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” http://www.theindustrycalendar.com/showWCDetails.asp?TCID=1014275&RID=1011610

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Incentives and Indicators

http://philladuke.wordpress.com/2014/12/03/incentives-and-indicators/

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What Do You Do When OSHA Is Knocking At The Door?

OSHA is focusing less on consultative assistance & more on enforcement action. This means citations are going up, penalties are going up, the potential for criminal charges are going up, with those responsible for ensuring workplace safety as the target!

First, I want to say that I am not an attorney and this is not legal advice. I am only sharing my understanding and experience with OSHA Inspections. I do strongly recommend that an employer seek experienced legal counsel anytime you have communications from OSHA. An OSHA Inspection is not a matter to take lightly and the possible repercussions can be extensive.

There are two general categories of inspections: programmed and non-programmed.
1) Establishments with high injury rates receive programmed inspections.
2) Non-programmed inspections are used in response to fatalities, catastrophes, and complaints.

Inspections normally occur without any advance notice. In fact, in most Non-Programmed Inspections, it is a Federal offense for someone to notify you in advance. There are OSHA publications and documents that detail the policies and procedures for inspections, including OSHA’s Field Operations Manual (FOM).

At an Inspection, the OSHA Compliance Officer (or Inspector) will normally arrive during regular working hours and will present their credentials (you should always ask if they don’t). An employer can call local OSHA office to verify that this is an OSHA inspection.

The Inspector will usually request to see the owner or “person in charge”. The OSHA officer does not need a warrant, but they must have your consent to enter and inspect your premises. But if you refuse entry, the Inspector will return to the area director where it will determined if a warrant should be sought. If they want to inspect your place, they will get in eventually.

In today’s world, you should expect that the OSHA Inspector will be very much enforcement-driven. They are not there to consult with you or to help. They are there to find violations and write citations. OSHA does have a consultative branch that exists to help employers, but inspections are done by the enforcement branch.

The time to prepare for an OSHA inspection is NOT when they come knocking at the door. NOW is the time to get ready, and there are some simple steps you can take to be prepared. These steps include:
• Knowing which OSHA Standards apply to your business and making sure you are in compliance.
• Ensuring your OSHA 300 (injury report) forms are up to date and posted according to OSHA rules.
• Having a qualified employee assigned as your Safety Manager.
• Training supervisors and managers in OSHA inspection basics.
• Developing an OSHA Inspection Plan.

A typical OSHA Inspection consists of four phases:
1. Opening conference
2. Records review
3. Facility walk-through inspection
4. Closing conference

In the Opening Conference, the Inspector will explain how your company was selected and will likely explain the scope and purpose of inspection. If there was a complaint, they will normally provide a copy but will usually not reveal the name of the complainant. The Inspector will ask for an employer representative to accompany him or her during the inspection, and will ask for an authorized employee representative to accompany as well. This might be a union representative or it can be just about any representative the employees choose. There have been some recent cases concerning who can be an employee representative, and it appears to me that it boils down to the Inspector’s discretion.

The OSHA Inspector will also determine if an OSHA consultation is currently in progress, and will take action as follows:
• If this is a Programmed Inspection, the consultation visit has priority and the Inspector will leave.
• If this is a Non-Programmed Inspection, the inspection has priority and the consultation will end.

The second phase is the Records Review. During this phase, the Inspector will review the following:
• OsHA 300, 301, and 300-A.
o At least 3 years back, but you must have 5 years on file
• “OSHA Poster”
• A written PPE Hazard Assessment (essential!)
• Safety Data Sheets (SDS)
• Your Written Programs
o These must be current and reflect your actual operations.
o A “canned” program that just sits on the shelf will not work!
• Training Records.
• Exposure & Medical Records, Confined Space Permits, Lockout/Tagout Records.
• Emergency Evacuation Drills.
• Posting of the OSHA 300A Injury and Illness Summary (2/1 – 4/30).
o Must be posted from February 1 to April 30, even if there were no recordable inuries.

It’s important to ensure your records are complete and up to date. Again, the time to do this is NOW, not during an Inspection.

An OSHA Inspection can be a very stressful event, but it need not be. If you would like to learn more about OSHA Inspections, I lead Audio Conferences on How to Survive an OSHA Inspection (“OSHA Citations Are Rising: Best Practices For Avoiding A Citation At Your Organization”) a few times each year. My next session is on May 5, 2015. You can view details and register at:
http://www.theindustrycalendar.com/showWCDetails.asp?TCID=1015034&RID=1011610

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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

  • 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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10 Steps to Effective Safety Programs

10 Steps to Effective Safety Programs

  1.  Find an Evangelist.This is critically important. While the steps to follow are not difficult, you do need someone to make it happen and manage it. You need someone in your company that truly believes in making the workplace safe for all employees, can do some research, learn quickly, has the ability to manage multiple projects, and can obtain buy-in from all levels. This might be an existing employee that has shown promise or you may need to bring in someone else. Not every company has someone like this in their employ, but you may and not even know it. Take a good look at your employees, the things they do and what sort of ideas they have had in the past. Start asking around and you might just find someone on staff that can be your Evangelist. If not, there are plenty of very good consultants out there that you might use. I would suggest getting one person to work on contract whose only responsibility will be your new safety project.
  2. Implement an ISMS. This is an Integrated Safety Management System. A lot of words for a means of making things happen and controlling them. Putting an ISMS in place is not really scary or difficult, it just sounds like it.  The ISMS is merely a tool and is not meant as a be-all and end-all. It is designed to help you plan, implement, and control safety measures that will reduce time off from work injuries, increase production, improve employee involvement, and ultimately reduce costs and increase revenue through improved customer relations. A search on the Internet will bring up lots of ISMS examples and help on developing an Integrated Safety Management System.
  3.  Educate & Train. This is probably one of the most important of the 10 steps. Everyone from the CEO to office and warehouse workers must be trained and educated (there is a difference between training and education). We train for skills and we educate for specific knowledge and concepts. Both are essential to a successful ISMS and a safe workplace. How training and education are implemented depends on your situation and resources. I recommend beginning with off-the-shelf, self-paced, interactive training courses in every safety subject appropriate to your workplace, such as chemical safety, materials handling, office ergonomics, etc. You can always move toward more customized courses later, but the important thing is to get the training started right away. These training courses need to be readily accessible to employees from anywhere in the world, 24 hours a day. This is easily done through one of many safety training providers that offer courses and a Learning Management System (LMS) to deliver and control everything. Good LMS’s are available for little money or you can go with an open source LMS like Moodle for free. Also check out MasteryTech or TrainCaster, which both offer courses and an LMS at a very reasonable cost. Try a search for “affordable LMS”.
  4. Make Information Accessible. Lots of ways to do this, but as easy as it is to build and manage an Intranet, it just makes sense to do so. Nearly every business has computers and these computers are connected in some sort of network. With today’s applications, creating and maintaining websites is really a quite simple task that nearly any employee can learn quickly. Once your site is up and running, this is where you post all of the information your employees need to stay safe, like job procedures, your safety policy, safety programs, and just about anything else you can think of. An Intranet is also a great tool for your employees to report accidents and submit suggestions for improvement.
  5. Involve Employees. None of this will be successful without everyone’s involvement to some degree. All safety professionals will agree that safety starts with management, and that ongoing safety in the workplace is the responsibility of each and every employee. Besides, your employees know the workplace better than anyone else and they can do the things that will save you money and increase your revenue. Setting up and running a safety committee is a good way to get employees involved and to continue spreading the word about working safely.
  6.  Identify & Control Hazards. Unsafe situations must be controlled in order to reduce injuries and limit or eliminate lost work days. And you can’t fix a problem that you do not know exists. This is where hazard identification comes in to play. It is actually very easy and does not take much time. Simple walk-around inspections and more in-depth job analysis will reveal the dangers with the biggest chance of causing injuries that put employees out of work. Do an Internet search for “job hazard analysis”.
  7.  Ensure Legal Compliance. Got to do it. If you are not in compliance, all it takes is one unhappy or disgruntled employee to make a call to OSHA and you will have inspectors all over your facility. And you can be certain that if you have not already implemented a very good safety system that OSHA will find violations. Sure they will give you a chance to fix them before they start hitting you with fines, but once you are on OSHA’s radar you may be on it forever. This is not a good thing. Another not so good thing is litigation. If an employee is injured because of a hazard that management knew about or should have known about, both civil and criminal prosecution is possible. Under California OSHA, and soon to be under Federal OSHA, managers can be held personally responsible and can go to jail.
  8.  Automate Recordkeeping. This is really easy. OSHA requires nearly all employers to maintain work-related accident records, including documented accident investigations. OSHA provides a really nice Excel spreadsheet for this purpose. Additionally, I have modified this spreadsheet to make recordkeeping really painless. Use my email link at the end of this article and I will send you a copy.
  9.  Let Your Customers Know Advertise your new safety system and its results to existing and potential clients. This will show just how serious you are about your safety responsibilities and how you want to do the right thing. Make a big deal (it really is a big deal) about your safety system and how it has improved your business.
  10.  Continuous Improvement. None of what has been done so far can remain static if it is going to continue putting more money in your pocket. Part of this safety system must include a means to occasionally re-evaluate it and continually be looking for ways to improve. As your safety system continues to mature, your employees will continue to benefit from a safe workplace and your customers will continue to see your commitment to safety. This is clearly a win-win situation for all stakeholders.

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