One of the most experienced safety professionals had a story about a facility that was used to model OSHA compliance for new inspectors. The facility had few issues during inspections and employees felt very safe there. However, someone eventually died on the job at the facility, showing that complete compliance does not prevent all injuries. While willful violations account for a small portion of OSHA citations, injuries often result from unintentional human errors like complacency, rushing, frustration, and fatigue. Complacency in particular can cause workers to underestimate risks and make mistakes. Regular safety training is needed to address human factors like complacency that contribute to injuries beyond compliance alone.

1. One of the most experienced CSPs I know has a story that he
likes to tell about a facility where he used to work. He calls it “the
darling of OSHA” because the government used it as a model
for new inspectors to get an understanding of what a compliant
worksite should look like.
Duringtheirregularvisitstheinspectorswouldinevitablydiscover
a few issues, but overall the site was an excellent example of the
proper application of OSHA’s rules. Employees who worked at
the site couldn’t imagine feeling safer. After all, it might have
been the most frequently inspected site in the United States.
And then someone at the facility died on the job.
Every year OSHA outlines its list of the top 10 serious safety
violations, and while the awareness this provides is excellent, it
doesn’t highlight the fact that compliance alone is not enough
to prevent all injuries. After all, folks who take the time to read
publications like Safety Decisions probably aren’t negligent
when it comes to actually following the rules, but I would bet that
9 out of 10 people reading this article are still struggling with tons
of back injuries, sprains, strains, slips, trips, and falls.
Still, the belief persists that if you strive to follow the rules you’ll
be safe from violations and free from injuries. But the numbers
seem to indicate otherwise. While it’s true that last year the single
biggest fine was handed out to a company that knowingly exposed
workers to asbestos (and certainly punishing companies like this
is important), these infractions are a relatively small portion
of OSHA’s citations. In fact, in 2014 only 375 of the 39,560
violations in OSHA’s top 10 list were classified as willful, that is,
“committed with an intentional disregard of or plain indifference
to” OSHA’s requirements. To put it another way, approximately
95% of serious safety violations committed last year weren’t
committed willfully.
It’s not like injuries that occur at OSHA-compliant worksites are
only occasional “freak” accidents, either. The fact is that injuries,
big or small, are difficult to prevent with compliance alone as
they are largely the result of worker actions—usually fuelled by
complacency and other human factors like rushing, frustration,
and fatigue—that lead to inattention and unintentional errors.
Some safety professionals feel that following the letter of the
Occupational HealthAdministrationAct is enough. Unfortunately,
as my CSP friend discovered, that’s not the case—you also have
to address the human side of the safety equation.
COMPLACENCY DESERVES
a Place on OSHA’s Top 10
by: Ray Prest
This article was published in BLR`s Summer/Fall 2015 issue of Safety Decisions
95 PERCENT
OF SERIOUS SAFETY VIOLATIONS LAST
YEAR WEREN’T COMMITTED WILLFULLY

2. Complacency in particular is a common contributor to
unintentional injuries. When workers get overly comfortable with
a procedure they’ll often mentally minimize the amount of risk
involved—and complacency can be exacerbated by a belief that
rules and regulations form an infallible safety net.
z
At its core, complacency is simply an inaccurate perception of
risk. The more you do something and nothing adverse happens,
the more you feel you can continue doing it without consequence.
It’s no surprise to hear that familiarity with a hazard breeds
complacency, and in many everyday cases this may not seem like
a huge issue … but if you’re working at heights, it only takes one
mistake to become the victim of a potentially fatal fall.
Companies can also get complacent. It’s possible for
organizational complacency to erode the usual safety procedures
and, if you’re not careful, you might find that someone has failed
to properly install a guard rail or wear their fall protection. If an
OSHA inspector is in the neighborhood when that happens, the
result can be a sizeable fine. Even if there’s no inspector present
it still elevates the level of risk for your workers.
The good news is that there are several training solutions that
augment OSHA’s compliance measures and that will strengthen
your company’s safety program. Last November BLR’s Safety
Daily Advisor surveyed 1,294 safety professionals about slips,
The fact is that injuries, big or small, are difficult to
prevent with compliance alone as they are largely
the result of worker actions—usually fuelled by
complacency and other human factors like rushing,
frustration, and fatigue—that lead to inattention and
unintentional errors.
trips, and falls and found that 85% of respondents believe that
toolbox talks temporarily raise employees’ understanding of
risk. Regular safety meetings are a key method of readjusting the
perception of workplace hazards—but it’s important to note that
its effectiveness is limited. It requires workers to keep a hazard
at the front of their mind, and eventually some new piece of
information, production demands or life in general will push your
safety lesson aside.
Human factors training presents a longer-term solution. Instead
of constantly fighting complacency with reminders like “be more
careful” or “where’s your PPE?”, you can teach people real-time
skills to maintain focus and keep safety and risk in mind in any
situation even when things get busy or go wrong.
Everyone knows that human factors like rushing, frustration,
fatigue and complacency can increase the risk of making a
mistake, clouding a decision, or causing an injury. But not
everyone recognizes the scale of these problems, nor do they
realize they can be managed with personal safety skills.
Complacency is one of the most common culprits of injuries at
OSHA-compliant companies. Though it eludes OSHA’s top 10, it
will continue to lurk in the shadows of every item on the list until
it’s effectively addressed at your workplace.
ABOUT THE AUTHOR
RayPrestistheMarketingManagerat
SafeStart,a family-owned company
that has provided safety training
solutions to industry, education,
and the military for over 40 years.
He is also a columnist for Safety
Decisions magazine. You can learn
more and read Ray’s recent articles,
blog posts, and safety guides at
safestart.com/ray.
www.safestart.com
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