Moving toward a data-driven outcome-based regulatory model

Reflections from a TSSA Chief Safety and Risk Officer

Moving toward a data-driven outcome-based regulatory model

As the sun warmed on an early spring day in 2024, I drove away from a plant inspection, reflecting on how much had changed since I first observed similar inspections five years ago. Back in 2019, the November landscape was bleak, matching the cold formality of the plant inspections I observed during my onboarding process as the new independent TSSA Chief Safety and Risk Officer. Each inspection I observed back then felt like a box-checking exercise, with stiff processes and little room for real collaboration. Fast forward to that spring day in 2024: the days were longer, colors brightened the fields, and the tone of the inspection had evolved just as noticeably. This time, I witnessed a genuine partnership between TSSA and plant staff, each side sharing expertise and insights to enhance safety.

Since 2019, I had witnessed TSSA taking deliberate steps to move away from a traditional to a modern outcome-based regulatory approach. Over the years, the journey faced the typical setbacks of any organization when moving to a more dynamic, outcome focused model. Given the positive results I observed that day, TSSA’s efforts were truly making a difference!

I was inspired - and curious! What was contributing to this success? As I reflected, I isolated six impactful pillars that were most influential in driving the transformation to a modern outcome-based regulator. With my unique, independent perspective as Chief Safety & Risk Officer, I felt compelled to share the lessons learned so that others could benefit.

In the following sections, I explore these six pillars in more detail, highlighting successes and lessons learned along the way and providing readers with relatable, real-world examples, offering actionable insights into their own regulatory or organizational improvements.

1. Building a Culture of Accountability and Outcomes

Building a culture centered on accountability and outcomes requires both a clear vision and a steadfast commitment to that vision. As TSSA transitioned toward an outcome-based regulatory model, this shift began with consistent, transparent communication. TSSA’s leadership shared not only the vision but the reasons behind it, helping both staff and industry partners understand the "why" driving the change. Every action and achievement were connected back to this vision, reinforcing its significance, and keeping everyone focused on the larger goal. This unwavering focus has been instrumental to TSSA’s success, as it shifted mindsets from traditional compliance to a broader, outcome-focused approach.

Central to this transformation was the ability to understand and measure safety outcomes through data. TSSA recognized that its relationship with data had to evolve from one of basic compliance and reporting to a more sophisticated, decision-oriented perspective. This required a fundamental shift in mindset, especially for inspectors, who began to see data not as an administrative task but as a powerful tool to identify trends, anticipate risks, and make informed decisions. TSSA’s leadership played a key role here, engaging inspectors in ongoing discussions that built trust and underscored the critical value of data. By listening to inspectors' perspectives and addressing barriers they faced, TSSA strengthened its internal culture of accountability and empowered inspectors to see their roles in new ways.

This culture shift of accountability and outcomes extended beyond TSSA's walls and into the industries it regulated. TSSA's interactions with industry leaders began to evolve from compliance-focused directives to collaborative discussions aimed at achieving shared safety outcomes. By engaging with industry advisory councils and fostering a spirit of partnership, TSSA promoted a culture that valued transparency, accountability, and mutual respect. Although not everyone embraced the shift immediately—and some encountered challenges due to legacy mindsets and resistance to change—TSSA remained committed to its vision. Even during the pandemic, when new safety protocols had to be swiftly implemented, TSSA kept its focus on building this outcome-based culture.

Creating a culture of accountability and outcomes is an ongoing journey. Maintaining a consistent vision, fostering open communication, and demonstrating a commitment to collaboration, TSSA has laid a solid foundation for a regulatory model that not only protects safety but empowers those responsible for it.

2. Empowering Staff for Success

Transforming an organization’s culture requires genuine staff engagement and support. TSSA recognized early on that building an outcome-based regulatory model would not succeed without the buy-in and empowerment of its staff. With a shared vision for TSSA as a modern, outcome-focused regulator, leadership established an atmosphere of trust, encouraging open communication and normalizing the fact that mistakes would be part of the learning curve.

In the early days of building data integrity, leadership held numerous conversations with field inspectors to understand the barriers they faced in data collection and processing. By creating an open forum for honest feedback, leaders learned what was working and what was not, directly from those on the front lines. Over time, inspectors saw how these discussions led to real changes. Data collection processes were refined based on their input, building trust, and showing how data could streamline daily work, rather than disrupt it.

Not everyone initially saw the value in these conversations, especially with the demands of daily tasks. However, leaders consistently emphasized how these exchanges were instrumental in advancing TSSA’s vision. With ongoing dialogue, staff began to view these discussions as an essential part of regulatory practice. Conversations shifted from process improvements toexamining the purpose behind data collection and determining if the “right” data was being gathered to support safety outcomes. This input from a variety of roles across the organization uncovered gaps, sparking improvements to the inspection process and strengthening the culture of continuous learning.

As data practices improved, ownership became obvious as staff expressed commitment to seeing the improvements working and making a difference. At times, frustrations arose when changes were delayed or processes fell short of expectations, but the openness to express these frustrations demonstrated an elevated level of trust within the organization. Leaders responded by refocusing on the vision, celebrating achievements to date, and addressing concerns directly.

Today, data discussions at TSSA are collaborative and action-oriented, with staff at all levels deeply engaged in understanding data trends and anomalies, interpreting insights, and aligning actions to enhance safety outcomes. Through this journey, TSSA has fostered a culture where empowered staff, grounded in a clear vision, actively contribute to—and take pride in— the role of data to inform safety outcomes.

3. Fostering Agility and Openness to Change

For TSSA’s transition to an outcome-based regulatory approach, leadership’s role in fostering agility and embracing change was essential. Without leader’s full commitment, direct reports would struggle to prioritize the new model, risking inconsistent application of this transformative approach. Recognizing this, TSSA leadership actively encouraged change champions within the organization.

The visible commitment from its champions was critical, as leaders not only communicated the importance of the outcome-based approach, but actively demonstrated how changes in daily processes contributed to the broader vision.

Leaders who embraced the shift saw data not as a challenge to their expertise but as a powerful tool that complemented their judgment. By integrating reliable data into decision-making, leaders found it enabled them to confirm their intuition and focus attention on emerging trends. In the initial stages, persuading leaders to adopt this mindset was critical—without their buy-in, transformation efforts could easily be undermined.

This commitment was crucial, especially as staff were asked to integrate new data practices on top of their regular duties, revising tasks and processes to strengthen data integrity. While adjustments were often incremental, the repeated need for minor change sometimes led to frustration as familiar tasks became less automatic and required pausing to think through the new steps. As the transformation progressed, TSSA leadership acknowledged that some team members struggled with the new direction.

Actions speak louder than words, and when leaders did not prioritize the changes, staff often mirrored this lack of urgency, deprioritizing the shift themselves.

In these cases, individuals misaligned with the vision moved out of the organization, either through attrition or natural turnover. Each new vacancy provided an opportunity to refine role expectations and prioritize attributes essential to future success. This deliberate, agile approach to leadership and staffing has enabled TSSA to build a resilient culture open to change and committed to an outcome-based regulatory future.

4. Ensuring Data Integrity for Informed Decision-Making

Reliable data is foundational to TSSA’s transition to outcome-based regulation. Prior to this shift, data collection was routine focused on compliance rather than on influencing decisions and actions. Moving to a data-informed approach required several shifts in the organization, not only from how data was viewed but how it was used at every level.

As TSSA consistently reinforced its vision of evidence-based decision-making, it established a comprehensive data governance framework aimed at data reliability and consistency. The organization recognized the importance of the right expertise in leading this development and restructured the data function from a limited reporting role, into a critical support system for regulatory decision-making. Data analytics evolved from a siloed operation into a strategic partner for the regulated lines of business, actively engaging in the design and implementation of data standards and providing ongoing guidance on effective data usage.

Building data literacy and integrating new tools required patience and leadership support. Leaders allowed time for staff to adapt, balancing the demands of daily work with the need to learn new processes and technology. Frontline insights were essential for identifying barriers in data collection and processing, ensuring that improvements were practical, and staff supported. Leaders also paced the implementation of changes, periodically pausing to let practices take root—especially during the challenging period of the pandemic and staff shortages.

As data reliability strengthened, TSSA shifted its focus to the value of the data itself, prioritizing data points that most effectively supported safety outcomes. The once-informal relationship between business leaders and data analysts matured into regular, collaborative discussions, fostering a unified approach to data interpretation and decision-making. A notable achievement was recognized when leaders in regulated lines began proactively seeking data insights to guide their actions.

Through these ongoing efforts, TSSA is cultivating a robust, data-driven culture where reliable information is not only collected but purposefully applied to support informed decisions and achieve regulatory goals.

5. Aligning Resources with Data-Driven Insights

As TSSA’s vision of outcome-based regulation continued to be reinforced by leadership, the organization began aligning resources to address data-driven priorities. Over time, data became increasingly referenced to guide workforce efforts. Although date integrity continued to be strengthened, data deficiencies were openly discussed and leaders regularly revisited goals and reflected on progress.

With the help of data, TSSA established a differential approach to inspections, directing more resources toward higher-risk plants and reducing oversight for those demonstrating strong safety records. This shift enabled a move beyond a purely enforcement-focused approach to one that emphasized engagement and education, fostering stronger partnerships with regulated plants. Much like the internal culture of listening and understanding, field inspectors began to apply this partnership approach externally.

The revision of certain regulations further supported this shift to data driven priorities. Alternate rules for the Operating Engineers’ regulation were implemented that provided businesses with flexibility and choice. Plants could choose to utilize the alternate rules or to continue adhering to requirements in the current regulation.

This change acknowledged the varying stages of plant development, allowing greater operational flexibility for facilities that could reliably demonstrate safety outcomes, thus formalizing TSSA’s commitment to a collaborative regulatory framework.

The design of the Alternate rules involved comprehensive input from industry advisory councils followed by striking a committee of industry volunteers to inform the guiding principles and approach in shaping the framework. This inclusive approach energized industry partners, who expressed enthusiasm for TSSA’s evolving partnership model and their shared role in designing a risk based regulatory framework. This collaboration fostered a unified commitment to the success of the Alternate rules.

TSSA’s ongoing refinement of data practices has enabled a responsive approach to Alternate rules, incorporating varied data points to monitor safety without compromising outcomes. This evolving approach leverages both data insights and the industry’s expertise to maintain rigorous safety standards in a landscape of changing practices and technologies. While data use at TSSA will continue to adapt, the combination of evidence-based insights and a cooperative mindset ensures that TSSA remains dedicated to its mission of keeping Ontarians safe.

6. Embracing Continuous Improvement for Lasting Impact

TSSA wisely recognizes that its transformation to a modern, outcome-based regulator is a continuous journey, one without a fixed endpoint. The nature of regulation requires constant evolution, adapting not only to industry advances but also to emerging risks and mechanical and technological innovations. For TSSA, this journey reflects an ongoing commitment to continuous improvement, ensuring that its practices remain relevant and impactful.

At the core of TSSA's transformation are the principles and practices now deeply embedded across the organization. These include a steadfast reliance on data-driven decision-making and a collaborative approach that values partnerships and industry expertise. Together, these principles create a culture of shared responsibility and mutual trust, supporting TSSA's mission of effective, outcome-based regulation.

A key aspect of continuous improvement at TSSA is ensuring the integrity and relevance of data. The organization has made strides in refining data collection, analysis, and reporting to align with regulatory needs and industry realities. Going forward, it remains essential to maintain and build upon this data integrity, continuously assessing which metrics best support informed decisions and timely actions. By investing in data quality, TSSA not only strengthens its regulatory impact but also enables its workforce to focus on the highest priorities with confidence.

Recent structural changes at TSSA underscore the organization's commitment to relevancy. New initiatives regularly monitor regulations against the evolving practices within industries. These efforts are designed to support TSSA in refining its regulatory framework to remain both adaptable and effective.

To sustain this momentum, TSSA continues to prioritize strong leadership, fostering a supportive environment where staff buy-in is cultivated at all levels. This alignment between leadership and staff has proven instrumental in integrating continuous improvement into TSSA's culture. As a result, staff now understand and value data as essential to their roles, seeing its impact firsthand on achieving their regulatory objectives.

As TSSA forges ahead, it remains dedicated to refining its processes, developing new tools, and building expertise to ensure that regulations stay relevant and impactful. By embedding continuous improvement into its regulatory DNA, TSSA is not only adapting to the present but also preparing for a future in which its actions continue to safeguard and add value to the industries it oversees. This commitment to improvement, adaptability, and data-driven insights positions TSSA to lead as a forward-thinking, modern, outcome-based regulator.

Conclusion

My independent role as Chief Safety & Risk Officer afforded me the unique opportunity to view TSSA evolution to a modern outcome-based regulator. This distance provided the perspective that helped me to identify the six pillars that I found were most influential in their success. The pillars provide invaluable lessons for any organization seeking to successfully evolve as a modern outcome-based regulator:

1. Building a Culture of Accountability and Outcomes unites everyone around a shared purpose and direction.

2. Empowering Staff for Success builds a resilient workforce that sees the value in their contributions and is ready to engage fully.

3. Fostering Agility and Openness to Change is essential in an ever-evolving environment. By encouraging adaptability, TSSA remains responsive and relevant.

4. Ensuring Data Integrity for Informed Decision-Making enables true accountability and precision, turning data into a trusted partner in decision-making.

5. Aligning Resources with Data-Driven Insights maximizes impact by strategically focusing resources where they matter most.

6. Embracing Continuous Improvement for Lasting Impact keeps TSSA moving forward, ensuring long-term success and sustained results.

As we have seen with TSSA, the rewards of this approach are well worth the effort, driving safer outcomes and enhancing regulatory impact. Looking back on that spring day in 2024, I saw how far TSSA had come in its journey. Their progress shows what is possible when we commit to a modern, outcome-based approach. I encourage regulators to consider the lessons from TSSA’s journey and embrace a modern outcome-based approach. This shift not only strengthens safety and effectiveness but fosters an environment where staff, leadership, and industry work together toward real, measurable safety outcomes.