To be objective, evaluating safety performance to determine if discipline is justified must be based on facts, not subjective hunches or feelings. The last thing we should do is to assume unsafe behavior is the employee’s fault. To be perceived as fair, discipline must be motivated to help, not hurt, the employee and to improve safety performance.
A performance evaluation process should be completed by a competent person. That might be a supervisor or safety professional if properly trained. It will naturally take some time and should be carefully conducted to accurately:
- describe the event representing the performance discrepancy
- determine contributing surface causes
- uncover possible system root causes
Because so many variables directly and indirectly influence unsafe behavior, it is best to assume the safety management system has failed the employee, not the other way around. The employee should be “innocent until proven guilty.”
To help determine if discipline is justified, we can use the Accountability System Decision Tree. (see image to the right) It walks you, step by step, through the analysis and evaluation process. Let’s take a look.
The first thing to do is to describe the discrepancy. This is the unsafe behavior or act. There is a gap between what should have been done, and what was actually done.
Next, ask these seven basic questions: (I call this the gauntlet)
- Has the responsibility been formally or officially assigned? If the responsibility has not been properly assigned, we need to stop and make sure responsibilities are clearly assigned and communicated to all employees.
- Has the authority to act been given? If the employee does not have authority, the lack control. Employees should never be held accountable for behaviors and actions over which they have authority and the ability to control.
- Is there a lack of knowledge, skills, or abilities (KSAs)? If the employee lacks any of these through inadequate training, physical or psychological ability, discipline should not be considered. Rather, get the employee the assistance need to gain the KSAs. If the employee does have the required KSAs, then, and only then, do we need to continue on with the analysis.
- Are resources adequate? We want to know if the employer provided its employees the needed personal personal protective equipment, tools, materials, equipment, and workplace environment to do the work safely. If they have, great. If they have not, we need to provide it.
- Is supervision adequate? OSHA defines adequate supervision as identifying and correcting hazards before they cause injury or illness to an employee. If an employee was injured on the job, it is going to be difficult to prove to OSHA he or she was adequately supervised. It is also going to be difficult for the employer to justify discipline.
- Is the enforcement adequate? Effective consequences result in improved behaviors. If hazards and unsafe behaviors are common, and if they are not corrected in a timely manner, you can bet that safety enforcement needs improvement.
- Is the support adequate? To satisfy this requirement, adequate leadership, management, and psychosocial support must exist. Tough-caring leadership and sound management of the safety management system. Managers value safety and have high expectations because they care about the success of their employees and the company.
If we can honestly say yes to each question through this “gauntlet” of questions, then leadership demands some form of honest and fair discipline be considered. This is because, based on the facts, it appears the employee failed the system, not the other way around.
Remember, it is not appropriate for a safety manager to discipline because that position is a staff position, the administration of discipline is a line responsibility. Because discipline can have dramatic positive or negative effects on a company’s safety culture, discipline should be administered when it is justified only after close coordination with human resource professionals.