- ISHN GLOBAL
- EHS RESEARCH
Thou shalt not kill. People have been using rules to protect people since man left the primordial forest and walked upright for the first time. For people some rules are sacred—they are worshipped for their own sake. For others, rules were meant to be broken. Irrespective of your view of rules, they form the foundation of society of all levels. But when we rely on rules to keep workers safe we delude ourselves into thinking that rules alone can protect workers (or anyone else, for that matter) we imperil workers, customers, vendors, and ourselves.
People don’t follow the rules. I’ve written and spoken extensively on why we don’t follow the rules (http://www.fabricatingandmetalworking.com/2011/05/why-we-violate-the-rules/) so I won’t prattle on about the whys here. The fact that people don’t follow the rules really isn’t the problem. The real problem lies in safety professionals and operations officials expecting people to follow really burdensome and in, many cases, stupid rules when they know that they won’t. For rules to be effective there must be a reasonable expectation of compliance. In other words, if you know in your heart of hearts that nobody in their right mind will do what is prescribed, then irrespective of you employee handbook, it really isn’t a rule.
To understand this issue, we need to understand rules a bit more. We live and work according to a codified set of behaviors that we give a variety of names—norms, laws, work rules, regulations, etc.—but they all boil down to “rules”. In general, rules exist to keep us from killing one another—both accidentally and on purpose.
While ostensibly this is the reason for all rules, in reality that’s not always the case. In many cases, rules exist primarily to enable us to punish those people who don’t behave the ways we want them to. I suppose that serves a purpose, but it sure doesn’t make us safer, and it flies in the face of the idea that safety should be primarily about proactive reduction of risk.
Control freaks love to govern the most basic things in life, and the most lethal tool in their arsenals are rules. They talk about the rules in the hushed reverence typically reserved for the divine. Rules afford them an opportunity to control other’s behavior and give them some peace. If someone violates their precious rules, they react in righteous indignation. But beyond the nuances of rules, rules exist in the workplace primarily to help us to decide who should be punished and even fired.
A fool’s paradise
But people, as I’ve said, don’t follow the rules, and organizations that pretend that people do follow the rules put workers at risk. If we were to shift away from codifying behaviors in favor of mitigating risk, we can prevent more injuries and save more lives that increasing the consequences for violating the rules.
If work rules exist to identify the people who need to be punished and who need to be knocked back in line, how can these rules protect the many innocent bystanders? Even if you believe that over 90% of injuries are caused by behavior, you must admit that rules are fairly ineffective in keeping people safe. (In fact, rules, aka “administrative controls” rank only above personal protective equipment as the least effective safety measures on the Hierarchy of Controls). The fact that someone got written-up for violating a rule has never saved a single life, at least not directly. And often it is not the rule breaker who gets injured. The violation that becomes the proximate cause of an injury may happen so far upstream that it seems like the consequence is completely independent from the violation.
So what’s the solution?
Organizations need to have fewer rules and more guidelines. A rule is really a reactive measure: Thou shalt not…or you will be… whereas a guideline provides…well, guidance. Most rules I’ve seen can only govern about 80% of the situations that workers face, and the workers are forced to cheat in the other 20%. Guidelines can be put in place such that workers are given advice on how to make safer choices and better decisions. By providing more flexible expectations workers can be held accountable for their decisions without the binary and predetermined punishments. Also, by reviewing the choices workers make instead of whether or not they violated the letter of the law, the organizations can hold workers accountable irrespective of the outcome. The risks associated with the decision become the issue, not whether or not a rule was followed or whether or not someone was injured as a result of the choices a worker made.
Guidelines also allow organizations to treat workers as accountable adults instead of mewling children. When an individual is given guidelines coupled with expectations about their behavior it eliminates excuse making and whining. I think about times when managers defended their avoidance of holding workers accountable by whining, “Well, there isn’t a rule against it so there is nothing I can do.” I would answer their arguments by pointing out that there isn’t a rule against me defecating in their wastebaskets, but if I did it they would quickly find a way to stop me. It is, I admit, a crude example, but it elicits a visceral response that proves my point. We have some reasonable expectations that people will behave as grown-ups, and grown-ups can be held accountable to behavioral norms that can be spoken or unspoken.
Common sense isn’t common practice
We walk a fine line between communicating our expectations and holding people accountable for egregious behavior and really, REALLY stupid decision-making. In the end, the line is where we as individuals draw it. Generally speaking, we should err on the side of caution and communicate our expectations, provide guidelines for decision making, and hold people accountable for the decisions they make and risks they take, irrespective of the outcome.