Research for an interview with L'Oreal's global health and safety director, Malcolm Staves, reveals a paradox. The world's largest cosmetics group has virtual shelves full of awards for its corporate social responsibility (CSR) work, it rides high in ethical business indices and was No 1 in Newsweek magazine's global green companies ranking. But if you comb its extensive annual CSR report, Sharing Beauty With All, or the sustainability pages of its corporate website or annual reports, you will find almost no reference to safety initiatives or performance -- an unusual omission for any multinational.
Does the company have something to hide? Far from it; the accident rates among its 83,000 strong workforce operating in research centres, factories, distribution hubs and shops in 150 countries are exemplary and it has collected the set of evolved OSH policies and initiatives, many of them seen as benchmarks by other multinationals.
2007-2008, Director HSE and social responsibility, Bureau Veritas
2004-2007, Director, EHS management systems and audit programmes, Alcan Packaging
1999-2004, Group EHS director, Pechiney
1992-1999, Manager, environmental programmes, then EHS manager, Europe, American National Can (Nacanco -- part of Pechiney Group)
1989-1992, Process/project manager, Dames and Moore International
1986-1989, Process technologist, then plant manager, The Associated Octel Company (Great Lakes Chemicals)
1984-1986, Site process engineer, Degremont Laing
1980-1984, Assistant environmental engineer, British Steel
Staves says the benefits of the campaign accrue not just to the communities around L'Oreal's premises. The programme's domestic focus helps to grow safety awareness among the parts of the workforce such as those in the administrative offices, where work hazards do not loom large. By exporting safety into the home "you make it personal" he believes, which in turn reinforces a culture of personal responsibility for safety, which will then have an impact at work.
Another outward-facing project with boomerang benefits was a mobile phone app developed to encourage good posture and stretching among the hairdressers who use L'Oreal's products. (The group's founder, EugÃ¨ne Paul Louis Schueller, started out selling hair dye to Parisian salons in 1909.) "That opened up the possibility for me to create an ergonomics app and website for internal use that also now goes into wellbeing and vitality," says Staves.
The centre can hold
Staves qualified as a chemicals engineer in the 1980s, rising to assistant plant manager at Associated Octel's Ellesmere Port plant in Cheshire. When the firm was being acquired by another chemicals maker, Great Lakes, the new owner sent in environment, health and safety consultants as part of the due diligence process. Staves says he refused to allow the lead consultant on site: "He had a beard and I had 150 tonnes of liquefied chlorine on the site so he wouldn't have passed the fit tests for the masks."
Far from holding a grudge, three months later the consultant poached him to work at Dames & Moore.
Working on a contract for American National Can led to him being poached again as the manufacturer's European environmental manager. He led the company's first plant through certification to the ISO 14001 in 1996. His reputation for competence in implementing management systems led American National Can to ask him to apply the same rigour to its OSH arrangements. "So this is how I 'fell' into safety," he says.
American National Can's parent company, Pechiney, then offered him the group EHS director's role based in France, which led him eventually to L'Oreal.
We don't set general rules and then let people do things in their own way
When he took up his post in 2008, safety management effort was concentrated mainly in the group's factories. "Part of my mission was to make it worldwide," he says.
Power was lent to his elbow by a highly centralised management structure, giving his small corporate OSH function direct authority to set standards globally.
This degree of centralisation is remarkable in an organisation so geographically spread.
"We don't set general rules and then let people do things in their own way to meet the rules," he says. "We are very specific in what our requirements are." Limited tweaks are allowed to adapt programmes to local culture.
Staves liaises with the heads of environment and security and says the matrix management structure gives him the flexibility to collaborate on changes without having to work solely inside the OSH hierarchy.
"Safety does not report into the CEO," he says, "and of the ten companies I've worked for it's the first where not reporting into the top isn't a restriction. It works."
Staves' team sets central policy and standards, develops safety programmes such as LIFE and the behaviour-based safety initiatives.
His function involves looking forward and developing programmes to improve safety standards and OSH competence throughout the workforce. For those in the highest echelons he developed a series of leadership and safety culture seminars with the French business school INSEAD, a programme that has expanded to admit executives from other companies.
"We don't encourage sites to buy equipment locally, manufactured to local standards, as we can't ensure that they will meet our safety requirements. Of course, local and national regulations must always be met; that's a given. All the HAZOP assessments for new machinery, for example, are conducted at corporate level and our minimum requirement for equipment in explosive atmospheres is the European requirements under [the EU] ATEX [directive].
"If you look at our line management behaviour-based safety programme, it doesn't matter where you go in the world. Whether it is here [the Clichy corporate headquarters in Paris] or our Cairo manufacturing site or our distribution centre in Australia, it is the same programme with the same KPIs."
But the risk of these requirements feeling like diktats is avoided by developing the standards in consultation with the divisional environment, health and safety directors.
The degree to which regional management was willing to cede authority to the corporate centre surprised him when he arrived ten years ago. He says when he asked for trend rates in safety metrics for the company's global regional divisions, he was told there was only basic data for the change in lost-time accidents, but no pattern analysis.
"I started looking at things and found 24% of accidents involved forklift trucks and pedestrians." The divisions knew they had a problem with forklifts, he says, but were waiting for a corporate directive to act on.
The long drop
L'Oreal's principal lagging safety measure is the number of lost-time accidents per million working hours across the group. In 2000 the rate stood at 9.7; by 2018 it was 1.1.
The steepest drop in the rate was from that 9.7 to 2.5 in the six years to 2006. What caused the fall?
Staves says it marked the abandonment of a nuts-and-bolts safety compliance approach after some serious accidents at the end of the 1990s. L'Oreal hired Zack Mansdorf as vice-president, environment, health and safety, who introduced a more systematised approach based on rigorous risk assessment, incident root-cause analysis and compliance auditing. Certification to the BS OHSAS 18001 management standard became a requirement for the factories.
After Mansdorf recruited Staves in 2008 the downward movement in the LTA rate continued, albeit with a shallower curve, since it is always harder to reduce an already low figure. Between 2008 and 2014 LTAs fell from 2.2 to 0.7 as Staves brought in behaviour-based safety programmes and spread thorough safety management beyond the factories and into the distribution centres, research and administrative sites and retail operations. He notes that the severity of LTAs also fell to the point where most accidents result in no more than a day or two off work. Staves notes this is a dangerous position; complacency could set in because employees think safety is "done" especially when around 80% of the group's 500 sites worldwide record no LTAs each year and some senior managers have not experienced a lost-time accident while working for L'Oreal.
In 2015, the LTA rate ticked back up to 1.2 and since has fluctuated between 0.5 and last year's 1.1. The variation partly reflects an increase in reporting of LTAs in the retail operations that might have gone unrecorded before. He says there is also an uptick in the company's western European factories, something that is reflected in the other industries against which L'Oreal benchmarks its rates and programmes.
Some of the rise may be also attributable to an ageing workforce, he suggests, as well the recent Operations 4.0 initiatives (see box below). The demand for automation is urgent but with new ways or working and new technology come new risks. The company has a seven-year-old global ergonomics programme which has introduced handling aids and assistive technology as well as training programmes.
The company recently convened a taskforce of workers in its European sites without senior management involvement and spent a day discussing the rise in LTAs with plans to meet again soon. "We'll see what they come up with," says Staves, "as we are open to all inputs. What matters is that people are not injured."
To add depth to the LTA metric the company also measures total recordable incidents, including those involving temporary workers, plus a simple total accident number. The final figure resonates better with non-specialists than the normalised rates, says Staves. "When you say, 'This year 100 people have gone home to their families and said they weren't going into work the next day because they had an accident working for L'Oreal', that has much more impact if you are trying to change the culture than saying our lost-time rate is 1."
The leading indicators posted for each site are the number of management visits under the MESUR behaviour-based safety programme (see opposite), the number of reports under the SIO hazard reporting scheme and a training index.
Malcolm Staves has co-authored a case study of L'Oreal's global safety programmes for a forthcoming issue of IOSH's journal Policy and Practice in Health and Safety (PPHS).
The PPHS article emphasises the success of L'Oreal's programmes, citing the fall in the lost-time accident rate to around one-tenth its 2000 level.
But Staves' co-authors, Dr Jennifer Lunt, formerly chief health psychologist at the Health and Safety Laboratory, and Andrew Weyman, a reader in psychology at the University of Bath, also note what they see as gaps in the company's arrangements.
One of these was the fact that wellbeing monitoring and management has been left primarily to L'Oreal's human resources staff rather than the OSH function, potentially splitting off part of the latter's health responsibilities.
Staves accepts that this is an area for improvement. Stress is already integrated into some activities and training initiatives by both HR and health and safety, but there is no corporate strategy. Mental health management is under review and one of Staves' priorities for 2019. A pilot training module is planned this month to help line managers to spot stress signs symptoms. This is not so they can intervene -- he is not a great fan of mental health first aid provision -- but to help managers to identify the signs both in themselves and others and then to assess the potential risks: "If I think you are stressed based on the low-level signals I see, do I want to give you a five-tonne forklift truck to drive?"
The OSH function's ergonomics programme, which has run since 2011, has a component on psychosocial factors and stress. This will soon be widened to cover the importance of good sleep, exercise and diet as contributors to wellbeing.
The title of the global safety and ergonomics manager in who reports to Staves has changed to safety and wellbeing manager. "That puts the word out there," he says.
Another gap Lunt and Weyman highlighted was the absence of worker representation on OSH steering committees. Staves says there is a reason for this.
Wherever trade unions are recognised, L'Oreal sites have union committees and safety representative committees in non-unionised sites. A member of management attends those committees to feed employees' concerns back to the organisation.
But the health and safety steering committees are separate, he says. "Health and safety steering is the responsibility of site management and I hold them accountable for the efficiency and effectiveness of the deployment of the group's programmes."
The steering committees can form subcommittees and bring in any employee if their contribution is needed, he says. "This combination works well and I see no need to combine the two into one committee."
One of Staves' biggest projects has been to redirect the attention of the group's divisions to the risks that have the highest potential severity.
"If you are in a L'Oreal factory there are a hundred safety directives that apply to you," he says.
The problem was in the lack of prioritisation of these directives. "You could be 99% compliant, which looks pretty good, but the 1% non-compliance could be in high-hazard activities."
To focus minds on critical risks, in mid-2017 the directives on activities such as driving, confined-space working, work at height and with electricity, were set apart and some rules reclassified as LIFE (short for life-changing incident or fatality event) requirements.
"We've even included slips, trips and falls," Staves says. "In our stores people falling downstairs is the area where we have the most potential to have a fatal or serious accident."
Improving management of each of the hazards in the LIFE programme is supported by its own poster campaign, communications kits issued to managers at all sites and a post-campaign check of compliance with the requirements.
"If it was driving, the manager would sit down with their team and discuss the risks of driving for work or at home," he says. "Then the team will agree on three commitments [to improve safety]."
The LIFE campaign is an opportunity to iron out the variations in approach that have developed in functions with varying risk profiles.
"A lot of people would have said, 'That's a rule that was developed for operations, it's not applicable to us in admin'. With LIFE, we have been able to reset that and say the requirements apply to every single site."
The LIFE requirements are split into two categories. LIFE 1 covers the hazards that, if not under control, could result in a fatality. By the end of September 2018 all sites had to be compliant with the LIFE 1 requirements or stop the activity that presented the risk.
LIFE 2 requirements mitigate the risk of serious injury. "We had a person who fell 5 m in India," Staves says. "He could have died, and the reason he didn't was that the first two people on the scene within 30 seconds were first aiders. They knew exactly what to do and didn't panic. LIFE 2 involves those management aspects that you need to have in place so that when you have an event like that you can react properly."
This management element extends to prevention as well, managing deviations from normal procedure before they become too severe. The prevention element sets the LIFE programme apart from some similar high-hazard rules in other companies, Staves says.
After an initial teaser to launch the programme there have been three campaigns so far. This is fewer than the originally planned three-monthly frequency would have achieved because there was an early hiatus to rethink the campaign branding.
"The image behind it was the circus," Staves explains. "If you are a circus act and you get it wrong you put your life at stake. So you have to train, you have to understand the risk."
They know they can challenge anyone and, if needed, stop activities
But in some countries the message did not take. People identified with the audience for the circus performers rather than the performers themselves and thought it was a "fun" theme.
The OSH function stopped the programme and switched the branding to use gaming dice to indicate risk, which has wider cultural acceptance.
"If you launch something and it doesn't work, even if you have done all the preparation, sometimes you need to turn round and say, 'Let's rethink it'," Staves reflects.
He adds there is a silver lining to having to change the visual messaging: "This initial reaction we got from lots of sites using the circus also had the impact of raising the profile of the campaign."
MESUR for MESUR
In response to demands from customers for faster response to new trends, L'Oreal's Operations 4.0 programme has seen it start to harness the internet of things and artificial intelligence to cut lead times and make production more agile.
Malcolm Staves has his own initiatives to exploit new technology for safety and health. For two years, he has run a virtual reality and safety contest throughout L'Oreal. Local teams around the world develop projects, many of them focused on training including for confined spaces work, hazard spotting and domestic risks, and submit them to the corporate centre. The finalists are shortlisted and present their work in Paris to a judging panel, which chooses a winner. The finalists' success is publicised throughout the group and the entries are made available to all sites.
To take advantage of technological developments outside the company, last year Staves initiated a competition titled INNSafety (Innovative Safety), based on the Dragons' Den television format in which entrepreneurs pitch their ideas to a panel.
An appeal for start-up businesses on social media to submit their OSH products brought tens of entries, which were whittled down to eight. These were invited to Paris for an event facilitated by EHS consultancy ERM and sponsored by L'Oreal, Sanofi, Procter & Gamble, Unilever, Danone, Plastic Omnium and St Gobain.
The start-ups met Staves and his equivalents in the other sponsoring businesses and around 75 invited directors from other large companies. The executives split into groups and received a half-hour presentation from each of the businesses, which pitched everything from ergonomics aids to use of artificial intelligence for detecting at-risk behaviours.
Staves says the start-ups and the directors all benefited from the event, which he plans to run again this year.
His own pick of the eight was an ergonomic tool developed by MATVISIO that has an infra-red camera to show users a real-time representation of their skeletal movements as they complete a task. L'Oreal will also use a product by HRV that compares video footage of employees wearing motion capture sensors taken on a phone or tablet against ergonomic assessment standards.
Staves is a firm believer in behaviour-based safety and has supervised the introduction of programmes for all operational levels in the group.
The line management programme is called MESUR (short for Measuring Effectively Safety Using Recognition and Readjustment). Managers undertake "MESUR visits" in pairs and ask open-ended questions about what could happen during a task that would result in injury.
"The idea is that I [the manager] try to get you to identify the risk and the solution," he says. "But in Japan that doesn't work," he adds. "If you are an operator and I ask, 'What could happen that would result in your being injured?' you will be looking to give me the reply that I want."
So, in one of the few areas where local variation from centrally ordained schemes is permitted, the MESUR visits at Japanese sites take the form of a joint risk assessment of the task by the operator and the manager to achieve the same safety dialogue.
At supervisory level the company is embedding a separate behavioural programme known as Visible Fundamentals. Here supervisors and operators conduct safety observations using golden rules that they have developed for their team or department.
All employees are also encouraged to participate in the Safety Improvement Opportunity (SIO) scheme, which encourages them to flag hazards and suggest improvements to procedures or workspaces.
Training for senior and line managers uses the ABC method, which explores the antecedents of any behaviour, the behaviour itself and then its consequences, and the PIC/NIC technique, developed by psychologist Dr Aubrey Daniels. This classifies behaviour according to whether its consequences are positive or negative, immediate or in the future, and are certain or uncertain. "We prefer to use positive reinforcement," Staves says, "but sometimes the consequences need to be more negative, for repeated non-compliance with a safety rule, for example."
The behavioural safety training is accompanied by sessions on interpersonal skills to give individuals the confidence to speak up about unsafe behaviour or to get the best out of MESUR conversations.
"It creates a culture where people do know how important safety is," Staves says, "and they know they can challenge anyone and, if needed, stop activities."
Staves measures the behavioural schemes' success by the fact that last year they generated 72,000 improvement actions from employees and 93% were followed up and resolved by the year end. Sites that fall below a 90% close-out rate are identified at corporate level and leaned on by the regional safety directors.
Those employee actions form the base of a set of interventions including the LIFE programme, accident root cause analysis, the efforts to improve emergency response and comprehensive risk assessments that all combine to create a strong defence against safety failings.
At the current low accident rate that the company has reached through almost 20 years of improved controls and tighter management systems, the LTAs are less often due to technical deficiencies than to individuals making the wrong judgement in the moment, he says. So all the cultural initiatives, from the behavioural safety programmes to the [email protected][email protected] campaign are designed to close the last gap and win hearts and minds.
"We've laid the foundations and built the house," says Staves. "The next step is to give sense to people as to why safety is important to them and to do this we need to make safety personal for everyone working on our sites."