Behavioural safety schemes: A union viewpoint
Nancy Lessin is the health and safety co-ordinator for the Massachusetts AFL-CIO and is an international union authority on Behavioural Safety Schemes. She provided this detailed briefing for Hazards readers, details of which are included in Hazards 79, July-September 2002

Nancy answered these questions for Hazards:

1. Surely there is nothing wrong with changing bad worker behaviour?
2. What is BS and does BS work?
3. Why should unions be concerned about BS?
4. Have unions taken action against BS?
5. Who is pushing BS and who is benefiting from it?
6. What message to you send to unions? To the Health and Safety Executive (our OSHA)? To employers?

1. Surely there is nothing wrong with changing bad worker behaviour?

What exactly is the definition of "bad worker behaviour"? Is that when a worker fails to don appropriate personal protective equipment? Was that what Brent Churchill manifested when he reached for a 7,200 volt cable without first putting on his insulating gloves? Mr. Churchill was a 30 year-old lineman for a utility company in Maine (U.S.); he died as a result of this industrial accident. His employer said it was his fault - he didn't use the protective equipment necessary to do his job safely.

There are really many questions one needs to ask in situations such as this: Was his training adequate? Were the insulating gloves available? In Mr. Churchill's case, he was both adequately trained, and the gloves were available. But there was something else operating here. In his last sixty hours alive, Brent Churchill slept a total of five hours.

The rest of the time he was working. It was during an ice storm in Maine. The utility company had down-sized the lineman department. Mandatory overtime was in full swing. And Mr. Churchill had been climbing up and down 30 foot poles for the better part of 60 hours, with very small breaks here and there totalling five hours. A contributing cause of this workplace fatality was a worker's failure to use protective equipment. The root causes lay in the system of production and how management decided to organize work: understaffing operations, mandating overtime and ignoring worker fatigue, all to gain more profit for the company.

Focusing on worker behaviour as opposed to hazardous conditions as the cause of workplace injuries and illnesses leads to approaches where workers are blamed for "bad" or "unsafe" behaviours such as not wearing safety glasses or not following procedures. What gets missed by focusing on worker behaviour, what never gets asked, is why. Why did a worker not wear safety glasses? Why did a worker not follow procedures? Workers may not wear safety glasses because their employer buys cheap glasses that scratch easily, and it's very difficult to see out of them; or, they may be working on a process where the glasses fog up and in order to see their work, they need to remove the glasses. Perhaps engineering controls could enclose the operation in a way that eliminated the need for workers to have to wear safety glasses in the first place. Blaming workers for not wearing safety glasses allows employers to never have to explore or deal with these issues.

In the case of workers not following procedures, there are many reasons why this happens. There is often a "push for production" that pits production against safety, and production is always primary.

A classic example of this involves an industrial laundry in Massachusetts (U.S.) where workers were trained to never put their hands in the machinery when material got stuck in the machine. The proper procedure was to shut the machine down and call maintenance to fix it. A multi-lingual workforce worked in this laundry, and training in this rule was presented in three different languages; signs posted in the workplace reminding workers to not put their hands in the machinery were also in three languages. Thus, when a worker got a hand injury on these machines, it was seen by management as the worker's fault.

The reality in this situation was that each worker had a production quota. If they did not meet their production quota by the end of each day, they could be terminated. The laundry had just down-sized the maintenance department. When workers called maintenance to fix a jam, it would take maintenance twenty minutes to two hours to respond to the call, and the lack of production during that time was counted against the worker.

The written rule in this workplace was: don't put your hand in the machine if something gets caught. The real rule was: workers better put their hands in the machine to clear jams, but if they get injured it will be their fault. Again, focusing on workers' "unsafe behaviours" eliminates the need for management to examine unsafe systems of work that promote or even necessitate workers taking risks in order to keep their jobs.

The fact is, good occupational safety and health practice is based in the understanding that all work-related injuries and illnesses are caused by workers' exposure to hazards. There are no exceptions. In order to have a so-called "at risk" behaviour, there must be a hazard. If there was no hazard, there would be no "risk" and there could be no injury or illness. The goal of workplace health and safety efforts, then, is to find and fix hazards and to understand and change systems of work such as unsafe staffing levels, mandatory overtime/extended work hours and a "push for production" that intensify work loads, create unreasonable work pace and cause workers to work when they are fatigued.

Do workers sometimes make "mistakes"? Absolutely. Al Chapanis, a former profession of human factors engineering at Johns Hopkins University in Baltimore, Maryland (U.S.) said, "Everyone, and that includes you and me, is at some time careless, complacent, overconfident, and stubborn. At times each of us becomes distracted, inattentive, bored and fatigued. We occasionally take chances, we misunderstand, we misinterpret, and we misread. These are completely human characteristics. …Because we are human and because all these traits are fundamental and built into each of us, the equipment, machines and systems that we construct for our use have to be made to accommodate us the way we are, and not vice versa."

Professor Chapanis's colleague Susan Baker, professor of health policy and management and director of the Johns Hopkins Injury Prevention Center put it this way, "All too often…victim-blaming has characterized responses to the problem, and emphasis on training and education have taken precedence over more effective ergonomic and 'passive' approaches that do not place the burden of prevention on the workers."

Health and safety approaches that focus on workers' behaviour condemn workers as the problem. The labour movement sees workers as the solution. There is no one better to identify the hazards on a job, or come up with ideas to eliminate or reduce those hazards, than the worker doing that job. If a job is being done "unsafely," a good rule of thumb is to "ask why five times."

To take the earlier example of workers not wearing safety glasses, it could look something like this:

Andrea got something in her eye at work.
But why?
Because she wasn't wearing her safety glasses.
But why?
Because they were all scratched up and she couldn't see out of them.
But why?
Because her employer bought the really cheap glasses that get scratched all the time.
But why?
Because her employer wanted to save money.
But why?
Because profits are more important to her employer than worker safety and health.

Asking "why" questions allows an inquiry to get to root causes - the source of the problem that will need to change in order to bring about a safer workplace. Unions can then strategize about what it would take to get an employer to purchase adequate personal protective equipment, or use engineering controls to eliminate the need for workers to wear personal protective equipment, or in some other way make the workplace safer. An approach that blames workers for their "bad behaviour" prevents root cause analysis, and thwarts real prevention efforts.

2. What is BS and does BS work?

Behavioural Safety is an approach to workplace safety that focuses on workers' behaviour as the cause of most work-related injuries and illnesses. Consultants who sell behaviour-based safety programs maintain that 80 per cent- 96 per centof workplace injuries are caused by workers' unsafe behaviours. Trade Union health and safety activists in the U.S. traced the origin of these statistics to "research" conducted by an insurance investigator named H.W. Heinrich in the 1930's in the United States. Heinrich's research consisted of reviewing supervisors' accident reports and making conclusions about accident causation from those reports. In the 1930's, not unlike today, supervisors' accident reports blame workers for the accident. Heinrich concluded that 88 per cent of all workplace accidents were caused by workers' unsafe acts. A behaviour-based safety approach focuses on ways to identify workers who are behaving "unsafely" and coax, cajole and/or threaten them into behaving safely on the job.

A variety of consultants market behaviour-based safety programmes. Among the consultants marketing these programs internationally are DuPont (the DuPont STOP program) and Behavioural Science Technologies (also known as BST). While there are some differences between the different brands of behaviour-based programs, most have several common elements. Lists of "critical worker behaviours" are developed, often with input from workers themselves who are invited and welcomed into the process. Inevitably these lists end up with elements such as "staying out of the line of fire," "proper body position," and "using personal protective equipment." Workers (and/or supervisors) are trained to observe workers doing their jobs and, using the "critical behaviour list" generated in that workplace, noting down when workers are using safe behaviours or committing unsafe acts. There is training for those who will be observing, and frequent observations of workers. There is often management commitment of substantial resources to promote the behavioural safety approach.

Several very problematic things happen in workplaces that have adopted behavioural safety. The "hierarchy of controls" is abandoned. This is a system of addressing workplace health and safety problems established an order of preference for hazard control measures:

• eliminate the hazard by redesign, toxic use reduction or other means;
• use engineering controls to prevent workers from coming in contact with the hazard;
• use warnings to notify workers of the danger (e.g. back-up alarms on trucks);
• training and procedures; and
• use of personal protective equipment.

Eliminating hazards is seen as the most effective way of addressing an occupational safety and health problem; personal protective equipment is viewed as the least effective method. When behavioural safety approaches are being used, "staying out of the line of fire" replaces effective equipment safeguarding and design; "proper body position" replaces good ergonomics programs and ergonomically-designed tools, workstations and jobs; and "personal protective equipment" becomes a substitute for noise control, chemical enclosures, ventilation and toxic use reduction.

Instead of having a focus on identifying hazards and eliminating or reducing them, the emphasis of the safety program is on getting workers to work more carefully around hazards that shouldn't be there in the first place. Workers are supposed to duck, dodge, jump out of the way, lift safely, wear personal protective equipment, avoid the line of fire, and keep their eyes on the task.

When a worker is injured, it is viewed as his or her fault for not working carefully enough. Discipline can then become management's preferred response to worker injury.

Even in cases where a behavioural safety program is implemented with assurances that there will be no discipline, there are several problems. Workers still often suffer inquisitions when they report injuries to determine what "unsafe behaviours" they were engaging in. And, the emphasis for corrective action remains on promoting safe worker behaviour rather than eliminating or reducing hazards.

Fear and intimidation descend upon a workplace with a behaviour-based safety program in place. Workers avoid inquisitions into their behaviour by ceasing to report accidents and injuries. When injuries aren't reported, hazards don't get identified or corrected.

Closely related to a behavioural safety approach are two programs employers frequently introduce with or without a full-blown behaviour-based safety program: safety incentive programs and injury discipline policies.

Safety incentive programs offer prizes to workers or groups of workers when no injuries are reported. Prizes can range from jackets and mugs to gift certificates to free lunches, cash, days off with pay, or trucks. Injury discipline policies deliver discipline or some adverse consequence such as automatic drug testing when workers report injuries.

An injury discipline program popular in the United States is the "Accident Repeaters Program," which identifies workers who have had a certain number of injuries (usually one or two in a 12 or 24 month period) and place them in a program whereby they will get counseling if they report another injury; receive a written warning for their next injury; suspension for the next injury; and termination should they report another injury after that.

Another injury discipline program popular in the United States assigns a point system to injuries reported and/or workers compensation claims filed. An injury requiring only medical care and no days away from work is assigned one point; a lost-time accident is worth five points. When a worker reaches thirty points, he or she is fired.

One result of full-blown behavioural safety programs as well as safety incentive and injury discipline policies is that workers don't report their injuries. They may not get the medical care they need as a result, and again, hazards causing those injuries don't get identified or corrected.

In a Massachusetts workplace last year, a worker was caught in an unguarded machine and crushed to death. Minor injuries that had occurred on that machine weren't being reported because the plant utilized both a safety bingo game that rewarded workers for not reporting injuries and a post-injury drug testing policy that mandated drug testing for all workers who reported injuries. If those minor injuries had been reported, the lack of machine guarding could have been identified and corrected. Instead, the hazard was never identified, and a fatality resulted.

Safety programmes and policies that discourage the reporting of work-related injuries and illnesses are hazards in and of themselves; they can, in fact, be deadly.

Another very problematic consequence of behaviour-based safety programs and safety incentive programs with group prizes has to do with the destruction of solidarity among a workforce. In safety incentive games where everyone in a department or workplace gets a prize as long as no one reports an injury, workers put pressure on co-workers to not report their injuries.

In the case of behaviour-based safety programmes complete with "critical behaviour" checklists and worker observations, those doing the observing get time off the job and special status; those being observed feel scrutinized by co-workers. There are sometimes one or more behaviour-based safety coordinators that the union is allowed to appoint, who work full-time on the safety program.

They enjoy their office space, their access to management, trips to conferences and other perks, and become invested in the programme.

Sometimes management will address a problem in the context of a behaviour-based programme that they were not addressing when the union was pushing for a solution. This serves to undermine the union. All of these situations can lead to a divided workforce, with some members supporting the programme and others opposing it. A main source of union power is our solidarity. Anything that messes with solidarity messes with the strength and power of a union. Behaviour-based safety programs can pit worker against worker, decrease solidarity and weaken union power.

Finally, it's not called behavioural safety for nothing. Safety is the prime concern, as opposed to health. In the U.S., employers grappling with the cost of workers' compensation are much more concerned about industrial accidents than occupational disease, because approximately 95% of workers compensation cases are for job-related injuries as opposed to illnesses. Employers have other ways of dealing with occupational disease (e.g. implicating "life-style" and genetic factors rather than workplace exposure) and don't feel they need a whole corporate program to deal with it.

Do behavioural safety programmes "work"? That depends on who is being asked, and what is meant by "work". Employers like behaviour-based safety for many reasons. When injury reporting is driven underground, several things happen that benefit employers. There is a decrease in the filing of workers compensation claims. This can save employers a lot of money.

In addition, employers can escape government inspections. In the U.S., OSHA (our Health and Safety Executive) collects employer's injury and illness records annually, identifies employers with high rates of injuries and illnesses and from this data makes a targeting list for surprise inspections.

Employers can minimize the chances of an OSHA inspection if they have fewer injuries and illnesses showing up on their reports. Instituting a behaviour-based safety programme and/or safety incentive programmes and injury discipline policies results in fewer reported injuries and illnesses after these programs are introduced. Employers and consultants who sell these programs tout wonderful statistics showing often dramatic declines in workplace injuries and illnesses. This is used to "prove" that these programmes "work."

Employers also like behaviour-based approaches because management is taken off the hook for fixing hazards. Gone are demands for engineering control, toxic use reduction, and ergonomic job design, as attention shifts to workers wearing personal protective equipment and using proper body position. Gone is any focus on how work is organized or being restructured - issues like adequate staffing levels, limits on extended work hours, humane work load and work pace are not even considered.

As an added bonus, employers enjoy the assault on solidarity created by behavioural safety programmes. Union power is weakened, to the delight of management. Behaviour-based safety in truly a win-win-win proposition for employers.

For workers and unions, the opposite is true. Behaviour-based safety programs focus attention away from hazardous workplace conditions and thwart hazard identification and control efforts, with harmful and tragic results. They divide the workforce, destroy solidarity and weaken union power.

3. Why should unions be concerned about BS? (see above)

4. Have unions taken action against BS?

In the U.S. there has been resistance to behavioural safety on the shop floor, local and national union level. The AFL-CIO (equivalent to the TUC) and a number of individual unions have passed health and safety resolutions at their conventions and/or executive boards that oppose behaviour-based safety. The AFL-CIO's policy resolutions opposing "blame-the-worker" safety programs passed at their 1999 and 2001 conventions state:

"At the same time work restructuring and changes in employment are raising serious safety and health concerns, many employers are moving to shift responsibility for job injuries to workers by focusing on worker behaviour instead of hazardous conditions. Across industries, a variety of programmes are being implemented that provide incentives and awards to workers who do not report injuries, establish elaborate procedures for observing and documenting workers' behaviour and "unsafe acts" while ignoring employer mismanagement and the root cause of injuries, institute policies to discipline and fire workers who are injured and impose drug testing for every worker who reports a job injury regardless of cause.

"These programmes and policies have a chilling effect on workers' reporting of symptoms, injuries and illnesses which can leave workers' health and safety problems untreated and underlying hazards uncorrected. Moreover, these programs frequently are implemented unilaterally by employers, pitting worker against worker and undermining union efforts to address hazardous workplace conditions through concerted action.

"The AFL-CIO opposes employer programs and policies that shift responsibility for worker safety by focusing on worker behaviour instead of workplace hazards and employer mismanagement and that create disincentives to reporting injuries or hazards. We believe such practices undermine worker protection and are illegal and discriminatory under the Occupational Safety and Health Act."

The AFL-CIO also encourages unions to assist members with filing OSHA complaints when they have been denied prizes or suffered automatic discipline or drug testing for reporting an injury. Under OSHA in the U.S., workers have protection against employer discipline or discrimination for exercising their rights under the Occupational Safety and Health Act. One right that workers have under the OSHA law is to report a work-related injury or illness. Workers who are denied prizes or given discipline when they report an injury have been discriminated against in violation of the OSHAct.

Labour law in the United States deems health and safety a "mandatory subject of bargaining," meaning that employers cannot refuse to bargain with unionized workers over health and safety issues and are prohibited from making unilateral changes in health and safety programs and policies without providing the union an opportunity to bargain. In situations where an employer has decided to initiate a behaviour-based safety program, a safety incentive program or injury discipline policy - even mid-contract - unions have demanded to bargain.

To counter management's proposal of a behaviouralal safety program, unions have proposed comprehensive worksite health and safety programs. These comprehensive worksite programs focus on a systems approach to health and safety that emphasizes the identification and elimination of root causes of workplace injuries and illnesses: workplace health and safety hazards.

Key to winning at the bargaining table is engaging in a campaign that includes educating and involving the membership, identifying allies, identifying leverage and employing escalating tactics. Examples of such tactics have included workers all wearing anti-behavioural safety buttons (badges); other types of solidarity actions; placing fluorescent stickers on hazards in the workplace to bring a focus back to hazards rather than workers' "unsafe behaviours"; making a sign for the union bulletin board that reads "It has been x days since we asked management to correct [a particular hazard] and they have still not fixed it" (and keeping the count going each day); and threatening to call OSHA in to inspect the workplace.

The United Steelworkers of America developed buttons (badges) for locals going through such campaigns that have a large BS in the center, with a line drawn through it, and the words "Eliminate Hazards - Don't Blame Workers" around the outside.

Some unions have also aggressively pursued the adoption of a systems approach to health and safety in workplaces where they represent members. A systems approach is rooted in the understanding that work-related injuries and illnesses are caused by workers' exposure to hazards, and hazards can exist or be magnified when systems of safety are not present.

Control of hazards lies in utilizing the hierarchy of controls, which supports the elimination of hazards and the use of engineering controls as preferable to lower-level and less effective control measures such as using personal protective equipment. Human factors play a role in occupational safety and health, and systems that allow or promote understaffing or mandate overtime are fundamentally unsafe. The issue isn't that workers are working unsafely or carelessly, but that there are unsafe systems that are problematic and in need of change. Unions that favor this systems approach have offered it as an antidote to behaviour-based safety programmes.

In a time of major work restructuring, work intensification and speed-up, the focus on individual workers at the expense of work environments makes behaviour-based safety programs themselves a work hazard that must be eliminated.

5. Who is pushing BS and who is benefiting from it?

Consultants who make millions selling these programmes, and employers (for reasons identified in #2) benefit and push these programs. (Again, see #2)

6. What message to you send to UK unions?To the Health and Safety Executive (our OSHA)? To employers?

For UK unions: Formal behaviour-based safety programmes originated in the United States. Often employers try, test and tweak programs in the U.S. and then export them across the globe.

Behaviour-based safety programmes reared their head in a big way in the U.S. about 10 or 15 years ago, when work restructuring was becoming rampant. Workforces were being down-sized; workers remaining on the job were confronted with increased work loads, increased work pace and extended work hours; and training for new job duties was absent or inadequate. Turbulence in the workplace was legion, with workers confronted daily with new technologies and new management policies that accompanied work restructuring. Employers were making changes in order to boost efficiency and productivity, and to increase their control over the workforce. These changes had significant negative impacts on individual workers as well as on unions.

One key impact of these changes was on safety. Union representatives from unions in many different and diverse industries noticed worsening workplace health and safety conditions associated with new technologies, new management policies and work restructuring. They spoke of increased back and repetitive strain injuries, hazards from working alone, hazards associated with absent or inadequate training, increased stress, safety hazards caused by the push for production, increased work-related injuries and illnesses and many other health and safety-related problems.

But, instead of examining how core work processes were affecting job health and safety, many employers chose to point the finger at workers themselves. Enter "behaviour-based safety" - the safety programmes that claim that 80% to 96% of job injuries and illnesses are caused by workers' own unsafe acts.

Behaviour-based safety programmes focus attention on worker "carelessness" and workers' "unsafe behaviours", place the blame for safety problems in the workplace on workers themselves, and divert attention from the root causes of the problem: hazards on the job, unsafe conditions, work restructuring, new technologies and other workplace changes.

Employers' emphasis on blaming workers is not new. For decades if not centuries, employers have understood that putting the burden of safety on their employees can save them the expense of more costly design changes and spare them challenges to what they see is their right to manage - their unfettered right to organize and restructure work in manner(s) of their choosing. What has changed is the nature and amount of restructuring going on in workplaces across industrial sectors.

Work restructuring is in full swing globally, and behavioural safety consultants based in the U.S. are aggressively marketing their wares to employers and governments throughout the world. This import from the U.S. is one of many employer-supported workplace programmes that needs to be sent packing.

Ask yourselves and your members one question: "Whose behaviour needs to be changed to improve health and safety at your workplace?" It's management behaviour that is putting workers' health and lives at risk, and management behaviour that must change in order to achieve safe and healthy workplaces.

To the HSE: Promoting behavioural safety flies in the face of good occupational safety and health practice, the hierarchy of controls and the goal of hazard elimination and control. Employers are making decisions to operate short-staffed, intensify work loads, speed up work pace, require workers to work extended work hours sometimes for days in a row, combine jobs, offer little or no training, and engage in a host of other practices that result in workers engaging in unsafe practices to get the job done and keep their jobs. It is the behaviour of management that is putting workers' health and lives at risk. And it is the job of government to assure that workers' health and safety is protected on their jobs.

To employers: Fix hazards, don't blame workers. Every step you take, every move you make, we'll be watching you.

Nancy Lessin, Massachusetts AFL-CIO, USA. Talking to Hazards, July 2002