While information about OHS outcomes explores OHS ‘failures’ (B1), information about OHS processes seeks to communicate what the company is doing to address OHS risks and prevent workplace injury and illness (B1, E10). Overall, 98.1% of respondents agreed that it was important for OHS reports to include a discussion of the way OHS is managed (86.5% strongly agreed). Most important to respondents was evidence of management commitment to OHS, information about corporate OHS policies, programs and initiatives and about significant changes in management strategy or OHS risk. These results are illustrated in Figure 5-11 below.
Importance of disclosures that explain OHS practices
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% Management commitment Policies & programs Change in risk profile Safe design, procurement Programs serious disease Regulatory feedback Incident recording OHS committees Safe behaviour programs ILO compliance Relationship with trade unions OHS incentives HIV related programs % of r e s pon de nt s
Extremely or very important Important
Undecided Not important
Figure 5-11: Stakeholder attitudes to OHS discussion topics for disclosure
When ranked in order of importance, those issues recommended for discussion by the GRI, such as reporting on programs to educate stakeholders on HIV or serious disease, disclosing compliance with ILO Health Management System guidelines and descriptions of formal agreements with trade unions failed to be identified as the primary issues of concern. Instead, stakeholders appeared more interested in details about how employers discharge their duty of care to provide a safe workplace. This
included demand for explanations about the level of integration of OHS within broader organisational and operational structures (M40, C2), the extent to which safety commitment was driven from the CEO and senior executive (M24, M40), the extent and methods of consultation with both workers and other stakeholders (R3, E38, C2, M24, M32, M40), and details of measures taken to eliminate or control OHS risks, particularly the extent to which firms seek to eliminate or control hazards rather than simply relying on safe behaviour or PPE (M18, M16, U18). These findings are summarised in Table 5-5.
Rank Demand for detail about
% respondents ranking this item MOST important
% respondents ranking this item as one of the four
most important
% respondents agreeing disclosure
is important
1 Evidence of managerial commitment 52.7% 83.9% 96.7%
2 Actions to provide a safe workplace 14.3% 78.6% 93.5%
3 OHS policies and programs 15.2% 67.9% 99.2%
4 Actions to encourage safe behaviour 2.0% 48.2% 88.6 %*
5 Operation of OHS committees or
other forms of OHS consultation 2.7% 21.4% 92.7%
6 Feedback from regulators 2.7% 17.0% 94.3%
Table 5-5: Demand for information about OHS processes
The comments provided by respondents suggested that they were concerned about the ability of process disclosures to accurately communicate the safety culture operating within an organisation and provide evidence as to: the level of “genuine commitment” (M18) versus “lip service” (M10); the “tolerance of daily risks” (U23); the relative degree of focus on hazard versus behavioural controls (U18, C3, M5, M29); and the extent to which the system is driven by a pursuit of employee welfare or by cost or productivity (operational) considerations (E20, E21, E38, U2, U19 U20). One manager suggested:
More consistent OHS reporting would ‘force’ a higher level of benchmarking, because it would make it very easy for employees and others to see if the company was a employer genuinely committed to OHS, or if it was just in policy document with no leadership by senior managers e.g. no KPIs and no ownership of staff and supervisors (M18).
Although strongly in favour of the use of OHS process KPIs to support explanation about organisational processes, respondents’ preferences for individual indicators were more varied than had been evident in respect to the OHS costs or outcome KPIs addressed above. For example, 7% of respondents dismissed absenteeism as
‘not important’, yet 10%81 rated it ‘extremely important’, with a number observing that absenteeism is “an important indicator for bullying and harassment” (U5) and for “workplace morale which is linked to OHS behaviour” (M19). One respondent suggested, “the stakeholder scope is large, different items are going to be pertinent to some groups and not others” (M32). Illustrating this, a summary of the attitudes to the top 10 process KPIs, presented by stakeholder group, is provided in Appendix 10. Some respondents also suggested additional KPIs such as measures of OHS complaints and ideas (U23), OHS targets and variances against those targets (R7), and indicators of leadership, commitment, communication (C2, U26) and empowerment (B1).
Rank Demand for
OHS process KPIs
% respondents ranking this item MOST important
% respondents ranking this item in
the top four
% respondents agreeing strongly that disclosure
is important
1 Near misses 33.9 68.6% 65.0%
2 Audit non-conformances 10.4% 56.0% 76.2%
3 New risks identified 21.7% 55.1% 68.0%
4 Risks structurally controlled 9.6% 56.9% 67.2%
5 Hazardous exposures 9.6% 51.5% 73.2%
6 Training attended 3.5% 36.1% 61.8%
Table 5-6: Stakeholder attitudes to the importance of disclosing OHS (process) KPIs
Analysis of the results by stakeholder group revealed all stakeholders prioritised the disclosure of data relating to near misses and audit non-conformances as very important. Shareholders were most likely to also prioritise absenteeism, reflecting perhaps a concern for indicators that give greater insight into potential human resource management issues. Interestingly, while managers, consultants and employees identified as very important the public disclosure of KPI data relating to OHS risks controlled, external stakeholders such as regulators, unions, shareholders and academics did not rank them as highly. This may be due to a level of scepticism about these types of claims. One shareholder, for example, described these as “pointless” suggesting “they give too much room for organisations to invent issues they can say have been solved” (S1).
Nevertheless, the results suggested that KPIs relating to OHS processes were preferable to measures associated with OHS commitment or policy. Furthermore, respondents were more likely to identify as very important those indicators of the outputs of OHS processes than indicators of process inputs or activity. For example, 66% of those surveyed were very interested in the number of audits completed but
81
The 10% for and 7% against reporting on absenteeism each comprised a similar distribution of respondents from employee, manager and trade union representative stakeholder groups.
76% sought to know how many audits were ‘clean’, or conversely how many non- conformances were identified or had been addressed (R3). In the same way, 55% were interested in how much OHS training was offered, or conducted, but 62% sought data on employees successfully completing OHS training. As one union official stated:
It’s all good to know how many training sessions a company ran or what percentage of sites offered training but it’s pointless when you’re left wondering if anyone actually went! (U14).
This is illustrated in Figure 5-12.
Importance of OHS activity PPIs
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% Hazardous exposures
Near miss Completed audits Audit non- conformances detected Training offered Training completed New OHS risks Total OHS risks Risks eliminated Risks controlled: structural Risks controlled: PPE OHS committee participation
Extremely or very important Important
Undecided Not important
Figure 5-12: Stakeholder attitudes to disclosing OHS management KPIs
Overall, survey respondents were particularly interested in the disclosure of information relating to OHS programs for providing a safe workplace and processes for monitoring both outcomes and programs. Keen for evidence to support these disclosures, KPIs relating to near misses, audit non-conformances, health hazard exposures, OHS risk control and training were identified as particularly important (as identified in Figure 5-12).
The ability to benchmark OHS progress, in terms of both processes and ultimate performance, requires firms to produce reports that are not only complete in terms of the relevant financial and non-financial information outlined in this section, but also complete in terms of presenting OHS content in a consistent and comparable fashion. The attitudes of survey participants to issues of information quality, such as information completeness, consistency and reliability (as defined in section 1.3) are now examined below.