OSHAcademy Course 116 Introduction to Safety Accountability - Module 2

Course 116 Introduction to Safety Accountability

Consequences and Evaluation

Element 4: Application of Effective Consequences

What is a Consequence?

A "consequence" is anything that occurs as a result of something that happens. Another way to express it is to think it in terms of cause and effect: the initial behavior is the "cause" and the consequence is the "effect." For every cause, there is an effect. The effect may be something that affects you internally, externally, or both.

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Be careful, or you'll suffer the natural consequences!
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In each example below, the initial behavior or action is the cause: the reaction or response is the effect or consequence. Let's look at some examples:

  • You don't pay attention when pounding a nail (cause), SO you hit your thumb with the hammer, and it hurts. (effect)
  • You don't think safety is important, SO you get injured taking an unsafe shortcut on the job.
  • Your supervisor sees you take an unsafe shortcut, SO he gives you a written warning.

Is there any escape from consequences?

Not in the workplace. It's important to understand there is no such thing as "no consequence" for an action. You cannot NOT have a consequence. For instance, if a supervisor thanks a worker for making a safety suggestion, the supervisor's recognition is a consequence (positive). If the supervisor ignores the worker who made the safety suggestion, the "act" of ignoring is also a consequence (negative).

Effective consequences increase desired behaviors.

If employee safety performance meets or exceeds the standards set by the employer, you know consequences are effective. When employees meet or exceed performance standards, some sort of positive recognition should follow. On the other hand, if employees make informed choices not to comply with the company's safety performance standards, some sort of appropriate corrective action should follow.

Every cause has an effect.

1. How can you tell when a consequence has been effective?

a. Employees behave when only when being supervised
b. Employees work only to stay out of trouble
c. Employees take shortcuts when unsupervised
d. Employees meet or exceed performance standards

Positive and Negative Reinforcement

There are various strategies for administering positive and negative consequences. Careful planning is critical to ensure consequences are effective. So, let's first take a look at positive and negative reinforcement, and why positive reinforcement is best in producing a world-class safety culture.

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A sincere handshake can go a long way!
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Positive Reinforcement

Positive reinforcement is the use of consequence strategies that attempt to increase the frequency of desired behaviors through positive recognition and/or reward. Consequences for safe behaviors that meet or exceed expectations should include some form of positive recognition and/or reward. Consequently, workers will believe that if they do something well, they will get recognized.

Important criteria to remember about positive reinforcement include:

  • It will increase desired behavior and employees may work far beyond mere compliance.
  • The desired behaviors may actually be safe or unsafe. If the desired behavior is to work fast, employees will prioritize working fast, not necessarily safe.
  • Workers may perform far beyond minimum standards - discretionary effort.
  • If the desired behavior is to work safe, no matter what - it's a value-based safety strategy.
  • If the desired behavior is to work fast, not necessarily safe - it's a priority-based safety strategy. Safety may be prioritized below production.
  • This strategy is more effective if the goal is to achieve a world-class safety culture.

It's important to know "desired" behaviors may not always be safe behaviors. Unfortunately, this may be true in safety cultures where it is more important to work fast than safe. In this instance, working fast and not safe is top priority. This is especially true when the employer is under pressure to finish a project on time. Here are some examples showing how perceived positive reinforcement can increase both safe and unsafe behaviors:

  • Your supervisor thanks you, if you comply with all the safety rules.
  • Your supervisor gives you time off, if you take safety shortcuts to get work done ahead of schedule.

2. Which strategy may result in performance far beyond mere compliance?

a. Ignoring performance
b. Positive reinforcement
c. Negative reinforcement
d. Zero tolerance for error

Negative Reinforcement

Negative reinforcement is the use of consequence strategies that attempt to increase the frequency of desired behaviors by withholding negative consequences. Workers will believe if they do something the employer wants, they will avoid negative consequences. If safety is what the employer wants, these strategies will be less effective because workers are generally only trying to do what is necessary just to "stay out of trouble". Important criteria of negative reinforcement include:

  • Workers perform only to avoid the perceived negative consequence - nothing else.
  • The desired behavior may actually be safe or unsafe.
  • The intent is to increase desired behaviors by withholding an unwanted consequence.
  • Workers perform to minimum standard but not beyond: just enough to stay out of trouble.
  • The focus is on compliance, not excellence. - it's a fear-based strategy.
  • This strategy is less effective if the goal is to achieve a world-class safety culture.

Once again, the outcome is dependent on the behaviors that the employer actually wants. Hopefully, the employer prioritizes safety, but that's not always the case. Here are some examples that show how perceived negative reinforcement can increase both safe and unsafe behaviors:

  • If you comply with safety rules, the supervisor says you won't be reprimanded.
  • If you take safety shortcuts to get work done ahead of schedule, your supervisor does not get upset.

3. Which of the following is the strategy to increase desired behaviors by withholding negative consequences?

a. Positive punishment
b. Positive reinforcement
c. Negative reinforcement
d. Negative punishment

Positive and Negative Punishment

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One winner - many losers! Positive reinforcement for one - negative punishment for many.

Positive Punishment

This is a little hard to figure out. How can punishment be positive? Positive punishment occurs when a worker's safety behavior or performance results in a perceived negative consequence that serves to decrease the probability of that behavior in the future.

For instance, a supervisor might yell at a worker who is violating safety rules. If the worker stops violating safety, the supervisor ceases yelling. The supervisor's yelling serves as a positive punishment because the supervisor adds an unpleasant response in the form of yelling.

Negative Punishment

Negative punishment occurs when a worker's behavior or performance results in the removal of a perceived positive consequence. Removal of the consequence decreases the probability of that behavior in the future. For instance, the supervisor withholds positive recognition if workers do not achieve certain standards of behavior or performance.

Why Recognition Programs Fail

Both positive reinforcement and negative punishment occur in safety recognition programs that reward one employee for being first, best, or most improved. At the same time the one winner receives positive reinforcement, everyone else receives negative punishment because they are, in fact, losers. Everyone else may have performed quite well, but since they were not the best, positive recognition is withheld. The result is one winner and many losers.

Recognition programs that reward only the best performer can actually demotivate most workers. This form of negative punishment is one of the primarily reasons safety recognition programs do not work. The best strategy is a recognition program that is criterion-based and recognizes everyone who meets the criteria for recognition. The goal is to have many winners who all meet or exceed management expectations.

4. What is the best strategy to ensure your recognition is most effective?

a. Recognition is criterion-based - create many winners
b. Recognition is merit-based - create one winner
c. Recognition is universal - everyone wins
d. Recognition is withheld - only good employees win

Ignoring

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Never ignore good performance!
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Ignoring, intended or unintended, is actually a common form of negative punishment. You might think ignoring employee behaviors is actually withholding a consequence. No such luck. Every response, including ignoring, is a consequence. In fact, ignoring desired behaviors in the workplace is usually the least effective consequence because it leads to extinction of those behaviors. Think about it. Have you ever been ignored when you thought you should have been recognized? I bet you were upset. And it didn't matter why you were ignored either: you didn't like it. So, let's take a look at some of the characteristics of extinction:

  • It is the withdrawal of recognition;
  • The worker is ignored and no matter what, desired behavior becomes less frequent. For instance:

    • If workers breaks safety rules and a supervisor ignores it, the worker may perceive this as a positive consequence and will less likely behave safely in the future.
    • If workers complies with safety rules and this is ignored, the worker may perceive it as a negative consequence and will more likely break safety rules in the future.
  • Workers eventually perform without an 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."

5. What is the most common form of negative consequence of desired behaviors in the workplace?

a. Punishing performance
b. Negative reinforcement
c. Positive reinforcement
d. Ignoring performance

Element 5: Appropriate Application of Consequences

Without the expectation of consequences, accountability has no credibility and will not be effective. In other words, 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.

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.

Justified Consequences

Negative consequences are justified when the person administering discipline has fulfilled their own accountabilities first. Positive consequences are justified any time employees meet or exceed expectations. Here's an important principle (I call it the 5-R principle) : The more Regularly you Recognize and Reward, the more Rarely you'll have to Reprimand.

6. What must occur FIRST for supervisors to be justified in disciplining for unsafe performance?

a. Supervisors must prove they are right
b. Supervisors must fulfill their own accountabilities
c. Supervisors must show the employee did not use common sense
d. Supervisors must indicate intent on the part of the employee

"Five Stars" Leadership is the Key

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A good way to remember your obligations.
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It's critical to understand that before administering progressive discipline, managers and supervisors exercise real leadership when they first ask five important questions to how well they have fulfilled their own obligations to employees. Doing this is important to make sure they are actually justified in administering corrective actions. The negative impact on the company if employees are disciplined inappropriately can be dramatic over time.

The good news is that determining if discipline is appropriate doesn't have to be difficult. When conducting a self-evaluation, managers and supervisors can use the " STARS" acronym to the right to help them remember their five basic safety obligations to employees. Let's take a look at each of the five obligations:

  1. Supervision: 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. Managers and supervisors should ask, "Did I catch them violating safety rules before they got hurt?"
  2. 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 understand the natural and system consequences of noncompliance. Managers and supervisors should ask, "Have I provided (or has the employee received) quality safety training?"
  3. Accountability: 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 without following through. If supervisors allow employees to violate safety rules, all justification for discipline disappears. Managers and supervisors should ask, "Have I applied safety accountability fairly and consistently in the past?"
  4. Resources: 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 to work safely.
  5. Support: 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. Managers and supervisors should ask, "Have I provided the employee with a safe and healthful workplace?"

If managers and supervisors can honestly answer "YES" to each of the above five questions, it may be appropriate to administer discipline because the five basic leadership obligations have been fulfilled. However, if they cannot honestly answer "yes" to each question, then an apology would be in order, and a promise to make personal and system improvements (provider better training, resources, expectations of enforcement, supervision and leadership).

7. If a new employee is caught, during his first day at work, wearing the wrong type of PPE while performing a hazardous task, which of the following supervisor accountabilities is least likely to have been fulfilled?

a. Adequate psychosocial support
b. Adequate supervision
c. Adequate physical resources
d. Adequate PPE training.

Consequences (Continued)

How Severity and Responsibility Affect Consequences

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Now this could be severe!
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  • Severity: 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.
  • Responsibility: 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 transformed from a mandatory requirement into a discretionary guideline. Consequently, as a guideline, it is not legally auditable or enforceable.

In the examples above, a more severe level of discipline would be in order for the supervisor because the supervisor, in effect, gives permission for all employees to violate the safety rules. Consequently, the negative impact on the safety of employees has the potential to be much greater when the supervisor 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 would certainly be appropriate.

Consistent Application of Consequences

  • Consequences are 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: up and down, and across functions. Every supervisor and manager must be held accountable in the same fair manner consistent with employees. If labor perceives the accountability system as applying only to them, they will naturally consider it unfair: the primary failure mode for accountability systems.

8. What occurs when a supervisor ignores an employee who fails to follow fall protection rules when required?

a. The mandatory rule becomes discretionary guideline.
b. The supervisor becomes the agent of the employer.
c. OSHA may not cite the employee for violations.
d. Top management criminally cited by OSHA.

Element 6: Continuous Evaluation of the Accountability System

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Continually evaluate to continually improve.
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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 in 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:

  • 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.
  • Evaluation: Compare and contrast each accountability system policy, plan, procedure, process against benchmarks and best practices to judge their effectiveness.

Evaluating for Accountability

OSHA looks primarily for two program elements when evaluating an employer for accountability: Policy and consequences. OSHA does not mandate or require specific recognition/disciplinary procedures: That's the responsibility of the employer. But, an effective accountability policy that is written and clearly communicated should be in place. Make sure your company has a written policy that addresses accountability including the three key components.

  • specific performance expectations
  • who is accountable - both management and employee
  • appropriate consequences such as progressive discipline

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 missing.

9. When should evaluation of the Safety Accountability Program occur?

a. At least annually
b. After a serious accident
c. Continuously
d. As needed

Check your Work

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Final Exam

Optional Video

One of our favorite speakers, Kevin Burns talks about how safety leaders define responsibility and accountability. Kevin Burns is a management consultant, safety speaker and author of "PeopleWork: The Human Touch in Workplace Safety."



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