Category Archives: Safety Leadership

Workplace Injury Recordkeeping: New Rules

The long-debated rule requiring employers to annually submit their injury data to OSHA has become a reality. In the past, injury data was kept internal to a company unless OSHA or DOL requested that information. But no more!

The 2016 injury data for nearly every employer in the U.S. must be sent electronically to OSHA by July 1, 2017. For 2016, the only form employers must send OSHA is the 300A Summary. But starting with calendar year 2017, ALL injury data forms must be sent to OSHA. This includes the OSHA 300 Log (which contains the names of injured employees), the 300A Summary, and the 301 Incident Investigation form (which includes details of the incident, medical treatment received, the injury cause, and what the employer is doing to prevent similar incidents in the future).

As if this is not enough, OSHA will make much of this data available to the public. Beginning next year, your “dirty laundry” about injuries in your workplace (employee names will NOT be made public) will be posted for anyone and everyone to see on the OSHA website.

The rule also prohibits employers from discouraging workers from reporting an injury or illness:

  • Requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation.
  • Employer’s procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting.
  • Prohibits retaliating against employees for reporting work-related injuries or illnesses.

It’s a new day, folks. If you have not been able to think of a good enough reason to reduce the number of injuries in your workplace, perhaps this new rule will light a fire.

Want to learn more about the new rule on electronic reporting of injury data to OSHA, as well as other information about OSHA injury reporting requrements? Sign up for this audio conference!…


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Right Tool For The Job: Is It Really A Tired Argument?

Once again, some of the more prolific safety bloggers on sites like LinkedIn are proclaiming that they have “the truth” about what works and what doesn’t when it comes to safety management and injury prevention. A current claim is that some safety management tools just don’t belong in the toolbox of any enlightened safety professional. The position is that slogans or BBS are such old technology that it’s akin to bloodletting; any use of tools like slogans or BBS are only for those that refuse to see the “truth” that these tools are not only outdated but dangerous. Some bloggers go so far as to refer to safety professionals that insist on using any part of “outdated” concepts like BBS as “knuckle-draggers”.

The argument is made that BBS is about blaming the majority of workplace injuries on deliberate and conscious employee behavior and that the intent of BBS is to modify and control the behavior of a population. Perhaps there are some BBS practitioners that believe this, but I don’t think this is so of the more reputable organizations that utilize BBS as one of their tools in injury reduction. In fact, I have never spoken with a BBS proponent or practitioner that did believe this to be true. Those that I have discussed this with understand that the human mind is complex. They understand that we make conscious and deliberate decisions and that we also make unconscious decisions. To throw out all of the concepts of BBS as “snake oil” and to state that there is no place for behavior modification is to say that we have mastered the workings of the human mind and have determined that understanding human behavior is of no value in safety management.

Behavior modification has been used for many years in dealing with changing our lives for the better. It’s used in therapy to help people with addictions; people that are not necessarily making a conscious and deliberate decision to be mired in substance abuse. My understanding is that there are often underlying issues that lead a person to abuse certain substances even though consciously they don’t want to do so. It is also my understanding that behavior modification can help a person better understand WHY they do what they don’t want to do. Am I saying that all safety professionals are equipped to embark on a journey of understanding human behavior and making attempts at behavior modification? No. But there are those that have been educated and trained in this field sufficiently that they can help in leading an organization to use certain concepts of BBS, including observation and feedback, in reducing injuries.

What about safety slogans? Are these entirely useless? Perhaps. I think it depends on the organization’s culture. If there is a culture of trust and respect, I believe that slogans and campaigns can help a team to focus. But in an organization where there is mistrust and fear, slogans could be not only of no value, they could do even more to increase the gap between management and front-line worker.

Only you and your organization can determine which tools are of value to you. A tool like BBS could be beneficial in an organization with a mature, trusting culture, but that same tool in another less-developed culture could be dangerous and damaging. I believe the same holds true for any of the many tools available to the safety professional. Just because another person believes these tools are outdated and don’t belong in ANY safety professional’s toolbox does not mean it is so. Just because those tools are of no value or are dangerous to THAT person does not mean they can’t have value for you and your organization. That decision about what is right for your organization is up to you; not me or any other blogger.

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Safety PR and Crisis Communication: Are You Ready?

A terrible accident has happened in your work place. An employee falls from a ladder, lands on his head, and dies at the scene. This is one of the most terrible events that can ever occur within any organization. Immediately after the employee’s death, there is confusion, guilt, sadness, anger, and a myriad of other emotions. What is the first thing you should do? What do you say? How do you say it? To whom do you say it? The decisions made and actions taken after any type of crisis situation can spell disaster for your organization.

Don’t think “It’ll Never Happen Here!” A crisis may happen anywhere – anytime, and high profile organizations are more susceptible to some crisis. It is a fact that bad things CAN and DO happen to good organizations. It’s essential to understand that new threats develop regularly, that we need to be aware and be ready.

Let me say first that I am not an attorney and nothing in this article should be construed as legal advice. The information and suggestions here are from my own experiences and understanding of dealing with crisis situations in the workplace. I strongly encourage anyone that is dealing with a crisis to seek out qualified and experienced legal advice.

In a catastrophic event, your every word, every eye movement, every emotion that shows, will resonate with those around you. In a crisis event, communication is different. Uncertainty is one of the greatest concerns for most, so it’s important to reduce anxiety and demonstrate that things are under control. But instead of making promises about outcomes, express the uncertainty of the situation and a confident belief in the process you are using to fix the problem and to address public safety concerns.

The consequences of a crisis can be far and wide and can lead to devastating results. What happens or is done on one front will impact what happens on another. This includes issues like litigation, law enforcement, regulatory agencies, the community, clients/customers, the press, business partners, employees, etc.

Two key issues to consider in crisis communication include the need to instill confidence and to provide information to all concerned (employees, family, police, government investigators, local news media, and public). The bottom line is that we want to have the public respond, en mass, in a logical, predictable manner designed to ensure the greatest good to the greatest number.

One thing for sure is that we must act quickly as bad news travels fast, especially in today’s world of social media which tends to thrive on bad news. By acting quickly, we can preserve the organization’s reputation and control the information that the public, employees, etc. receive. It does take work, but it’s much simpler than rebuilding a damaged reputation.

The KEY to success or failure is effective, caring, and honest communication. Before with employees (training) and media. During with employees, media, outside responders, regulatory agencies. And After with employees, media, regulatory agencies, contractors.

No doubt, there will be lots of questions from every direction. While you can’t always prevent the crisis, you can be prepared by understanding what sort of information people will want to know, such as:
• What caused the accident?
• What is the organization’s procedure to handle such an incident?
• Will there be an investigation?
• What is being done to mitigate the risk?
• Has this happened before? If so, when?

Of course, there will also be lots of rumors going around. Immediately dismissing a rumor is a dangerous move. Take everything you hear seriously, but with a grain of salt and investigate rumors before you comment. Correct wrong information quickly and thoroughly. Try to persuade those with unconfirmed incident information not to publicize it until official confirmation is received. It is extremely easy for information to be published very rapidly on blogs and social media, and it can be extremely distressing if the next of kin of a victim finds out about an accident through such unofficial, unconfirmed channels.

The goals of your crisis communication should be to protect your organization’s reputation, reduce tension, demonstrate commitment to values, to communicate promptly and continuously, to maintain control of the flow of information, and, of course, to end the crisis.

So what can you do? Think carefully about the messages you send out. Consider using just two to three key messages that include things like: Facts, Concern, Commitment, and Actions to take. I suggest that these be no more than ten seconds each and no more than 30 words, and then keep repeating these three messages. . .
Famous Example: STOP! DROP! ROLL!

There are some keys to navigating a crisis; these include:
• Consider, above all other factors, the health/safety of visitors, employees, public and community.
• Gather all facts as rapidly as possible.
• Immediately notify, and maintain contact with, appropriate local authorities (Police, Fire, etc.).
• Notify legal advisers when appropriate.
• Maintain records of all proceedings.
• Encourage candid discussion of solutions.
• Communicate quickly and fully with one another and public.
• Develop answers to predictable questions.
• Monitor events and adapt as necessary.
• Lead and facilitate investigation.
• Don’t be afraid to say “I don’t know”.

There is much, much more to consider in crisis communication, including how to deal with the media, press releases, matching the message to the audience, how to use social media to your advantage, understanding risk communication, putting together a crisis management plan and team, and understanding the skills required of a spokesperson. All of these, and more, will be covered in my upcoming audio conference titled “Safety PR: What To Say When A Serious Incident Hits Your Organization”, February 3, 2015. Learn more or register at:

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What Behavior Based Safety (BBS) Is And What It Is Not.

BBS theory has been around for many decades, but in the past few years it has become increasingly popular among some businesses and with many safety professionals. The phrase Behavior-Based Safety in its strictest sense refers to the use of applied behavior analysis methods to achieve continuous improvement in safety performance. Behavior Analysis is promoted as the scientific study of behavior, with the primary objective being the discovery of principles and laws that govern behavior. I would say, though, that to be truly effective this must include all behaviors, not just those of the front-line worker.

Many proponents of BBS Claim it To Be:

  • An excellent tool for collecting data on quality of a company’s safety culture.
  • A scientific way to understand why people behave the way they do when it comes to safety.
  • When properly applied, an effective next step towards creating a pro-active safety culture where loss prevention is a core value.
  • Conceptually easy to understand but often hard to implement and sustain.

…But Claim It Is Not:

  • Only about observation and feedback.
  • Concerned only about the behaviors of line employees.
  • A substitution for traditional risk management techniques.
  • About cheating, manipulating people, and aversive control.
  • A focus on incident rates without a focus on behavior.
  • A process that doesn’t need employee involvement.

Yet some safety professionals with which I have communicated claim BBS is the only method to use in safety management and injury reduction. Others I have talked with claim that BBS is too flawed to be useful. BBS proponents often state that conditions do not cause accidents, behavior does. In fact, some BBS proponents state that more than 85% of accidents are the result of unsafe acts. This belief seems to stem from Herbert Heinrich’s theories developed in the 1930’s. Personally, I have not found any solid evidence of Heinrich’s “statistics”, yet time and again I see this so-called “fact” used to support the position on BBS. So, the Heinrich myth lives on. But does this mean there is no value to some concepts of Behavior Based Safety? No, I think there is value in BBS when properly combined with other methods.

BBS says safety is about people, and behavior is the challenge. But BBS does not focus on identifying and correcting hazards and is often seen as “carrot and stick”. Critics claim BBS emphasizes the worker without taking the system into account. Another approach to consider is that of using a Safety Management System (SMS) . The SMS uses planning, risk identification, analysis, operational control, directives and processes, and continual improvement. Safety Management Systems focus on hazards (which I believe to be the true source of injuries) and I would suggest that removing or reducing the risk of injury can be more successful than relying solely on BBS.

It’s important to note that an effective SMS is not about regulations or reprimands: it is about systems and using what works for the given situation. It’s also important to realize that there are pros and cons to both SMS and BBS methodologies. Safety management systems will always be flawed to some degree, as you can’t plan and control for every hazard. And systems can be inflexible while behavioral approaches may be more adaptive. However, behavior is hard to understand and change, while hazard identification and correction can be implemented easily in most situations.

Accidents are complex and a concentration on behavior alone can detract from finding other causes. But a focus on systems alone might overlook some behavioral issues; there are things in BBS that may be useful. So what are we to do? We need to understand that there are many causes to accidents other than just behavior. There may be environmental conditions, physical hazards, management & systems, equipment, etc., to consider as causes.

It’s not unusual for an organization to see these two approaches as an “either-or” proposition. While the strong proponents of each (BBS and SMS) may see them as diametrically opposed, this may not necessarily be true. But there is no “canned” solution; each organization should select the components of various theories and systems that work for them.

What Really Works In Keeping The Workplace Safe?
1. Controlling risks at their source.
2. Vigorous enforcement of the law.
3. Treating people with dignity and respect.
4. Using BBS and Safety Management Systems (SMS) together.

A combination of safety management systems and behavior-nurturing systems might better ensure a higher probability of working safely. BBS and SMS can and do work together. But BBS in its entirety and on its own might cause more harm than good, as it has a tendency to cause a level of distrust between management and front-line workers. In my opinion, bringing BBS into a culture where there is no trust can only lead to disaster.

So I would suggest that using caution with behavioral theories is appropriate. We are always learning new things about human psychology, and what we thought was true about human behavior a few years ago may not be true today. Bear in mind also that employees don’t like being “psychoanalyzed” and many unions are strongly opposed to BBS in any form. There is clear value in injury reduction through removing or controlling hazards (conditions). While behavioral modification might work, it can be complex and involved, and often is met with tremendous resistance. It all boils down to using what works. No one system, process, or theory has all of the answers.

There is no doubt this is a complex, controversial, and even divisive subject. To learn more about combining BBS and Safety Management Systems, join me on January 6, 2015 for my next audio conference on this subject. “Behavior Based Safety: What Works, What Doesn’t, And How It Can Help Your Organization”

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The Expectation of Safety

The Expectation of Safety.

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The Problem with Safety

The Problem with Safety.

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Why Accidents Occur

Why Accidents Occur


The purpose of an incident investigation is to find the root cause and any contributing causes. We do this so we can find ways to prevent future occurrences. An incident investigation is not conducted in order to assign blame, but to find the true cause. Remember, the Root Cause is that one thing, that if not present, would have prevented the incident.

While there may be many possible causes that have been determined by incident investigations in the past, each incident is unique and the only way to find the root cause is to carefully consider all of the evidence.

But even without looking at an actual incident investigation in process, we know from past research that there are a variety of reasons why accidents have occurred. By knowing what sort of things might lead to an accident, managers are in a better position to take actions that might prevent incidents from occurring in the first place.

Below are some of reasons that accidents occur. As you read through this list, think of the actions that you can take to prevent these reasons from leading to an accident in your group.

NOTE: The items below are not in any particular order and do not represent the frequency of occurrence.

Beliefs and Feelings

  • Employee did not believe accident would occur to them.
  • Employee liked working fast, showing off, or pretending to know it all.
  • Employee didn’t follow rules because he/she disliked rules and authority.
  • Employee worked unsafely as the result of peer pressure.
  • Employee was unhappy because of personal problems or problems on the job leading to conscious or unconscious decision to work unsafely.
  • Employee’s attitude is hostile, uncooperative, apathetic, etc.

Decision to Work Unsafely

  • A consequence of a person’s personal beliefs and learning
  • Through experience, people learn many possible behaviors.
    • They generally choose those behaviors that they perceive will bring them the greatest reward with the least negative consequences.
    • Unfortunately, some employees perceive that it is to their advantage to work unsafely in some situations.

Mismatch or Overload.

  • Occurs when the employee’s physical and/or mental capacity is not adequate to safely perform the task.
    • Poor physical condition of employee.
    • Fatigue or high stress level.
    • Mentally unfocused or distracted.
    • Task too complex or difficult.
    • Task too boring, repetitive, etc.
    • Physical environment is stressful (noise, dust, heat, etc.).
    • Inadequate training provided.

Systems Failure.

  • The term “systems failure” includes all the errors that management and its representatives make that are not grossly negligent or “serious and willful” in nature.
  • These systems failures are errors, mistakes or lapses in management control that allow or contribute to the occurrence of accidents.
    • Lack of clear policy, rules or procedures.
    • Poor hiring or placement procedures.
    • Inadequate inspections.
    • Failure to correct hazards.
    • Inadequate employee training.
    • Lack of in-depth accident investigation.
    • Rules not enforced.
    • Safe behavior not reinforced.
    • Adequate equipment or tools not provided.
    • Production requirements too high.
    • Poor safety communication (safety not publicized or promoted).
    • Poor safety management (problems with authority, goals, evaluations, coordination, responsibility, or accountability).
    • Inadequate knowledge and analysis of jobs and potential hazards (no job safety analysis).
    • Lack of full management and supervisory support for the safety program.


  • Traps are a type of unsafe condition created by poor workstation or job design that make it more likely an unsafe behavior will occur, thus increasing the probability of an injury.
    • Inappropriate or defective equipment provided.
    • Personal protective equipment not provided, maintained or replaced.
    • Confusing displays or controls.
    • Poor adjustability, layout or size of the work area.
    • Inadequate mechanical lifting equipment.
    • Uncontrolled slip/ fall hazards.
    • Excessive reaching, bending, stooping, twisting, contact pressure, vibration, repetition or force.
    • Awkward postures or movement as the result of poor tool or workstation design.
    • Excessive heat, cold or noise.
    • Insufficient lighting or ventilation.

Unsafe Conditions.

  • Unsafe physical conditions include the general environment, equipment, work facilities and ergonomic interaction between the employee and the job.
  • Unsafe conditions occur as the result of traps and individual behavior that makes the environment unsafe (Traps + Behavior = Unsafe Condition).
    • Unsafe condition created by employee who had accident.
    • Unsafe condition created by fellow employee or third-party individual.
    • Unsafe condition created or allowed by management.
    • Unsafe condition created by the environment (rain, ice, darkness, wind, sun, etc.).

Unsafe Acts.

  • The immediate cause of the accident may include some sort of error by the employee who had the accident.
    • Chose not to follow safety rule.
    • Horseplay or fighting.
    • Used drugs or alcohol.
    • Used incorrect or unauthorized equipment.
    • Improper work method chosen.
    • Did not ask for equipment, information or assistance that was needed to do job safely.
    • Did not remember rule or procedure.
    • Did not pay proper attention.
    • Improper body mechanics.


Even though an investigation may lead to the employee’s behavior as the cause of the accident, this behavior is often the result of ineffective or non-existent safety management systems. Effective safety management systems can lead to a change in behavior, which can lead to a change in beliefs and values.


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