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BS Alert: Behavioural safety schemes warning

BS badge imageIn June 2002, HSE published research "that aims to promote more widespread application of behavioural safety principles to improve health and safety."

Announcing the HSE contract research report (CRR), Dr Norman Byrom, of HSE's Nuclear Safety Directorate, said: "There is potential to extend behavioural safety principles and strategies, which are often focused on frontline staff in organisations, more widely to encourage and promote behaviours that support the health and safety management system as well as the development of a positive health and safety culture."

Not everyone though views the wider application of behavioural safety with such enthusiasm, something HSE neglects to mention. The report, Strategies to promote safe behaviour as part of a health and safety management system, also gives scant attention to dissenting voices.

Wrong prescription

The health and safety of workers flows directly from work processes. Decisions made about what and how to produce (or serve, in the case of service industries) determine workers' well-being on the job. As Hazards magazine rather prosaically put it in its commentary on behavioural safety: "It's the hazards, stupid."

It shouldn't happen to a dog! image

If you accept this premise, HSE's advocacy of an approach that claims the use of "behavioural safety techniques [to] improve health and safety risk control by promoting behaviours critical to health and safety" (HSE 2002: 2) starts with a misdiagnosis of the problem, and follows it up with the wrong prescription for a solution.

The CRR states at the outset: "There is strong research evidence that behaviour modification techniques are effective in promoting desired health and safety behaviours" (HSE 2002: 1). It adds: "Strong research evidence exists from a range of industries on three continents that behaviour modification can lead to safer behaviour"
(HSE 2002: 15).

The HSE report focuses on ways to get workers to practice safe behaviours: "The frequency of a behaviour can be increased or decreased by altering the consequences following that behaviour. There are three main types of consequences that influence behaviour. There are: positive reinforcement, negative reinforcement, and punishment." (HSE 2002: 5).

But is this true? According to Alfie Kohn, one of the USA's preeminent critics of behaviour modification, the problem with behaviourism is that its "assumptions are misleading and the practices it generates are both intrinsically objectionable and counterproductive." (Kohn 1993:4)

In his book Punished by rewards: The trouble with gold stars, incentive plans, A's, praise and other bribes, Kohn methodically reviews the rhetoric and promises of behaviour modification, including scores of research studies documenting its failures.

He notes: "All rewards, by virtue of being rewards, are not attempts to influence or persuade or solve problems, but simply to control" (Kohn, 1993: 27), concluding that three key planks of behavioural safety - rewards, performance surveillance and evaluation - "do not make deep, lasting changes because they are aimed at affecting only what we do (Kohn, 1993: 79-80).

Kohn reminds us that BF Skinner, cited in the CRR and one of the original and most influential of the behaviourists, could be described "as a man who conducted most of his experiments on rodents and pigeons, and wrote most of his books about people."

What they measure

It is possible to find in the CRR report numerous references to successful behavioural safety schemes. There are two factors that should be borne in mind when considering these claims.

Firstly, many of the key references, including at least two earlier HSE CRRs on behavioural safety, are co-authored by consultants providing behavioural safety services on a commercial basis. While this might not be damning evidence of itself, it is something that is rarely made apparent in the publication credits, something that could lead to bias, and is certainly something that codes of ethics would require declared in medical journals.

The second factor is more concrete. The standard measure of success of a behavioural safety scheme is increased "safe behaviours" observed, and/or a reduction of the reported injury rate. Injury rates can go down when workplace health and safety conditions improve. But they can also decline when workers are pushed and coaxed and cajoled to work very, very carefully (using "safe behaviours") around hazards that shouldn't be there in the first place.

More importantly, injury rates are also reduced when workers do not report their symptoms, injuries and illnesses.

A 1999 policy resolution from AFL-CIO, the 13 million strong US union federation, notes: "These programmes and policies have a chilling effect on workers' reporting of symptoms, injuries and illnesses." It adds that this "can leave workers' health and safety problems untreated and underlying hazards uncorrected" (Hazards, no.79, 2002).

Professors Theo Nichols and Eric Tucker identify similar concerns about behavioural safety management in the UK and Canada, citing examples where injury figures had been suppressed - not reduced - in the UK mining and steel industries.

They express particular concern "about the tendency of OHS systems to ignore trade unions; about the tendency for firms which adopt such systems to focus on worker behaviour as the primary cause of accidents; about a tendency towards the suppression of injury reporting and the shortening of recuperative time, prompted by some of the reward structures that characterise such systems; and about the extent to which these systems have become actively promoted commercial products" (Nichols and Tucker, 1998).

Never mind the hazards

Whereas the CRR credits behavioural schemes with reducing accident rates - or at least reported accident rates - it does not mention any evidence of the schemes eliminating workplace hazards.

This is a startling shift from the usual mission of the occupational safety professional - identifying and taking measures to remedy hazards by elimination, substitution, investment in new safety plant, introducing engineering controls, product modification, hiring of more staff, introducing better, more worker-friendly work organisation or other measures to make the job, the whole workplace, better and safer.

The success of behaviour-based approaches is not evaluated this way. Even when hazards do muscle their way into view, the worker is seen as the confounding factor and any notion of the hierarchy of control becames at best a secondary consideration.

This point is illustrated well by the CRR. Throughout the document, indicators of compliance or otherwise with behavioural safety strictures concentrate of worker failings to the exclusion of an appreciation or consideration of more fundamental measures to make the workplace safer, more ergonomic, better organised or better managed, for example:

•  wearing ear defenders (pages 3, 4 and 7)
•  adopting correct posture while working with VDUs (page 12)
•  wearing eye protection, adhering to speed limit and wearing gloves    when handling steel strip deliveries (page 17)
•  safety-harness-wearing behaviours (page 20)
•  permit to work systems (page 28)
•  wearing personal protective equipment, permits to work, climbing    ladders and lifting materials (page 32), and
•  wearing eye protection (page 42).

The tables have a similar flavour. Table A5 defines the "essential features" and "mechanisms" of a behavioural safety programme, none of which include identifying or remedying hazards. Instead we see "challenge dangerous behaviours" and "targeted observations for infrequently performed activities" and "observers conduct initial observations" and "observers give face-to-face feedback at the time of the observation" and "graphical feedback of results are displayed".

Throughout, there is an assumption that the hazards - irritant chemicals, eye hazards, heavy weights - are there to stay and the workers are there to adapt.

The CRR does note: "Several examples also described efforts being made to identify why an at-risk behaviour occurred, so that any root cause (eg. poor equipment design) could be rectified, thus eliminating the hazard at source" (HSE 2002: 47). But no examples are given of hazard elimination actually occurring.

The CRR does acknowledge: "The literature review did not identify any publications that systematically reviewed the effectiveness of behavioural safety programs in changing management behaviour."

Insult to injury

Throughout the CRR - and in this it reflects the entire behavioural safety philosophy - workers are seen as the problem, and their skills and expertise is never credited as a valuable contribution to securing health and safety improvements.

A diagram which looks at "expert judgment" limits these qualities to supervisors, managers, external experts (HSE 2002: 36).

This isn't just a slight, it is a major management blunder. Worker expertise and involvement has been shown repeatedly to be the single most valuable measure in securing workplace health and safety improvements.

The effect is most marked in well-organised, unionised workplaces with informed and active workplace safety reps. This holds true whether you are in the US, Canada, Australia, the UK or elsewhere (Hazards, no.78, 2002).

New findings of research commissioned by the Northern Ireland and the Ireland health and safety authorities found it was only the presence of safety representatives - not official safety inspectors or company safety professionals - that had any measurable impact on workplace injury rates (Hazards, no.79, 2002).

Writing on the wall

The CRR gives just one example of a behavioural safety method failing [pages 65-68] - but it misses some high profile cases histories where the approach has been spectacularly ineffective. Of course, any management approach can and will have its failures. But behavioural safety stands alone in its willingness to dress up inglorious failure as unqualified success.

For example, one of the most visible manifestations of behavioural safety at work is the "zero lost time accident" boards found inside workplaces - and increasingly outside, as a public boast - counting off the "accident free" days.

One workplace, a chemical plant in Pasadena Texas, had such a bulletin board in 1989. It tracked 5,000,000 hours without a lost time injury. Then the plant exploded, and 23 workers were killed and 232 workers were injured. What did that 5,000,000 really mean? It clearly had nothing to do with hazards in the plant being identified and fixed, as subsequent explosions would seem to attest (OSHA news release, 21 September 2000).

In the UK, the Corus steel company is a keen advocate of the "zero lost time accidents" behavioural safety approach. It is also a company that has been roundly condemned for its safety standards and whose Port Talbot plant exploded killing three workers on 8 November last year. Less than two weeks after the Port Talbot blast it became the recipient of the largest ever health and safety fine imposed on a manufacturing company following an earlier explosion at its Llanwern plant (HSE news release, 21 November 2001).

The CRR also promotes the use of noticeboards to publicise behavioural safety observations - who did what, when and where (HSE 2002: 33). What effect this might have on workplace morale goes unexplored. Nor do these public declarations tell the real story, the production pressures, fatigue, or other factors that might of have led to "bad" behaviour.

Yes, but it works, right?

The CRR says, baldly and upfront: "Behaviour modification programmes have become popular in the safety domain, as there is evidence that a proportion of accidents are caused by unsafe behaviours" (HSE 2002: 1), citing an 80 per cent contribution at one point.

The oft-quoted "evidence" however can be suspect at best. As in the CRR, a typical claim is that 80 to 96 per cent of workplace accidents are the result of workers' unsafe acts and behaviours.

The estimate dates back to the depression. HW Heinrich, an insurance investigator for the US Travelers' Insurance Company, compiled in the 1920s and 1930s thousands of supervisors' accident reports, and concluded that 88 per cent of accidents were cased by unsafe acts, 10 per cent were caused by workplace conditions and two per cent were unavoidable.

Heinrich revisited: Truisms or myths, written by Fred A Manuele and published this year by the US National Safety Council, utterly discredits the research that became the platform on which behavioural safety established its worth.

Manuele says: "Of all the Heinrich concepts, his thoughts pertaining to accident causes, expressed at the 88-10-2 ratio, has had the greatest impact on the practice of safety, and done the most harm."

He adds that some critics of behavioural safety say it is "Heinrich repackaged, and they can present an arguable case," concluding: "I believe those who proclaim that unsafe acts are the principle cause of accidents do the world a disservice."

Who wants it?

There is no example in the HSE report of workers and unions voting on what type of safety programme and consultant (if any) an employer should purchase or engage, and no example of employers putting a choice in front of the workforce: "Do we go with a behavioural safety programme or a comprehensive worksite health and safety programme aimed at finding and fixing hazards and addressing root causes in management systems such as understaffing, extended work hours, work overload, etc.?"

The critical behaviour benchmarks for behavioural safety programmes do not include the behaviours that workers and unions view as critical to health and safety in the workplace, such as "refusing hazardous or unsafe work" (probably the most critical safe worker behaviour of all), "identifying root causes of symptoms, injuries and illnesses," "communicating health and safety problems to union representatives," "reporting symptoms, injuries, illnesses and hazards," and "identifying supervisors and managers who are not addressing health and safety problems."

Reviewing the evidence

There is plenty of UK evidence showing a behavioural safety focus is squinting in the wrong direction. The 1998 Nichols and Tucker paper makes clear that falling accident rates reflected lower reporting rather than lower incidence.

J.B. Cronin's 1971 paper, Cause and effect? Investigation Into aspects of industrial accidents in the UK, found "some sort of direct relationship between good safety record and successful joint consultation." (Sass 1993: 17-18)

Recent evaluations of the "union effect" on accident rates show that Cronin's findings hold true today.

Yet, instead of examining how core work processes are affecting health and safety and working with the workforce to remedy problems, many employers have chosen to bring in behaviour-based safety programmes that focus on workers' unsafe behaviours - workers - as the problem.

Not surprisingly, workers have expressed a rather jaundiced view of this "problem" tag. While employers and consultants call them "behavioural safety programmes," many workers and unions in the US refer to them as employers' "blame-the-worker safety programmes," or simply by their initials: BS (Multinational Monitor, 2000)

Now, more than ever behaviour and blame oriented systems are an inappropriate and ineffective approach at work. The failings of old are compounded by a system that concentrates on the behaviour of the individual when the behaviour of the organisation is increasingly recognised as the route of modern occupational ills including stress, overwork and conflicting pressures (NIOSH 2002).

Alfie Kohn pointed out in his book Punished by rewards that there is a time to admire the persuasive power of an influential idea, and a time to fear its hold over us.

There are real solutions to real problems of workplace hazards and work-related injury, illness and death. Behavioural safety, whatever the CRR and HSE say, is not one of them.

Note: A version of this article appeared in the October 2002 issue of Health and Safety Bulletin.

Nancy Lessin is the Health and Safety Officer of Massachusetts AFL-CIO, USA.

Rory O'Neill is editor of Hazards magazine.


1. Health and Safety Executive: "Strategies to promote safe behaviour as part of a health and safety management system." HSE. Contract Research Report 430/2002.

2. It's the hazards, stupid. Rory O'Neill, Hazards magazine, no.79, July-September 2002, pages 1-5. www.hazards.org/bs

3. Kohn, Alfie. Punished By Rewards. 1993. Boston, New York: Houghton Mifflin.

4. Theo Nichols and Eric Tucker. Occupational health and safety management systems in the United Kingdom and Ontario, Canada: A political economy perspective. Paper for the OHS management systems and workplace change. Amsterdam, 21-24 September 1998.

5. The union effect. Rory O'Neill, Hazards magazine, no.78, April-June 2002, pages 4-5. www.hazards.org/unioneffect

6. Safety is better organised. Owen Tudor, Hazards magazine, no.79, July-September 2002, pages 20-21. www.hazards.org/unioneffect

7. OSHA news release, 21 September 2000. http://www.osha.gov

8. Heinrich revisited: Truisms or myths, Fred A. Manuele, National Safety Council, 2002. ISBN 0-87912-245-5.

9. Sass, Robert. "Prospects For Working Life Reform," New Solutions Vol. 4, No. 1, Fall, 1993 p. 17-28

10. Blame the worker: The rise of behavioral-based safety programs, James Frederick and Nancy Lessin, vol.21, no.11, November 2000. http://multinationalmonitor.org/mm2000/

11. National Institute for Occupational Safety and Health (NIOSH). The changing organization of work and the safety and health of working people: Knowledge gaps and research directions. April 2002. DHHS (NIOSH) Publication No. 2002-116. http://www.cdc.gov/niosh/



Bad behaviour

Briefing on the hazards of behavioural safety schemes by Nancy Lessin and Rory O'Neill, October 2002

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