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    July 22, 2022

    "How Do You Do That?" Blog Series- Part 7: Behavior Based Safety

    Question: What are some of the challenges observed when implementing a Behavior Based Safety program?

    This is an excellent question!

    Implementing any new safety program can come with challenges but Behavior Based Safety (BBS) programs seem to have more than their fair share of them, especially in environments where the safety culture is still maturing. To best answer this question, we’re going to talk about several of those challenges and what you can do to avoid them altogether.

    Challenge #1 – Undefined Goals

    When companies jump right into a BBS program without having defined goals, they end up turning an otherwise meaningful activity into busy work. Without knowing why you’re instituting the program and what you’d like to get out of it, you’re really just observing work without a real purpose. Sure, you might get a few good responses that provide an opportunity for small improvements but overall, you’re going to get inundated with data that is hard to do anything with. So, before you do anything else, decide what you want the program to do for you, and then create a few “SMART” goals. If you’re not familiar, SMART stands for: Specific, Measurable, Attainable, Relevant, and Timely. Creating SMART goals will also help keep your BBS program to a manageable size so that it doesn’t become overwhelming for everyone. To get started with SMART goals, we’ve created a simple template that will help walk you through the process.

    Challenge #2 – Collection Process

    Another challenge companies experience when getting a BBS program off the ground is the process they use to collect observations. The observation process should be simple and not take a lot of time to complete. However, what frequently happens is that a company will try to capture too much information during the observation process and it results in a tedious, lengthy task that becomes a target for pencil whipping. To avoid problems, we recommend doing a trial run with whatever form will be used and then asking the workforce for their input such as what they liked and didn’t like about it, what problems they encountered and how it could be made better or easier to complete. Then take their input and actually use it to make the collection process better. When workers feel like they’re part of the process and when they see their input and ideas being taken seriously, they’re much more inclined to actively participate. And if you think about it, they’re the ones who actually have to use the form so it makes a lot of sense to try and collaborate with them as much as possible.

    Along with the form itself, another part of the collection process that presents challenges is how and where a company chooses to input and store the observation information they collect. The typical collection method is to set up a spreadsheet and have someone manually enter the data from the observation forms. Entering data manually into a spreadsheet is a miserable, tedious task even when a company is very small and doesn’t collect a lot of observations. Not only is it time-consuming and generally unpleasant for the person tasked with data entry, but it can also be difficult to pull the data back out when it’s time to use it which is a big problem since the entire point is to use the data being collected.

    The alternative to using a paper form and manually entering the data into a spreadsheet is to find a software program that will tackle both things, like EHS Insight’s Work Observations module, which is designed specifically for BBS observations (and tracking reward and recognition programs) and can be used on any device without the need for an active network connection.

    Challenge #3 – Flimsy or Lacking Ground Rules

    When BBS programs are established, certain things like who will be conducting them and how many each person will have to complete are generally determined upfront. However, what’s often not ironed out during the creation phase are things like whether the observations will be anonymous, what workers should do when safety violations are encountered during an observation and whether disciplinary actions will be assigned when violations are observed. Not having these things clearly defined before rolling out the program and not communicating them properly will contribute to a lot of problems throughout the life of the program.


    Whether to keep the observations anonymous or not is going to be important to the people being observed, especially if the observed group only consists of hourly workers. From our perspective, the BBS observation process should always be as anonymous as possible because when workers feel like they’re under a microscope or that an observation “gone wrong” could land them in trouble, they won’t want to participate. Now, if the general concern with keeping things anonymous is that without including worker names in the observation it makes it easier to pencil whip or fabricate observations, that’s not really a problem with the observation—that’s a management issue (and it’s one that needs to be resolved without penalizing hourly workers in the process). If 100% anonymity isn’t possible, then consider including job titles, departments, shifts, teams, etc., because this will provide data points allowing you to identify problems in these places without singling out workers.

    Handling Safety Violations

    Another really important thing to hammer out well before a BBS program is implemented is not only how to handle safety violations when they’re observed but also whether disciplinary actions should be included. If we can offer any advice on this topic it’s to keep things non-punitive and to make sure it’s clearly understood that unsafe behaviors should never be allowed to continue once observed. If there is confusion about how to handle this situation, consider adding scenario-based examples that provide a few options for handling this situation if encountered.

    Additionally, we want to emphasize how important it is to keep this program non-punitive meaning, if a worker is observed doing something unsafe or that violates the safety rules, they won’t be disciplined for it. Having an open and meaningful dialog about this topic is incredibly important because it’s during this discussion that you’ll encounter two different camps of supervisors and managers—those who are keen on including disciplinary actions and those who aren’t.

    The Pro-Discipline Type:

    These are the supervisors and/or managers who think using disciplinary action (or the potential for it) will deter unsafe behavior. These are the supervisors and/or managers who also think counseling is a form of coaching and who ultimately create an environment where workers don’t feel comfortable asking questions or are terrified to ask for help. They will use the observation program as a means of issuing disciplinary actions and creating a list of “repeat offenders”.

    The Anti-Discipline Type:

    These are the conflict adverse supervisors and/or managers who are worried about not being liked and who will do anything to get out of having to discipline a worker, even when warranted. When safety violations or general unsafe behavior are noticed by this type of supervisor and/or manager, they will use the observation program as a way of getting out of issuing discipline by doing an observation “after the fact” because they know observations aren’t allowed to be punitive. Meaning, that if a worker violates a safety rule or does something unsafe, instead of issuing counseling to that worker, they will approach the worker and say something like “I’m not going to write you up. We’re going to consider this an observation.”

    Of course, there are many other types of supervisors and managers who aren’t in either camp but for the purpose of this article, we wanted to highlight these two types in particular because they will stand out the most and give the most impassioned arguments for why disciplinary actions should or shouldn’t be included. If you remember nothing else you’ve read in this article, remember this: Management issues have nothing to do with the BBS program—and this is absolutely a management issue.

    On a side note, we want to mention that when all of these things have been worked out and you’ve got a good set of ground rules to work off of, consider creating a formal written policy for your BBS program. If this sounds like a bit much, keep in mind that having a written policy gives it some authority, places it in the same arena as the rest of the safety policies, and gives everyone a place to go for direction when questions arise, which keeps everyone on the same page!

    Challenge #4 – Training

    The fourth and final challenge we’re going to talk about deals with training—but maybe not the training you’re thinking about. It should go without saying that everyone who has to participate in this program should be properly trained on the process itself, but there are two other really important types of training to consider adding.

    The first is training or coaching on more “soft skills” such as using the right approach and tone of voice, handling conflict, and how to provide constructive feedback. When a BBS program is unleashed without even a little bit of coaching on these things, big problems can ensue when workers feel picked on, talked down to, or intimidated by the process. Think about it for a second. Does anyone really like it when they’re approached by someone carrying a clipboard who never communicates why they’re there and who then proceeds to intently watch them while writing things down before abruptly leaving? We’re going to go out on a limb and say most people wouldn’t like this approach but more importantly, this approach will reduce the benefits you’re hoping to get out of implementing a BBS program because people won’t want to participate in this kind of environment.

    The second type of training to consider adding is additional training on your safe work practices and other required programs. You probably already do annual training on these things but we can almost guarantee that if you were to randomly ask employees (both hourly and salaried) about the proper way to perform certain tasks and activities, you’d find a lot of discrepancies and deviations from your written practices. This lack of a universal understanding of how things are to be performed causes a lot of problems within a BBS program and can result in faulty data being collected. For example, in order to conduct an observation on a worker who is inspecting their forklift for the day, the person observing first has to know the proper procedure for inspecting a forklift. If they don’t, how can they be sure the worker is following the right procedures or identify potential unsafe behaviors if they aren’t? The simple answer is that they can’t and what you’ll end up with are a lot of missed opportunities that will turn into incidents, and when that happens, the first thing that will be questioned is why the BBS program isn’t helping the way it was advertised.

    The best way to avoid this rather large issue (and to improve overall program knowledge in the process) is to break the BBS program up into four quarters and provide a list of tasks and other procedures that can be observed during each quarter. For each task or procedure on the list, make sure there is an up-to-date Standard Operating Procedure (SOP), Job Safety Analysis (JSA), or even a simple Safe Work Practice (SWP) and require these things to be used during the observation process. What this does is it allows the observation to be conducted based on the right information, improves everyone’s knowledge of the company-approved ways of performing tasks, and ensures when coaching is given during an observation, the right information is passed along to workers. In return, this helps ensure that the data being collected is good, usable data that will help pinpoint true gaps and areas for improvement. If this seems like a lot of work to manage, it doesn’t have to be with the right tools, like EHS Insight’s Job Safety Analysis module.

    Final Thoughts

    Hopefully, with the information we’ve provided in this article, you have a better understanding of some of the challenges you might encounter when implementing a BBS program and maybe a few ways of avoiding these challenges. When done well, BBS programs are well worth the effort and can go a very long way towards helping improve your overall safety culture. Good luck!

    Katy Lyden, MS, OHST

    Katy Lyden is a EHS Domain Analyst and Subject Matter Expert for StarTex Software, the company behind EHS Insight. Prior to her current role, Katy spent 17 years successfully leading EHS programs for several large companies within the manufacturing industry. Katy is a Navy veteran, Licensed Emergency Medical...