Kathy Seabrook, Center for Safety and Health Sustainability
24th September 2018
For someone who has spent so much of her career involved in safety and health, Kathy Seabrook appears a little circumspect about her profession.
"When people ask me what I do [I say] I'm a management consultant. I work with companies to help them understand risk."
Global Solutions, the consultancy that Seabrook founded almost 20 years ago, is similarly stealthily named for the brand of someone who is a chartered fellow of IOSH and former president of the institution's US analogue, the American Society of Safety Professionals (ASSP).
Asked about her company name's inscrutability, her answer: "I don't want to limit it, there is so much more to managing OSH risk", could be used to sum up her wider approach to promoting the value of good OSH management in organisations.
She is driven to make the business community acknowledge safety as an integral part of risk management and safeguarding profits, not something that sits apart from other priorities such as asset management or financial probity.
Kathy Seabrook career file
1996-present: President and founder, Global Solutions
2015-present: Chair, Center for Safety and Health Sustainability
2011-2015: Adviser, Center for Safety and Health Sustainability
2013-2014: President, American Society of Safety Professionals
2013-2018: US delegate PC 283 for ISO 45001 and vice chair US TAG (mirror committee)
One of the main conduits for her efforts to this end recently has been the Center for Safety and Health Sustainability (CSHS -- www.centershs.org), which was spun out of the ASSP (then the American Society of Safety Engineers -- ASSE) in 2011, with IOSH as a co-founder, growing from an ASSE taskforce that Seabrook led. She now chairs the CSHS, whose other directors include IOSH's director of strategy and business development, Richard Orton.
The CSHS draws on the United Nations' 1987 definition of sustainable development as "meeting the needs of the present without compromising the ability of future generations to meet their own needs". The center's formation grew from the OSH professional bodies' feeling that in the mainstreaming of sustainability as a business priority and metric, the triple bottom line, balancing people, profit and planet had overlooked a significant part of the people strand: worker safety and health.
"Sustainability is market driven," says Seabrook. "Ninety-five per cent of publicly traded organisations report on sustainability performance, but not all report on their OSH performance in a meaningful way."
A study by researchers at Harvard Law School, in collaboration with the CSHS in 2017, found that only around half of 3,400 publicly quoted companies surveyed for the Dow Jones Sustainability Index disclosed fatality or injury rates. The center has held workshops at Harvard University to publicise these findings and raise awareness of and support for more widespread OSH metrics reporting.
"At the center we are looking at the human capital aspect of sustainability, corporate responsibility and organisational performance, which includes health and safety," Seabrook says. "Protecting people in an organisation helps to demonstrate the organisation is sustainable, is actually performing."
Human capital, she believes, is set to become a sustainability indicator, just as has been the case with stewardship of natural capital -- the planet's natural resources.
Is that a hard message to sell to organisations used to focusing on other metrics in sustainability?
"Occupational health and safety has always been an important aspect of any business," she says. "At the center we are trying to help organisations understand how everything is interconnected."
A lot of leaders don't do that well. They get frustrated, they yell. But you don't get anything out of your people that way
Seabrook refers often to "joining the dots", whether it is helping her Global Solutions clients see the link between safety and their other business risks or the wider work of the CSHS in lobbying for OSH to form part of sustainability measurement.
If she and the center can help achieve that integration, the prize is a hefty one. The impetus for large organisations to report their environmental impacts and sustainability initiatives has grown and grown in the past ten years and along with it a host of quality marks and league tables, such as the Dow Jones Sustainability Index in the US and the FTSE for Good in the UK, that the corporations vie to rank in.
Critically for the major corporations, the major investment groups that buy and sell their stock are using organisations' action on climate change and modern slavery and pollution as an indicator of how they manage business risk more generally. The CSHS is now persuading those same businesses to extend the parameters to include worker protection. "If the investment community is looking at risk," Seabrook says, "then one aspect of risk is how you treat your people."
Its work is gaining traction. The Canadian-based Corporate Knights publication -- which describes itself as "the magazine for clean capitalism" -- produces an influential ranking of the world's 100 most sustainable companies, based on their environmental and social impacts, including resources management and community engagement. In 2016, the CSHS commissioned research into workplace fatalities among the 100 and found some with annual death rates as high as 40.
Seabrook and her predecessor as center chair, Tom Cecich, revealed the results in a panel discussion at an America's Safest Companies event. Corporate Knights publisher Toby Heaps was also on the panel and "was staring at us. He said, 'I didn't know this. We need to make it right'.
"Now when they rate the top 100 companies, one of the criteria they use is fatality rates."
This victory is "just the beginning" she says, because of the lagging nature of the indicator.
Held to account
The US Sustainability Accounting Standards Board (SASB) aims to set standards for corporate performance that mirror the accounting statements long required by law and prescribed by the Securities and Exchange Commission.
"When a specific risk is considered material for an organisation, it can impact the financials," Seabrook explains. "In the US we have a very strict definition of materiality that went to the Supreme Court, because it determines what a company has to disclose by law in its annual report."
Ninety-five per cent of publicly traded organisations report on sustainability performance, but not all do on OSH
SASB, whose advisory group includes the major investment groups including Blackrock, Goldman Sachs Asset Management and Bank of America Merrill Lynch, has published what it calls "materiality matrices" for 80 business sectors listing the environmental, social and governance dimensions which are material to each industry. SASB has listed more than 30 industry sectors where it sees OSH metrics as material, including energy and transportation.
Seabrook says the CSHS is pressing for the inclusion of other sectors, arguing that higher illness and injury rates in any sector will have an adverse impact on an organisation's profitability and sustainability.
"But you have to take baby steps and at least we are on the radar screen in many sectors now," she says. "Raising the level of OSH materiality in integrated reports provides a direct line of sight to the board of directors and the CEO like never before."
In April, she was asked to represent the CSHS on the board of the new Social and Human Capital Coalition (SHCC). The SHCC and its founder, the World Business Council on Sustainable Development, represent more than 200 global multinationals such as Diageo, Exxonmobil, Hitachi and Unilever, with a combined workforce of more than 19 million. It is focused on sustainable development, recognising the value of communities and people.
Seabrook believes the planned work of the SHCC and the influence of the United Nations' Sustainable Development Goals (SDG) -- including SDG 8 on decent work -- to which many global corporations have already pledged support, show the trend to recognise human capital has spread well beyond North America.
Taking the initiative
45001 and beyond
One of the organisational disclosures required by the new GRI 403 OSH standard (see p 36) is that an organisation shall report whether it has implemented an occupational safety and health management system and whether it conforms to "recognised risk management and/or management system standards/guidelines".
The guidance notes to the disclosure suggest organisations describe the system's arrangements for continual improvement. Other disclosures require detailed descriptions of the arrangements for safety and health training and for worker consultation and participation in OSH matters.
From these it seems obvious that GRI 403 has been drawn up to mesh with the requirements for the new ISO 45001 management systems standard. Seabrook, who sat on the PC 283 project committee that steered the development of ISO 45001, confirms that GRI 403 is intended to align with it.
She says she is pleased by both the connection and the fact that there is now an OSH ISO standard as she has believed since the 1990s that management systems were the foundation of good risk management.
If the pressure for evidence of good safety management spreads down supply chains, as it has with environmental management, won't smaller companies find that 45001 is an onerous and expensive way to have to satisfy their bigger clients?
She agrees that it is not the lightest standard: "One of the criteria when they developed it was that it had to be scalable. But anybody that looks at that on the face of it would go, 'You've got to be joking', because it looks overwhelming."
However, she believes small businesses will not be railroaded into certification.
"The global companies won't necessarily say to their supply chains, 'We want you to certify to 45001'," she says. "But they will say '45001 or comparable'. So those suppliers could say, 'These are the requirements for 45001, here is our management system. These were the gaps, this is how we closed them. We decided not to go for certification, but we will be happy to show you what we are doing'."
She notes that the Center for Safety and Health Sustainability's criteria for sustainable OSH management includes a formal management system, verified outside the OSH function. "But we didn't say it had to be certification, we said verification. So that could be an external or internal registrar."
There may also be scope for a lighter management system certification to suit smaller operations, she suggests. "When there's a need in the market, there are usually entities that come to satisfy that need."
Another focus of CSHS and Seabrook's activity in recent years has been working with the Global Reporting Initiative (GRI), whose framework for corporate sustainability reporting is widely recognised by governments and investor bodies. Around three-quarters of the world's 250 biggest corporations report on their impact on climate change and human rights using the framework.
The GRI has morphed in recent years from a body providing guidance and frameworks into a standards development organisation, which meant it could unbundle the discrete performance areas that were previously rolled up into the iterations of its overarching framework.
"That allowed them to be more nimble in response to stakeholders' expectations," she says of the change, "and the two issues they set standards on first were water and OSH."
At the end of 2016 the GRI assembled 15 experts, including Seabrook representing the CSHS, to create a model set of "disclosures" for firms to make in their sustainablity or corporate social responsibility reports.
"At the center we had developed our metrics back in 2013 that we believed demonstrated an organisation's OSH performance and we wanted to make sure those got in to the GRI disclosures," she says. "And I'm happy to say they did."
The standard, GRI 403: occupational health and safety, was released in June (bit.ly/2lRqK7q). There are ten main disclosures OSH performance indicators an organisation is expected to disclose in a sustainablity report. Seabrook says it is significant that the conventional lagging indicators of safety performance -- accident rates -- are the subject of only two of the disclosures. But there is also a breakthrough in the requirement for the way these injury rates must be stated.
Even where organisations have begun to report their workplace fatalities and injuries in annual reports in the past ten years, their value to outside observers has been limited by the different bases they use to calculate the rates.
"This is the difficulty," Seabrook says, "some countries' rates are based on one million person hours worked; some use 200,000 hours, some 100,000 as in the UK and EU."
Organisations have tended to adopt the formula used by their national regulators, to allow easier benchmarking with industry averages, but this has caused headaches for multinationals.
"Stakeholders want to be able to compare apples with apples; they want consistent and comparable measurement," says Seabrook.
Disclosure 403-9 in the new standard says the reporting organisation must report the numbers of fatalities, high-consequence injuries and reportable injuries using the number of injuries divided by the total hours worked and then multiplied by either 200,000 or one million and must state which of the latter multipliers it has used.
The standard is new and voluntary, and its formulae may not be ideal for European employers used to a 100,000-hour multiplier, but its attempt to set a standardised rate (or two) is important.
"That came from the investment community, so they can do their own comparisons," says Seabrook of pressure for the fixed measures. "They and customers -- whether it's consumers or business customers -- all want consistency and comparability, so they can determine which companies are sustainable based on their own values."
Returning to management systems more broadly, she says her view and that of the CSHS is that OSH management systems, validated by schemes such as the new ISO 45001 (see above box) are only a stepping stone to fully integrated management systems, since the same principles apply to all aspects of doing business well and sustainably.
She offers the example of a company she is working with where she is talking to the leaders about the fundamentals of their manufacturing operation.
Seabrook says that when they describe the stages of planning the quantity and quality of products: making them, verifying they are meeting targets and spotting and correcting any defects, she tells them they are already following the four principle stages (plan, do, check, act) of a management system.
"If you extend that to other risks, to cut unscheduled downtime and improve reliability you are reducing business risk," she says. "And if you can talk to small and medium-sized organisations in that way, you can get them to adopt integrated management systems."
Embedding these systems, she says, relies on skills in organisational change and finding people, early adopters, in the organisation who can see the business benefits and can "make it real and relevant, explaining it to everybody in real-world terms, not ISO terms."
She does not believe integration is a hard concept to sell: "You talk to your leadership and they'd be very happy to have one system for all this. Most would rather not have siloed and separate environment, health, safety and quality processes or certification schemes such as ISO 45001 and 14001."
I wonder where all this integration of safety into a wider risk agenda and making it the responsibility of production or operational managers leaves the OSH practitioner.
"Safety professionals are the subject matter experts, and internal consultants to the business, including the operational leaders," she says.
"The occupational health and safety staff in most organisations is pretty small these days, so we have to learn two things. One is to manage projects, and a good project manager is the one who can identify resources, such as early adopters who think this is cool stuff.
"And the second thing is organisational change. We are change consultants if we want to be. We need those early adopters to help transfer the knowledge and those are people of influence. Some of them may end up being safety advisers or safety advocates as part of their career progression.
"The organisation can put these systems in place but at the end of the day it's about the operator, an electrician, for example, who is building out an addition to a large complex, or someone manufacturing an aspect of a product, or even a flight attendant. They have to be able to take that information on risk reduction and incorporate it into the standard operating procedures. So they don't have to worry about asset management, quality, environment, safety, productivity; it's all part of the standard operating procedures.
"There are companies out there doing this right now and they are very successful," she adds. "But it's early days for many others."
She says the message she gives to OSH audiences is that, "This is about career development. Some of these influences are still to be realised."
Change is non-negotiable, she says. Technological advances, uncertainty, working in ambiguous environments and changing business structures will leave practitioners behind if they don't keep up: "You have to embrace change."
"It's about finding your 'sea legs', a stable footing, and developing strategies and skills to deal with organisational change. If there's so much uncertainty, how do you create an element of certainty to make a decision? You do experiments. You do a pilot so if it fails it's only a small part."
With one of her clients she is assessing a trial involving a team of ten in a new lockout/tagout inspection programme.
"We will look at how well that team works together and how well the leader coaches through the obstacles," she says. "So we are determining if the programme is working but the by-product project is helping the people in the team develop interpersonal, collaborative and leadership skills as well as subject matter expertise. Then they could start to influence the other teams, to ultimately build internal capacity."
As an undergraduate, Seabrook studied chemistry in James Madison University in Virginia but when the time came to consider what she would do after her degree she "realised I did not want to be a bench chemist and I didn't want to do research. I'm too much of a people person.
"An insurance company came [to the university] and wanted to interview science majors. I thought: insurance, really? But I wanted interview experience so I went to the interview. This was in Virginia. They liked me and I went to their head office and the more I talked to them the more I found it fascinating."
The insurer employed her to travel round the state assessing the firm's business customers.
"It was workplace safety and health and I loved it. That's where I learned the concepts of risk. I'd go into companies and spend anywhere from half a day to a week assessing what their risks were and whether they were adequately controlled and would they make a good client?
"That gave me an ability to step back and look at the big picture and that's what I do well."
Her fellow assessors taught her the ropes of risk assessment and control.
In 1991 she moved to the UK and ran the company's risk control operations there. The shift "opened up a whole world. It was the best thing that ever happened to me," she says. She joined IOSH and her talent for organisation saw her appointed as a founding member of the institution's international committee.
When she returned to the US in 1996 she found her expanded horizons made it hard to settle back into her old work, "So I decided to do something on my own." That was the genesis of Global Solutions.
In her early work as a freelance consultant she used her knowledge of the UK safety regime to help auditors in multinationals move and adapt from one jurisdiction to the other, telling them, "You have to be looking for the same outcome, not for the process to be exactly the same."
In the late 1990s she also developed a two-day seminar on global environment, safety and health management for senior management in multinationals that included issues such as travel risk and cross-cultural risk management that were later to become more prominent. She still runs the seminar today.
After her return from the UK she also became actively involved in the ASSE, and was appointed as founding chair of an international practice taskforce, the first of many special groups she has served on and headed before and since being elected to serve as the association's president in 2013 to 2014.
"I'm proud of being able to get people together around something that we feel there's a need for," she says of the projects she has helped steer. "Proud of having that conversation and coming out with something that can be implemented and that brings a solution to a problem."
More than 20 years after setting up as a consultant, she remains a sole trader, though she can assemble teams of consultants under the Global Solutions label when she needs more hands to service larger contracts.
She has been approached by headhunters over the years trying to tempt her to return to corporate employment. But "to be honest it has really worked doing my own thing. I can choose my clients. The relationship is everything. There has to be trust and you have to know you can work together.
"I talk to them about the values of their organisation. If their values do not include safety and health and if the CEO does not believe it's important and it's an articulated value, I can't work with that company. If you are looking to truly change an organisation and make it one that values people and is very proactive in assessing risk to ensure risk reduction, it takes three to five years to implement management systems that change the culture. And you need a CEO that is going to hold that line and that's hard when you have all the nay-sayers saying, 'We have to get the product out the door'."
She says enjoying engagement with people adds value to her work because it allows her to probe for the real issues that exacerbate risk.
"So why did that happen? The machine guard wasn't on. Well why was that? Sometimes it will be because it was slowing production down. But sometimes it's because the equipment broke down and the maintenance people forgot to put the guard back on and the person who was in the area was a contractor who wasn't supposed to be there.
"You have to really dig deep and not just say 'the person needs to be trained', and for that you have to listen and I have honed that skill over a long time. I'm not getting the information I need to reduce risk if I'm not open."
These listening skills are the key to good leadership generally, she believes. "Leadership is about leading people and people need to be listened to. So many times I come across people who just want to tell me stuff. And when I was younger I would say 'I want to tell you-¦' because that would demonstrate that I was a leader and a subject matter expert. But over time I've learned to take my ego out. If I allow people to just talk, I'm going to learn; there are always pearls.
"Leadership is about being able to engage people and you can't engage with someone unless you ask them questions. If I engage with people I get data points and I can make the most effective decisions with the most people having part ownership of them."
Listening to clients carefully, she says, often leads her to a point where, after a discussion of their problems, she is able to identify a more important underlying issue.
"The other thing I've learned is that I don't have to have all the answers. The best leaders are those that turn it back to the group. Find those subject matter experts and ask, 'What do you think?' All of them together will give you the best solutions. That's the best leadership quality one can have. It's been really effective for me."
But she wants to correct any impression that this is a passive approach to leadership: "There is also a time to coach. When someone is not meeting targets to be able to help them see that and to talk about why they are not and what's in the way and how to get them there.
"A lot of leaders don't do that well. They get frustrated, they yell. But you don't get anything out of your people that way."
Seabrook comes across as anything but frustrated. Her enthusiasm for encouraging others to join the dots as she already has between safety and health, business risk and sustainable performance is infectious, but she says she has never been driven by personal ambition.
"I wasn't somebody who plotted a course. There are some people who say, 'I want to be at this level by X number of years in my career'. I always just said yes and it worked for me."