Rockfordgreeneinternational's Blog

Changing the World, One Company at a Time

Why I Continue to Criticize Behavior Based Safety

with 5 comments

Much has been made of my criticisms of Behavior Based Safety.  For some, my questioning of BBS is essentially a personal affront.  Others accuse me of offering criticisms without providing viable alternatives. For the record, I don’t feel I have to offer any alternatives—and yes, I am publicly saying that if you knowing sell, promote or advocate a systems (safety or otherwise) that you know doesn’t work or that costs more than it will ever recoup, you are a conman, a thief, and yes a snake oil salesman and you know how you are so spare me your false indignation.

Despite all the hoopla about my criticisms of BBS and my repeated requests to those who would shout me down as charlaton who knows nothing of BBS to define the quintessential elements of a BBS program no one has responded.  There seems to be little consensus on the definition of BBS. So either people are selling something that they can’t define, or they are too fearful that another pretentious gas bags will decry them as heretics.

So deafening was the silence that I was forced to turn to the most dubious of sources: Wikipedia. It’s easy enough to dismiss Wikipedia as a useless source, but given the article is so blindly pro-BBS and virtually anyone can change the entry, I have to assume that the advocates would have turn into me with the same petty snappishness with which they have lit into me. According to Wikipedia a good BBS process contains four elements:

  • Observation at site.  This practice can be boiled down to openly and honestly watching the worker and providing feedback on the safety with which the worker has performed the required tasks.  There are some obvious flaws associated with Behavior Observations. First, the success of the process assumes that the work performed during the observation is generally representative of the work as it is typically performed.  In other words, it assumes that the worker will perform the task while he or she is being observed in much the same way he or she would when unobserved.  This assumption is made despite reams of research that shows that any observation will change the behavior of that which is being observed.  It also ignores the Hawthorne Effect, which is the tendency for things to improve simply because there is an intervention of any stripe simply because the subjects know they are being watched.  The improvement is not permanent, however, so little or no benefits are derived from this short-term improvement.
    Secondly, even if the observer were to observe an unadulterated, and fairly representative performance of a task, it is fraught with problems.  Process variability and variability in human behavior means that for the observer to glean statistically valid information about the job the observer would have to devote considerable time to the observation and watch tasks being performed over and over again. This commitment just isn’t practical.  If we assume that a typical supervisor has 10 direct reports and does one observation a week, and said observation lasts 10 minutes we have a very small sample with which to work, a sample so small that any inference would be invalid—even if the process is in control. If the process is out of control and is not reliable than any observations are isolated events from which no meaningful inference can be drawn.
    Many organizations employing a BBS system expect a supervisor to do more than 10% observation rate and that in itself because problematic. Supervisors are increasingly scarce and are expected to do more and more with less resources. The pressure to conduct observations that consume resources while producing little in tangible results when supervisors are evaluated and compensated according to their productivity is far more likely to provide and incentive to complete the observation quickly instead of completing fewer, high-quality observations.
    Workers who are being observed understandably feel judged by supervisors and so BBS encourages supervisors to begin the feedback by focusing on the positive behaviors before turning to the areas requiring improvement.  But what BBS advocates tend to ignore is that supervisors will require substantial interpersonal skills to provide accurate and timely feedback.  BBS assumes a good faith effort by over taxed supervisors, and it further assumes a fairly mature training and performance appraisal system that provides and reinforces feedback skills. Certainly, these skills are important in the success of any supervisor but in my experience organizations where first line supervisors universally have mastered and routinely apply these skills are exceedingly rare.  This a foundation that is critical to the success of BBS and one seldom identified before the sale.
    Instead of requiring supervisors to observe an individual in isolation, supervisors should be encouraged to conduct layered process audits where the principle objective is to assess the overall effectiveness of  the department and to identify, contain, and correct the hazards that cause injuries.  It should not matter if the hazard is behavioral, procedural, or systemic. In fact, the walk thru need not be limited to safety—hazards often place more than workers in jeopardy.  A single hazard could threaten safety, quality, delivery, morale, profitability, and the environment.  Why burden supervisors with the requirement to laboriously observe workers one at a time when a more holistic approach would take far less time and yield much more substantial results.  When I say there is a better way, it is to this to which I am referring.
  • Data gathering and preliminary reports. This element of BBS really is no different than any other approach.  Except that BBS relies on the information gathered in the observations.  While there is nothing explicit in BBS that would forbid including Total Productive Maintenance (TPM), 5S Tours, Process Layered Audits, Job Safety Analysis, or ergonomic data in this activity, I would submit that doing so muddies the water to such an extent those doing so are no longer following a strict BBS discipline.
  • Report analysis and recommendation. Again, there is very little difference in this element of BBS than an element of any responsible approach to worker safety.  Unfortunately there is the GIGO phenomena which pertains to everything from accounting to databases.  GIGO stands for Garbage In Garbage Out and in the case of BBS GIGO means that if the information is flawed in what, where, when, and how it is collected than it is not likely to result in useful results.
    Let’s assume, though, that behavior observations produce perfect snapshots of workers doing performing there jobs.  Unless a process is under control, and by this I mean in the statistical sense, any inferences made based on this data is specious.
    But beyond the efficacy of the information, there is even more problems.  One principle problem is the whole concept of “recommendation”  BBS is a safety-professionalcentric process.  Safety professionals craft recommendations instead of a committee lead and staffed by Operations professionals who can make decisions and effect real changes in the workplace.

The Wikipedia article fails to identify several philosophic and procedural commonalities of many BBS initiatives that I believe should be addressed:

  • Recognition and Rewards for a Lack of Injuries.  Most BBS programs have at least some program that recognizes a good safety record and rewards workers for not getting injured.  This element of BBS is dangerous and destructive.  Far from achieving its stated goal of rewarding safety, it instead rewards people for not reporting injuries and near misses.  Instead of having Safety BINGOs and bonus for days worked without injury employers should reward participation in making the workplace safer.  Most companies have some sort of suggestion program and should divert the resources currently expended on safety incentives to incentives for making suggestions that make the workplace safer. Workers who are injured often become pariahs and outcasts because they deprive the other workers of the reward.
  • A Belief That Most Injuries are Caused by Intentional Unsafe Behaviors and At Risk Activities.  Nobody wants to get hurt and our business processes are not intended to hurt people so no amount of behavior modification will change these things.  Further, there are many types of hazards that may cause injuries that have little or no cognitive behavioral element—poorly maintained equipment, low process reliability, ergonomically unsound practices, inappropriate workspace layout, ineffective training, human error and a host of other failure modes can cause injuries.  The belief that any of these causes, up to and including deliberate risk taking, can be universally said to be the single greatest threat to worker safety is either the height of arrogance or the height of stupidity.  Instead of building a process based on questionable 80-year old research organizations need to do systematic research on the causes of injuries in their work environments, pareto the causes, and bring their limited resources to bear on the causes most likely to pose the greatest threat.  Organizations need to understand where they are at risk and focus their attention on the things that will help them reduce their risks.

There are elements of BBS that can be very effective, but when we go into a problem assuming we already know the majority of the answers (in this case we assume that most injuries are caused by unsafe behaviors in most work environments) we are highly likely to inappropriately attack the problem with prefabricated solutions.  People who make money on a given methodology will always find ways to manipulate research to support an off the shelf solution when a custom-solution (perhaps a far cheaper and simpler one) will suffice.  We can’t continue to spend what we can’t defend. Does BBS get results? sure.  Are BBS results real? Sometimes.  Are they sustainable? Maybe. Even a broken clock is right twice a day.  But selling a solution without completely knowing my situation just because some insurance inspector in 1931 asked around the shop and the supervisors told him that most workers got hurt because they needed to be more careful is, again I say, snakeoil.

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5 Responses

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  1. Phil. Previous comments were suggested on successful BBS initiatives. You provided, again, a generalized response completely biased without consideration from others who have implemented success BBS programs recognized and supported by international unions.

    This was a further waste of time reading, as was your original rant.

    J

    December 18, 2011 at 12:47 pm

    • J: Then stop reading. I neither want nor need a readership that continues to whine that what I am describing doesn’t meet their esoteric definitions of BBS. (I couldn’t help but notice you offered no definition). I keep hearing that “many successful initiatives are supported by Unions”. I haven’t seen them. I do know that the U.S. Steelworkers, UAW, Teamsters, CIO-AFL, Unity, and other Unions have issued statements condemning them. Why don’t you people who praise these Utopian initiatives ever talk about that? (beyond to whine about lies and politics?) And as long as we are looking for specifics why doesn’t anyone ever mention the Unions involved? And as you sit and sulk about what I’ve written please be mindful that: a) I can only speak from my own experience. I have not been party to these situations where Unions support BBS. For me to speak to them would be irresponsible. B) I can provide 4 specific examples where companies that were heavily invested in BBS resulted in fatalities that in my opinion would not have happened in a more balanced system. How graphic would you like me to be? should I have published a photo of the blood stained “remember to work safe” poster that hung a few feet from where a man was crushed to death? Or a graphic account of the incident investigation where a safety engineer was killed by a crane? Seriously how specific do you need me to be? C) This is a blog, I have no interest in or responsibility for, including every half-baked opinion for someone who wants to defend BBS as “way cool”. I think the LinkedIn Group BBS does a sufficient job of propagandizing the benefits, you want to hear you’re doing a swell job go there and sit and congratulate each other for being smarter than the rest of us. But PLEASE stop reading my work, you will never be anything but offended by opinions other than your own.

      Keep doing what your doing, and when someone finally dies on your watch, don’t say you didn’t know or that there was no way for you to predict it. The blood will on your hands.

      rockfordgreeneinternational

      December 18, 2011 at 1:51 pm

  2. Phil. My point is the author’s perspective is far to jaded to the point where the subjective slandor is off putting. I’m all for opinions; however, when offering links to the blog you invite the sharp cricitism you’ve encountered before.

    You’re also assuming my philosophy and most others rely entirely on BBS and not a “balanced” approach towards ensuring safe working conditions, effective training, process safety, supervisor/manager accountabilities, etc. There’s a time and place for everything, including BBS approaches. I hope you eventually see that.

    Best regards and Merry Christmas.

    J

    December 19, 2011 at 9:35 am

    • J:
      I have been repeatedly shouted down by BBS proponents for a) not providing specifics (and I have repeatedly done so) b) not really understanding BBS (despite inviting numerous opportunities for ANYONE to identify the common elements of all BBS processes and having none offered) c) failing to recognize that BBS is but one tool in a vast array of blah blah blah. I have written extensively about the need for a blended approach, most recently in the Nov/Dec issue of Fabricating and Metalworking. But BBS can’t have it both ways; it can’t be the wonderful, science-based, cure all for worker safety AND be just one tool in a blended workplace. And before you react, read the piece I have written, (available at http://www.fabricatingandmetalworking.com/author/phil_la_duke/) and ask yourself if what you are advocating is really BBS or is it a holistic approach. Also, it’s the height of irresponsibility to build a process around a practice that in and of itself will not solve most of the injury causes. The fact that people keep jumping down my throat for criticizing BBS (admittedly in its purest form—but if people are adulterating it, why? Probably because in the purest form I am at very least mostly right in my criticism of BBS. I know that there’s a time and place for everything, including BBS approaches but it’s not in ALL or even MOST cases. This isn’t just my opinion, it is the conclusion (albeit indirectly) of research, most notably that conducted in response to the BP Texas City Oil Refinery explosion. But don’t take my word for it, let’s take a look at some common causes of worker injury and see how many would be best approached by BBS:

      Equipment failure: Not likely the fault of the worker using it and thus not likely to be positively effected by BBS. Although, a worker injury caused by this spoils the BINGO, at least, that is, if the injury is reported. A far better solution is a robust TPM program, not BBS.
      Poor Ergonomic Work Station Design Again, assuming the worker is completing the work as designed this is not likely to come to light via BBS. Sure, it might be uncovered in a Behavioral Observation, but only if the supervisor is trained to spot ergonomic issues; cares enough about the quality of the observation to include it in his assessment: accurately communicates to the safety committee; conveys sufficient urgency to sway the maintenance department to make the issue a priority; and follows up to ensure the issue is corrected. A far more effective approach is an improvement team or a Kaizen event.
      Nonstandard Work. Work that is not done according to a standard or that is a “one-off” represents significant risk and yet much of our jobs fall into this category. I am not talking about workers working outside an existing standards, but where no standard work exists. Reminding workers to be more careful will not effect this. But Job Hazard Analysis will.
      human error Human brain research conducting in U.S. Healthcare has shown that the average American (infer applicability to other nationalities at your own peril) makes five mistakes an hour, irrespective of attempts to intervene. Human error is not the result of carelessness or absentmindedness (according to the studies) but caused by a basic attribute of the human brain. Behavior modification and recognition and rewards will not change basic physiology and it will not make people safer.
      Recklessness and intentional At Risk Behavior Yes, BBS is ONE alternative for addressing this injury cause.
      Unintentional At Risk Behavior In cases where people are taking extreme risks without knowing it, BBS is inappropriate because we are dealing with an individual, not the system. A better solution is to look at ways in which a person could be better trained or improve ways to highlight the risk (poke yoke, andon systems, etc.)
      Failure to Protect My father died of mesothelioma. At the time he was working with asbestos the manufacturers of said substance knew that prolonged exposure to it would kill him. His employer did not. When his employer found out it provided protection to him; too late unfortunately. My father took every precaution once the risk was conveyed to him. To suggest that had he only followed the rules he might be alive today is deeply offensive to me. PPE is far less appropriate than removing the threat altogether.

      And it occurs to me that therein lies my deepest criticism of BBS. We know the Hierarchy of Controls holds that the most effective means to protect workers is to remove the hazard, and if that isn’t possible we substitute the hazard with something benign, and if that can’t be done we implement engineering controls, and when that is not feasible we implement administrative controls, and when those are ineffective we address behaviors, and finally we move to the least effective, PPE. But we don’t hear safety professionals extolling the virtues of an Elimination Based Safety, or a PPE Based Safety, or an Engineering Controls Based Safety. No. Because doing so would be silly. No one would ever build a whole business plan around selling something so simple-minded. Except behavior.

      Far too much has been made of Herbert Heinrich’s assertion that 86% of all injuries are caused by unsafe acts. A not-so-cottage, cottage industry has been built on that dubious percentage. I do know this: Heinrich’s work was largely anecdotal (he asked supervisors how and why people got hurt) and conducted on a limited scale. His inference that his work was universally applicable is as laughable as phrenology now, but people cling to it as dearly as any superstition. Is unsafe acts a problem in some workplaces, I would be willing to bet that it is. Can anyone, without further research say that any one risk factor (behavior included) takes precedence over the others? NO! I have worked with mining, aerospace, craft manufacturing, mass assembly, batch manufacturing, and healthcare and I am here to tell you, generalizing (a charge you’ve lobbed at me several times) about hazard types even within an industry is irresponsible, and yet BBS generalizes, sight unseen, across all industries. What, if not generalization, is BBS? It starts with the erroneous, or at best unproven contention that most injuries are caused by conscious decisions to act unsafely. That’s not being jaded, that’s calling it as I see it.

      I hope this clears things up

      Thank you for your Christmas wishes and please do the same.

      rockfordgreeneinternational

      December 19, 2011 at 2:22 pm

  3. Reblogged this on Phil La Duke's Blog and commented:
    So much of a stink has been raised about this, I thought I’d repost and stir the pot

    Phil La Duke

    December 27, 2011 at 9:49 am


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