Many well-intended companies are drowning in a sea of rules, cardinal rules, complicated procedures, and high dollar “quick fixes.” The result is often a prohibitively expensive and overly complex workplace, where getting anything done “by the book” (including safety management) is far too difficult. This condition is known as “rule creep,” and it is costing companies millions of dollars every year with little to no return on those investments. In addition, attempts by safety professionals to achieve “zero harm” levels at their organizations generally serve to deplete the cost efficiency and effectiveness of their safety programs. As Cary Usrey pointed out in a recent interview, focusing on “high frequency, low-severity issues” may have been an effective tactic of many companies’ safety management programs for a time, but the continual effort to do so is now becoming a concentration on the trivial at the expense of the serious. This article will address the top three fallacies responsible for this dangerous trend in safety management and suggest a solution.
- More complex = more covered.
Many safety management programs are comprised of a variety of unintegrated safety tactics that can add little value but considerable expense and complexity to a workplace. This is typically due to these safety tactics focusing on symptoms (e.g., unsafe acts and unsafe conditions) while doing little to address systemic issues. It is also common to find procedures that cover every imaginable hazard, no matter how minor or remote. These procedures are particularly problematic when they are not reviewed for usefulness by the workers they have been assigned to, as generically assigned safety processes may not apply to the work being done and therefore cause the whole safety system to be ignored. Then, when an incident occurs, organizations merely express shock that the elaborate but unworkable procedures were not followed.
Overly long and complicated procedures are routinely not followed. These requirements seem good on paper, as they contain nearly every precaution and control imaginable. However, if workers are unable or unwilling to follow these elaborate processes, what good is actually accomplished? I have observed many companies bury and burn out their workers with these “feel good” procedures. Rather than bolstering safe work performance, infelicitous and over-done procedures make work performance slower, more difficult, more expensive, and more prone to error.
2. Lower incident numbers = safer.
Many companies have made a low or zero TRIR their holy grail. There are numerous problems with this approach to safety management, with under-reporting and fudged numbers being the issues most cited. However, often overlooked is the fact that this strategy generally ends with the company spending 80% of the budget on 20% of the risk. These low number goals will drive organizations to spend most of their time, finances, and other resources in a quest to root out relatively low risk/low consequence events. Singular focus on the most frequently occurring and easily observable risks to lessen incident numbers denies a holistic approach to safety that includes attention to more serious, but less obvious risks. Multiple studies have shown scant or no correlation between low TRIRs and a reduction in serious injuries and fatalities. Safety resources are finite and should therefore be spent where they will do the most good. Perfection (e.g., zero harm) is a costly illusion.
3. Quick fixes.
Quick fixes abound in the safety management arena, as the consequences of being late in the “safety game” are increasingly high and those who market them can be highly persuasive. The temptation to “do something fast” when issues with compliance and safety arise is understandable but generally misguided. The problem with “quick fixes” is that they are rarely quick (or sustainable.) Attempts to solve complex, systemic, and cultural safety issues with paint-by-the-numbers “solutions” are little more than a displacement of valuable time and resources. Equally troublesome is the post-incident response of imposing more training, rules, and/or more cumbersome and lengthy procedures as a means of showing that something is being done. A “check-the-box” response such as this may result in an increased perception of safety accomplishments, but also adds expense and complexity to the work that can lead to unintended consequences (a deflection of addressing more fundamental organizational issues that could be the true root cause.)
More safety protocols do not necessarily add up to better safety management. When workers are inundated with more and more rules, bigger and more complicated procedures, start cards, stop cards, take-fives, etc., increased safety is not usually the result. While some traditional safety tactics may add value, many do not, and can instead serve to make work more difficult, complex, expensive, and hazardous. There is also the risk of alienating the workforce by creating what some workers have described to me as “EHS disease.”
Taking a hard look at what is promoted in the name of safety management may mean a simplification, discarding the things that strain safety resources but do not add value. Reviewing safety processes can begin with a multi-discipline team that includes impacted workers. This is an excellent practice for “good housekeeping,” and I have found that many workers are quite happy to engage in such an effort. Safety excellence is never a simple task, it cannot be achieved by an over-complicated, hyper-focused, quick fix, but it can be made a clearer target to shoot for if safety efforts are transformed to be user-friendly and practical. Safety perfection may not be attainable, but safety improvement always is.
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.