The Multinational Monitor

November 2000 - VOLUME 21 - NUMBER 11


Blame the Worker

The Rise of Behavioral-Based
Safety Programs

By James Frederick and Nancy Lessin

Over the last decade, workplaces throughout the world have experienced massive restructuring that has included downsizing, increased hours of work (e.g., 12 hour shifts, mandatory overtime), intensification of work (increased work load and/or job duties), increased pace of work ("push for production") and a host of changes in technologies, work processes and management techniques. These changes, aimed at making workplaces more competitive and productive, have been associated with significant adverse health and safety impacts - repetitive strain injuries, stress, workplace violence, fatalities and other work-related injuries and illnesses.

Instead of examining how core work processes are affecting health and safety, many employers are directing attention to workers themselves as the problem rather than work restructuring and hazardous job conditions.

Enter "behavior-based safety" - safety programs that, depending on the particular behavioral safety program, claim that 80 to 96 percent of job injuries and illnesses are caused by workers' own unsafe acts. Behavior-based safety programs focus attention on worker carelessness and conscious or unconscious unsafe behaviors, and place the onus for a safe workplace on workers themselves.

The Behavioral Safety Industry
The "unsafe worker" statistics espoused by behavior-based safety consultants and repeated by employers purchasing or developing behavioral safety programs were derived from the work of insurance investigator H.W. Heinrich in the 1930s. Heinrich's research into injury causation consisted of his review of supervisors' accident reports, which critics pointed out naturally blame workers for accidents and injuries. He arrived at the statistic that 88 percent of workplace accidents and worker injuries were caused by workers' unsafe acts, numbers echoed by today's behavioral safety programs.

A variety of consultants and companies market behavioral safety programs to employers throughout the United States and around the world. The leading companies include Dupont (the Dupont STOP program), Behavioral Science Technologies, Aubrey Daniels (SafeR+ program), E. Scott Geller's Safety Performance Solutions (Total Safety Culture program), Topf Organization (SAFOR program) and Liberty Mutual Insurance Company (Liberty's Managing Vital Performance - LMVP program). These programs identify "critical worker behaviors," train "observers" (workers and/or supervisors who observe worker behaviors) and use some form of "critical behavior check-lists" to document when a worker has engaged in a safe behavior or committed an unsafe act.

Promotional materials for the Dupont STOP program say "STOP is people talking with people about safety. In a series of training programs, behavior is modified in favor of safety. The objective of the STOP program is to teach safety auditing skills, so supervisors and employees can observe workers who are performing normal work activities, reinforce safe work practices, and correct unsafe acts and conditions. STOP effectively communicates management's commitment to safety through the entire organization. From the top manager down, all employees are involved in the program. Everyone has a role to play in the safety effort when STOP is on the scene."

The rhetoric is similar from Aubrey Daniels International. "Our systems approach includes safety-related behaviors at all levels, ensuring that people from executives to frontline associates form a partnership of responsibility for creating and maintaining a safe workplace," the company proclaims. "ADI uses Applied Behavior Analysis methods in every part of the safety intervention. This dedication to behavioral principles is reflected in the four basic steps of ADI's SafeR+:

  1. Target the behaviors that actually cause accidents. Some unsafe behaviors are obvious, but many critical risk-taking behaviors are ingrained, automatic and subtle and must be identified.
  2. Complete observations and measurement in less than five minutes per day. A simple, but precise observation/measurement method allows for more data collection which facilitates fast improvement.
  3. Integrate safety feedback into meetings, discussions and regular interactions. Numbers don't change behavior, but sharing data in a positive and constructive performance context gives people the direction and opportunity to improve.
  4. Create a culture that recognizes and rewards safe behaviors. Frequent recognition/reward is the only way to establish and maintain safe behaviors."

"Culture" - counterposed to work organization - is a major focus of the behavioral safety crowd. "The key to safety and environmental excellence lies in creating a new culture," explains the Topf Organization. "Culture is defined as the ideas, customs, values, norms, attitudes, commitments, and behaviors of a group of people in a given period."

Sometimes, the programs are less friendly in practice than they sound in promotional brochures. Some behavior-based programs emphasize employers disciplining workers. The training materials from a Dupont-based behavioral safety program at a New England defense manufacturer states, "Discipline for Safety Infractions. Do Not Wait for Injury." Other programs, however, suggest that overt discipline associated with the program could be problematic.

But overt discipline or no, what unifies the behavioral safety programs is their focus on the workers, rather than working conditions.

In a Midwest tire manufacturer with a behavior-based safety program, the official accident report written up after a worker slipped and fell on ice in the parking lot stated, "Worker's eyes not on path," as the cause of the injury. The report did not mention the need to have ice and snow removed from the parking lot. It did not mention that the sidewalk had not been cleared of snow and ice for several weeks, even though workers were required to use the sidewalk periodically.

Some behavior-based safety program consultants have expanded their business internationally. One consulting firm, Behavioral Science Technologies, markets or implements its program in 17 countries. Behavioral Science Technologies conferences in the United States offer workshops in Spanish, attracting industry leaders and executives from countries in Central and South America.

Fear and Intimidation on the Job
Workers whose employers have implemented behavior-based safety programs describe an atmosphere of fear that descends upon the workplace, where workers are reluctant to report injuries and illnesses for fear of being labeled an "unsafe worker."

At one factory that had implemented a behavioral safety program, the United Auto Workers Health and Safety Department reports, when a union representative asked workers during shift meetings to raise their hands if they were afraid to report injuries, about half of 150 workers raised their hands. Worried that some workers feared even raising their hand in response to the question, the union representative asked a subsequent group to write "yes" on a piece of paper if they were afraid to report injuries. Seventy percent indicated they were afraid to report injuries. Asked why they would not report injuries, workers said, "we know that we will face an inquisition," "we would be humiliated" and "we might be blamed for the injury."

Related to a behavior-based approach to safety are several other employer-initiated programs that also discourage workers from reporting injuries. Safety incentive or "safety bingo" programs offer cash or prizes to workers who do not report injuries. Another related strategy threatens workers who report injuries with discipline or other disincentives, such as drug testing, loss of overtime opportunity or days off with no pay.

Prizes for safety incentive programs range from jackets, pizza parties and gift certificates to automobiles and cash. At one Midwest plant, all workers who did not report an injury during the course of a year were invited to dinner. At the dinner, one of the workers' names was pulled from a hat. That worker was given a check for $10,000.

Earlier this year, Sysco Food Services implemented a point system for its delivery and warehouse workers, whereby workers accrue points for injuries, accidents and workers' compensation claims filed. A workers' compensation claim costs a worker one point; a workers' compensation claim involving days away from work is assigned five points. Workers are terminated if they accrue 30 points, or report five workers' compensation-related injuries.

The theory underlying these programs is that workers who work carefully do not get injured (and therefore deserve rewards), and those who work carelessly and become injured deserve punishment.

ADI's Performance Management (PM) process is based on the science of Applied Behavior Analysis and focuses on the positive approach to systematically change the way people work. PM, when implemented effectively, inevitably results in measurable and meaningful business achievements and an improved and more productive work environment.

Transferring PM skills and system management to an organization's internal performance managers - an essential for ongoing success - requires both training and follow-up coaching from an ADI professional. PM training and coaching includes:

The ABC Model: An analysis technique for connecting behavior with consequences and using that knowledge to maximize and reinforce desired behavior.

Pinpointing Results & Behaviors: The difficult art of identifying and specifically describing results and the behaviors required to attain those results.

Measurement: How to develop fair and accurate measures of desired behaviors and outcomes and how to make measurement an enjoyable, even reinforcing event.

Feedback: The specific and frequent sharing of performance data that leads and encourages employees to improve.

Reinforcement: Combining all of the tools of PM to determine when and how to recognize and reinforce improvement and achievement to attain and sustain discretionary effort.

Monitor/Evaluate: Continued monitoring of results and behaviors to evaluate progress, or lack thereof, to troubleshoot the process.

What to expect: 6 Steps to Behavioral Solutions

Step 1. Analysis: ADI works with your organization to increase the probability of a successful PM implementation by examining current conditions, cultures and issues. This allows you to apply PM so that it has an immediate, positive, significant and lasting impact on your workplace operations.

Step 2. Planning: ADI helps your organization develop detailed plans and schedules for every phase of PM application from training to process structure to follow-up requirements.

Step 3. Training: We offer several training methods to fit your needs including: On-site training for all PM participants; Advanced Performance Management Training (APMT) presented for selected representatives from your organization at ADI's Atlanta home office, to supplement and advance your on-site training and implementation; PM Basics qualifies your internal trainers to provide PM training to others in the organization.

Step 4. Follow-up coaching and support: After training is completed, ADI specialists work with PM participants and your designated internal consultants through contact and consultation in small group settings, by phone, fax and/or e-mail according to customer preference.

Step 5. Skills transfer: Supported by the follow-up process, skills transfer is designed with the objective of bringing PM performers to a self-sufficient level of future PM planning and implementation. ADI also offers continuing opportunities for education and training that allow you to maintain and enhance PM competencies over time.

Step 6. Accountability: ADI consultants assist your organization in the design, application and management of accountability procedures so that your company can establish PM as the core component of your management process. Our goal is to ensure the long-term success of PM initiatives and to support an evolving process that meets your business objectives over time.

"The theory behind safety incentive and disincentive programs is more than questionable," says Michael Sprinker, director of health and safety at the International Chemical Workers Union Council.

Critics say the real goal of these programs is to discourage worker reports of injury and illness. Discouraging injury reporting can be hazardous. Workers may not get the care and early treatment they need, and job hazards may not be identified and corrected.

"Our union's experience confirms that these programs only cause underreporting of injuries and illness," says Sprinker. "Peer pressure and pressure from management are factors that cause a �put a cut hand in your pocket until you get home' practices in workplaces."

Employers have many reasons for wanting to discourage workers from reporting injuries. If workers do not report injuries as work-related, it can be difficult for them to receive workers' compensation benefits - covering medical costs and/or lost wages - related to those injuries. Those costs are then shifted to workers' health insurance at the same time that employers are increasing the share of these costs that are borne by workers themselves. Fewer workers' compensation claims also translate into lower workers' compensation premium payments for employers.

In the United States, discouraging workers from reporting injuries may also help employers escape Occupational Safety and Health Administration (OSHA) inspections. The Department of Labor collects employers' records of work-related injuries and illnesses (known as OSHA 200 logs). Under a new OSHA initiative, OSHA inspectors will make unannounced inspections of employers with rates of injuries and illness above a specified level. Employers with injury rates below that level are unlikely to receive an OSHA inspection unless a very serious accident occurs in the workplace or someone files a complaint with OSHA.

Union Resistance
The national AFL-CIO along with a number of U.S. unions have issued policy positions opposing "blame-the-worker" approaches to health and safety.

"These programs and policies have a chilling effect on workers' reporting of symptoms, injuries and illnesses," states a 1999 AFL-CIO policy resolution, "which can leave workers' health and safety problems untreated and underlying hazards uncorrected. Moreover, these programs frequently are implemented unilaterally by employers, pitting worker against worker and undermining union efforts to address hazardous workplace conditions through concerted action."

A 2000 United Steelworkers of America health and safety resolution offers a similar perspective.

"We will oppose those �behavioral safety' programs that assume misbehavior is the primary cause of workplace accidents," the resolution says. "We will oppose �safety incentive' programs that assume workers are too stupid to care about their own safety and must be bribed with trinkets. We will insist on safety programs that enlist the skill, knowledge and commitment of the workforce in finding and correcting hazards."

Workers, especially unionized workers, are not defenseless against behavioral safety programs.

Labor law in the United States deems health and safety a "mandatory subject of bargaining," meaning that employers cannot refuse to bargain with unionized workers over health and safety issues and are prohibited from making unilateral changes in health and safety programs and policies without providing the union an opportunity to bargain. Thus, when and if an employer decides to initiate a behavior-based safety program, a safety incentive program or injury discipline policy - even mid-contract - unions can demand to bargain.

To counter management's proposal of a behavioral safety program, unions can propose a comprehensive worksite health and safety program - focusing on identifying and eliminating hazards and utilizing the recognized hierarchy of controls, which supports the elimination of hazards and the use of engineering controls as preferable to lower-level and less effective control measures such as using personal protective equipment. To counter an employer-proposed safety incentive program that offers prizes to workers who do not report injuries, unions can propose that rewards be offered to workers when they identify serious hazards or recommend ways to eliminate them.

All workers covered by the Occupational Safety and Health Act (OSH Act) may have some legal protections from programs that discourage or penalize workers from reporting injuries. Section 11(c) of the OSH Act prohibits discrimination against workers who exercise their health and safety rights under the Act. Since employers are required to record worker injuries on their OSHA 200 logs, workers have rights to report their injuries without fear of discrimination. A safety incentive program that denies prizes to workers who report injuries may violate the anti-discrimination provisions of the OSH Act. Likewise, policies that place workers reporting injuries on a disciplinary track or require drug tests also discriminate against workers for exercising their right to report injuries.

Additionally, many state workers' compensation law prohibit programs and policies that punish workers when they exercise their right to file workers' compensation claims. Those safety incentive and injury discipline programs that punish workers when they file a workers' compensation claim may be illegal under specific state laws.

OSHA and NIOSH Complicity
U.S. federal worker health and safety agencies are doing little to curb the proliferation of behavior-based safety, safety incentive and injury discipline programs, and in some cases are supporting them.

OSHA attempted in 1998 to get companies in its Voluntary Protection Program (VPP) - a Reagan era program that rewards employers with good safety records by exempting them from unannounced programmed OSHA inspections - to stop using safety incentive programs that offer prizes to workers when they don't report injuries. A majority of VPP companies have implemented these types of safety incentive programs, which critics believe calls into question what their "exemplary safety" and low injury statistics actually mean.

OSHA's "Draft Policy on Employee Incentive Programs at Voluntary Protection Program sites" barred the use of safety incentive prize programs in VPP companies.

The VPP Participants Association (VPPPA), a non-profit organization comprised of VPP firms, greeted the draft policy with harsh criticism. In an August 1998 letter to OSHA chief Charles Jeffress, Lee Anne Elliott, executive director of VPPPA, accused OSHA of "unfairly target[ing] the nation's safety worksites," applying the policy "prematurely and incorrectly" and presuming "that a VPP facility's incentive program results in underreporting." In response to VPPPA's outcry, OSHA withdrew the draft incentive program policy in September 1998.

Later that year, OSHA released the results of a literature review it had conducted on safety incentive games. The report, released in November 1998, concluded that safety incentive programs that "focus on reduction in the number of injuries and illnesses do not improve safety practices," and that "incentive programs relying on material rewards have little or no lasting effect on safe work practices." No empirical research exists to verify claims that safety incentive games improve safety, the OSHA report found. Further, the report noted the concerns that programs "providing rewards for fewer injuries chills employee reporting of injuries rather than improving workplace safety and reduces the reliability of the data on injury logs." With this report completed, OSHA could have pursued its original course of action, banning safety incentive games in its VPP sites. It did not.

Meanwhile, behavior-based safety consultants are seeking to align with VPP companies. In recent years, several national conferences, some sponsored by behavioral safety consultants and some by the VPPPA, have offered workshops with titles such as "Alignment of the VPP and Behavioral Safety." Every year, the VPPPA holds a conference for all VPP companies, and invites companies and organizations to help sponsor the conference and exhibit their wares at a "safety exhibition." The number of behavior-based safety consultants and companies filling these roles has steadily increased over the last few years. Workers in one facility were told by VPPPA members that they would be required to implement a behavior-based safety program if their plant was to become part of VPP.

Behavior-based safety consultants have also managed to win some backing from the National Institute of Occupational Safety and Health (NIOSH). NIOSH has awarded research grants, studying the impacts of behavior-based safety, to the very consultants who market and sell behavior-based safety programs.

NIOSH has awarded at least two grants to behavioral safety consultant E. Scott Geller. Prior to being awarded NIOSH funds, Geller conducted research in the mid-1980s in which he reviewed the effects of 28 programs used by nine different companies to get their employees to use seat belts. The results of his research: programs that rewarded people for wearing their seat belts with cash or prizes were the least effective as compared with those that offered no reward, both in the short term and the long haul. "The greater impact of the no-reward perspective," Geller and his colleagues concluded, was "not predicted and [is] inconsistent with basic reinforcement theory."

But two years later, as Alfie Kohn reported in his book, Punished by Rewards, Geller declared in another journal that "incentive strategies have been particularly promising as a method of increasing safety belt use," and then cited the very research that documented the opposite.

But this did not discredit Geller in NIOSH's eyes. NIOSH issued him a two-year grant in the 1990s to study the critical success factors for behavior-based safety. Geller's research involved placing a questionnaire about behavior-based safety in a safety and health "trade magazine" to collect company health and safety official's experiences and opinions regarding behavioral safety.

Geller is a repeat presenter at NIOSH conferences - regardless of the stated focus of the conference. Last year, NIOSH and the American Psychological Association held a conference on "Work, Stress and Health." There appeared E. Scott Geller - or at least graduate students working for him. They presented a session on how to increase employees' ear-plug-wearing behavior, proper lifting technique behavior ... and seat-belt-wearing behavior, using behavior modification approaches.

Asked if they had sent industrial hygienists and engineers into the plant to establish if all practicable engineering controls had been installed first before embarking on the project to push ear plugs, the graduate students were unable to answer. OSHA's Hearing Conservation Standard requires employers to engineer out noise and to instruct employees to use ear plugs only when this is not feasible.

The Hazard of Behavioral Safety
The graduate students' inability to respond was not surprising. The blame-the-worker approach of behavior-based safety programs is incompatible with, and designed to represent an alternative to, efforts - including those mandated by law - to identify and eliminate or reduce the hazards responsible for the epidemic of worker injuries, illness and death. In a time of major work restructuring and speed up, critics say the focus on individuals at the expense of work environments makes behavior-based safety programs themselves a work hazard that must be eliminated.

James Frederick is an industrial hygienist with the United Steelworkers of America. Nancy Lessin is health and safety coordinator of the Massachusetts AFL-CIO.