Behavior-based bashing

Union officials tell NSC audience that these programs divert attention from hazards

Representatives from organized labor made their case against behavior-based safety programs at the National Safety Council’s Congress and Expo in San Diego, claiming such programs focus on workers rather than actual hazards in the workplace.

“We say all injuries and illnesses in the workplace are the result of exposure to hazards — no exceptions,” said Jim Howe, assistant director of the United Auto Workers health and safety department, at a congress session on Oct. 7.

Before at-risk behavior can exist, there must be a hazard, and that is where efforts at identification should be directed, not on how workers do things, Howe said.

“No respirator in the workplace is better than not having used asbestos at all in its construction,” he said.

Unions believe engineering design-phase decisions have a greater impact on workplace safety than those seeking to affect worker behavior. For organized labor, he said, the most important issue is a “hierarchy of controls” that includes the following, in order of priority:
• elimination or substitution of workplace hazards,
• engineering controls,
• warnings,
• training and procedures, and
• personal protective equipment.

Reversal of priorities
Advocates of behavior-based safety, Howe said, take these priorities and reverse them, putting personal protective equipment at the top of the list and the elimination of workplace hazards at the bottom.

“We say identify hazards; they say identify behaviors. We say evaluate risk; they look for ‘at-risk’ behaviors. We say apply a hierarchy of controls; they say modify behavior,” he said.

Howe said he did not mean to suggest that the actions of workers do not contribute to workplace injuries and illnesses, emphasizing that the entire process should be considered — from hazards to behaviors — when addressing safety.

For an example, he mentioned a recent effort at Ford Motor Company that mapped out pedestrian traffic flows at a particular plant.

“They found that people were walking around places where loading and unloading was going on,” he said. “They said, ‘We’ve got to approach facility layout differently,’ and they created segregated walkways.”

At the same time, he noted, Ford decided it also needed to work with the pedestrians and let them know that they did not have the right of way, as they do in public.

“It was a comprehensive approach and different than just telling people at the plant to watch where they walk and drive,” Howe said.

Ignoring the causes?
John Molovich, a health and safety specialist with the United Steelwork-ers of America, said behavior-based safety programs are growing in popularity without having a noticeable effect on the causes of workplace injuries and illnesses.

“Companies buy these programs and shy away from identifying and correcting unsafe conditions and the lack of proper workplace safety training,” he said.

Molovich provided examples from his work on behalf of the steelworkers. In one instance, a chemical burn case investigation revealed a workplace at which 150 dangerous chemicals were present.

“The company’s training program included a 15-minute video,” he said. “You can’t train someone by telling them that all chemicals are dangerous and that they should work safely when they’re around them.”

In another case, a woman lost her hand working at a machine for which there was no safety guard. The workstation did, however, have a sign posted warning of the potential dangers posed by the machine.

“The company report said that injury was due to an unsafe act,” he said.

Alleged underreporting
Molovich argued that behavior-based safety programs are fine where a worker’s right is protected to identify workplace hazards without fear of retaliation.

“Safety incentive programs that get everybody a Kentucky Fried Chicken two-piece dinner at the end of the month are having a chilling effect on the number of job injury and illnesses reports,” he said.

Investigating one injury claim, Molovich said he came across a worker who had not lost any work days, but had taken 12 vacation days so that the department’s accident report would meet a behavior-based safety program incentive at the company.

“At least six other injuries had not been reported,” he said, “and they were driven underground by intimidation or peer pressure.”

Molovich said he comes upon “case after case” in the steel industry where workers are penalized for reporting injuries or required to take a drug test upon doing so.

“We’re encouraging our local unions to file unfair labor practice charges in such cases,” he said.

This article appeared in the December 2002January 2003 issue of MRO Today magazine. Copyright 2003.

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