I always appreciate a good debate. That’s how we learn. We must challenge our beliefs on a regular basis otherwise we can not and will not move forward. I appreciate Wayne Pardy as a fellow Safety Professional and I respect his thoughts and conclusions, even if I disagree with some of them. To that end, let me respond to Wayne’s original argument and response to my rebuttal.

BBS ‘Cult’ v Hierarchy of Controls

I believe that Wayne’s original proposal was that the Hierarchy of Controls (HOC) is superior and that behavior based safety (BBS) is ineffective and “cult like.” I’m not sure exactly what Wayne means by “cult following,” but I don’t see any evidence in Wayne’s argument that such a thing exists. Nor have I come across this cult in my personal experience. For example, I travel a great deal and have never been accosted by any saffron-robed BBS converts chanting BBS hymns in airports. Nor have I heard of children being spirited away by BBS Messiahs.

HOC is superior. . . says who? Let me consider the evidence Wayne cites. First, we have the Ham Commission of 1976. I’m still unclear how a report issued by a group of guys over three decades ago has much relevance today. We have much more knowledge about human behavior than we did 34 years ago. I trust we will continue to learn how to use our knowledge of human behavior to make our workplaces healthier and safer. I certainly hope that in the year 2039 we aren’t quoting today’s articles as absolute truths. I also hope that three decades from now we’ll be much better at safety management than we are today.

Moreover, if you take the time to read the Ham report, you’ll see that few of the implemented recommendations have resulted in reductions in the injury rates in those countries following our “make OH&S laws” plan of hazard control. Early gains have not resulted in the continued “superior” results as Wayne suggests. Where is the evidence that these controls have worked? Statistically, over the past 30-35 years we have failed miserably to significantly change our safety outcomes.

Dan Petersen’s opinions and evidence in the area of OHSA law failure is well documented in his many texts. I’ll return to Dan later.

And then there’s Wayne’s contention that the ASSE report shows that BBS doesn’t work and HOC is somehow superior. But the ASSE doesn’t say that. In fact, it doesn’t reach any solid conclusion that managing human behavior is failing universally. What the report does say is that controlling physical hazards and behavior should receive equal time and effort. Specifically, the paper describes how some 200 workers (who probably had BBS done to them) failed to improve their safety behaviors. I suggest that this very limited study is about as conclusive as observing that pickles cause cancer because every one of the last 200 cancer patients once ate a pickle.

Dan Petersen Misunderstood

Wayne goes well beyond just quoting Dan but actually supports his own conclusions from Dan’s work. Dan Petersen’s well documented opinions of the failure of the Three E’s of Safety (Engineering, Education and Enforcement) clearly puts him in the camp of believing that both behavior and management systems are the key to safety excellence. His views of the failure of OSHA are clear and I trust his opinion of the Ham Commission’s recommendations would have followed the same path. OSHA laws have failed to get the results we wished for.

If the HOC was a superior key to Safety Excellence then Dan would have included it on his list of Six Criteria of Safety Excellence:

• Forced Supervisory Performance
• Upper Management Support
• Active Middle Management Involvement
• High Level of Employee Involvement
• Program Flexibility
• Positive Perception Among Employees

He did not. So I believe that to use a Dan Petersen quote to support the argument that the HOC is superior to anything is a huge error. I invite all who read this to read any of Dan Petersen’s texts and find anything that suggests he supports the HOC as the secret to superior safety results.

Human Behavior CAN’T Fail

Wayne’s assumption that I know little about human behavior and BBS is incorrect. I’ve studied and taught safety practitioners about human behavior for many years. I trust that I have many of the same books in my library that Wayne has in his. I have discussed BBS personally with Dan Petersen and Aubrey C. Daniels. I’m positive that I can furnish as many internet links to articles supporting my position as Wayne can.

What is BBS? Rather than use a popular website’s definition, I’ll cite E. Scott Geller who coined the phrase: “Behavioral safety is an approach for analyzing what needs to be done to make safe behavior more probable and at-risk behavior less probable. Then, with BBS principles and procedures, line workers are empowered to help each other eliminate barriers to safe behavior and factors that motivate at-risk behavior.”

Do I think that BBS is perfect? Of course not. My rebuttal states that “human behavior” can’t fail—not that BBS can’t fail. To repeat what I said in the piece, my belief is that BBS can and always will fail when it’s done TO employees. I suspect that this is why the workers observed in the ASSE report failed to improve.

Conclusion

At the end of the day, who gets the better of the debate between Wayne and me is far less important than the question of what’s the best way to prevent accidents and injuries. If, as Wayne asserts, HOC were the superior system, it would have worked by now. I also think that if—and it’s a big “if”—BBS is effectively applied, it produces real results. My belief is that to ensure safety, we need both the management systems stressed by HOC and a superior understanding of how the human beings we’re counting on to implement and follow those systems behave. On these points, I assure you, I am not wrong.

Wayne, feel free to quote me on that.

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