Behavior Based Safety (BBS) programs have developed a cult following in the safety industry even though studies from objective sources like the Ham Commission and the ASSE cast doubt on their theoretical premise that workplace accidents and injuries are caused primarily by unsafe behavior. I’d like to discuss what I believe to be a theoretically sounder method of hazard control: the "Hierarchy of Controls."

Accidents Are Caused By Systems, Not Just Behaviors

The late Dan Petersen and his supporters are among the most perceptive critics of BBS. According to Petersen, accidents are the product not just of behavior but environments. Behavior is one element of the environment. But so are conditions and, ultimately, systems. As Petersen explains, “behind every unsafe condition, there is a management system that could have allowed that hazard to exist.” People behave the way they do for a reason, says Petersen. To the extent people engage in unsafe behavior, the explanation lies in some aspect of the management system—the way people are measured and rewarded, the culture of the organization—that suggests that behaving unsafely is acceptable.

By focusing on unsafe behaviors, Petersen notes, safety managers end up dealing with accidents on a symptomatic rather than causal level. Managers have to look at the causes of accidents as being "a combination of a management system and a culture or environment that leads to human error." Only then can effective hazard management controls be forged.

The Hierarchy of Controls Method

It is for this reason that management controls work better than BBS methods in controlling hazards. One of the best management control methods is called the Hierarchy of Controls (HOC). The HOC model should be an integral part of any structured and formalized or integrated safety management system. In fact, management systems and the focus they provide are the perfect compliment to the HOC model.

The HOC began in 1950, when the National Safety Council began to enunciate the principle of establishing an order of preferences for selecting controls to minimize hazards. At the top of the “hierarchy” are controls that use design and engineering solutions to eliminate hazards. At the base of the hierarchy are solutions that leave the hazard in place but use simpler administrative and work measures like warnings, training, safety procedures and personal protective equipment to control it. Section 5.1.1 of the ANSI/AIHA Z10-2005 outlines the Standard’s requirements for the use of the HOC model:

Hierarchy of Control: The organization shall implement and maintain a process for achieving feasible risk reduction based upon the following preferred order of controls:

1. Elimination;
2. Substitution of less hazardous materials, processes, operations or equipment;
3. Engineering controls;
4. Warnings;
5. Administrative control; and
6. PPE.

Feasible application of this hierarchy of controls shall take into account:

1. the nature and extent of the risks being controlled;
2. the degree of risk reduction desired;
3. the requirements of applicable local, federal and state statutes, standards and regulations;
4. recognized best practices in
5. available technology;
6. cost-effectiveness; and
7. internal organization standards.

(Source: http://www.asse.org/practicespecialties/docs/Z10SpecialIssue.pdf) The fact that the Z10 standard formalizes and gives credence to the HOC model is additional evidence of the importance of the management systems approach to any modern approach to safety.

Conclusion

The BBS school is a powerful lobby in our industry. But don’t be seduced by the literature and self-serving studies. Objective sources demonstrate that behavior is just one variable of accident causation. Stated differently, behavior is the product of the safety environment, not its determinant. To control accidents, you must control all aspects of the environment in which people work—engineering, procedural, training, equipment, etc. A hierarchy of controls that enables safety directors to select controls on a principled basis that accounts for resource constraints and all aspects of the environment is, I submit, superior to a system that uses a flawed theory to justify putting puts all of its eggs into one behavioral basket.

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