The Rule Mill
Rules are so easy to make. So easy that they proliferate and the safety offices that produce them are often accused of being a “Rule Mill” because they continuously produce their “rules-of-the month”. Why do we create so many rules? One particular ‘cog in our mill’ (pardon the pun) that causes us to create rules are incidents. When we suffer an incident we want to use every tool in the arsenal to keep it from happening again. And one of the simplest tactics is to create (yet another) rule. We may even add new rules when we receive minor injury or close call reports. Do you think adding all these new rules encourages folks to report their minor injuries, close calls, and concerns? The answer is “no”.
Most, if not all, of us don’t like rules that become overly restrictive. Our employees are the same way. In my many discussions with the workers of the world I’ve heard many comments about rules.
They are made in a vacuum and don’t fit the work I do.
They are just created as a C.Y.A. exercise so the lawyers are happy they can pin one of us to the wall when an incident occurs.
These rules require me to add more and more layers of PPE to the point I can’t move.
Instead, employees prefer discretion over the way they do their tasks. And, to be frank with you, without this discretion employees cannot help you find new ways to do their tasks safely. If you overly restrict their behaviors with rules you also run the risk of restricting safety innovations.
As easy as rules are to make they are just as hard to enforce. Rules are just antecedents. Students of behavior science know that antecedents only direct behavior, they don’t motivate. I’m fond of calling most antecedents, like rules, “exhortations” (translation = begging). Antecedents need to be connected to consequences to be powerful. Incidentally, in behavioral science we use the term “rule governed behavior” to describe how we reflect on the possible consequences of our actions when we come in contact with environmental antecedents.
Rules, therefore, need to be related to something else to be effective. Often, this “something else” is the threat of discipline. Discipline doesn’t work unless the disciplinarian is present and even then the disciplinarian may, and often does, look the other way...because they find the rules cumbersome as well. So is there a better way?
New Rules for Rules
Rules are designed to keep us safe and are made by well-meaning folks thinking through potential risks in the face of hazards. In the end, rules are good for all of us. So the pertinent question is “how do we get people to follow the rules?”
A good friend of mine and I were traveling around the world assessing the safety culture within large mines in a multinational mineral resources company. We saw a lot of variance between this company’s sites but one consistent finding was that the mine’s mill always had the most negative safety culture associated with the worst safety incident rate.
For those of you unacquainted with mining, there are two main areas of operation. There are the folks that drive down into holes that have been dug out through explosives and mega-shovels. You can see hazards everywhere as you ride down into these pits. Respecting the rules in the pit can keep you from being buried, crushed, or otherwise blown to bits.
After the ore is exposed, dug, and brought to the surface it is dropped on a conveyer and carried to the mill where huge grinding machines tear up the rock until its processed into the end product. The mill consists mostly of operators and maintenance folks doing dirty, dusty, and loud work. When equipment in the mill goes down, all production stops and there is hell to pay.
One of the questions my friend and I were asking in confidential interviews of employees was “do your fellow employees follow the safety rules?” We had anonymous survey responses from the site’s different departments that gave us an idea of the responses to come. The answer to this question from folks working the pit was generally “yes” with some complaints about how the rules slow down production or are a pain in the ass. However, without fail, across the world, the answer from the mill was emphatically “no”.
This was the case until we visited a site outside of Perth Australia where mining is a way of life. We had spent a pleasant morning interviewing the pit employees who painted a picture of a pretty good safety culture. We even took a tour of the property which, to these Americans, was like a safari with the kangaroo, brown eagles, and other indigenous animals of the “down under”. But our afternoon was to be with the mill employees and we knew our pleasant day was ending.
We found ourselves across a lunch table from 5 guys from the mill as we pulled out their injury and survey data. To our amazement, they had one of the best safety records we had seen in this company and their safety culture survey data was equally amazing. Compared to the company norms, they were in the top percentile in employee perceptions of everything safety culture.
My friend and I were skeptical. This skepticism heightened when we asked our stock question, “do your fellow employees follow the safety rules?” and their answer was “YES”. My friend replied with a scrunched face, “Really? You know this is confidential and no one can get in trouble… so you can tell the truth.” Their reply, with straight faces, was “Yes”. We knew this was highly unlikely for a mill setting.
Not believing a word of this, my friend leaned forward and said accusingly “we’ve been to almost every one of your company’s sites, all over the world, and no one, not one person interviewed from the mill said they always followed the company safety rules. Yet… here you are looking us in the eyes telling us that you do? Why should we believe you? Why would your mill be so very different and follow rules?”
I still remember their puzzled faces staring back at us in disbelief. There was an awkward silence until one of them ever-so-calmly replied “Why would we break the safety rules? We created them.”
In all my years studying behavioral safety, this had to be the most profound thing I had ever heard.
They went on to tell us of how their safety manager would meet with them quarterly, 30 minutes a shot, and help them create and revise rules around the mill’s hazards. We found out a couple things: a) Their rules were nimble and allowed for discretion when the situation didn’t line up; b) They constantly were trying to find new ways to do tasks safer, and get this, c) we found out their rules tended to be more stringent than rules created by managers at other sites. Most importantly, we learned that their rules were followed and the workforce was safer… the data proved it.
Rules turn us into police officers who go “fishing for faults,” compelled to “catch” people breaking the rules. I’ve seen safety managers and operations supervisors intoxicated by this power. When you view the workplace through the “lens of rules” then you often fail to see the real context for behavior.
But when I think about that crew in the mill exactly on the other side of the globe from my home I think a new approach to safety rules are in order.
And the answer is as simple as asking a question.