Accountability ranks right at the top with management commitment as a critical ingredient in a company's safety and health management system. Why do we behave the way we do in the workplace? Consequences. Why do we take the unsafe shortcut? Consequences. Management may impose all kinds of safety policies, programs, written plans, directives, rules, training...on and on...yet if appropriate application of effective consequences within a culture of accountability does not exist, desired behaviors will not be sustained. If employees do not believe they are going to be held accountable for the decisions they make and the actions they take, you can be sure that any safety effort is ultimately doomed to failure.

You hear a lot about responsibility and accountability in safety and health, and sometimes people speak as though the two terms have the same meaning. But, as used in OSHA standards and generally in safety and health management, these two terms have very different meanings. Let's find out why.

Take a look at a dictionary. You'll find responsibility and accountability defined something like: Responsible - expected or obliged to account for or answer to; involving obligation or duties. Responsibility - able to account for or answer to. Accountable - responsible; liable; legally bound or subject to giving an account (or explanation), answerable. Accountability - able to give account or answer to.

• Responsibility may be thought of as simply the "obligation to fulfill a task." To be responsible, you need only be assigned one or more duties.

• Accountability may be thought of as establishing the "obligation to fulfill a task to standard or else." When you are held accountable, your performance is measured against some specific criteria or standard and consequences are applied appropriate to that your performance.

The Six Elements of an Effective Accountability System

Six important elements should be present in an employer safety accountability system:

OSHA has developed rules in occupational safety and health which serve as standards of performance for employers. Similarly, employers are required to establish company policies, procedures, written plans, processes, job descriptions and rules to clearly convey their standards of performance in safety and health to employees.

It is important that safety policies and disciplinary procedures be clearly stated in writing and made available to everyone. In fact, it is necessary to educate all employees on these policies and procedures. Make sure they certify that they have read, understood, and will comply with those safety policies and procedures. Do this when they are hired, and annually thereafter.

Element 2. Adequate Resources and Psychosocial Support

Before employers are justified in administering appropriate consequences, they should first provide their employees with the means and methods to achieve the standards of performance that have been established. Employers should provide a safe and healthful physical and psychosocial workplace environment.

• Physical resources. Ensures safe and healthful conditions. Safe tools, equipment, machinery, materials, workstations, facilities, environment. OSHA emphasizes this category.

• Psychosocial support. Ensures safe behaviors. Effective safety education and training, reasonable work schedules and production quotas, human resource programs, safe work procedures, competent management, tough-caring leadership. Through the years, Federal OSHA and professional safety organizations have demonstrated more emphasis in this area as evidenced by increased interest in developing rules requiring a comprehensive safety and health program, and workplace violence standards.

Once again, when applied to safety behavior and performance, accountability demands more than simply being answerable. In an effective accountability system the quality or level of safety performance is measured regularly and often. Measurement processes include informal/formal observations. Real measurement means more than merely observing behaviors. It also includes quantifying observations...adding up the numbers. Those numbers form the statistics that you can use to improve the safety management system.

On the other hand, employees may have very little control over operations in the workplace. They do, however, have control over their own behavior. Employees have the ability to make a choice to comply with safety rules, and they may choose to report injuries and hazards in the workplace. Consequently, we need to measure these personal behaviors.

Effective consequences increase desired behaviors or decrease undesired behaviors. If employee safety performance meets or exceeds the standards set by the employer, some sort of recognition should follow. On the other hand, if the employee makes an informed choice not to comply with the company's safety rules, some sort of appropriate corrective action should follow. There are various strategies for administering positive and negative consequences. Careful planning is critical to ensure consequences are effective. Let's take a look at four approaches to consider.

• It must always increase desired behavior;
• The worker performs to receive a positive consequence;
• The worker may perform far beyond minimum standards - discretionary effort;
• The focus is on excellence - it's success-based strategy;
• Examples include:
• If you report a hazard you'll be recognized in a positive way;
• If you prevent an injury or save money you will be rewarded.

• The worker performs to avoid the consequence - nothing else;
• The intent is to increase desired behaviors;
• The worker performs to minimum standard - just enough to get by;
• The focus is on compliance - it's a fear-based strategy;
• Examples include:
• “If you break a safety rule, you'll be fired;”
• “If you comply with safety rules, you won't be reprimanded.”

• It is the withdrawal of recognition;
• The worker is ignored and no matter what, desired behavior becomes less frequent. For instance:
• If the worker misbehaves and is ignored, he may perceive it as positive and the behavior will continue;
• If the worker behaves and is ignored, he may perceive it as negative and the behavior will discontinue;
• Worker eventually performs without expectation of recognition;
• No relationship with management exists;
• It is the most common form of consequence in the workplace - It's epidemic in organizations
• Examples of the thoughts and beliefs produced when people are ignored include:
• “It doesn't matter how hard I work around here.”
• “Apathy is rampant, but who cares.”

Consequences for safety behaviors that meet or exceed expectations usually include recognition and rewards. However, only appropriate behaviors should be rewarded. The employer should recognize employees for behaviors and performance over which they have exclusive control. If the person has authority...decision-making control, then the person should be held accountable for the decision and subsequent behaviors and personal outcomes. Managers and supervisors have varying degrees of control over the conditions of their work areas and the behaviors of their employees. For employees, control usually refers only to personal behaviors. Let's look at some examples of activities and behaviors that are typically accountability measures.

Top/mid-level managers. Unfortunately, measurement at this level usually includes results statistics over which top managers actually have little direct control. These measures include:

• Accident rates.
• Experience modification rate (MOD Rate).
• Workers' compensation costs.

This situation may cause top managers to put pressure on supervisors to hold down the number of accidents in their departments. Consequently, the result may be ineffective measurement at all levels. Appropriate behaviors and activities to measure at top/mid- level management include:

• Involvement in safety management system formulation and implementation;
• Developing effective safety policies, programs, procedures;
• Arranging management/supervisor safety training;
• Providing physical resources and psychosocial support;
  
• Involvement in safety education/training;
• Supporting involvement in the safety committee.

Supervisors. Supervisors may not be able to completely control the results (such as the accident rate) of their work area. They do, however, have the ability to control their safety management and leadership activities. Therefore, measurement at this level should primarily include personal safety behaviors and activities such as:

• Making sure workers have safe materials, tools, equipment, machinery, etc.
• Ensuring a healthful psychosocial environment
• Following company safety rules
• Conducting safety inspections
• Enforcing safety rules
• Training safe work procedures
• Recognizing employees for safety
• Conducting safety meetings

Employees. Measurement of employees usually includes personal behaviors such as:

• Complying with company safety rules
• Reporting injuries immediately
• Reporting hazards
• Making suggestions
• Involvement in safety activities

Most employers establish safety incentive programs to increase awareness and influence behaviors in a positive direction. However, some of those employers unintentionally reward their employees for not reporting injuries. Their intention is to do the right thing, but the problem is that they're not doing the thing right.

• "...furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees, and comply with occupational safety and health standards promulgated under the Act."

• In the Act we read that "Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct."

Consequences for below standard safety behavior typically includes negative performance appraisals, some form of progressive discipline, or forfeiture or some reward like a bonus.

Remember, for an accountability system to work most effectively, managers, supervisors and employees should be measured only for those behaviors over which they have control.

Without the expectation of consequences, accountability has no credibility and will not be effective. No consequences...no accountability. Consequences need to be appropriate as well as effective. This is the element with which everyone is probably most familiar. Unfortunately, in some companies, consequences are either not appropriate, not effective, or both.

• They are justified.
• They correspond to the degree of positive or negative results of the behavior.
• They are applied consistently throughout the entire organization.

Determining the appropriateness of administering negative consequences does not have to be difficult. You can use the acronym to the left to help remember the five basic safety obligations managers and supervisors have responsibility to fulfill. Let's take a look at each of the five:

1. Training. Ask, "Have I provided (or has the employee received) quality safety training?" Employees must be provided with the required knowledge and gain the skills to comply with safety requirements. Employees, then, have the necessary knowledge and skills to understands the natural and system consequences of noncompliance.
2. Resources. Ask, "I provided the employee with a safe and health workplace?" Do employees have the physical resources and psychosocial support to comply with safety requirements? Supervisors need to provide adequate tools, equipment, materials that make it possible for employees work safely. Supervisors should also manage workloads, schedules, employee relations so that the workplace is as stress-free as possible. When the employee believes working fast is more important than working safe, supervisors are failing in this area.
3. Enforcement. Ask, "Have I applied safety accountability fairly and consistently in the past?"Do employees believe they will be disciplined if they're caught violating safety rules? Or, do they know that all you will do is shake your finger and threaten them ("if I catch you doing that again") without following through. If supervisors allow employees to violate safety rules, all justification for discipline disappears.
4. Supervision. Ask, "Did I catch them violating safety rules before they got hurt?" By definition, adequate supervision means "detecting and correcting hazards or unsafe behavior before they cause an injury or illness." If supervisors are stuck in the office all day it's not possible to oversee the work employees are doing. Lack of supervision is a major reason disciplining employees after an accident is usually inappropriate.
5. Leadership. Ask, "Am I setting the right example for my employees?" Supervisors must "walk the talk." That means they need to set the highest examples by following all safety policies and rules, and they need to be fulfilling the other four obligations.

If a manager or supervisor can honestly answer yes to each of the above four questions, it is probably appropriate to administer negative consequences because he or she has fulfilled their own accountabilities first. If a manager cannot honestly answer each question in the affirmative, leadership requires an apology and a commitment to make improvements.

• Consequences should increase with the severity of the potential injury or illness that might result from the behavior. If an employee is performing an unsafe work practice that could result in a fatal injury to himself or another employee, that certainly warrants a severe consequence. On the other hand, an employee who performs a behavior that violates a safety rule, yet will not result in an injury or illness, a less severe consequence is more appropriate.

• Consequences should increase with the level of responsibility of the person performing the behavior. If an employee neglects to perform a safe work practice such as wearing ear protection, a safety rule has been violated and discipline may be in order. However, if a supervisor or manager neglects to wear the ear protection, we're not just talking about violating a safety rule. That safety rule has, in effect, been legally revised. A mandatory requirement becomes a discretionary guideline and not auditable or enforceable. A more severe level of discipline would be in order because of the position of responsibility they assume. The supervisor or manager, in fact, gives permission for all employees to violate the same safety rule. The negative impact on the safety of employees has the potential to be much greater when the supervisor or manager violates a safety rule.
  On the other hand, if a supervisor or manager does something positive, the net impact will likely be greater than that of one of his or her employees. Consequently, more significant positive consequences are certainly in order.

• Identification. Inspect the accountability system policies, plans, procedures, processes to identify what exists.
• Analysis. Dissect and thoroughly study each accountability system policy, plan, procedure, process to understand what they look like. The devil is in the detail.
• Evaluation. Compare and contrast each accountability system policy, plan, procedure, process against benchmarks and best practices to judge their effectiveness.

OSHA looks primarily for two program elements when evaluating an employer for accountability: Policy and consequences. OSHA does not mandate specific recognition/disciplinary procedures: That's the responsibility of the employer. But, an effective procedure that is written and clearly communicated should be in place. Does your company have a written policy that addresses accountability? If it does, are the three key components addressed?

Employers are held accountable by law for ensuring a safe and healthful workplace, and employees are held accountable by their employers for individual safety behavior. It's important to note that if employees are "empowered" (authorized) to perform certain responsibilities and have control over those responsibilities, they should also be held accountable. For instance, if they are empowered to fix minor hazards in their work area, they should realize that if they don't follow through they should expect some sort of consequences as a result.

Put yourself into the role of a supervisor. It may not be appropriate to administer disciplinary procedures even if it first appears that an employee is not complying with safety rules. Before disciplining an employee, it is appropriate to first ask some very important questions to determine if you, as a supervisor, have fulfilled your own safety responsibilities adequately.

To think of it another way, you may be pointing the finger of discipline at an employee, but remember, the other fingers are all pointing back at you, as if to ask some very pointed questions about how well you are fulfilling your supervisor accountabilities.

Jump for more information on providing a safe and healthful work area.

The second supervisor accountability: Safety Training. Providing safety training is another extremely important supervisor accountability. Training teaches the skills to apply the knowledge the employee has learned. Demonstration is key to effective safety training.

Jump for more information on providing safety training.

The third supervisor accountability: Safety Oversight. OSHA attaches a rather narrow definition to the term "supervision," considering it to be primarily a control and monitoring function. OSHA expects someone with authority to oversee work being accomplished to make sure unsafe work conditions do not exist, and that employees use safe work practices. Adequate supervision means detecting and correcting hazards before they cause an injury or illness.

Jump here for more information on safety supervision. 

The fourth supervisor accountability: Enforcing safety rules. Accountability is generally thought to mean "enforcement of safety rules" using progressive discipline. However, it's important to understand that consequences may take many forms, and that they are not always negative. If progressive discipline is used, it's important that supervisors understand how to administer it fairly and consistently.

Jump here for more information on enforcing safety rules.

Last Words

Well, that was a lot of information. You learned that the components of responsibility and accountability are different. Accountability has three basic components: established standards, methods of measurement, and consequences. You also learned that supervisors have accountabilities associated with controlling the workplace, and employees have accountabilities related to personal behavior. Now it's time to take the module quiz.