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Closing Time

Workers help craft the best safety rules

Time to rebuild the “Rule Mill”

By Timothy Ludwig Ph.D.
Workers help craft the best safety rules
December 4, 2018

Rules are so easy to make that safety offices are often accused of being a “Rule Mill” because they continuously produce their rule-of-the month. Why do we create so many rules? One particular cog in our mill that causes us to create rules is incidents. When we suffer an incident we want to throw every tool in the arsenal to keep it from happening again. One of the simplest tactics is to create (yet another) rule. Do you think adding new rules encourage folks to report their minor injuries, close calls, and concerns? The answer is “no.”

Discretion, not restrictions

Most of us don’t like rules that become overly restrictive. Our employees are the same way. I’ve heard many comments about rules:

They are made in a vacuum and don’t fit the context in which I work.  

They are just created as a C.Y.A. exercise so the lawyers are happy they can pin one of us to the wall when an incident occurs.  

These rules require me to add more and more layers of PPE to the point I can’t move.

Instead, employees want discretion over the way they do their tasks. And, to be frank with you, without this discretion employees cannot help you find new ways to do their tasks safely. 

Rules — a form of begging

Rules are hard to enforce. They are just antecedents. Students of behavior science know that antecedents only direct behavior, they don’t motivate. I’m fond of calling most antecedents like rules “exhortations” (translation = begging). Antecedents need to be connected to consequences to be powerful. 

Rules need to be related to something else to be effective. Often, this something else is the threat of discipline. Discipline doesn’t work until the disciplinarian is present and even then the disciplinarian may, and often does, look the other way... because they find the rule cumbersome as well. So is there a better way?

How to get compliance

Rules are designed to keep us safe and are made by well-meaning folks thinking through potential risks in the face of hazards. Rules are good for all of us… so I guess the pertinent question is “How do we get people to follow the rules?”

A good friend of mine and I were traveling around the world assessing the safety culture within large mines in a mineral resources company. There are two main areas of pit mining. There are the folks that drive big trucks down into holes that have been dug out through explosives and mega-shovels. Respecting the rules in the pit can keep you from being buried, crushed, or otherwise blown to bits. After ore is brought to the surface, it is dropped on a conveyer and carried to the mill. Huge grinding machines tear up the rock until it’s processed into the end product. And brother, when equipment in the mill goes down, all production stops and there is hell to pay.

Workers don’t know the rules

One of the questions my friend and I asked as we conducted confidential interviews of employees was, “Do your fellow employees follow the safety rules?” The answer from the pit was generally “yes” with some complaints about how the rules slow down production or are a pain in the ass. 

However, without fail, across the world, the answer from the mill was emphatically “no.”  

This was the case until we visited a site outside of Perth, Australia. We had spent a pleasant morning interviewing the pit employees who painted a picture of a pretty good safety culture. Took a nice tour. Our afternoon was to be with the mill employees and we knew our pleasant day was ending.

We found ourselves across a lunch table from five guys from the mill and we pulled out their injury and survey data. To our amazement, they had one of the best safety records we had seen in our travels. Their safety culture survey data was equally amazing. Compared to the company norms, they were in the top percentile in employee perceptions of everything safety culture. 

My friend and I were skeptical when we asked our stock question, “Do your fellow employees follow the safety rules?” Their answer: “YES.” My friend replied with a scrunched face, “Really? You know this is confidential and no one can get in trouble, you can tell the truth.”  Their reply again was “Yes.” They were looking at us with straight faces telling us something we knew was highly unlikely for a mill setting.

Not believing a word of this, my friend leaned forward and said accusingly, “We’ve been to almost every one of your company’s sites, all over the world, and no one, not one person interviewed from the mill said they always followed the company safety rules. Yet… here you are looking us in the eyes telling us that you do? Why should we believe you? Why would your mill be so very different and follow rules?”

Workers creating & revising rules

I still remember their puzzled faces staring back at us in disbelief. There was an awkward silence until one of them ever-so-calmly replied “Why would we break the rules? We created them.”

In all my years studying behavioral safety, this had to be the most profound thing I had ever heard.

They went on to tell us of how their safety manager would meet with groups of them quarterly, 30 minutes a shot, and help them create and revise rules around the mill’s hazards. We found out a couple things: a) Their rules were nimble and allowed for discretion when the situation didn’t line up; b) They constantly were trying to find new ways to do tasks safer, and get this; c) We found out their rules tended to be more stringent than rules created by managers at other sites. Most importantly, we learned that their rules were followed and the workforce was safer, the data proved it.

Intoxicated by rules

Rules turn us into police officers “fishing for faults,” compelled to “catch” people breaking the rules. I’ve seen safety managers and operations supervisors intoxicated by this power. When you view the workplace through this lens of rules then you often fail to see the real context for behavior.

But when I think about that crew in the mill exactly on the other side of the globe from my home I think a new approach to safety rules is in order.  

And the answer is as simple as asking a question.

KEYWORDS: employee engagement rulemaking workplace safety and health

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Timothy Ludwig’s website is Safety-Doc.com where you can read more safety culture stories and contribute your own. Dr. Ludwig consults and serves as a commissioner for Behavioral Safety Accreditation at the non-profit Cambridge Center for Behavioral Studies (CCBS: behavior.org) and teaches behavioral psychology at Appalachian State University, in Boone, NC. If you want Tim to share his stories at your next safety event you can contact him at TimLudwig@Safety-Doc.com.

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