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Oregon OSHA Online Course 100

Safety and Health Management Basics

 

This material is for training purposes only. Its purpose is to inform Oregon employers of best practices in occupational safety and health and general Oregon OSHA compliance requirements. This material is not a substitute for any provision of the Oregon Safety Employment Act or any standards issued by Oregon OSHA. For more information on this online course and other OR-OSHA online training, visit the Online Course Catalog.

MODULE TWO: ACCOUNTABILITY

Note: The subject of this module is extremely important to the success of any safety program, so we spend more time on it. Be sure to give yourself adequate time to complete the module to you won't have to rush.

Accountability from the employer to employee



Accountability ranks right at the top with management commitment as a critical ingredient in a company's safety and health management system. In fact, if employees don't believe they're going to be held accountable (experience consequences) for the decisions they make related to safety, you can be sure that any safety effort is ultimately doomed to failure. Generally, when OR-OSHA compliance officers ask you about "accountability," they want to know if you're enforcing safety rules using some sort of disciplinary system. So, that's the direction we're headed.

Note: It's important to understand that OR-OSHA rules do not require any specific or standard disciplinary process or procedure. The design and implementation of an accountability system is left to the employer.

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 OR-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; subject to giving an account (or explanation), answerable. Accountability - able to give account or answer to.

If you examine these two definitions, it's understandable why we might conclude these two terms have virtually the same meaning. However, when applying them as management concepts in the workplace setting, they take on very important and distinct differences in meaning and application.

  • Responsibility may be thought of as the "obligation to fulfill a task."

     

  • Accountability may be thought of as the "obligation to fulfill a task...or else."

To be responsible, you need only be assigned a duty by someone in authority. On the other hand, when you are held accountable, the assigned performance in fulfilling a duty is measured against some specific criteria that results in certain positive or negative consequences.



Elements of an Effective Accountability System

The following six critical elements should be present in any employer accountability system:

Element 1. Established Formal Standards of Performance

OR-OSHA has developed rules in occupational safety and health which serve as standards of performance for Oregon employers. Similarly, employers are required to establish company policies, plans, procedures, job descriptions and rules that clearly convey standards of performance in safety and health to employees.

It is important to understand that if progressive discipline policies and procedures are used, they should be clearly stated in writing and made available to everyone. In fact, it is a good idea to have all employees read and sign a statement that they read, understand, and will comply with safety procedures 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. Since the system, itself is flawed, justification for discipline may be in doubt.

Element 2. Resources to Meet the Standards of Performance

To be justified in administering discipline, management should first fulfill the obligation to provide 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. Ensure safe and healthful conditions. Safe tools, equipment, machinery, materials, chemicals, 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.

Element 3. A Process of Evaluation

When applied to safety performance, accountability demands much more than simply being answerable. When employees are held accountable for meeting safety standards set by the company, the quality of their safety performance should be measured some way. Evaluation strategies include:
  • Informal daily observations. Through observation, supervisors may provide feedback on safe behavior.

  • Periodic formal evaluations. Supervisors keep track of employee safety performance, writes an appraisal and conducts a review with the employee.

It's important that behaviors, rather than results, be evaluated. When behaviors somehow impress the employer, recognition is certainly appropriate. However, when employees violate safety rules and discipline is justified, then discipline is appropriate. If employees believe they will be disciplined for having an accident (a result), they are less likely to report incidents or accidents.

Bottom line - don't discipline employees for having an accident (a result). Discipline employees, when justified, for non-compliance (a behavior). The accident, itself, is irrelevant to the discipline process. When an employee has an accident, he or she suffers natural consequences. Discipline is a form of system consequence and should address only behaviors.
Discipline for substandard behavior, not for getting hurt!

Element 4. Effective Consequences

Without an expectation of effective consequences, accountability is not believable and has no credibility. 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 many companies, consequences are either not appropriate and/or effective.

Effective consequences increase desired behaviors. Effective consequences have the effect of increasing the frequency of desired 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 three strategies to consider.

Three Types of Consequences

Positive reinforcement - If we do something well, we get rewarded.
  • When effective, increases desired behavior.
  • Worker performs to receive a positive consequence
  • Worker may perform far beyond minimum standards - discretionary effort
  • Focus is on excellence - success based motivation
  • “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.
  • Intent is to increase desired behavior. Can be successful when only looking for compliance.
  • Worker performs to avoid the consequence
  • Worker performs to minimum standard - just enough to get by
  • Focus is on compliance - fear based motivation
  • “If you comply with safety rules, you won't be punished.”

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 (after evaluation validates justification), certain, significant, and sincere. When consequences are inappropriate and/or ineffective, accountability is not functioning properly in your company.

Consequences for safe 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 a person has authority...decision-making control, then he or she 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 rates, and workers compensation costs.

This situation may place enormous pressure on top managers to pressure supervisors to hold down the number of accidents in their departments. The emphasis is placed on achieving "zero accidents" rather than "total compliance." Consequently, the result may be ineffective evaluation of results at all levels. To be most effective, appropriate behaviors and activities to evaluate at top/mid-level involvement 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 are not capable of actually controlling the number of accidents in their workarea. However, they do have the ability to control their safety management and leadership activities. Therefore, measurement at this level should 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. Focus on measuring activities rather than outcomes. 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.

Element 5. Appropriate Application of Consequences

What are the criteria for appropriate consequences?
  • First and foremost, consequences are justified.
  • Consequences correspond to the severity of the infraction or violation.
  • Consequences progress in significance.
  • Consequences are applied consistently throughout the entire organization.
Are consequences justified?

Negative consequences are justified only when the safety management system has not failed the employee. In other words, when management fulfilled all of their obligations to employees.
Take the Five-Finger Test: Ask these important questions to determine justification

Before administering discipline, managers and supervisors need to evaluate their own performance and make a judgment about how well they have fulfilled their obligations to employees. We can categorize them into five general obligations: Leadership, resources, training, supervision, and enforcement. To determine if discipline is justified, ask these very important questions:
  1. Have I provided (or has the employee received) adequate safety training? The employee has the required knowledge and skills to comply. The employee understands the natural and system consequences of noncompliance.


  2. Have I provided adequate resources that ensure a safe and health workplace? Do they have the physical resources and psychosocial support that gives them the ability to comply?


  3. Do I fairly and consistently enforce safety policies and rules? Does the employee know that I will follow through with discipline? Or, do they know that all you will do is issue a threat, "If I catch you doing that again, I'll...." Remember, a supportive safety culture insists on, not merely encourages, safe behaviors.


  4. Have I provided adequate safety supervision? I'm not stuck in my office all day...I'm overseeing their work regularly or delegating that responsibility to someone. Adequate supervision is defined as the ability to detect and correct unsafe behaviors and hazardous conditions before they cause an injury or illness.


  5. Have I demonstrated adequate leadership by complying with all safety policies and rules? Do I set a good example?

If a manager or supervisor can honestly answer yes to each of the above five questions, he or she is likely justified in administering discipline. If a manager cannot honestly answer each question in the affirmative, integrity might more likely require an apology along with a commitment to make improvements.

Do consequences correspond with the severity of the infraction?

  • 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 significant consequence such as suspension or termination. On the other hand, an employee who violates a safety rule that could only result in a minor injury, a lesser consequence, such as a verbal warning, is more likely appropriate.

  • Consequences should increase with the level of responsibility of the person performing the behavior. If an employee neglects to wear personal protective equipment, discipline may be in order. However, if a supervisor or manager neglects to wear the personal protective equipment, a more significant level of discipline may be appropriate. Why? Due to the fact the manager is legally an "an agent of the employer," the act of violating a safety rule has the effect of transforming a require rule into a voluntary guideline for employees. It effectively gives the employee the option to chose use/not use the PPE. The employer can't enforce guidelines, only mandatory policies and rules, so supervisor/manager non-compliance with safety rules might jeopardize the employer by increasing the likelihood of litigation should a serious injury or fatality occur.

Do consequences progress in significance?

  • If an employee continues to violate a particular safety rule, it's most effective if the resulting level of discipline progressively more significant. If a consequence does not change the behavior in the desired direction, the employee is likely perceiving the consequences as insignificant. If the behavior changes in the desired direction, the consequence has achieved significance.

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. It's important to remember that one should be held accountable only for that which he or she has control. With this in mind...

Do the right thing...Do the thing right

Most employers establish safety incentive programs to increase awareness and influence behaviors in a positive direction. However, some of those employers unknowingly reward their employees for withholding incident and accident reports. The employer's intent is to do the right thing, but the problem is that they're not doing the thing right.

Unfortunately, failing to report injuries immediately violates OSHA law and any policy that encourages or otherwise promotes delayed injury reporting will be carefully scrutinized.

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.

According to Oregon Administrative Rule 437, Division 1, Rule 760, 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 required by OSHA law, the employer is obligated to do what is reasonably necessary to require this behavior and nothing that promotes withholding injury reports. Consequences for failure to meet safety standards typically includes negative performance appraisals, some form of progressive discipline, or forfeiture of a tangible reward.

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

The bottom line.

For an accountability system to work effectively, managers, supervisors and employees should be evaluated only for those behaviors/activities over which they have the ability to control.

Element 6. Effective Evaluation of the Accountability System.

Although as a supervisor you may not be responsible for 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 Oregon, the safety committee is required by OAR 437 Div. 1 Rule 765 to conduct an evaluation of the employer's accountability system. It's important to assist in that effort if asked.

The process usually involves three levels of activity:
  • Identification. Inspect the accountability system policies, plans, processes, and procedures to identify what exists.

  • Analysis. Dissect and thoroughly study each accountability system policy, plan, process and procedure to understand what they look like. The devil is in the detail.

  • Evaluation. Compare and contrast each accountability system policy, plan, process and procedure 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.

Accountability System Evaluation Checklist.


An effective accountability system is required to ensure compliance with required employer safety standards. Here’s a simple checklist your safety committee can use to evaluate your organization’s accountability system. (0= Not present 3=Needs Improvement 5=Effective)

1. Formal standards and expectations. Before employees can be held accountable, management must design and communicate employee accountabilities.

  • Do clear safety policies, plans, processes, procedures, practices exist?
  • Are safety standards written in the primary language(s) of all employees?
  • Are safety policies and rules discussed with new employees at orientation?
  • Are reasons discussed for the importance of following safety rules and policies?
2. Resources to meet/exceed expectations. Before management can hold employees accountable, they must first fulfill their obligation to provide employees with the tools to perform safely.

Physical Resources
  • Are tools, equipment, machinery and materials adequate in ensuring a safe workplace?
  • Are workstations designed to be ergonomically appropriate for the assigned worker?
  • Is adequate Personal Protective Equipment provided to employees?
  • Are chemical, noise, atmospheric and other environmental safety hazards controlled?
Psychosocial Support
  • Is adequate initial safety orientation training being provided?
  • Is adequate safety training on specific safety procedures being provided?
  • Is management providing adequate safety leadership through example?
  • Are workloads reasonable? (Employee has ability to complete work without undue physical or psychological stress)
  • Are work shifts reasonable? (Does not produce excessive fatigue)
  • Is an Employee Assistance Program (EAP) available?
  • Do employees suffer any negative consequences from working safe?
  • Do positive working relationships exist between employees and supervisors?
3. A process of evaluation. It’s important that behaviors are measured and evaluated so that discipline is based on facts, not feelings.
  • Is a process of observation and feedback in place and carried out effectively?
  • Are compliance behaviors evaluated rather than results (such as getting injured)?
  • Do employees have control (authority) over behaviors/results being measured?
  • Are the results of observations being tracked to improve the safety management system?
  • Do formal appraisals/reviews index safety performance?
4. Effective consequences. Without effective consequences, improvement of behaviors and performance will not occur.
  • Is discipline for noncompliance expected?
  • Does discipline occur soon after justification is established?
  • Do employees know exactly why they are being disciplined (given the facts)?
  • Are the motives for disciplining perceived as sincere attempt to help, not hurt?
  • Do disciplinary procedures change behavior/performance in the desired direction?
  • Is discipline progressively more significant for repeated noncompliance?
  • Does management first make sure that their obligations to employees are have been fulfilled before disciplining? (clear expectations, resources, training, enforcement, example)
  • Does discipline occur as a result of failure to comply with safety policies and rules (behaviors) rather than “having an accident” (results)?
  • Are employees automatically disqualified from safety recognition/rewards if they have an accident?
  • Is discipline consistently applied throughout the organization - top to bottom and across functions?
  • Is the purpose of discipline to improve performance rather than merely to punish?
  • Is recognition occurring more often than discipline?
  • Is discipline appropriate to the severity of the infraction?
  • Is discipline appropriate to the negative impact the infraction has on the company?
5. Evaluation of the accountability system. This element is essential in continually improving the accountability system.
  • Is the safety committee evaluating the accountability system on a periodic/continuous schedule?
  • Are all processes within each of the accountability system elements evaluated?
  • Does the safety committee submit the evaluation results to management?
  • Does the safety committee develop and submit recommendations to improve the accountability system?
  • Does management respond to and implement safety committee recommendations?

Last Words. I want to recommend that one or more safety committee members continually analyze and evaluate the safety accountability system to ensure continuous improvement. If you'd like to receive more training on this topic, be sure to enroll in OR-OSHA Course 119. OK, time to complete the review quiz.

Let's Review


6. According to the text, accountability is defined as being able to give the right answers to any questions that might be asked:

a. True
b. False
7. One of your jobs, as a supervisor, is to make sure safety is considered when purchasing materials, equipment, and tools for your employees:
a. True
b. False
8. What is the test to determine if a consequence is effective?
a. If the employee quits.
b. The employee's behavior changes in the desired direction.
c. The employee is happy about the consequence.
d. The employee is sure the consequence was appropriate.
9. Which of the following supervisor self-evaluation questions is most likely to result in a "no" response when a supervisor discovers a new employee driving a forklift in a unsafe manner?
a. Have I provided adequate resources?
b. Have I provided adequate safety education and training?
c. Have I provided proper safety supervision?
d. Have I enforced safety rules in the past?
10. Supervisors should be held accountable only for what they can control. They have the ability to control all of the following, except:
a. The number of safety meetings conducted.
b. The number of accidents that occur.
c. The number of inspections conducted.
d. The number of training sessions conducted.
Answer the questions on the following review quiz. Here are the answers.

Congratulations on completing the second module!

Now that you have learned what accountability is all about within the context of workplace safety, let's continue on to the next module to learn more about employee involvement. If you have any questions or comments, just drop me an email.