3 E’s: Engineering, Education and Enforcement
- Engineering: At the most basic level, employers are obligated to assess ALL hazards associated with a specific scope of work BEFORE work begins. If those hazards cannot be eliminated, the employer must develop safe work practices and procedures to control those hazards and ensure the worker is protected from harm, preferably using the hierarchy of hazard control.
- Education: Employers are also obligated to educate workers in the content and intent of safe work practices and procedures designed to control those hazards and protect the worker from harm.
- Enforcement: Lastly, employers are obligated to ensure adherence to all safe work practices and procedures developed and utilized.
These basic entry level processes, including safe work practices and procedures, are reflected in a company’s safety manual and are lovingly referred to as the “safety rules”. Some companies have deemed certain subsets of rules as sacred and given them the label of “Cardinal Rules,” ”Rules to Live by,” or simply referred to as “zero tolerance”. These rules are very clearly written requiring absolute adherence with violators being terminated, or at the very least automatically disciplined. But what happens when these safety absolutes are not absolute, or even worse sometimes absolute?
Why use Safety Absolutes?
Companies use Safety Absolutes for several reasons. They may work in a highly hazardous environment and specifically point out which risky behaviors can get you killed. Some companies have a difficult time getting their employees to comply with certain rules, so they enlist Safety Absolutes as a “line-in-the-sand”. Some organizations use Safety Absolutes as new safety programs to raise awareness by calling them “Rules to live by”.
Although safety absolutes are often created for good reason, they pose a problem for a number of reasons. Most importantly, if companies single out a group of rules that are elevated to Safety Absolutes, then this diminishes the importance of the rest of the safety rules. Secondly, if companies take a “black or white” approach to rule violation, this will severely limit their ability to become a leaning organization because employees will hide the truth.
Failure to Comply
Here are several classic examples that played out recently at a company that has a Zero Tolerance policy related to Fall Protection issues:
Case Study #1
A worker is observed is not tied off at a roof edge and is told to move to a safe position. In accordance with the company’s zero tolerance policy, the worker was terminated. The worker argues but is informed by the Safety Manager that the company policy has no capacity for variance. Frustrated, the worker goes to the Project Manager to argue his case.
Following the meeting with the worker, the Project Manager calls in the Safety Manager and informs him that the worker (a Foreman for a heavily staffed contractor on the site) is indispensable. Terminating the Foreman would severely delay the project schedule. The decision was then made to admonish the worker, re-train him (hastily), and get him back to work.
Case Study #2
A young site Safety Manager observed a mechanical contractor crew working at height without safety harnesses. He documented the unsafe behavior on a self-inspection form that read like this:
Two men were observed not wearing harnesses. I asked them how stupid they were for not wearing their PPE. PUT IT ON NOW OR GO HOME!
This was the ninth time the same crew had been observed (and documented) having failed to comply with the company’s fall protection policy. The Safety Manager brought the risky behavior to the attention of the 30-year veteran Foreman of the mechanical contractor who then told him in an unkindly fashion to mind his own business.
What do you think happened next? If you said the “zero tolerance” policy was enforced (finally), you would be wrong. If you said the foreman was fired, you would again be wrong. Unfortunately, nothing was done beyond the warning. What happened next? A tragic event took place when a worker from that mechanical contractor crew fell from an elevated work platform.
Case Study #3
Two workers violate a zero tolerance policy. One is the son of a senior executive. The other is not. One is made an example of with immediate termination followed with a “lessons learned” communication that is distributed companywide to demonstrate accountability for safety violations related to zero tolerance policies. The other worker is privately scolded and allowed to go back to work.
Can you guess which worker was fired?
If rules are not equally applied, then can we call them rules?
Perception of Safety
So what is actually happening in the “big picture” when workers DO NOT follow these rules and employers DO NOT enforce their own clearly defined safety rules?
At the most basic level, this hypocrisy places both line managers and workers in a state of total confusion, as no one clearly understands which safety message the employer is sending. The message instead is that not all rules must be followed (but you won’t know which ones ahead of time).
Additionally, having a punitive effect can actually promote the opposite behavior in that nobody would willingly come forward to report any violations or close calls for fear of retribution.
So what is the end result? The person who does not have the total support of senior management and is caught in the middle of this totally dysfunctional mismanagement of safety is rendered absolutely useless in his/ her ability to enact any form of positive change.
So what should you do?
If the intent is to conduct a management review on a case-by-case basis for each “absolute incident” and allow for variation in how the incident is handled, then do not select certain rules to be Safety Absolutes. Either follow the zero tolerance policy every time without variation or consideration of the circumstances, or remove the rule. Or, simply change the rule to reflect reality and put a process in place that is effective, enforceable and will be followed as it was designed. This will ensure it is both clear and fair to everyone.
* Hypocrisy meter graphic courtesy of Robert Griffith – http://askgriff.deviantart.com/
Frank K. MacDonald is a Project Management Specialist, a Power Engineer and a Canadian Registered Safety Professional (CRSP) from Edmonton Alberta Canada with 32 years of professional Project Management and Project Safety Management experience.
Cary Usrey is a Process Improvement Leader at Predictive Solutions, implementing training solutions and best practices for customers seeking to prevent worker injuries and reduce potential injuries. He coaches customers through an assessment, goal-setting, and goal measurement process that is designed to maximize safety improvement and widespread organizational engagement, from the field to leadership.