Promoting and protecting the health and safety of the workforce is a widely agreed upon moral imperative, but often viewed differently from a methodology standpoint when it comes to the practices of creating and maintaining safe work environments. At Randstad, our approach to safety is driven from commitment to our values, our business principles and an understanding that how we think about and practice safety is strongly connected to our clients' working environments — and the future of work itself.
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history of safety - and the emergence of a new view
Perceptions of safety and how it should fit within an organization have evolved, or some would say matured, in myriad ways, from the perspectives and expectations of shareholders to the supply chain and even generational influences (in particular, millenials and Gen Z). Here are a few important items to recognize among today’s global trends that are setting expectations in workplace health and safety:
Safety metrics are becoming more transparent — and integrated with sustainability and environmental, social and corporate governance (ESG).
- Safety performance criteria (the number of risk assessments, improvement projects to minimize serious risk and so on) are increasingly presented alongside and correspond with safety injury data (failure-based metrics).
Safety management systems are maturing.
- Having a common framework that integrates safety planning — and continually monitors and assesses risk — has become the rule, rather than the exception, at leading companies.
- High-risk intervention strategies are now more clearly defined and strategically targeted.
- Targeting serious injuries and fatality risks has become a strategic imperative, with widespread leadership buy-in.
While many of these trends were visible in the past, COVID-19 acted as a catalyst. During the pandemic, organizational thinking shifted rapidly from injury prevention to illness prevention, generating a common framework through the safety community to better communicate about risk in general (for example, through the hierarchy of controls). Randstad led and leveraged these techniques early during the pandemic, quickly establishing industry protocols and alliances through our white paper Safely Back to Work in the New Normal, which also advised the American Staffing Association and was later adopted by the World Employment Confederation. This represented a highly collaborative effort, from the C-suite and throughout the organization, and perhaps represents at least one silver lining for us through our experience with COVID-19 — a reminder of how much we can accomplish when we harness our collective energy to drive better health and safety outcomes for the workforce.
This is especially important in the contingent labor community: Injuries and illnesses among temporary workers occur at a rate higher than among their counterparts in similar jobs who have more traditional employment arrangements. There is a new view of safety that enables those closest to the risk to be part of the solution (that is, the workforce itself). It recognizes fundamentally that leveraging principles of safety management throughout the ecosystem where work takes place is what allows employers to more effectively create and sustain safe working environments for all employees. Nowhere is this more important than in joint-employer environments, as when a staffing company partners with a client.
Of course, there are always going to be different, and even competing, views as to when, where and how safety measures should be prioritized. For now, however, the more important thing is to understand where we are at the moment, and begin to understand and formulate a plan for a preferred future state — to draw a line from where we are today, in terms of understanding and managing risk, to where we want to be in the future. Here, as elsewhere, it will be useful to also recognize what has shaped our thinking and understanding when it comes to safety in the first place. Understanding the evolution of safety over the past 150 years can help us better identify where our organizations understand and practice safety in connection with a workforce that continues to evolve itself, and that today includes significant numbers of contractors together with the vendors that support our supply chains.
evolution and eras of safety management
There have been five general — but distinct — eras of safety management, separated by moments when the emergence of new risks, combined with deficient safety systems, mandated better safety solutions. Below is a very brief overview of these five eras. While the first era (the “era of death”) may sound extreme, it was in this period that Theodore Roosevelt included in his presidential address: “The number of accidents which result in the death or crippling of wage earners is simply appalling. In a very few years it runs up a total far in excess of the aggregate of the dead in any major war.” Naturally, as we shall see, each successive period in the history of safety management attempts to correct for the most glaring safety gaps or shortcomings of the one that preceded it, for example, conspicuously improving life-safety measures in building design and rescue equipment following the Triangle Shirtwaist Factory fire of 1911.
era of death: late 1800s to 1930s
- post-agricultural to Industrial Revolution period
- pre-child labor and other labor and safety laws
- very limited understanding of human-machine interactions in industrial settings
era of engineering: 1940s through late 1960s
- machinery designed with the intent of partitioning risks away from workers (machine guarding, separating workers from hazards, etc.)
- relatively ineffective early safety designs often interfered with machine operations, slowing production
- workers often removed safety guards in order to maintain production
era of compliance: 1970s through late 1980s
- Occupational Safety and Health Administration (OSHA) defines employer requirements to ensure safe work environments and creates related regulatory requirements
- decrease in minor and moderate injuries, but reduction in fatalities soon plateaued, indicating limitations to a purely compliance-based approach
era of behavioral-based safety (BBS): 1990s through 2000s
- based on methods of risk and safety observations of the workforce
- intended to connect management with employees in order to identify and resolve safety issues
- data can be improperly interpreted by employers to reveal unsafe behavior as the fault of employees, thus becoming punitive and less effective at delivering desired safety outcomes
era of safety management systems and human and organizational performance (HOP)
- successful history from high-risk industries like the U.S. Department of Energy
- methods deployed show significant reduction in serious injuries and fatalities, and are easily adapted to different environments
Why is it important to understand where safety has been practiced, or how it has been understood over time? To start with, it’s closely connected with what shapes our thinking and understanding of risk in the first place. For example, it may be easy to focus on machinery design alone — and to overlook the dramatic increase in risk to employees when engineering designs failed or became so cumbersome to production that they were removed by employees themselves. But can you imagine the stakes from the view of the worker? Risking your job, income, limb and (potentially) life in order to work on a machine on which safety guards, intended to prevent amputation, were in fact preventing you from hitting your quota? What would you do? This proved to be a significant safety challenge in the early days of what we are calling “the era of engineering.”
Fast forward to the “era of compliance” — which defined at least the very basic plumb line for employers to measure up to when it came to safety: BLS statistics show that, while this era was in many ways successful, it was also limited in its capacity to address the dynamic systems issues and latent risk associated with serious injury and fatality (SIF) events. Notably, this era is characterized by a decrease in non-fatal injuries alongside a plateau, and then an increase, in fatality figures. It calls to mind an old saying: “If you only aim for compliance, that’s all you will ever get” — an important saying to consider when we think about the fact that there is very little capacity to absorb failure with a strictly compliance-based approach. You’re either at the level of compliance, or you’re not, in other words.
In the era of behavioral-based safety, Behavior-Based Safety was able to begin to connect basic system conditions, aspects of leadership and culture as well as behaviors of the workforce within an active work cell to discover (feedback) opportunities between leaders and workers, with ongoing data reviews as a guide for further organizational learnings. While effective in its purest forms, the challenge for BBS was connecting worker behaviors to variables in leadership, culture and the organization. These two are inextricably linked, yet the focus often ended up being only on worker behavior as the problem to solve. The other challenge with BBS has been to keep observations and feedback positive, specific to risks and job tasks and done in a way that establishes trust and upward communications between those being observed (the workforce) and those doing the observing (management).
What’s more, observations and communications must evolve, conducted in a manner that represents actual behaviors in the work environment, rather than modified behavior. This modified behavior, also known as the “Hawthorne Effect,” is what happens when people know they are being observed, and therefore adopt behaviors they believe the observer wants to see. Obviously, this can be a limiting factor in the effectiveness of any BBS program. As before, this calls to mind a familiar saying — in this case, George Bernard Shaw’s famous statement that “the single biggest problem in communication is the illusion that it has taken place.” And while BBS has been, and can still be, effective at managing hazards and improving safety, it must evolve to avoid the illusion that risk within a workcell is at an acceptable level, merely based on the most recent observation.
Perhaps the biggest difference between yesterday’s era of BBS and today’s era of safety management systems and Human and Organizational Performance is that BBS became commoditized as a method done to the workforce, rather than for, with and by the workforce. The difference has everything to do with meaningful communication between the corporate leaders and the workforce, as well as meaningful buy-in and engagement by those closest to the risk: the workers.
What does that mean, exactly? Safety for the workforce means the organization has an integrated business plan to enable safety improvement as part of their mission, leveraging powerful performance tools such as leader/worker participation, as described in world-class safety management systems. With the workforce means that, for example, the leader/worker participation model has been operationalized to the point where it is viewed as a necessary aspect of organizational learning and continual improvement, enabling trust and inclusion along the way. And by the workforce means the organization views the workforce as the solution to safety, rather than the cause of safety problems.
As a result, workers are able to actively manage risks, make decisions specific to their job tasks — and define and support work practices to ensure two critical things, especially as they relate to the prevention of SIF events. Those two things are:
- Do we have what we need today to ensure good work is done safely?
- Do we know what to do if we face new risks, changes to our process or potential harm (to oneself or to others)?
One of the important lessons we’ve learned from this evolutionary progression of safety is that an organization matures in understanding its risk and safety capabilities when it views those people who are closest to the risk — and likely in the best position to recommend solutions (i.e., the workforce) — as the safety mission itself. Interestingly, this is closely connected to Lean methodology, which promotes the idea that those closest to the work are in the best position to improve it.
As many organizational leaders understand safety from the standpoint of their own experiences, or even their roles within the organization, the following safety maturity model can be a helpful guide to structure organizational thinking and discussion around safety. It answers the question “Where are we right now — and where do we want to be?” when it comes to the safety journey.
safety culture and maturity model
As discussed, the first step in your safety journey is understanding where and how your organization thinks and practices safety today. The second? Drawing a solid line of action to where you want to be in the future.
Safety culture is easiest to describe as the context in which we understand safety within the organization where the work takes place. Safety as a shared value and priority throughout the organization, from top to bottom and left to right, would describe a positive safety culture, which numerous studies have shown correlates to better safety outcomes. Safety that is communicated through negative connotations by leaders and supervisors, on the other hand, often results in a culture where safety is viewed as a checkbox — a “have to.” These negative environments for safety culture often have intense focus on safety improvements in order to avoid negative reviews (for example, before an audit) or because we “have to” report after every incident.
While the term “safety culture” itself has been around for several decades, and sometimes comes in for criticism as another needless buzzword, make no mistake: culture matters. Crucially, of course, safety culture is fundamentally a product of organizational culture, reflecting a complex mixture of attitudes, behaviors, shared perceptions, beliefs and values. Culture is important because a healthy culture will actively guard against the degradation of safe practices and positive norms in the midst of change, such as high turnover or fluctuations in production levels.
That’s part of the reason why it is so critical to partner with organizations that understand how safety culture is impacted in joint-employer environments. Having the right workforce management strategy, together with providers who have the right level of safety knowledge and capabilities, can contribute to the ongoing development of a positive safety culture for all employees.
You may not have a robust, "best-in-class" safety culture and strategy in place at your organization today, but it’s important to take the time to evaluate nonetheless. Indeed, now is the time to do something about safety, as some of the risks touched on in this e-book so far should make abundantly clear.
So your first step is to gain an in-depth understanding of your safety culture: Where you stand today will determine the proper course of action to help get your organization to a place of safety excellence tomorrow.
But where to start? With the following five-step safety-culture maturity model from the experts at Randstad.
what is a safety-culture maturity model, exactly?
Safety-culture maturity models were developed to help organizations with the following:
- diagnosing the existing level, or as-is state, of business and safety systems
- identifying the best path forward for making improvements — that is, for reaching the preferred future state along the journey to safety excellence
From a high level, companies can generally think of this as progressing through the five stages listed below, each of which describes a point in time on the path to safety excellence. As you read each of them, begin thinking through where your organization falls today — but don't worry, we'll also examine each stage in far greater detail to help you figure it all out.
safety culture maturity overview: the five stages
Let's look at each of these five stages more closely. At the same time, we’ll also carefully outline next steps for your organization. That way, no matter where you are in your safety journey today, you'll be ready to spring into action by the end of the chapter — and to start making impactful changes that can alter the course of your safety journey tomorrow.
restrictive: active resistance to improvements
- There's little or no safety ownership. Requests for improvement are unwelcome. People who speak up on the topic of safety may be negatively singled out in order to maintain the unhealthy status quo.
- Shortcuts to complete tasks are common and expected. The fact of frequent accidents and injuries has been normalized. It’s accepted as par for the course, simply another part of work.
- The overall emphasis is placed on satisfying legal requirements to avoid negative attention — and the tendency to hide errors erodes safety improvement efforts.
- Communication patterns are strictly “top-down.” The only communication coming up from the workforce is good news, or if a situation is uncontainable, such as a workplace incident.
leadership view of safety and the workforce
"Employees are the major source of safety problems, so punitive measures are an appropriate move to control them."
- Reset leadership expectations: Start with the moral imperative and agreement that injuries are no longer acceptable as a matter of business practice, nor are people easily replaceable resources.
- Dedicate safety ownership to a person or team, providing them with a clear mandate and goals to ensure that expectations are set across each line of business.
- Start with a four-wall risk assessment, ensuring basic compliance measures, job descriptions and standard work practices are in place. All of this should set a strong baseline for improvement.
- Demonstrate the connection between employee safety and business success, so that collaboration and "safe work" is the primary focus, rather than fear-based tactics and legal mandates.
reactive: blame culture
- Responsibility for safety is delegated with limited authority or resources.
- Problems are typically identified after incidents occur, with punitive measures introduced as an attempt to correct them. “Blame and punish” is often the default setting in leadership’s mindsets following an injury.
- High levels of turnover in safety-specific positions are a common feature of these environments.
- The safety program is built to satisfy legal requirements, but it has since advanced to include incident-reporting for any/all incidents. However, these incident-reporting systems often blame and punish employees as the cause, to the exclusion of deeper systemic problems.
- Bonuses are often tied to lower injury rates, driving an organizational tendency to under-report injury events and incorrectly assume that lower injury rates equate to acceptable levels of risk.
Upward communication remains irregular — it’s not valued as a core part of operations.
leadership view of safety and the workforce
Leadership often defaults to "employee error" as the primary reason injuries occur, such as not following training or lack of attention. This view places blame on employees first, as well as stakeholders such as labor providers with the misguided notion that "if the staffing firm would only send us better employees, injuries would decrease."
While the organization may track injury rates, it is unable to describe why incidents continue to happen — and so continues its messaging aimed at employees to just "try harder — be safer."
Areas of safety improvement may be evident, but corrective actions are inconsistently applied across leaders and work units. Most critically, the business strategy and goals remain disconnected from the overall safety strategy.
- Shift leadership's mindset: Gain understanding that the last thing an employee did before a workplace incident was heavily influenced by the systems and culture where that work took place. That means, in turn, taking a hard look at everything from verbal and non-verbal communications to perceptions, examples set by supervisors, shortcuts observed, tools, training and more.
- Provide your safety team with a clear mandate.
- Define the expectation for basic safety communications on a specific cadence.
- Eliminate punitive actions tied to workplace injuries in all but the most extreme cases.
- Conduct simple compliance-based and job-specific risk assessments as an active measure of safety, rather than simply doing after-injury reports. And be sure to include your workers in the process, too!
transitional: compliance culture
- Regulatory requirements are well established and the primary vehicle for delivering messages about safety's importance.
- Safety communications are understood by the workforce as what’s important to the company, rather than what’s important to them.
- Safety-specific roles and designations are seen as responsible for improvements across business units.
- Goal-setting initiatives tied to safety have been developed and are tied to OSHA metrics and/or related costs.
- “Safety is a priority” is a common theme, but often misunderstood — competing priorities in the organization and production environment often trump safe decision-making and initiatives (such as critical safety areas in lockout/tagout procedures, machine guarding, dock safety practices, safety meetings, floor walks with leaders/workers, risk assessments).
- The safety program is built to satisfy legal and incident-reporting requirements. It has developed to encompass incident-reduction efforts derived from reporting metrics.
- A hyper-focus on reducing OSHA recordable rates creates a narrow focus on risk-control practices, establishing priorities to reduce minor and moderate injuries at the expense of preventing SIF events.
- However, interdependency for improvement among departments is increasingly visible — and an encouraging sign for the development of a positive, healthier safety culture.
leadership view of safety and the workforce
"I'm aware of historical safety data driving OSHA and claims frequency rates — but uninformed on what is required to specifically prevent serious injuries and fatalties. The teams are demonstrating initial improvements and increasing awareness of safety performance initiatives. We’re open to further improvements, too, but we mostly view that through the lens of compliance as a benchmark."
- Integrate your safety strategy and goals into the overall business strategy.
- Set clear safety goals with strong participation among leaders and workers alike. It’s imperative for you to communicate across the organization, “We’re doing this together.”
- Track progress toward goals, share results with employees and continually ask for feedback.
- Celebrate when employees begin proactively reporting hazards and identifying potential gaps in performance. Promote this level of shared communication as the ideal for a safer workplace.
- Empower your safety team to engage and communicate up with simple performance tools such as pre-work safety checklists, STOP work authority (SIF risk escalations), continual improvement ideas for work improvement (practices, tools, scheduling, communications) and more.
proactive: ownership culture
- Efforts to integrate safety into the business model are underway at the C-suite level, going beyond post-incident metrics and compliance audits.
- The role of safety is viewed as one of subject-matter experts, coaches and influencers to enable a workforce of safety leaders.
- Basic elements of safety management systems are in place, such as Plan-Do-Check-Act (PDCA) and leader/worker participation efforts around risk assessment and safety solutions.
- Frontline supervisors are trained to manage and control common risks as well as SIF exposures specific to their area. It should go without saying, but this includes managing hazards related to a contingent labor workforce.
- Clearly defined prevention metrics are in place and defined as all of the things that create a reliable, safe working environment.
- Performance improvement in safety is viewed as a better business outcome.
- Interdependency for safety improvements is prioritized among all stakeholders and influencers, including third parties like staffing agencies.
- Operational risk assessments have informed the organization who the key stakeholders are — and they are expected to contribute to the ongoing monitoring and assessment of risk as business partners, too.
leadership view of safety and the workforce
"We embrace the role that all employees must play in safety performance improvement. We’re actively working to connect and understand the relationship between work practices and organizational policies."
- Build and implement a clearly defined safety management system, including a system for more efficient risk identification and analysis (reference ANSI Z-10 or ISO 45001).
- Make preventive actions the rule, rather than the exception.
- Prioritize and enable feedback at all levels of the organization, creating trust and reliability in upward communications from the workforce.
- Ensure staff members are engaged and empowered cross-functionally to improve safety.
- Identify areas of the business that may be struggling with safety and build proactive plans for improvements, working collaboratively to establish and guard this new normal for safety and a healthier culture.
transformative: safety-as-daily-practice culture
- A clearly defined safety-management system is in place.
- Intervention strategies are closely integrated into the roles and responsibilities of each function, with oversight of the process framed in terms of continual improvement and employee development.
- Competent frontline supervisors and workers operate from shared expectations and values across their teams.
- Safety engagement is done for employees, with employees and by employees.
- Highly engaged staff members work cross-functionally to make safety a collective responsibility at every level.
- Transparent communication and collaboration with all workers and business partners is the norm.
leadership view of safety and the workforce
“Employee’s are in the best position to identify and understand risks as they accomplish their work. As such, we are intently listening to and learning from them, and ensuring that they have what they need in order to safely accomplish their work.”
- Continue to measure, manage and refine safety practices.
- Celebrate and highlight organizational improvements gained through better safety performance — for example, cost reductions or efficiencies eliminated. You could also highlight worker stories promoting healthy culture.
- Share externally facing thought leadership on safety to help other organizations improve, while also increasing the perceived value of your employer brand.
- Leverage the “new norm” for how the organization monitors and assesses risks at every level through success stories about how workers are solving problems and managing risks.
closing thoughts: the safety climate
One more important area to understand is the so-called “safety climate,” which can be a leading indicator of whether your organization is promoting healthier culture and safety practices or not. Let’s look at that in a little bit more detail.
Culture — meaning shared values, beliefs, attitudes and similar — tends to be established in a relatively steady state: It can change, in other words, but usually does so slowly. Climate, on the other hand, can fluctuate like the weather. As such, it acts as an early indicator of what is currently influencing your safety culture, positively or negatively.
Thinking of the concept of our safety climate alongside risk, a few similarities immediately jump out. For starters, both can fluctuate and change in a short amount of time.
The truth is, risks can go from acceptable to unacceptable very rapidly in joint-employer environments, where the shared workforce is actually composed of two distinct management systems. In fact, that’s one of the reasons why a systems approach, leveraging the basic components of the safety-maturity model and safety management systems, serves to not only strengthen your current safety climate but also guide your safety culture toward a healthier and more reliable state.
This is done through methods that connect leaders and workers (as well as the staffing firm and their client) to the present state of risk, enabling safe decision-making. For example, the Plan-Do-Check-Act (PDCA) and risk assessment methods leveraging leader/worker participation described (as in the “proactive” level of maturity) can serve as a powerful indicator for the safety climate, signaling how the entire workforce (leaders and workers) connects to the things that enable safe work to occur.
When we see evidence of this, we typically also see micro-learning and continual adjustments based on ongoing assessments of the current state of risk. These are the positive things we do in safety to establish and strengthen our shared understanding of how we work together to solve problems — collectively, they represent our attitudes toward accomplishing good work safely. In other words, the journey toward the next level of safety maturity is one that strengthens and preserves the things we need in order for work to go right, be meaningful and get done safely.
This section described the safety-maturity model, then introduced several important safety concepts — climate and culture, in particular — and suggested some of the reasons management systems need to stay informed and connected, especially in joint-employer environments. Next, we’ll break out into the specifics of safety management systems in much greater detail.
safety management systems
According to the global standard for safety management systems, ISO 45001, a safety management system is used to achieve the occupational health and safety (OH&S) policy of the organization. Its intended outcomes are several fold: preventing injury and illness to workers, providing safe and healthy workplaces through interrelated and interacting elements of the organization and establishing policies, objectives and processes to achieve key safety objectives, among others. Further, it defines important areas such as key safety-related roles and responsibilities, and positions planning as a necessary ingredient in achieving better safety outcomes.
In the context of joint-employer working environments, where there is a shared workforce and not one, but two management systems involved, understanding these definitions is especially critical. In fact, it even helps illuminate new ways of improving safety in these environments.
A few key words stand out in the context of a joint-employer workforce:
- Interrelated: There is a mutual dependency on each employer in order to accomplish work, especially when it comes to providing context for how that work is actually being performed.
- Interacting: The employers must work together to identify, understand and manage hazards together. This involves communicating at every level throughout the lifecycle of the work project.
- Roles and responsibilities: Leaders of both organizations must assign responsibility for ensuring conformity to health and safety requirements. They also have to report on current levels of risk and performance to leadership.
- Planning: This is the essential starting point for risk assessment, hazard management and continual improvement.
- Intended safety outcomes: These are products of the business systems in place.
How should the two employers who make up this joint-employer environment work together to drive the illness and injury prevention outcomes they want? And could there be a better framework for understanding risks and communicating expectations and activities for a safer work environment? A safety management system (SMS) is part of the answer — and a terrific framework for achieving better health and safety outcomes during exactly these types of engagements.
Two very important things to consider as we learn about how safety management systems apply to joint employers:
- The term “worker” as defined by SMS standards includes: a person performing work or related activities under the control of the organization, including various arrangements (including regular or temporary workers, seasonal and part-time employees). Notably, this term also includes “Top Management” according to ISO 45001.
- Emphasis on worker engagement:
- Participation: The measure of a worker’s involvement in decision-making, as appropriate for the worker/role and position, engaging in feedback systems (like an effective safety committee) to inform both leaders and workers of the current state of risk.
- Consultation: The act of seeking views prior to decisions, such as a client seeking feedback from their staffing agency on perceptions of safety communications, frontline safety efforts and ideas for improvement.
Given the above, we need to ask a few simple questions:
- How have we designed our risk and safety systems specific to the level of risk presented by the inclusion of a contingent labor workforce?
- Have we included temporary workers as an essential part of hazard identification, continual improvement and safety solutions?
- How do we include temporary workers into our safety management processes, beyond the mandatory and required compliance training?
- Participation: Are temporary workers able to give regular and open feedback — for example, whether or not work is being performed in a way that is consistent with training and safety requirements?
- Consultation: Do we include the staffing agency and temporary workers in proposed solutions and feedback? Do we nurture and listen to their ideas about how we can improve?
Asking these simple questions can be a great place to start, and it can even help evolve your current program to the next level of maturity. Also, consider integrating these questions into your procurement process to evaluate how any third-party labor provider is able to contribute in these areas.
At the center of safety management systems like the ISO 45001 or recently updated ANSI Z-10 standard is the process known as Plan-Do-Check-Act (PDCA). The PDCA process is strongly connected to risk assessment and the continual improvement process, and while it has traditionally been thought of from the standpoint of only one employer, best practices and industry-leading methodologies have advanced to integrate it for employers in joint-employer settings for the betterment of employee health and safety. A critical component of this process is leader/worker participation, strongly leveraging the concepts of team and communication across organizational lines and inclusive for each employer.
Figure 1, modeled after the ISO 45001 standard, visualizes the framework that both employers in a joint-employer environment could follow:
Notice how the PDCA process literally surrounds what’s at the center of the safety management system represented here. With that in mind, let’s take a closer look at all of this from the context of joint employers who are both focused on illness and injury prevention.
plan: dedicated time and safety development activities
- Leadership commits time/resources to assess hazards and risks, evaluating opportunities for improvement as well as other considerations, such as legal requirements.
- Expectations are established and set by leaders of both organizations (host employer and staffing agency), including the setting of both short- and long-term goals.
- A cadence is established (whether weekly, monthly or quarterly, the goal is for teams to review goals, risks and progress on an ongoing basis).
- Define the factors that are critical to worker safety in your joint-employer environment. While many risks are inherent with the operation — for example, risks related to machinery, equipment or tools — planning should include consideration of new or emerging risks due to change, such as turnover, new processes or even new environmental conditions.
Establish performance metrics — for example, the number of non-conformities identified as it relates to what is needed for safe work, the number of trainings or safety interventions in a given period or KPIs related to SIF prevention.
do: activities we planned for and accomplish together lead us to better safety
- Eliminate hazards using the hierarchy of controls methods, which we’ll cover in considerable detail in the following chapter.
- Evaluate your completion of the items identified during the planning phase, including:
- safety-related trainings and communications
- injury/illness-related risk assessments, floor walks/frontline feedback and safe/unsafe observations
- SIF prevention efforts such as fall-protection evaluations, forklift operations, dock safety, electrical, start-up procedures, machine guarding and more — always keeping an eye out to ensure safe assignments for temporary workers
- Record successes, areas for improvement and course corrections related to your safety-planning activities. You should also be sure to record peripheral activities — think near hits, root-cause evaluation and compliance activities — as well as creative items, such as surveys from employees or frontline supervisors.
- Action items and target completion dates respective to each employer (both client and staffing), ensuring they are jointly reviewed by both employers with the understanding that providing this insight together is critical for the next planning cycle. Examples include:
- Staffing agency: Prepare data and information such as what is impacting length of assignment, claim type turnover rates, assignment activity and critical insights like feedback from temp workers. This could also include appropriate risk assessments and evaluations as agreed upon by both employers.
- Client: Schedule meetings and follow-ups, lead risk assessment practice/review and share feedback with leadership teams.
- These elements of “Do,” which occur both inside and outside of the plant, facility or production floor, help ensure that each employer in the joint-employer setting contributes to the development of a shared safety strategy.
check: is what we’re doing working?
- Monitor the reliability, completion and results of safety activities.
- Focus on ongoing hazard identification, reporting, audit processes and safety committee communications.
- Are the planned communications and activities happening the way they should? If there are any gaps, do we know why?
- Is what we’re doing working? Have we encountered anything unexpected?
- Are we seeing any non-standard practices?
- Do we need to escalate any serious risk or concerns?
- Did scheduling/rescheduling of critical safety activities happen?
- Verify knowledge and retention of items critical to safety.
- Follow up on open safety items and corresponding actions, ensuring that they’re not only reliable but match the level of risk (e.g., missing machine guards are ordered and the machinery remains locked out or tagged out until they have been replaced).
act: review results, adjust and continually improve
- Everything we’ve just covered precedes and informs the next planning cycle.
- Identify and ensure resolution of any escalations related to items critical to safety.
- For any unresolved serious risks identified, is work related to this task allowed to continue?
- Celebrate wins, and be sure to communicate any risks removed.
- Align on goals and communication modes and channels between employers.
- Include employee feedback and communications to inform leadership and ongoing adjustments of risk controls.
- Ensure all items identified during the "check" phase are built into the next planning cycle.
As discussed, PDCA is a structured approach whereby each employer contributes to safety in a joint-employer work environment. It’s also where we see some of the other elements of safety management systems come into play: Roles and responsibilities, for instance, become much more clearly defined and understood. As this is closely aligned with expectations of how the two organizations work together, it can be a powerful cultural enabler. Furthermore, the PDCA model serves to keep both employers aligned around short-term and long-term goals. By establishing a cadence around the activities needed to create a safe work environment, it goes a long way toward advancing the reliability and safety of the work environment as a whole. And while some components of a safety management system may seem a bit broad, the PDCA process embedded within an SMS should serve as a simple yet powerful tool to keep both employers aligned on managing — and maintaining — acceptable levels of risk.
But what should be clear, above all, particularly in light of the COVID-19 pandemic, is that a fresh assessment of the risks affecting your organization, together with a commitment to building and implementing a strong framework (like the ISO 45001 standard), is an organizational imperative. In fact, doing so will place you on the same path as many best-in-class organizations right now.
leveraging the hierarchy of controls in your safety systems
The hierarchy of controls is a common framework for better understanding and communicating risk at the highest level of reliability and control. As a strategic framework, it also has wide-ranging applications across a host of different industries — healthcare, energy, aviation, manufacturing and more.
Evaluating risk through this lens creates a more collaborative environment for stakeholders to assess controls and mitigate risks. It’s directly applicable in the context of staffing, too. Notably, staffing firms and companies can use the hierarchy of controls to identify the most effective controls, then consider the feasibility of applying them before moving down to the next level.
At the same time, what we need to guard against is not having a process in place to challenge the norms around existing risk controls. When it comes to new or emerging risks, this is especially true, too. After all, without well-known, effective risk methodologies in place, organizations can easily default to operating from the bottom of the pyramid — for example, by relying on personal protective equipment (PPE), the lowest and least reliable method, to guard against workplace hazards. Worse, they often wind up doing it under the false belief that they are actually managing safety well.
In that light, it’s important to note that higher-order controls like elimination, substitution and engineering yield much higher levels of reliability and effectiveness as risk controls. By the same token, they may require more resources, and come with potentially higher costs, too. It also typically takes time to agree on the right approach or solution — and the same is true of accurately evaluating the potential ROI. That’s one of several reasons that lower-order controls like administrative tools and PPE are often selected as preferred methods. In many cases, after all, those practices have been in place for years.
Understanding and practicing the hierarchy of controls is especially valuable when two or more employers are collaborating in a shared work environment. Doing so can unleash tremendous value, lead to greater awareness around risk and controls and help keep workforces safe.
In the context of the COVID-19 pandemic, how can the hierarchy of controls be leveraged for better performance in risk and safety?
The diagram below shows a simple overview of the hierarchy of controls. Notice that levels of reliability increase the higher up you go, which is why the best rule of thumb is to start as high in the hierarchy as feasibly possible. While the diagram includes examples of common controls as part of a COVID-19 response, this same visual can be applied to any risks — those around controlling hazardous energy for machinery and equipment, for example. Finally, the diagram also foregrounds how important it is for both employers to understand how to approach the discussion of risk controls, and to stay connected throughout the process, as well.
If you aren’t familiar with the hierarchy of controls or using it in your current approach to safety, think of it as a terrific teaching tool for all of the teams, supervisors and employees involved in your program. Here are a few highlights to emphasize and teach from:
Have we reviewed our work processes through the lens of the hierarchy of controls?
- Are we able to eliminate any unnecessary job tasks/risks?
- Can we substitute any job tasks or materials (such as replacing an alcohol base with a water base) to reduce risk?
- Where do we currently have engineering controls? Are they effective?
- Do our work practices — including training, job descriptions, standard work instructions and more — show consistency with how work is actually being completed?
- Are there any job tasks where engineering controls are desired/needed, but not feasible at this time?
- Where engineering controls are not feasible, can we add levels of redundancy in work practices to gain higher levels of reliability?
Does our organization understand that PPE is the last and least preferred option in order to control risks?
- Where PPE is required, does it effectively protect the worker?
- Have we considered PPE fit and function, such as providing options for female employees?
Basic understanding of the hierarchy of controls can open up new areas of risk that were formerly not considered and greatly improve conversations between managers and the workforce, such as in team learning environments or meetings of the safety committee.
According to the National Safety Council (NSC), the cost of work injuries exceeded $171 billion in 2019. This is a significant economic impact in an area of business connected to mostly preventable injuries, with ripple effects far into the future. It is estimated that 55 million additional days are lost in future years due to the on-the-job deaths and serious injuries occurring in 2019.
A report of an injured worker creates an emotional response to anyone who hears it, ranging from “Are they okay?” to “How did this happen?” and even “Who is at fault for this?” There is a lengthy list of administrative requirements and responses involved, too, from injury reporting to investigation, loss control and more.
All of these are important to organizations, which need to ensure they’re adhering to federal and state reporting requirements, for starters. (There’s also the natural human curiosity about how or why something has happened.) But let’s also take a step back and remember that this process started after the event took place in which a human being was injured. Unfortunately, therefore, bias can be introduced early on in the process. Underlying the question of “Who or what caused this?” for example, is often a desire to assign blame that only serves to limit our understanding of the complex and interconnected sequence of events immediately preceding the injury. In more difficult settings, fear of punitive measures by an employer or legal recourse can shut down vital insight into how an injury event occurred, severely limiting organizational learning around what is needed to drive safety improvements for employees in that same environment.
In fact, scenarios like this are especially prevalent in joint-employer settings when temporary workers are injured while working at an assigned client’s location. This situation involves an employee of the primary employer (the staffing agency) who reports injury on the property of the host employer (the client), and where the host employer is most often responsible for the day-to-day supervision of the injured temporary worker. What we’ve described is a challenging and complex situation, but let’s not forget the two most important things in this process:
- A person has been injured and requires medical care.
- There’s clearly an opportunity for organizational learning to improve safety moving forward.
Both employers in these situations are involved around the activities and reporting of the injury, and both have similar, if slightly different responsibilities, in terms of responding to the report of injury. Namely, the primary employer (the staffing agency) is responsible for the provision of medical access and care through the workers’ compensation process, for example, while the host employer (the client) is in a position to respond directly to the event that occurred within their work environment, such as proper medical response and related communications.
As such, the client is also in a position to drive an effective incident investigation. After all, in many cases, the host employer is the first employer with knowledge of the injury to a temporary worker, creating a natural dependency on the part of the staffing agency for good communications to exist regarding their employee. Evidence of this collaboration between the employers is highly critical and may even become a part of OSHA’s investigation (if they are involved). But to be clear, both employers must work together to ensure that the needed medical care is provided to the employee(s) involved in the incident, that the incident is thoroughly investigated and that any necessary countermeasures are implemented in order to avoid similar outcomes in the future.
While all of that is still fresh in your mind, let’s cover some of the basics and best practices when it comes to incident management, specifically in the context of a joint-employer environment.
Ensure your teams are trained in basic emergency response and life safety, especially as they relate to the use of hazardous chemicals, equipment shut-off, emergency evacuation routes and any life-saving personal protective equipment that may be necessary
- Train your site teams and supervisors to know how to assess an injury scene for their safety as well as the safety of others, including:
- when/how to notify 911 and Emergency Management System (EMS)
- escalation process around who to call for ongoing developments such as hazardous chemical spills, equipment damage, hazardous energy management and facilities support
- Assess the situation, providing necessary first aid as trained and arranging prompt medical care.
The reporting process must be timely. Simply put, you must report the injury when it occurs
- Establish the process and ensure it is understood between both employers.
- Clarify points of contact (and backups) for each company as it relates to a report of injury for a temporary worker.
- Consider communication needs for after hours, such as second or third shifts, holidays and weekends.
- Confirm medical providers and transportation arrangements in non-emergency situations.
Gather all of the facts
- Conduct your fact-finding as close as possible to the time of incident. This helps prevent pertinent information from getting “stale.”
- Include the workforce in a team environment and learning process.
- Obtain statements from eyewitnesses and those within earshot of the event.
- Speak to employees in areas adjacent to the event.
- Leverage video/CCTV and access-control systems (if available) to confirm what occurred from a visual standpoint, as well as to establish timelines of factors and conditions preceding the event.
- If equipment is involved, observe for proper functioning or signs of failure.
- Secure equipment from use until it is cleared safe by the proper authority.
- Consider recreating the scene and walking through events for greater insight, but do not recreate actual hazards or conditions. We repeat: Do not do this!
- Discuss and gather recent maintenance records of relevant machinery.
Review and sharing all relevant facts with the team(s) involved
- In a joint-employer environment, this means both employers, with all necessary team members present.
- Ensure necessary countermeasures are in place to prevent future occurrences.
- Establish ongoing communications and follow-ups throughout the medical care of the employee.
- Respect the need for information that both employers need together and individually, without sharing unnecessary private information or information subject to HIPAA protections.
- Primary employer (the staffing company): As the employer on record to ensure medical care for their employee, the staffing agency needs records of training, work practices contributing to the medical event (chemical/solutions, type of energy, etc.) and supporting information to properly manage the claim. The staffing agency may also be in a position to identify a hazard or discover a report of injury before the host/client has knowledge of it. In such cases, it is imperative that the host employer be fully informed.
- Host employer (the client): The host employer needs information related to the extent of the injury and medical care in order to properly record on their OSHA log within the proper amount of time, if necessary (OSHA Recordkeeping Rule: 1904.7(a)), or even reporting to OSHA for serious injuries. As some injuries include days away from work, close communications and support from the staffing firm will support the host employer’s need for accuracy in their reporting.
Clearly, a collaborative and ongoing relationship between the two employers is necessary not only for effective risk management and safety practices, but to ensure effective medical care and reporting requirements are met. Injury management in a joint-employer environment adds to the complexity of an already highly regulated environment. Therefore, a well-informed and established process is especially key.
This is one area highlighted by OSHA in their Temporary Worker Initiative (TWI), which was designed to assist employers in understanding their individual requirements in this area. Take, for example, the subject of OSHA log management in a joint-employer environment. OSHA's TWI Bulletin #1 clarifies several important areas, such as which employer must place injured temporary workers on the OSHA log, and what constitutes “day-to-day supervision.” The matter of day-to-day supervision is particularly important, as it is how OSHA determines recordkeeping requirements in a joint-employer environment. According to OSHA’s Recordkeeping Rule in 29CFR 1904.31(a), as well as the OSHA FAQ 31-1, an employer is classified as performing day-to-day supervision when:
- in addition to specifying the output, product or result to be accomplished by the person’s work, the employer supervises the details, means, methods and processes by which the work is accomplished
- controls conditions presenting potential hazards
- directs workers' activities around, and exposure to, those hazards
In most cases, the host employer is providing the day-to-day supervision, and as such is responsible for management of the OSHA log. However, the staffing agency is in an important position to keep their client appropriately informed while contributing to both the incident management process as well as subsequent safety performance improvements. As it is well understood that knowledge of and proper investigation of workplace injuries leads to improved safety performance, the processes in place between joint employers need to be well established, reliable and integrated into a robust performance improvement system.
In addition to the recordkeeping bulletin referenced above, you should visit the OSHA website for temporary worker safety for more information on topics ranging from training to forklifts, hazard communications, respiratory protection, hearing protection and more. Note that OSHA’s Recommended Practices for Safety and Health also includes a section for Communication and Coordination for Host Employers, Contractors and Staffing Agencies, which should give employers further ideas for program evaluation and improvement.
total worker health — industrial hygiene and illness prevention
The unprecedented challenges created by the COVID-19 pandemic caught many organizations off guard. What’s more, many found themselves on unsure footing not only around injury prevention, but illness prevention as well. Perhaps the silver lining of this experience will be the creation of more widely recognized frameworks for understanding both injury and illness prevention, rather than focusing more on the physical injury aspect, as many organizations have in the past. In addition, a growing emphasis on the overall health of the workforce became paramount — the concept of “total worker health” — as we began to see greater integration of important areas such as wellness and mental health support.
In that vein, it is certainly interesting to consider how easily our former (pre-COVID) thinking often steered our chief risk and safety efforts to primarily focus on preventing physical injuries, such as those leading to OSHA-recordable and lost-time events. In other words, we focused on practices and communications to prevent physical injury, often with very little awareness of the biological risks that could lead to illness. The COVID-19 pandemic heightened the sense that a common framework was needed to develop risk controls and safety practices — between both employers in joint-employer environments — that can effectively combat both physical and operational risks, as well as risks in the work environment that can lead to illness.
While 2020 was a year where industry was challenged like never before in the realm of occupational health and safety and illness prevention, Randstad teams united to lead both our company and industry in a common framework to better enable risk identification, risk decision-making and problem-solving through a framework for both injury and illness management. In fact, our approach, which we developed through the lens of the hierarchy of controls (chapter 4), was adopted by 24 countries through our alliance with the World Employment Confederation. This work created a much-needed forum for leading risk management practices, guiding employers in an important common framework (and safety language) early in the pandemic. This should continue to serve as a silver lining of the pandemic as it models advanced risk-based thinking for employers going forward.
2021 and momentum: filling our sails with the “leadership updraft”
The pandemic created a new sense of urgency and momentum: Where standard safety communications had often been conducted on a cadence set by regulatory requirements and post-incident (injury) data, senior leaders began reaching down into the organization to better answer the question, “What are the things we should do in order to create safe working environments?”
Meanwhile, the top organizations were literally asking, “Is there a common framework for focused risk and safety communications to guide us through this pandemic?” We call all of this the “leadership updraft” created by the pandemic, which almost overnight transformed the way business leaders understand risk-based thinking and decision-making. It has enabled more appropriate planning for resources and workplace design ranging from basic hygiene to sanitation, corporate guidance, communications and even structural changes to the workplace (such as engineering controls and new technology). Clearly, senior leaders needed to gain as accurate a view as possible related to their acceptable risk tolerance.
As these leaders balanced the costs and risks of keeping their operations and workforces going alongside the skyrocketing and unplanned safety costs brought on by the pandemic, this "leadership updraft" streamlined the flow of vital business information between field operations and the C-suite. What’s more, the rapidly evolving environment — in which only highly accurate information could be relied upon to support strategic decision-making — effectively guarded against “stale” information, too.
At Randstad, our leadership teams asked early on, “How do we best identify risks and enable safe decisions in order to safely conduct business?”
Part of the discussion was considering business and economic risks together with health and safety. From there, we led the way to create a framework — and invited others to follow. Why do we see this phenomenon of leadership updraft as such an important cultural signal — something to pay attention to, and an opportunity to embrace?
For starters, we serve what many globally recognized safety institutions, including ASSP and NIOSH, consider to be a “vulnerable workforce” (e.g., contingent workers, young/aging workers, people of color). There is overwhelming evidence that injuries and illness occur to temporary workers at a rate higher than their counterparts working in similar jobs within traditional employment arrangements. So our core values guided us toward the simultaneous promotion of all interests, understanding that how well we do safety impacts our employees, our clients’ businesses and society as a whole.
Of course, striving to actively create safer work environments requires having an accurate understanding of risk specific to your organization. The hierarchy of controls (chapter four) is a globally shared best practice and among the most common frameworks — it’s a good starting point for understanding how risks lead to physical injury as well as illness. Furthermore, as risk changes and fluctuates quickly, it’s important that organizations embrace the idea that risk is a continuum. As such, evaluating risk must be an ongoing process of monitoring and assessment, and one that involves all relevant stakeholders.
When thinking of occupational safety, it’s important we think of it in terms of what can impact the body directly by force, as well as what can harm the body through environmental and related exposures, such as a chemical that is absorbed through the skin, causing harm or illness to any degree. Airborne exposures, whether COVID-19 or flu- or chemical-based, also fit into this category. According to the American Industrial Hygiene Association, the term “industrial hygiene” is defined as “a science and art devoted to the anticipation, recognition, evaluation, control and confirmation of protection from those environmental factors or stresses arising in or from the workplace which may cause sickness, impaired health and well-being, or significant discomfort among workers or among citizens of the community.”
If this definition sounds familiar, it should. In fact, it recalls what NIOSH describes as “total worker health,” which is simply defined as ”policies, programs and practices that integrate protection from work-related safety and health hazards with promotion of injury- and illness-prevention efforts to advance worker well-being.”
So we should be encouraged that the same frameworks we discussed earlier for assessing risk (hierarchy of controls, chapter four) as well as the basic elements for safety management (safety management systems, chapter three), which emphasize essential elements of safety management such as leader/worker participation, planning for risk assessment and designing out hazards are compatible and in harmony with the approach to total worker health.
Safety-related work in the area of joint employers has already benefited many employers, staffing companies as well as their clients, guiding them toward a better future state for both injury and illness prevention. Let’s take a look at a few of the more common areas related to industrial hygiene and illness prevention outlined below.
hazard communication (29 CFR 1910.1200(e))
This is “the right to know and understand” hazardous chemicals in the workplace where a worker may be exposed. It is important to understand that this risk category for chemicals is especially important, as chemicals have enormous potential to cause harm, both directly (physical contact) and indirectly (exposures). For example, if a liquid compound leaks from its container where it is normally safely stored, it can change properties to an airborne exposure, thus requiring certain emergency precautions. Onsite workers must know about those precautions, even if those employees (such as temporary workers) are not directly responsible for a hazardous spill cleanup. The hazard communication standard should be well understood by the staffing company as well as the host employer, but here are a few basic practices to consider in this area of risk:
- Both the staffing agency and host employer are responsible for ensuring all employees potentially affected by hazardous chemicals are appropriately trained.
- Training must be completed before the worker begins their assignment and before a new chemical is introduced into the workplace.
- Training must be in a language the worker understands, and as robust for temporary employees as it is for those employed in traditional work arrangements (host employer’s workers).
The host employer has primary responsibility for site-specific hazard communication, information and training, including a written HCS program, appropriate labeling of chemical containers, safety data sheet management and providing appropriate PPE.
- The staffing agency has a duty to inquire and verify the host employer has fulfilled the requirements of their Hazard Communications Program as it relates to the work assignment at the host employer. At a minimum, that means providing generic hazard communications to explain basic requirements in different occupational settings that workers may encounter. Additionally, there are basic, but nonetheless critical, concepts and information that the staffing agency must inform and train temporary workers on:
- Topics such as proper labeling, safety data sheets and related information should give the worker a basic ability to identify a hazardous chemical.
- Staffing agencies should also ensure that employees understand their “right to know and understand” the hazardous chemicals that are present in their work environment.
It’s important to note that the staffing agency’s duty to inquire and verify in this sense, while related to hazard communications broadly, is also applicable across all potential hazards specific to the host employer’s worksite. OSHA has made this very clear: Ignorance of hazards is not an excuse. You can find out more about the Hazard Communications Standard specific to a joint-employer environment in OSHA’s Bulletin #5: Hazard Communications.
respiratory protection (29 CFR 1910.134)
Respirators are designed to protect a worker from harmful air contaminants. Fumes, gases, vapors and even dust can be harmful by-products of work processes, as well as unexpected releases of these contaminants in the air such as when two liquid chemicals accidentally leak from their containers and mix, releasing the harmful substances into the air breathed by employees. Whether a by-product of work or unexpected exposure, employees need to be trained on what to do and how to respond. An additional but no less critical factor is that a respiratory control program requires medical oversight, and while this can be managed in a joint-employer environment, both employers must be fully apprised of, and in agreement with, the type of work and correct PPE (respirator) used by temporary workers. Respirator use, requirements and protection must be well understood by the staffing company as well as the host employer, but here are a few basic practices to consider in this area of risk:
- Both the staffing agency and host employer are responsible for ensuring that any employee potentially affected by respiratory hazards:
- completes training before the worker begins their assignment and before a new chemical is introduced into the workplace
- receives training in a language the worker understands, and that training is as robust for temporary workers as the training provided to employees in more traditional work arrangements (host employer's workers)
- understands the extensive list of critical requirements around the regulations briefly outlined below (for a more detailed review, reference OSHA TWI #8 for Respiratory Protection):
- a written respiratory protection program that includes worksite-specific procedures and elements for respirator use
- correct type of respirator based on the respiratory hazards to which the worker is exposed and other workplace and user factors (e.g., filtering facepiece), reusable (e.g., half-mask and full-face elastomeric), powered air purifying (PAPR), self-contained breathing apparatus (SCBA) or supplied air respirators (SARs)
- medical evaluations and oversight as appropriate based on exposure
- respirator fit-testing
- proper use of respirators in routine and reasonably foreseeable emergency situations
- maintenance and care of respirators
- adequate air quality, quantity and flow of breathing air for atmosphere-supplying respirators
- training of employees required to wear respirators
- recordkeeping of the medical evaluation, fit-testing, training and written respirator program
- evaluation of the program
- Both employers (host and staffing agency) that do allow voluntary use of respirators must ensure the employee is medically able to use the respirator and does not present a health hazard.
- Provide the employee a copy of Appendix D from the Respiratory Protection standard. Coordination between joint employers is essential for this provision.
Host employer: This employer is primarily responsible for the creation of the work itself, and with any related exposures and risks from the work practices and chemicals used or produced by this work. The host employer usually has primary responsibility for the evaluation of the exposure levels and related controls. Program implementation, surveillance of work conditions and program re-evaluation are also closely aligned with requirements for the host employer.
Staffing agency: This employer has a duty to inquire and verify that the host employer has fulfilled the requirements of their Respiratory Protection Program as it relates to the work assignment at the host employer. This includes:
- awareness of the respiratory hazards employees may be exposed to
- protective measures that should be in place at the host employer, and whether or not they have been implemented
- additional related requirements, such as cleaning, medical oversight, record retention and program evaluation
The staffing agency is also identified by OSHA as in position to maintain communications with its workers as well as the host employer as it relates to safe work practices and adherence to the Respiratory Protection Program at the host employer's site. For additional information and scenarios related to a joint-employer environment, review OSHA TWI Bulletin #8.
noise exposure and hearing conservation (29 CFR 1910.95)
Exposures to high levels of noise can cause loss of hearing, and while this risk is initially thought of in the obvious physical sense, damage caused by excessive noise can range from short-term medical conditions, such as tinnitus (ringing in the ears), to long-term medical complications like hearing loss and other impairments. As with the previous areas related to industrial hygiene in a joint-employer work environment, both employers play a role in terms of preventing harm and ensuring the right safety programs are in place to manage these risks.
- OSHA’s legal limits for noise exposure should be known and understood by both employers. Per OSHA, this is based on the TWA (time-weighted average) over a worker's eight-hour day, with the permissible exposure limit (PEL) during this period being 90 dBA (decibel: A-weighted sound level). While the host employer is usually in a position to determine if these conditions exist in the workplace, the staffing agency should be informed enough to inquire and verify about these hazards and related requirements about the host employer's Hearing Conservation Program (HCP) and how it affects the workforce. Ignorance of hazards is not an excuse for either employer, and both employers must be well grounded in terms of what is required specific to their role. What both employers should know is also described in the OSHA TWI Bullet #9 — below is a brief outline for each employer to understand and follow.
- Host employer: This employer’s primary responsibility is determining noise exposure levels, developing and maintaining written programs as required, and implementing engineering, administrative and work practice controls specific to the type and levels of noise exposure in their work environment. In addition, they are tasked with ensuring appropriate surveillance of workplace conditions along with compliance with the Hearing Conservation Program.
- Staffing Agency: This employer shares responsibility in knowing the noise hazards and related controls outlined in the host employer's Hearing Conservation Program. Through their duty to inquire and verify, this employer should also take reasonable steps to ensure the host employer’s HCP covers temporary workers in the same manner as the client’s traditionally employed workforce.
- Maintain communications with temporary workers and the host employer to ensure compliance with the HCP, in addition to monitoring any new risks or hazards.
- Joint Responsibility per the Occupational Noises Standard (29 CFR 1910.95(g)(5)(i)(ii): In working environments where a baseline audiogram is required, this baseline audiogram must be conducted within six months of an employee’s first exposure, with hearing protection used during the interim.
- This should be carefully discussed with leadership of both employers, as temporary workers may be assigned to several different employers for shorter durations during this six-month period.
As with respiratory protection, there is a degree of medical program oversight with a Hearing Conservation Program in addition to regulatory and compliance requirements. For deeper insights and a review of related scenarios on this subject, reference the OSHA TWI Bullet #9 for Noise Exposure and Hearing Conservation.
The anticipation, recognition, evaluation and control that can lead to injury or illness, sickness, impaired health and well-being is a broad subject, all of which fall beneath the umbrella of industrial hygiene. Other subjects also fall within this category, such as blood-borne pathogens as well as adjacent categories in safety/health training and personal protective equipment. While it is not imperative to be an expert in every subject in this realm, it is important to be well versed in what is required as it relates to industry-specific risks and work practices performed by your employees, no matter if they are temporary employees or in traditional employment arrangements.
Ultimately, total worker health should be approached as a mindset, a way of thinking about risk as it relates to physical injury, illness and even emotional or mental health. For example, the newly released ISO 45003 standard addresses psychosocial risk and harmonizes with other safety management systems to address psychological safety in the workplace. Taking another silver lining away from COVID-19, too, we can begin to see how our collective countermeasures and safety practices correlated to dramatically lower levels of flu-related illnesses, hospitalizations and deaths. This, according to the 2020-21 Flu Season Summary by the CDC, should serve as a powerful highlight of the benefits that come from having shared frameworks for understanding risks and practicing better safety.
Similarly, think of how quickly technology replaced well-worn and time-trusted practices: Holding a menu at a restaurant, for example, was phased out when it became clear how easily this could be done via smartphone. Reducing touch rates on highly transmissible surfaces like menus led to lower transmission rates for other risks, such as the flu. This is not only good news, but a terrific example of the concept of substitution in the hierarchy of controls (chapter four) — substituting an established method that is a higher risk with a lower-risk option to achieve the same result.
With that in mind, one of the key takeaways seems to be: Look at how quickly and effectively we can solve problems when we all focus on solving them together.
a new view toward preventing serious injury & fatality (SIF)
Traditional practices of measuring safety performance merely by the absence of incidents, rather than the presence of the activities needed to make us safe, is a broken concept. Best-in-class employers have journeyed past this “old view” (or are beginning to), but it is important for employers in shared working communities, such as the contingent labor industry, to do so as well. While it is true that closely monitoring loss data and injury experience are useful from the standpoint of showing loss history (what happened and when), they do very little to inform leaders on why things are happening, or how that relates to risk levels throughout the lifecycle of a work engagement.
The other challenge with the old view is the overreliance on injury and illness data to inform us of the current state of risk, or answer the question, “Is our current state of risk acceptable today?” After all, a majority of catastrophic incidents have occurred at workplaces with historically low incident rates, and this is consistent across industries. While injury and illness data can tell us what happened and how many times, it cannot tell us if current risk levels are acceptable in order to safely continue work. This is why we should not assume that the absence of injury or incident events equates to the absence of risk (or, presence of safety) in the work environment. Finally, it’s important to realize that while safety efforts over the past few decades have made progress toward reducing minor incidents and injuries, overall fatality rates plateaued long ago — and in some cases, in fact, they are even increasing, as confirmed by data from the Bureau of Labor Statistics’ National Census of Fatal Occupational Injuries, which shows that 2019 had the largest number of fatalities since 2007.
Today’s state of safety and health is no longer based on the absence of injuries or illnesses as an indicator of safety performance, but rather on an organization's ability to continually monitor and assess the current state of risk. In this way, it is a natural extension of organizational leadership, technology and system resources that continually monitor and inform alongside those closest to the risk to enable proper interventions and decision-making.
This recognizes that health and safety are properties of the system itself, and outcomes of the system, too. They arise from the interaction of the parts, people, management methods, hazard controls, tools/equipment, production pressures as well as the climate and culture within that system. This is a completely different view of how to establish safe working conditions and leads to a better understanding of why SIF events occur within a working system. In Advanced Safety Management: Focusing on Serious Injury Prevention, Fred Manuele, a board-certified safety professional, engineer and author, described these system connections to SIF events as “multiple and complex,” and having “organizational, technical, operational or cultural origins.” Adding another employer into the working environment, such as a staffing agency, where we see both shared responsibility for safety yet with distinctly different roles, we multiply these complexities to that management system in areas like critical-risk identification and communications leading to hazard abatement. As such, employers should integrate this knowledge into their safety management systems.
This proves especially important in joint-employer environments where multiple management systems all have a role in worker safety — and are interdependent parts of the safety management systems — while having varying degrees of influence. This is a complex system that understands that workers are influenced by system events surrounding the employees, and not in an oversimplified linear fashion. For example, the most recent thing that happened right before the incident is rarely the source of the problem, yet is often held to be the root cause, prompting an intense focus on what occurred immediately before the event and often overprescribing training or disciplinary measures as the solution.
In reality, deviations from safe work practices occur deeper within the system. They are linked to system weaknesses, latent conditions, flawed processes, hazards, safety-specific deficiencies and other factors. That’s why the interrelated aspects of safety management systems should be getting the attention of joint employers who are in the best position to address these system deficiencies. Employers who still view the employee as the “problem” to solve and the reason why accidents happen are missing the opportunity to address critical risk multipliers in the business of joint-employer safety management. These risk multipliers, such as leadership turnover within safety-sensitive areas, magnify risk within the work environment. When that happens, it should be understood by both employers that they need to manage and communicate with one another accordingly. The visual references below are often helpful as employers begin discussions about staying connected with risks experienced by the workforce and doing so throughout the continuum of risk and work projects through design and planning:
Similarly, each employer viewing team development factors, such as the ones outlined below, are making progress in areas of prevention for SIF events:
View of the worker: critical part of solution toward a safe and inclusive workforce
- Includes temporary workers, part-time, seasonal and even volunteers
View from leadership: to create and enable reliability in the systems that connect the corporate and operational ends
- Manages the gap between “work as we imagine” (corporate) and “work as completed” (workers)
View of human error: the starting point toward understanding why error occurs
- This view guards against the common assumption of employee error as the cause of safety incidents. This assumption is the greatest obstacle toward better system understanding and blocks necessary system improvements.
This approach to safety is much more focused on what goes well, and why, than “Who causes all the accidents?” As a safety practice and methodology (as opposed to only investigating when things go wrong), it provides much more revealing insight into what is needed to safeguard the things for work to be done well (safely). It’s also especially effective at calling attention to underlying causes and gaps that ultimately lead to that one injury or incident everyone is trying to avoid. And this is most often where we discover these small, cumulative gaps in system controls that often culminate into the worst form of injuries — those causing SIF events.
It is within the working systems itself that we find what we call “risk multipliers,” which are conditions that may be tied to the safety climate/culture, management practices or even perceptions of how work should be completed based on experiences from previous employers. These are both physical and operational circumstances as well as the unique risks and vulnerabilities specific to the contingent labor workforce that create risk multipliers in and of themselves. These risk multipliers specific to contingent labor (outlined below) have powerful, cultural implications, and better understanding should be sought collaboratively among both employers in joint-employer environments.
- Low risk perception: “How can I get hurt performing this task?”
- Contingent workers may have a lower understanding in this area as compared to employees in traditional working arrangements.
- Increased risk tolerance: “I’m willing to do more than I should for reasons that make sense …”
- Gain an opportunity (extend an assignment or become a permanent employee).
- Avoid a perceived negative, such as assuming more risk than acceptable if requested by a supervisor — and being a “team player,” rather than saying “no.”
- Complete lack of awareness of risk: Areas such as lockout/tagout, machinery safety, confined space, electrical and falls from height are just a few critical areas where more risk is assumed based on sincere lack of knowledge.
- Diminished upward communications: “I’m not likely to raise my hand and inform others of a safety concern, due to …”
- lack of knowledge
- fear of losing assignment or related negative repercussions
- lack of an established mechanism to enable critical safety communications
As described in previous chapters, elements of safety management systems such as planning can help identify methods to attack and reduce these risk multipliers in a joint-employer environment. Regarding SIF events, it's not that employers keep getting surprised by things they are not able to anticipate. One could even make a strong argument that when we investigate why and how a serious injury occurred, we’re not surprised it happened given the circumstances that are presented. Rather, we’re often left with the perception “Why didn’t we see that sooner?” or “Why didn’t the workers say something?” This represents a disconnect from the needed risk controls and management methods specific to the unique risks and multipliers experienced by the workforce. Needed risk controls and interventions within that system are missing. Why? Because that system is not fully understood. Fortunately, this can be improved and enabled by organizational leadership.
The figure below outlines SIF categories alongside some of these unique risk multipliers in a joint-employer environment, along with basic guidance that is firmly aligned with elements of safety management systems and the hierarchy of controls addressed in previous chapters.
Adopting a new view toward safety and better practices toward preventing SIF events may be new for some employers, but it has been successfully tested and implemented in areas as diverse as the U.S. Department of Energy, the field of aviation — and many others around the world. What’s important for us in the U.S. is to understand that many of our safety programs have been based on reducing our minor or moderate injuries (and thereby driving down OSHA recordable rates) with the assumption that doing so will also improve outcomes in severity. After all, we’ve advanced far enough in the past few decades to remember what Dan Petersen said, in his book on safety management (second edition), when it comes to SIF events: “There are a different set of circumstances surrounding severity …”
So when it comes to managing risks that are capable of causing SIF events in a joint-employer work environment, it’s important now more than ever for employers to grow into their next level of safety maturity. Above all, that will require collaboration and a new view of greater capabilities through effective safety management systems.
best-in-class safety committees
Perhaps no other term in industrial organizations has stirred up such mixed and conflicting opinions as “safety committee.” It is a sad fact that many safety committees have become more of a donut-hub and reluctant social setting, having failed to meet their established purpose of contributing to the creation of safer work environments. One thing, however, remains fundamentally true: Where better business and safety performance is an expected norm, safety committees are made to work.
In a joint-employer environment, this requires contributions from both employers, completely in line with a higher-level safety management systems approach (chapter three).
In the context of fast-paced industrial work environments, it can be easy to forget how quickly risk can change, and that to effectively assess and monitor risk requires a connected system from the top down as well as end to end among all employers involved.
An effective safety committee is a chance to bring leadership together with team members from diverse areas of your organization, not only to define and ensure progress toward stated goals, but to continually ask a few critical questions that should drive immediate engagement as well as ongoing action:
Does the workforce have what they need to ensure safe work is performed?
- Clearly define job descriptions, standard work and tools and safety equipment.
- Establish escalations to support systems, empowering workers to stop when confronted with new risks or uncertainty.
Is work happening like we think it is?
- Is there evidence of on-the-fly problem-solving by workers in order to accomplish work? Where should employee solutions be operationalized? Where is "on-the-fly" problem-solving creating risk?
- Are we engaging the workers to understand where work is challenging: tendencies for shortcuts to meet production, lack of clarity, conflicting work instructions?
- What is telling us what we think we know about safety besides injury numbers?
- If low injuries: What is informing us of actual levels of risk?
- If injury experience is increasing: Do we understand system influences of the event end-to-end?
- Are we connecting both items to organizational learning and improvement within the workforce?
The above questions are also more closely related to elements of human and organizational performance, yet expressed in a collective and established learning team. Below are ingredients of best-in-class safety committee programs for you to integrate and leverage into your own workforce. The good news is that these can be implemented or strengthened no matter where you are in your current level of safety maturity.
Include representatives from all departments and shifts at your organization. Consistent with a safety management system approach, evaluate your stakeholders and include those who are a part of your workforce and supply chain, such as contractors, temporary workers and seasonal workers, together with members of leadership.
What common goal is everyone working toward? Benchmark progress based on clarifying actual levels of risk, especially as it relates to SIF events and the specific activities that enable safe work around those areas of risk. Teach your learning teams and safety groups about the hierarchy of controls, gaining an understanding of controlling risk at the highest possible levels.
support and other resources
This includes leadership support, “tone from the top” and the time, training and tools to enable the active assessment of risk and solutions in the work environment.
learning opportunities and agenda
Consider starting by leveraging learning among the safety committee. What is the team learning? These and related stories can be powerful tools for engagement. Including an established agenda to cover, along with minutes/notes from previous meetings, can help keep the team focused and should relate to the purpose of the team and the goals being pursued.
Everyone on the safety team should be aligned on the cadence of meetings that's appropriate for your organization. In the event that absences become an issue, first speak to the party in question privately to learn about any obstacles or concerns and work together to solve them.
tracking and monitoring
End each meeting with concrete goals with defined steps toward measured progress toward the next meeting. Leaders should leverage the art of "frequent and positive" follow-up between the formalized meetings as an ongoing act of discovery and support.
All members of your safety committee need to feel comfortable speaking as they learn the art of the “safety conversation.” Recognize that continual learning applies to everyone, and one purpose of the safety team is to promote organizational learning, part of which comes through establishing trust and openness when it comes to talking about safety matters.
Connecting progress to senior leaders and developing a shared, organizational communications process will highlight progress as well as establish transparency around problems the organization is working to solve, allowing for feedback and ideas from the entire workforce.
Finally, keep in mind that it's still possible to have fun — in fact, that three-letter word can be what differentiates organizations that succeed with safety from those that don't. Strive to maintain a positive tone throughout the course of your safety committee meetings, keeping in mind, too, that even short-term wins deserve to be commemorated and shared.
the importance of onboarding
onboarding's essential role
Training your employees to develop competency in safety knowledge and skills is essential for safety culture advancement — and an integral, yet often overlooked, part of that is onboarding.
Why is onboarding so important to safety outcomes? What can you do to make improvements? And what does it take to achieve best-in-class status? In this chapter, we'll answer these questions and more.
breaking down the data: the state of onboarding today
Let's start with the current state of onboarding at manufacturing and logistics companies today, drawing on insights from Randstad's survey of more than 1,000 managers and employees.
What are the most common onboarding practices at manufacturing and logistics companies today?
- 55% online learning modules
- 54% educational videos
- 52% new-hire checklist
- 43% mentoring
- 41% job shadowing
- 27% self-directed research
At first blush, this picture of current onboarding practices looks promising. For example, the data suggests that manufacturing and logistics companies are not only investing in new onboarding tools, but continually upgrading and improving their offerings, too.
Equally encouraging are the 69 percent of managers who say their companies either "always" or "very often" provide training or development opportunities for employees to learn new skills specific to their roles. That's good news, given that role-specific training is an OSHA-recommended safety practice and a key part of any effective safety program. And in a seemingly related finding, managers in manufacturing and logistics are more likely than their counterparts in all other industries to describe employees as "continuously" taking advantage of opportunities to gain new skills at work. That's a very positive sign of alignment between what manufacturing and logistics companies are offering and what their employees want.
Less encouraging, on the other hand, is that a whopping 32 percent of the talent surveyed revealed that they had received no onboarding at all. Given that only about half of our clients, according to our research, are using that most basic of onboarding tools — a new-hire checklist — it's clear that there's plenty of room for improvement. Formalizing new-hire onboarding with a checklist not only helps managers and HR streamline and standardize the process, but also sets the stage for better relationships between coworkers.
The first few days of employment can determine whether the investment in a new hire does — or does not — pay off.
These checklists also serve as key risk-management tools, enabling employers to systematically set and manage expectations on all things safety, like machine-specific training. Without them, how can you ensure that you're delivering a standardized onboarding experience and creating a common base of knowledge around safety and operations for all new hires?
The simple answer is: You can't.
Moreover, new-hire checklists have been shown to help get new hires up to speed as much as 25 percent faster, so the business case for implementing them at your worksite should be fairly cut and dry. And as an added bonus, by implementing checklists, you'll also gain the ability to review processes far more objectively when things go wrong.
Finally, the fact that self-directed research is a component of onboarding at more than a quarter of manufacturing and logistics companies right now should raise some eyebrows (and not least because it sounds like a euphemism for "You're on your own now, buddy!"). Most fundamentally, the problem is that, whatever form this research takes, it can't be effectively or safely brought to bear on day-to-day floor operations unless everyone else on the team is in the loop. In light of the close connection between onboarding and on-the-job safety — which is more pronounced in manufacturing and logistics than in most other industries — this is a worrying finding, indeed.
onboarding in safety training: key takeaways
When approached holistically, onboarding is about more than just what happens when new hires show up at your plant or warehouse. That's when the process formally kicks into gear, of course, but ultimately, the scope and goals of your onboarding process should be much broader, with downstream impacts across the full employee life cycle.
safety management in a joint-employer environment: opportunity for better business outcomes
Risk management is getting increasingly complex today, as recent trends — most notably, the proliferation of the gig economy and a greater reliance on contract workers — reshape the future of work before our very eyes.
With so much in flux, leading companies are increasingly turning to staffing partners to solve their most critical talent pain points. In part, that's because staffing partners can help companies better manage a wide range of risks — everything from business interruptions to accidents, compliance and more — that impact their bottom lines.
Of course, that impacts risk as well.
So how should manufacturing and logistics companies evaluate potential partners from the standpoint of risk and safety? Moreover, once a partner has been selected, what's the best approach in order to ensure successful implementation on the ground?
In this chapter, we'll be answering these questions and more — so you can overcome a bevy of risks that might otherwise derail your business in joint-employer environments.
essential criteria for evaluating potential partners
Working with the right staffing partner brings with it a host of benefits for manufacturing and logistics companies. But to see those benefits, you'll need to take an end-to-end view of safety and risk — and that begins with your approach to evaluating partners.
Here are some key questions — organized around core elements of Prevention Through Design (PTD) and risk control — that are crucial to consider when evaluating any potential staffing provider.
goals and expectations
- Start by looking at the procurement process. How is it incentivized internally? For example, is performance tied to the success and capabilities of recommended vendors, or does "successful procurement" just mean securing the lowest possible cost? Clearly defined goals and shared expectations are cornerstones of successful partnerships — and when it comes to managing risk, you can't afford to let the procurement process be disconnected from safety goals.
- Consider the performance metrics that matter to you, whether that means risk identification and communication, incident and injury reduction or candidate quality, wages and rates. How will these metrics be reinforced through specific interventions, such as risk assessments, site evaluations, training and communication?
- What will be the touchpoints between your organization and your staffing partner to ensure the success of your efforts? Leaders in risk-based thinking recognize that it's easy to drift from good intentions — and that's why defining and guarding these touchpoints is so critical.
- What site-specific information must be communicated? What follow-up methods will be used to verify retention of critical safety knowledge?
- Studies show that contingent workers can have lower risk awareness and be at greater risk of injury when conducting the same job activities as their full-time peers. So what hazards critical to safety — for instance, life safety, equipment safety or chemical safety — must be communicated to them? What serious injury or fatality exposures must be communicated? What follow-up methods will be used to confirm that key safety knowledge is not only being retained, but practiced every day on the job?
- What hazards are the most critical to safety outcomes at your worksite? See Appendix 2 of OSHA's guide to job hazard analysis if you need help classifying these hazards.
- How will frontline supervisors be trained to communicate safety and manage your temporary and contingent workforce? How will they manage workers' tendencies to do more than assignments require? Can they limit access to machinery, equipment, ladders and other high-risk processes? Are there opportunities to control the work environment during high-risk, nonstandard work, such as equipment changeovers or sanitation tasks?
- How will assignments be managed? What escalation and approval processes should be in place in the event that you or your staffing partner needs to alter assignments?
- Can peer-to-peer knowledge be leveraged to enhance problem-solving, improve processes and uncover solutions? If so, what role should frontline supervisors play?
These questions should help you not only evaluate vendors more rigorously, but also begin to think through what implementation looks like on the ground. In the next section, we'll break down a framework to help you do so. By taking a structured approach, you'll be far better equipped to manage actions, timelines and expectations down the line.
the continual improvement cycle: plan, do, check, act
The occupational health and safety (OH&S) management system ISO-45001 is an international standard and framework to help companies, regardless of industry, proactively manage risk in order to prevent work-related injuries and illness for employees. One central piece of the ISO framework is the Plan-Do-Check-Act (PDCA) cycle, which has proven especially valuable in the context of joint-employer environments.
To help you out, let's look at how some best-in-class manufacturing and logistics companies have put the PDCA cycle into action today in order to more effectively manage staffing partners and drive business outcomes.
- Establish key touchpoints, as well as a meeting cadence — say, monthly, quarterly or annually — for senior leadership to review goals, risks and progress.
- Define the factors that are critical to worker safety in your joint-employer environment, and implement ongoing injury-prevention activities to address them.
- Identify metrics and leading indicators — for example, the number of trainings or safety interventions during a given time frame — that matter the most to your organization.
- Ensure completion of all items identified during the "plan" phase.
- Record any successes, areas for improvement and course corrections related to your safety-planning activities. You should also be sure to record peripheral activities — such as near hits, root cause evaluations, compliance activities and creative items, like surveys from employees or frontline supervisors.
- Document who — between the primary and host employer — owns each component of safety planning and preparation, with clearly established action items and target completion dates in place to keep everyone on track. This ensures all parties follow through and helps safeguard against potential process breakdowns.
- Test the reliability of existing systems, including hazard identification, reporting, audit processes and safety committee communications, in order to mitigate potential drift.
- Manage and communicate changes on an ongoing basis.
- Understand deviations from planned safety methods and expectations.
- Ensure all team members — especially new(er) employees — understand not only the overarching goals, but why taking a proactive approach to safety is such an urgent priority.
- Identify and ensure resolution of any escalations related to items critical to safety.
- Communicate risks through an established hierarchy of leadership and controls.
- Celebrate wins, and be sure to communicate risks removed — as well as big-picture goals for the future.
- Ensure all items identified during the "check" phase are built into the next planning cycle.
By taking this structured approach, you and your staffing partner can ensure alignment and continually make progress toward your goals. With proper goal setting, clearly defined expectations and an established communication cadence, the journey to best-in-class should be within reach. And as you work in that direction, the PDCA process should serve as a simple yet powerful tool to keep you and your partner on track.
Staffing partners bring considerable value and benefits to manufacturing and logistics companies today — but realizing all of those benefits isn't always easy. And when primary and host employers aren't aligned on the management of current and future risks, the costs and drawbacks can quickly add up.
For these reasons and more, building a strong joint-employer environment starts early. You just need to ask the right questions when evaluating potential staffing partners, then adopt a structured approach to implementation.
Now that you're armed with these insights, you should be able to not only approach staffing partners with confidence, but ultimately uncover opportunities to drive your business forward — while continually improving, assessing and managing risk with your staffing partner.
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