Safety Science 72 (2015) 55–65

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Occupational health and safety management in municipal wastecompanies: A note on the Italian sector

http://dx.doi.org/10.1016/j.ssci.2014.08.0020925-7535/� 2014 Elsevier Ltd. All rights reserved.

⇑ Corresponding author. Tel.: +39 050 883974 (O), mobile: +39 3498612683, +393453978215; fax: +39 050 883936.

E-mail addresses: m.battaglia@sssup.it (M. Battaglia), emilio.passetti@sssup.it(E. Passetti), frey@sssup.it (M. Frey).

Massimo Battaglia ⇑, Emilio Passetti, Marco FreyInstitute of Management, Scuola Superiore Sant’Anna, Piazza Martiri della Libertà, 24, 56127 Pisa, Italy

a r t i c l e i n f o

Article history:Received 10 April 2014Received in revised form 25 June 2014Accepted 9 August 2014

Keywords:Occupational health and safetymanagement systemMunicipal waste management companiesEnvironmental hygiene sectorItaly

a b s t r a c t

The environmental hygiene sector is a high risk industry in terms of the public health and safety ofemployees. This study analyses the level of maturity of the occupational health and safety (OHS) manage-ment system in municipal waste companies in Italy. The results show that the training and involvementof employees and operational activities are the most developed aspects, while OHS policy and perfor-mance measurements need further improvement. Overall companies have a sufficiently developed levelof maturity in terms of their OHS management system. An analysis of contextual factors reveals thatorganisational factors are more correlated with the OHS management system maturity level than exter-nal factors. Companies located in the south of Italy have a low level of maturity in terms of OHS manage-ment. Audits by public authorities exercise a punitive role and legislative pressure is not considered by allthe companies as a key factor in OHS development.

� 2014 Elsevier Ltd. All rights reserved.

1. Introduction

OHS in the workplace influences the private and social lives ofindividuals. The aim of health and safety management is toimprove working conditions and peoples’ health in the work place.The effectiveness of OHS management depends on managerial, cul-tural and normative factors (EU-OHSA, 2010). All organisationshave a moral obligation to ensure that employees and all otherpeople affected by the company’s actions remain safe at all times(Miller and Haslam, 2009). Legal reasons for OHS managementrelate to the preventative, punitive and compensatory effects oflaws that protect workers’ safety and health (Hale et al., 2013).OHS management can reduce costs related to injury and illnessamong employees, including medical care, sick leave and disabilitybenefit (Tappura et al., in press). OHS management can alsoincrease (or decrease) a company’s reputation and its image amongstakeholders (EU-OHSA, 2010). Several studies have been carriedout to verify the effectiveness and the effects of OHS managementand of the related managerial system; for example, the relationshipbetween OHS management and company performance(Fernández-Muñiz et al., 2009), the integration of OHS aspects intocompany culture (Granerud and Rocha, 2011). Furthermore, it has

also been underlined the importance of analysing the associationbetween OHS management and contextual factors in order to iden-tify organisational and environmental conditions linked to OHSmanagement (Rosness et al., 2012).

OHS management has also been examined in different sectors(McDonald et al., 2000; Parejo-Moscoso et al., 2013). OHS manage-ment in the environmental hygiene sector on the other hand, hasrarely been investigated despite the fact that employees who workon the road are exposed to different risks caused by chemical, bio-logical, physical agents that influence their health and safety(Kuijer et al., 2010; Giusti, 2009). In the environmental hygienesector, waste collection and road sweeping can be performed inmany ways (Seadon, 2010). Collection activities may be manual,aided by machinery that can pick up great loads, completelymechanised or mechanised with the aid of workers (Kuijer andFrings-Dresen, 2004). Although the workers themselves performthe same duties, the work environment can change drastically ona daily basis and even during the same day, due to the changeableconditions of the outdoor environment. As such, workers are sub-ject to risks from work on the road and from machine-interactions(INAIL, 2009). The lack of OHS management studies in the environ-mental hygiene sector contrasts with the medical and epidemio-logical literature, which classify the environmental hygienesector as high risk with regard to health and safety problems.

In light of the above considerations, our study analyses: (1) thelevel of maturity of OHS management of municipal waste compa-nies, and (2) whether contextual factors influence this level. The

56 M. Battaglia et al. / Safety Science 72 (2015) 55–65

analysis was carried out through surveys on a sample of 29 wastemanagement companies and through 10 direct interviews. Theresults demonstrate a sufficiently developed level of maturity ofOHS management and the influence of organisational factors onits maturity. This paper contributes to the OHS management liter-ature by empirically addressing OHS management in the previ-ously neglected sector of environmental hygiene, and the factorsassociated with the development of OHS management.

The paper is structured as follows: Section 2 presents the theo-retical context and the research hypothesis. Section 3 describes thedata collection and research design. Section 4 analyses the results.In Section 5, the discussion, limitations and future research oppor-tunities are presented.

1 Forms of contingency can be divided between Cartesian and Configurationapproaches (Donaldson, 2001). The Cartesian approach is characterised by reduc-tionism, while the Configurational approach takes a holistic view. The two approacheslead to divergent opinions about what constitutes a fit and how a fit is attained(Gerdin and Greve, 2004). The Cartesian approach seeks to understand organisationsby analysing their constituent parts separately. The focus is on how individualcontextual factors affect individual structural attributes and the fit between contextand structure is a continuum that allows frequent, small movements by organisationsfrom one state of fit to another. Each level of a contingency variable fits with a level ofstructural variable and they provide stepping-stones for organisational growth(Donaldson, 2006). The Configuration approach considers that the parts of anorganisation take their meaning from the whole and cannot be understood inisolation (Meyer et al., 1993). Relationships can only be understood if manycontextual and structural variables are analysed simultaneously (Drazin and Van deVen, 1985). The Configurational approach underlines the idea of radical change ortransformation. It claims that organisations can be conceived as configurations, orconstellations, of tightly integrated elements (Demers, 2008).

2. Hypotheses development

An OHS management system is a set of policies, strategies, prac-tices, procedures, roles and functions associated with safety(Fernández-Muñiz et al., 2007). OHS management system stan-dards, such as CSA Z1000-06 and BSI OHSAS 18001-07, define man-agement systems as, respectively:

� A set of interrelated elements to establish and support an OHSpolicy, its objectives and targets, and the means to achieve them(CSA Z1000-06);� Part of the overall management system that facilitates the man-

agement of the OH&S risks associated with the business of theorganisation. This includes the organisational structure, plan-ning activities, responsibilities, practices, procedures, processesand resources for developing, implementing, achieving, review-ing and maintaining the organisations’ OH&S policies (BSIOHSAS 18001-07).

Implementing an OHS management system is the most efficientway of allocating safety resources for, since it not only improvesworking conditions, but also positively influences employees’ atti-tudes and behaviours as well as promoting a culture of safety (Torpand Moen, 2006; Vredenburg, 2002). Bottani et al. (2009) showthat companies with a more mature OHS management systemhave obtained a better health and safety performance than compa-nies without a system or with a less mature level. An OHS manage-ment system stimulates and enables the inclusion of OHS issues inordinary company management. Fernández-Muñiz et al. (2009)show that a more mature OHS management system reduces therate of incidents and the amount of damage to people, machineryand material, thus enhancing working conditions and employeesmotivation. An OHS management system can raise a company’scompetitiveness because it has a positive effect on the image, rep-utation, productivity and innovation. Robson et al. (2007) indicatethat both voluntary and mandatory OHS management systemshave a positive effect on safety climate, safety performance, pro-ductivity and costs of accidents.

OHS management has become important in companies’ andorganisations’ codes of ethics over the past 20 years (Chen andZorigt, 2013). However, various factors can aid or obstruct theimplementation of an OHS management system (Grote, 2012).According to the contingency theory, which views a company asan open system, there is no best way to organise and to lead a com-pany, or to make decisions. Instead, the optimal course of action iscontingent (dependent) upon the internal and external situation.Company processes, systems and decisions are linked to contin-gency factors such as the competitive environment in which thecompany operates, the technology it adopts, and the level of envi-ronmental uncertainty (Grote, 2012; Rosness, 2009). Therefore, theeffective structural design of the organisation is where the struc-

ture fits the contingencies (Donaldson, 2001). This implies that itis also unlikely that there will be a single best approach to OHS thatis equally optimal for every company, but that the approach whichis taken in each case will depend on the specific situation.

In the literature on OHS management, a few studies havereferred to the concepts associated with the contingency theoryand the related contextual factors (Arocena and Nuñez, 2009;Bottani et al., 2009; Fernández-Muñiz et al., 2007, 2012; Ismailet al., 2012; Vinodkumar and Bhasi 2011). For example, Chen andZorigt (2013) analyse five factors (act and regulation, stakeholderpressure, investment, integrated OHS and organisational culture)that influence the implementation of occupational health andsafety management in mining companies. Vinodkumar and Bhasi(2011) empirically investigate the influence of certified manage-ment systems on the relationship between OHS management andsafety performance in sectors of the chemical industry that havea significant risk of accidents. Their analysis suggests that employ-ees of OHSAS 18001 certified companies, ISO 9001 certified compa-nies, and those with no certification, perceive different levels ofsafety. Specifically, management commitment, employee training,communication and feedback and rules and procedures, whichrepresent four of the six OHS management practices envisagedby the OHSAS 18001 certification, stimulate proactive conduct.

This low number of studies implies a lack of knowledge of thecontextual factors that are important determinants of the effec-tiveness of safety intervention, and a lack of consensus on the tax-onomy of relevant contextual factors. Rosness et al. (2012) call formore studies investigating the relationship between contextualfactors (or synonymous concepts) and safety at work. Furthermore,theoretical insights from an organisational perspective could alsohelp refine and improve current health and safety specialist knowl-edge (Zanko and Dawson, 2012).

Therefore, considering Taylor et al.’s (2011) taxonomy of con-textual factors, we focus on organisational characteristics (OHSavailable budget, employees and trade union pressure, geographi-cal location); external factors (market stakeholder pressure, legis-lative pressure and public authority audits) and the availabilityof implementation and management tools (OHSAS 18001 certifica-tion), as highlighted in Fig. 1. We adopt a Cartesian approach sincethe implementation of OHS management systems requires incre-mental changes (Granerud and Rocha, 2011), rather than the radi-cal change that the configuration approach postulates.1

2.1. OHS available budget

Investment is a key driver for implementing and ensuring effec-tive occupational health and safety management. For example,financial support by governments has contributed substantiallyto OHS projects. The growing use of OHS management systems

Organisational characteristics

OHS available budget

Employees and trade union pressure

Geographical location

External Factors

Market stakeholder pressure

Legislative pressure

Audit by public authorities

Management tools

OHSAS 18001 certification

OHS management system

OHS policy

Training and involvement

Operating activities

Performance measurement

Fig. 1. Contextual factors and their relationship with OHS management systems.

M. Battaglia et al. / Safety Science 72 (2015) 55–65 57

highlights the significant investment of financial and humanresources by both governments and companies (Chen and Zorigt,2013). A specific budget (economic resources) dedicated to OHSmay indicate that a company considers OHS to be as importantas other company activities and thus lead to a greater commitmenton the part of management.

Investments in OHS generate positive economic returns. Studieshave reported that employers investing in workplace health andsafety can expect a reduction in fatalities, injuries, and illnesses.This could result in cost savings such as the lowering of workercompensation costs and medical expenses, avoiding legal penal-ties, and reducing the costs of training replacement employeesand conducting accident investigations. In addition, employersoften find that investments in workplace health and safety resultin significant improvements in productivity and financial perfor-mance (Huang et al., 2007, 2011).

Thus, hypothesis H1 indicates that:

H1. There is a positive relationship between the presence of aspecific budget dedicated to OHS management and the maturitylevel of the OHS management system.

2.2. Employees and trade union pressure

Increasing the health and safety of employees is the main aim ofan OHS management system. To ensure the success of OHS actions,the International Labour Office guidelines (ILO-OSH, 2001) encour-age the continual improvement in employee health and safety,achieved via a constant process of policy-making, organisation,planning and implementation, evaluation, and improvements, allsupported by constant auditing. Employees have the knowledgethat makes it possible to diagnose problems and design new formsof OHS intervention, and their influence on OHS management hasincreased (Kristensen, 2011). Frick (2011) discusses a series of fac-tors that facilitate or obstruct the development of a voluntary OHSsystem. These factors include management commitment, involve-ment of employees and pressure from trade unions. Torp andGrøgaard (2009) demonstrate that employee compliance withOHS routines and instruction and the maturity level of an OHSmanagement system is positively and significantly correlated. Theyalso show a positive and significant correlation between the per-centage of unionization and the maturity level of an OHS manage-ment system.

Thus, hypothesis H2 indicates that:

H2. There is a positive relationship between the degree ofemployee and trade union pressure and the maturity level of theOHS management system.

2.3. Geographical location

Italy has large regional disparities created by historical andpolitical factors (Battaglia and Iraldo, 2011; Terrasi, 1999). Forexample, in northern and central regions of the country, incomeis much higher, as is the employment rate especially amongwomen. The quantity and quality of business activities also varyaccording to geographical location, and companies that operatein the north, centre and south have different levels of performance(KPMG, 2010). Companies located in the south of Italy have fewermanagerial skills compared with companies in the centre andnorth (Daniele and Malanima, 2011). For example, Perrini et al.(2007) show that companies in the south of Italy implementedfewer socially responsible initiatives compared with companiesin the centre and north. Thus, hypothesis H3 indicates that:

H3. There is a positive association between companies located inthe north and centre of Italy and the maturity level of the OHSmanagement system.

2.4. Market stakeholder pressure

Reasons for implementing an OHS management system can bedivided between those that establish relations and legitimacy ver-sus economic benefits, and those that promote internal proactiveseeking incentives versus external-reactive avoidance of disincen-tives (Frick, 2011).

Companies need to respond to external stakeholders whorequire more transparency with regard to working conditions,environmental and social impacts and ethical conduct (Epsteinand Buhovac, 2006; Montero et al., 2009). External stakeholdersare increasingly concerned with how OHS issues are measured,monitored and reported because an ineffective OHS managementhas a negative impact at the society level (EU-OHSA, 2010). Assuch, pressure from an increasingly complex external context hascreated a situation in which companies must change their conductin relation to other companies, the local community and customers(Kristensen, 2011). For example in the environmental managementliterature, pressure from external stakeholders, such as customerand suppliers, has been shown to positively influence the manage-ment of environmental variables (Buysse and Verbeke, 2003) andenvironmental management practices (Testa et al., 2012). TheOHS literature demonstrates that a more mature OHS managementsystem can improve the company’s image and reputation amongexternal stakeholders (Fernández-Muñiz et al., 2009). Thus, pres-sure from market stakeholders may encourage companies toimplement a more advanced OHS management system.

Therefore, research hypothesis H4 is:

58 M. Battaglia et al. / Safety Science 72 (2015) 55–65

H4. There is a positive relationship between the degree of marketstakeholder pressure and the maturity level of the OHS manage-ment system.

2.5. Legislative pressure

Safety legislation requires ensuring the safety, health and wel-fare of workers and to manage and conduct all work activities insuch a way as to guarantee their safety, health and welfare. Thisrequires all those with a legal responsibility in business activitiesto be proactive in managing their safety, health and welfare respon-sibilities and to deal with them in a systematic way. Compliancewith legislation has traditionally been a key factor in influencingthe adoption of health and safety management practices (HSE,1998). Arocena and Nuñez (2009) and Torp and Grøgaard (2009)suggested that legislative compliance influences the implementa-tion and improvement of an OHS management system. In Italy,health and safety legislation (d.lgs 81/2008) requires companiesto identify and remove causes of risk and to define an organisationalstrategy, based on technology integration and operational activities,in order to reduce health and safety risks in the workplace.

Thus, research hypothesis H5 is:

H5. There is a positive relationship between the degree oflegislative pressure and the maturity level of the OHS managementsystem.

2 Federambiente is the Italian Trade Association of Environmental Hygiene in thePublic Services.

2.6. Audit by public authorities

Public authorities have a legal mandate to govern, manage andmonitor aspects of public life such as environmental, and healthand safety issues. Regarding OHS issues, public authorities have akey role in implementing constructive compliance strategies, pro-viding guidance on hazard identification and risk control (Bassoet al., 2004). They carry out inspection and enforcement activitiesfocusing on poor-performing industrial sectors and organisationsand work with employers to improve workplace health and safety.In doing so, they analyse specific hazards that pose serious risksand causes of injury (WorkSafe Victoria, 2012). Thus companiesthat undergo routine, effective, critical and unbiased audits bypublic authorities have more likely to have effective OHS manage-ment systems because public authority auditors can provide themost up-to-date information.

However public authorities, particularly in Italy, often operatewith scarce resources. They thus need to prioritise which compa-nies to audit. For example, they may focus on companies that showunsatisfactory levels of health and safety in order to stimulate bet-ter management, and opt for fewer checks of companies with agood health and safety record. In fact, good safety performancestend to linked to a more mature management system(Fernández-Muñiz et al., 2009; Goh et al., 2012). A more maturemanagement system provides a greater set of guarantees foremployees and external agents. It guarantees the existence of anactive surveillance committee and of a reporting system throughwhich managerial activities and performances are documentedand assessed. It also foresees the implementation of internal auditsaimed at verifying and improving the normative compliance, aswell as enabling a greater public disclosure of the results achieved(EU-OHSA, 2010; Vredenburg, 2002). In sum, public authoritiesmay carry out fewer (more) checks on companies with effective(ineffective) OHS management systems and good (bad) healthand safety performances, focusing their attention and resourceson poorer-performing firms.

Thus hypothesis H6 is:

H6. There is a negative (inverse) relationship between the numberof audits by Public Authorities and the level of maturity of the OHSmanagement system.

2.7. OHSAS 18001 certification

Company certification of OHSAS 18001, the OHS managementsystem standard, has been increasing rapidly (Salomone, 2008).The primary goal of OHSAS 18001 is to foster good practice andthe structured management of health and safety issues. Certifica-tion also has a number of strategic and competitive implications,since it is intended to help organisations guarantee the existenceof an appropriate OHS management system to the parties con-cerned. Its implementation is designed to improve work conditionsand reduce risks, both personal and material, thereby protectinghuman capital and a company’s reputation (Sánchez-ToledoLedesma et al., 2009). As such, the presence of a third party certi-fication which is effectively integrated within the managementcontrol system improves a company’s management and perfor-mance (Buhr and Gray, 2012). A previous study indicates that theimplementation of an OHS management system, including theattainment of OHSAS 18001 certification, encourages the integra-tion of OHS aspects into daily company management (Bottaniet al., 2009; Fernández-Muñiz et al., 2012).

Thus hypothesis H7 is:

H7. There is a positive relationship between OHSAS 1800 certifi-cation and the maturity level of the OHS management system.

3. Data collection and construction of the variables

3.1. Data collection

The environmental hygiene sector is a high risk sector for indi-viduals and public health (Giusti, 2009). A seminal study con-ducted by An et al. (1999) shows that whilst injury rates for allindustrial workers in Florida decreased from 1993 to 1997, theinjury rates of council workers in the solid waste departmentalmost doubled in the same period. Bunn et al. (2011) found thatwaste collection is one of the occupations with the highest riskfor injuries and illnesses. A study in the UK covering the period2001/2002 (HSE, 2004) showed that the overall accident rate forthe environmental hygiene sector is around four times the nationalrate, the fatal injury accident rate is ten times the national rate, andthe severity rate is more than three times the national rate. Thesame study highlighted a series of risks to which municipal wastemanagement workers are exposed, such as manual handling, slipsand trips, and workplace transport.

In the environmental hygiene sector in Italy, the overall acci-dent rate has been decreasing since 2006 despite an increase inthe number of workers. In 2012, the severity rate stood at halfthe national average, while the frequency of injury and accidentswas four times the national rate. The level of turnover of operatingstaff is also low, with an average level of seniority of 14 years. Thus,health and safety costs can increase over time, as the length of timethat workers are exposed to risks increases along with their age(Federambiente, 2012).

To carry out our research, data were initially collected throughan e-mail questionnaire. Company selection started with a sampleof 221 companies associated with Federambiente.2 From the initialsample, companies were selected according to two main criteria.

M. Battaglia et al. / Safety Science 72 (2015) 55–65 59

The first criterion combined the company dimension with the size ofthe geographical area where the activity is carried out. Companieswere divided into large companies, operating over large areas andwith over 500 employees, and medium/small companies, coveringsmaller areas and with less than 500 employees. The second crite-rion refers to geographical location. The companies were subdividedbetween those located in the northern regions of the country, thosein the centre and those in the south. At the end of the sampling pro-cedure, 60 companies were selected.

The questionnaire was pre-tested by a small group of academicsand managers in order to verify the questions and their measure-ment methods. This verification led to minor changes in the word-ing of the sentences. Questionnaire was composed of threesections. The first section asked general information regardingthe characteristics of the respondent (job experience, job positionand sex) and the company (size and geographical localisation).The second section analysed the contextual factors, and the thirdsection focused on health and safety management. As indicatedin Section 3.2, the design of the questions was mainly derived fromprevious studies. The questions in the third section were adaptedfrom another study, the questions in the second section weremixed (some were adapted and others newly designed), whilethe questions in the first section were designed from scratch.

Questionnaires were managed in collaboration with the Fondaz-ione Rubes Triva .3 The direct involvement of the Foundation was keyin promoting our research among companies in order to encourage ahigh response rate (Dillman, 2007). The Foundation contacted thecompanies by telephone in order to present the research and verifytheir interest in participating. Health and safety offices were identi-fied as the optimal respondent, given the key role played in OHS man-agement. During the telephone contact, all 60 companies confirmedtheir participation. Subsequently, the questionnaire was sent by e-mail together with a letter presenting the study. In line withDillman’s (2007) study on the recommendations for follow-ups, threeweeks after the first telephone contact, the companies were contactedby telephone with a reminder, and then again 10 days later.

A total of 29 questionnaires were returned - a response rate of48.3%. The companies who responded to the questionnaire coveredjust under 65% of the Italian territory, and represent more than halfof the total number of employees in the waste management sector.The questionnaires were initially checked to verify their level ofcompleteness, from which it emerged that three questionnaireswere incomplete and thus further clarifications were requested.In addition, in order to verify the reliability of the respondents,the characteristics of the respondents (size and geographical loca-tion) were compared with the characteristics of the companieswho did not respond. The check showed that the ‘‘non-respondent’’category was not substantially different from the responding com-panies. Therefore, the sample was considered as reliable for thestudy.

The average experience of the respondent was around six years,thus ensuring their ability to respond fully to the questionnaire.Twenty-two respondents were health and safety managers, sixwere OHS office heads, and one was the CEO. All the 29 companiesperformed waste collection activities, 16 hazardous waste trans-port, 23 waste storage, 19 disposal of non-hazardous waste, and8 hazardous waste disposal. All were publically owned.

In the next phase, interviews were conducted to extend theanalysis of the two research questions and the results of the survey(Creswell and Clark, 2007). The characteristics of four dimensionsof an OHS management system, the strengths and weaknessesand its possible association with contextual factors were the focus

3 Fondazione Rubes Triva is a National Foundation for health and safety manage-ment in the waste management sector. It aims to promote proactive policies andinitiatives to increase health and safety in the workplace.

of the semi structured interviews. Of the 29 respondent companies,10 agreed to participate. Confidentiality was ensured prior to eachinterview. The interviews were semi-structured and composed ofquestions based on survey results. The interviews lasted from 30to 60 min, with a combined length of about 8 h. During the inter-views one researcher conducted the interview while another tooknotes. The notes were analysed by the researchers through an iter-ative process of manual elaborative coding in order to identify themost important information on OHS management systems(Auerbach and Silverstein, 2003).

3.2. Construction of the variables

In order to identify the relevant dimensions for the creation ofan OHS management system the Deming -Plan, Do, Check, Act-(PDCA) approach was chosen. It was divided into four main dimen-sions: OHS policy and improvement planning; training andinvolvement; operating activities; performance measurement.4

For each of the four dimensions, specific questions were posed.The companies were requested to express a judgement, using theLikert scale from 1 (low) to 5 (high), on the perception of the levelof implementation of the OHS management system.

Regarding OHS policy, it was formulated by modifying the pro-tocol defined by Fernández-Muñiz et al. (2007, 2009) to measurethe ‘‘safety policy’’ variable. The respondents were asked to indi-cate the level of formalisation of a series of activities related toOHS planning. OHS training and involvement was constructed byadapting the protocol used by Fernández-Muñiz et al. (2007,2009) to measure the ‘‘employee incentives’’ and ‘‘training in occu-pational hazard’’ variables. The respondents were asked to indicatethe level of formalisation of a series of activities connected to train-ing and employee involvement.

The dimension -analysis of operating activities- was defined byadapting the protocol used by Fernández-Muñiz et al. (2007,2009), referring to ‘‘preventive planning’’. Respondents were askedto indicate the level of formalisation of the procedures and activi-ties. Finally, the measurement of OHS performance measurementvariable was adapted by the protocol used by Fernández-Muñizet al. (2007, 2009) using the ‘‘internal control’’ variable. In orderto verify the validity and reliability of the variables used to mea-sure the OHS management system, a principal components analy-sis was carried out and Cronbach’s alpha was calculated. Thevalues of the tests indicated in Table 1 were in line with the criteriain the literature (Hair et al., 1998).

In order to analyse the contextual factors, the question related tostakeholder pressure was formulated by adapting the protocol usedby Banarjee et al. (2003). The respondents were asked to indicate,using the Likert scale with values from 1 (no influence) to 5 (stronginfluence), what importance they placed on the influence of stake-holders on OHS management. There were two specific questions:one for employees and trade union and one for market stakeholders.

For the legislative pressure related to OHS, the same protocol byBanarjee et al. (2003) was adapted to formulate the question.Respondents were asked to indicate, using the Likert scale with val-ues from 1 (no influence) to 5 (strong influence), to what extent theyagreed with the role that OHS legislation had on management prac-tices adopted by their company. In order to verify the quality of theconstruct, PCA (PL_1 = 0.71; PL_2 = 0.77; PL_3 = 0.82) and Cron-bach’s Alpha (0.72) were used. Both checks demonstrated satisfac-tory results, in line with the criteria indicated in the literature.

To measure the number of inspections from public authorities(audits by public authorities) companies were asked to indicatethe number of checks received by public authorities in the previous

4 The main questions are showed in Appendix A.

Table 1Reliability and validity of OHS management system dimensions.

OHS policy Training and involvement Operating activities Performance measurement

Cronbach’s alpha 0.81 0.74 0.80 0.75SSL_PO_1 .581 .018 �.571 .031SSL_PO_2 .713 �.452 �.089 .131SSL_PO_3 .782 �.120 �.281 .089SSL_PO_4 .601 .140 �.321 �.112SSL_PO_5 .845 �.112 �.250 .248SSL_F_1 �.001 .759 �.201 �.396SSL_F_2 .398 .789 �.089 .315SSL_F_3 .043 .742 .169 �.237SSL_F_4 .201 .613 .201 .145SSL_AO_1 .301 .296 .773 �.050SSL_AO_2 �.232 .384 .640 �.201SSL_AO_3 �.487 .435 .689 �.080SSL_AO_4 .287 .110 .603 .106SSL_AO_5 .134 �.181 .813 �.174SSL_PE_1 �.089 �.580 .289 .591SSL_PE_2 �.198 �.480 .372 .614SSL_PE_3 .195 .066 .073 .712SSL_PE_4 .180 �.390 �.297 .561SSL_PE_5 .401 .119 �.201 .749

Table 2Maturity levels of OHS management systems.

OHS policy Training and involvement Operating activities Performance measurement

Written plan of the policy 3.30 Use of project team 3.01 Presence of operating instructions 3.69 Measurement of results 2.72Measurable objectives and

goals3.35 Employee training 4.10 Job position analysis vs. level of risk

analysis3.87 Monitoring of indicators 3.59

Tools for internalcommunication

3.01 Updating of training plan 3.45 Training for high risk jobs 3.95 Registering of accidents and nearaccidents

3.31

Employee involvement 3.41 Planning of trainingactivities

3.91 Presence of emergency procedures 3.77 Accident analysis 3.50

Comparison objectives/results

3.20 Updating of emergency procedures 3.76 Internal audits 3.62

Average value 3.25 Average value 3.61 Average value 3.80 Average value 3.34OHSMS average value 3.50

60 M. Battaglia et al. / Safety Science 72 (2015) 55–65

three years. Geographical location was measured using the legalheadquarters of the company and the geographical area in whichit operates. This variable was measured with a dummy variable:0 was assigned to companies located in the south and on theislands and 1 to companies located in central and northern Italy.Similarly OHS available budget was also measured with a dummyvariable with 0 if the company did not have specific economicresources for OHS issues, and 1 if the company had specific eco-nomic resources for OHS issues. Finally, the companies were askedwhether they possessed an OHSAS 18001 certification. The answersfor this last question were then verified through the websitewww.accredia.it, which includes the names of all certified compa-nies operating in Italy. In the questionnaire respondents were alsoasked to indicate how many years ago the certification had beenobtained.

4. Analysis of the results

The survey results showed that the average level of maturity ofOHS management system was 3.50, with a minimum value of 2.30and a maximum value of 4.64. As indicated in Table 2, the «operat-ing activities» had the highest average value (3.80), followed by«training and involvement» (3.61), «performance measurement»(3.34) and «OHS policy» (3.25). Operating activities and «trainingand involvement» were the most mature dimensions. Operatingactivities was the most mature dimension because workers aresubject to significant safety risks while working on the street. Inthe words of one interviewee, risks analysis is ‘‘continuouslyimproved and tailored for each specific task’’ (Interview 5). Training

was carried out continuously to provide the employees with thenecessary knowledge to protect themselves on the job. It was nec-essary to ‘‘raise awareness and promote the adoption of correct con-ducts by the workers’’ (Interview 3) and to ‘‘create a sharedunderstanding on specific topics’’ (Interview 6).

On the other hand, «OHS policy» maturity is instead hindered insome companies by the fact that OHS is perceived as a specialisedactivity. In contrast, in other companies OHS policies receivedmore attention by senior management (Miller and Haslam,2009). The maturity level of the performance measurement wasvery low. Companies measured their performance through ex-postindicators (severity rate and frequency rate) and the use of leadingand early warning indicators were not taken into consideration(Øien et al., 2011a,b). Some companies analysed accidents by geo-graphical area, age, role and job shifts but they were lagging indi-cators. No companies had a cost-benefit analysis to facilitate safetyinvestments, and incentive systems were often not linked withOHS performance evaluations. ‘‘We use the information to supportex-post analysis but we should direct our information towards ex-antedecisions’’ (Interview 2).

Pearson correlations (Table 3) indicate that the level of maturityof the OHS system was positively correlated with the influence ofemployees and trade union (b 0.610, p < 0.01), thus confirminghypothesis H2. The correlation was positive for «training andinvolvement» (b 0.667, p < 0.01) and «operating activities» (b0.703, p < 0.01), but not for «OHS policy» (b 0.393, p > 0.10) nor«performance measurement» (b 0.519, p > 0.10). Legislative pres-sure had no influence on the maturity of the OHS management sys-tem (b 0.143, p > 0.10) and indicated that companies do notconsider that legislation is capable of influencing the maturity level

Table 3Pearson correlation between management system and contingent factors.

Organisational characteristics External factors Management tool

Budget ETUP GL MSP LP APA OHSAS 18001

OHS policy 0.331 0.393 0.701** 0.101 0.126 �0.387 0.745**

Training and involvement 0.099 0.667** 0.600** 0.187 0.289 �0.639** 0.535*

Operating activities 0.145 0.703** 0.701** 0.185 0.400 �0.499* 0.524*

Performance measurement 0.321 0.519 0.780** 0.130 0.280 �0.401 0.540*

OHSMS 0.257 0.610** 0.801** 0.156 0.143 �0.589* 0.691**

Budget, OHS available budget; MSP, market stakeholder pressure; ETUP, employees and trade union stakeholder pressure; LP, legislative pressure; APA, audits by publicauthorities; GL, geographical location; OHSAS 18001, OHSAS 18001.

* The correlation in significant at a level of 0.05 (2-code).** The correlation in significant at a level of 0.01 (2-code), n = 29.

8 These three points emerged during the interviews.9 The average number of implementation years of OHSAS 18001 was 3.6.

10 Of the total sample, just eight companies had an OHSAS 18001 certification.11 Cohen’s d test is an index that measures the significance of the difference

between the mean. It our case it verifies whether there are significant differencesbetween groups of companies in terms of the level of maturity of the managementsystem in relation to various contextual factors. The validity of the test does notdepend on sample size. It is calculated as the difference between M1 and M2, divided

M. Battaglia et al. / Safety Science 72 (2015) 55–65 61

of OHS management systems. Thus, hypothesis H5 was not signif-icant and therefore not confirmed. In this regard, the interviewsindicated that legislative pressure was perceived as the necessarycondition which in some cases drove companies to develop proac-tive safety practices. In addition, moral duties towards the employ-ees and the possibility of improving safety performance andconsequently of legitimizing health and safety results were consid-ered more important than legislative pressure.

The interviews highlighted that the continuous improvement inOHS management systems requires a specific plan and focus bysenior management and in particular more awareness of theimportance of health and safety in some areas such as accountingand finance departments. Other barriers included the inadequateamount of financial resources to allocate to OHS management sys-tems and the demanding tasks required by routine OHS manage-ment activities. We found that 50% of the companies had nodedicated economic resources for OHS management, which mayexplain why H1 was not confirmed (b 0.257, p > 0.10). Almost allof the interviewees indicated that the amount of financial invest-ments made in previous years was not able to satisfy all the OHSchanges needed. Furthermore, government funding was indicatedas a source used in previous years for OHS investments.5

Market stakeholder pressure was not perceived as a key factor (b0.156, p > 0.10) and thus hypothesis H4 was not confirmed. Thisresult could be explained by the nature of waste management ser-vices, which does not involve competitive relationships with themarket. In the waste management sector, which is a regulated indus-try by specific laws, the service beneficiaries are individual citizenswho pay annual tariffs to receive waste management services andwho may be more interested in the quality of the service providedrather than OHS issues. The interviews also highlighted the exis-tence of a continuous dialogue with market stakeholders focusedon the efficiency and effectiveness of waste management services.

The role of public authorities was significant, confirminghypothesis H6. The results indicate a negative and significant cor-relation between the OHS management system and the number ofpublic audits received by companies (b 0.156, p < 0.05), confirmingthat there are more audits when the system is less structured. Theinterviews confirmed that control by public authorities was greaterin companies with more accidents and with less attention onsafety requirements.6 Of the four dimensions, «training and involve-ment» showed the most significant correlation (b 0.639, p < 0.01).Employee training has been given close attention by regulators since1990 (see for example the European Directives on OHS)7 and compa-

5 Since 2012, the Italian National Social Authority (INAIL) has provided economicincentives for companies to obtain the OHSAS 18001 certification. From a policyperspective, the OHSAS 18001 is considered as a driver to improve OHS management.

6 The mean number of Public Authority audits in companies is 8.63.7 Some examples are: 89/391/CEE, 90/270/CEE, 93/88/CEE, 95/63/CE, 97/42/CE, 98/

24/CE, 99/38/CE, 2001/45/CE, 2003/10/CE, 2004/40/CE, 2005/47/EC, 2006/15/EC,2009/104/CE, 2010/32/EU.

nies with a high focus on training and involvement have been per-ceived as being more sensitive to reducing risks to workers and,therefore, have been less subject to controls by local authorities.

The correlation for geographical location was significant (b0.801, p < 0.01). Between companies located in the north and cen-tre and companies in the south there were notable differences forall four dimensions of OHS management system, thus confirminghypothesis H3. A proactive management of OHS in southern Italyis negatively influenced by a lack of managerial culture and knowl-edge on the topic, by the absence of economic resources for invest-ments and also by the (negative) influence of political parties on acompany’s conduct.8 Finally, we found a positive correlation ofOHSAS 18001 on the maturity of a OHS management system (b0.619, p < 0.01), confirming hypothesis H7.

As with geographical location, OHSAS 18001 had a positive cor-relation with all four dimensions of the management system.9 Theinterviews highlighted that OHSAS 18001 certification was initiallyused for accountability. All the companies in our survey are publiclyowned and a lack of attention to OHS management can negativelyimpact on the company’s reputation in the area where it operates.Some of the companies can manage OHS also for demonstrating theircommitment to improving the local community and public healthand safety (Smallman and John, 2001). In fact, the interviews showedthat maintaining good relations with other external stakeholders,such as the local community, is important to avoid negative impactsin terms of company legitimacy. Internally, OHSAS 18001 certifica-tion was perceived as a sign of the importance of effectively manag-ing OHS issues and stimulated, in particular, the formulation of awritten OHS policy (b 0.745, p < 0.01). None of the eight companieslocated in the south had an OHSAS 18001 certification.10

Cohen’s d test11 was performed to corroborate the correlationanalysis (Table 4).12 Employees and labour union pressure, geo-graphical location, and OHSAS 18001 showed a higher level of differ-ence between the sub-groups. Legislative pressure and audits bypublic authorities showed a moderate level of significance, while

by the standard aggregate deviation. Cohen (1988) suggests interpreting thestandardised difference between the mean with small (d = 0.2), medium (d = 0.5)and large (d = 0.8).

12 The groupings of companies were calculated starting from the average value ofeach contingent factor and sub-dividing among companies with high values (abovethe average contingent factor) and companies with low values (below the averagecontingent factor). This criterion was used for market stakeholder pressure, employ-ees and trade union pressure, legislative pressure and audit by public authorities. Forthe OHS available budget, geographical location and OHSAS 18001 certification wereused the criteria indicated in Section 3.2.

Table 4Cohen’s d test results.

Organisational Characteristics External Factors ManagementTool

OHSavailablebudget

Employeesand tradeunionpressure

Geographicallocation

Marketstakeholderpressure

Legislativepressure

Audits by publicauthorities

Existence of OHS certification

Yes No High Low North andcentre

South High Low High Low Belowaverage

Aboveaverage

With OHSAS18001

Without OHSAS18001

OHS Policy 3.56 3.00 3.76 2.44 3.73 2.40 3.42 3.20 3.58 3.15 3.44 3.12 3.91 2.80Training and

involvement3.77 3.63 4.23 2.69 4.01 3.10 3.80 3.59 3.97 3.71 4.02 3.35 4.19 3.28

Operating activities 4.05 3.85 4.46 2.98 4.31 3.28 4.13 3.75 4.25 3.76 4.20 3.76 4.44 3.54Performance

Measurement3.60 3.10 3.76 2.60 3.78 2.56 3.45 3.30 3.78 3.11 3.40 3.32 3.82 3.00

OHSMS 3.75 3.39 4.05 2.68 3.96 2.78 3.70 3.46 3.89 3.39 3.76 3.39 4.07 3.15

Cohen’s d testOHS policy Medium Large Large Small Medium Medium LargeTraining Not significant Large Large Small Medium High LargeOperating activities Small Large Large Medium Medium High LargePerformance measurement Medium Large Large Not significant Medium Small LargeOHSMS Medium Large Large Small Medium Medium Large

62 M. Battaglia et al. / Safety Science 72 (2015) 55–65

market stakeholder pressure indicated a small difference. Cohen’s dtest results confirmed that an increase (decrease) in the value of thecontextual factor led to an increase (decrease) in the maturity levelof the OHS management system for six of the seven contextual fac-tors. Only for OHS available budget, did Cohen’s d results partiallycontrast with the correlation analysis results.

13 Five companies had an integrated management system. Of these, four demon-strated an above average maturity level of OHS management systems , while in thefifth company the maturity level was in line with the sample average.

5. Discussion and conclusions

5.1. Discussion

The waste management sector deals with rising environmentaland legal standards, the need for increased efficiency, quality man-agement and the effectiveness of OHS management. The results ofour study showed that the maturity level of OHS management sys-tems can be considered as sufficiency developed. The companieswere aware of the importance of OHS management. Despite this,they were unable to fully implement the Deming PDCA approach.

OHS policy and «performance measurement» were the two leastimplemented dimensions. Companies appeared more focused on‘‘core activities’’ such as «training and involvement» and «operatingactivities», but less on managerial analysis linked with the defini-tion of policies and plans and results measurement and analysis(Passetti et al., 2014).

Due to the nature of waste management a greater focus on‘‘core activities’’ is necessary. Regrettably if this focus continuesover time, it may impede the improvement in the OHS manage-ment system and may also be inadequate to increase OHS knowl-edge. Promoting an «OHS policy» is an important way tocommunicate and diffuse OHS awareness and targets in all com-pany areas. Developing a more structured «performance measure-ment» system can help in acquiring increasingly accurateinformation for ex-post analyses but also, more importantly, forimproving ex-ante decision making and planning, such as OHS pol-icies and new OHS targets.

There is also a strong and a recursive relation between thematurity of an OHS management system and the safety climate.If companies are able to fully develop their management system,they will also increase the workers’ shared perceptions of the firm’sapproach to safety, i.e. their safety climate (Choudhry et al., 2007;Guldenmund, 2000). In turn, the safety climate can improve a com-

pany’s health and safety management and performance, thusreducing workplace injury rates. To promote a safety climate, allthe employees should be aware of the OHS policy and of its impor-tance (Granerud and Rocha, 2011). All the employees should alsoparticipate in OHS programs aimed at improving OHS managementsystems. Finally, formal operational and performance managementtools, such as root cause analysis, appreciative enquiry, preventiondiaries, simultaneous engineering and leading indicators should beused to guarantee the continued development of the OHS manage-ment system and the OHS climate.

One way for municipal waste management companies toincrease the maturity of OHS management systems may be to inte-grate it with environmental management systems (Cunninghamet al., 2010).13 The integration of management systems is importantfor those organisations with operations involving high hazards(Wilkinson and Dale, 1999), such as municipal waste managementcompanies. In our survey, 23 companies had environmental certifi-cations (ISO 14001 and/or Emas), which may indicate that the PDCAapproach for environmental concerns was more structured andmature. Environmental management systems tend to be imple-mented before setting up an OHS management system(Karapetrovic and Casadesús, 2009). Consequently, the acquisitionof OHSAS 18001 and the simultaneous integration of OHS and envi-ronmental management systems may stimulate the maturity of OHSmanagement systems, particularly with regard to planning, invest-ments decisions and performance measurements (Duijm et al.,2008; Jørgensen et al., 2006).

We found that organisational characteristics are more corre-lated with the maturity of OHS management systems than externalfactors. The most correlated is geographical location, followed byOHSAS 18001, employees and trade union pressure, and auditsby public authorities. Geographical location results indicate theneed for specific public policies tailored for the south of Italy topromote and accelerate OHS knowledge, managerial skills andthe diffusion of tools. Pressure from employees and labour unionsis more important than legislative pressure, and OHSAS 18001helps to build on previous results. High numbers of public author-ity audits can highlight a company’s poor performance in terms of

M. Battaglia et al. / Safety Science 72 (2015) 55–65 63

safety. Over time the improvements in maturity of OHS manage-ment systems may reduce the number of inspections, thus reduc-ing administrative costs and enhancing the company’s image.

The overall results indicate that municipal waste managementcompanies have made some changes in the last few years in termsof the active management of OHS issues. Sub-systems, such asworker protection devices and machinery protection devices, andorganisational characteristics, linked with managerial and commu-nication processes, have been improved in order to increase work-er’s safety and company performances. Values and beliefs withregard to OHS importance have driven the more tangible changes.Indeed, from a moral perspective, all the companies interviewedrecognised the importance of adequately managing OHS issuesalthough they were well aware of the barriers that can hinder theirimprovements.

These results show that organisational characteristics and man-agement tools seem to be the most important factors influencingthe maturity of OHS management systems. We believe that thisis a positive signal for future improvements driven by internalmanagerial awareness and moral obligations towards workersafety.

5.2. Conclusions

This paper analysed the level of maturity of the OHS manage-ment of municipal waste companies operating in Italy, andwhether different types of contextual factors influenced this level.The results show that the companies examined reported a suffi-cient level of maturity of their OHS management system and thatbudget availability, employee and trade union pressure, geograph-ical location, and OHSAS 18001 certification positively influencethe maturity level. Our exploratory study thus indicates that thecontingency theory may be a suitable framework for OHS manage-ment. In addition, the results highlight that if companies want toachieve a complete level of maturity of their OHS system, theyneed to invest more resources in OHS issues (Battaglia et al.,2014; Rikhardsson and Impgaard, 2004) and also increase theimportance of OHS both internally and externally.

Internally, fixing the OHS performance targets in line with adedicated budget is a key aspect. In addition, those companieswithout OHSAS 18001 could implement the certification in orderto communicate the importance of managing OHS issues and toincrease their OHS knowledge. The pressure of trade unions under-lined the relevance of mobilising stakeholder engagement and dia-logue, in order to effectively meet the needs of workerrepresentatives, and the workers themselves, regarding OHSissues. Externally, due to the public ownership of companies (inmost cases the main shareholder is the local municipality), andtheir sphere of activities in the local area, increasing the skills inmanaging OHS issues and the related performance may be impor-tant in order to achieve a better legitimation of their conduct. Thus,the more the trend moves towards OHS transparency, efficiencyand effectiveness, the more legitimate companies will be.

Our research has some limitations. Firstly, the small samplemakes it impossible to generalise the results, and it could evenhave influenced the results themselves. However, although thesample size was small, it was representative of the environmentalhygiene sector in Italy. Consequently the correlation analyses aredemonstrations of relationships (or of non-relationships) to be furthertested with larger samples. Despite this, Cohen’s d test largely con-firmed the correlation results. Secondly, the results reflect how theinterviewees evaluate practices linked to company management,but they cannot reveal whether or not these perceptions are wellgrounded. Thirdly, all studies that examine the social nature of acompany are subject to self-selection, or rather to obtaining resultsonly from those people who are interested in social questions, thus

presenting an unrealistic positive reception. However, the dataexpressed various types of OHS management and thus this riskmay have been reduced. Finally, other OHS management dimen-sions could have been investigated in order to have a wider repre-sentation of OHS management systems and of the relatedperformance.

In conclusion, we believe that our results represent a startingpoint to define more complex contingency models in the OHSmanagement literature. The analysis of contextual factors hasled to an initial evaluation of some of the factors that influencethe maturity of OHS management systems. By exploiting contin-gency theory, future research should help to pinpoint the bestfactors that improve (or inhibit) OHS management developmentand reveal how companies should manage these factors in orderto achieve a satisfactory level of maturity and performance. Ananalysis of the various forms of fits (Drazin and Van de Ven,1985; Gerdin and Grave, 2004) may improve the OHS analysisfrom a managerial point of view, by facilitating company choices.In addition, other organisational, external and managerial factorssuch as environmental uncertainty, technology developmentcould be studied. Being able to accurately design OHS manage-ment based on the indications provided by contingency studieswill create a bridge between research activities and companydecisions.

Furthermore, future research could extend the analysis to a lar-ger sample of companies, even to an international level, and couldcover the question of the integration of health and safety manage-ment into company culture. Barriers to OHS policy definitions andperformance measurements could also be investigated. Finally,physiological aspects could be tested and linked with the imple-mentation and the effects of OHS management systems.

Acknowledgements

We are very grateful to the editor in chief and two anonymousreferees for their constructive comments during the reviewing pro-cess. This research has been financially supported by FondazioneRubes Triva (Rome, Italy).

Appendix A. The questionnaire

Section two (contextual factors)1. Does your company have specific economic resources

(budget) for occupational health and safety management?2. In the last three years how many times has the company

been inspected by public health and safety authorities(local health authority, employment inspectorate,municipal administrations, etc.)?

3. How important is the influence of the followingstakeholders on your company’s policies in relation toimproving worker health and safety management (from 1‘‘not important’’ to 5 ‘‘very important’’)?:� market stakeholders, such as customers and suppliers;� internal stakeholders within the organisation, such as

employees and trade unions.4. Considering the occupational safety and health legislation

in your company, to what extent do you agree with thefollowing statements?:� health and safety regulations influence company

decisions concerning occupational safety and health (from 1‘‘not at all’’ to 5 ‘‘very much’’);� with respect to the level of compliance required, health

(continued on next page)

64 M. Battaglia et al. / Safety Science 72 (2015) 55–65

and safety legislation in our sector is (from 1 ‘‘not severe’’ to5 ‘‘very severe’’);� in the future, the correct management of legislative

compliance with regards to health and safety will entailadopting more stringent health and safety managementprocedures (from 1 ‘‘completely disagree’’ to 5 ‘‘completelyagree’’).

Section three (OHS management system)5. Using a scale from 1 to 5, assess the implementation level of

the following initiatives (1: no action implemented; 2: poorimplementation; 3: adoption of initiatives has begun but hasnot been completed; 4: good adoption of initiatives; 5: goodadoption of initiatives with effective outcomes). Consider thelast three years as a period of time.5.1. Concerning the planning of health and safety matters, isthere an official and written declaration that has beensigned by the Chairman/CEO showing the company’s healthand safety policy:� your company has no official and written declaration all

staff have been made aware of the health and safety policy;� management have established measurable health and

safety objectives and targets;� managerial tools have been implemented to facilitate

communication to all staff;� observations and suggestions by employees or their

representatives for OHS improvement are collected;� systematic comparisons are drawn between

improvement plans and actions carried out, and the extentto which the objectives and targets are achieved isconstantly measured.5.2. Considering employee training and involvement withregards to health and safety:� teams of staff from different departments have been set

up to solve problems relating to working conditions� employees receive training when they join the company

(specific training for new employees) and when their dutieschange;� there is a formalised system to detect health and safety

training needs;� specific training plans are established at least once a

year.5.3. Considering the implementation of worker health andsafety management initiatives:� specific health and safety operating instructions have

been prepared;� work procedures are established considering the risks

associated with the duties carried out;� training is provided for particularly risky roles and

duties;� there is a procedure to identify and respond to potential

emergency situations;� the emergency response procedures are regularly

revised (particularly after regular tests or emergencysituations).5.4. With regards to measurement, surveillance and internalcontrol systems:� there is an official performance system to measure the

safety targets achieved;� the company’s injury indices (frequency and severity)

are regularly monitored throughout the year and comparedwith sector data and data from other companies withsimilar characteristics;

� the company has procedures to record and investigatenear-misses;� information and data on incidents are reported,

recorded, investigated and analysed;� regular internal audits are carried out in order to verify

the correct implementation of instructions/procedures andcompliance with health and safety legislation.

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