Can Safety Culture Be Regulated? (Part 1)

One of our recent posts questioned whether safety culture is measurable.  Now we will slide out a bit further on a limb and wonder aloud if safety culture can be effectively regulated.  We are not alone in thinking about this.  In fact, one expert has flatly stated “Since safety culture cannot be ‘regulated’, appraisal of the safety culture in operating organizations becomes a major challenge for regulatory authorities.“*

The recent incidents in the coal mining and oil drilling industries reinforce the idea that safety culture may not be amenable to regulation in the usual sense of the term, i.e., as compliance with rules and regulations based on behavior or artifacts that can be directly observed and judged.  The government can count regulatory infractions and casually observe employees, but can it look into an organization, assess what is there and then, if necessary, implement interventions that can be defended to the company, Congress and the public?

There are many variables, challenges and obstacles to consider in the effective regulation of safety culture.  To facilitate discussion of these factors, I have adapted the Rumsfeld (yes, that one) typology** and sorted some of them into “known knowns”, “unknown knowns”, and “unknown unknowns.”  The set of factors listed is intended to be illustrative and not claimed to be complete.

Known Knowns

These are factors that are widely believed to be important to safety culture and are amenable to assessment in some robust (repeatable) and valid (accurate) manner.  An adequate safety culture will not long tolerate sub-standard performance in these areas.  Conversely, deficient performance in any of these areas will, over time, damage and degrade a previously adequate safety culture.  We’re not claiming that these factors will always be accurately assessed but we’ll argue that it should be possible to do so.

Corrective action program (CAP)

This is the system for fixing problems.  Increasing corrective action backlogs, repeated occurrences of the same or similar problems, and failure to address the root causes of problems are signs that the organization can’t or won’t solve its problems.  In an adequate safety culture, the organization will fix the current instance of a problem and take steps to prevent the same or similar problems from recurring in the future.

Process reviews

The work of an organization gets done by implementing processes.  Procedural deficiencies, workarounds, and repeated human errors indicate an organization that can’t or won’t align its documented work processes with the way work is actually performed.  An important element of safety culture is that employees have confidence in procedures and processes. 

Self assessments

An adequate safety culture is characterized by few, if any, limits on the scope of assessments or the authority of assessors.  Assessments do not repeatedly identify the same or similar opportunities for improvement or promote trivial improvements (aka “rearranging the deck chairs”).  In addition, independent external evaluations are used to confirm the findings and recommendation of self assessments.

Management commitment

In an adequate safety culture, top management exhibits a real and visible commitment to safety management and safety culture.  Note that this is more limited than the state of overall management competence, which we’ll cover in part 2.

Safety conscious work environment (SCWE)

Are employees willing to make complaints about safety-related issues?  Do they fear retribution if they do so?  Are they telling the truth to regulators or surveyors?  In an adequate safety culture, the answers are “yes,” “no” and “yes.”  We are not convinced that SCWE is a true "known known" given the potential issues with the methods used to assess it (click the Safety Culture Survey label to see our previous comments on surveys and interviews) but we'll give the regulator the benefit of the doubt on this one.

A lot of information can be reliably collected on the “known knowns.”  For our purpose, though, there is a single strategic question with respect to them, viz., do the known knowns provide a sufficient dataset for assessing and regulating an organization’s safety culture?  We’ll hold off answering that question until part 2 where we’ll review other factors we believe are important to safety culture but cannot be assessed very well, if at all, and the potential for factors or relationships that are important to safety culture but we don’t even know about.

* Annick Carnino, "Management of Safety, Safety Culture and Self Assessment," Top Safe, 15-17 April 1998, Valencia, Spain.  Ms. Carnino is the former Director, Division of Nuclear Installation Safety, International Atomic Energy Agency.  This is a great paper, covering every important aspect of safety management, and reads like it was recently written.  It’s hard to believe it is over ten years old.

** NATO HQ, Brussels, Press Conference by U.S. Secretary of Defense Donald Rumsfeld, June 6, 2002. The exact quote: “There are known unknowns. That is to say, there are things we now know we don’t know. But there are also unknown unknowns.  These are the things we do not know we don’t know.”  Referenced by Errol Morris in a New York Times Opinionator article, “The Anosognosic’s Dilemma: Something’s Wrong but You’ll Never Know What It Is (Part 1)”, June 20, 2010.