Managing Safety Rule ViolationsWritten by Tyrone Tonkinson, Ph.D., P.E.
I know that sounds like a consultant's answer, so let's discuss what I mean. We can start by considering human nature. We all choose our behaviors based on expected consequences. What are the consequences of taking shortcuts on the job? While there are possible negative consequences, like rework or an injury, these problems are few and far between. One definite result is that the job takes less time. Getting done faster is usually considered a good thing. But what if the shortcut involves violating a safety rule? If there are no consequences for violating safety rules, can they be ignored? Will this affect your safety record?
For the most part, people do not deliberately violate policies and safety rules. Our workers, however, are responding to many influences on their actions, including company goals, a sense of urgency to restore customer service, personal issues at home, and so on. When shortcuts get results and they are not corrected, the decision becomes a bad habit. And while bad habits will not lead to an injury every time, they will eventually catch up to the worker.
While delivering root cause training to a client, I was told the tragic story of one of their coworkers. Let's call him "Joe." Joe had the bad habit of not wearing his safety harness while working in the basket of his boom truck. Early in his career, Joe's truck was struck by a public vehicle, he was ejected, and he suffered serious injuries. He made a full recovery, but continued to not wear his harness. He was reprimanded several times over the years and was observed by his coworkers many times, but he continued his bad habit.
You know the rest of the story. Joe was doing more work, got ejected again, and this time he died from his injuries. When I investigate serious injuries, the "bad habit" is frequently one of the contributors. This individual had a pattern of not wearing his required PPE, which caused the injuries to be much worse.
How do we influence the decisions made by our workers? We must understand that we are dealing with adults and adult decision-making. Adults choose behaviors based on expected consequences. The theories tell us that providing rewards for desired behavior is the best approach. Try catching people doing right. Reward them for being fully prepared, taking the time to do complete pre-job briefings or tailboards, and making conservative decisions when unsure about conditions. There are good reasons for rewarding safety milestones.
The theories, as well as direct experience, also tell us that undesirable behavior that can harm people must be corrected. Can we tolerate a worker who regularly violates safety rules? This person is a danger to himself and others around him (or her). There must be some form of negative consequences (punishment) in place to deter conscious violation of safety rules. This brings us to the "it depends" part of my answer.
It is important for us to understand the circumstances surrounding safety rule violations before deciding if punishment is appropriate. In addition to shortcuts, there are other possibilities. Do our workers understand the rule? We trained them, but if multiple workers don't understand how to implement the rule, we set them up for failure. Can the rule actually be implemented in the work environment? It may have sounded good on paper, but during a storm response, in the dark and rain, will it work? Are we giving workers the tools they need to succeed?
A common approach used by utilities is to perform some fact finding first in order to understand if the actions were deliberate or were influenced by other factors. Did the person consciously choose to violate the rule? Before passing judgment, you have some questions to ask. Has this person taken this action before? Did his or her supervisor condone it?
During a recent investigation, we ran into this case. The individual readily admitted to violating one of the company's safety rules. Case closed, right? Not yet. Why did he ignore the rule? "I asked about this rule before, and my supervisor told me it's optional." Who is implicated now? Should there be some consequences for the supervisor who is telling his or her employees that safety rules are optional? Absolutely! Can we tolerate this type of behavior by our supervisors?
Many companies have policies in place that provide a graded approach to discipline, based on the severity of the infraction and the employee's work history. The more severe the infraction or frequency of violations by the employee, the more serious the punishment; ranging from documented verbal warnings, to letters in the personal file, to time off. There is usually the stated option of termination.
Here are a few important points to consider when judging your current policies on this topic.
• The use of punishment will influence the willingness of employees to self-identify low-level safety issues. It must be used sparingly or else your workers will stop revealing the low-level issues and near misses.
• The use of punishment must be well thought out and match the severity of the infraction.
• Your company should document its safety policy and clearly identify the consequences associated with non-conformance.
• Some form of formal investigation should occur prior to deciding on appropriate forms of punishment. Who is really culpable for the act—the individual, his/her supervisor, or the larger organization? Be careful not to confuse root cause analysis with fact-finding for discipline.
Due to the influence on the culture and the willingness of people to identify low-level safety issues, I encourage companies to reserve punishment for those cases where individuals have deliberately and willfully violated the rules and put themselves and others at risk. Your workers will accept a policy that is fair and consistently applied. They will understand and even appreciate that some type of consequences are necessary for people who willingly violate safety rules. This option is necessary to deter willful acts.
This is a tricky topic to work through with your staff, but also quite necessary. In the end, we are all striving to work more safely. Is punishment a necessary part of my safety program? Yes. Do we punish everybody who violates a safety rule? You need to work through the many variables to sort out the "it depends" answer.
Good luck and work safely! ip
Dr. Tyrone Tonkinson, President – Simple Approach, Inc., has more than 20 years of electric utility experience and
is a recognized expert in root cause analysis, human
performance, and organizational assessment. For more information, visit www.simpleapproachinc.com.
Editor's Note: This article was based on a presentation by Dr. Tonkinson called "Violation or Organizational Induced Error" during the Hands-On Safety Conference in November 2007 and will be given at the Hands-On Safety Conference in May 2008.