Occupational Safety and Health Management System ...

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State 24

ISSN 1000 7924 The Journal of the Association of Professional Engineers of Trinidad and Tobago Vol.44, No.2, October/November 2016, pp.24-34

Occupational Safety and Health Management System Implementation Metrics: Results of a Survey of Manufacturing Companies in a Small Island Developing State Marcia Nathai-Balkissoon Department of Management Studies, The University of the West Indies, St. Augustine, Trinidad and Tobago, West Indies; E-mail: [email protected]

(Received 30 September 2016; Revised 14 October 2016; Accepted 17 October 2016)

Abstract: Occupational safety and health (OSH) emerged as a field of practice in the 1800s, as workplace safety challenges became exacerbated during the Industrial Revolution. Following a series of United Kingdom Factory Acts starting in the 1800s, the United Kingdom and the United States developed OSH legislation in the 1970s, mandating OSH management system (OSHMS) development within factory operations. In Trinidad and Tobago, a small island developing state (SIDS) in the Caribbean region, a diversification thrust is currently challenging the manufacturing sector to produce faster and in greater quantities, despite resource constraints like human resource availability and capacity. Increased OSH-related risks and costs in manufacturing are likely, making OSHMS development more critical. Although T&T’s OSH legislation was proclaimed in 2004, few statistics about manufacturers’ OSH compliance have been published to date. This study therefore investigated the extent of OSHMS implementation in T&T manufacturing companies in alignment with the country’s OSH Act. A survey was developed and validated for gathering self-reports on implementation of 22 OSHMS elements in companies across 6 manufacturing sub-sectors. Demographic data and general opinions about OSH were also sought. Descriptive statistics and correlation analyses were used to assess OSH perceptions and practices, element implementation, and element inter-relationships. The study found that 9 elements were well-implemented and 13 were under-implemented. Notably, some of the under-implemented elements (e.g. risk assessments, safeguarding, and accident reporting and investigation) were OSH Act mandates. Correlations were also found between certain elements (namely employee participation, top management commitment, dedicated safety practitioner, and continual improvement focus) that influence OSHMS development. Implications of the findings and prospects for the way forward are also discussed. Keywords: OSHA; OSHMS; OSH Act; manufacturing sector; diversification, Caribbean, Trinidad and Tobago

1. Introduction Occupational safety and health (OSH) emerged as a field of practice in the 1800s, around the time when the Industrial Revolution brought about exacerbated workplace safety challenges (Humphries 2010; Trueman 2015). Following Factory Acts starting in the 1800s, the United Kingdom (UK) and the United States (US) developed OSH legislation in the 1970s, mandating OSH management system (OSHMS) development within factory operations (Fleming 2001). As a British colony, Trinidad and Tobago’s (T&T) legislation was aligned with that of Britain, so its major occupational safety legislation was a Factories Act. More modern OSH legislation came into effect in 2004, and is commonly referred to as “The Occupational Safety and Health Act of Trinidad and Tobago (2004) as amended (2006)”. This OSH Act recommends development of safe systems to reduce risk to levels as low as reasonably practicable for employees and others (GORTT 2004, 2006). T&T is a small island developing state (SIDS) in the Caribbean region. Its economy has been buoyed by oil and natural gas exploration and sale (ECTT 2016) for the past several decades. While there are several

manufacturing enterprises, most remain small. This could be part of the reason why, despite the sector’s high investments in labour (9% of T&T’s labour force in 2011), it has not generated proportionate returns (5.3% of GDP in 2010) (Sookram 2012). Recent geological surveys have cautioned that T&T’s non-renewable energy reserves could run out in less than a decade (Singh 2011). Recognising the danger of the country’s overreliance on oil and gas to keep the economy buoyant, the Government of the Republic of Trinidad and Tobago (GORTT 2012) has stated that it “is focused on diversifying the energy sector to support a thriving manufacturing sector”. To stimulate growth and diversification to non-energy sectors of the economy, several investment incentives have been established for the manufacturing sector (Sookoo 2013; MTIIC n.d.). Also, the enhancement of programmes under the Evolving Tecknologies and Enterprise Development Company Limited (eTecK) has encouraged light manufacturing innovation and entrepreneurship. Additionally, the government has called for downstream product development to add value to all new investments

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

in the energy sector, with several of the projects being manufacturing endeavours (Sookram 2012). Through the United Nations Development Programme’s Sustainable Development Goal Number 8, the United Nations (2016) has encouraged maintenance of decent work standards even as countries chase economic growth and productivity increases. As the manufacturing sector ramps up, it will rely more on technology and place greater demands on the workforce. To manage operational risk without compromising productivity, companies will need to formalise their Occupational Safety and Health (OSH) approaches through the use of standardised systems and structures (PCAST 2012). Some of the greatest risks borne by workers will be in the area of occupational health and safety, necessitating much greater levels of compliance with national safety legislation and international safety best practice. However, T&T still has a long way to go in order to establish a positive safety culture (Newsday 2009). Although T&T’s OSH legislation was proclaimed in 2004, few OSH compliance statistics have been publicly published from T&T manufacturing companies (Mustapha-Scott 2011). Coming out of a wider study seeking to support safety management system development in T&T manufacturing companies (Nathai-Balkissoon, Pun, and Koonj Beharry 2012), this paper reports on the extent to which OSH system elements have been implemented in T&T manufacturing companies in alignment with the requirements of the OSH Act. It sought to: (1) obtain descriptive statistics on the extent to which various elements were implemented; and (2) gain insight into how certain elements could influence the implementation of other elements within the OSHMS. 2. The Industry Context One of the wealthiest countries in the Caribbean and Americas (Guardian 2013), T&T is recognised as the most industrialised Caribbean nation (Sanders 2013) and has attracted considerable international investment. Its economy is oil and gas energy-centric, with petrochemical/ process industries also being significant (Beales 2013). In comparison to other Caribbean nations, T&T’s growing tourism sector does not yet have major economic importance. Manufacturing, which showed good promise in the 1980’s, has not flourished into a major economic contributor either, and T&T continues to import most of its manufactured goods. Steadily declining natural gas reserves (Williams 2015), crude oil and natural gas production levels (Rowley 2015), depressed world oil prices (ECTT 2016) and increased shale oil production in the US have forced the country to face up to sobering reduced export earnings, and the need to ramp up economic diversification (Beales 2013; Sorias 2015). In addition to agriculture and tourism, the expansion of manufacturing is one path to such diversification (Anatol 2012; Sanders

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2013). Indeed, manufacturing is recognised as a key growth engine in both the US and UK economies, driving the need for collaboration between government, industry, and academia (Foresight 2013). There are eight (8) manufacturing sub-sectors in T&T: agriculture, fishing and forestry; finance and insurance; mining and quarrying; services; construction equipment and contractors; petroleum and gas; transportation; and manufacturing, production and wholesale (TTMA 2015). Manufacturing has a huge national positive social and economic impact due to its status as the largest non-government employer as well as the fact that value-added manufacturing reduces dependence on imports and earns foreign exchange (Sookoo 2013). Manufacturing sector growth would be facilitated by factors such as CARICOM, CARIFORUM-EU, and WTO trade arrangements (Trinidad and Tobago. MTI 2014), and the potential for significant export of niche products to T&T diaspora populations. A mini industrial revolution is likely for T&T, as ramped up demands for quality, quantity, and efficiency will stretch and stress existing production systems. These could exacerbate existing OSH challenges such as improper work practices, inadequate workplace conditions, and poor safety attitudes, leading to injuries, illness, and even possibly death (Goetsch 2015). Proper OSH Management Systems thus become critical to reduce risk in support of T&T’s diversification thrust. OSH legislation, standards, guidelines, and codes of practice all support OSH systems development. The Factories Act was replaced in 2004 by the OSH Act as T&T’s major OSH legislation (GORTT 2004). Together with amendments (GORTT 2006), the OSH Act addresses several important aspects pertaining to health and safety in the workplace. These include responsibilities of employers/occupiers and employees; industrial diseases; and to a lesser degree, environmental issues. OSH regulations accompany the OSH Act, and locally there are also some OSH standards (TTBS n.d.) and a few guidelines (OSHA 2011). The Act contains mandates as well as sanctions for non-compliance. It also contains several recommended elements, which would depend on voluntary actions. To a notable extent, however, T&T has been seeking voluntary compliance as opposed to using enforcement and levying sanctions for non-compliance with OSH Act mandates (McLeod 2011). It is a concern that implementation of several mandatory elements might currently be left to company discretion. According to Mustapha-Scott (2011), additional challenges to OSHMS development in T&T manufacturing companies include insufficient information and interventions from OSHA, limited availability of expertise, and the inability of many companies to afford consultancy services. Furthermore, there is a question of whether manufacturing organisations will place sufficient priority

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

on OSHMS development if there is little enforcement in the manufacturing sector (Nathai-Balkissoon 2011). 3. Methodology An online survey was developed to gather OSHMS implementation data from manufacturing companies. The data gathered included company profile and respondent demographics, respondents’ judgment of degree of implementation of several OSHMS elements, and opinions and attitudes to OSHMS development in their companies. The instrument was refined (Rea and Parker 2005) using a pilot group. The Cronbach-α reliability of the questionnaire’s OSHMS implementation section was found to be 0.965, where a value of ≥0.70 is desirable (Hair et al. 2010). A minimum corrected item-total scale correlation of 0.546 evidenced strong inter-item consistency. The T&T Manufacturers’ Association (TTMA) online member directory was a key reference point for the survey. Two sub-sectors, namely “finance and insurance” and “transportation”, were not included, since they provided services for manufacturers, as opposed to performing actual manufacturing work. The remaining 341 TTMA members (spanning 6 sub-sectors) constituted the survey population. A convenience sampling approach was used, with the researcher approaching safety professionals, engineers, and managers from companies in each sub-sector to get their agreement to participate in the survey. Ultimately, 100 manufacturing companies were short-listed for the survey. An online survey programme was used to administer and automatically collate the survey data, and the data file was imported into SPSS for data coding and analysis. Likert scale responses were coded with the lowest code (e.g. 1) representing the least positive response and the highest code (e.g. 5) the most positive response. Data manipulation also took the form of new variable creation, in cases where multiple responses were combined. Statistical review and interpretation, for this paper, was limited to calculation of means and standard deviations, as well as variance statistics, F-tests, and significance (p) values. Relationships between factors were considered significant if p ≤ 0.05. 4. Results and Discussions The survey was a rich source of data about OSHMS implementation in the manufacturing sector. This was useful for the T&T context, given that Mustapha-Scott (2011) noted that little of this type of data has been published for public reference in T&T. It may also reflect a situation that exists in other SIDS countries. 4.1 Respondent Profiles 4.1.1 Survey Respondents Of the 100 targeted TTMA members, 40 companies responded. The lowest number of responses obtained for

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any OSH-related question was 34. With 341 TTMA members in the sector’s population, this resulted in a response rate of 34/341 or 10%, and met acceptable sampling rates for this initial survey (Neuman 2006). Respondents included 6 engineers, 8 safety officers, 8 supervisors, and 12 managers who held primary safety responsibilities in their companies. 4.1.2 Sub-Sector The survey responses were distributed across all 6 subsectors, with 4 sub-sectors (manufacturing for petroleum and gas applications, construction applications, manufacturing applications, and service applications) providing a total of 88% of the responses. Only 3 companies did not provide information about their subsector (n=37), while several companies reported that their business spanned multiple sub-sectors. A pie chart of sub-sectors of responding companies is shown in Figure 1.

Figure 1. Sub-Sectors of Surveyed Companies

4.1.3 Number of Employees and Age of Companies As shown in Table 1, 91.2% of the companies had over 25 employees. Of these, 28 (or 82.4% of the responding companies) were from manufacturing companies with over 100 employees. Only 1 respondent company was a micro-enterprise (1-5 employees), and 2 were small (6-24 employees). Table 1. Number of Employees in Surveyed Companies Number of Employees 1-5 6-24 25-100 More than 100 Total

Frequency 1 2 3 28 34

Percent 2.9 5.9 8.8 82.4 100.0

N = 34

It is not certain why most responding companies had large numbers of employees, but 2 reasons seem likely. Firstly, more members of the TTMA may be larger companies who seek TTMA membership in order

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

to build their networks or boost their trade prospects through TTMA’s support tailored to member groupings. Secondly, smaller companies may not have the wherewithal to fully implement some requirements of the OSH Act, and this may have influenced them to choose not to respond to the survey to avoid selfreporting of non-compliance with the act. Companies fell into 2 main age groups, 6-10 and over 20 years old. Only 3 companies were 11-20 years old, while there were no responding companies that had been operating for less than 6 years. Table 2 provides a breakdown of how responding companies varied by age and by number of employees. Of the 34 companies who provided demographic information, 22 were over 20 years old and had over 100 employees. A further 3 companies (aged over 20 years) reported that they had 25-100 employees. In the age category 11-20 years, 3 companies employed over 100 persons, and there were also only 3 companies in the 6-10 year age range. One company was a micro-enterprise with no more than 5 employees, while the remaining 2 companies had between 6 and 24 employees. Table 2. Ownership Makeup of Surveyed Companies Age of Company Over 20 years 11-20 years 6-10 years Total

Company Size (by number of employees) 1-5 6-24 25-100 Over 100 Total 0 0 3 22 25 0 0 0 3 3 1 2 0 3 6 1 2 3 28 34

N = 34

4.1.4. Ownership Makeup and Markets Of the companies surveyed, 61.8% were entirely localowned while the remaining 38.2% were at least part foreign-owned (see Table 3). Table 3. Ownership Makeup of Surveyed Companies Ownership Type Fully local-owned Local-foreign joint ownership Fully foreign-owned Total

Frequency 21 10 3 34

Percent 61.8 29.4 8.8 100.0

N = 34

Not all companies had local markets; 5 of the 33 respondents who provided data about their sales markets indicated that they only held markets outside of T&T (see Table 4). Only 3 fully foreign-owned companies responded to the survey, and only 1 had an international market (North America). There were 10 companies with only part local ownership. 8 had local markets, while 4 had CARICOM markets, 2 North American, 3 South American, and 3 European. Most of the responding companies (18) were fully local-owned. 14 sold to

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CARICOM, 4 to North America, 2 to South America and only 1 to Europe. Table 4. Respondent Profile by Ownership Type and Market Location CARICOM/

North

South

Caribbean

America

America

0

1

0

0

8

4

2

3

3

18 28

14 18

4 7

2 5

1 4

T&T Fully foreign ownership Local-foreign joint ownership Fully local-owned Totals

2

Europe

N = 33

Companies appear to be restricting themselves to markets that are relatively close to T&T, as 53% of international markets were regional, while a further 35% were extra-regional, but still in the western hemisphere. Only 12% of markets ventured across the Atlantic to Europe, and despite the multi-cultural makeup of T&T, none went further afield to Asia, Africa, and Australia. It is possible that trade agreements influence this pattern, as local manufacturers would know of several trade agreements and partnerships within the western hemisphere and in the European Union, but few with Asia, Africa, and Australia (MTI 2014). 4.2. OSH System Statistics The survey enabled some statistics to be compiled about OSH systems in the T&T manufacturing companies. These statistics included respondent perceptions of OSH systems, and the extent to which OSHMS implementation was achieved. 4.2.1. Perceived Benefits of OSHMS Survey Question 1 asked respondents how much they agreed that a structured OSHMS would positively affect their company. Although responses fell along a 5-point Likert scale ranging from strongly disagree to strongly agree, the results were interpreted using just a 2-point scale to gauge the number of respondents who agreed that there were perceived benefits from having an OSHMS and the number who could not recognise certain benefits (see Table 5). Of those who reported that they perceived the benefits of an OSHMS, respondents recognised the humanistic benefits of “improved safety of personnel” and “improved quality of life” 17.6% more than they recognised the resource-centric benefits “improved productivity” and “financial benefits”. Also, from those who were unable to agree that certain benefits were enjoyed due to having an OSHMS, respondents were 68.4% more likely not to agree that an OSHMS yields productivity and financial benefits than they were to not agree that an OSHMS boosts personnel safety and quality of life. These statistics may be

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

indicators of a negative attitude toward safety systems – one where companies perceive safety to be an expenditure item on the books, rather than an investment or savings-generating item. Although research shows

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that financial benefits are enjoyed as a result of OSHMS implementation (Fernández-Muñiz, Montes-Peón, and Vázquez-Ordás 2009), many companies still fail to believe that this so.

Table 5. Respondents’ Ratings of Benefits of OSHMS

Strongly Disagree, Disagree or Neither Agree nor Disagree Strongly Agree or Agree

Improved Safety of Personnel Freq. % 2 5.0 38

Improved Quality of Life Freq. % 4 10.0

95.0

36

90.0

Improved Productivity Freq. % 9 22.5 31

77.5

Financial Benefits Freq. % 10 25.0 30

75.0

N = 40

4.2.2. Perceived Causes of OSHMS Shortcomings Table 6 shares data on factors contributing to OSHMS shortcomings at companies surveyed. Company culture was a major contributor to OSHMS shortcomings as 41.8% of responses cited poor management or employee safety culture, a low priority placed on safety, and a tendency to compromise safety to raise production levels. 33.9% of responses pointed to resource constraints (such as financial, staffing, and knowledgerelated), while another 14.5% recognised monitoring and measurement shortcomings (e.g., inspections and audits, as well as safety performance tracking against goals and targets). Table 6. Perceived Contributors to Company OSHMS Shortcomings Perceived Contributing Factors Poor management safety culture Poor employee safety culture

Frequency 18 17

Percent 17.5 16.5

Insufficient finances

10

9.7

In-house knowledge low

9

8.7

Insufficient inspections and audits

9

8.7

Not enough staff Safety low priority

8 7

7.8 6.8

Inadequate information, instruction, training, supervision

7

Safety goals/ targets not measured

6

5.8

Safety org structure inadequate OSH arrangements not in place

6 3

5.8 2.9

No dedicated safety position

2

1.9

Production demands compromise safety

1

1.0

Poor access to experts

0

0.0

manufacturing sector would be wise to seek positive change. 4.2.3. Reference Documents Used to Develop OSHMS As shown in Table 7, all 40 companies used the OSH Act to guide their OSHMS development, and 19.3% of them also used local Safe to Work (STOW) guidelines. 18.2% of companies also relied upon international (US or UK) OSH legislation, while an international standard of OHSAS 18001 was used by 10.2% of the companies. Only 6.8% of companies reported that they used international guidelines (e.g., ILO-OSH 2001 and environmental guidelines). Table 7. Reference Documents Used to Develop OSHMS Reference Document Used TT OSH Act used STOW guidelines used OHSAS 18001 used US OSH Act used UK HASW Act used ILO-OSH 2001 used Other (international) guideline used No guideline used

Frequency 40 17 9 10 6 5 1 0

Percent 45.5 19.3 10.2 11.4 6.8 5.7 1.1 0.0

N = 40

6.8

N = 40

The last 9.7% of responses highlighted weak OSH arrangements, including inadequate information, instruction, training, and supervision. Interestingly, and as pointed out by Wolany and Spilka (2011), safety culture influences many other OSHMS areas, including some noted as shortcomings, and so this would be a major area of potential in which companies in the

It is of concern that relatively few companies were guided by reference documents beyond the major local OSH legislation, since standards and guidelines appear to be meaningful enablers for companies across all sectors. For example, OHSAS 18001 is such a popular OSH standard that between 2003 and 2009, almost 48,000 companies had earned certification to the standard in as many as 116 countries (Fan and Lo 2012). OSH e-government systems in both the US and UK make a wide range of supplementary materials freely available to companies and individuals (SHP 2014; USDOL n.d.). Fewer resources are disseminated in this way in T&T (Nathai-Balkissoon and Pun 2016b), and so T&T companies are not able to rely as much on these types of supplementary materials.

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

4.2.4. Perceptions of OSHMS Implementation Question 4 of the survey focused on respondent perceptions of the state of the OSHMS in their companies. In the 5-point Likert scale used, a score of 4 indicated that respondents agreed with the statement made. The researcher therefore used a score of 4 or more to mean that the state of a surveyed element was judged to be adequate by the respondent, with elements scored below 4 not meeting that standard. The statistics pertaining to this question are presented in Table 8. The first item of Question 4 asked whether respondents agreed that “(a)n OSHMS exists at the company”. This item was the only statement to earn a mean score that surpassed 4, indicating that, on average, respondents agreed that an OSHMS did exist at their companies. The question did not ask respondents whether they judged the OSHMS to be adequate, but instead asked if they believed that there was a system that functioned to manage OSH. According to MerriamWebster (2015), a system may be defined as “a regularly acting or interdependent group of items forming a unified whole”. Thus, a company’s OSH system would be any set of interconnected processes and procedures used by an organisation to fulfil its functions, and such a system may be tenuous and informal. Therefore, respondent judgements that there was an OSH management system in place should not be construed as implying that all minimum standards have been met as defined in the OSH legislation or that component elements of the OSHMS were formally structured and maintained.

Table 8. Perceptions of the State of OSHMS Implementation An OSHMS exists at the company All OSH Act mandatory requirements have been met The company has implemented safety measures that go beyond the mandates of the OSH Act OSH monitoring and assessment are done using inspection and/or audit activities Within the next 12 months, the company intends to review its OSHMS in order to continue improving it

Mean 4.03 3.84 3.49

Std. Dev. 1.040 1.014 1.146

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that further exploration of OSHMS implementation would be likely to uncover several insufficiencies with regard to implementation of at least some mandatory and voluntary OSH Act elements, approaches to monitoring and assessment, and focus on continual improvement. 4.2.5. Extent of Implementation of Elements This section reports on some findings from survey Questions 5 and 6, which asked whether respondents agreed that specific OSHMS elements had been properly implemented at their companies. The data coding used in this study assigned ratings of 1 to strongly disagree, 2 to disagree, 3 to neither agree nor disagree, 4 to agree, and 5 to strongly agree. Tables 9 and 10 reveal that there were two element groups: one group with means above 4 and below 5, and one group with means above 3 but below 4. The interpretation of the data follows. 1) Well-Implemented Elements In the survey, a value of 4 meant that respondents agreed that an element was properly addressed at their company. Therefore elements with a mean of 4 or more were considered by the researcher to have been wellimplemented in the surveyed companies (see Table 9).

Table 9. Elements Reported as Properly Addressed Elements Documented Safety Policy exists Personal Protective Equipment and Devices for employees Emergency planning OSH Committee exists Dedicated safety practitioner exists Confined space practices Hazardous material practices Training, information, instruction, and supervision Med. exam of employees

Mean 4.3611

Std. Dev. 0.79831

4.2857

0.85994

4.2857 4.1944 4.1389 4.1143 4.0556

0.89349 0.88864 1.04616 0.90005 0.75383

4.0000

1.02899

4.0000

0.93934

N = 37

3.76

0.925

3.76

0.925

N = 37

The remaining 4 statements earned means ranging between 3.49 and 3.84. These mean values indicated that respondents, on average, did not log agreement that mandatory OSH Act requirements had been met, that safety measures surpassing the OSH Act had been implemented, that inspections and/or audits were being used to do monitoring and assessment, or that the company was intending to engage in OSHMS continual improvement efforts in the next 12 months. If used as an indicator question, the low mean values were signaling

Surprisingly, few elements (only 9 of the 22 from the survey) were reported as being properly addressed in companies, and all of these are mandated by the OSH Act. Oversight of the OSHMS appeared to be well in hand, as safety policy, safety committee, and safety leadership all received scores that marked them as wellimplemented. Also, the OSH Act - mandated provision of personal protective equipment and devices, emergency planning specific to fire safety, and practices for hazardous materials (i.e. chemical safety) are sufficiently addressed. The elements training, information, instruction, and supervision, and performance of employee medical examinations scored the minimum mean necessary to be considered properly addressed.

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

2) Under-Implemented Elements The remaining 13 elements were considered insufficiently addressed because their calculated survey means were less than 4 (see Table 10). A surprising result was that risk assessment and safeguards, welfare and health, and OSH submissions – all mandatory elements in the OSH Act – were not properly

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implemented. With no full-scope OSH Act mandates and few national guidelines addressing accident investigation and reporting, posting up the OSH Act for employee access, health surveillance of employees, environmental responsibility, and how to focus on contractor safety checks or at-risk groups, weakness was expected in these areas. Nevertheless, such weakness is cause for concern.

Table 10. Elements Reported as Not Properly Addressed Elements Risk Assessments done Proper safeguards Accident reporting and investigation Health requirements met Welfare requirements met OSH submissions made At-risk groups considered Environmental responsibility Contractor safety checks Top management commitment OSH Act (summary) posted up Health surveillance of employees Employee participation

N 36 35 35 35 35 35 36 35 36 36 35 35 36

Mean 3.9722 3.9714 3.9714 3.9714 3.9429 3.9143 3.8889 3.8571 3.8333 3.6667 3.6286 3.6000 3.4167

Std. Dev. 0.84468 0.78537 0.95442 0.78537 0.87255 0.88688 0.88730 0.97446 0.91026 1.06904 1.05957 1.03469 0.93732

N = 37

For more serious accidents, the OSH Act mandates that accidents be reported to OSHA on a prescribed form. Outside of this, however, the OSH Act does not require accident reporting and investigation duties to be performed by companies themselves, and therefore maintaining accident records and investigating accident root causes may not be done in many companies, despite the fact that this element is critical in an OSHMS (De Koster, Stam, and Balk 2011; Mossink 2002). Also, there is a strong rationale for welfare and health provisions to be well-met by companies (Miller and Haslam 2009, Parry et al. 2006), but these and other mandatory elements are not being sufficiently addressed by T&T manufacturing companies. This may be a reflection that employers consider the financial outlay too onerous to meet the minimum requirements and will not comply with these mandates of the OSH Act until OSHA enforcement takes place, or that a lack of awareness has led them to perceive the requirements as voluntary instead of mandatory. With regard to the non-fulfilment of voluntary aspects, similar responses were noted in the UK about a decade ago, when only 7% of employers were implementing voluntary elements of stress management standards and 55% were unaware of the existence of the documents (Personnel Today 2004). In T&T, it is likely that many employers are placing priority only on the areas they perceive to be absolutely necessary, due to resource constraints, the perception that there is no mandate to comply, and low enforcement from the OSH Agency.

In responding to survey question 7, a respondent’s comment about a factor that contributed to company shortcomings was: “With respect to posting of the OSH Act, the Act requires that an abstract of the act be posted. However, the Abstract has not yet (over a decade after the Act was first proclaimed) been made available (by) the Government Printery. In its absence, most companies still post the abstract of the repealed Factories Ordinance, although it is no longer law.” In much the same way that employees seem to align their behaviours with top management priorities, slow action on the part of the government/OSHA could convey the impression that OSH is not a high priority and so negatively influence companies’ OSH focus. Although safety committee and safety leadership were seen as well-addressed elements, top management commitment and employee participation earned low ratings. This may indicate that a safety manager and/or safety staff, along with a safety committee, are seen as solely responsible for safety; that top management does not buy-into or work to actively support OSH; and therefore that the organisational values may not prioritise OSH – all cause for concern. This possibility is highlighted in this quote from one respondent’s comment in the response given to survey question 7: “The Provisions for Safety are in place, however some managers use and practice safety only when it is convenient to them and their department. It should be enshrined in their duties”. In responding to the same survey question, another respondent’s concern about responsibilities assigned for safety came through: “(Our) OSHMS is a fledgeling [sic] one, being

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

developed mainly through the efforts of the Safety Officer who is shared with 2 other companies in the group, and who has other responsibilities outside of Safety and Health Management”. Also, it is likely that lack of visible top management commitment encourages lack of employee buy-in and participation, a relationship explored later in this paper. After all, if the organisation delegates all safety responsibilities to safety staff, employees would not see the need to extend themselves. There is also the possibility that certain categories of worker are more lax about safety, as pointed out in this survey question 7 quote: “...during peak work, some casual workers do not pay adequate attention to their responsibilities with respect to safety”. 4.3. Elements Influencing OSHMS Development This section reports on some additional relationships that were explored in an attempt to better understand how elements influenced OSHMS development. Though several areas were explored, due to inadequate data availability the researcher was unable to look into how using international documents such as OSH legislation, standards and guidelines influenced the implementation and characteristics of OSHMS development. 4.3.1. Influencers of Implementation of Mandatory and Voluntary Elements It was found that company size (as measured by the number of employees) did not significantly influence mandatory element development (R2 = 0.000, F=0.005, p=0.945) or voluntary element development (R2= 0.018, F=0.573, p=0.455). The extent of those employees’ participation, however, did have a significant influence on implementation of mandatory elements (R2= 0.362, F=19.287, p=0.000) as well as voluntary elements (R2= 0.302, F=14.690, p=0.001). Top management commitment was another significant influencer (R2= 0.470, F=30.100, p=0.000 for mandatory elements; R2= 0.307, F=15.092, p=0.000 for voluntary elements) as was the presence of a dedicated safety practitioner (R2= 0.610, F=53.216, p=0.000 for mandatory elements, R2= 0.345, F=17.947, p=0.000 for voluntary elements). These statistics underscore that an organisation’s people are critical to safety and safety systems. Each hierarchical level of the safety system can be seen to impact on the establishment of both voluntary and mandatory safety system elements, from safety practitioners as the biggest influencers who constantly monitor and drive safety, to top management who set safety policy and provide safety resources, to employees who must consistently implement safety practices in their duties and cooperate with others to work safely. Also, a focus on continual improvement was significantly linked to both mandatory element development (R2= 0.377, F=20.539, p=0.000) and voluntary element development (R2= 0.198, F=8.409,

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p=0.007). Further, mandatory element development appeared to influence the development of voluntary elements (R2= 0.707, F=0.81.855, p=0.000), likely signalling that companies focus first on mandatory elements and then seek to enhance their OSHMS by improving voluntary aspects. This does make sense in the context of legislative structure, given that mandatory elements, if not properly implemented, could result in OSHA’s levying of fines and other penalties for noncompliance. 4.3.2. Employee Participation in the OSHMS No significant relationship was identified for the influence of size of company on employee participation levels (R2= 0.020, F=0.643, p=0.429). However, the presence of a dedicated safety practitioner was found to have a significant effect on employee participation levels (R2= 0.164, F=6.690, p=0.014) and so did top management commitment (R2= 0.508, F=35.124, p=0.000). These statistics indicate that employee participation is positively influenced when the company broadcasts its commitment to OSH, when top management’s words and actions convince employees of their commitment to developing a strong OSHMS, and also when they go so far as to hire a safety leader whose primary role is to develop and maintain the OSHMS. 4.3.3. OSHMS Continual Improvement Employee participation was not significantly linked with a continual improvement focus (R2= 0.029, F=1.002, p=0.324), and so a link between higher organisation levels was explored. Top management commitment was found to have a significant relationship with a continual improvement focus (R2= 0.245, F=11.007, p=0.002), and this could be because top management is responsible for determining the priorities and direction of a company, as well as providing resources to help the company meet its goals. Having a dedicated safety practitioner was also significantly linked to continual improvement focus within the OSHMS (R2= 0.403, F= 22.912, p=0.000). As the company’s day-to-day OSHMS driver and resident safety expert, the safety practitioner would understand the OSHMS’ weaknesses and strengths. With the role of promoting company safety by developing supporting systems, this person would likely have the greatest single impact on the OSHMS and safety in the entire company. This is the person whose job it must be to enhance the company’s continual improvement culture. A major aspect of a safety practitioner’s job should be to understand how safety is practiced in the sphere of the employees. Therefore, it makes sense that the statistics also reflected a significant relationship between number of employees and the presence of a dedicated safety practitioner (R2= 0.137, F=5.097, p=0.031). As their size increases, companies would likely find it difficult to keep abreast of all aspects of operations,

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

including safety. Therefore, it would become imperative to depend on a dedicated safety leader to monitor, measure, and improve safety systems and performance. These findings underscore McIlroy’s (2013) assertion that the most critical aspect of an effective OSHMS comes from people-support, i.e. strong leadership, supervision, and employee participation. 5. Conclusion and Recommendations This paper has made new OSH-related statistics available from the manufacturing sector of the small island developing state, T&T. The following contributions centering on the state of OSHMS development and relationship between OSH system elements in the sector has been made. Firstly, identification of perceptions of OSH systems, documents used in developing OSH systems, and the extent to which OSH systems have been implemented in T&T manufacturing companies; and secondly, identification of factors that may influence OSH system development in T&T manufacturing companies. Also presented were some of the results of an extended study about OSHMS development in the T&T manufacturing sector. The research has previously generated a paper that arranged OSHMS elements into factors that influence OSHMS development (NathaiBalkissoon and Pun 2016a). The survey data was also used to perform hypothesis testing evaluating whether OSHMS development is affected by various mandatory and voluntary elements, certain company attributes, and a continual improvement focus. Further research outcomes to be generated from the larger study include publication of the survey instrument that was developed, proposal of an Analytical Hierarchy Process priority framework, and development of an OSHMS selfassessment framework that could be used by manufacturing companies to evaluate and continually improve their OSHMS. A wider survey of the Caribbean’s manufacturers should be conducted to explore whether the implementation statistics and correlations suggested in this paper hold for a wider group of SIDS manufacturers. It should be noted that collaboration with manufacturing associations would be beneficial in order to successfully conduct such a survey, since many companies were reluctant to participate in the study reported in this paper. A survey of this nature would be useful as a driver to raise OSH standards for the entire Caribbean region. This survey has documented actual statistics that validate the “gut instinct” (and expressed qualitative opinion) of many OSH experts and practitioners that compliance with the OSH Act is not up to the desired standard in manufacturing companies. Achieving such compliance consistently throughout the sector can only come about if there is understanding and buy-in by

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manufacturers, and if adequate systems and support are provided to the sector. There is a need to conduct a needs assessment for such interventions, and to roll out the required support in a timely manner. Considerations should include, but would not be limited to: (1) increased development of standards, codes of practice, guidelines and other documents to boost understanding, buy-in, and knowhow by stakeholders; (2) enhancement of e-Government systems that would enhance OSHA’s ability to disseminate materials; (3) improved structuring and resourcing of mechanisms to enforce the requirements of the OSH Act; and (4) outreach to the public, including schools, to influence early adoption of OSH tenets. References: Anatol, M. (2012), “Industrial diversification in Trinidad and Tobago: Strategies for diversifying the Trinidad and Tobago economy beyond oil and gas”, Paper presented at the UCCI Caribbean Conference 50-50 – Surveying the Past, Mapping the Future, University College of the Cayman Islands, Grand Cayman, March 21-23. Beales, I. (2013)(ed.) “An Interview with the Prime Minister Kamla Persad-Bissessar”, In: Global – The International Briefing. In Spotlight: Trinidad and Tobago, Smuts-Beyers, Cambridge, Vol.13, pp. 34-35, 38, Accessed January 6, 2016. http://www.global-briefing.org/Global_13/index.html#/36. de Koster, R.B.M., Stam, D. and Balk, B.M. (2011), "Accidents happen: The influence of safety-specific transformational leadership, safety consciousness, and hazard reducing systems on warehouse accidents”, Journal of Operations Management, Vol.29, No.7-8, pp.753-665 (doi:10.1016/j.jom.2011.06.005). ECTT (2016), “Minister Nicole Olivierre - Speech at the Energy Conference 2016”, Energy Now (Blog), The Energy Chamber of Trinidad and Tobago), January 29. Accessed June 20, 2016. http://energynow.tt/blog/minister-nicole-olivierre-speech-at-theenergy-conference-2016. Fan, D., and Lo, C.K.Y. (2012), "A tough pill to swallow? The impact of voluntary occupational health and safety management system on firms' financial performance in fashion and textiles industries", Journal of Fashion Marketing and Management, Vol.16, No.2, pp.128-140. Fernández-Muñiz, B., Montes-Peón, J.M. and Vázquez-Ordás, C.J. (2009), "Relation between occupational safety management and firm performance", Safety Science, Vol.47, No.7, pp.980-991. Fleming, S.H. (2001). “OSHA at Thirty: Three decades of progress in occupational safety and health”, Job Safety and Health Quarterly, Vol.12, No.3, pp.23-32 (OSHA, Washington). Foresight (2013), The Future of Manufacturing: A New Era of Opportunity and Challenge for the UK, The Government Office for Science, London. Goetsch, D.L. (2015), Occupational Safety and Health for Technologists, Engineers, and Managers, 8th edition, Pearson, New Jersey. GORTT (2004), The Occupational Safety and Health Act (2004). The Government of the Republic of Trinidad and Tobago, Port of Spain. GORTT (2006), The Occupational Safety and Health (Amendment) Act (2006), The Government of the Republic of Trinidad and Tobago, Port of Spain. GORTT (2012), Socio-Economic Status, The Government of the Republic of Trinidad and Tobago, Accessed May 31, 2014. http://www.tnt50.gov.tt/about/socio-economic-status.

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

Guardian (2013), “T&T is second richest in Caribbean”, Trinidad and Tobago Guardian, December 22. Hair, J.F.Jr., Black, W.C., Babin, B.J., and Anderson, R.E. (2010), Multivariate Data Analysis, 7th edition, Pearson Prentice Hall, New Jersey. Humphries, J. (2010), Childhood and Child Labour in the British Industrial Revolution, Cambridge University Press, Cambridge. McIlroy, S. (2013), "Step in the right direction", The Safety and Health Practitioner, Vol.31, No.11, pp.39-40, 44. McLeod, E. (2011), “Keynote Address”, Speech delivered at the SCTT 2011 Breakfast Seminar, Port of Spain, Trinidad and Tobago, October 18, 2011. Accessed November 1, 2011. http://safetycounciltt.com/images/stories/pdf/panel_discussion_re port.pdf. Merriam-Webster.(2015), “System.” Accessed February 18, 2016. http://www.merriam-webster.com/dictionary/system. Miller, P., and Haslam, C. (2009), "Why employers spend money on employee health: Interviews with occupational health and safety professionals from British industry", Safety Science, Vol.47, No.2, pp.163-169. Mossink, J. (2002), Inventory of Socioeconomics Costs of Work Accidents, European Agency for Safety and Health at Work, Luxembourg. MTI (2014), Trade Agreements, Ministry of Trade and Industry, Trinidad and Tobago, Accessed May 31, 2014. http://tradeind.gov.tt/Trade/Trade-Agreement. MTIIC (n.d.), Compendium of Investment Incentives in the NonEnergy Sector, Ministry of Trade, Industry, Investment and Communications, Trinidad and Tobago, Accessed May 31, 2014. http://www.tradeind.gov.tt/Portals/0/Documents/Investment/revis ed_Compendium_of_Investment_Incentives_in_NonEnergy_Sector.pdf. Mustapha-Scott, N. (2011), “OSH Act: Is it business as usual?” Speech delivered at the SCTT 2011 Breakfast Seminar, Port of Spain, Trinidad and Tobago, October 18, 2011. Accessed November 1, 2011. http://safetycounciltt.com/images/stories/pdf/ panel_discussion_report.pdf. Nathai-Balkissoon, M. (2011), “Towards compliance with the OSH Act of Trinidad and Tobago: Gap analysis of a food and beverage manufacturing enterprise”, The Journal of the Association of Professional Engineers of Trinidad and Tobago, Vol.40, No.1, pp.34-43. Nathai-Balkissoon, M., and Pun, K.F. (2016a), “Factor analysis of elements influencing occupational safety and health management system development in Trinidad and Tobago”, West Indian Journal of Engineering, Vol.38, No.2, pp.13-23. Nathai-Balkissoon, M., and Pun, K.F. (2016b), “OSH at Trinidad and Tobago’s fingertips: Learning from first-world OSH website approaches.” International Journal of Public Administration in the Digital Age, Vol.3, No.3, pp.57-72. Nathai-Balkissoon, M., Pun, K.F. and Koonj Beharry, A. (2012), “Development of a compliance framework for safety management practices in manufacturing companies in Trinidad and Tobago: An agenda and some findings”, In: Proceedings of PICMET '12: Technology Management for Emerging Technologies, Portland, 3304-10. Neuman, W.L. (2006), Social Research Methods: Qualitative and Quantitative Approaches, 6th edition, Pearson Education, Boston. Newsday (2009), “OSH authority gets tough on compliance”, Trinidad and Tobago Newsday, April 28. OSHA (2011), Publications, The Occupational Safety and Health Authority and Agency, Trinidad and Tobago, Accessed August 15, 2014. http://osha.gov.tt/Resources/Publications.aspx. Parry, T., Jinnett, K., Molmen, W., and Lu, Y. (2006), The Business Value of Health: Linking CFOs to Health and Productivity, Integrated Benefits Institute, San Francisco.

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Author’s Biographical Notes: Marcia Nathai-Balkissoon is a Lecturer at The University of the West Indies (UWI), St. Augustine Campus, Trinidad and Tobago. She is a Registered Professional Engineer and member of the Safety Council of Trinidad and Tobago (SCTT), The Association of Professional Engineers of Trinidad and Tobago (APETT) and The

M. Nathai-Balkissoon: Occupational Safety and Health Management System Implementation Metrics – Results of a Survey of Manufacturing Companies in a Small Island Developing State

Institute of Industrial and Systems Engineers (IISE). Ms. NathaiBalkissoon has served in various industry posts as manager, engineer, auditor, and consultant. Currently pursuing a Ph.D. Industrial Engineering, she holds a B.Sc. degree in Industrial Engineering and an M.Sc. degree in Engineering Management.

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Her research interests include occupational safety and health, teaching and learning, and business management systems.

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