Don’t Confuse Compliance with Safety

Don’t Confuse Compliance with Safety

The view of safety as little more than employee obedience to the rules may be old school but it remains foundational in the safety practice. Shortly after the Three Mile Island nuclear incident, E.L. Zebroski, a nuclear safety analyst, performed a detailed analysis of four highly publicized tragedies: The Piper Alpha oil rig fire; Challenger space shuttle explosion; Bhopal toxic gas leak; and Chernobyl nuclear explosion. According to Zebroski’s analysis, believing that rule compliance was enough to ensure safety was a “principal cause” of man-made disasters such as Three Mile Island and Chernobyl. More recent events such as the Deepwater Horizon have reinforced Zebroski’s findings.  Compliance remains a principal goal for many company safety efforts, however, and it is instructive to review how such goals became so prevalent.

OSHA was enacted in 1970. Its abundant requirements were essentially adoptions of existing standards (e.g., ANSI) and, as a result, dealt largely with conditions. Everything from scaffold toe board dimensions to the design of toilet seats became the law of the land. Not wanting to run afoul of the law, companies scrambled to comply.  New safety positions, such as compliance manager and compliance engineer, proliferated.  Newly armed with an encyclopedic knowledge of safety requirements, many safety practitioners set out to enforce every detail in the Code of Federal Regulations and the company safety manual, regardless of their importance to safety.

Eventually, many companies became disillusioned with low-return OSHA compliance efforts, which were often accurately perceived as nitpicking. By the mid-80s, however, many companies turned their attention back to compliance when the rise of behaviorism shifted safety emphasis from compliant conditions to compliant workers.  Controlling “unsafe acts” became the safety focus for many companies and remain so today.  Vendor supplied behaviorist programs became ubiquitous and were mostly focused on changing worker behavior from unsafe (noncompliant) to safe (compliant) via positive and negative reinforcement (i.e., operant conditioning). Safety goals merely shifted from compliant conditions to compliant workers.

But compliance is a low bar; it does not provide significant protection from the complex interactions and the infinite number of factors that can contribute to catastrophic incidents.  Any company should want and expect more from its workforce than mindless rule adherence. Taking full advantage of worker involvement, however, requires companies to shift from the common view of workers as liabilities to be controlled to a recognition of workers as assets to engage in the continuous improvement of their work.

No company should expect, or want, its workers to check their brains at the gate. Neither should any firm want its employees to feel like puppets, powerless to control any aspect of their assigned work. Undoubtedly, following the rules is important. But the author has come to view compliance as a by-product (not a driver) of organizations that make safety a value. Better to develop employees with a questioning attitude and multiple opportunities to actively engage in making the work they do safer and more productive.  All work exists in what are always imperfect and dynamic systems.  Companies that fail to enlist those most knowledgeable and impacted to improve those systems are squandering their resources   Safety is a value, not a compliance goal, and organizations that treat it as such get returns that go far beyond safety.

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Mr. Loud’s over 40 years of safety experience includes 15 years with the Tennessee Valley Authority (TVA) where he served as the supervisor of Safety and Loss Control for a large commercial nuclear facility and later as manager of the corporate nuclear safety oversight body for all three of TVA’s nuclear sites. At Los Alamos National Laboratory he headed the independent assessment organization responsible for safety, health, environmental protection, and security oversight of all Laboratory operations.

Mr. Loud is a regular presenter at national and international safety conferences. He is the author of numerous papers and articles. Mr. Loud is a Certified Safety Professional (CSP), and a retired Certified Hazardous Materials Manager (CHMM). He holds a BBA from the University of Memphis, an MS in Environmental Science from the University of Oklahoma and an MPH in Occupational Health and Safety from the University of Tennessee.

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