Robert Emery, DrPH, CHP, CIH, CBSP, CSP, CHMM, CPP, ARM Vice President for Safety, Health, Environment & Risk Management

The University of Texas Health Science Center at Houston Professor of Occupational Health The University of Texas School of Public Health Robert.J.Emery@uth.tmc.edu

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Define “ethics”

Review and discuss the elements of the

ABIH/CBSP ethics codes

Define “dual loyalty” as it applies to

safety professionals

Describe “safety culture”

List examples of ethical decision making

tools that can be used to help address

issues with ethical consequences 2

“a set of moral principles or values”

“the principles of conduct governing an individual or group”

“conforming to accepted professional standards of conduct”

› “If the situation involves risk, then it involves

ethics” Dr. Lawrence Whitehead, UT SPH

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Be honest -- have you ever read either

the ABIH or CBSP ethical codes of

conduct?

› A. Yes

› B. No

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Responsibilities to ABIH, the profession,

and the public

› Comply with laws, regulations

› Provide accurate and truthful

representations regarding certifications

› Maintain security of exam information

› Report apparent violations

› Refrain from public behavior that is in violation of professional, ethical or legal

standard 5

(Abbreviated – for full document see: abih.org)

Responsibilities to clients, employers, employees, and public › Deliver competent services with objective and

independent professional judgment

› Recognize your own limitations

› Make professional referrals

› Respect confidentiality

› Properly use credentials

› Provide truthful and accurate representations

› Recognize and respect intellectual property

› Only affix seal to own or supervised work

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Conflicts of interest › Disclose to clients and employers possible

conflicts

› Avoid conduct that could result in a conflict of interest

› Assure that a conflict of interest does not compromise legitimate interests of a client, employer, employee, or public

› Refrain from offering or accepting payments, gifts in order to secure work or influence judgment

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Word cloud of ABIH Code of Ethics, as produced by Wordle.net

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Word cloud of BCSP Code of Ethics, as produced by Wordle.net

Industrial

Hygienist/Safety

Professional

Workers

Company

Supervisor

To whom does the Industrial

Hygienist/Safety Professional within an

organization owe primary loyalty?

› A. the workers

› B. the organizational leadership

› C. both

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Industrial hygiene and safety programs within an organization have simultaneous obligations, both explicit and implicit, to the workers and to the organization

When these loyalties are incompatible, can result in significant ethical challenges

A key consideration: does an environment of trust exist?

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Recently published study suggests possible link between chemical exposure and specific type of cancer

Chemical is used at your facility

Develop sampling strategy, which consists of personal samplers on certain individuals › Do you tell them why you’re sampling?

Non-sampled workers in same area want to know the results › Who do you/can you share personal sampling results with?

› How would you go about doing this?

› Could this situation be managed differently to avoid ethical dilemmas?

› What if no legal or suggested limit currently exists?

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Disagreement amongst

experts

Lack of communication, coordination amongst

risk management

organizations

Inadequate risk

communication skills, actions

Lack of exposed

person participation

Apparent mismanagement or

neglect

History of distortion,

secrecy

See: Covello and Sandman 2001

Applying a lesson from business

In contract negotiations, accountability, not

trust, is the dominant value

Accept the obligation to prove contentions to

critics, using methods such as third party sampling, analysis, oversight, or audits

By relying more on accountability and less on trust, safety programs can become more trustworthy

See: Covello and Sandman 2001

Within your organization, are workers

able to speak freely to management

(and be heard)?

How would you know?

Does an absence of voiced concerns

mean there are none?

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If a typical worker at your facility saw a

co-worker doing something unsafe, he

would:

› A. Ignore it

› B. Approach the worker to stop it

› C. Notify the worker’s supervisor

› D. Notify the safety department

› E. Notify the regulatory agency

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Heinrich’s Ratio n = 75,000 accidents

1 major injury

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minor injuries

300 near miss events with no injuries

Historically applied in settings where

the top event was:

› Rare, but

› Catastrophic

Classic example:

› Airline industry

Organizational commitment Worker education – full involvement

encouraged Simple method of reporting unsafe acts or

conditions: “things that almost happened” › Note: may be acute or chronic, existing or evolving

conditions

May be anonymous – no repercussions for reporting

Investigation Intervention Feedback

Near miss reporting systems necessarily rely on open communications between workers and supervision

How workers interact and respond to supervision is critical

Key question: are the workers truly free to question?

Or are we in a situation of “organizational silence?”

Study by Stanley Milgram

Interest stemmed from Nuremberg Trials after WWII

Goal: to understand how people are affected by authority

Study participants to teach a student

Variable electrical shocks provided when errors occurred

Students actually actors who faked errors and being shocked

Authority figure provided instruction to study participants

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Wrong

Answer!

Zap him! Person portraying a study participant, but actually an actor

Unwitting actual research subject, relaying commands and applying electrical shocks if wrong answer given

Supervisor

63% of study participants provided shocks to students knowingly above the lethal level

Although the study is now noted today for its ethical problems, it did reveal issues inherent to certain organizational environments

Organizations must hold safety as a core value, visible to all

Need to encourage input through word and deed –do we say one thing and do another?

Eliminate even the notion of intimidation – acknowledge and reinforce positive acts

Actively solicit input, listen, act, respond

Many definitions exist, most exhibit similar themes such as

› “the attitudes, beliefs, and perceptions shared by natural

groups as defining norms and values which determine how they act and react in relation to risk and risk control systems” (Hale 2000)

› “Culture” (a noun) is linked inextricably to “behavior” (a verb). Culture can’t be directly measured, but behavior can. Behavior, good or poor, can be an indicator of culture “Safety Climate” a snapshot indication of overall “Safety

Culture”

› In short: safety culture is how people behave when no one

is looking

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U.S. Chemical Safety Board

› Investigation into 120 lab accidents – noted

absence of culture of safety

› Deepwater Horizon accident noted to be similar

to Texas City Refinery event – absence of culture

of safety

U.S. Nuclear Regulatory Commission

› Focus on safety culture at reactors

American Board of Industrial Hygiene

› New ethics continuing education requirement

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Consider this paradox: Addressing the most

frequent workplace injuries experienced by an

airline – namely injuries to baggage handlers – in

no way provides assurance that a plane crash will

not occur

Such assurance is achieved only when everyone in

the organization is attentive to safety at each step

of the process – particularly in highly complex risk

settings See: Prof. Andrew Hopkins remarks in US

CSB video “Anatomy of a Disaster”

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Catastrophic Event

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Catastrophic Event

Safety

Culture

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Catastrophic Event

Safety

Culture

Individual

Ethical

Decision Individual

Ethical

Decision

Individual

Ethical

Decision

Individual

Ethical

Decision

The existence of an EH&S program, while important, does not ensure a viable safety culture

A true culture of safety requires commitment across the organization – with a particular emphasis on the front line supervisor as they are primarily responsible and accountable for the safe conduct of workers and operations

› But are the front line workers equipped with the tools to

make ethical decisions regarding safety?

Important for EH&S to function as a role model and in a service capacity, perceived as providing a collegial and valuable service to the organization

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Safety’s focus › Hot works permit, portable fire extinguisher, fire

watch

› Protective equipment for eye’s lungs, skin

› Curtains, barriers

› Confined pace, elevated work surface

But was the weld done correctly? How do we

know? › Welder proficiency, professionalism

› Knowledgeable supervisor who verifies work

› Worker empowered to voice concerns

› Management commitment/support

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“Many of the definitions of safety culture present a view of workers having a shared set of values and beliefs regarding safety”

“However, the presence of subcultures within an organization suggests an absence of a cohesive safety culture”

“Therefore, it is questionable whether a culture change program can be designed for any large organization without taking into account the subcultures in place, how they interact and the power relations between them”

CSHEMA’s pilot work on measuring safety climate on campuses suggests recognition of safety performance (both good and bad) warrants attention

Pidgeon, 1998

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Gutierrez, et al. In revision

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1

2

3

4

5

Perceptions of Risks Being Managed

Employee's Safety

Commitment

Administration's Safety

Commitment

Department and Supervisor's Commitment

Recognition of Safety

Performance

Sa

fety

Cli

ma

te

Safety Climate Dimensions

Figure 2: Five Dimensions of Safety Climate (Means and Standard Deviations) for the Five Universities on a Five Point Likert Scale†, n=971

Institution 1 Institution 4 Institution 2 Institution 3 Institution 5

very low

perception of

safety†

low

perception of

safety†

neutral

perception of

safety†

high

perception of

safety†

very high

perception of

safety†

Real culture change requires a long term view and

commitment

Not an engineering solution – it’s an organizational

solution

Recently published report on a grassroots led,

management supported change at a major utility

that took 9 years to fully implement

Simon and Cistaro, Prof Safe April 2009 37

Principle

› Autonomy

› Non-maleficence

› Beneficence

› Justice

› Truth-telling

› Promise-keeping

Duty

› Respect self governance

› Do not inflict harm on others

› Promote the good of others

› Give others what is owed or due them, give others what they deserve

› Disclose all relevant information honestly and intelligibly, do not intentionally deceive

› Be faithful to just agreements, honor contracts

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Junior pipefitter notices what appears to be excessive corrosion within a critical pipe, but supervisor says sign off on it. Within your organization, what would the junior pipefitter do?

a. Sign off as instructed

b. Ask why is it ok to sign off

c. Refuse to sign off

d. Report to the company?

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Contractor junior pipefitter notices what appears to be excessive corrosion within a critical pipe, but supervisor says sign off on it. Within your organization, what would the contractor junior pipefitter do?

a. Sign off as instructed

b. Ask why is it ok to sign off

c. Refuse to sign off

d. Report to the host company?

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Budget constraints have resulted in reduced workforce, placing more demands on remaining workers. Impossible to do all required maintenance. Within your organization, what would the front line workers do?

› A. keep quite and do the best they can

› B. voice concerns to supervisors

› C. voice concerns to management

› D. voice concerns to regulatory agencies

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How much longer should this

presentation last?

› A. Stop now – I can’t take any more

› B. A bit longer, but please wrap up soon

› C. Please don’t stop

› D. Too late, I’m already asleep

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1. Establish a sense of urgency

2. Create a guiding coalition

3. Develop a vision and strategy

4. Communicate the change vision

5. Empower broad-based action

6. Generate short-term wins

7. Consolidate gains and produce more change

8. Anchor new approaches in the culture

Kotter, 1995

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Instilling a true culture of safety is a long term process requiring commitment and involvement at all levels of the organization

The issue of ethical decision making that leads to a culture of safety goes far beyond the traditional boundaries of typical safety programs

Safety can seize the leadership role in educating the organization about the need for ethical decision making at all levels to instill a true culture of safety

It is our professional obligation to do so!

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American Board of Industrial Hygiene, Code of Ethics. Available at: http://abih.org/sites/default/files/downloads/ABIHCodeofEthics.pdf

Covello, V. and Sandman, P. Risk communication: evolution and revolution. In Wolbarst A. (ed) Solutions to an Environment in Peril. Baltimore, MD: Johns Hopkins University Press (2001): 164-178

Gutiérrez, JM, Emery, RJ, Whitehead, LW, Burau, KD, Felknor, SA. A multi-site pilot test study to measure safety climate in a university work setting. In revision.

Kotter, J. Leading change: Why transformation efforts fail. Harvard Business Review. PN4231, March-April; 59-67. 1995.

London, L. Dual loyalties and the ethical and human rights obligations of occupational health professionals. Amer J Industrial Med 47:322-332, 2005.

Patankar, MS, Bown, JP, Treadwell, MD. Safety Ethics: Cases from Aviation, Healthcare and Occupational and Environmental Health, Ashgate Publishing 2005.

Pidgeon, NF Systems, organizational learning, and man-made disasters. In A. Mosleh and R. Bari (Eds.) Proceedings of International Conference on Probabilistic Safety and Management - PSAM IV, London, Springer-Verlag, 2687-2692, 1998.

Pidgeon, NF Stakeholders, decisions and risk. In A. Mosleh and R. Bari (Eds.) Proceedings of International Conference on Probabilistic Safety and Management - PSAM IV, London, Springer-Verlag, 1583-1590, 1998.

Simon S, Cistaro PA. Transforming Safety Culture: Grassroots-Led/Management-Supported Change at a Major Utility. Prof Saf April 28 -35; 2009

US CSB Anatomy of a Disaster (video) Available at: http://www.csb.gov/videoroom/detail.aspx?vid=16&F=0&CID=1&pg=1&F_All=y

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I appreciate the opportunity to speak to you today.

Your comments and questions are welcomed!