We discipline for the behavior - NOT for the result/outcome of that behavior.

This is never more true in safety-related events. When we discipline a worker for an injury for not wearing their PPE. We just set the standard for NOT WEARING PPE! So the next time a worker fails to wear their prescribed PPE, regardless of whether they were injured, the discipline is the same for the worker who was injured.

Do we want to set a standard of discipline in the journey to safety excellence?

Accountability is a necessary element in establishing a culture of safety; however, too much emphasis on holding those closest to the risk more accountable for their ACTIVE FAILURES than those farther away from the risks and their LATENT ORGANIZATIONAL FAILURES is no way to build trust and credibility in the safety efforts.

For example:

Last year, we performed one of our deep dive PSM/RMP audits over two weeks at a large facility.  Over those 10 days, we learned of many occasions where operators and maintenance personnel were disciplined for "safety infractions."  The management team seemed almost proud of their actions as to them it showed how serious they take safety.  Yet over those same ten days, we identified serious failures by managers to follow PSM/RMP programs and protocols and making decisions that flew in the face of risk for the name of meeting budgets.  Not only did these four (4) managers not receive any discipline, but they also got promoted to higher-level jobs.  Two are now in corporate-level technical roles in the engineering function to specifically manage process safety matters.  One is now a plant manager at a smaller facility, being groomed for a more prominent role. 

Rest assured, the workforce, especially those who feel they were wronged with their discipline over the past several years, are very aware of these actions. 

One of these managers had multiple failures that will come back to be the defense of those he/she disciplined.  For example, a team of four (4) operators was disciplined for "not following procedures"; however, the two (2) operating procedures involved in the release were three (3) years out of date from their "annual certification," and the safe work practice was five (5) years out of date (based on internal document control annual review and approval policies/practices).

These disciplinary actions mock any attempt to perform a fair and factual causal analysis and, even worse, erode credibility in the safety management system and trust between those who do the dirty and dangerous work and their supervisors.  This is how Human and Organization Performance (HOP) can be used to BALANCE the fact that we ALL MAKE MISTAKES; LEARNING from those mistakes is much more important than holding certain groups or individuals accountable.

However, if there is a different standard for active vs. latent organizational failures, there will be a massive wedge between the groups that MUST work together to manage safety. 

Most of us can admit that holding someone accountable for not following a procedure management failed to review and certify annually is a bit rich.  In terms of discipline for management personnel, it does NOT matter if the procedure was "accurate" at the time of the event; it is ALL about meeting the expectations of the process safety management system and LEADING BY EXAMPLE. Suppose we need to discipline the operators for failing to follow the SOP. Why would we not feel the need to discipline the manager for not following the Process Safety Management System requirements to review and certify those SOPs?  Of course, the "causal analysis" for this event never identified the "certification" failure, and management believes it had no impact on the outcome of the event; however, the causal analysis should have identified this failure and addressed this failure rather than wait until an out of date SOP contributes to or is the root cause of an event.

Remember, in PSM/RMP, these annual certifications are a government MINIMUM, so failure to satisfy these minimums used to embarrass management teams; today it seems to be viewed as a minor blimp in the management of process safety.  Trust me, it is not a minor blimp and it is shining a bright light on the famous saying...

Rules for thee, but not for me

And this is NO WAY to build TRUST and CREDIBILITY in safety with the men and women doing the dirty and dangerous work.