When Harry Truman said, "The buck stops here," he meant that he was responsible for his decisions and accepted the consequences that followed them: He understood accountability. Many do not understand what accountability is. Consequently, they fail to plan and design an effective accountability system. To better understand what accountability discuss each part of this very important equation:
Accountability may be thought of as the condition of being held liable or answerable for one's safety performance. It establishes an obligation to (1) perform assigned responsibilities, (2) at a prescribed level or standard. Accountability is fixed through the application of natural and system consequences.
OSHA believes accountability helps employees understand management's commitment to achieve and maintain a safe and healthful workplace. Their research indicates enforcement through a progressive disciplinary procedure is an indispensable piece of a whole approach to safety and health protection. There is little possibility of effective safety and health protection without carefully designed policies and rules for safe and healthful practices that cover all personnel, from the site manager to the hourly employee.
Since hourly employees are most often exposed to workplace hazards, it makes good sense to involve them in the establishment of safe work practices and safe work rules. Once safe work practices are established and employees understand why it is important to follow them, corrective disciplinary action may be rarely needed.
The General Duty Clause of the OSHAct of 1970 furnishes some insight into five important employer safety accountabilities:
Accountability exists within the safety culture as a condition or state of being. An employee's sense of accountability is a felt internal condition or effect caused by the knowledge that failure to achieve standards of performance will lead to a consequence. Successful accountability exists when appropriate behavior is objectively evaluated and results in effective consequences. This can be expressed with the following equation:
It is appropriate to hold employees accountable for behaviors over which they have control. Generally, appropriate behaviors for employees include:
It is not appropriate to hold employees accountable for behaviors and results over which they do not have control. For example, employees should not be held accountable for correcting a hazard if they only have authority to report it, not correct it. Employees should not be held accountable for the number of accidents they've suffered because, in most instances, they do not have control over the many factors that may have directly caused or contributed to the accident.
Working safe is a behavior and should be defined in behavioral terms such as, "using safe procedures and practices." Working safe should not be defined as a result with terms like, "working injury-free." In the workplace, lucky employees can work all year, regularly violating safety rules, and not get hurt. Other employees can consistently comply with safety rules, yet get injured. Using safe procedures and practices will reduce exposure and, therefore, probability of injury, but it does not eliminate the possibility. Bottom line, the following principle is fundamental to effective accountability:
To be objective, the performance evaluation must be based on factual data rather than subjective hunches or feelings. To be perceived as fair, it must be motivated by a need to help, not hurt, the employee. The performance evaluation process will naturally take some time and should be carefully conducted to accurately:
For discipline to be justified, analysis of the behavior and evaluation of the safety management system (SMS) must occur prior to evaluation of the behavior. In most cases, due to the large number of possible variables (contributing surface and root causes) at play in an SMS, it is appropriate to assume that the SMS somehow contributed to the unsafe behavior. A thorough event analysis and system evaluation will result in two outcomes:
Regardless of the performance evaluation outcome, consequences will occur. Actually, there can not NOT be consequences. The challenge is to make sure consequences effectively increase the frequency of desired behavior. Consequences may be categorized as follows:
Effective discipline is progressive
OSHA requires a progressive disciplinary system. This does not mean that OSHA expects discipline to be administered liberally, but rather, that progressively more significant (or severe) consequences should be designed into the accountability system. The receiver of the discipline determines the significance of the discipline. If the unsatisfactory behavior continues, assume the disciplinary action was not perceived as significant to the employee. Consequently, progressively more significant discipline may be required. Hopefully, the employee will get the message early-on and decide to change his or her behavior in the desired direction.
To make sure the condition of accountability for safety is effectively maintained in the workplace, an accountability system needs to designed and implemented. Understanding the concept of accountability as a system is important to all line and staff managers as well as employees. The various processes within an effective accountability system are critical to the success of an organization's SMS.
The intended purpose of a safety accountability system is to increase desired safety behaviors through a system of standards, measurement, evaluation, and consequences. Accountability systems are likely to fail if employers do not effectively design and implement a number of important processes and best practices. Six essential processes in an effective safety accountability system should be considered:
In an effective safety management system, employees, from top mangers to line workers, are held accountable only for those responsibilities over which they have control. What an employee actually controls in the workplace depends on the position they hold. With greater assigned responsibility comes greater fixed accountability. Accountability follows control.
Discipline should be based on objective facts, not subjective momentary feelings. It should be consistently administered throughout the entire organization.
Discipline should be appropriate to the negative impact the infraction has on the individual and organization. For example, when employees perform unsafe acts, they violate an organization's safety rules. However, when managers perform those same unsafe acts, they not only violate safety rules, they actually revise enforced organizational safety policy such that (1) required behaviors become optional behaviors, and (2) the employer is in jeopardy of legal liability should an injuries occur. Thus, the severity of the consequence should be greater. Likewise, infractions that result in serious injuries or fatalities deserve greater discipline than minor infractions. Finally, repeated infractions should result in progressively greater discipline.
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 that resulted in an uncontrolled release of 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 activated to contain the spill and an outside contractor hired to clean the spill. The follow-up incident analysis determined that 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 shift changeover. Joe notified Gloria at the beginning of the shift that 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 on very carefully: you need to. Although there is a limited amount of information in this scenario we can, nevertheless, establish that Gloria was not justified in disciplining Joe. Analysis of this scenario will uncover system failures. Let's take a look at a few of the possible failures within the accountability system that supports this position:
Given more background information and analysis, other important system failures would also be discovered throughout various levels of staff and line management. These and other failures support the position that employee discipline is not justified in this scenario. Additionally, it's important to note that safety staff would help top-level staff and line managers design and implement the improvements to the safety management system.
If you Regularly Recognize and Reward, you'll Rarely have to Reprimand!
Designing and implementing an effective safety accountability system has the potential to improve safety compliance behaviors to record highs within an organization. In the next article, I'll discuss recognition system processes safety staff can promote to help staff an line managers improve discretionary employee safety behaviors and performance so that discipline is rarely required.
Copyright ©2000-2019 Geigle Safety Group, Inc. All rights reserved. Federal copyright prohibits unauthorized reproduction by any means without permission. Disclaimer: This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirement and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency. CertiSafety is a division of Geigle Safety Group, Inc., and is not connected or affiliated with the U.S. Department of Labor (DOL), or the Occupational Safety and Health Administration (OSHA).