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Safety
PERSPECTIVES ON RESORT SAFETY

When Compliance Isn’t Enough

BY GREG WEATHERBY, HPI SAFETY SYSTEMS, LLC

AT A RECENT REGIONAL ski industry meeting I attended, it was clearly established expectations and accountability for mounting
obvious that employee safety was—and rightfully has been— and dismounting machinery?
an immediate priority for resort owners and their workers. Resorts that are willing to look deeper into their work
Publicly available injury and workplace incident statistics processes and systems with the intention of improving them,
from OSHA indicate that more regulators are beginning to well beyond compliance, are the ones that will reduce or
turn their attention to the workplace challenges facing ski eliminate the causes of many of their most significant incidents.
area operations as injury rates in the industry remain well Many organizations have trained managers, supervisors, and
above other industries. employees in Human Performance Improvement (HPI),
If you want to get OSHA’s attention, have a fatality or which enables them to fully evaluate and improve their
even just one serious, highly visible employee injury. These safety-related performance outcomes.
events likely will trigger OSHA to instigate on-site inspections
that can further spotlight potential compliance and behavioral When Employees ‘Touch’
issues, often resulting in fines and penalties. This can have a a Latent Weakness
significant impact on a resort’s bottom line and reputation. Old school thinking places the blame for many incidents on
This upward trend in workplace incidents has its foun- the shoulders of employees. Years ago, managers believed that
dation not only in the unique work environment of ski area if they could just stop people from “behaving badly” they
operations but also in safety performance, and not simply would prevent these incidents. But the true causes of many
safety compliance. You can be arguably compliant with incidents are rooted in the management systems that support
OSHA standards and still have people getting hurt at your the work people do. As it turns out, very few incidents are
resort. That’s because OSHA compliance is not enough to caused merely by “bad behavior.”
have a truly safe, incident-free operation. Latent weaknesses and conditions lay dormant in the
First of all, OSHA standards are minimum standards. work processes or tasks until an employee touches the system
Second, they don’t address the most frequent contributor to and triggers an event. As a matter of fact, this was true in
employee incidents: latent organizational weaknesses or hidden both space shuttle explosions. The Space Shuttle Challenger
deficiencies in management control processes and values (i.e., (1986) contained a latent weakness in its “O” ring design,
policies, work control, training, and resource allocation). These which was not built to withstand cold temperatures.
system weaknesses—which OSHA compliance alone cannot Management did not believe this was a problem, despite the
resolve—can lead to workplace conditions that provoke unpre- engineers’ strongly expressed concerns. Tragically, the shuttle
dictable, possibly unsafe behavior. exploded when the launch commenced; the astronauts
For example: Your groomer operator stops for a break, “touched” the system, exposing the weakness. Similarly, the
places the equipment in a safe configuration, unbuckles his Columbia (2003) disintegrated upon reentry after a piece
seatbelt, then stands up and jumps out of his cab. Since he was of foam, that was not attached correctly, damaged the wing.
wearing a seatbelt, has the proper training, and a functioning This hidden weakness (the damaged wing) sat dormant in the
back-up alarm and horn, OSHA is not overly concerned. But system until the astronauts commenced reentry, triggering
if you’re the supervisor, are you happy that he is only compliant the latent condition and killing the crew.
with OSHA standards? (I hope you answered no!) Getting Most incidents at resorts follow similar patterns. A weak-
on and off of equipment is one of the most hazardous acts an ness in the work system, process, or control creates a condition
employee can perform, especially in the winter environment. that is triggered by a behavior—not necessarily an intentionally
Why did the operator jump from his machine rather than bad behavior—that exposes the latent weakness. For example,
climb down safely. Was this a learned behavior? Is this type of a snowcat operator leaves the cab to perform a task. His actions
behavior consistent with the norms and values of the organiza- allow a latent weakness in the system—a modification to the
tion or its support groups? Has management and supervision safety system lockout—to be triggered, posing a serious risk of

22 | NSAA JOURNAL | WINTER 2019