Resources - OSHA Compliance

Safety Accountability Systems

Introduction

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.

What is Accountability?

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.

If you examine only these two definitions, it's understandable why we might conclude that these two terms have virtually the same meaning. However, notion of being "liable or legally bound" sets accountability apart. When applying these two concepts to management in the workplace, they take on very important and distinct differences in meaning and application.

  • 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

Accountability may also be thought of as one of the very important subsystems within the overall safety management system. The safety committee or coordinator may use these guidelines to help develop, monitor and improve workplace accountability for safety.

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

1. Established formal standards of performance

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 they have read, understood, and will comply with those safety policies and procedures. Do this when they are hired, and annually thereafter.

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

2. Resources to meet the standards of performance

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.

3. A system of performance measurement

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 then use to improve the safety management system.

Accountability and authority A basic rule of thumb for any accountability system states that, "a person should held accountable for a responsibility only if that person has the authority or the ability to control." If a person is being measured and held accountable for results over which they have no control, that person will attempt to gain control somehow. 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 injury report. Not only is that behavior counterproductive for the company, it's illegal!

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. 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. 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.

In the workplace, it's important that supervisors measure their employees' safety behaviors. Managers should measure supervisor activities and behaviors. OSHA doesn't merely observe, they inspect and investigate...issue citations that may include monetary penalties: now that's measurement with consequences, isn't it. To find out when/if your employer was last inspected/investigated by OSHA and the results, visit OSHA's Establishment Search.

4. Effective consequences

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.

Four categories of consequences

Positive reinforcement - If we do something well, we get rewarded.

  • Must always increase desired behavior.
  • Worker performs to receive a positive consequence
  • Worker may perform far beyond minimum standards - discretionary effort
  • Focus is on excellence - success based
  • "If you report a hazard, you will be recognized."
  • "If you prevent an injury or save money, you will be rewarded."

Negative reinforcement - If we do something well, we don't get punished.

  • Worker performs to avoid the consequence
  • Intent is to increase desired behavior.
  • Worker performs to minimum standard - just enough to get by
  • Focus is on compliance - fear based
  • "If you comply with safety rules, you won"t be punished."

Punishment - If we do something wrong, we get punished.

  • To avoid the consequence, the worker does not perform.
  • Must always decreases undesired behaviors.
  • Is usually unintentional in organizations
  • "If you engage in horseplay, you will be suspended from work."

Extinction - No matter how well we do, we don't get rewarded.

  • Withdrawal of positive reinforcement.
  • Worker eventually performs without expectation of consequences (other than wages)
  • Person is ignored - no relationship with management
  • Is epidemic in organizations
  • "It doesn"t matter how hard I work around here."
  • "Apathy is rampant, but who cares."

In all instances, to be effective, consequences should be soon, certain, significant, and sincere. Accountability is operating effectively only when consequences follow behavior. When consequences are nonexistent or inconsistent, accountability is not functioning properly in your company.

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.

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

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 puts potentially enormous pressure on top managers to put pressure 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

After all is said and done, if the 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! Is this all "pie in the sky"? It doesn't have to be. Now let's take a look at some real-world problems related to this element.

Good intentions...bad results

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.

Although the company may be able to boast of thousands of production hours without a reported injury, some of their employees may actually be injured or ill. (I call this the "walking wounded" syndrome.) However, negative peer pressure, the desire to "win", or other workplace factors may cause the employee to decide not to report their injury or illness.

Not only is the behavior being rewarded not appropriate, it's not legal! According to the OSH Act of 1970, Section 5(a) Each employer must:

  • 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.
  • Comply with occupational safety and health standards promulgated under this Act.
  • Ensure each employee complies 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.

Since reporting injuries is a mandated responsibility, the employer should do what is necessary to promote this behavior, and nothing that promotes "not reporting."

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

Performance appraisals should index specific safety behaviors and performance just as other production/service criteria are evaluated.

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.

5. Appropriate application of consequences

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.

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?

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 4-R principle) : The more regularly you recognize, the more rarely you'll have to reprimand.

It's critical to understand that before administering progressive discipline, managers and supervisors 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 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.

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 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 mandatory safety rule has, in effect, been transformed into a discretionary guideline. 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 do 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.

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: 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.

6. A process of 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:

  • 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.

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.

Evaluating for Accountability

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?

Who's accountable for what?

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 an employee is 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.

When are negative consequences appropriate?

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're fulfilling your supervisor accountabilities.

The first supervisor accountability: Providing a safe environment. As stated earlier, one very important supervisor accountability is to provide a safe and healthful work area. This means providing all those resources necessary for employees to complete their tasks safely.

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.

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.

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.

Source: OSHAcademy

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Copyright ©2000-2016 Geigle Safety Group, Inc. All rights reserved. Federal copyright prohibits unauthorized reproduction by any means without permission. Students may reproduce materials for personal study. 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).