Is Your Stoplight Flashing?


2009 is behind us and for many it was a very difficult year. Since I last wrote, most of us have had holidays and returned to work. Unfortunately, a good number of our brothers and sisters are still out on the street. Peoria Journal Star Business Editor Paul Gordon gave his 2009 Business Person’s of the Year award to the 22,000 CAT workers worldwide who were tossed overboard for the good of Team Caterpillar. Thanks to the sacrifices paid by those honorees, CAT didn’t lose a single one of their 29 Vice Presidents or any Group President…wow, what a relief!


Did you see the photo of the D7E on front page of Journal Star in December? Could you tell from the picture that the workers who welded the frames in Building LL did not have a safe job procedure (SJP) for the first two-plus months the 7E was in production? Our members routinely get discipline for failure to follow the SJP to the letter (especially when something goes wrong, like getting hurt) so how could this have fallen through the cracks?.


More interesting still is the fact that there was a weld procedure for the job. Why would there be a welding procedure and no safe job procedure? A callous observer might infer that the lack of a SJP and the provision of a highly detailed welding procedure indicates welding the frame in the proper sequence using the correct parameters was more important than the safety of the person(s) doing the job—surely not!


Building LL is quite proud of their behavioral safety program (BS Safety). Since workers are required to perform mandatory behavioral safety observations, how would one be able to perform a behavioral observation without the SJP to determine if the worker were following the prescribed procedure? Even though there was not a detailed SJP, I’m sure those in the D7E frame area were checked to be sure they had safety glasses and ear plugs.


I wonder how the supervisor of the area was able to determine if the workers assigned to him were doing their jobs safely. Where were the management safety personnel, you’d think they would have caught this omission? What about the building manager? Was a safety Failure Mode Effects Analysis (FMEA) done on the job as required by CPS? Isn’t there some kind of sign-off sheet or inspection checklist that has to be completed before a job is released to production?  Hell, we’ve had UAW members given disciplinary time off for not filling out a lousy commodity sheet at the end of the shift. All things being equal, it would only make sense that a number of heads should roll because production work was allowed in areas with unidentified hazards and no documented safety procedures in place. It’s certain that no excuse would be acceptable if a worker had a lapse of this magnitude..


BS Safety is not new. In fact, it is one of the oldest and most outdated approaches

to health and safety. The basis of the BS Safety movement came as the result of a study done by Travelers Insurance Investigator H.W. Heinrich in the 1930’s and 40’s. 12,000 insurance company accident claims and 63,000 injury and illness records submitted by plant owners were studied and conclusions were drawn based on corrective actions recommended by the supervisors. Who do you think those supervisors blamed for the injuries and illnesses—yes you!


Although Heinrich’s flawed study has led proponents of BS Safety to claim that 76% to 96% of all injuries and illnesses are caused by unsafe acts, the only true statistic is that 100% of all workplace injuries and illnesses involve worker exposure to a hazard. If there is no worker exposure to hazards, there are no injuries or illnesses.


The other problem for workers subjected to BS Safety programs is the focus on reducing downstream safety metrics, particularly Recordable Injury Frequency (RIF) and Lost Work Days (LWD’s). This focus leads to measures being taken that lead to non-reporting or under-reporting of injuries. If you don’t know if you have BS Safety or not, ask yourself if you have or heard of any of the following:


·        Being told to stay out of the line of fire

·        Being told to keep your eyes on task

·        Watch for proper body position

·        Being told to keep your mind on task

·        Being sure to use your PPE

·        Safety Stoplight

·        Contests for days without injury

·        Injury Discipline Policies


How many of the items listed above remove you from exposure to hazards? None of them do, in fact, all of those issues are covered by OSHA Standards and be careful isn’t one of them.


The policies listed above simply allow you to continue to work in hazardous situations. “Staying out of the line of fire” and “Keep your eyes on task”, is used in place of effective machine/equipment safeguarding and design (either the Machine Guarding Standard or Lockout/Tagout apply). “Proper body position” has become a replacement for a good ergonomics program and well-designed work stations (This is covered by 5(a)(1) the General Duty Clause). “Personal Protective Equipment” becomes a substitute for noise control, chemical enclosures, ventilation, and toxic use reduction (the Occupational Noise Exposure Standard or the Air Contaminants Standard apply).


Furthermore, any contest that measures days without injuries between workgroups or individuals provides incentive not to report injuries or illnesses. Injury discipline policies also drive under-reporting. These BS Safety concepts do not improve safety; they shift the employer’s obligation for safety to the workers and improve metrics performance by encouraging under-reporting.


As a sadistic twist to the injury incentive/discipline policies, our benevolent employer makes reporting injuries a condition of employment. Talk about having your cake and eating it too. On one hand, if you don’t report an injury, you’re rewarded. On the other hand, if you don’t report an injury, you’re disciplined and if you do report an injury, management will find a way to blame you and you’ll be disciplined. Any way you turn management’s message is clear, don’t report your injury.


In the past several weeks, we’ve had brothers and sisters disciplined for reporting and not reporting (in what management considered an appropriate time frame, which in this case was as soon as the worker knew he was hurt, but that wasn’t soon enough).  In one of our business units, a group grievance was filed because during a start-up meeting, a supervisor threatened to discipline anyone who reported an injury. This is illegal! OSHA 1904.36 says reporting an injury is protected activity. If you receive discipline, coaching, reassignment, don’t receive a prize, or any other adverse action because of being hurt at work, file a grievance and ask for your UAW Safety Representative.


Is there is a Safety Stoplight in your facility? What do the flashing lights stand for? Does your Stoplight count the number of days without an OSHA recordable injury or lost time injury? Does it flash yellow when there’s a First-Aid case? Does it flash red for a recordable or lost time injury? Does the Stoplight in any way reduce the hazards to which you are exposed?


I know of a person who tripped over a board sticking out from a pallet, fell and broke their arm. This person didn’t want to report their injury because they knew it would turn the Safety Stoplight flash red and cause the numbers of days counter to go back to zero—that’s sick!


So given all the problems related to BS Safety, why is it so popular? First, it shows new management commitment to safety. I can appreciate this sentiment, misguided as it may be; because management knows what they are doing isn’t getting them where they want to be. Additionally, management feels that by spending a lot of money, it indicates their level of commitment.


A recent 6Sigma project at the Tech Center had the team choose between four behavioral safety programs. This was done without the input of the union safety committee, so it was like having to choose between four pigs—at the end of the project, you ended up with a pig! No matter, it’s going to be implemented and the price tag for this so-called data-driven project implementation will be in excess of $1,000,000 (1100 people attending between 7.5 to 9 hours of training at an average burden rate of $100/hour).


BS Safety is supposed to increase worker involvement. I’ll concede that involvement to a point, but is either a welder observing an assembler or a machinist observing a heat-treat operator an expert at the job they’re observing? How would either one know if what the person they were observing was doing was safe or not?


Unfortunately, many workers and victims fall prey to thinking they were the sole cause for an injury or illness, but that’s not the whole story. I do admit that worker behavior can be one of the many root causes of injuries and illnesses, but it is never the only one. 


The BS Safety theory implies that it is not hazards on the job that cause injuries and illnesses, but it is the behavior of those exposed to the hazards (victims) that cause injuries and illnesses. Workers are seen as the problem and not as the solution so the best way to manage this problem is to change the worker, not address the hazard.


To assist management in addressing the hazards, let’s suggest our own version of behavioral safety that will address management’s behavior. Whenever a worker is disciplined for a safety infraction, their supervisor should also be disciplined in kind for allowing the worker to believe whatever happened was acceptable. For major violations, the supervisor and their boss should be disciplined.


Regarding the safety incentive programs, they should be based on the number of hazards identified and addressed using upper level controls like engineering or elimination. No hazard can be reported without a solution.


Finally, what to do with all of those Safety Stoplights? I think we should use the stoplights ability to blink red to indicate a hazard has been identified by the workers/union and how many days it has been unaddressed since it was reported. To me, that would be a fitting end for an idea whose time has come and gone. I hope your light is flashing green.


Steve Mitchell.


 To learn more about BS Safety and Caterpillar’s OSHA history, go to