‘Behavior Based Safety’ Articles

OSHA Memo Warning about Improper Use of Safety Incentives and Discipline

Guest post by Cloyd Hyten, Ph.D.

Managing consequences such as incentives and punishment are thorny issues in safety. ADI has long held that monetary bonuses based on injury counts/rates are problematic for a number of reasons including the likelihood of generating underreporting and coverups. We have also held that overusing punishment for injuries has the same effect. Safety is an area that requires a thorough understanding of how consequences such as incentives and discipline affect the behavior of employees and employers. It is rarely as simple as it seems.

In a March 12, 2012 memorandum from OSHA Deputy Assistant Secretary Richard Fairfax, Regional Administrators and Whistleblower Program Managers were warned to be on the lookout for several employer practices that may discourage reports of injuries, violating several OSHA regulations. Regarding punishment practices specifically, OSHA is concerned that practices such as disciplining employees for getting injured regardless of the circumstances surrounding the injury, or for failing to report that injury in the time or manner prescribed by the employer, or for violating a rule in the course of getting injured if this is merely a pretext for discipline, will all discourage reporting of injuries. Similarly, if an employer has a safety incentive program in place that has such strong incentives that a reasonable worker might be dissuaded from reporting injuries for fear of losing that incentive for him-/herself or for a group of people, such practices would be considered “unlawful discrimination” against a worker’s right to report injuries and invite further scrutiny from OSHA investigators.

Companies must be careful how they design consequence systems around safety. On the surface, a bonus for no injuries sounds like a good idea, but trying to reward outcomes like this leaves the chain of behaviors unspecified. True, one way to get fewer injuries is by being safer in all your actions, but an easier way is to simply do things as usual and suppress reports of injuries. Another way is through luck. Neither of these latter 2 strategies help create a safer workplace.

Similarly, when companies rely on punishment to do too much of the “heavy lifting” in managing safety, underreporting and coverups are common, and a safety culture where safety issues are openly and honestly discussed is out of reach. A successful safety program requires a sophisticated understanding of behavior and consequences.


See also Why Incentives and Safety Don’t Mix and Safe By Accident.

Are nuclear power plants too safe?

tsunamiEven though the anniversary of the Japan tsunami is less than a year old, the U.S. is licensing new nuclear power plants for the first time since 1978.  While it would be understandable to react with caution to the Fukushima disaster by temporarily closing plants and suspending or cancelling new or existing plants, the U.S. is moving ahead.  And why shouldn’t they?  Nuclear power generation in the U.S. is very safe. In fact it may be too safe!

Although there are a lot of articles warning of the dangers of death and disease caused by nuclear power, most are based on estimates and speculation that are largely unconfirmed. What we do know is that fossil fuel power plants are a much more dangerous place to work than nuclear plants. In the last 15 years there have been no deaths at nuclear plants but over 400 at fossil fuel power plants.

The danger I see for the nuclear power industry comes from overconfidence resulting from the high reliability of processes and equipment in the industry.  Therefore, the real danger may be more from human performance than nuclear radiation. I say that because a lot of what employees do at nuclear power plants is to monitor, inspect and repair equipment.

What happens when you monitor something that, because of high reliability, never changes?  The non-scientific description of the result is “complacency.”  The scientific term for complacency is extinction.  It refers to the fact that previously reinforced behavior will eventually stop when it does not produce a reinforcer. Although it is invisible in that nothing is happening, the process does produce tell-tale signs that it is occurring.  Inattention is the one that is most pervasive and dangerous.  Under extinction there is a slowing response to changes, failure to see small changes, insensitivity to them and uncharacteristic emotional reactions to the behaviors of peers and management. All businesses face a similar problem when many jobs involve monitoring reliable processes.

The well-publicized examples of sleeping on the job that occurred in the air control towers last year are examples of what happens when there is no reinforcement for looking at the monitors. When data on monitors rarely change or where no response is required when processes are in control, it is unlikely that employees will be vigilant. The solution that the Transportation Secretary implemented in the control towers (adding another controller) will not fix the problem. The problem is not in the people.  It is in rate of reinforcement built into the job. In most cases it is woefully inadequate. Correcting such problems requires a more in-depth understanding of reinforcement than a pat-on-the-back, an atta-boy or a warm fuzzy.

While the nuclear industry pays great attention to processes and behavior surrounding them, the extinction problem may need to be identified and changes made to prevent it. Otherwise, it could be lulled into complacency by being “too safe.”


Read the latest on safety regulations put in place by the NRC in this New York Times article.

Improving Post-Accident Behavior

Predictability is one word you could use to describe an organizations reaction after an accident. It is quite common for organizations to jump to some kind of response after an incident or accident has occurred.  But do they always do the right thing?  In the latest video blog, Dr. Judy Agnew examines what typically occurs in the aftermath of an accident and why organizations should turn instead to more proactive measures of safety to better avoid the potential for future problems.





See also: BBS Basics Instructor Start-Up Package and BBS Orientation Booklet

The Key to Understanding At Risk Behavior

Drs. Judy Agnew and Aubrey Daniels tackle the issue of reporting and acting on unsafe behavior in this latest video blog.  Watch as they discuss why management must not only listen but act, publicly, to remediate unsafe working conditions.  In the end, organizations will benefit from improved trust between employees and leadership.


Discipline and Safety: what you need to know before you act

While discipline is important under the right conditions, it can also be overused and misused. In this video blog, Dr. Judy Agnew describes the potential problems discipline can cause if not used properly and the side effects that may result. She also discusses why organizations shouldn’t jump to conclusions and what they should do first instead.


Personal Responsibility within a Behavioral Approach

42-15501641Guest post by
Judy Agnew

We have received much positive feedback on our book Safe by Accident and we are delighted that so many people find it helpful.  There is one issue that some people are struggling with so we want to take this opportunity to clarify.  Some readers are having trouble reconciling our discussion of the influence of organizational/management systems on at-risk behavior and the concept of personal responsibility for safety.  The question is: if at-risk behavior is found to be influenced by management-controlled organizational systems, does that let the frontline performer off the hook?

To some extent this is a philosophical issue.  The notion of personal responsibility is embedded in our culture.  It is present in our judicial, political and social systems and has served us well in many respects.  In a work setting, telling employees that they are “responsible for their personal safety” at work is helpful as a broad antecedent.  It sets the expectation that each person must do what they can to protect themselves and others.  The question is what specifically are they responsible for?  Telling miners they are responsible for their own safety and then sending them into a mine that is poorly ventilated and structurally unsound is absurd.  They cannot be responsible for their own safety under those conditions because they do not control them.  We think everyone will agree with this extreme example.  The difficulty comes with less extreme examples.  Workers who are trained in procedures but don’t follow them consistently, for example.  Our position is that there is shared responsibility in most cases.  Our concern with the notion of “personal responsibility” is that it sounds like an easy solution to a very complex problem.  We are sure that some of you have told employees in your organization that they are responsible for their personal safety.  We assume since you are reading this, that hasn’t solved all your safety problems.  Antecedents rarely do.

So where does personal responsibility fit in?

Let’s back up. The goal in safety is to prevent injury and illness.  If we say that people are responsible for their own safety, then it follows that if they are not safe, they are to blame. Our point is that blaming people for things that are, at least to some extent, outside of their control does not accomplish the goal.  If it did more organizations would be perfectly safe by now.  But let us be very clear: we are not suggesting that accountability (a synonym of responsibility) is bad.  Accountability is essential in safety.  However, it is critical that organizations first determine WHO should be accountable for WHAT.  The word, accountability, is often code for whom to punish.  The issue is not who should be punished but what actions will correct the situation so that it will not recur.  Although punishment is appropriate under certain circumstances, we see too often that organizations punish only the person at the point of the accident without fully understanding the systemic issues that have contributed. This is not only unjust, but it fails to rectify the situation.

Systems are designed and maintained by people.   Therefore, there should be accountability for those who control the systems to change the systems if they are faulty.  Once the systems are changed then everyone who works in those systems should be held accountable (positively reinforced for engaging in safe behaviors and corrected when they are not).  This is not about absolving personal responsibility–quite the opposite.  It is about establishing accountability, at all levels, that will lead to true improvement.  Frontline performers need to be held accountable for those things under their control.  They should be responsible for reporting hazards, providing feedback to keep peers safe, participating in safety meetings, talking to management when systems make working safely more difficult, offering solutions, and working to improve their own safe behaviors.  Frontline performers will be more successful in “taking personal responsibility for their safety” if they work in partnership with management and those who control the organizational systems within which they work.

Incident Investigation: Using Science to Develop Safe Working Habits

Understanding human behavior scientifically is critical in safety, particularly when it comes to investigating when something has gone wrong. In this video blog, Dr. Judy Agnew and Dr. Aubrey Daniels explain how a scientific approach can lead to a safer workplace and why consequences are the most important thing in determining whether or not someone will do something again.


Why Incentives and Safety Don’t Mix!

In our latest video blog, Dr. Judy Agnew and Dr. Aubrey Daniels challenge commonly used safety incentives.  Who doesn’t like a good challenge or contest, right?  True, but safety incentives, by their very nature and design, are set up to reward an outcome that can come at any cost. Find out why, even with the best of intentions, organizations can put themselves at risk for unsafe behavior by using safety incentives.

Lagging Indicators: Don’t get caught focusing on the wrong safety measures

Yesterday, the Federal Government filed its final report on what caused the 2010 Gulf oil spill. It’s no surprise that there are number of factors that contributed to this disaster. One of which is sure to be a reliance on lagging indicators as a measure of safety.

In this latest video blog, Dr. Judy Agnew explains why a reactive approach to safety, such as relying on lagging indicators, fails to identify what can be done to prevent accidents in the first place, and what organizations should focus on instead.


Safe For What? Why most of us are focusing on the wrong things when it comes to safety

Who doesn’t want to be safe?  But, more times than not, organizations focus on safety for safety-sake instead of as the gateway to quality, cost and production. In this latest video blog, Dr. Aubrey Daniels shares a broader discussion on safety in the workplace and the benefits of using a scientifically based approach to gather and track data. Learn why the data of safety is behavior and how matrices can help you identify the right behaviors and get them to habit strength.


For more on the topic of workplace safety, visit our many safety related articles on www.pmezine.com.