Are Your EHS Goals Leading to Unintended Consequences?

February 27, 2018

It’s now official. ISO 45001 will be published on March 12, 2018. Upon hearing the news, I thought about the proverb “The road to hell is paved with good intentions”. You’re probably wondering “What’s the connection between the two?

The answer is in this interesting article: Will ISO 45001 Displace Workers with Artificial Intelligence and Robots? The article raises the possibility that organizations will replace workers with artificial intelligence and robots to minimize hazards and risks, in order to achieve ISO 45001. The conclusion includes the following sentence: “Legislators and regulators must be reminded that the road to hell is paved with good intentions and created by the law of unintended consequences.

Sometimes organizations can have the right intentions, but there can be unintended consequences. The future will tell the extent to which ISO 45001 may displace workers, but even today initiatives designed to improve EHS performance may instead be creating unintended consequences. Are you in such a situation? Are you even aware that the possibility exists? Let’s look at four examples of good intentions leading to unintended consequences. Check if any of them applies to you.

Bonuses and Compensation Plans

Executives and managers are sometimes encouraged to improve EHS performance across the organization through bonuses and compensation plans that reward them if EHS goals are achieved. The unintended consequence is that executives and managers may misreport or under-report incidents, or misrepresent other metrics, to the board of directors or executive management, in order to get their bonuses and rewards from their compensation plans. This leads to a situation where workplace hazards are not identified properly, and therefore cannot be addressed to improve safety.

Zero Incident Targets

This is such a hot topic in EHS that we wrote a about it. “Zero incidents” is a noble target worth pursuing, but some argue that a formal zero incident target is unrealistic and may lead to under-reporting incidents, which can negatively impact the safety culture. Zero may be perceived as too hard to achieve, and thus not be motivating for employees. Instead, some experts recommend achievable, individual-specific goals and rewarding employees when they reach them.

Number of Observations

Workers should report observations of unsafe behaviors or conditions. Observations can help to identify workplace hazards. Some organizations encourage participation by benchmarking individual sites or workers, and recognizing and rewarding the site or worker with the most observations. The intention is good (increase the number of observations), but a contest for the highest number of observations can lead to a numbers game where people report low-quality observations just to drive their totals up. Luckily there is a solution: .

Number of Near Misses

Organizations should reduce incidents, which include accidents and near misses (). Accidents are very visible and therefore difficult to hide and under-report. Near misses are different because a near miss is an incident that did not result in a fatality, injury, illness or property damage. A near miss is easier to under-report. But near misses can provide valuable information on hazards, so the reporting of near misses should be encouraged. When setting incident reduction goals, consider having different approaches for accidents and near misses. They’re both incidents, but they should be handled differently. Obviously the number of near misses should be reduced, but it should be done in a way that does not discourage the reporting of near misses.

In conclusion, it’s easy to be cynical because there is a risk that good intentions designed to improve EHS performance may lead to unintended consequences. But the lesson isn’t that you shouldn’t bother to pursue EHS performance goals. Rather, strengthen the safety culture to make sure that there are no unintended consequences, and verify periodically that your goals are promoting the expected behaviors.

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