Kevin Ian Schmidt

Corrective Actions

It’s important to divide your recommended corrective actions into the categories below:

  1. Immediate or short-term corrective actions to eliminate or reduce the hazardous conditions and/or unsafe behaviors related to the accident.
  2. Long-term system improvements to create or revise existing safety policies, programs, plans, processes, procedures and practices identified as missing or inadequate in the investigation.


High Priority Strategies that Eliminate the Hazards

1. Elimination: Totally eliminate the hazard. Why is this control strategy our top priority and considered by OSHA to be most effective? This control strategy has the potential to completely remove the hazard. We’re somehow changing a thing/condition in the workplace. And as we all know…

No hazard, no exposure = no accident.

2. Substitution: Substitute the hazard with a less hazardous condition, process or method. Some basic examples are substituting a toxic chemical with a non-toxic chemical or replacing an old poorly-designed machine with a new model.

3. Engineering controls: See if any of the strategies below are used in your workplace.

  • Design: Example – Design a tool so that it reduces the likelihood of a strain or sprain.
  • Redesign: Example – Change the design of a machine so that dangerous moving parts or electrical circuits are out of reach.
  • Enclosure: Examples – Place a hood over a noisy printer. Place a machine guard around a dangerous moving part.

These are the first to parts of the Hierarchy of Controls


Recommend System Improvements

This episode of “Safe in 60 Seconds” InterAct Safety Solution shares some tips on incident investigation – sustainable corrective actions.

The surface causes for accidents actually represent the symptoms of underlying safety management system weaknesses. This cause-effect relationship is so important to understand that I’ll say it again: the behaviors and conditions that caused the accident are, themselves, usually the effects of deeper root causes. This is a fact.

Consequently, your first assumption, as an accident investigator, should be that root causes have contributed to an accident, and your job is to find them. Your first basic assumption should never be that an accident is simply the result of surface causes. Once in a while, you’ll find that an accident was solely the result of a “personal failure,” but that won’t be often: in fact, it will be rare in most organizations.

Learn more about Root Cause Analysis

Therefore, make every effort to improve safety management system components to ensure long term workplace safety in your company. As we learned in the last module, the most successful accident investigator is actually a systems analyst. Making safety management system improvements might include some of the following examples:

  • including “safety” in a mission statement;
  • improving safety policy so that it clearly establishes responsibility and accountability;
  • changing a work process so that checklists are used that include safety checks;
  • including hands-on practice as part of the safety training program;
  • revising purchasing policy to include safety considerations as well as cost; and
  • changing the safety inspection process to include all supervisors and employees.

Check Out: Incident Investigation: Top 10 Mistakes

Answer the following six questions to help develop and justify recommendations.

1. What exactly is the problem?

  • What are the specific hazardous conditions and unsafe work practices that caused the problem?
  • What are system components – the inadequate design or implementation of safety management programs, policies, plans, processes, procedures and general practices that allowed the conditions and behaviors to exist?

2. What is the history of the problem?

Have similar accidents occurred previously? If so, you should be able to claim that the probability for similar accidents is highly likely to occur.

  • What are previous direct and indirect costs for similar accidents?
  • How have similar accidents affected production and morale?
  • Describe how it has affected direct, budgeted or insured costs related to past injuries or illnesses.
  • How has it affected indirect, unbudgeted or uninsured costs related to loss of efficiency and/or productivity and employee morale?

3. What are the solutions that would correct the problem?

  • What are the specific engineering, administrative and PPE controls that, when applied, will eliminate or at least reduce exposure to the hazardous conditions?
  • What are the specific system improvements needed to ensure a long term fix?

4. Who is the decision-maker?

  • Who is the person who can approve, authorize, and act on the corrective measures?
  • What are the possible objections that he/she might have?
  • What are the arguments that will be most effective in overcoming objections?

5. Why is the decision-maker doing safety?

It’s important to know what is motivating the decision-maker. Is the decision-maker doing safety to fulfill one or more of the following imperatives?

  • Fulfill the legal obligation? You may need to emphasize possible penalties if corrections are not made. Common in a fear-driven culture.
  • Fulfill the fiscal obligation? You may want to emphasize the costs/benefits. Common in an achievement-driven culture.
  • Fulfill the social obligation? You may want to emphasize improved morale, public relations. Common in a humane corporate culture.

6. What will be the cost/benefits of corrective actions and system improvements?

  • What are the costs that might result if/when OSHA inspects? Answer this question to address the legal obligation your employer has.
  • What is the estimated investment required to take corrective action, and how does that contrast with the possible costs if corrective actions are not taken? Answer this question to address the fiscal obligation your employer has.
  • What is the “message” sent to the workforce and the community as a result of action or inaction? Answer this question to address the social obligation your employer has.


OSHA Employer Responsibilities

Your employer has many responsibilities or obligations detailed within the OSH Act and other standards. OSHA’s job is to protect employees, not necessarily employers. If there is a serious accident in the workplace, OSHA will investigate to determine if the employer did not adequately meet their obligations under the law. By doing so, OSHA’s ultimate goal is to protect you, the employee.

With this in mind, your employer must meet the following obligations to employees:

  • Provide a workplace free from recognized hazards and comply with OSHA standards.
  • Provide training required by OSHA standards.
  • Keep records of injuries and illnesses.
    • Set up a reporting system.
    • Provide copies of logs, upon request.
    • Post the annual summary.
    • Report within 8 hours any accident resulting in a fatality.
    • Report any work-related hospitalization, amputation or loss of an eye within 24 hours.
  • Provide medical exams when required by OSHA standards and provide workers access to their exposure and medical records.
  • Not discriminate against workers who exercise their rights under the Act (Section 11(c)).
  • Post OSHA citations and hazard correction notices.
  • Provide and pay for most PPE.

Employer OSHA General Responsibilities

Your employer must provide a workplace free from recognized hazards and comply with OSHA standards. Establishing a safe and healthful workplace requires every employer to make safety and health a core value. In general, OSHA requires employers to:

  • Maintain conditions and adopt practices reasonably necessary to protect you on the job. The first and best strategy is to control the hazard at its source. Engineering controls do this, unlike other controls that generally focus on the worker who is exposed to the hazard. The basic concept behind engineering controls is that, to the extent feasible, the work environment and the job itself should be designed to eliminate hazards or reduce exposure to hazards.
  • Be familiar with the standards that apply to their workplaces, and comply with these standards.
  • Ensure that you are provided with, and use, personal protective equipment (PPE), when needed. PPE is needed when exposure to hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices and other forms of administrative controls cannot provide sufficient additional protection. PPE may also be appropriate for controlling hazards while engineering and work practice controls are being installed, and
  • Comply with the OSHA’s General Duty Clause where no specific standards apply. The general duty clause, or Section 5(a)(1) of the Act requires each employer to “furnish a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.”
Check Out: How to Conduct a Job Hazard Analysis to identify PPE needs

Employers Must Provide PPE

OSHA requires that employers protect you from workplace hazards that can cause injury or illness. When engineering, work practice and administrative controls are not feasible or do not provide sufficient protection, employers must provide personal protective equipment (PPE) to you and ensure its use.

  • With few exceptions, OSHA requires employers to pay for personal protective equipment used to comply with OSHA standards.
  • Employers cannot require workers to provide their own PPE
  • The worker’s use of PPE they already own must be completely voluntary.
  • Even when a worker provides his or her own PPE, the employer must ensure that the equipment is adequate to protect the worker from hazards at the workplace.

Employers are not required to pay for some PPE in certain circumstances:

  • Non-specialty safety-toe protective footwear (including steel-toe shoes or boots) and non-specialty prescription safety eyewear provided that the employer permits such items to be worn off the job site. (OSHA based this decision on the fact that this type of equipment is very personal, is often used outside the workplace, and that it is taken by workers from jobsite to jobsite and employer to employer.)
  • Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots.
  • Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen
  • Items such as hair nets and gloves worn by food workers for consumer safety.
  • Lifting belts because their value in protecting the back is questionable.
  • When the employee has lost or intentionally damaged the PPE and it must be replaced.

Employers Must Provide Training

We already discussed your right to receive training from your employer on a variety of health and safety hazards and standards, such as chemical right to know, fall protection, confined spaces and personal protective equipment.

Many OSHA standards specifically require the employer to train workers in the safety and health aspects of their jobs. Other OSHA standards make it the employer’s responsibility to limit certain job assignments to those who are authorized, certified, competent, or qualified – meaning that they have had special previous training, in or out of the workplace as follows:

  • Authorized person – means a person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite.
  • Certified Person – is one who has passed stringent written and practical exams related to the work that he will perform. OSHA requires the organization providing the examinations be accredited.
  • Competent person – means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
  • Qualified person – means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

OSHA construction standards include a general training requirement, which states: “The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.” Additional general training requirements for construction include training for workers:

  • required to handle or use poisons, caustics, and other harmful substances;
  • who may be exposed to job sites where harmful plants or animals are present;
  • required to handle or use flammable liquids, gases, or toxic materials; or
  • required to enter into confined or enclosed spaces.
Check out: How to Put Together a Workplace Safety Training Workshop

Employers Must Keep Records of Injuries and Illnesses

Recordkeeping is an important part of an employer’s responsibilities. Keeping records allows OSHA to collect survey material, helps OSHA identify high-hazard industries, and informs you, the worker, about the injuries and illnesses in your workplace. About 1.5 million employers with more than 10 employees must keep records of work-related injuries and illnesses. Workplaces in certain low-hazard industries such as retail, education, finance, insurance, and real estate may be partially exempt from routine recordkeeping requirements.

For more information on updated exemptions see this OSHA Fact Sheet.

To meet OSHA reporting requirements, employers must do the following

  • Set up a reporting system.
  • Provide copies of logs, upon request.
  • Post the annual summary.
  • Report within 8 hours any accident resulting in a fatality.
  • Report all work-related hospitalizations, amputations, and loss of an eye within 24 hours.
Make sure your company representatives are well trained on reporting, training available here

I offer an OSHA recordability flowchart, which will help you identify which injuries to report.

Employers Must Post OSHA Citations and Hazard Correction Notices

An OSHA citation informs the employer and workers of the standards violated, the length of time set for correction, and proposed penalties resulting from an OSHA inspection.

Your employer must post a copy of each citation at or near places where the violations occurred for 3 days or until the violation is fixed (whichever is longer).

Employers also have to inform workers of what they have done to fix the violation, allow workers to examine and copy abatement documents sent to OSHA, and tag cited movable equipment to warn workers of the hazard.

Causal Tree Analysis Root Cause

An accident may be the result of many factors (simultaneous, interconnected, cross-linked events) that have interacted in some dynamic way. In an effective accident investigation, the investigator will conduct three levels of root cause analysis:

  • Injury analysis: At this level of analysis, we do not attempt to determine what caused the accident, but rather we focus on trying to determine how harmful energy transfer caused the injury. Remember, the outcome of the accident process is an injury.
  • Surface Cause Analysis: Here you determine the hazardous conditions and unsafe behaviors described in the sequence of events that dynamically interact to produce the accident. The hazardous conditions and unsafe behaviors uncovered are the surface causes for the accident and give clues that point to possible system weaknesses.
  • Root cause analysis: At this level, you’re analyzing the weaknesses in the safety management system that contributed to the accident. You can usually uncover weaknesses related to inadequate safety policies, programs, plans, processes, or procedures. Root causes always pre-exist surface causes and may function through poor component design to allow, promote, encourage, or even require systems that result in hazardous conditions and unsafe behaviors. This level of investigation is also called “common cause” analysis (in quality terms) because you’re identifying a system component that may contribute to common conditions and behaviors that exist or occur throughout the company.

Injury Analysis

It’s important to understand that all injuries to workers are caused by one thing: the harmful transfer of energy. Let’s take a look at some examples that illustrate this important principle.

  • If a harsh acid splashes on your face, you may suffer a chemical burn because your skin has been exposed to a chemical form of energy that destroys tissue. In this instance, the direct cause of the injury is a harmful chemical reaction. The related surface causes might be the acidic nature of the chemical (condition) and working without proper face protection (unsafe behavior).
  • If your workload is too strenuous, force requirements on your body may cause a muscle strain. Here, the direct cause of injury is a harmful level of kinetic energy (energy resulting from motion), causing injury to muscle tissue. A related surface cause of the accident might be fatigue (hazardous condition) or improper lifting techniques (unsafe behavior).

The important point to remember here is that the “direct cause” of the injury is not the same as the “surface cause” of the accident event.

  • The direct cause of injury is the harmful transfer of energy as a consequence of your exposure to that energy. The direct result of the harmful energy transfer is injury. The cause is the harmful transfer of energy. The effect is the injury.
  • The surface cause of the accident is the condition and behavior that interacts in a way that results in the harmful transfer of energy. The interaction of the condition and behavior is the cause. The effect is the harmful transfer of energy.

Harmful Forms of Energy

  1. ACOUSTIC ENERGY – Excessive noise and vibration.
  2. CHEMICAL ENERGY – Corrosive, toxic, flammable, or reactive substances. Involves a release of energy ranging from “not violent” to “explosive” and “capable of detonation.”
  3. ELECTRICAL ENERGY – Low voltage (below 440 volts) and high voltage (above 440 volts).
  4. KINETIC (IMPACT) ENERGY – Energy from “things in motion” and “impact,” and are associated with the collision of objects in relative motion to each other. Includes impact between moving objects, moving object against a stationary object, falling objects or persons, flying objects, and flying particles. Also involves movement resulting from hazards of high pressure pneumatic, hydraulic systems.
  5. MECHANICAL ENERGY – Cut, crush, bend, shear, pinch, wrap, pull, and puncture. Such hazards are associated with components that move in circular, transverse (single direction), or reciprocating motion.
  6. POTENTIAL (STORED) ENERGY – Involves “stored energy.” Includes objects that are under pressure, tension, or compression; or objects that attract or repulse one another. Susceptible to sudden unexpected movement. Includes gravity – potential falling objects, potential falls of persons. Includes forces transferred biomechanically to the human body during lifting.
  7. RADIANT ENERGY – Relatively short wavelength energy forms within the electromagnetic spectrum. Includes infra-red, visible, microwave, ultra-violet, x-ray, and ionizing radiation.
  8. THERMAL ENERGY – Excessive heat, extreme cold, sources of flame ignition, flame propagation, and heat related explosions.

What are Surface Causes?

The surface causes of accidents are those hazardous conditions and unsafe or inappropriate behaviors within the sequence of events that have directly caused or contributed in some way to the accident.

Hazardous Conditions

  • Are unique things or objects that are somehow defective or unsafe
  • Are “states of being” such as employee fatigue
  • May also be unique defects in processes, procedures or practices
  • May exist at any level of the organization
  • Are the result of deeper root causes

Hazardous conditions may exist in any of the categories below.

  • Materials
  • Machinery
  • Equipment
  • Tools
  • Chemicals
  • Environment
  • Workstations
  • Facilities
  • People
  • Workload


Unsafe or Inappropriate Behaviors

It’s important to know that most hazardous conditions in the workplace are the result of the unsafe or inappropriate behaviors that produced them.

  • Actions we take or don’t take that increase risk of injury or illness
  • May also be thought to be unique performance errors in a process, procedure or practice
  • May exist at any level of the organization
  • Are the result of deeper root causes

Below are some examples of unsafe or inappropriate employee/manager behaviors.

  • Failing to comply with rules
  • Using unsafe methods
  • Taking shortcuts
  • Horseplay
  • Failing to report injuries
  • Failing to report hazards
  • Allowing unsafe behaviors
  • Failing to train
  • Failing to supervise
  • Failing to correct
  • Scheduling too much work
  • Ignoring worker stress


System Analysis

Let’s take a look at analyzing the surface causes to determine possible safety management system weaknesses. There are many “general” conditions and behaviors (variables) inherent in the safety management system. Oh yes… to me the safety management system is “organic”. By that I mean it is dynamic, ever-changing and behaves as though it were alive. Think about it. If that’s a little too metaphysical for you… read on.

The root cause for an incident is the underlying safety management system weaknesses, which consist of thousands of variables, any number of which can somehow contribute to the surface causes of accidents. These weaknesses can take two forms.

  • System Design Root Causes: Inadequate design of one or more components of the safety management system. The design of safety management system policies, plans, programs, processes, procedures and practices (remember this as the 6-P’s) is very important to make sure appropriate conditions, activities, behaviors, and practices occur consistently throughout the workplace. Ultimately, most surface causes will lead to system design flaws.
  • System Implementation Root Causes: Inadequate implementation of one or more components of the safety management system. After each safety management system component is designed, it must be effectively implemented. You may design an effective safety plan, yet suffer failure because it wasn’t implemented properly. If you effectively implement a poorly written safety plan, you’ll get the same results. In either instance, you’ll eventually need to improve one or more policies, plans, programs, processes, procedures or practices.

Effective Recommendations

An accident investigation is generally thought to be a “reactive” safety process because it is initiated only after an accident has occurred. However, if we propose recommendations that include effective immediate corrective actions and system improvements, we may transform the investigation into a valuable “proactive” process that helps to prevent future injuries. In this module we’ll explore tips and tactics for making effective recommendations that “sell” safety improvements.

Once you have developed engineering and administrative controls to eliminate or reduce injuries, the challenge becomes convincing management to make changes. Management will most likely understand the importance of taking corrective action and readily agree to your ideas. However, if management doesn’t quite understand the benefits, success becomes less likely. Your ability to present effective recommendations becomes all that more important. This module will help you learn how to put together “an offer they can’t refuse,” by emphasizing the long-term bottom-line benefits of the corrective action you are recommending.


Download and view the Causal Tree Analysis Root Cause Training below




Behavior Based Safety Programs: A Comprehensive Guide

n the realm of workplace safety, Behavior-Based Safety (BBS) programs stand out as powerful tools for preventing incidents and fostering a culture of continuous improvement. While many organizations have implemented BBS, there’s always room for enhancement to ensure its sustained success. But even the most well-intentioned BBS initiatives can benefit from a tune-up. This comprehensive guide explores strategies and best practices to elevate your BBS program, turning it into a robust framework that not only identifies unsafe behaviors but actively promotes a safer workplace

Understanding the Core Principles of Behavior-Based Safety:

To improve any BBS program, it’s crucial to grasp its fundamental principles. BBS focuses on observing and addressing at-risk behaviors by engaging the workforce and fostering a collective commitment to safety. Recognizing these core tenets sets the stage for effective enhancements.

Sure, your BBS program might excel at pinpointing unsafe actions. But the true ascent lies in transitioning from observers to motivators. Here’s how:

  • Focus on the positive: Shine a light on safe behaviors just as much as you address the unsafe ones. Acknowledge and celebrate positive choices – they’re the stepping stones to lasting change. Foster an environment where safety is not just a rule but a shared value.
  • Embrace feedback loops: Open communication is your oxygen. Encourage employees to report not just safety hazards, but suggestions for improvement. Listen actively, address concerns promptly, and demonstrate that their voices matter.
  • Involve everyone, everywhere: BBS isn’t a solo climb – it’s a team expedition. Engage all levels of your organization, from front-line workers to top management, in shaping and implementing safety initiatives. Ownership breeds commitment.
  1. *Responses to unsuccessful Behavior Based Safety Program survey

Building a Culture of Shared Responsibility:

A successful BBS program isn’t just about rules and checklists; it’s about fostering a collective sense of responsibility for safety. Here’s how to build that foundation:

  • Lead by example: Actions speak louder than words. Leaders must actively embody safe behaviors, demonstrating their unwavering commitment to creating a safer workplace.
  • Empower employees: Equip your team with the knowledge and resources they need to make informed safety decisions. Train them to identify hazards, intervene in unsafe situations, and champion safety practices.
  • Celebrate milestones: Take the time to acknowledge and celebrate safety achievements, big and small. Recognition fuels motivation and reinforces the importance of a safety-first mindset.


Data-Driven Decisions, Sustainable Results:

Numbers might not tell the whole story, but they can illuminate valuable insights. Leverage data to continuously refine and optimize your BBS program:

  • Leveraging Technology: Explore the integration of technology, such as mobile apps or wearables, to streamline the observation process.
  • Track leading and lagging indicators: Monitor not just incident rates, but also near misses, safety observations, and employee feedback. This holistic approach paints a clearer picture of your safety culture.
  • Analyze trends and patterns: Identify areas where unsafe behaviors are most prevalent, and tailor your interventions accordingly. Data-driven decisions lead to targeted solutions.
  • Regularly evaluate and adapt: Don’t get set in your ways. Periodically assess the effectiveness of your BBS program and make adjustments as needed. Agility is key to long-term success.
*Responses to unsuccessful Behavior Based Safety Program survey

Real-Time Intervention Strategies:

Immediate Feedback:

In the fast-paced world of workplace safety, timing is everything. And when it comes to Behavior-Based Safety (BBS) programs, immediate feedback isn’t just a perk – it’s a game-changer. Here’s why:

  • Strike While the Iron is Hot: Imagine witnessing a near miss. The adrenaline pumping, the lesson still vivid. That’s the exact moment when feedback has the most profound impact. Delaying it dilutes the learning opportunity, leaving the lesson lost in the daily grind. Immediate feedback seizes the moment, solidifying the connection between action and outcome, driving lasting change.
  • Nip Negative Nudges in the Bud: Caught an unsafe behavior in the act? Prompt intervention is critical. Immediate feedback allows you to address the issue right then and there, before it has a chance to become a bigger problem. It’s like putting out a spark before it grows into a wildfire, preventing potential accidents and building a culture of real-time safety awareness.
  • Positive Reinforcement on Speed Dial: Witnessing a safe act deserves instant applause! Timely recognition amplifies the positive impact, encouraging employees to repeat these behaviors and set a strong example for their peers. Imagine the boost in morale and safety mindset when a “job well done” rings out while the safe practice is still fresh in everyone’s minds.
  • Building Trust and Transparency: When feedback is prompt and open, it fosters trust and transparency. Employees understand the program’s purpose and see its direct impact on their daily work. This fosters a collaborative environment where safety becomes a shared responsibility, not just a top-down mandate.
  • Making Data Count in Real Time: Immediate feedback isn’t just about words; it’s about harnessing data for real-time insights. Imagine a system that tracks observations and feedback in real-time, identifying trends and areas for improvement as they emerge. This empowers you to adapt your BBS program on the fly, making it a dynamic force for continuous safety improvement.
  • Remember: Immediate feedback isn’t just a nice-to-have; it’s a critical ingredient for a thriving BBS program. By prioritizing real-time insights, you’ll unlock its full potential, transforming it from a passive observer to an active driver of a safer, more productive workplace. So, ditch the delays, embrace the power of immediate feedback, and watch your BBS program blossom into a safety champion!


Behavior-Based Coaching:

Behavior-based coaching is a crucial component of a Behavior-Based Safety (BBS) program, enhancing its effectiveness by providing personalized feedback and support to employees. Here’s a step-by-step guide on how to integrate behavior-based coaching into your BBS program:

  1. Understand the Basics of Behavior-Based Safety (BBS): Before implementing behavior-based coaching, ensure your organization has a solid understanding of the principles of BBS. This includes identifying at-risk behaviors, creating a positive safety culture, and fostering employee engagement.
  2. Define Clear Objectives for Behavior-Based Coaching: Establish specific objectives for incorporating coaching into your BBS program. These could include reducing specific at-risk behaviors, improving overall safety culture, or enhancing communication about safety concerns.
  3. Train Coaches and Observers: Provide comprehensive training for coaches and observers involved in the program. Ensure they understand the principles of behavior-based coaching, effective observation techniques, and how to provide constructive feedback.
  4. Develop a Coaching Framework: Create a structured coaching framework that outlines the process from observation to intervention. This should include guidelines for immediate feedback, coaching sessions, and ongoing support.
  5. Identify Key Behaviors for Coaching: Determine which behaviors are critical to address through coaching. These might include unsafe practices, failure to use personal protective equipment (PPE), or lapses in following established safety procedures.
  6. Promote Positive Reinforcement: Emphasize positive reinforcement during coaching sessions. Acknowledge safe behaviors and highlight improvements. This approach encourages employees to continue exhibiting safe practices.
  7. Implement Real-Time Feedback: Integrate real-time feedback into the coaching process. If an observer identifies an at-risk behavior, coaches should provide immediate, constructive feedback to the employee involved. This helps address issues promptly.
  8. Encourage Two-Way Communication: Foster open communication between coaches and employees. Encourage employees to share their perspectives, concerns, and suggestions for improving safety. A collaborative approach enhances the effectiveness of coaching.
  9. Utilize Technology for Efficiency: Leverage technology, such as mobile apps or digital platforms, to streamline the coaching process. This can include recording observations, tracking progress, and providing resources for self-directed learning.
  10. Establish Clear Reporting Mechanisms: Implement a reporting system for coaches to document their interactions and observations. This data can be valuable for assessing the impact of coaching on behavior change and overall safety performance.
  11. Schedule Regular Coaching Sessions: Set up regular coaching sessions to review progress, discuss challenges, and reinforce positive behaviors. Consistency is key to embedding behavioral changes into the organizational culture.
  12. Measure and Evaluate Coaching Effectiveness: Define key performance indicators (KPIs) to measure the effectiveness of behavior-based coaching. This could include a reduction in at-risk behaviors, improved safety metrics, and increased employee engagement in safety initiatives.
  13. Provide Ongoing Training and Development: Continuously train and develop coaches to ensure they stay informed about best practices and maintain their coaching skills. This ongoing investment contributes to the sustainability of the behavior-based coaching program.
  14. Celebrate Success and Continuous Improvement: Celebrate successes and milestones achieved through behavior-based coaching. Additionally, use feedback and data to identify areas for continuous improvement, adjusting the coaching program as needed.

By integrating behavior-based coaching into your BBS program with a strategic and employee-centric approach, you can create a safety culture that prioritizes continuous improvement, individual accountability, and a collective commitment to a safer workplace.

Check Out: How Effective Leaders Use Positive Reinforcement For the Greatest Effect

Tailoring BBS Programs to Industry-Specific Needs:

 Customizing Behavioral Checklists:

    • Tailor observation checklists to address industry-specific risks and behaviors.
    • Collaborate with industry experts to identify unique challenges and solutions.

One size doesn’t fit all, and that’s especially true when it comes to workplace safety. While Behavior-Based Safety (BBS) programs offer an invaluable toolkit for preventing accidents and building a culture of safety, simply plopping a generic program into any industry won’t unlock its full potential. That’s where industry-specific tailoring comes in, transforming BBS from a one-note melody into a symphony of safety tailored to the unique risks and rhythms of each workplace.

Gearing Up for the Grind: BBS in Manufacturing:

Imagine the whirring machinery, the sparks flying – the inherent risks of manufacturing demand a BBS program that speaks its language. Focus on:

  • Task-specific observations: Train supervisors to identify and address unsafe behaviors specific to each task, from machine operation to material handling.

  • Near-miss reporting: Encourage workers to report close calls as learning opportunities, not just accidents waiting to happen.

  • Safety champions: Empower experienced workers to mentor and advocate for safe practices among their peers.


The Key to BBS Customization:

Remember, tailoring is an ongoing process. Regularly analyze incident data, conduct employee surveys, and engage in open communication to identify areas for improvement and ensure your BBS program stays relevant and effective.

By embracing industry-specific needs, BBS programs shed their generic skin and transform into powerful tools for fostering safety in every corner of the working world. So, ditch the one-size-fits-all approach and get ready to craft a safety symphony that resonates with the unique rhythm of your industry. The reward? A healthier, happier, and ultimately more productive workplace for everyone.

Measuring the Impact: Key Performance Indicators (KPIs):

Establishing Relevant KPIs:

    • Define key metrics aligned with the goals of the BBS program.
    • Metrics may include incident reduction rates, observation completion rates, and positive behavior reinforcement rates.

Behavior-Based Safety (BBS) programs are powerful tools for cultivating a safer and more productive workplace. But measuring their success requires more than just counting bandages. To truly understand the impact of your BBS initiatives, you need to track the right Key Performance Indicators (KPIs).

Here are some essential KPIs to consider for your behavior based safety program:

Engagement & Participation:

  • Observation Rate: How often are safe and unsafe behaviors observed? This measures the program’s reach and employee engagement.
  • Feedback Rate: Do employees feel comfortable reporting near misses and safety concerns? This indicates trust and a willingness to participate actively.
  • Training Attendance: Are employees attending safety training sessions and actively learning about safe practices? This reflects their commitment to safety.

Behavior Change & Culture:

  • Positive Behavior Frequency: How often are safe behaviors observed compared to unsafe ones? This shows a shift towards a culture of safety.
  • Incident Rate Reduction: Are accidents and injuries decreasing over time? This is the ultimate measure of the program’s effectiveness in preventing harm.
  • Safety Climate Surveys: Do employees feel safe and supported in their work environment? This gauges the overall safety culture and identifies areas for improvement.

Leading Indicators for Proactive Safety:

  • Hazard Identification Rate: Are employees actively identifying and reporting potential hazards before they lead to incidents? This shows proactiveness and risk awareness.
  • Near Miss Reporting: How many near misses are reported? This indicates employees are paying attention to potential safety issues and taking preventative measures.
  • Safety Stop Rate: Do employees feel empowered to stop unsafe work practices and address safety concerns? This reflects a culture of ownership and responsibility.


  • KPIs are not one-size-fits-all: Choose metrics that align with your program’s goals and your industry’s specific risks.
  • Track trends over time: Don’t just focus on individual data points. Look for patterns and trends to identify areas for improvement and celebrate successes.
  • Regularly evaluate and adapt: No program is perfect. Use your KPIs to identify areas for improvement and refine your BBS initiatives to achieve optimal results.

By tracking the right KPIs and taking action based on the data, you can ensure your BBS program is not just a box-ticking exercise, but a powerful driver of real change in your workplace. Remember, measuring what matters is the key to unlocking the true potential of BBS and creating a safer, healthier, and more productive environment for everyone.

Check Out: How to Set Goals for Safety Performance

Regular Audits and Assessments:

Behavior-Based Safety (BBS) programs thrive on continuous improvement. Just like a well-oiled machine needs tune-ups, your BBS program requires regular check-ins to ensure it’s running smoothly and effectively. Enter the stage: audits and assessments, your trusty spotlights illuminating areas for refinement and maximizing the program’s impact.

Why Audit and Assess?

Regular audits and assessments aren’t just bureaucratic exercises; they’re vital tools for:

  • Gauging Program Effectiveness: Are your BBS initiatives actually changing behaviors and reducing risks? Audits provide evidence-based insights to validate or disprove your assumptions.
  • Identifying Areas for Improvement: No program is perfect. Assessments help you pinpoint weaknesses, uncover gaps in knowledge or implementation, and prioritize areas for improvement.
  • Demonstrating Commitment: Regular evaluations showcase your dedication to safety, fostering trust and buy-in among employees and stakeholders.

What to Audit and Assess?

Your audit and assessment toolkit can be customized to your specific program and organizational needs, but some key areas include:

  • Program Design and Implementation: Are your BBS components clearly defined, well-communicated, and effectively implemented across all levels of the organization?
  • Observation and Feedback Processes: Are observations conducted frequently and effectively? Does feedback reach employees promptly and lead to positive behavior change?
  • Employee Engagement and Participation: Are employees actively involved in the program? Do they feel comfortable reporting issues and participating in safety initiatives?
  • Data Analysis and Utilization: Are you collecting and analyzing relevant data to track progress and inform program adjustments? Are insights translating into actionable changes?
Check Out: How to Develop an Internal Safety Audit Schedule

Shining the Light: Conducting the Audit

Audits and assessments come in various flavors, from internal self-evaluations to external expert-led reviews. Choose the approach that best aligns with your needs and resources. Regardless of the method, remember these key principles:

  • Objectivity and Transparency: Conduct audits with an unbiased eye and openly share the findings with stakeholders.
  • Collaboration and Feedback: Involve employees at all levels in the process. Their insights are invaluable for understanding challenges and identifying solutions.
  • Actionable Outcomes: Don’t just point out the problems; translate findings into concrete action plans for improvement.

Remember: Audits and assessments are not punitive exercises; they’re opportunities to learn, grow, and strengthen your BBS program. By embracing regular evaluations and acting on their insights, you can continuously fine-tune your approach, build a robust safety culture, and create a safer, more productive workplace for everyone. So, grab your flashlight, shine a light on your BBS program, and pave the way for a brighter, safer future.

Addressing Challenges and Overcoming Resistance:

Change Management Strategies:

    • Anticipate and address resistance to change through effective change management strategies.
    • Communicate the benefits of BBS and address concerns transparently.
Check Out:  Making Behavior Change Stick Through Effective Change Leadership

Leadership Buy-In:

    • Secure leadership buy-in by showcasing the positive impact of BBS on safety outcomes.
    • Encourage leadership to actively participate in the program to set an example.

Remember, climbing the safety summit isn’t a single sprint, it’s a continuous journey. By incorporating these strategies into your behavior based safety program, you’ll build a robust framework that fosters a culture of shared responsibility, cultivates positive behaviors, and empowers everyone to play an active role in creating a safer, healthier workplace for all. Take the first step today, and watch your safety culture reach new heights!

Check-out my slideshow about implementing a behavior based safety program

BEHAVIOR based safety Kevin Ian Columbus Ohio Safety Consultant

Tips for Developing A Successful Emergency/Crisis Management Program

Emergency/Crisis Management Planning needs vary with the industry, type of operations, and regulatory applicability; however, the following guidelines can be used for any situation:


The first step is to Identify vulnerabilities and hazards associated with your operation. No one understands your operation better than you. Ensure that emergency, business continuity, and security issues are considered and use this analysis to prioritize your plan development efforts.

  • You should consider the following topics, at a minimum:
  • What are your vulnerabilities to natural disasters? Depending on the geographic scope of your operation, you may be subject to hurricanes, earthquakes, tornadoes. floods, ice storms, or all of these.
  • How would your company continue to operate in the midst of a pandemic situation?
  • What are the hazards introduced by your operation, and who may be impacted from a fire, release of hazardous material, oil spill, or explosion? Consider various events involving similar types of operations involving other entities, not the fact that it may have never happened in yours.
  • In the event that your primary or corporate office becomes uninhabitable due to a fire, flood, hurricane, earthquake, power failure or other event, could your company to operate?
  • What are your security vulnerabilities?


The next step is to use the results of the Hazard Analysis performed above, and determine what plan types should be developed, and which should be developed on a facility level or corporate/enterprise-wide level. For instance, site-specific fire pre-plans may be valuable for buildings and storage tanks that contain flammable contents; business continuity plans may be applicable at the corporate level.

Does your company need more components of an emergency action plan? Check what is available here

Example programs may include the following:


  • Emergency Response Plans (industrial operations), Emergency Operations Plans (hospitals, schools and universities), Emergency Action Plans (office building) describing site-specific initial response and activations procedures for potential hazards.
  • Fire Pre-Plans for buildings and process equipment, if applicable.
  • SPCC, OPA 90 Plans, RCRA Contingency Plans, SWPPP and other regulatory plans for facilities that store oil.


  • Crisis Management Plans describing corporate procedures for supporting operational emergencies, and for responding to corporate crises, including security, product liability, financial and other reputation issues.
  • Business Continuity Plans for corporate and regional offices
  • Pandemic Plans (often included as a subset of Business Continuity Plans)


Identify applicable regulatory requirements and ensure that your program addresses them, but remember that the primary purposes of the plans are to enable your company to respond effectively, and in the process, to ensure compliance. A common mistake is to organize plans specifically to meet the order of the regulations, when in fact, this may not result in the most logical or user-friendly format. Keep in mind that some regulations require a specific plan format or order of content, however, in many cases there is flexibility to organize the plan differently, as long as a regulatory cross-reference is provided and clearly identifies where each requirement is addressed.

Develop plans in a logical format that will be intuitive to responders who may not have had time to review them or training. A good test is to provide the plan to someone outside the organization and find out how long it takes for them to find key response information.

Ensure that plan content is comprehensive enough to provide tools needed for a response but is not so detailed that it reduces the effectiveness of the plan and results in more plan maintenance than necessary. Consider providing references and/or hyperlinks to detailed technical or regulatory information that may be needed but is too detailed to include in the plan.

Develop the content in a streamlined format with the goal of reducing the time required to read it. Bullet points and checklists are favorable to paragraphs of information.

OSHA offers publication 3088 to help organizations plan for emergencies and evacuations.

Download and view the OSHA Emergency Whitepaper below:

osha3088 how to plan emergencies



9 Components of a Safe Working Environment

A safe working environment is a condition or state, it is not necessarily an event like an incident of an accident. This means that the low number of incidents or accidents doesn’t mean that the workplace is particularly safe. What really counts is the process of safety because it is an integral part of everyday activities in the workplace. There are several activities which clear indicators of a safe working environment and this article lists 9 of them.

1) Daily safety briefings. Every morning at the beginning of the work day or the shift, the leader holds an interactive safety briefing with his or her team. It lasts less than 10 minutes and has contributions from the team members.

Need Topics? Check out 12 Months of Toolbox Talks

2) Weekly inspections to identify unsafe conditions. Every staff member participates in turn and conducts a regular safety inspection where they look for hazards and unsafe conditions. This can occur weekly or twice a week.

Check Out: How to Setup an Internal Audit Schedule

3) Accident/incident investigation. Every accident or near accident is investigated with the sole objective of prevention in the future. The process of investigation is not a witch hunt to apportion blame

Need components of an Incident/Accident Program? Click here to see what I offer.

4) Constant improvement. During the daily safety briefings, the group members have an opportunity to recommend and discuss improvements to the workplace and the processes that are carried out within it

5) Reporting near misses. Every single near hit (this is an incident where no damage or injury occurs) is investigated and prevention measures are put in place so it will not happen again.

6) Positive reinforcement. Each day the leader goes into the workplace and gives positive reinforcement to those members of staff for working safely. This encouragement and enthusiasm for safety is a great motivator for safe working practices.

Check Out: Be Aware of the Negative Aspects of Positive Reinforcement

7) Blame. It is noticeable that all safe working environments do not use blame or punishment as tools for creating safe behavior. Instead, they use positive reinforcement, encouragement and recognition.

8) Practical on-the-job training. Group members are continually receiving on-the-job training from experts within the company and outside.

Check Out: Safety Training Is About Behavior Change

9) Effective leadership. Is no coincidence that all safe workplace environments have good leadership. This means that the leader is prepared to listen and has the skills to create followers. These leaders engender cooperation and most of all discretionary effort. They are the main reason why people are working safely. They are not invisible and spend between 30 and 50% of their time with their team members.

First Aid – Policy and Procedures

When a medical emergency or injury occurs, knowing what to do and being able to react quickly is critical to limiting the severity of the incident. Proper first aid training provides individuals with the confidence and skills they need to address an emergency, prevent further injury, and a save a life. In extreme cases, equipping employees with first aid training could mean the difference between life and death.

Although all jurisdictions in the United States and Canada require workplaces to provide a first aid kit, a first aid attendant, and training, the requirements vary depending on the nature of the work, the number of employees on site, and the location of the worksite. All oil and gas work in is considered high hazard work and it’s highly recommended that all employees working onsite receive first aid training. This guarantees that first aid is readily available and accessible at all times, regardless of which employees are on shift. If providing first aid training all employees is not possible, it’s important to understand the requirements for the state or province you’re operating in to ensure compliance with their standards.

Check Out: OSHA Letter of Interpretation on First Aid Training

Having employees properly training in first aid is one component of a comprehensive First Aid Plan. A First Aid Plan sets out expectations and requirements regarding first aid services, equipment, supplies, records, communication, and transportation. Developing a First Aid Plan requires an assessment of the potential workplace hazards and the types of injuries and illnesses likely to occur. Consider information such as the number of workers, the type of work, and available medical treatment. When developing your First Aid Plan, you should always consider the worst-case scenario.

In summary, your First Aid Plan should include:

Creating a comprehensive first aid policy is crucial for any business to ensure the safety and well-being of employees and visitors. Here are essential components that a business should include in its first aid policy:

  1. Policy Statement: Clearly state the company’s commitment to providing a safe and healthy workplace, including provisions for first aid assistance in case of injuries or illnesses.
  2. Responsibilities: Define the roles and responsibilities of designated first aiders, employees, and management concerning first aid procedures. Specify who is responsible for maintaining first aid kits and equipment.
  3. First Aid Training: Outline the requirements for first aid training, including the type of training needed, how often it should be renewed, and who should undergo the training. Ensure that there are an adequate number of trained first aiders based on the size and nature of the business.
  4. First Aid Supplies: Specify the contents of first aid kits, their locations, and how often they are checked and restocked. Ensure that first aid kits are easily accessible and clearly labeled.
  5. Emergency Procedures: Provide step-by-step instructions for dealing with common workplace injuries and medical emergencies. Include procedures for reporting incidents and contacting emergency services.
  6. Communication: Establish a clear communication protocol for informing employees about the location of first aid facilities, the identity of first aiders, and the procedure to follow in case of an emergency.
  7. Record Keeping: Outline the procedures for documenting and reporting first aid incidents. Maintain records of incidents, first aid treatments provided, and any follow-up actions taken.
  8. Special Considerations: Address any special considerations related to specific workplace hazards or employees with known medical conditions. Ensure that there are appropriate first aid measures in place for unique risks.
  9. Review and Training Updates: Specify that the first aid policy will be regularly reviewed and updated to align with changes in the workplace, staff turnover, or changes in regulations. Include a schedule for regular first aid refresher training.
  10. Legal Compliance: Ensure that the first aid policy complies with local, state, and national regulations regarding workplace safety and health, including any specific first aid requirements.
  11. Accessibility: Ensure that the policy is readily accessible to all employees. Consider displaying summarized versions of the policy in common areas and distributing copies to new employees during orientation.

By including these components in a first aid policy, a business can create a safer work environment, respond effectively to emergencies, and promote the health and well-being of everyone in the workplace.


It is the role of managers and supervisors to understand the First Aid Plan and their accountabilities, as well as making sure first aid information is provided to all employees.

Regular reviews are an important part of maintaining your First Aid Plan. Emergency drills and exercises can help you make sure that your plan will work if an emergency does occur, and first aid kits and facilities should be reviewed on a regular basis. If an incident requiring first aid does occur, this is an opportunity for you to evaluate the effectiveness of your first aid plan and make any necessary changes or improvements.

Check Out: First Aid Training and Kit Requirements

Download and view the First Aid Policy and Procedures below:

First Aid - Response, Planning & Equipment Policy and Procedures


Crane, Hoist, and Sling Safety

Overhead cranes have become vital in modern industry. They are a common sight in sectors like construction, steel, mining, shipyards, repair shops, and others. Overhead Cranes are useful in many industrial activities and are commonly used to move extremely heavy items from one place to another. The rapid industrialization in many parts of the world has made the use of overhead cranes a crucial component of every major industry.

Overhead cranes can be of many types according to their need and usage.

Given below are various types of cranes:

Bridge Cranes

Bridge cranes are installed on metal beams that run along the ceiling of the room of the factory or warehouse. It needs two strong beams on the sides, a trolley which travels with it and carries the load as well as a hoist, which is needed to lifting and lowering the objects. These types of cranes can be again of two types.

Top running bridge cranes: These cranes run on the top of the beams. This requires quite some space above the beams for the easy movement of the crane. The installation must be planned as the rooms require higher ceilings. These cranes are stronger and can lift very heavy objects. They can be of single girder (which can lift lighter weights, up to 20 tons) or double girders (which can lift weights up to 100 tons).

Bottom running bridge cranes: These cranes run at the bottom of the beam. They reduce the available room height. They can even be installed in an already built factory. However, they cannot carry very heavy loads and can carry only up to 15 tons.

Monorail cranes

These are simpler types of cranes as compared to the bridge cranes. Unlike the latter, they operate on a single rail mounted on the ceiling. They operate by means of a forklift. They can be run from either a distance or by a car that moves behind the forklift.

The forklift can be used for lifting objects such as boxes, cartons and other similar objects. These cranes can be used in a small unit as well.

Jib cranes

These cranes are very compact and efficient for smaller work places with limited space. One end is fixed on something stationary, such as a wall. Hinges are provided so that the crane can swivel within the room. The distance covered is quite small at about 20 feet. They carry lighter loads.

Gantry cranes

These cranes are the advanced modification of the bridge cranes. The tracks that they run on are mounted on the floor. Due to this, they can carry heavy loads as much as 350 tons. They have deep water access as well. They are mainly used for loading and unloading cargo and hence found at ports and docks.

Wall cranes

Like the rest, these cranes are also mounted on horizontal beams. They remain at an angle of 90 degrees to the floor when they are stationary. But they can go up and down as and when required. They can be used to lift loads in a circular motion.

Operating overhead cranes requires skill and proper knowledge of safety procedures. For the proper utilization of overhead cranes, it is essential that workers and crane operators are fully trained and are completely skilled in the job. It is always to be remembered that unskilled or untrained operators not only put their lives at peril, but also cause the lives of other to be at risk.

Check Out: Ground Ladder Safety

For this reason, certain safety regulations for workers have been laid down by OSHA and US law for operating overhead cranes. Crane operators are responsible for their actions and for therefore, they must obey various rules and regulations that are in force. All employers must realize that there are different types of cranes and each crane has a different set of training and maintenance requirements. For proper operation of the crane, it is essential that the crane owner as well as the operator is familiar with its operating instructions. Amongst the foremost safety regulations for crane operators, it is essential that they possess corrected eyesight as mandated for a driver’s license. It is also essential that crane operators are able to effectively use both their hands and feet and are sufficiently tall to operate the controls of the overhead crane. Additionally, operators are expected to have proper coordination between their eyes, hands, and feet and should be free from disorders that could cause convulsion or unconsciousness.

Furthermore, as required by the new rules passed in July 2010, the US safety and health administration body OSHA has come up with new safety regulations for crane operators. Amongst the more important safety regulations are that cranes operators are required to be certified by an accredited body such as the National Commission for the Certification of Crane Operators (NCCCO). This is to ensure that crane operators are familiar with the hazards that come along with their daily routine. This will also help them to prevent accidents. Amongst the other notable safety measures require that the equipment be safely assembled. They should not collapse during or after installation and should be assembled under the guidelines of a qualified individual. Regular inspection of the crane equipment is mandatory every year. The crane should also be visually inspected after installation and also before the commencement of each shift.

Furthermore, audible warning signs are required for cranes when they are in motion. Every worker who is working onsite requires to be trained in crane warning signals so that they are aware of every potentially dangerous situation. No one should exceed the load capacity of the crane. The point is clear – loads that exceed the weight limit should not be moved at all. At the same time, if an operator cannot rig the load properly due to technical or other reasons, it should not be lifted. The crane operator should also inspect the path of the crane and check for any obstacles or people crossing the path. This should be done before the crane is operated. Additionally, the controls on the crane should be clearly marked and the operator should be very familiar with the use of these controls.

Workers should know how to evacuate the area in case of an emergency. Additionally, they should be familiar with how to handle an unexpected even such as an electrical or a mechanical failure. They should also be familiar with crane operation signs and should know how to handle the crane in event of a power failure. Additionally, workers should not wear loose clothing and also should secure their hair and jewelry. They should also park the crane safely when not in operation and lower the loads when the crane is not in use. Also, never ride on the hoist or pulley of a crane. This can be dangerous to life as just a slip could cause the worker to fall and can lead to disastrous consequences. Regulations also stipulate that workers should be familiar with using lockout procedures to avoid accidental starting or movements.

Broadly, it is essential that workers should understand signs, labels, as well a various instructions. In conclusion, the worker needs to be trained and tested before operating an overhead crane. There are other operator requirements including demonstrating proficiency in operating the crane. Once all the requirements are met, the worker is issued with a permit, and it is mandatory for workers that this permit is carried on their person and is made available upon request.

Download the Crane, Hoist, and Sling Safety Program below:

Download the Crane, Hoist, and Sling Safety Monthly Inspection below:

View the Crane, Hoist, and Sling Safety Program below:


View the Crane, Hoist, and Sling Safety Monthly Inspection below:



SPCC – A brief Introduction

A SPCC (Spill Prevention, Control and Countermeasure) plan is a document that should be drawn up by the owner of any oil storage facility to describe what steps are to be taken for the handling of oil, what to do if spills occur, what drainage or discharge controls are in place, who is in charge, and what resources and equipment can be brought into use to prevent any oil spills from reaching the coastline or any busy shipping lanes. The SPCC plans must be drawn up according to recognized engineering standards.

Oil spills are a danger to the health of the public, pollute drinking water, spoil natural resources and cause disruptions in the economy. The United States uses enormous quantities of oil for heating, fuel for vehicles and for the operation of hundreds of thousands of machines. Often, oil is spilled from storage facilities, while being transported, or during the course of exploration or production processes and it ends up soaking into the land or being carried away by rivers and streams.

The prevention of oil spills should be high on the agenda of any oil storage facility and if they do occur, they should be cleaned up as quickly as possible. It often costs less to prevent a spill than to clean one up after the event. The purpose of the SPCC rule is to assist oil storage facilities prevent spilled oil from reaching navigable waterways or the closest shoreline.

The SPCC rule applies to any facility that can store more than 1,320 gallons of oil above ground or greater than 42,000 gallons below ground and there is a reason to suspect that there may be an oil leak. All types of oil are covered, including fuel oil; petroleum; refuse oil; sludge; waste oil and vegetable oil to name but a few. The type of facilities that are covered by the regulation are any that store, refine, process, consume or use oil and are not in the business of transporting the oil.

Check Out: Spill Response Plan – Training

All covered facilities have to comply with the SPCC rules by preventing oil from spilling and by setting up and following their own SPCC plan. Some of the steps an owner or operator can take to prevent oil from spilling include; use suitable containers for the stored oil, use an alarm system to indicate overfill, provide backup containment measures for bulk storage vessels that is able to contain a major spill from the vessel plus any rainfall, if using a dike, this should be constructed from concrete or earth. Using a tank with double walls may also be acceptable.

Secondary containment should be provided to catch the spills that occur when transferring oil between containers and when offloading tankers. Drip pans, absorbing materials or curbing mechanisms should be used as well as regular inspections of all containers and pipes. Underground pipes need to be leak tested after installation or repair and written records should be included in the plan for these tests.

It is the owner/operators responsibility to draw up and implement an SPCC plan. Once all of the elements have been described in detail, the plan has to be certified by a Professional Engineer. The owner or operator can certify the plan if he is able to or chooses to only if certain conditions are met.

These conditions are subject to certain eligibility criteria such as; the total capacity of aboveground storage should be 10,000 gallons or less, for three years prior to certification, there has been no single oil discharge into the water or onto the shoreline that exceeds 1,000 gallons, two discharges of oil into the water or shoreline have not exceeded 42 gallons over the previous twelve months. If the facility cannot meet the above requirements then a licensed Professional Engineer must certify the SPCC plans.

Download and view the SPCC Generic Template below:



How to Persuade Your Staff to Wear Personal Protective Equipment

Let’s be honest: wearing PPE isn’t always top of mind. But before throwing up our hands in frustration, let’s acknowledge a vital truth – people have reasons, sometimes complex ones, for their actions (or inaction).

This article isn’t about finger-pointing. It’s about unlocking the secrets of human behavior to persuade your staff to embrace PPE and, ultimately, work safely.

The key? Stepping into their shoes.

Before barking orders about mandatory regulations, ask yourself: “Why might I hesitate to wear PPE?” Perhaps it’s discomfort, inconvenience, or even a perceived lack of necessity. Identifying your own potential stumbling blocks helps you understand and anticipate those of others.

Think of it as leadership evolution. In today’s dynamic world, understanding human behavior is no longer optional, it’s essential. The ability to decode motivations, address concerns, and tailor your approach is the difference between compliance and genuine buy-in.

This article isn’t just about PPE; it’s about unlocking the full potential of your team. By investing in understanding their why, you empower them to choose safety, not just follow rules. So, let’s ditch the frustration and embrace the fascinating journey of human behavior. It’s the key to creating a safer, more engaged, and ultimately, more successful workplace for everyone.

If you have a situation where staff members are not wearing PPE at the appropriate time and in the appropriate place, the first stage is to ask them why they are not wearing it. Normally, the range of responses will include, “It’s too uncomfortable.” “I have been doing it this way for 20 years and never hurt myself.” “I can’t see the point of it.” “I forgot.” And so on. Without a doubt, human nature being what it is, the easy way or the comfortable way will always be the first choice before the slightly harder way or the less comfortable way.

One of the ways to increase the use of PPE is to talk to your team about the consequences of not wearing it. For example, ask them if it is fair and reasonable to wear ear protection in noisy areas. You may get the response, “I am already deaf so it won’t make any difference.” Point out at this stage that the newer people will mimic behavior so they will copy a bad example. Ask them if they had their time again would they like their hearing returned.

On the other hand, the majority of people will readily agree that it’s fair and reasonable to wear ear protection in noisy areas. You then have to ask the question, “What will be the consequences of not wearing ear protection?” This way, it’s possible to set in place a consequence for that unsafe behavior. Gradually you can go through each item of PPE during your safety talks and achieve two objectives, firstly, get agreement that wearing PPE is fair and reasonable and, secondly, get agreement of the consequences that should occur if people don’t wear it.

Need components of a PPE program? Check out what I offer for small businesses here

That may be necessary to follow this method several times before an impact is made. Gradually, you will find that the levels of compliance will rise until the majority of people will raise the situation with the minority who were not wearing their protective equipment.


The 6 Fundamental Principles of Persuasion

  1. Reciprocity – This principle is epitomized by the phrase “Gimme Five.” It revolves around the human inclination to anticipate and desire the return of favors, even in the form of simple gestures like handshakes. The concept is akin to the reasoning behind providing free samples at grocery stores. Human psychology is wired to expect reciprocal actions, creating a social dynamic reminiscent of a “scratch my back, and I’ll scratch yours” scenario.
  2. Commitment and Consistency – People tend to uphold promises when these commitments align with their self-perception. Even in situations where the other party fails to meet expectations, individuals are more likely to stay true to their word. This principle underscores the enduring power of honesty and the human inclination to adhere to consistent self-identities.
  3. Social Proof – The influence of the crowd is a powerful force. People often follow the path of “crowd think,” assuming that if a significant number of others are engaging in a particular behavior or belief, it must be valid. This principle reflects the human tendency to seek validation through the actions and choices of the larger group.
  4. Authority – Individuals tend to deviate from their normal behavior when figures of authority endorse certain actions. Even when those actions may be ethically questionable, the permission granted by authoritative figures can sway behavior. This principle illustrates the impact of influential individuals on shaping collective conduct.
  5. Liking – The principle of liking underscores the human inclination to be influenced by those we admire or find appealing. Whether it’s heeding advice or making purchasing decisions, endorsements by celebrities, movie stars, or pop idols carry substantial weight. This principle explains why diet plans become more appealing when associated with well-known personalities.
  6. Scarcity – The scarcity principle is based on the idea that limited availability enhances desirability. If a product or opportunity is perceived as scarce or exclusive, individuals are more likely to be motivated to acquire it. This principle highlights the psychological impact of perceived rarity on consumer behavior.

These six principles of persuasion are not confined to specific cultures or contexts; they hold universal relevance. An example often cited by Cialdini demonstrates how these principles operate subtly yet consistently in shaping human behavior.

An Example of Persuasive Superpowers

The experiment by Harvard social psychologist Ellen Langer, states that it is commonly believed when asked a simple favor, we are more likely to oblige if the request is accompanied by a plausible reason. It goes something like this:

STAGE 1. Langer first provides a base test by asking a ‘small favor’ of a group of people in line at… Let’s say a coffee shop, “Excuse me, I need to get my caffeine fix. May I go ahead in the line, because I’m in a hurry?” The effectiveness of this request-plus-reason was nearly total: Ninety-four percent of those asked allowed her to skip to the front of the line.

STAGE 2. Compare this success rate to the results when she made the request-only, “Excuse me, I have to get my caffeine fix. May I go ahead in the line?” Under those conditions, only 60 percent complied. It would infer that the difference in results was due to the additional information offered, “because I’m in a hurry” as in the stage one.

STAGE 3. But a third request tried by Langer demonstrated this was not the case. It seems it was not the series of words that made the difference, but solely the first word, because“. Langer’s third attempt used the word “because”, but added no new information or reason for the request. She merely restated the obvious, “Excuse me, I need to get my caffeine fix, may I go ahead of you, because I need my caffeine fix.” The result was once again nearly all (93 percent) allowed her to cut in line even though there was no justifiable reason given.

When you make a request of someone else, regardless of the reason, humans are programmed to respond positively to the stimulus word “because”. Knowing this, there would be no reason not to use this.

Ask yourself, if you stated in front of all your work mates that you thought that wearing PPE because it was fair and reasonable, what would be the chances of you complying with that statement? I would suggest that it would be very high. It is called a psychological contract and is very effective.