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A LOOK AT IMPLEMENTATION AND COMPLIANCE WITH THE TT OSH ACT

by Timothy A. Fisher, OSHA Services, LLC presented by Dave Boyer, OSHA Services, LLC

The conference theme "From Paper to Practice" is challenging the HSE community to clearly delineate a practical way forward for implementing the TT OSH Act. Therefore, I believe changing the terms of reference usually reserved for a discussion about implementing a world class safety system is necessary. If we put the discussion into business/marketing terms, it would shift the discussion from the technical elements of HSE implementation to what it will take to continue the momentum of the past three years. The change is necessary so that more stakeholders can be engaged in the discussion. Let's look together at implementation of the Act as if it was a new product that was being launched into the marketplace. Isn't that what we are asking the business community and government to do? Accept a new product category. We must remember our "product" did not even exist three years ago. Like in any new product launch there are barriers that must be overcome; product mix issues to be resolved; reliable delivery system to be created; marketing strategies to be developed; compelling reasons to buy must be found and perhaps most importantly early adopters of the new product to be identified. It is against this backdrop that we begin our look at implementation of the TT OSH Act. What barriers, you say, our "product" must be accepted because it is mandatory, right? Well in Trinidad there is another truism that creates a barrier to our product even if it is law - "All things foreign are better." However for our product this is not the case. It is only a perception that must be rectified. Entrenched already are two foreign competitors ­ US OSHA and NEBOSH. It is clear that first in market has a significant advantage, so what has been done and what remains to be done to elevate the TT OSH Act above its two foreign competitors? 2005/2006 - TTBS accredited four programmes based on the Act and AMCHAM, STCIC, TTMA and ECA endorsed them as the way forward. 2006-2007 - TT Chamber, The Trinidad Hotels, Restaurants and Tourism Association, and the Shipping Association all came on board 2007 ­ Two significant organisations were formed: OSH Authority and OSH Agency making the statement that the TT OSH Act is here to stay. 2007/2008 ­ We challenge all remaining Chambers and Associations to begin the dialogue with their member base about this preeminence of the TT OSH Act. We are at the tipping point as it relates to legitimizing against our competitors! What remains is national accreditation of the Act. The good news is this is underway via ACTT at the request of the OSH Authority. Recognizing the Act to have equal value as a safety management system, to the US or UK models would allow the country to create a competitor to the NEBOSH certificate and diploma programmes (it might be noted that presently there is not such programmes for US OSHA). Why is this competition necessary? Because the marketplace requires a more diverse product mix to meet the need of the country. What's next you ask? Do we have the right product mix? 1

Product Mix? Isn't there just one product, the Act itself! Well let's look at another category, dandruff shampoo. Why are there now nine different kinds of "Head and Shoulders"? Because the marketplace demands choice. The current product mix of 10 Hour and 30 Hour US OSHA or the NEBOSH Certificate/Diploma do not adequately address the requirements of the TT OSH Act. The marketplace is diverse. It includes small to large organisations; apprenticeship and vocational programmes; public to private organisations; differing business sectors from service, manufacturer, hotels/tourism, energy ­ upstream and downstream operators. It demands choice. The product mix must cater to this diversity, but also acknowledge the level of compliance that individual organisations are currently at to be able to deliver the right product at the right price. The variety of the product mix is much greater than the US OSHA and NEBOSH programmes. Some of the products that are needed are: Plan and Policy Writing Risk Assessment Hazard Identification Job Hazard Analysis ­ Safe System of Work Risk Ranking TT OSH Act Sensitization Training Topic Specific Training Emergency Action Trenching and Evacuation Blood borne Pathogens First Aid and CPR Forklift and Ladder Safety Hazardous Communication Yet, how do the business community and government know what specific requirements they need? Research indicates that the marketplace does not know this answer.1 This lack of knowledge leads to confusion and frustration on the part of the "Buyer", thereby making a difficult and unwanted purchase easy to postpone. What can be done to help the marketplace analyze their needs to make a more informed buying decision? A review of the existing safety culture literature was undertaken to identify the appropriate criteria to measure progress in the implementation of the mandates of the TT OSH Act into a workplace. As a result of this study, OSHA Services has developed the Safety Culture Climate Assessment Tool (SCCATTM). The SCCATTM is a comprehensive on-line assessment tool that provides the information necessary to make an informed buying decision. The information gained from the SCCATTM is: 1. What should be in place given the company's current level of compliance. 2. Cites the relevant section in the TT OSH Act. 3. What products need to be obtained and put into place to raise the company's level of compliance to an acceptable level.

1

Health and Safety Executive (HSE). 2003. Cost of compliance with health and safety regulations in SME's, Research Report 174

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Clearly, this tool solves the question: "What product mix do I need to be in compliance with the TT OSH Act?" Currently this tool is being used by AMCHAM, TTMA, STCIC and TT Chamber members to aid in their decision making process. We look forward to many more Buyers using this tool to aid in their decision making process. Once the decision to buy is made, is there a reliable delivery system to handle full marketplace acceptance of our "product"? Quite simply the answer is NO! It's not that progress is not being made, numerous providers are now focusing on the Act. Including but not limited to: CHESS (Trinidad) Limited HHSL Safety Systems Limited HSSE Jaric Environment Safety and Health Services Limited RGIT Montrose Set, Ready, Go TechSafe Training and Consulting OSHES OSHA Services is now a registered branch and has four dedicated trainers in Trinidad and Tobago compared to only one two years ago. Yet, this is not enough. This lack of ability to deliver the product will create a supply shortage, will increase cost, will create "a have and have not" situation with the most needy being left behind and, of course create frustration among the marketplace. What can be done? We have been working on a "train the trainer" program, as well as a one-year safety practitioner program designed to give practical hands on training to help meet this impending shortfall. We look forward to working with the Ministry of Science Technology and Tertiary Education (STTE) and the OSH Authority to create qualified persons. Secondly, and most importantly to the marketplace, is how do they know if they are being given the correct information by a qualified provider? The qualifications of the providers must be challenged, in light of the current shortfall. It is imperative that our product quality not be compromised. What quality system is in place to assure the marketplace that our product is being delivered to the highest standards. I am pleased to report, if you do not know already, that all training providers ­ including OSH trainers will be required to be registered with ACTT by July 2008 The OSH Authority has also undertaken the process to establish criteria for programme approval from the ACTT or NTA/NEC for OSH training. This will certainly give the marketplace confidence in the delivery system. Marketing of a new "product" is essential to its initial success and the deepening of its use by the consumer. This is an area where little has been accomplished; in fact the foreign competitors have outpaced our efforts. Daily print ads offering US OSHA and NEBOSH courses abound, giving the impression to the general marketplace that they are the only game in town. It should be noted that the OSH Authority did a blitz campaign in May to help promote National Safety Week. This lack of a coherent strategy is puzzling since the HSE research that states "lack of 3

awareness not lack of desires to comply" was given by SMEs as to why they had not achieved compliance.2 What is the way forward? I would like to challenge the Ministries of Information and Education to create a national safety campaign, comprised of billboard ads, TV, radio and print ads. As well as getting the nation's youth to compete in a poster campaign to create a buzz around this "product". One of the most exciting elements of this product for me is that the necessary cultural change could occur within one generation because of the workforce demographic of Trinidad and Tobago. If safety is promoted as a way of life by all forms of the media and the education begins early the results will be dramatic. By 2020 the current three year olds will be 16, the current 16 year olds will be 29 and they will not only expect but demand a healthy and safe work environment as this is all they will have known. This cultural shift is really possible but we must take action now. Ok, let's say we could create a buzz around our product, is that enough of a reason to buy? It should not be overlooked that businesses do not buy buzz. So, what compelling reason, other than the inherent benefits of safety, is there for the marketplace to invest in health and safety? What compelling reasons are there currently being offered to the business community to invest? We do not see any. Dan Anderson, Financial Controller of OSHA Services made the case that "safety pays" in his paper for this conference but that message is not shared by the wider marketplace. In order for the businesses to see a return on their investment in safety they must first make the investment! What could make the business community want our product? Financial incentives! We have been advocating for the past three years for some positive financial incentive to address the well documented issue of the lack of funding for safety in the SME community.3 There has been some success in this area with the STCIC STOW Programme obtaining funding to assist the SME community, but overall very little progress has been made. We continue to believe and will continue to push for funding an SME implementation programme. AMCHAM, TTMA and TTBS will again submit a proposal for funding by years end. Secondly, we will continue to work with the insurance industry to reward businesses for their compliance efforts by creating a premium discount once compliance is achieved. We call on ATTIC to begin this necessary step to recognize and reward business for their compliance further underscoring the truth that "safety pays". Progress is being made ­ buyer's are accepting and buying the product. Let's just look at what OSHA Services has done from February 17, 2006 through the second quarter of 2007:

2

Health and Safety Executive 2005, Making an impact on SME compliance behaviour: An evaluation of the effect of interventions upon compliance with health and safety legislation in small and medium sized enterprises, Robyn Fairman and Charlotte Yapp, Kings Centre for Risk Management.

3

Health and Safety Executive (HSE). 2003. Cost of compliance with health and safety regulations in SME's, Research report 174

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Sensitization Training for the TT OSH Act o 169 companies and 1,639 individuals Safety Management Excellence Programme o 16 companies and 59 individuals Safety Practitioner Program o 14 companies and 23 individuals

There is still much more to do ­ with over half million people in the workforce and over 29,000 businesses ­ many need the "product". The diversity created by just the sheer volume of buyers shows there is room for many vendors in the marketplace. The success of our product, like any other, lies in the hand of the consumers. Many have answered the challenge to date. But these early adopters are not enough to significantly defeat the product barriers. The challenge to businesses and government is to recognize what is at stake if the product is not embraced. Belief in corporate social responsibility along with the Country's pursuit of the 2020 Vision makes the acceptance of the product not only important but essential. Our product is not a new dandruff shampoo it has a much greater value. The TT OSH Act is about protecting the greatest resource of the country ­ our people now and in future generations. What greater value could a product have? The adoption of the product will create a cultural shift in Trinidad and Tobago. This cultural shift will result in a positive safety culture for the workforce. This positive safety mindset will be carried by the worker's into the home and onto the roadways. Safety is everyone's responsibility. SAFETY must become a cornerstone of the Trinidad and Tobago mindset. It is time to embrace the importance of safety in everything we do. We look forward to continuing to help in this historic endeavor and we will report back next year.

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A LOOK AT IMPLEMENTATION AND COMPLIANCE WITH THE TT OSH ACT