In its 2002 report, the World Health Organisation estimated that up to 16% of hearing loss globally is attributed to workplace noise exposure. Despite an understanding of the exposure levels that create harm, rules and policies put in place to mitigate those exposures are all too frequently ignored.
In part, the problem stems from poor risk perception; unlike other injury types, noise induced hearing loss is seldom detected before considerable damage has already occurred. But risk perception is only one issue in the way of compliance.
Hearing protection rules are subject to the same laws of human and organisational behaviour as other safety standards. In one study of workers who had suffered head injuries, for example, only 16% had been wearing hard hats, despite the fact that two-fifths were required by law to wear them .
More recently, rule violations were thought to be a significant contributing factor in the 2008 commuter train crash that killed 25 people just north of Los Angeles, California. The train’s engineer had been texting, up to 22 seconds before impact, contrary to the agency’s well-known policy against the use of personal communication devices on the job.
Why, despite the well-known risks, would people continue to operate outside the protection of safety rules and policies?
Understanding the gap between good safety rules and policies and their execution is critical to assuring adequate employee protection. This article explores why employees continue to violate safety rules around hearing protection, despite the known dangers associated with non-compliance, and offers leaders practical suggestions for addressing it in a more proactive way.
The purpose and place of rules
Rules play an important role in setting expectations and standards around acceptable work practices. Without rules, we are asking people who haven’t seen all the research, and who don’t have access to all the information around hazards, to use their own discretion in determining what is safe in the workplace.
Rules and regulations help raise awareness of what is and isn’t harmful – and they sanction protective behaviour that might otherwise be difficult.
For example, in the case of hearing protection, rules make it acceptable to use personal protective equipment (PPE) within a peer group that values ‘toughness’. While it would be tempting to blame workers for injuries suffered after violating a rule (or, as is often the case in hearing loss, of violating rules repeatedly), the reality of non compliance is somewhat more complex.
Most of us are all too familiar with the gap between what we know we should do and what we actually do. We know we would like to be more fit, devote more time to our families, be more patient, and get our important errands done. Nevertheless we often fall short of doing what we intend.
The same gap appears in organisations. The way we intend things to be done often differs from how they actually get done. This gap is so much a fact of organisational life that most of us have adapted to it and accept it as inevitable.
Seasoned safety professionals frequently see that immediate demands or consequences (good and bad) are a stronger influence on employees than rules or policies, even when breaking those rules poses risk of injury.
Systems influences, perceptions of risk, the norms of culture, organisational consequences, and the example of leaders are among the factors that influence decisions about personal protective equipment use. When these organisational elements are poorly aligned with standards and law, deviation from safety rules is not far behind. Yet, in cases where the intention is to prevent exposure to accidents and injury, closing this gap is an imperative and it starts with understanding what the various pieces are.
Safety outcomes result from the confluence of multiple factors, of which rules play one part. At the macro level, the mechanisms that drive safety performance can be illustrated in the Blueprint for Safety Transformation. (Figure 1). The five elements of this blueprint are:
1. The Working Interface is the configuration of equipment, facilities, systems, and behaviours that defines the interaction of the worker with the technology. This configuration is where hazards exist and safety excellence is directly related to how effective the organisation is at controlling exposure here. Each of the other four elements plays a critical role in optimising this interface for safe performance
2. Safety Enabling Systems are the basic safety systems or programmes that assure adequate safety functioning. These systems include rules and standards, as well as training, hazard recognition and mitigation, and exposure reduction systems
3. Organisational Sustaining Systems are those processes that sustain enabling systems and assure their effectiveness. They include mechanisms such as selection and development, performance management, organisational structure, employee engagement, and other management systems. Effective organisations understand the relationship between the quality of their sustaining systems, their safety systems, and what occurs in the working interface. For instance, is the structure of the organisation such that safety is given adequate emphasis? Does the performance management system meaningfully address safety leadership issues (not just through lagging indicators?)
4. Organisational Culture refers to the driving values of the organisation, ‘the way we do things around here.’ Unlike climate, which refers to prevailing influences on a particular area of functioning and is quick to change, culture is deeply embedded and longer lasting. Effective safety practitioners look realistically at culture and identify issues that could undermine safety objectives.
Cultural attributes such as low trust, poor communication, or mixed management credibility can neutralise even the best enabling and sustaining systems 5. Leadership drives both the culture of an organisation as well as the functioning of enabling and sustaining systems. In this configuration, leadership refers to seeing the right things to do to reach objectives and motivating the teams to accomplish them effectively. Safety leadership is exercised by decision making which is related to the beliefs of the leader and demonstrated by his or her behaviour
Understood in this context, it’s clear that whether or not rules are followed depends on the quality and alignment of other business, safety systems and practices.
When rules and people meet
Given that rules are one piece of a broader system, how does the alignment, or misalignment, of various influences combine to create singular examples of compliance? Applied behaviour analysis – also known as ABC analysis – sheds light on why people behave the way they do and provides a useful tool for understanding multiple influences, organisational and otherwise, on individual behaviour.
Derived from psychology, it provides a powerful methodology for understanding, measuring, and influencing behaviours of all kinds. Research in education, clinical psychology, and organisational improvement all demonstrate the effectiveness of applied behaviour analysis as a tool for improving behaviour. Applied behaviour analysis dissects a behavioural event, such as the failure to use personal protective equipment, into three elements:
• Behaviour: an observable act
• Its antecedents: the events or circumstances that precede and trigger a behaviour
• Its consequences: the results following the behaviour, including any event or change
Using ABC analysis to understand behaviour starts by pinpointing a behaviour that we are interested in:
• A specific behaviour, performed by a specific person, in a specific situation. Next, we list the antecedents and consequences associated with that behaviour. Finally, we evaluate each consequence on three characteristics:
• Positive or Negative: positive consequences make the behaviour more likely to recur
• Sooner or Later: the closer they are connected to the behaviour, the more powerful they are
• Certain or Uncertain: the reliability of the consequence influences how quickly the behaviour develops and how quickly it fades after the consequences change
Consider the following example:
At the end of his shift, an employee enters a work area to perform one last task before going home. The area requires the use of hearing protection, a fact that is prominently noted on signs posted at the entrance. Still, the employee walks past the signs and goes to perform his task. It’s only a few minutes, the employee thinks, and it would take more time to go get the hearing protection than it would to just do the job. In addition, the employee reasons, the exposure must surely be minimal. Waving to the area supervisor, who greets the employee with a friendly nod before returning to his own task, the employee finishes his work and goes home for the day without incident.
Analysing the behaviour in this example (Table 1) it is clear that the most powerful consequence controlling the hearing protection behaviour is the immediate, positive reinforcement of getting the job done in a short amount of time. The worker is looking forward to the end of the day and completing the job and has a friendly, if brief, exchange with the supervisor. These positive social consequences far outweigh the very weak negative consequences – getting caught, being reprimanded, or suffering hearing loss. These negative consequences are weak because they are rare outcomes relative to the number of times someone can fail to use hearing protection without suffering any negative consequences.
Besides the personal factors related to this worker, this analysis also points to several barriers that complicate the issue: the lack of understanding of the unique risk associated with hearing loss; lack of agreement that the risks apply to this particular worker; cultural norms; the design or availability of hearing protection and the pressure to complete work to leave on time. These are all significant barriers that could be addressed as part of the solution. Given the factors driving and reinforcing non-compliance, it’s unlikely that a single layer solution, such as training or reprimand, will be sufficient for long-term behaviour change or assure reliable compliance.
The behaviour analysis in Table 1 points to opportunities in shaping the antecedents and consequences to support the desired behaviour, in this case the use of hearing protection every time it is required. If we want to impact this problem, we need to improve the antecedents, align the consequences, and remove barriers to performing desired behaviours. Fundamentally:
• Improving antecedents: If an organisation does not have a policy or training around hearing protection, these can be among the most helpful antecedents to put in place. Providing the basic elements should be accompanied by an awareness campaign that educates people about the risks, and reinforces their responsibility. Organisations should be prepared to explain why failing to wear hearing protection is a long-term risk that can create irreversible damage. Improving the antecedents by itself will not change persistent behaviour, but it sets the stage for it
• Aligning the consequences: The most important thing an organisation can do to change hearing protection behaviour is to neutralise the powerful consequences that reinforce non compliance and replace them with positive consequences for the desired behaviour: performing the task with required equipment. What if supervisors in the area intervened every time they saw an employee working without protection? What if work was scheduled with sufficient time to acquire and use all of the necessary equipment (rather than leaving tasks to the end of the day?) Feedback is another very powerful social consequence that could be used to reinforce employees using the desired behaviour, which is use of all required protective equipment
• Remove barriers to the desired behaviour: In some cases, safe execution may be difficult or impossible because of the limitation of training or knowledge, the configuration of work systems and schedules, or even lack of communication. Some organisations may need to establish systems for assuring that equipment is always readily available and in good repair. In some workplaces, simply reevaluating the type of PPE provided and switching to equipment that more closely matches the needs, fit, and comfort of employees has helped increase compliance significantly
Aligning people, the organisation and rules
At a broader level, assuring consistent use of hearing protection requires attention to the unique nature of noise hazards. Specifically the lag in noticeable effects of noise exposure requires vigilance on the part of individual employees and a consistent, clear message about the purpose and importance of hearing protection from the organisation.
While people might agree in the abstract that hearing loss is an important problem, they may have very low levels of risk perception in their day to day jobs. This is one of the dangers of overreliance on training as a compliance tool; often what we’re trying to impart to people runs counter to their actual experience.
We learn behaviours by experiencing the results that come from performing those behaviours ourselves. If no negative consequences occur, the behaviour is reinforced and usually repeated until it becomes habitual. So for example, even though we’re told not to speed, and we know that speeding can lead to an accident, most of us have experienced no negative consequences from speeding. Even the occasional speeding ticket does not change the belief developed from our experience – that speeding is not inherently dangerous. Our experience gives us false feedback. In the same way, employees learn to perform at-risk behaviour in the workplace when no negative consequences result – or at least none that are apparent. Employees’ experience, that nothing bad happens, informs their belief that this behaviour is not at risk.
In addition to requisite training in the use of and reasons for hearing protection, organisations can increase the level of engagement in exposure mitigation through engaging employees in safety systems. This might mean including employees on a safety team overseeing a large number of activities, or it could mean creating a task-oriented committee to address hearing loss prevention specifically. Regardless of the format, direct involvement in safety systems helps create a new and different experience for employees of those systems and the reasons behind them. It allows them to see for themselves the validity of what they learned in safety training.
Aligning the organisation
Despite establishing rules, enforcing them, and training people in their use, many organisations continue to send conflicting messages about how rules are to be applied. Differing messages may be unnoticeable to leaders, but they speak loud and clear to employees at the front line. Specifically, organisations need to support hearing protection through a clear focus on reducing exposures, rather than injuries, as the goal of safety activities.
Many organisations over rely on injuries as the measure of success and the trigger for change. The problem is that injury numbers by themselves do not accurately reflect safety performance and can mask real exposure levels, particularly to hazards like those that cause noise induced hearing loss. This is why it so common to see organisations with very low injury rates that continue to have fatalities or loss time accidents, recordkeeping violations, low levels of rules compliance, ‘surprise’ cumulative injuries, and so on. In addition, an injury focus often leaves individual employees to risk assess their own decisions and actions. That is, deviations from established rules and protections are routinely overlooked so long as they don’t result in injury. Every time this happens, the outcome is no better than a roll of the dice.
The goal for organisations that want to support hearing protection is to manage exposures rigorously to the standards the organisation has already set with its rules, procedure, policies, best practices, and training.
By shifting the focus to exposures, organisations establish a value for protection in every instance that it is required. They also reframe safety rules as essential and nonnegotiable protections for managing exposures rather than optional checklists to be discarded when they are inconvenient.
From compliance to commitment
Managing the risks associated with hearing protection takes more than implementing more rules and policies. Given the complexities of human and organisational behaviour, such measures only function to the extent that they provide positive consequences for following them.
Using a behaviour-change model that seeks to understand the environment that rules are used within can help organisations better align intention with practice, not just in the area of hearing protection, but in any area that puts employees at risk of serious and lasting harm.
Teg Matthews is a senior advisor with BST, a global safety consulting firm. Teg works with senior leaders and leadership teams to design and implement safety change initiatives throughout the Gulf, Middle East, and the UK. Teg is based in United Arab Emirates and can be reached at [email protected]. Rebecca Nigel is communications manager with BST and focuses on advancing thought leadership in safety. Rebecca is based in the United States and can be reached at [email protected].
Started in 1979, BST pioneered the application of behavioural science to safety performance. Today, BST works with organisations to reduce occupational injuries, improve organisational functioning, and develop strong safety leadership. BST’s clients represent more than 60 countries, 30 languages, and many of the leading organisations in oil and gas, manufacturing, chemical, mining, metals, paper, transportation, consumer products, utilities, healthcare, and other critical industries. More information about BST is available at www.bstsolutions.com . www.osedirectory.com/health-and-safety.php
Published: 01st Feb 2011 in Health and Safety Middle East