First, I am not fully bought into the “psychological safety” concept. For me, it is just how we should manage safety, so I am not a “labels” kind of safety pro. However, I get a lot of questions about HOP and Psychological Safety, and the one place we could begin to utilize these approaches is in our “annual periodic LOTO inspections.” Let me explain…
In my entire career, everywhere I have managed, and with almost every client I work with today, LOTO has been elevated to a “Life Critical” safe work practice (SWP). This means it gets managed AND ENFORCED very differently from other, less significant SWPs. This means that with LOTO, a single error/mistake/violation could result in the termination of those involved. Add the fact that in my early days in the 1990s, we were all about the “Active Failures” in our investigations. Looking back on many of these disciplinary cases, I can think of more “organizational failures” that played a role in these cases than “active failures.”
These two (2) simple facts led to a “LOTO Underground” environment; hence, any errors/mistakes that occurred (without injury) were pushed underground for fear of losing one’s job. Fear was so high that our Periodic Inspections were a pencil-whipping exercise. Authorized employees told and showed the inspectors what they wanted to hear and see, knowing that that is not how it happens. This was a failure of epic proportions for everyone!
While working for BFGoodrich Specialty Chemical (2000-2004), I got to work for this Plant Manager, who was a former Safety Pro (CSP) when he was growing up in BFG. Jim was an incredible teacher of safety management. He had been out of the profession too long to be a compliance guru, but his SMS knowledge and approach were second to none. He called me into his office one day to discuss some observations from a walk-through earlier in the day. He was concerned that our periodic inspections were failing to identify any opportunities to improve, yet every time he walks through the plant, he can almost always find a LOTO concern. So we created a “Discipline-free bubble” around our periodic inspection, much like we do with our Behavior-based Safety observations.
This meant that when a Supervisor, Superintendent, or Manager was in the midst of a periodic inspection, any error, mistake, or routine/situational violation identified would be discussed without any disciplinary action. Now, “Exceptional Violations” are dealt with harshly, but these are very rare. Within a couple of weeks, we began to learn of incorrect equipment-specific procedures, a lack of LOTO supplies, and far too many questions (that the Supervisor, Superintendent, or Unit Managers were unable to answer), etc.
Jim welcomed all these issues; he saw them as progress. He always said, “We can’t fix what we don’t know is broken,” and this data was instrumental to us tackling LOTO as a major project the following year.
So, I suggest we embrace the HOP principles and Psychological Safety within our Periodic Inspections. We are just sticking our toes into these approaches, but it is a perfect opportunity to lessen the fear factor around LOTO. We ALL make mistakes; embrace this fact, and let’s LEARN from our mistakes to IMPROVE a life-critical SWP.
