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December 10, 2010
Behavior-Based Safety: Two Perspectives

A Consultant and a Union Rep Explain, Defend Their Views

Differences of opinion between proponents of behavior-based safety (BBS) and organized labor are as old as, well, behavior-based safety itself. We sought out leaders on both sides of the issue to explain their current positions. Along the way we learned a lot about the process–how it’s evolved and changed, why passions run deep, and likely future directions for BBS.

Don Groover is an executive with Behavior Safety Technologies (BST) and Nancy Lessin is a veteran safety and health specialist with the United Steelworkers of America. We share their responses to our interview questions in a Q-and-A format in this Compliance Report. We hope the answers they provide address some of your questions as well.

BBS is generally defined as the application of the science of behavior change to problems, including workplace incidents. The approach is said to have originated with Herbert William Heinrich, an employee of Traveler’s Insurance Company in the 1930s. After reviewing thousands of accident reports, Heinrich concluded that many are the result of the actions of workers.

Today, the practice typically involves training employees to observe co-workers and to offer constructive feedback if they are found to be using at-risk behaviors, and to acknowledge their use of safe behaviors and practices.


Don Groover is a senior vice president of BST, a California-based, global safety consulting firm that helped pioneer the application of behavioral science to safety performance. Groover has helped hundreds of clients prepare for and implement successful change systems and has written extensively about safety and employee behavior.

Before joining BST, Groover worked for a Fortune 500 company as a safety and health manager. He is a Certified Safety Professional and a Certified Industrial Hygienist.

Q: Is behavior-based safety similar to the practice as BST and others introduced it more than 30 years ago?

A: The underlying principles are exactly the same. First of all, we look for the exposures that are getting people hurt and clearly define these in safe terms. We go out and collect data [observations] that are an accurate representation of what’s happening in the workplace. You [do this by looking] at both the safe and the at-risk behaviors to figure out where the biggest opportunities are. Then you develop an action plan to change those exposures. That has not changed. When I was with Balkan Chemical in 1986 I hired BST. The same principles made a lot of sense back then when I was considered an “early adopter” of behavior-based safety.

Q: What has changed?

A: We’re seeing a greater recognition by leadership that they have to establish a climate and culture in which employee engagement thrives. For many years BBS was seen as an hourly program that took care of that nagging problem called ‘behavior,’ which left management free to go and do their thing. Now there’s a greater recognition that leaders have to have their eyes wide open about what they’re asking employees to actually do and how their behavior supports them.

Management has to make sure they’re not sending conflicting messages [about expectations]. For example, we would be naive to think that productivity is not part of a supervisor’s evaluation, but you need a more balanced look at things—like is the supervisor getting employees engaged and committed?

Another thing that’s changed is that we’re figuring out how to adapt the principles to diverse workplace situations. In the early days there were a lot of rules that mostly applied to groups of employees inside closed workplaces. When we tried to apply those principles to a distributed workforce—like truckers or utility linemen—they would not always work.

So, for example, years ago we had a rule of thumb about having one trained observer for every 10 workers. With a truck driver working alone it’s not feasible to assign an observer to ride with him. So we set up a system that teaches people to do self-observations. Or we use existing mechanisms, such as using a driving trainer to also conduct observations.

You’ve got to adapt the practice to the culture. I’m actually against what people call “best practices.” It’s not been my experience that a cookie-cutter approach is workable in most situations.

Q: Why is behavior-based safety still relevant in today’s workplace?

A: The real value of behavior-based safety is that it provides a definable and impactful role in helping the organization create that culture of reciprocity between management and employees. BBS also gives employees an opportunity to demonstrate their leadership skills to the organization.

I hear leaders talk about creating a culture of engagement or a culture of commitment. To do that requires reciprocity. As an employee, I see my manager doing things on my behalf and treating me with dignity and respect. When I see giving from that level I want to give back, which is a sign of a healthy relationship.

I recently attended a meeting where three hourly [BBS] facilitators were presenting some of the creative ways they were solving safety problems and getting the message out to their co-workers. [The issue was noncompliance with a requirement to wear reflective vests because they were bulky for climbing scaffolds and other tasks.]

Employees themselves came up with an idea of a pullover reflective shirt and got co-workers to buy into the idea. They worked with a manufacturer to make sure the material would work in their particular environment.

The noncompliance uncovered in observations was solved. Management had known about the problem, but they kept going at it the old way—by continuing to reinforce the rule vs. getting employees involved in finding an acceptable solution.

Q: What does that culture of commitment ‘look’ like? What are the signs that you have it, or lack it?

A: You have to have a culture that’s ready for behavior change. When I work with a location, the buy-in I see is totally dependent on the relationship that exists between management and employees.

In a “ready culture” there are clearly defined roles about the importance of safety across all management levels and there is no confusion about how things get reported or fixed. Safety leadership is demonstrated from the site manager through supervisors.

But in an organization where management has yet to demonstrate its true commitment to the process, it’s a fight all the way to get people involved and to get any traction with the system.

Q: What’s on the horizon for the practice of behavior-based safety?

A: BBS has [traditionally] been focused on what I call personal safety. There is an evolution now targeting process safety [for more complex operating environments]. It’s about asking the right questions about critical process elements. It’s similar to what takes place on a personal level in a typical behavior observation because it’s a conversation about what’s happening.

So, personal safety is about an individual working on a piece of equipment and keeping his or her fingers from being smashed.

In process safety, the idea is to find out how much employees know by asking questions like, “Is there anything we’re doing as an organization or you’re being asked to do as an employee that causes you concern?”

Often, abnormal operations become normalized just because “things have always been done this way.” An example is that in a processing unit a bypass valve has for a long time been left in a wide-open position to increase productivity—that’s a problem and it needs to be uncovered.

Another change in direction for BBS is a focus not just on injury prevention but also on human factor events. For example, with a railroad client, we’ve established something we call “cab communication” between the engineer and the conductor to prevent train mishaps of all kinds.

When the two employees, who may be together for a run as long as 12 hours, enter into an area of concern, such as a particularly hazardous stretch of track, their communication has to be crisper and more focused than in other situations. Following the critical period, the employees engage in a directed conversation about how they communicated during that time, using a checklist to collect data.

NANCY LESSIN, United Steelworkers International Union (USW)

Long-time safety and health advocate Nancy Lessin is currently on the staff of the United Steelworkers’ Tony Mazzocchi Center for Safety, Health, and Environmental Education. There, she is involved in planning and presenting education and training programs and consulting with local unions.

Lessin was formerly Health and Safety Coordinator for the Massachusetts AFL-CIO. She has served on the boards of worker protection organizations, including NIOSH and the Massachusetts Department of Public Health’s Occupational Health Surveillance Program.

Q: Historically, organized labor has opposed behavior-based safety. Could you explain the USW’s current position?

A: Today the Steelworkers Union includes in the category of behavior-based safety anything that targets worker behavior. So that would include any prize or reward programs that are based on injury reporting. The next set is what we call injury or discipline policies. With these, if you report an injury you’re automatically seen as a careless worker and you might be threatened with or given some sort of punishment, verbal or written warning, suspension, or even termination.

Another is post-injury drug testing because the assumption is that if you’ve been injured it’s just cause for a drug test. Also included are signs posted in the workplace that track lost time or recordable injuries, as well as signs that give the message that employees are responsible for their own health and safety. The OSH Act says it’s the employer’s responsibility to provide a place of employment that is free of recognized hazards likely to cause death or physical harm.

Last but not least are behavior safety observation programs, which are often the only type people think of as behavior-based safety. In general, workers are trained to observe others and use a checklist to see if they are wearing ear protection, lifting properly, etc. These are about what workers are doing to avoid being hurt by hazards that shouldn’t be there. We’re seeing a shifting of responsibility in which employers would like to hold workers responsible for their own safety rather than address hazardous job conditions.

Q: Both OSHA and the Bureau of Labor Statistics point to apparent declines in workplace injuries and illnesses, but you’ve expressed doubts about those figures. Could you explain?

A: One of the problems in this whole dialogue is that there are not good metrics that really show what a safe workplace is. Traditionally, what’s been used as a metric is recordable injuries and lost time accidents. But often we see that when any kind of behavioral-safety program comes in, things happen that discourage the reporting of injuries and illnesses. When a consultant selling a program says that it led to a 50 percent drop in the injury and illness rate, we wonder is it really the rate or the reporting?

Back in 1989 Phillips Petroleum in Pasadena, Texas, had gone 5 million hours without a lost time accident when they experienced an explosion that killed 23 and injured hundreds. So we have very serious concerns about the measurements out there to look at what has been achieved. Our [preferred] measurements are thing like how many hazards have been identified, how many have been eliminated using the hierarchy of controls, and how many days it took between identifying a hazard and correcting it.

Q: So, apart from employee behavior, what other contributors do you see to unsafe workplaces?

A: The local unions tell us every day about things going on that are causing or contributing to workers being injured or made ill on the job. It starts with downsizing and understaffing and it goes to the issue of mandatory overtime, work overload, a lack of training, and emphasizing production over safety. With one person now doing the job of three, workers are multitasking and under time pressure.

When the backdrop is too few people doing too much work under enormous pressure, then the idea of somebody performing safe or unsafe behaviors is ludicrous. If somebody isn’t doing something right, we often find an understaffing situation, pressure, or a lack of training.

Q: BBS proponents say the practice boosts employee engagement, which is something organized labor also encourages. What’s yourresponse to that?

A: There are many ways to get employees involved, including good training about job hazards, the hierarchy of controls, and employer responsibilities to provide a safe workplace. My colleagues and I would like each and every worker to be trained to identify hazards and hazardous conditions on their jobs (including work organization hazards) as well as identify and judge various hazard control measures, utilizing the hierarchy of controls. If employers need help with that, labor is here to help them. Employers are crying poor in this economy and are turning to big-dollar BBS programs, but not really out of a desire to eliminate or reduce hazards.

At this point in time, we look at programs that focus on worker behavior as being very hazardous in themselves because they take the focus off identified hazards that have gone on to severely injure and kill workers. Our commitment to bring real hazard-based systems and eliminate behavior-based systems has never been stronger. Anyone interested in making workplaces safer should introduce hazard-observation, rather than behavior-observation, programs.

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