Too often serious accidents occur, people are hurt – and organisations pay large fines – because well understood hazards are not formally identified as hazards, or because the actions to prevent harm have not been put in place.
The need to guard machinery is well understood in manufacturing, and controls are mandated by the Provision and Use of Work Equipment Regulations (PUWER). Food manufacturer, Nestlé, had at least five machines on their production line where, contrary to the regulations, there was an unguarded gap near moving parts.
The problems weren’t tracked, so no action was taken until after an operator suffered a major injury. His arm was pulled inside the machine, badly breaking two bones and requiring surgery. Four years after the accident, his arm is still weak and scarred. Nestlé was fined £640,000 for breaching PUWER. Following the accident, Nestlé fitted guards to all five machines.
To prevent harm to individuals - and to organisations – from such unnecessary accidents, employers need to have a system for tracking and managing critical safety actions. But what does a good action tracking system look like? Here are six features to look for.
1) You need to be able to record new actions immediately
If you spot that machinery needs guarding, or that a step on a fixed access ladder needs repairing, you need to record the action as soon as possible. By the time you get back to your desk, you’ve had three more conversations with people, and the action has dropped down your priority list.
Being able to record actions immediately on a device you’re carrying around makes it less likely to be forgotten. Suggestion cards on the factory floor have been a simple, traditional way to get people to raise actions immediately, but as we’ll see, a paper system can’t meet the other features we need in a 21st Century action tracking system.
2) You need people to define actions clearly
With a paper-based system people can write as little as they like, and whatever they like. While you don’t want an essay, you do need some essential information.
Clear specification of actions is even more important during the pandemic, when shifts are often deliberately prevented from overlapping and some workers are on flexible furlough or working from home. You can’t assume that the person who suggests the action will be the person who tracks it to close out, or even that they will be around to get more detail from.
Your action tracking system therefore needs to be clear about defining what action is required, where it applies, who might be involved, and any deadlines. A form-based layout on a screen is a simple way for the person recording the action to see that all relevant details have been recorded, and pull-down lists of site locations and employee names can reduce the amount of typing needed.
Where the organisation has a system for classifying actions according to system type (eg access equipment, fire systems, water systems) you can improve the clarity of the action by prompting the reporter to add the classification.
3) You need to be able to track any changes to the action
Sometimes, the person reporting has a clear idea of what needs to be done. At other times, a second person might need to refine the actions. For example, an auditor notices an area is untidy. Rubbish left on the floor could cause slips and trips. In the event of a fire, it will provide fuel and create an obstacle for evacuation. The auditor raises the simple action “Improve housekeeping.” This might spawn a range of other actions – mark up areas for storage, provide training on storage and disposal, carry out a weekly inspection. Each needs to be created as a separate action, with an action owner, and different deadlines.
4) You want to be able to calendarise regular actions
Many actions can’t be signed off once and for all. With the example above, marking up areas for storage might be a one-off action, but training will be repeated annually, and inspections weekly. Other actions have intervals defined in legislation, such as once in 14 months for the thorough examination and test of local exhaust ventilation (LEV) systems.
Unless you want to manually enter repeats for an action, make sure that your action tracking system lets you define the frequency of repeat for a task. For some hazards, you might want to adjust frequencies according to risk. Frequency of portable appliance testing (PAT), for example, should be based on the risk of the appliance and the environment within which it is used, and should be adjusted based on experience.
5) You want to be able to see links between actions
Actions can be linked for two key reasons. If you can spot actions that complement each other, you can combine two actions into one. For example, two departments raise an action for a new type of PPE, allowing you to make better purchasing decisions. Or five lines raise actions to have guarding improved on machinery, and you can use the same contractor for all the jobs. If you don’t spot complementary actions, you will irritate people by assigning similar actions to two people, or asking the same person to do something twice.
The second reason for linking actions is where they conflict with eachother. For example, production raises an action to reduce the amount of paperwork needed before restarting a packaging plant after maintenance. Simultaneously, following an investigation of a near miss, the safety team has raised an action to include an additional checklist to prevent any further tools being stuck in the packaging plant at start up.
If both actions were followed through independently, a lot of time would be wasted, and a lot of people upset. Knowing there is a conflict in viewpoints will allow a conversation between those involved, to get agreement about how best to deal with this.
Having an action tracking system that allows you to sift and sort actions, by department or system or urgency will make it easier to find those links.
6) You need actions to be followed up and completed
If it was important enough to action, it’s important enough to follow up. In some ways, card-based suggestion schemes had one advantage. Until you had dealt with a card, it stayed on your desk reminding you it needed to be actioned. Too often now, action lists are created in a spreadsheet like Excel, or even worse, in a Word document. And then ignored.
The spreadsheet doesn’t remind anyone what needs to be done. If someone is assigned an action, you want that person to be notified – and reminded - without your having to send multiple emails. Where an action has supporting information, such as photographs, plant schematics or instruction manuals, your email needs to include multiple large attachments. How much easier then if all the information anyone needs is in a secure, cloud-based system. When the system notifies someone of an action assigned to them, the same system has all the information they need available.
Ready to invest in an action tracking system?
When there is an accident, organisations are seen as more culpable – and pay higher penalties – if it can be shown that someone in the organisation was already aware of the problem, but no action was taken. It is a good investment therefore to make sure that any actions raised are looked at and followed through. Such an important process can’t be left to a pile of suggestion cards, or an unstructured ‘to do’ list.