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This material is for training purposes only. Its purpose is to inform employers and employees of best practices in occupational safety and health and general OSHA compliance requirements. This material is not a substitute for any provision of the Occupational Safety and Health Act or any standards issued by OSHA.

MODULE SIX: ENSURING ACCOUNTABILITY

Introduction

The supervisor, as an "agent of the employer," is charged with carrying out a very important responsibility; that of holding employees accountable for their actions. And, of course, the supervisor himself or herself is held accountable for carrying out this very important leadership responsibility.

Before a safety accountability system can be effectively implemented and applied, it must be understood. It's important to understand what accountability is, and how it functions to ensure safety system effectiveness. To better understand accountability, let's answer some very important questions:

  • What is accountability?
  • What are the behaviors for which an employee should be held accountable?
  • How does a supervisor measure those employee behaviors?
  • What are the obligations management must fulfill before holding employees accountable?
  • What are appropriate and effective consequences?

With the above questions in mind, let's take a look at accountability in the workplace, and how we can implement and apply it.

What is "accountability"?

If we reference Webster's, "accountable" is defined as being... responsible; liable, explainable, legally bound, subject to. As we can see, accountability has to do with being liable, bound, or obligated to do something. In the workplace employees are obligated to comply with policies, rules, and standards. Accountability also implies that our performance is measured and that we'll be subject to some sort of consequences depending our ability to meet the obligations that have been assigned to us.

What is an accountability system?

Now that we're a little more familiar with the concept of accountability, let's examine what an effective accountability system looks like. There are five critical elements to an effective accountability system. Each of these elements must be present, or the system will be doomed to failure.

Element 1: Established standards of performance

Established standards inform everyone about expected levels of performance and behavior. Standards of performance should be in writing and clearly stated so that everyone understands them.

Standards of performance include the mission and vision statements, policies, written plans, job descriptions, procedures, and safety rules.

Element 2. Resources to achieve those standards

If the employer is going to hold employees accountable to perform to standards, he or she has the obligation to ensure that those employees are provided the resources to achieve those standards. This obligation is detailed in OSHA's "General Duty" clause.

OSHA Act 1970. Section 5. Duties

(a) Each employer -- 29 USC 654.

(1) shall 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;

(2) shall comply with occupational safety and health standards promulgated under this Act.

The employer may not be justified in administering progressive discipline unless all resources to help employees achieve established standards are provided. If, in fact all resources are provided, the employer will probably have many opportunities to recognize and reward employees for meeting and exceeding those standards. What resources are necessary? That depends on the task, but generally employees should be provided:
  • Place of employment: Safe tools, equipment, machinery, and materials so that they can safely produce or provide the highest quality product or service.
  • Place of employment: A healthful physical environment that ensures minimum exposure to extremes in noise, toxic chemicals, hazardous atmospheres, and temperatures.
  • Employment: Work procedures and practices that are free from hazards that will cause serious injury or illness.
  • Employment: A healthful psychosocial environment that minimizes distress by making sure employees have adequate control over the various aspects of their worklife. This includes healthful relationships with co-workers and management. More information on Job Stress.

Element 3. A system of measurement

Once performance standards are established, processes should be developed to measure employee and manager behaviors against those standards. You are probably familiar with the process OSHA uses to measure your employer's safety performance. They conduct workplace inspections and issue citations.

Measurement implies more than merely observing behaviors. It's actually keeping track: quantifying behaviors. You put numbers to something. In the workplace, it's important that supervisors measure their employees' safety behaviors. And, managers should be measuring measure supervisors' activities. OSHA measures employer performance through an inspection process. They measure, they do not merely observe. And, as you know, OSHA issues citations that may include monetary penalties.

In an effective accountability system, the employer also conducts inspections to measure how well employees at all levels are meeting the established standards in element one. Take a look at more information on the measurement process.

By the way, to find out when/if your employer was last inspected/investigated by OSHA and the results, click here.

Element 4. Appropriate application of effective consequences

Without the expectation of consequences, accountability has no credibility and will not be effective. No consequences...no accountability. Effective consequences should meet certain criteria to be 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.

What are the criteria for appropriate consequences?

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

Are consequences justified?

A basic rule of thumb for any accountability system states that, "a person should held accountable for a responsibility only if that person has control of the resources or the ability to fulfill that responsibility." If a person is being measured and held accountable for result over which they have no control, the person will attempt to gain control of that result somehow. That attempt may take the form of inappropriate behaviors. For example, a supervisor who's measured only on department accident rates may threaten to fire anyone who completes a an OSHA 101 injury report. Not only is that behavior counterproductive for the company, it's illegal.

Your work schedule, the quality of materials provided, work assignments, production quotas, and the co-workers you work with, describe common aspects of your job that you may have little control over. Consequently, you should not be held accountable for these. On the other hand, how well you adhere to procedures, policies, rules, and carry out safety responsibilities is a personal behavior over which you do have some or complete control. You can choose to meet expectations or choose to "do it your way." The decision is yours to make. Therefore, accountability is appropriate.

Do consequences correspond with the positive or negative results of the behavior?

  • 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 his or her head protection discipline may be in order. However, if a supervisor or manager neglects to wear the head protection, a more severe level of discipline would be in order because of the position of responsibility they assume. The supervisor or manager, in fact, give permission for all employees to do the same. The negative impact on the safety of employees has the potential to be much greater when the supervisor or manager violate 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.

Are consequences applied consistently at all levels of the organization

To build a high level of trust between management and labor, accountability must be applied consistently at all levels of the organization. It's important to remember that one should be held accountable only for that which he or she has control. With this in mind...

A very important question...

It's critical to understand that , before administering progressive discipline, supervisors should evaluate (make a judgment about) how well they have fulfilled their own accountabilities. This is important to make sure they are actually justified in administering corrective actions.

Determining the appropriateness of administering negative consequences does not have to be difficult. It can be a simple straightforward process: All that's required is that you honestly answer the following four questions in the affirmative:

  1. Have I provided the employee with a safe and health workplace? Do they have the physical resources and psychosocial support to comply?
  2. Have I provided adequate safety supervision? I'm not stuck in my office all day...I'm overseeing their work regularly so that I'm able to "catch" unsafe behaviors and hazardous conditions before they cause an injury.
  3. Have I provided (or has the employee received) quality safety training? The employee has the required knowledge and skills to comply. The employee understands the natural and system consequences of noncompliance.
  4. Have I applied safety accountability fairly and consistently in the past? Does the employee know he or she will be disciplined if caught? Or, do they know that all you will do is threaten them..."if I catch you doing that again."

If you, as a supervisor, can honestly answer "yes" to each of the above four questions, it is probably appropriate to administer negative consequences because you have fulfilled your own accountabilities. If a supervisor cannot honestly answer each question in the affirmative, it's probably more appropriate to apologize and determine what safety system weaknesses exist so that they can be improved.

Two sides to the accountability coin

Some companies think accountability is only about administering progressive discipline. They emphasize only negative consequences that result from a failure to meet standards of performance. In reality, an effective accountability system awards consequences for all behaviors: consequences appropriate to the level of performance. So, what form should those consequences take?

Let's take a look at the consequences that might result from two categories of employee/management safety behavior:

  • Meeting or exceeding standards, and
  • Failing to meet standards.

Meeting or exceeding standards. To restate: In an effective accountability system, positive recognition is given regularly (and hopefully often) for meeting or exceeding employer expectations.

If your company does not have a formal safety recognition program, take a look at some examples.

Failing to meet standards. In some companies, this is unfortunately the only category resulting in consequences. In an effective safety culture, corrective actions are rare and perceived as positive in the long term. Usually (not always), corrective actions involve some sort of progressive discipline

Element 5. A process to evaluate the accountability system.

Although as a supervisor you may not be responsible for formally evaluating the accountability system it's good to know that someone is. Usually, the safety coordinator and/or safety committee are involved this activity. In some "state-plan" states, like Oregon, the safety committee is required by law to conduct an evaluation of the employer's accountability system.

The process usually involves three levels of activity:
  • Assessment. 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.

If you believe there are weaknesses in your employer's accountability system, make sure to take notes on the behaviors and conditions you see in the workplace that may be pointing to accountability system policies, plans, processes, and procedures that are inadequate or mission.

Last words...

Accountability is an extremely important element in the safety and health management system. Having a firm understanding of the concept and program will help ensure success.

Well, it's time to take the module quiz. If you have difficulty answering the questions, just scroll back up the page and study the section related to the question.

Take the Review Quiz
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