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An analysis of

6 tools to help you go beyond regulatory compliance and assess risk     

By The American Association of Safety Professionals (ASSP)


     lthough “risk” is a term frequently used by safety professionals, they may not be fully leaning into its use as a means of going beyond regulatory compliance to achieve greater safety and operational goals.
    “This is a word we need to come to grips with,” says Fran Sehn, M.S., CSP, ARM, principal consultant at F x S Risk and Safety Consulting. “As a tool, we need to take it and embed it in what we do to get to where we need to be.”
    Simply defining risk can be difficult: In 2021, an ISO Technical Committee 262 task group that included Sehn, Peter Milsom and Awad Loubani found that risk is used or defined in 225 ISO standards. However, they found it is not used or defined often in OSHA standards. Sehn credits this scarcity to safety professionals’ focus on hazards over risk.
    Relying on regulatory compliance standards is not enough to improve incident prevention, he says.
    “We’ve used compliance and regulations as our strategy for such a long time, but have we been successful?” Sehn asks.
    He points to data from the U.S. Bureau of Labor Statistics that show how little the needle has moved on serious injuries and fatalities.
    From 2017 to 2021, the rate of nonfatal injuries and illnesses has barely changed, from 2.8 per 100,000 workers to 2.7. The 3.6 per 100,000 fatal occupational injury rate in 2021 actually represents the highest annual rate since 2016.
    “We need different tools as safety professionals to bring to management to say we have an opportunity to make things better, not just from a safety perspective but operationally as well,” he says.
    To help safety professionals move beyond regulatory compliance and appropriately assess risk, Sehn presented several tools in the webinar “Demystifying Risk for the OSH Professional,” presented by our Risk Management Practice Specialty.

“We need different tools as safety professionals to bring to management to say we have an opportunity to make things better, not just from a safety perspective but operationally as well.”

1 Complete a risk matrix
You can quantifiably assess risk for individual hazards using a risk matrix.
    One easy-to-understand example is picking up boxes from a pallet on the floor. The first step is to identify hazards, which in this case include excessive force, repetitive motion and posture. The next step is to assign numbers to the frequency and severity of each exposure to develop a risk score. By calculating the upper limit of an acceptable score, safety professionals can systematically propose and implement risk control measures. In this example, options for corrective measures include installing a lift table and conveyer, implementing job rotation or redesigning the task.
    The key to ensuring the recommended controls are implemented lies in completing a cost-benefit analysis and effectively communicating the new measures and their anticipated results. Doing this effectively requires a robust change management process, Sehn adds.
    Risk assessment resources, education and training are also available to support your use of tools like the risk matrix.

2 Conduct a bow-tie analysis
While a bow-tie analysis is not as quantitative as a risk matrix, it can also help safety professionals and other operational or executive leaders understand the risks inherent in their work.
    It involves outlining the hazards, causes and preventive controls in a winnowing fashion until reaching the scenario — the knot at the center of the bow-tie — then fanning out to mitigative controls and resulting consequences.
    Get step-by-step instruction on creating these diagrams in “Risk Management Tools for Safety Professionals” by Bruce Lyon and Georgi Popov.

3 Create safety committee-informed checklists
“The people who do the work really are in the best position to help us identify the risks,” Sehn says. “Their participation and consultation are critical to the success of identifying and correcting hazards.”
    But safety committees need guidance to be fully effective. Sehn recommends having them design a checklist for a workplace or job site following the advice of Atul Gawande in the short book “The Checklist Manifesto.” Gawande describes how his team tapped all emergency room personnel in the creation of procedural checklists at Brigham and Women’s Hospital in Boston.
    Because everyone had an equal opportunity to provide input, these checklists allowed for better and faster treatment at a critical moment — when victims of the Boston Marathon bombing needed treatment.
    By collecting input from staff and crafting safety requirements from their recommendations, safety professionals can ensure sound processes and achieve positive outputs while minimizing risk.

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4Design a risk pathway diagram
A risk pathway diagram is another tool for assessing risk beyond regulatory compliance. This diagram involves looking at the risk source, risk driver, exposure, trigger, incident and consequence.
    As an example, Sehn assessed a dust explosion, where combustible dust is the risk source; poor housekeeping and maintenance are the drivers; people, property and business objectives are the exposure; ignition source is the trigger; fire and explosion is the incident; and business interruption, property damage, injuries and even fatalities are the consequence.
    In this case, basic process changes like implementing better housekeeping and maintenance measures can positively impact safety.

5Use value creation principles
Providing value to an organization as a safety professional must go beyond merely saving money by avoiding OSHA fines, Sehn says. Risk management provides the potential to create value across an enterprise through the principles, framework and process outlined in ISO 31000:2018, figure 1.
    This includes modeling for “value creation and protection,” which focuses on principles that are integrated, structured and comprehensive, customized, inclusive, dynamic, based on the best available information, inclusive of human and cultural factors, and involve continuous improvement.

6 Shift your safety perspective with these books
Not every tool is as concrete as a diagram. Some tools help you shift how you view risk and safety in the workplace. Sehn recommended two books:
    “Team of Teams” by four-star General Stanley McChrystal, who led the Joint Special Operations Command, and a team of authors, highlights how the U.S. Army adapted to challenges in Afghanistan and Iraq by scaling the effort of small teams to respond more quickly, communicate more freely, and make better and faster decisions when managing risk.
    “Safety Differently: Human Factors for a New Era” by safety expert Sidney Dekker will help you stop seeing people as a problem to control and start seeing them as a solution to harness. It also emphasizes how to help organizational leaders see safety as less bureaucratic and more ethical.
    Ultimately, “we need to be open-minded in our approach to solutions to safety and health concerns,” Sehn says. “Risk assessment tools are valuable. We need to read and understand what they’re all about.”
    You can even combine risk- and hazard-based assessment methods into a hybrid model. When you address risk, “ultimately hazards will come along for the ride,” he adds.

ASSP is a global association for occupational safety and health professionals committed to advancing members’ careers and the safety profession. Learn more at


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VOL. 57  NO. 7