Standards, Resources, and Measurement

Accountability and responsibility are not the same.
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What is "Accountability?"

You hear the terms "responsibility" and "accountability" a lot when dealing with safety and health, and sometimes people use the terms as though they have the same meaning. The question to ask is, "are you responsible and accountable for your safety performance?" So, let's take a look at both concepts to help answer that question.

Are you responsible?

Being "responsible" implies that you have been assigned a position or have a duty to perform. One important employee responsibility is to work safely. Think of "responsibility" is an assignment.

Are you accountable?

Being "accountable" exists when you are subject to consequences based on your safety performance. Accountability is a condition that exists when outcomes your employer administers depend on your safety performance.

In other words, when you are held accountable, your safety performance is measured against company performance standards and expectations, and based on your safety performance, consequences are administered. As you'll see, those consequences may be perceived by the employee as positive or negative.

OSHA and Accountability - Two Outcomes

An employer is held accountable by OSHA for complying with specific regulatory performance requirements. Since accountability requires a consequence, one of two outcomes must occur as a result of an OSHA inspection:

1. If OSHA inspects and determines the employer meets or exceeds safety standards, the inspector is satisfied and does not issue citations.
2. If OSHA inspects and determines the employer has violated safety standards, the inspector may issue citations and assess penalties.

In either case, OSHA administers consequences. Remember, effective accountability for safety exists only when performance results in appropriate consequences: This is the fundamental principle of a successful accountability system.

The Six Elements of an Effective Accountability System

Accountability is one key to effective safety management systems.

Accountability is an essential element within the safety management system (SMS) because if you don't have it, the safety management system won't function effectively. Although the intended purposes of the SMS are to prevent accidents and save money, the SMS may unintentionally do just the opposite. In this section, we will discuss the six elements within a Safety Accountability Program that help the employer achieve the purposes of an effective SMS. The six elements are:

1. Formal standards of performance: Everyone is expected to work to an expected level of performance.
2. Adequate resources and support: The employer must provide the resources and support to achieve the expected level of performance.
3. A system of performance measurement: The level of performance must be measured in an objective manner.
4. The application of effective consequences: Consequences are effective when they increase desired behaviors.
5. The appropriate application of consequences: Consequences, such as discipline, are appropriate when they are justified, objective, and administered after careful analysis.
6. Continuous evaluation of the accountability program: The accountability program is analyzed and evaluated to help it continually improve.

You can use the guidelines in the six elements of an accountability system to help design, develop, and deploy an effective accountability system.

With that in mind, let's look at an example of how each of the six elements can be evaluated to determine if the accountability program is effective.

What's Wrong With This Picture?

Joe's driving a defective forklift.

Given the criteria for effective accountability above, read the following scenario to determine if discipline is appropriate.

• Gloria, the shipping supervisor at XYZ Distributors, immediately suspended Joe, a forklift driver, for two days without pay for driving a forklift into a 55-gallon drum of agent-x which resulted in an uncontrolled release of a hazardous chemical. Gloria was under a lot of pressure from her manager to get three late shipments of product out the door before the end of the work shift. As a result of the incident, the company's emergency response team had to be activated to contain the spill, and an outside contractor hired to clean the spill.
• The follow-up incident analysis determined the brakes on the lift truck were defective. No preventive maintenance inspection on the forklift had been conducted for five months. Neither the supervisor nor driver from the previous shift had reported the condition at workshift changeover. Joe notified Gloria (per safety policy) at the beginning of the workshift he believed the brakes might be weak. Gloria, who was "buried in paperwork," responded with, "just be careful and use common sense."

If you think Gloria was justified in disciplining Joe, please read the partial findings in the next section very carefully. Unfortunately, discipline like this is commonly administered subjectively, blaming the employee, not the safety management system.

Appropriate Discipline

Fix the system before you fix the blame.

Let's take a look at a few of the possible accountability system failures in the previous scenario that supports the position that discipline was not justified nor appropriate:

1. Standards of performance: Gloria responded to Joe's hazard report by merely telling him to be careful. As an agent of the employer, she actually "re-wrote" and reversed a safety policy prohibiting the use of defective equipment. Thus, operating a forklift with defective brakes was allowed if Joe "just used common sense." Improvement: Education on OSHA supervisor responsibilities.
2. Physical resources: Gloria's decision to allow Joe to continue using of a defective forklift. Improvement: Develop and implement preventive maintenance policy and inspection procedures.
3. Lack of adequate education and training: Gloria may not have received adequate education and training on the company's safety accountability system and disciplinary procedures. Improvement: Design and conduct management education and training on concepts of accountability policies and procedures.
4. Failure to detect and correct: The prior shift supervisor and employee did not detect and correct the defective forklift before the incident. Improvement: Design and conduct management training on safety oversight and reporting responsibilities.
5. Lack of analysis: Gloria administered discipline too soon; before the facts uncovered in the follow-up incident analysis were completed. Improvement: Design and conduct management training on disciplinary procedures.
6. Discipline is based on subjective data: Gloria did not have the facts before disciplining. Discipline was the result of an emotional reaction and based on assumptions. In this case, had she waited, she would have realized that discipline was not justified because some rather glaring safety management system weaknesses existed. Why did she react before having the facts? Improvement: Design and conduct management and employee training on safety accountability criteria.

These were not all of the system failures: just a few examples. Given more background information and analysis, other important system failures would also have been discovered throughout various levels of staff and line management. These and other failures support the position that employee discipline was not justified in this scenario. Remember, if the system has somehow failed the employee, discipline is NOT justified. The appropriate response, one that demonstrates real leadership, is to apologize to the employee and make a commitment to fix the system.

Clearly state standards of performance
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Element 1: Formal Standards of Performance

OSHA has developed rules in occupational safety and health that are standards of performance for employers. Employers are required to, likewise, establish standards that include safety programs, plans, policies, processes, procedures, practices, job descriptions, and rules. Employers must convey these safety standards of performance to employees clearly by doing the following:

• Make sure safety policies and disciplinary procedures are clearly stated in writing and made available to everyone.
• Educate all employees, both management and labor, on these policies and procedures.
• Make sure employees certify they have read, understood, and will comply with those safety policies and procedures.
• Do this when you hire them and annually after that.

If standards of acceptable behavior and performance are not established and communicated to employees, an effective accountability system is impossible. Management may not be justified in administering discipline without clearly written and communicated standards.

Element 2: Adequate Resources and Psychosocial Support

We can't work safe while overly stressed!
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Before employers are justified in administering appropriate consequences, they should first provide their employees with the means and methods to achieve established standards of performance. Employers should provide a safe and healthful physical and psychosocial workplace environment.

• Physical resources: Helps to ensure safe and healthful conditions and exposures. Examples include safe tools, equipment, machinery, materials, workstations, facilities, and environment. State and Federal OSHA agencies emphasize this category.

• Psychosocial support: The prevention of psychosocial stress is closely linked to the promotion of a healthy work environment. Stress refers typically to feelings of strain, tenseness, nervousness, and reduced feelings of control. Stress takes our mind off of the work we're doing and increases the chance of being injured or ill.

Examples of psychosocial factors that increase stress include job dissatisfaction, monotonous work, pressure from others to work fast, limited job control, and lack of positive consequences.

Examples of ways to support the psychosocial environment that reduce stress include:

• effective safety education and training,
• reasonable work schedules and production quotas,
• human resource programs,
• safe work procedures,
• competent management, and
• tough-caring leadership.

Element 3: A System of Performance Measurement

Develop a way to measure performance.
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Once again, when applied to safety behavior and performance, being held accountable demands more than merely being answerable to someone. In an effective accountability system, the quality or level of safety performance is measured regularly and often. Measurement processes include informal/formal observations. However, effective measurement means more than merely observing behaviors. It also includes quantifying behaviors and activities and then adding up the numbers. Those numbers, called Key Performance Indicators, form the statistics that you can use to improve the safety management system.

Key Performance Indicators Up and Down the Organization

Examples of measured safety behaviors and performance at various levels include:

Top/mid-level managers: Unfortunately, measurement at this level typically includes lagging indicators or results statistics over which top managers have little direct control. It's hard to control something, like an accident that has already occurred. 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 an ineffective measurement at all levels. Leading indicators measure performance that occurs before an accident. They are more proactive and beneficial because they help to prevent future accidents. Appropriate leading indicator 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;
• participation in safety education/training; and
• supporting involvement in the safety committee.

Key Performance Indicators (Continued)

Develop Key Performance Indicators for all organizational levels.

Supervisors: Supervisors may not be able to completely control the results (such as the accident rate) of their work area. However, they do have the ability to control their safety management and leadership activities. Therefore, to hold supervisors accountable, performance measurement at this level should primarily include proactive supervisor 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 should include appropriate proactive personal behaviors such as:

• complying with company safety rules
• reporting injuries and near-misses immediately
• reporting hazardous conditions and practices
• submitting safety suggestions
• participating in safety activities

If managers expect and recognize employee behaviors and activities above are expected and recognized, the results that we all worry about will take care of themselves. Improve the process and watch the outcome follow!

Appropriate Accountability

No control, No discipline
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A basic rule for accountability is that managers should hold employees accountable for a responsibility only if they have adequate:

1. time,
2. authority,
3. resources, and
4. ability to fulfill it.

If managers and employees are being measured and held accountable for results over which they have no control, they will attempt gain control over the results. The attempt to establish control may include inappropriate strategies.

For example, a supervisor who's measured only on department accident rates may threaten to fire anyone who completes an OSHA 301, Incident Report. Not only is that behavior counterproductive for the company, it is illegal!

OSHA assumes the employer ultimately controls all of the many operational variables such as raw materials, equipment, machinery, work schedules, personnel, and policies that make up the day-to-day work environment. Therefore, employer performance in providing resources and implementing policies, etc., should be measured.

On the other hand, employees may have very little control over operations in the workplace. However, they do have control over their behavior: Employees can choose to work safely or to take chances.

In the workplace, managers should measure supervisor activities and behaviors, and it's important that supervisors measure their employees' safety behaviors. Employees can choose to comply with safety rules, and they may decide to report injuries and hazards in the workplace. Consequently, we need to measure these personal behaviors.

OSHA doesn't merely observe, they inspect, investigate, and issue citations that may include monetary penalties: Now that's the measurement with consequences, isn't it?

OK, we've looked at Elements 1-3 of the accountability program. Now let's head over to Module 2 to check out Elements 4-6.

Check your Work

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Optional Video

Regardless of your operations and organization, accountability is what makes your safety system work. Dan Peterson tells how holding people accountable — top to bottom — eliminates accidents and injuries more than any other single approach. Learn more about Caterpillar's safety culture products.