Are you running a safety bureaucracy?
Obsessing over numbers leads to more valueless mandates
• What exactly does counting negatives really say about your organization’s safety?
• If the quantity of negatives is going down, does that mean the quality of your safety program is going up?
Dr. Sidney W.A. Dekker provides an interesting perspective on the use of “error counting” to demonstrate progress in safety.1 Dekker notes that safety professionals and management embrace the belief that the “absence or reduction of errors is synonymous with [improved] progress in safety.”2 He adds as errors increase an opportunity presents itself for management to intervene in some fashion.
Countless times I’ve witnessed senior leaders debate and discuss on and on the nuances of their so-called safety statistics, thinking they can actually draw conclusions and render decisions from numbers, percentages, bar charts, and graphs of tabulated safety errors that have already occurred. Often these discussions lead to a mandate to revamp the corporate safety policy, create more procedures, conduct more inspections, make more observations, set higher safety goals, initiate a new wave of training, etc.
Obsessing over safety errors that have already occurred, thinking this obsession will improve the future safety performance of the organization going forward, drives all of these mandates. Interestingly, these same senior leaders will do nothing other than pontificate about their personal contribution to safety if the number of safety errors is going down, believing they will continue to track downward. Tabulating what has already happened in the past is no indicator of what is going to happen in the future.
Where’s the context?
Of course, the missing link in all of these safety error statistics is “context.” Sure, virtually every one of these error events has likely undergone some formal or informal analysis, often using our most popular tool, the notorious “root cause analysis,” but is there really a “root cause” to safety errors? Intellectually, I believe safety professionals, in general, recognize and agree that there are typically many causes to a safety error; but many of us are trapped in management’s demand to conduct a “root cause analysis” so leaders can take some kind of action.
Unfortunately, many managers are still fixated with the conduct of “root blame analyses” when a safety error event occurs. Once the offender is identified, the analysis is closed, the safety error is tabulated, and some form of retribution is administered to the wrongdoer and, more times than not, his/her supervisor.
All of this leads to the safety axiom that “humans are a problem to control.”3 It is only in the latter part of the 20th century that attention began to focus more on reducing or eliminating the risks associated with operating technologies and work environments instead of focusing on “changing” humans through “behaviorism.”
Dekker notes humans are beginning to be viewed as the recipients of trouble versus the cause of trouble. Indeed, humans are recipients because of their proximity to safety-critical processes. This proximity provides an opportunity for organizations to capitalize on workers’ expertise and practical experience – people become resources to harness.4
Safety error counting has contributed to the expansion of safety bureaucracies in organizations. Following the mantra of “seeing people as a problem to control” and mandating procedures, inspections, compliance, etc. will likely deliver more of the same and realize little, if any, improved safety performance. Dekker points out that research has shown numerous unintended consequences surfacing from safety bureaucracies, such as the inability to predict unexpected events; a focus on bureaucratic accountability, quantification and numbers games; creating safety problems due to applying safety rules; along with constraint on workers’ freedom, diversity, and creativity.5
Dekker refers to a recent Delphi analysis in the construction industry that pointed to safety interventions most associated with safety bureaucracies that were deemed least worthwhile. The interventions included writing of safety plans and policies, recordkeeping and incident analysis, and emergency response planning. Having them makes no real safety difference.6
Nothing could be further from the truth than believing safety bureaucracies are necessary to insure safety progress. Dekker says that safety bureaucracies:7
• Self-perpetuate through bureaucratic accountability, government regulations, paperwork begets paperwork, and nonoperational positions grow more nonoperational positions.
• Tend to institutionalize and further legitimize the counting and tabulation of negatives (i.e., incidents, violations, etc.);
• Are organized around lagging indicators – measuring that which has already occurred. The predictive value of lagging indicators is known to be poor [if not nonexistent];
• Tend to value technical expertise less, disempower middle management, and delegitimize operational experience;
• Allow the gap to expand between how an operation works and how a safety bureaucracy thinks it works;
• Compromise richer communication with operational staff by supervisors and managers by the daily, if not hourly, demands of safety bureaucratic accountability in the form of countless meetings, emails, and volumes of paperwork.
Compounding the problem
If it isn’t enough for you to have to endure a safety bureaucracy within your organization, effective January 1, 2015, the U.S. OSHA’s new recordkeeping and reporting rules will require many more companies to report within 24 hours severe work-related injuries beyond reporting fatalities to OSHA within eight hours. According to OSHA’s spokesperson, Ms. Ann Mangold, the agency estimates it will receive 117,000 reports/year nationwide, or about 60 times the almost 2,000 fatality reports it received in 2013. OSHA wants us to believe that all these additional reports will provide the agency with a better insight into allocating resources, assessing the adequacy of its standards, and helping OSHA to do a better job.8
With all due respect to Ms. Mangold, unless Congress plans on providing OSHA a larger budget for increasing its workforce, the likelihood OSHA can manage and analyze this expected huge influx of safety error reports in the coming years is doubtful. OSHA will join the ranks statistics-obsessed companies that have mastered the skill of driving into the future by only looking in the rearview mirror
1 Dekker, S.W.A. 2015. Safety Differently – Human Factors for a New Era. CRC Press. Boca Raton, FL.
2 Ibid. pp. 93.
3 Dekker, S.W.A. August 2014. Employees – A Problem to Control or Solution to Harness? In Professional Safety. 59 (8): 32-36.
4 Ibid. pp. 33.
5 Ibid. pp. 34.
6 Hallowell, M.R. and J.A. Gambatese. 2009. Construction safety risk mitigation. In Journal of Construction Engineering and Management. 135 (12): 1316-1323.
7 Op. Cit. pp. 32-33.
8 The Morning Call. January 1, 2015. Employers face rigorous OSHA injury-reporting rules in 2015. Retrieved January 3, 2015. http://www.mcall.com/news/local/mc-osha-new-rules-20150101-story.html