Compliance policyJune 19, 2017
For management principles, the focus is now on the 3rd principle, compliance policy. Although rule setting and compliance belong to the discipline of process management, we can identify elements of social management through proper compliance. Compliance needs to be observed by a credible authority, but an overly rigid application of compliance can be at the expense of an organization’s learning capacity. An incorrect application even damages principle 1 (social safety).
No rules without compliance
A rule becomes a rule only if breaching it leads to consequences. This insight has led to a renewed trend in the field of safety management. When introducing a new rule, the corresponding sanctions are introduced simultaneously.
As there were too many rules, super rules were introduced—the Life Saving Rules. These rules arose from a deep concern about the most valuable asset: the human life. The introduction by Shell, the forerunner of this trend, was achieved through a big communication campaign with completely new icons. The entire management team from all levels was heavily involved from Day 1. Strong language was used to introduce the serious punishments corresponding to these super rules: violations of these rules could lead to sever warning or even dismissal.
The first effects
Social psychology has taught us that threatening with heavy sanctions at first leads to shocking reactions and increased alertness. Increased alertness is especially good for overall readiness and this has a positive effect on strengthening safety behaviors. Shell could proudly show that a major change took place. Shortly after the introduction of LSR, there was a sharp decrease in the number of fatal accidents. Many families of employees can be extremely grateful for the introduction of these rules without ever knowing it.
What is more logical than concluding that there is a relationship between threatening with sanctions, the compliance of rules and the achievement of a higher level of safety? Many other organizations follow Shell’s example and introduced their own version of LSR. The same or similar stickers appeared on many industrial sites and punishment was broadly used. Even the legal world adapted the sanctions accordingly. Courts accepted violation of such rules as a valid reason for dismissal when it was explicitly emphasized that an offence could lead to dismissal.
Imitation is no guarantee for success
The striking thing is that the positive effects that were visible at Shell were a lot less visible or not visible at all for their imitators. This is strange, because the rules are comparable as are the sanctions. What did Shell do differently that led to their success and not with their imitators?
An alternative explanation/ interpretation
From the perspective of Brain Based Safety, it seems justified that there is a relation between threatening with a sanction and the positive effects it has on safety. But the success of Shell could be caused by something totally different. After all, Shell used a well-organized communication campaign (Principle Priming). Above all, during the introduction a lot of focus was put on the visibility of the total management who showed personal commitment (Principle Example Behavior). 99% of the employees received a personal face-to-face introduction from first line supervisors and their managers. This could explain why other organization that tried to copy Shell’s way of working but without such a communication strategy and visibility of management, did not achieve the same results.
Undesirable side effects
In recent years, developments have progressed. In many organizations the effect of LSR has vanished, but the sanctions remain. These sanctions lead to undesirable side effects: employees are afraid to bring up near misses or dangerous behaviors. People are afraid that someone is picked to make an example of, while the real problem lies deeper under the surface. Only sporadically an incident is fully caused by the behavior of only one person. An incident usually reflects a weakness of the whole system. This is why employees question the justification of some sanctions. Once sanctions are perceived as unfair, they undermine the social safety of an organization (Principle Social Safety). The result is that employees tend to keep quiet. Openness can be seen as selling out your colleagues or your boss. Sydney Dekker refers to this as an “anxiety culture”.
This conclusion forces us to go back to the essence. We want to increase the impact and compliance of rules by creating a “just culture”. Perhaps an example of our daily life could clarify. Has anyone been able to get a rebellious teenager to do his or her homework with strong punishment? This hardly happens. What does help however is to sit down with each other and discuss concerns and severity of the matter and to try to find ways to deal with the problem. This is no different in the working environment.
Communication leads to strength
From a psychological perspective, a rule gains strength when a violation leads to communication more than sanctions. Communication can consist of sharing anger and personal concern. But when emotions are let loose the manager wants to understand with which intention the rule was broken. In rare cases where incidents are due to nonchalant or irresponsible behavior, punishment can be useful as a wakeup call. But in most cases, the violation will be due to the commitment of the employees’ attempts on achieving a desirable output for the organization.
Compliance also means investigating deviations
Instead of focusing on punishment, a better way for the manager is to focus on investigating why a violation occurred. A mistake is always an opportunity to learn. Why is it possible that a working environment is created in which the employee is seduced to gamble with his own (or someone else’s) safety to achieve an organizational goal (Principle Prioritizing)? The answer to this question could help the manager to improve his organization. The employee can in turn learn to understand his behavior (how could I be this stupid?) and from this insight be an example to his surroundings. This kind of investigation is a lot more powerful than handing out punishment.
The big difference between handing out punishment and investigating the intention of the “offender” is that in one case the problem is reduced to the smallest possible cause and nothing is learned. However, when violations are investigated and are seen as a phenomenon of the entire system, many people involved can learn and develop. With this way of working, people make themselves stronger and the world safer.