Editor’s Note: A writer claiming to be a safety official sent the USW Blog a message this week complaining about the USW’s position on Behavior Based Safety (BBS) programs. Michael J. Wright, director of the USW Health, Safety and Environment Department sent him the response below. It was written on the day Mr. Wright’s department began investigating the explosion at the U.S. Steel Corp. coke plant in Clairton, Pa. that injured 20 workers, three critically. It was the same day that an electrician from Massey Energy’s Upper Big Branch Mine, where a methane explosion killed 29 workers in April, confirmed that he’d been ordered to bypass a methane detector. The USW and United Mine Workers of America are working together to secure more stringent safety standards and enforcement.
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By Michael J. Wright
Director, USW Health Safety and Environment
In your message to the USW Blog, you say: “Unless the safety manager is an inexperienced rube, BBS does NOT replace or displace a comprehensive health and safety program…” Sadly, we’ve seen a lot of workplaces where that is exactly what’s happened. I’ve seen programs where a BBS consultant sells their services as “all you need for a safe workplace.” I’ve seen cases where a company spends all its budget of BBS and lays off the plant safety professionals. And in almost every small or medium size company that initiates a BBS program, that program becomes the centerpiece of the whole safety effort. Hazard recognition and control, job safety analysis, and root-cause incident investigation become afterthoughts.
As I’m sure you know, BBS programs are so variable that the term is almost meaningless. Some believe in assigning discipline, some do not; some use incentive programs; some are against them. But they all begin with the premise that by observing and correcting individual worker behavior we can eliminate most accidents. That is certainly not the case with the majority of the accidents our department investigates. Take, for example, some of the most serious accidents in the last five years or so – BP Texas City in 2005 and this year’s Upper Big Branch Mine, Tesoro Anacortes, and the Deepwater Horizon. (Texas City and Tesoro were USW workplaces, where we participated in the investigation.) In no case was the behavior of the individual workers an underlying cause. Rather the causes were poor maintenance, inadequate instrumentation, failure to learn from past near-misses, failure to properly analyze complex systems, cost-cutting and a willingness on the part of management to tolerate an unacceptable level of risk.
You mentioned the DuPont STOP system. At least in the past, STOP training started with the assertion that 90% or more of all accidents are caused by unsafe acts, and the rest by unsafe conditions. That statement doesn’t even rise to the level of being wrong – it’s meaningless. In one sense every accident is caused by unsafe acts – if we include decisions by the CEO or plant manager or engineering consultants. But that’s not what DuPont means – they are focused on unsafe acts by the accident victim or a close co-worker. But all accidents require an unsafe condition, by definition. In many cases a worker also “committed an unsafe act” – which we prefer to call “made a mistake.” Attributing causation to one or the other is like saying that a third of all fires are caused by the presence of fuel, a third by the presence of oxygen, and a third by a source of ignition.
By the way, in the past couple of years we’ve investigated two fatalities in STOP workplaces. Both plants were pretty dangerous, with numerous unaddressed hazards. One of my co-workers called one of the plants the worst place he had ever seen, which from him was quite a statement. But both plants had great STOP programs.
That’s not to say we ignore human factors in accidents. We address human factors in two ways. First, we try to find and remove the impediments to working safely – fatigue, poor instrumentation, bad training, conflicting job demands, etc. As part of that, we also work to achieve the right to refuse unsafe work without retaliation.
Second, we recognize that everyone eventually makes a mistake. We can and should work to make mistakes less likely, but it’s critical to have a workplace where a single mistake isn’t going to get you killed.
One more thing: we hate the word “behavioral.” It’s trendy and sounds academic, but if your childhood was like mine, when our parents talked about our “behavior,” it was never a good thing. I don’t know how to do safety work without enlisting the knowledge, skill and commitment of employees in things like job safety analysis, incident investigation, and recognizing the risk of unusual or upset conditions. Behavioral safety sends workers the subtle message that they are the “problem.” Our message should be that employees are the solution.
Posted July 15, 2010 at 3:11 pm, in From the News

