), 30-38. (Available in the Business Source Complete database of the CSU Online Library)

We have said that managers, supervisors, and employees all have individual responsibilities for safety and need to be held accountable. What then, is the role of safety professionals? How should they be held accountable? What has been your observation/experience in this regard as a safety professional or while dealing with safety professionals? Please give a full and practical example to the clsss.

30 PROFESSIONAL SAFETY MAY 2010 www.asse.org

Risk AssessmentRisk Assessment

Acceptable
Risk

Time for SH&E professionals to adopt the concept
By Fred A. Manuele

THETERMACCEPTABLERISK is frequently used in
standards and guidelines throughout the world, yet
a substantial percentage of those with SH&E respon-
sibilities are reluctant to adopt or use it. Evidence of
this reluctance often arises in discussions surround-
ing the development of new or revised standards or
technical reports. The aversion may derive from:
•a lack of awareness of the nature of risk;
•concern over the subjective judgments made

and the uncertainties that almost always exist when
risks are assessed;
•the lack of in-depth statistical probability and

severity data that allows precise and numerically
accurate risk assessments;
•insufficient real-world experience in more haz-

ardous environments where nontrivial risks are nec-
essarily accepted every day.
However, in recent years, the concept of accept-

able risk has been interwoven into international
standards and guidelines for a broad range of equip-
ment, products, processes and systems. This has
occurred in recognition of the fact that risk-related
decisions are made constantly in real-world applica-
tions and that society benefits if those decisions

achieve acceptable risk levels.
This primer is designed to

help readers gain an under-
standing of risk and the con-
cept of acceptable risk. The
far-reaching premise presented
is fundamental in dealing with
risk. Several examples of the
use of the term acceptable risk
as taken from the applicable lit-
erature. Discussions address
the impossibility of achieving
zero risk levels, the inadequacy
of minimum risk as a replace-
ment term for acceptable risk,
and the shortcomings that may
result from designing only to a

standard’s requirements. Finally, the “as low as rea-
sonably practicable (ALARP) concept” is presented
with an example of how it is applied in achieving an
acceptable risk level.

Fundamental Premise
The following general, all-encompassing premise

is basic to the work of all personnel who give coun-
sel to prevent injury, illness and damage to property
and the environment.
The entirety of purpose of those responsible
for safety, regardless of their titles, is to identi-
fy, evaluate, and eliminate or control hazards
so that the risks deriving from those hazards
are acceptable.
That premise is supported by this theory: If there

are no hazards, if there is no potential for harm, risks
of injury or damage cannot arise. If there were no
risks, there would be no need for SH&E profession-
als. (Note: For simplicity, the terms hazard, risk and
safety apply to all hazard-related incidents or expo-
sures that could cause injury or illness, or damage
property or the environment.)

Use of the Term Acceptable Risk
The more frequent use over time of the term

acceptable risk in standards and guidelines is
notable, as the following citations show. SH&E per-
sonnel reluctant to adopt the concept implied by the
term should consider the breadth and implication of
this evolution. The term acceptable risk is becoming
the norm. The following (intentionally lengthy) list
of citations shows how broadly the concept of
acceptable risk has been adopted.
1) Lowrance (1976) wrote, “A thing is safe if its

risks are judged to be acceptable.”
2) The following citation, from a 1980 court deci-

sion, is significant because it has given long-term
guidance with respect to Department of Labor poli-
cy and to the work performed by NIOSH.

Fred A. Manuele, P.E., CSP, is president of
Hazards Limited, which he formed after retiring

from Marsh & McLennan where he was a
managing director and manager of M&M
Protection Consultants. He is the author of
several books, including Advanced Safety

Management: Focusing on Z10 and Serious Injury
Prevention, On the Practice of Safety, Innovations

in Safety Management: Addressing Career
Knowledge Needs and Heinrich Revisited: Truisms

or Myths.Manuele was also coeditor of Safety
Through Design. He is an ASSE Fellow, a

professional member of the Northeastern Illinois
Chapter and a member of the Engineering

Practice Specialty. He is a former board member
of ASSE, BCSP and National Safety Council.

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www.asse.org MAY 2010 PROFESSIONAL SAFETY 3

3) International Organization for Standardization
(ISO) and International Electrotechnical Commis-
sion (IEC) (1990) issued guidelines for including
safety aspects in standards. These guidelines pro-
vide standardized terms and definitions to be used
in standards for “any safety aspect related to people,
property or the environment.” The second edition,
issued in 1999, contains the following definitions:

Safety: freedom from unacceptable risk (3.1).
Tolerable risk: risk which is accepted in a given

context based on the current values of society (3.7).
4) Fewtrell and Bartram (2001), in a document for

World Health Organization, address standards relat-
ed to water quality. They offer the following guide-
lines for determining acceptable risk.

Arisk is acceptablewhen: it falls below an arbi-
trary defined probability; it falls below some
level that is already tolerated; it falls below an
arbitrary defined attributable fraction of total
disease burden in the community; the cost of
reducing the risk would exceed the costs
saved; the cost of reducing the risk would
exceed the costs saved when the “costs of suf-
fering” are also factored in; the opportunity
costs would be better spent on other, more
pressing, public health problems; public health
professionals say it is acceptable; the general
public say it is acceptable (or more likely, do
not say it is not); politicians say it is acceptable.

5) OSHA (2003) set forth requirements for organ-
izations seeking certification under the agency’s Vol-
untary Protection Programs (VPP):

The Supreme Court’s benzene decision of 1980
states that “before he can promulgate any per-
manent health or safety standard, the Secretary
[of Labor] is required tomake a threshold find-
ing that a place of employment is unsafe—in
the sense that significant risks are present and
can be eliminated or lessened by a change in
practices” (Industrial Union Department, AFL-
CIO v. American Petroleum Institute U.S. at 642).
The Court broadly describes the range of risks
OSHA might determine to be significant: It is
the agency’s responsibility to determine in the
first instance what it considers to be a “signifi-
cant” risk. Some risks are plainly acceptable and
others are plainly unacceptable (emphasis added).
For example, if the odds are 1 in 1 billion

that a person will die from cancer by taking a
drink of chlorinated water, the risk clearly
could not be considered significant. On the
other hand, if the odds are 1 in 1,000 that reg-
ular inhalation of gasoline vapors that are 2%
benzene will be fatal, a reasonable person
might consider the risk significant and take
appropriate steps to decrease or eliminate it.
The Court further stated:

The requirement that a “significant” risk
be identified is not a mathematical straitjack-
et. Although the agency has no duty to cal-
culate the exact probability of harm, it does
have an obligation to find that a significant
risk is present before it can characterize a
place of employment as “unsafe” and pro-
ceed to promulgate a regulation.

Abstract: The term
acceptable risk is
becoming the norm.
The more frequent
use over time of the
term acceptable risk
in standards and
guidelines is notable.
SH&E personnel
reluctant to adopt
the concept implied
by the term would
do well to focus on
the breadth and
implication of this
evolution, and recon-
sider their views.

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32 PROFESSIONAL SAFETY MAY 2010 www.asse.org

Acceptable risk:An acceptable level of risk for
regulations and special permits is established
by consideration of risk, cost/benefit and pub-
lic comments. Relative or comparative risk
analysis is most often used where quantitative
risk analysis is not practical or justified. Public
participation is important in a risk analysis
process, not only for enhancing the public’s
understanding of the risks associated with
hazardous materials transportation, but also
for ensuring that the point of view of all major
segments of the population-at-risk is included
in the analyses process.
Risk and cost/benefit analysis are important

tools in informing the public about the actual
risk and cost as opposed to the perceived risk
and cost involved in an activity. Through such a
public process PHMSA establishes hazard clas-
sification, hazard communication, packaging
and operational control standards.

12) ANSI/PMMI B155.1-2006 on packaging
machinery and packaging-related converting
machinery contains this definition: “Acceptable risk:
risk that is accepted for a given task or hazard. For
the purpose of this standard the terms acceptable risk
and tolerable risk are considered synonymous (3.1).”
13) In the 2007 revision of BS OHSAS 18001:2007

on occupational health and safety management sys-
tems, British Standards Institution (BSI) made a sig-
nificant change. Specifically, the term tolerable risk
was replaced with the term acceptable risk (3.1).
14) In the introduction of IEC 60601-1-9 (2007),

which addresses medical equipment design, IEC
states, “The standard includes the evaluation of
whether risks are acceptable (risk evaluation).”
15) A machinery safety document issued in 2009

by the Institute for Research for Safety and Security
atWork and the Commission for Safety and Security
at Work in Quebec, Canada, states, “When machine-
related hazards . . . cannot be eliminated through
inherently safe design, they must then be reduced to
an acceptable level.”
16) ASSE’s (2009) technical report on prevention

through design includes the following information:

Scope and Purpose
1.3 The goals of applying prevention through
design concepts are to:

1.3.1 Achieve that state for which risks are at an
acceptable level.

Definitions
Acceptable risk: That risk for which the probabil-
ity of a hazard-related incident or exposure occur-
ring and the severity of harm or damage that may
result are as low as reasonably practicable
(ALARP) and tolerable in the setting being con-
sidered.
ALARP: that level of risk which can be further
lowered only by an increment in resource expen-
diture that is disproportionate in relation to the
resulting decrement of risk.

Worksite Analysis.Ahazard identification and
analysis system must be implemented to sys-
tematically identify basic and unforeseen safety
and health hazards, evaluate their risks, and pri-
oritize and recommendmethods to eliminate or
control hazards to an acceptable level of risk.

6) ANSI/ASSE Z244.1-2003(R2009) on lockout/
tagout states, “A.2: Acceptable level of risk: If the
evaluation in A.1.6 determines the risk to be accept-
able, then the process is completed. . . .”
7) UN (2009) offers this definition when address-

ing basic terms of disaster risk reduction: “Accept-
able risk: The level of potential losses that a society
or community considers acceptable given existing
social, economic, political, cultural, technical and
environmental conditions.”
8) The online Sci-Tech Dictionary (accessed at

www.answers.com/topic/acceptable-risk-geo
physics) provides this definition of acceptable risk as
the term is used in geology:

Acceptable risk: (geophysics) In seismology,
that level of earthquake effects which is
judged to be of sufficiently low social and eco-
nomic consequence, and which is useful for
determining design requirements in structures
or for taking certain actions.

9) Australia/New Zealand AS/NZS 4360: 2004
risk management standard uses this definition (in
1.3.16): “Risk acceptance: An informed decision to
accept the consequences and the likelihood of a par-
ticular risk.”
10) ANSI/AIHAZ10-2005 contains the following

citations with respect to acceptable risk.

E5.1.1: Often, a combination of controls is
most effective. In cases where the higher order
of controls (elimination, substitution and
implementation of engineering controls) does
not reduce the risk to an acceptable level,
lower order controls may be necessary.
Appendix E (Informative), Assessment and

Prioritization (Z10 Section 4.2): The last sen-
tence in Step 7 in a Hazard Analysis and Risk
Assessment Guide says: “The organization
must then determine if the level of risk is
acceptable or unacceptable.”
A definition of residual risk follows the hazard

analysis and risk assessment guide in Z10:
Risk can never be eliminated entirely, though
it can be substantially reduced through appli-
cation of the hierarchy of controls. Residual
risk is defined as the remaining risk after con-
trols have been implemented. It is the organi-
zation’s responsibility to determine whether
the residual risk is acceptable for each task and
associated hazard. Where the residual risk is
not acceptable, further actions must be taken
to reduce risk.
11) DOT’s Pipeline and Hazardous Materials

Safety Administration (PHMSA, 2005) has issued
risk management definitions, including this one:

http://www.answers.com/topic/acceptable-risk-geophysics

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www.asse.org MAY 2010 PROFESSIONAL SAFETY 33

risk. One resource, the Framework for Environmental
Health Risk Management (The Presidential Congres-
sional Commission on Risk Assessment and Risk
Management, 1997), was selected for citation because
of its broad implications. Excerpts follow.

What Is “Risk”
Risk is defined as the probability that a sub-
stance or situation will produce harm under
specified conditions. Risk is a combination of
two factors:
•the probability that an adverse event will

occur;
•the consequences of the adverse event.
Risk encompasses impacts on public health

and on the environment, and arises from expo-
sure and hazard. Risk does not exist if exposure
to a harmful substance or situation does not or
will not occur. Hazard is determined by
whether a particular substance or situation has
the potential to cause harmful effects. Risk . . . is
the probability of a specific outcome, generally
adverse, given a particular set of conditions.
Residual risk . . . is the health risk remain-

ing after risk reduction actions are implement-
ed, such as risks associated with sources of air
pollution that remain after implementation of
maximum achievable control technology.
Risk assessment . . . is an organized process

used to describe and estimate the likelihood of
adverse health outcomes from environmental
exposures to chemicals. The four steps are haz-
ard identification, dose-response assessment,
exposure assessment and risk characterization.

Zero Risk: Not Attainable
It has long been recognized that zero risk levels

are not attainable. If a facility exists or an activity
proceeds, it is impossible to realistically conceive of
a situation that presents no probability of an adverse
incident or exposure occurring. According to
Lowrance (1976):
Nothing can be absolutely free of risk. One

About the Foregoing Citations
1) Since it is almost always the case that

resources are limited, this phrase in the
WHO citation, “the opportunity costs
would be better spent on other, more
pressing problems,” has a significant bear-
ing on risk acceptance decision making
and on priority setting.
2) Several citations relate to the fact that

residual risk cannot be eliminated entirely
and that residual risk acceptance decisions
are commonly and frequently made.
Whenever a productionmachine is turned
on, a residual risk level is being accepted.
Every time a design decision is made or a
product design is approved, thosemaking
the decision approve a residual and
acceptable risk level.
3) Definitions of acceptable risk nearly

identical to that in ANSI/PMMI B155.1-
2006 appear in ANSI B11-2008, General Safety
Requirements Common to ANSI B11 Machines, and
ANSI/AMTB11.TR7-2007,ANSI Technical Report for
Machines: A Guide on Integrating Safety and Lean
Manufacturing Principles in the Use of Machinery.
4) Replacing the term tolerable risk with acceptable

risk in BS OHSAS 18001 by an organization as influ-
ential as BSI is noteworthy. In some parts of the
world, because of requirements in contract bid situ-
ations, companies must show that their safety man-
agement systems are “certified.” BS OHSAS 18001 is
often the basis of such certification. This modifica-
tion by BSI indicates that the goal to be achieved is
acceptable risk levels.
As the cited references illustrate, the concept of

acceptable risk has been broadly adopted interna-
tionally, and the term is becoming the norm. SH&E
professionals who are reluctant to adopt this concept
would do well to recognize that they have an obli-
gation to be current with respect to the state of the
art and reconsider their views.

The Nature & Source of Risk
Risk is expressed as an estimate of the probabili-

ty of a hazard-related incident or exposure occurring
and the severity of harm or damage that could
result. All risks with which SH&E professionals deal
derive from hazards without exception. A hazard is
defined as the potential for harm. Hazards include
all aspects of technology and activity that produce
risk. Hazards include the characteristics of things
(e.g., equipment, dusts, chemicals) and the actions or
inactions of people.
The probability aspect of risk is defined as the

likelihood of an incident or exposure occurring that
could result in harm or damage—for a selected unit
of time, events, population, items or activity being
considered. The severity aspect of risk is defined as
the degree of harm or damage that could reasonably
result from a hazard-related incident or exposure.
Comparable statements and definitions appear in

much of the current literature on risk and acceptable

Table 1Table 1
Occupations With
High Fatality Rates

Note. Data from National Census of Fatal Occupational Injuries in
2007 (USDL 08-1182), by Bureau of Labor Statistics, U.S. Department
of Labor, 2008, Washington, DC: Author.

aper 100,000 workers

Although the fatality
rates among all
employment cate-
gories are highest for
the occupations high-
lighted in Table 1,
the public has not
demanded that the
operations in which
they occur cease.
The inherent risks in
the high-hazard cate-
gories are considered
tolerable.

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34 PROFESSIONAL SAFETY MAY 2010 www.asse.org

procedures, and plant and hardware come together
at the worksite to perform a given task.”
Start from the beginning in a process of creating a

new facility and the credibility of Stephan’s state-
ment is validated. Consider, first, a site survey for
ecological considerations, soil testing, then move
into the facility’s construction and fitting.
Thousands of safety-related decisions are made

in the processes that result in an imposed level of
risk. Usually, those decisions meet (or exceed) appli-
cable safety-related codes and standards with
respect to issues such as the contour of exterior
grounds, sidewalks and parking lots; building foun-
dations; facility layout and configuration; floor
materials; roof supports; process selection and
design; determination of the work methods; aisle
spacing; traffic flow; hardware; equipment; tooling;
materials to be used; energy choices and controls;
lighting, heating and ventilation; fire protection; and
environmental concerns.
Designers and engineers make decisions on these

issues during the original design processes. Those
decisions establish what the designers implicitly
believe to be acceptable risk levels. Thus, the occu-
pational and environmental risk levels have been
largely imposed before a facility begins operation.
Indeed, if those employed in such settings conclude
that the imposed risks are not acceptable, communi-
cation systems should be in place to allow them to
express their views and to have them resolved.

Minimum Risk as a
Substitute for Acceptable Risk
Those who oppose use of the term acceptable

risk often offer substitute terms. One frequent sug-
gestion is to say that designers and operators should
achieve minimum risk levels or minimize the risks.
That sounds good, until one explores application of
the terms.
Minimum means the least amount or the lowest

amount. Minimization means to reduce something
to the lowest possible amount or degree. Assume
that the threshold limit value (TLV) for a chemical is
4 ppm. For $10 million, a system can be designed,
built and installed that will operate at 2 ppm. For an
additional $100 million, a 1 ppm exposure level can
be achieved. Increase the investment to $200 million
and the result is an exposure level of 0.1 ppm.
At 2 ppm, the exposure level is acceptable, but

not minimum because a lower exposure level can be
achieved. Requiring that systems be designed and
operated to minimum risk levels, that risks be mini-
mized, is impractical because the investments neces-
sary to do so may be so high that the cost of the
product required to recoup the investment and
make a reasonable profit would not be competitive
in the marketplace.

Designing to Standards
as a Substitute for Acceptable Risk
Developing consensus standards often involves

lively discussion, strong stances, much debate and
many compromises. Some of these standards estab-

can’t think of anything that isn’t, under some
circumstances, able to cause harm. Because
nothing can be absolutely free of risk, nothing
can be said to be absolutely safe. There are
degrees of risk and, consequently, there are
degrees of safety.

Similar comments appear in ISO/IEC Guide 51,
under “The Concept of Safety” (section 5):

There can be no absolute safety: some risk will
remain, defined in this guide as residual risk.
Therefore a product, process or service can
only be relatively safe. Safety is achieved by
reducing risk to a tolerable level, defined in
this guide as tolerable risk.

In the real world, attaining a zero risk level,
whether in the design or redesign processes or in
facility operations, is not possible. That said, after
risk avoidance, elimination or control measures are
taken, the residual risk should be acceptable, as
judged by the decision makers.
Also, one must recognize that inherent risks

which are acceptable and tolerable in some occupa-
tions are not tolerable in others. For example, some
work conditions considered tolerable in deep sea
fishing (e.g., a pitching and rolling work floor, the
ship’s deck) would not be tolerable in other work
settings. In other situations, such as for certain chem-
ical or radiation exposures designed to function at
higher than commonly accepted permissible expo-
sure levels, the residual risk will be judged as unac-
ceptable and operations at those levels would not be
permitted.
Nevertheless, society accepts continuation of cer-

tain operations with high occupational and environ-
mental risks. This is demonstrated by fatality rate
data from the Bureau of Labor Statistics (Table 1, p.
33). The fatality rate (rounded) is the rate per 100,000
workers. The national average fatality rate for all pri-
vate industries is 4.0.
Although the fatality rates among all employ-

ment categories are highest for the occupations high-
lighted in Table 1, the public has not demanded that
the operations in which they occur cease. The inher-
ent risks in the high-hazard categories are consid-
ered tolerable. It should be recognized that
considerable research has been undertaken to make
those occupations safer.

Opposition to Imposed Risks
Literature is abundant about people’s resistance to

being exposed to risks they believe are imposed on
them. For some, the aversion to adopting the accept-
able risk concept derives from their view that
imposed risks are objectionable and are to be rebelled
against. Conversely, they accept the significant risks
of activities in which they choose to engage (e.g., ski-
ing, bicycle riding, driving an automobile).
This idea needs exploration, which commences

here with a statement that can withstand a test of
good logic. As Stephans (2004) says, “The safety of
an operation is determined long before the people,

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assessment and applied risk reduction literature.
ALARA stands for as low as reasonably achievable;
ALARP stands for as low as reasonably practicable.
Use of theALARAconcept as a guideline originated
in the atomic energy field. According to Nuclear
Regulatory Commission (2007):
ALARA . . . means making every reasonable
effort to maintain exposures to ionizing radia-
tion as far below the dose limits as practical,
consistent with the purpose for which the
licensed activity is undertaken, taking into
account the state of technology, the economics
of improvements in relation to benefits to the
public health and safety, and other societal and
socioeconomic considerations, and in relation

lish only minimum requirements. For example, the
scope of ANSI/AIHA Z10-2005 states, “This stan-
dard defines minimum requirements for occupation-
al health and safety management systems.” Also, if a
standard is obsolete, using it as a design base may
result in designing to obsolescence and perhaps
unacceptable risk levels.
Semiconductor Equipment and Materials Inter-

national (2006) convincingly addresses the need to,
sometimes, go beyond issued safety standards in the
design process and to have decisions on acceptable
risk levels be based on risk assessments.
Compliance with design-based safety stan-
dards does not necessarily ensure adequate
safety in complex or state-of-the-art systems. It
often is necessary to perform hazard
analyses to identify hazards that are
specific with the system, and develop
hazard control measures that ade-
quately control the associated risk
beyond those that are covered in exist-
ing design-based standards.
Designing to a particular standardmay

achieve an acceptable risk level, or it may
not. In any case, the results of risk assess-
ments and subsequent amelioration
actions, if necessary, should be dominant
in deciding whether acceptable risk levels
have been reached.

Considerations in
Defining Acceptable Risk
If the residual risk for a task or opera-

tion cannot be zero, for what risk level
does one strive? Resources are always lim-
ited, and there is never enough money to
address every hazard identified. As a
result, SH&E professionals must give
counsel so that the greatest good to socie-
ty, employees, employers and product
users is attained through applying avail-
able resources to obtain acceptable risk
levels, practicably and economically.
Determining whether a risk is accept-

able requires one to consider many vari-
ables. ISO/IEC Guide 51 (1999) speaks to
the concept of designing and operating for
risk levels as low as reasonably practicable.
Tolerable risk [acceptable risk] is deter-
mined by the search for an optimal bal-
ance between the ideal of absolute
safety and the demands to be met by a
product, process or service, and factors
such as benefit to the user, suitability
for purpose, cost effectiveness and con-
ventions of the society concerned.
Understanding cost effectiveness has

become a more important element in risk
acceptance decision making. That brings
the discussion to ALARA and ALARP,
commonly used acronyms in the risk

Table 2Table 2
Risk Assessment Matrix

Incident or exposure probability descriptions
Very low: Improbable, very unlikely
Low: Remote, may occur, but not likely
Moderate: Occasional, likely to occur sometime
High: Probable, likely to occur several times
Very high: Frequent, likely to occur repeatedly

Incident or exposure severity descriptions
Very low: Inconsequential with respect to: injuries or illnesses, system loss or

down time, or environmental chemical release
Low: Negligible: first aid or minor medical treatment only, non-serious

equipment or facility damage, chemical release requiring routine
cleanup without reporting

Moderate: Marginal: medical treatment or restricted work, minor subsystem
loss or damage, chemical release triggering external reporting
requirements

High: Critical: disabling injury or illness, major property damage and busi-
ness down time, chemical release with temporary environmental or
public health impact

Very high: Catastrophic: one or more fatalities, total system loss, chemical
release with lasting environmental or public health impact

Risk scoring and categories
Combining probability values with severity descriptions yields a risk score.

That score can be categorized as follows.

Risk score
Under 4 Category 1: Remedial action discretionary
4 to 8 Category 2: Remedial action to be taken at appropriate time
9 to 14 Category 3: Remedial action to be given high priority
15 or greater Category 4: Operation not permissible. Immediate action necessary

A risk assessment
matrix that assigns
numbers to risk levels
demonstrates the
application of the
ALARP principle.
Combining the severi-
ty and occurrence
probability values
yields a risk score
in the matrix.

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36 PROFESSIONAL SAFETY MAY 2010 www.asse.org

3) For items 1 and 2, deci-
sion makers are to consider
purpose of the undertaking;
state of the technology; costs of
improvements in relation to
benefits to be obtained; and
whether the expenditures for
risk reduction in a given situa-
tion could be applied else-
where with greater benefit.
Since resources are always

limited, spending an inordi-
nate amount of money to
reduce the risk only slightly
through costly engineering and
redesign is inappropriate, par-
ticularly if that money could be
better spent elsewhere. This
premise can be demonstrated
through an example that uses a
risk assessment matrix as a
part of the decision making.

Risk Assessment Matrix
A risk assessment matrix

that assigns numbers to risk
levels demonstrates the application of the ALARP
principle. One must understand that the numbers in
the matrix presented (Table 2, p. 35) are qualitative,
not quantitative. They are relational and have mean-
ing as they interact with each other. Many other risk
assessment matrixes could be used as well. An
SH&E professional may want to use other probabil-
ity and severity descriptions and risk scoring cate-
gories. Combining the severity and occurrence
probability values yields a risk score in the matrix.
Table 2 also includes information on categorizing the
risks and action levels based on urgency.
The following example illustrates how a team

used the matrix and applied the ALARP concept to
make a decision about acceptable risk.
1) A chemical operation was built 15 years ago.

While engineering modifications have been made in
the system over the years, management knows that
its operations are no longer state of the art.
2) A risk assessment team is convened to consid-

er the chemically related risks in a particular process
in the overall system.
3) In the deliberations, the group refers to its

established hierarchy of controls:
a) Eliminate or reduce risks in the design and
redesign processes.

b) Reduce risks by substituting less hazardous
methods or materials.

c) Incorporate safety devices.
d) Provide warning systems.
e) Apply administrative controls (e.g., work
methods, training, work scheduling).

f) Provide PPE.
4) The group first considers the possibility of

redesigning and replacing the process. Substitution
of materials or methods is considered, but the group

to utilization of nuclear energy and licensed
materials in the public interest (10 CFR
20.1003).
The implication that decision makers are to

“[make] every reasonable effort to maintain expo-
sures to ionizing radiation as far below the dose lim-
its as practical” provides conceptual guidance in
striving to achieve acceptable risk levels in all class-
es of operations.
ALARP seems to be an adaptation fromALARA.

It has become the more frequently used term for
operations outside the atomic arena and it appears
more often in the literature. ALARP is that level of
risk which can be further lowered only by an incre-
ment in resource expenditure that is disproportion-
ate in relation to the resulting decrement of risk.
The concept embodied in these two terms applies

to the design of products, facilities, equipment, work
systems and methods, and environment controls. In
the real world, benefits represented by the amount
of risk reduction to be obtained and the costs to
achieve those reductions are important factors.
Trade-offs are frequent and necessary.
An appropriate goal in the decision-making

process is to have the residual risk be ALARA.
Paraphrasing the terms contained in the definition
of ALARAhelps explain the process:
1) Reasonable efforts are to be made to identify,

evaluate, and eliminate or control hazards so that
the risks deriving from those hazards are acceptable.
2) In the design and redesign processes for phys-

ical systems and for the work methods, risk levels
for injuries and illnesses, and property and environ-
mental damage, are to be as far below what would
be achieved by applying current standards and
guidelines as is economically practicable.

Unacceptable
region

ALARP region
Steps must be taken to
reduce risks to as low as
reasonably prac!cable.

Having less importance
or urgency

•Immediate ac!on required.
Opera!on not permissible,
except in rare and extra-
ordinary circumstances.

Risk category 4

•Remedial ac!on is to be given
high priority.

Risk category 3

•Remedial ac!on to be taken at appropriate
!me.

Risk
category 2

•Remedial ac!on is discre!onary. Procedures
are to be in place to ensure that this risk level
is maintained.

Risk
category

Figure 1Figure 1
The ALARP Principle

ALARP promotes a
management review,
the intent of which is
to achieve acceptable
risk levels. Several
depictions of the

ALARP concept begin
with an inverted
triangle because it
indicates that risk is
greater at the top
and much less
at the bottom.

http://www.asse.org

www.asse.org MAY 2010 PROFESSIONAL SAFETY 37

that the definition of acceptable risk included in this
article represents the development of and practical
use of the term over the past several years.

Social Responsibility:
An Emerging Opportunity
Formal consideration of social responsibility by

senior executives is a fairly recent development.
What is social responsibility?An Internet search will
reveal a large number of definitions. This article
focuses on two.
1) The World Business Council for Sustainable

Development (2000) defines corporate social respon-
sibility as “the continuing commitment by business
to behave ethically and contribute to economic
development while improving the quality of life of
the workforce and their families as well as of the
local community and society at large.”
2) Gap Inc. states, “[S]ocial responsibility is fun-

damental to show how we do business. It means
everything from ensuring that workers are treated
fairly to addressing our environmental impact.”
It is logical to suggest that if a company initiates a

social responsibility endeavor which is to include the
well-being of workers, the environment and the com-
munity at large, knowledge and application of accept-
able risk principles would inform its decisionmaking.
The result would be efficient allocation of resources,
fewer injuries and illnesses and property damage inci-
dents, and serving the community well. That seems to
present opportunities for SH&E professionals.

The State of the Art in Risk Assessment
SH&E professionals must understand that risk

assessment is as much an art as science and that sub-
jective judgments—educated, to be sure—are made
on incident or exposure probability and the severity
of outcome to arrive at a risk category. Also, one
must recognize that economically applicable risk
assessment methodologies have not been developed
to resolve all risk situations.
For example, when asked, “How would you

assess the cumulative risk in an operation in which
there was an unacceptable noise level and toluene
was used in the process?” one would hope that
resource material such as EPA’s (2003) Framework for
Cumulative Risk Assessment would provide an
answer. It does not. The agency is cautionary about
cumulative risk assessment methods.
It should be acknowledged by all practitioners
of cumulative risk assessment that in the cur-
rent state of the science therewill be limitations
in methods and data available (p. 31).
Finding a commonmetric for dissimilar risks

is not an analytical process, because some judg-
ments should be made as to how to link two or
more separate scales of risks. These judgments
often involve subjective values, and because of
this, it is a deliberative process (p. 55).
Calculating individual stressor risks and

then combining them largely presents the same
challenges as combination toxicology but also
adds some statistical stumbling blocks (p. 66).

determines that such opportunities have already
been addressed. Safety devices and warning sys-
tems are considered state of the art, and mainte-
nance is considered superior.
5) Occurrence probability for a chemically related

illness is judged to be moderate (3) and the severity
level is moderate (3). Thus, the risk score is 9, which
is in Category 3 and remedial action is to be given
high priority.
6) The team recognizes that to reduce the risk fur-

ther, appropriate training must be delivered and
repeated, and standard operating procedures and
the use of PPE must be rigidly enforced.
7) Management agrees to fund the necessary ad-

ministrative improvements.
8) Assuming that these improvements are made,

the risk assessment group decides that the probabil-
ity of occurrence of an illness from a chemical expo-
sure would be low (2) and that the severity of harm
expected would be low (2). Thus, the risk score is 4,
in Category 1.
9) Reengineering and replacing the process would

reduce the probability level to very low (1) and the
severity level to very low (1), thereby achieving a risk
score of 1, also is in Category 1. The estimated cost of
redesigning and replacing the process, $1.5 million,
was considered disproportionate with respect to the
amount of risk reduction to be obtained.
10) The risk assessment group tells management

that it would prefer having the money spent on a
wellness center.

The ALARP Principle
ALARPpromotes amanagement review, the intent

of which is to achieve acceptable risk levels. Practical,
economic risk trade-offs are frequent and necessary in
the benefit/cost deliberations that occur when deter-
mining whether the costs to reduce risks further can
be justified “by the resulting decrement in risk.”
Several depictions of the ALARP concept begin

with an inverted triangle (Figure 1) because it indi-
cates that risk is greater at the top and much less at
the bottom. Figure 1 shows the concept combined
with elements in the risk assessment matrix.

Defining Acceptable Risk
This author’s definition of acceptable risk is

included in ASSE TR-Z790.001-2009. Risk acceptance
is a function of many factors and varies considerably
across industries (e.g., mining vs. medical devices vs.
farming). Even at locations of a single global compa-
ny, acceptable risk levels can vary. Company culture
and the culture of the country in which a facility is
located influence risk acceptability, according to col-
leagues working in global companies. Training, expe-
rience and resources also can influence acceptable
risk levels. Risk acceptability is also time dependent,
in that what is acceptable today may not be accept-
able tomorrow, next year or the next decade.
A sound, workable definition of acceptable risk

must encompass hazards, risks, probability, severity
and economic considerations. This author believes

ALARP is
that level of
risk which
can be further
lowered only
by an incre-
ment in
resource
expenditure
that is dispro-
portionate in
relation to
the resulting
decrement
of risk.

http://www.asse.org

38 PROFESSIONAL SAFETY MAY 2010 www.asse.org

British Standards Institution (BSI). (2007). Occupational
health and safety management systems: Requirements (BS
OHSAS 18001:2007). London: Author.

Bureau of Labor Statistics. (2008, Aug. 20). National census of
fatal occupational injuries in 2007 (USDL 08-1182). Washington, DC:
U.S. Department of Labor, Author.

DOT. (2005). Risk management definitions. Washington, DC:
Author, Pipeline and Hazardous Materials Safety Administration.
Retrieved March 19, 2010, from http://www.phmsa.dot.gov/haz
mat/risk/definitions.

EPA. (2003, May). Framework for cumulative risk assessment
(EPA/630/P-02/001F). Washington, DC: Author. Retrieved March
19, 2010, from http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm
?deid=54944.

Fewtrell, L. & Bartram, J. (Eds.). (2001).Water quality: Guide-
lines, standards and health. London: IWAPublishing for World
Health Organization.

Gap Inc. Social responsibility. San Francisco: Author. Re-
trieved March 19, 2010, from http://www.gapinc.com/public/
SocialResponsibility/socialres.shtml.

Health and Safety Executive.ALARP “at a glance.” London:
Author. Retrieved March 19, 2010, from http://www.hse.gov.uk/
risk/theory/alarpglance.htm.
Industrial Union Department, AFL-CIO v. American

Petroleum Institute U.S. at 642.
Institute for Research for Safety and Security at Work & The

Commission for Safety and Security at Work in Quebec. (2009).
Machine safety: Prevention of mechanical hazards. Quebec,
Canada: Author. Retrieved March 19, 2010, from http://www
.irsst.qc.ca/files/documents/PubIRSST/RG-597-Pref-TCont
-Intr .

International Electrotechnical Commission (IEC). (2007).
International standard for environmentally conscious design of
medical equipment (IEC 60601-1-9). Geneva: Author.

International Organization for Standardization (ISO)/IEC.
(1999). Safety aspects: Guidelines for their inclusion in standards
[ISO/IEC Guide 51:1999(E)]. Geneva: Author.

Lowrance, W.F. (1976). Of acceptable risk: Science and the deter-
mination of safety. Los Altos, CA: William Kaufman Inc.

Manuele, F.A. (2008). Advanced safety management: Focusing on
Z10 and serious injury prevention. Hoboken, NJ: John Wiley & Sons.

Manuele, F.A. (2003). On the practice of safety (3rd ed.). Hobo-
ken, NJ: John Wiley & Sons.

Manuele, F.A. & Main, B. (2002, Jan.). On acceptable risk.
Occupational Hazards. Retrieved March 19, 2010, from http://ehs
today.com/news/ehs_imp_35066.

Nuclear Regulatory Commission. (2007). 20.1003 Definitions:
ALARA. Washington, DC: Author. Retrieved March 19, 2010,
from http://www.nrc.gov/reading-rm/doc-collections/cfr/part
020/part020-1003.html.

OSHA. (2003). Voluntary Protection Programs: Policies and
procedures manual (archived). Washington, DC: U.S. Department
of Labor, Author. Retrieved March 19, 2010, from http://www
.osha.gov/pls/oshaweb/owadisp.show_document?p_table
=DIRECTIVES&p_id=2976.

Presidential/Congressional Commission on Risk Assess-
ment and Risk Management. (1997). Framework for environmental
health risk management.Washington, DC: Author.

Semiconductor Equipment and Materials International
(SEMI). (2006). Environmental, health and safety guideline for
semiconductor manufacturing equipment (SEMI S2-0706). San
Jose, CA: Author.

SEMI. (1996). Safety guideline for risk assessment (SEMI S10-
1996). Mountain View, CA: Author.

Standards Association of Australia. (2004). Risk management
standard (AS/NZS 4360: 2004). Strathfield, NSW, Australia: Author.

Stephans, R.A. (2004). System safety for the 21st century. Hobo-
ken, NJ: John Wiley & Sons.

United Nations/International Strategy for Disaster Reduc-
tion (UN/ISDR). (2009). UNISDR terminology on disaster risk
reduction. New York: Author. Retrieved March 19, 2010, from
http://www.unisdr.org/eng/library/lib-terminology-eng.htm.

World Business Council for Sustainable Development. (2000).
Corporate social responsibility: Making good business sense.
Geneva: Author. Retrieved March, 19, 2010, from http://www
.wbcsd.org/DocRoot/IunSPdIKvmYH5HjbN4XC/csr2000 .

Where multiple, diverse hazards exist, the practi-
cal approach is to treat each hazard independently,
with the intent of achieving acceptable risk levels for
all. In the noise and toluene example, the hazards are
indeed independent. Complex situations, or when
evaluating competing solutions to complex systems,
may require the assistance of specialists with knowl-
edge of more sophisticated risk assessment method-
ologies such as hazard and operability analysis or
fault tree analysis. For most applications, however,
the author does not recommend that diverse risks be
summed through what could be a questionable
methodology.

Conclusion
Risk acceptance is the deliberate decision to

assume a risk that is low enough with respect to the
probability of a hazard-related incident or exposure
occurring and the severity of harm or damage that
may result, and which is considered tolerable in a
given situation. Management’s decision to accept a
risk should be deliberate and the criteria for the deci-
sion should be

documented.

In an ideal world, all
personnel who are impacted should be involved in
or be informed of risk acceptance decisions.
Use of the term acceptable risk has arrived. It is

becoming a norm. In organizations with advanced
safety management systems, the idea of achieving
practicable and acceptable risk levels throughout all
operations is a cultural value. It is suggested that
SH&E professionals adopt the concept of attaining
acceptable risk levels as a goal to be embedded in
every risk elimination or reduction action proposed.
To achieve that goal, SH&E professionals must edu-
cate others on the benefits of applying the concept.
SH&E professionals also must be able to work

through the greatly differing views people can have
about risk levels, incident and exposure probabili-
ties, and severity. Workers may have differing views
about risk and they should be considered for their
value. With respect to environmental risks, commu-
nity views must be considered as well.
In arriving at acceptable risk levels where the

hazard/risk scenarios are complex, it is best to gath-
er a team of experienced personnel for their contri-
butions and for their buy-in to the conclusions. �

References
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(ANSI/ASSE Z244.1-2003(R2009). Des Plaines, IL: Author.

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assessment and risk reduction: A guide to estimate, evaluate and
reduce risks associated with machine tools (ANSI B11.TR3-2000).
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ANSI/Packaging Machinery Manufacturers Institute
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ments for packaging machinery and packaging-related converting
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ASSE. (2009). Prevention through design: Guidelines for
addressing occupational risks in design and redesign processes
(ASSE TR-Z790.001-2009). Des Plaines, IL: Author.

Management’s
decision to
accept a risk
should be

deliberate and
the criteria for
the decision
should be

documented.

http://www.unisdr.org/eng/library/lib-terminology-eng.htm

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2976

http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1003.html

http://ehstoday.com/news/ehs_imp_35066

http://www.irsst.qc.ca/files/documents/PubIRSST/RG-597-Pref-TCont-Intr

http://www.hse.gov.uk/risk/theory/alarpglance.htm

http://www.gapinc.com/public/SocialResponsibility/socialres.shtml

http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=54944

http://www.phmsa.dot.gov/hazmat/risk/definitions

http://www.asse.org

not be copied or emailed to multiple sites or posted to a listserv without the copyright holder’s express written

permission. However, users may print, download, or email articles for individual use.

www.occupationalhazards.com May 2005 / Occupational Hazards 43

Want to create world-class safety

performance in your organization?

The answer isn’t more safety programs

and it won’t be easy, but you can

do it – now!

STEPPING UP
TO OPERATIONAL
SAFETY EXCELLENCE

I
n 1985, I dared to ask one single question that
ended my 18-year career as a safety practitioner. It
also, however, impacted how safety would be
managed in companies throughout this country,

and marked the beginning of a second, more produc-
tive career as an organizational performance consult-
ant specializing in pre-emptive risk management. That
question was presented to the profession in March
1993 in Professional Safety’s cover story titled: “Safety
Management: A Call for Revolution.” Now, some 10
years later, it is being asked across five (known) conti-
nents impacting the thinking of academics and the
practices of many global institutions and organiza-
tions. That critical question was – and remains –
“Why?”

Inquiring minds want to know:
☛ Why… are all industry LWD incident rates only

marginally improved, in spite of 30 years of federal reg-
ulation and enforcement?

☛ Why … do workers’ compensation costs continue
to escalate in many business segments in spite of these
incident rate declines?

☛ Why … do multi-location companies with one
centralized safety program have such diverse results
across their organizations?

☛ Why … did NIOSH researchers find that compa-
nies with better safety efforts had higher accident
rates?

☛ Why … did a Department of Energy study con-
clude that sites that invested more (percent of budget)
in safety incurred higher loss costs?

☛ Why, in many organizations, is safety managed dif-
ferently than all other business functions? And most im-
portantly,

☛ Why … did HR executives of the Conference
Board cite “safety” when asked what function could
be eliminated due to failure to add value?

These questions frame the bigger question: “If safety
programs are a common denominator to organizations
that both fail and succeed, what then is the “X Factor,”

BY LARRY L. HANSEN

In his October 2003 OCCUPA-
TIONAL HAZARDS article, “Get-
ting the Culture Right,” Don
Eckenfelder contends that or-
ganizational attitude ulti-
mately determines whether
safety initiatives succeed or
fail, and proposes three core
truths: “1 – Culture predicts
performance; 2 – Culture can
be measured; and 3 – Nothing
is more important than get-
ting the culture right!” The cul-
ture of an organization – its
basic beliefs and values con-
cerning people – is what
drives safety excellence.

Tom Peters and Bob Waterman spent a
decade In Search of Excellence, attempt-
ing to discover what lies at the core of op-
erational excellence. After years of re-
search, they summarized their findings in
a simple, yet powerful message to Ameri-
can management: “Figure out your values
system!” Values lie at the core of an orga-
nization’s culture, and are the predictors
of, and ultimate determinants of, all oper-
ational outcomes … safety included.

Stephen Covey warns: “If we always
do what we’ve always done, we’ll al-
ways get what we’ve always got.”
Hence, the obvious question is: “What
do we do, and what have we got?”

Research by the National Institute for
Occupational Safety and Health

the differentiating variable that separates
world-class performance (the best) from
the vast majority who struggle to maintain
mediocrity (the rest)?

THE X FACTOR

T
he answer to these questions in
specific, and clarification of the
X Factor (excellence differentia-

tor) in general, was provided by Profes-
sor Richard Wokutch in 1992. In his
book, Worker Protection, Japanese Style,
two important insights emerged. The
first was a comparison of United States
vs. Japan injury frequency trends, which
indeed visualized the X Factor. The sec-
ond was his observation that in spite of
the vast difference in results, Japanese
safety programs were very much the
same as those employed by U.S. firms,
suggesting that safety programs weren’t
the differentiating factor – culture was.

“Concern for safety and health is inte-
grated into the production system: It
supports efforts to promote quality, and
productivity. Accidents would severely
disrupt production, and therefore must
be avoided at all costs. Individual work-
ers and line managers take primary re-
sponsibility for ensuring the workplace
is safe and healthy. They don’t rely as
much on safety managers, or govern-
mental regulators as is often the case in
the United States,” Wokutch wrote.

44 Occupational Hazards / May 2005 www.occupationalhazards.com

(NIOSH) initiated in the late 1970s has
documented the limited effectiveness of
traditional safety approaches in mini-
mizing loss outcomes. When safety ef-
fectiveness ratings of a studied popula-
tion of companies were compared to
loss outcomes produced, no significant
correlation of effort to results was found.
However, when the same population of
companies was studied a second time
comparing management competencies
to loss outcomes, a clear correlation of
management effectiveness to low inci-
dent rate outcomes was revealed.

A more recent study (safety budget
vs. loss incurred) at selected sites within
the Department of Energy also resulted
in unexpected findings … the more sig-
nificant being (Crites):

1. “Increased investment in a formal
safety program did not produce im-
proved safety performance.” Distribution
of results indicated an inverse relation-
ship, i.e., the greater the safety invest-
ment, the higher the level of loss, and

2. Factors having minimal impact were:
• A shift in safety emphasis;
• Size of the safety budget;
• Degree of hazard;
• Safety rules (quantity or quality);

and
• Safety committees.

These and other similar studies con-
ducted over the past 10 years confirm
that management (more than pro-
grams) is the major controlling influ-
ence in achieving safety excellence,
and that overall maximally effective
safety programs in industry will depend
on those practices that can successfully
deal with people variables. Dan Pe-
tersen, who concurs with such findings,

FIGURE 1

FIGURE 2

cellence – the “C”– Culture and “O” – Or-
ganization of the business.

When conceived 10 years ago, the
safety excellence continuum model pro-
posed to define and diagnose culture im-
provement opportunities consisted of
only three levels and two requisite “step-
changes.” It is now evident that a fourth
high-end performance level and a third
mindset change is requisite to attaining
true world-class distinction. The revised
excellence model now consists of four
step-change performance levels: SWAMP

– NORM – EXCELLENCE and WORLD-
CLASS. For those familiar with the origi-
nal work, this revision will reinforce origi-
nal concepts. For those more recently
entering the profession, this model serves
as a strategy beacon to guide efforts to-
ward world-class results. In Good to
Great, Jim Collins and his research team
concluded: “The first step of Leadership
is not visioning, but rather confronting
the brutal facts.” Following are the pat-
terned management practices and pre-
dominant cultural beliefs that define the
current reality of safety, and which must
be confronted at each level of the step-
change journey to world-class safety in
an organization.

STAGE I – THE S.W.A.M.P.
(SAFETY WITHOUT ANY

MANAGEMENT PROCESS)
Safety is ‘Unmanaged’ –

Safety is Ignored!
COSTS ARE THE PROBLEM!

www.occupationalhazards.com May 2005 / Occupational Hazards 45

has concluded: “We believe probably
that there’s something having to do with
the culture and the climate of the organ-
ization that makes the whole safety pro-
gram work. What works in one organiza-
tion, may not work in another.”
(Sheridan). And similarly, D. A. Weaver,
a thought leader of the profession 50
years ahead of his time, observed: “Ex-
cellent organizations frequently achieve
exceptional safety results in the absence
of any visible safety program, and excel-
lent safety performance cannot be at-
tained in a generally poor organization.”
His bottom line: “Safety is nothing more
than a byproduct of doing things right.”

THE SAFETY
EXCELLENCE EQUATION

M
ore recent Gallup Organization
research on high-performance
companies also identifies val-

ues and leadership as key differentiating
factors. In First Break All the Rules, lead
researcher and author Marcus Bucking-
ham summarized the key findings of
that study: “Excellence is not the oppo-
site of mediocrity … Excellence is differ-
ent.” Excellence is not generated by
more of the same, only faster, quicker,
harder; but rather by re-focusing on the
drivers of high performance – culture
(values) and leadership (practices).
Relative to safety, this would suggest
that traditional safety elements (pro-
grams), although valid and necessary,
are, alone, not sufficient to achieve
safety excellence in an organization.
These elements need be empowered by
the culture of the organization. There is
a Safety Excellence equation that ap-
plies to all organizations, and it is:

SAFETY EXCELLENCE = CEOu
Where:
C = the CULTURE of the organization

(Values)
E = the ELEMENTS of the safety

(Program)
O = the ORGANIZATION’S safety

performance (Systems)
u = the LEADERSHIP (Actions of

Executives and Champions)
The Safety profession has spent more

than 50 years perfecting the “E” – Ele-
ments of safety. It’s now time to move
forward and focus on the enablers of ex-

Organizations mired in the SWAMP
are frequently managed by the Tyrant-a-
Saurus Wrecks, a management species
that has evaded extinction in many or-
ganizations. These companies reject re-
sponsibility and perceive safety as a task
with no productive value, a burden
placed upon them by regulators, the in-
surance industry or labor. They accept
accidents as an unavoidable cost of do-
ing business, are autocratic and have a
heavy production focus, with safety fre-
quently compromised to quota and/or

delivery schedules. People are viewed
as expendable resources. Their plan-
ning is short-term and reactive; commu-
nications are one-way (down) and
founded in mandates of fear. They em-
ploy “make-do” solutions to equipment
and facilities problems, often leaving
them unsafe. Minimal employee in-
volvement is allowed in the process and
labor/management relations often are
at odds concerning safety and adversar-
ial on most everything else. It’s always a
case of them versus us!

These companies have high insur-
ance costs driven by both frequency
and severity. Their Experience Modifica-
tion typically exceeds 1.25 (25 percent
debit surcharge). They populate the
high-risk pools, and adversely affect the
insurance rates for their industry classifi-
cation. These companies operate in
statutory ignorance, often in violation of
recognized codes and regulations. Em-
ployee complaints and whistleblowing

FIGURE 3

mise them in their own day-to-day be-
havior, sending a clear message to em-
ployees: “Read my lips … ” Efforts are cy-
clical as they follow blood cycles –
injuries occur, pressure applied; injuries
reduced, pressure removed.

Activities focus on inspecting out haz-
ards and observing and disciplining out
unsafe work practices. This process fails
to identify core problems, and only ad-
dresses surface symptoms. Line managers
“do” safety but don’t “buy into” safety. In-
surance costs in these organizations show
some improvement, but plateau at or
about industry norms. Experience Modifi-
cations hover around 1.00 plus or minus
25 percent. This varies year to year.

The NORM is where many companies
exist, and where most will remain. For
an organization to advance onward to
Stage III … EXCELLENCE, they must un-
dergo a “Radical Organizational
Change” (ROC), discarding traditional
beliefs and approaches, and adopting a
more progressive mindset on systemic
cause and correction. These become
the excellence companies.

STAGE III – EXCELLENCE
(SAFETY EXCELS TO THE TOP QUARTILE)
Safety is ‘Managed’ – Safety is Integrated.
PROCESS IS THE OPPORTUNITY

In excellence companies, safety is less
scheduled and more systemic. Efforts
are dedicated to building collaborative
systems and cooperative partnerships
that integrate safety into core business
processes. There are few, if any, safety
rules, safety meetings, safety audits,
safety training, safety metrics and, least
of all, safety committees. The objectives
of such activities are integrated into op-
erational procedures. In place of sepa-
rate safety activities, there are:

☛ Normally held operations meetings
(that include, and often start with,
safety);

☛ Standard operating procedures
and training (that include safety);

occur frequently. They are targets of labor
lawsuits and workplace litigation emanat-
ing from injuries, which frequently make
national headlines.

Companies mired in the SWAMP re-
main there until a Significant Financial
Crisis (SFC) occurs, which can be either a
single catastrophic event or a cumulative
increase in loss costs so significant as to
impact profits, and threaten the CFO’s or
CEO’s position, hence forcing senior man-
glement (not a typo) to acknowledge a
problem and declare: “We need a safety
program!” It is with this impetus that evolu-
tion to Stage II, the “N.O.R.M.,” begins.

STAGE II – THE N.O.R.M.
(NATURALLY OCCURRING
REACTIVE MANAGEMENT)
Safety is ‘Mismanaged’ –

Safety is a Program!
PEOPLE ARE THE PROBLEM!

Because the decision to act was
driven by cost and ignorance rather
than an understanding of real causes,
the NORM is typically christened with
the kiss of death – the hiring of a safety
director! This is a typical move as man-
agement believes people are the prob-
lem, hence the natural answer is to hire
someone to fix them, not us!

At this stage, companies implement
safety programs without having an ade-
quate understanding of the problems or
the actions necessary to resolve them.
They implement programs patterned after
what others have done, i.e., create com-
mittees, establish rules, implement train-
ing and enforce progressive disciplinary
policies. None of these proves effective, as
they are answers that do not address the
problem – the management problem.

Line managers typically excuse away
accidents as employee carelessness.
They are in conflict with the safety officer
who they perceive to be a nitpicker im-
peding their real job – to get product out
the door! Line supervisors do not accept
responsibility for the safety and health of
the people assigned to their units, and
embrace “quick fix” programs that have
minimal impact, as employees see
through the ploys and blow them off.

Safety campaigns have high visibility,
with slogans, contest, gimmicks and in-
centive programs. Managers issue rules
and more rules, but frequently compro-

46 Occupational Hazards / May 2005 www.occupationalhazards.com

☛ Problem seeing and solving ses-
sions (that address safety); and

☛ Manager meetings to address on-
going performance improvement op-
portunities (that include safety).

These organizations are well-

schooled in TQM concepts, progressive
management principles and modern
leadership practices. Accidents are rare
events. When they occur, they are ad-
dressed quickly and effectively at their
root-cause level. Labor relations is
healthy with many of these companies
listed on recognized business lists, i.e.,
“Best 100 Companies to Work For”
and/or publicized in business trades, B-
school case studies and management
journals. Accident costs are low, and Ex-
perience Modifications evidence a
downward (credit) trend to 0.75 or bet-
ter (at least 25-percent better than indus-
try average). For these companies,
safety pays dividends and adds to the
bottom line. Many in this group have
transformed their safety function from a
cost center to a profit center in recogni-
tion of its ability to make margin contri-
bution and create shareholder value.
Excellence companies face one addi-
tional mind shift on the journey to be-
coming a true world-class safety organi-
zation. This final step-change involves a
Critical Thinking Shift (CTS) wherein
safety is no longer perceived as a techni-
cal and/or managerial issue, but as a
core value critical to business success.
Safety in world-class organizations is
cultural, an issue of leadership values –
“Safe is how business is done.”

STAGE IV – WORLD-CLASS
(SAFETY AT THE TOP)

Safety is ‘Non-Managed’… Safety is Led!

CULTURE IS THE SOLUTION!
In a short but powerful statement, Pe-

ter Drucker summed up the cumulative
insight of his 5-decade career as this
planet’s most influential thinker on
management practice: “With 50 years of
hard evidence at hand, it’s awful hard to

One of the most distinguishing features of world-class safety

organizations is that “shared ownership” by all replaces

“forced accountability” by a few.

come a reality in an organization when
all managers – executive, operations,
line and staff – fully integrate safety into
the organization’s mainstream value sys-
tem, policies and practices. This will not
result from safety programs superim-
posed upon the organization, but only
when safety is fully accepted as integral
to the organization’s mission, and as a
strategy critical to the success of busi-
ness objectives.

For those organizations willing to com-
mit proactive leadership and willing to re-
focus efforts (it doesn’t cost any more
money), world-class safety is attainable,
now. Peter Drucker’s observation, how-
ever, on the requisites of business success
applies in all organizations: “All theory de-
generates into work.” Given an opportu-
nity to pursue transformational change (in
mindset and strategy), an unfortunate real-
ity is, most defer to Coderre’s (Paul) Law of
Least Resistance: “Given the opportunity
to do nothing, most will.” They prefer to
employ L.A.M.E. (Lazy – Antiquated –
Mediocre – Externally focused) excuses
for substandard performance. To these or-
ganizations, the soft, warm ooze of the
SWAMP is too comfortable (numbing),
and the status quo of the NORM too famil-
iar (easy). They opt for the more common
alternatives(and costs) of mediocrity:

☛ Increase the annual workers’ com-
pensation premium budget.

☛ Add legal and claim administra-
tion staff.

☛ Blame the government, the union,
El Nino and their useless brother-in-law.

☛ Set higher production quotes to off-
set loss costs.

☛ Lower the bar on margin projec-
tions!

World-class safety is a journey avail-
able to all, taken by some and com-
pleted by an elite few.

“Watch that first step. It’s a big one – and
potentially a very profitable one!

REFERENCES

Arthur D. Little Survey, “Green Wall Be-
tween Environmental and Business Staffs
Blocks Successful Environmental Manage-
ment,” Professional Safety, August 1996.

Cohen, Alexander. “Factors in Success-
ful Occupational Safety Programs,” Jour-
nal of Safety Research, December 1977.

Cohen, Harvey H. and Cleveland,
Robert J. “Safety Program Practices in

www.occupationalhazards.com May 2005 / Occupational Hazards 47

‘slough off’ the truth … It’s all about PEO-
PLE!” (Drucker) One of the most distin-
guishing features of world-class safety
organizations is that “shared ownership”
by all replaces “forced accountability”
by a few. Line managers accept primary
responsibility for leading safe opera-
tions, and employees actively con-
tribute to and cooperate with the
process because it is founded upon
shared values, not imposed rules.

Senior managers place a high value
on the health and well-being of people,
believe that accidents are unnecessary,
intolerable and preventable and let
those thoughts be known throughout
the organization. In world-class organi-
zations, safety is a measure of opera-
tional effectiveness – a key metric of
strategic business success or failure. The
decisions managers make are time-con-
suming and planning is formal and
strategic. Responsibilities for both line
and staff managers are clearly defined
and aligned with collaborative partner-
ships replacing inter-function conflict.

These companies shun quick fixes,
knowing quite well they won’t work.
Their employee relations policies and
manager practices are employee-cen-
tered and humanistic. Employees are
empowered and rewarded, often
through gain-sharing arrangements.
Communications are open and informal.
Feedback is encouraged, and the
grapevine is more constructive than de-
structive. Methods to produce safety are
built into job briefs and standard operat-
ing procedures. Results are closely meas-
ured and monitored. Causes for varia-
tions are identified and rectified, and
there is a predominance of reinforce-
ment over discipline in this process.

There are no flag-waving campaigns,
stump speeches or bells and whistles;
there are simply “good business” prac-
tices that produce superior results. In-
surance costs and retained losses are
low relative to the size and scope of op-
erations. Experience Modifications are
among the best in class, and hover his-
torically below 0.50 (50-percent credit)
or better than the industry.

In these organizations, safety loses its
identity; there are no “safety programs.”
There are few, if any, accidents. There is
simply excellent leadership. As Peter
Senge asserts: “Mastery is invisible.”

World-class performance only will be-

Record-Holding Plants,” Professional
Safety, March 1983.

Collins, Jim. Good to Great, Harper
Business Books, New York, 2001.

Crites, Thomas, R. “Reconsidering the
Costs and Benefits of a Formal Safety
Program,” Professional Safety, Decem-
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Buckingham, Marcus and Coffman,
Curt. First Break All the Rules, Simon and
Schuster, New York, 1999.

Eckenfelder, Donald J. Values-Driven
Safety , Government Institutes Inc.,
Rockville, Md., 1996.

Eckenfelder, Donald J. “Getting the
Culture Right,” OCCUPATIONAL HAZARDS,
October 2003.

Hansen, Larry L. “Safety Management:
A Call for Revolution,” Professional
Safety, March 1993.

Minter, Stephen G. “Creating the
Safety Culture,” OCCUPATIONAL HAZARDS,
August 1991.

NOVA Documentary, “Peter Drucker
– An Intellectual Journey,” WGBH TV,
Boston, June 2004.

Peters, Tom and Waterman, Robert.
In Search of Excellence.

Planek, Thomas W. and Fearn, Kevin
T. “Reevaluating Occupational Safety
Priorities: 1966 to 1992,” Professional
Safety, October 1993.

Sarkis, Hank. “What Really Causes Ac-
cidents,” Presentation at Wausau Insur-
ance Safety Management Seminar,
Canandaigua, N.Y., June 1990.

Sheridan, Peter J. “The Essential Ele-
ments of Safety,” OCCUPATIONAL HAZARDS,
February 1991.

Veltri, Anthony. “Transforming Safety
Strategy and Structure,” OCCUPATIONAL
HAZARDS, September 1991.

Wokutch, Richard E. Worker Protection,
Japanese Style; Occupational Safety and
Health in the Auto Industry, ILR Press, Cor-
nell University, Ithaca, N.Y., 1992.

Wokutch, Richard E. “Myths of the
Japanese Factory,” Journal of Com-
merce, Aug. 26, 1992.

Larry Hansen, CSP, ARM, is principal of
L2H Speaking of Safety Inc., a safety ex-
cellence facilitation company. He resides

in Syracuse, N.Y., and can
be reached at (315) 383-
3801, via e-mail at
LLHSOS@dreamscape
.com and online at
http://www.L2Hsos.com.

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