Special Topics in Safety Management

OSHA Compliance: Does it INTERFERE With Safety?


OSHA spends millions to promote safety. But some say their efforts produce just the opposite by diverting resources to compliance that could be used in injury prevention. Which side of the controversy are you on?


OSHA is one of Washington’s most established agencies, with an extensive program, a half-billion dollar budget, and 2,000 employees, all in the name of creating workplace safety. Wonder how they’d feel if they knew their activities might actually be interfering with safety?


Those holding this view believe that while safety managers are out dealing with compliance issues, they are not dealing with injury prevention.



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That’s because OSHA regulations largely center on equipment and system faults and failures, which cause a minority of accidents. All the while, the agency does not deal effectively with the cause of the great majority of workplace injuries—simple human error.


A Different View


Seeking different perspectives, we didn’t have to travel very far. Randy DeVaul is a long-time safety consultant, based in Westfield, New York, who also produces BLR audio conferences.


He partially agrees with the prior author’s point of view, saying that indeed safety management can be diverted from its primary purpose by compliance needs, but that whether or not it happens doesn’t depend on OSHA. It depends on the culture of the company involved.


“In an environment that has a compliance-driven safety culture,” he says, “I have had to spend time justifying safety measures to upper management, and frontline supervisors, based on the ‘gospel of OSHA.’ If it wasn’t in the book, it was a hard sell, to say the least.


“The bottom line,” he continues, “is whether the organization views safety as a priority or as a value. A priority changes based on circumstances [such as an OSHA compliance drive]; a value remains constant.”


This differentiation comes from DeVaul’s concept of “Performance Safety,” which he first presented in a conference paper he wrote in 2001 and then expanded into a book called Performance Safety: Above and Beyond (Filbert Publishing).



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DeVaul developed his concept as an answer to the popular notion of behavior-based safety, which postulated that it was largely wrongful worker choices—such personal decisions as whether to wear or not wear PPE, or whether or not to take the time to lock out equipment before servicing it—that were responsible for injuries.


“Behavior alone cannot fully create or cause injuries,” DeVaul writes, because “the choice made by a worker is not always a reflection of his behavior. It includes the ‘behavior’ of the manager and the safety expectations of the company.”


To deal with all the factors involved, DeVaul’s concept looks at three key elements: practices, procedures, and processes. We’ll look at these elements as well, in tomorrow’s Safety Daily Advisor.


Meanwhile, what’s your opinion? Is there a built-in conflict between workplace compliance and safety? Do compliance activities drain the time and energy you need to make your workplace safer? Use the Share your Comments button and let us know.

1 thought on “OSHA Compliance: Does it INTERFERE With Safety?”

  1. This is an interesting topic. I would be hesitant to call the relationship between compliance and safety a conflict. It would be wonderful if everyone always worked safely, employers cared, training was done regularly and was effective, accidents never happened and all without regulatory enforcement/compliance back-up. But, in real life even with the many employers and employees who truly care and do a great job with workplace safety there are many more who do not. As culturally diverse human beings, our differences, needs and priorities, personnally and business wise are not measurable. Business NEEDS Safety Compliance entities to exist in todays society. Maybe we should call the relationship Symbiotic (a mutually beneficial relationship?)

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