By Phil La Duke
Each week I hammer out another missive on the state of safety and each week I worry that I may have exhausted the well when it comes to offering up suggestions for improving the safety function, something hits me. This week it was really simple: are we collectively, as a profession imbeciles? Before you answer consider this: 86% of safety professionals (in a poll conducted by S+H magazine) said that they believed that Heinrich was at least in part correct and that the primary cause of injuries was unsafe behaviors and yet instead of focusing our efforts on ensuring that unsafe behaviors don’t get people killed, we insist on focusing on changing people’s behaviors. Are we soft in the head? If we could change people’s behaviors on a wide scale there would be no crime, no war, and a host of other lingering problems that plague society. And even if we could change behavior to any meaningful extent would we be arrogant enough to claim that we could change basic human nature? Would we dare claim that we would be able to eliminate human error? That’s nonsense of course.
I’m not going again argue against Heinrich and BBS; it’s a tired conversation and one that degrades quickly into the bombastic bellowing of fanatics on both sides. I have neither the patience nor the energy for it. But for the sake of arguments I will grant you this: Injuries are caused by unsafe behaviors—if people don’t do anything they don’t get hurt and if they get hurt doing something what ever they are doing is, by definition unsafe. If this is true we have two basic choices: either we can alter human behavior or we can accept the fact that people are fallible creatures that inevitably make mistakes and take actions that will protect people from themselves.
The idea that we should protect workers from their own unsafe actions is no, I admit, a particularly revolutionary or new idea. The Hierarchy of Controls was developed for just such a purpose, as was Failure Modes Effects Analysis (FMEA), and a bunch of other tools, and yet we cling to the idea that changing behavior is the best chance we have of protecting workers.
If we aren’t mentally feeble, then why do we obsess on changing behavior? According to the Hierarchy of Controls eliminating the hazard is the best way to prevent an injury so if we were really serious about eliminating injuries it would make sense that we would expend most of our resources identifying, containing, and correcting hazards. There is more than a correlation between hazards and injuries there is cause and effect. When we eliminate enough hazards we reduce the probability of injury. The lower the probability of injury the better or safety performance and isn’t that what we are trying to accomplish? What’s more, if we focus more on eliminating hazards we can also lessen the severity of injuries. Once again, what I am saying isn’t particularly ground breaking, but we all know that there are limits to the Hierarchy of Controls and we all know where that leads: to the lowest and least effective controls. While the lowest control on the hierarchy is PPE, even PPE cannot be considered a control without the addition of administrative controls.
We the safety function are overly reliant on administrative controls and then we blame workers for getting hurting because they didn’t follow the rules. People are going to violate the rules (I’ve written two articles on this Fabricating & Metalworking magazine), people will forget, people will take risks, people will do stupid things, but WE continue to create these ridiculous codification of behavior as if people were perfect; it makes no sense.
I’m not saying that we should abolish administrative controls, far from it. Administrative controls are integral to creating a safe workplace and we need to have them. But we need to stop making administrative controls our primary means of protecting workers. Before you prepare me to shout me down as a heretic I want you to do something. Make a mental note of your administrative controls—you probably have a hundred-page safety manual, a several hundred-page HR policy manual, and maybe even an impressive training manual. Add to that all your Job Safety Analyses, and Safe Work Instructions. Now consider how many hazards were consciously identified and eliminated in the design process, how many engineering controls you have, and how many hazards your organization actively identifies in a year. My guess would be that most of you have an order of magnitude more administrative controls than all other controls put together.
I understand the obsession with administrative controls—they’re cheap, fast, and easy to implement. I also understand the need for administrative controls chiefly because we do a really poor job of anticipating hazards until we have little choice BUT to implement administrative controls.
We need to do a better job of managing hazards and actively work to push our organizations up the Hierarchy of Controls pyramid (the real mystery of the pyramids is why so many of them ended up in safety). We need to teach our leaders to anticipate process breakdowns and take steps to prevent them and mitigate the risks to workers when prevention fails, and most of all we have to stop reacting to violations of the rules with more rules. It’s a tall order. But the pay off is that we change the RIGHT behaviors and we have a safer and more effective workplace. This won’t be easy but it will be a hell of a lot easier than trying to prevent people from making mistakes, taking risks, and making dumb decisions.