To avoid the BBS “blame game,” organizations must build Behavior-Based Safety programs on anonymity, root-cause analysis, and a non-disciplinary culture — transforming observations into learning opportunities rather than punishment triggers. In this blog series, we ask industry experts how to avoid the BBS ‘blame game’ to support the successful implementation of a Behavioral Based Safety (BBS) program. We have spoken with industry professionals Joseph Braun, EHS Manager at Ferrara Candy Company; John Peoples, Global EHS Manager at Huntsman Corporation; and Chad Rasmussen, EHS Manager at Cardinal Health to get an insider look at how to manage an effective Behavior Based Safety management program.
Behavior-Based Safety programs follow the philosophy that unsafe behaviors and attitudes are behind every workplace incident. No amount of protective equipment, safe-guarding, or elimination of hazards can protect workers as effectively as they can protect themselves through knowledge, education, and sound safety decision-making. Under ISO 45001:2018 and OSHA’s General Duty Clause, organizations are required to proactively identify and address behavioral risk factors — making a well-designed BBS program a critical component of any compliant safety management system.
Research consistently shows that human factors — including decisions, habits, and organizational culture — contribute to the vast majority of workplace incidents. What matters is not assigning blame, but understanding why unsafe acts occur so they can be systematically eliminated. It is a worker’s decision to engage in work that may be unsafe. It is the worker’s decision to address management about unsafe working conditions. It is the worker’s decision to notify OSHA or another governing body about conditions they have found to be unlawful. At the end of the day, it is the worker who gets injured, and they should do everything they can to be knowledgeable about what constitutes an acceptably safe working condition. Here we’ll take a look at how to, as Chad Rasmussen, EHS Manager at Cardinal Health emphasizes, prevent “the program from becoming a tattle-tale program.”
Workers Can Make the Right Safety Choices
One of the most important things you can do as a manager of a safety program is to provide your employees with an open and non-judgmental forum for expressing their concerns and offering their ideas on how to improve workplace safety. No one understands the hazards of a workplace better than the people on the floor every day. They will often have practical, cost-effective solutions — and may have already implemented some informally that can be scaled across the organization. By empowering workers to take ownership of their personal safety and the safety of their peers, you are developing what leading BBS frameworks call “Safety Leaders.” Under ISO 45001 Clause 5.4, worker participation and consultation are foundational requirements — not optional extras. John Peoples, Global EHS Manager at Huntsman Corporation says “People see that Leaders understand and are committed to a shared safety vision so those common beliefs, attitudes, and behaviors are consistently delivered to everyone.” This is one of the strongest outcomes you can achieve with a BBS program — inspiring people to inspire those around them to be vigilant, confident, and knowledgeable about the safety decisions they are making every day.
BBS Observations are for Learning, not discipline
Making your BBS program anonymous shifts focus away from the individual and onto the action and the environment. As Joseph Braun, EHS Manager at Ferrara Candy Company says, “All observations are treated as anonymous. Discipline and blame cannot stem from observation; they are used as teaching and learning tools only.” A common pitfall of the BBS “blame game” is treating observations as a mechanism to identify and remove unsafe workers — but this defeats the purpose entirely, because the root conditions that drove the unsafe behavior remain. Anonymous observations allow safety teams to focus on the root causes of unsafe behaviors: inadequate training, ergonomic hazards, time pressure, defective equipment, or poorly designed workflows. This is precisely the approach supported by OSHA’s Safety and Health Program Management Guidelines and the ISO 45001 standard’s emphasis on hazard elimination at the source.
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The program is not a tool to suppress injury numbers by discouraging reporting. It is not for identifying “accident-prone” workers and punishing or removing them. Behavior-Based Safety is most effective when used anonymously to identify the root causes of hazards within your workplace — and to empower and recognize workers for making positive safety decisions. Organizations that pair BBS observation data with a digital inspection and audit platform can track behavioral trends over time, close corrective actions faster, and demonstrate continuous improvement to regulators and insurers alike.
Check out previous blogs in this series and stay tuned for more!
Why You Should Include Behavior Based Safety in your Safety Management Program
How Do You Measure the Success Of A BBS Program?
Tips To Increase Participation, Buy-In, And The Effectiveness Of Your BBS Program
Frequently Asked Questions (FAQs)
What is the BBS blame game and why is it harmful?
The BBS blame game occurs when Behavior-Based Safety observations are used to discipline or punish individual workers rather than identify and correct systemic root causes. This undermines trust, suppresses reporting, and ultimately makes workplaces less safe — the opposite of a BBS program’s intent.
How do you keep BBS observations anonymous?
Effective BBS programs strip personally identifiable information from observation records before they are reviewed by management. Digital safety management platforms like Certainty Software can automate this process, ensuring that observations feed into aggregate trend analysis rather than individual performance records.
What regulations support a non-punitive BBS approach?
OSHA’s Voluntary Protection Programs (VPP) and Safety and Health Program Management Guidelines, as well as ISO 45001:2018 Clause 10.2 (Incident investigation), explicitly promote non-punitive incident reporting and worker participation. A blame-free BBS culture aligns directly with these regulatory expectations and supports stronger audit readiness.
How can technology help prevent the BBS blame game?
A dedicated audit and inspection management platform centralizes BBS observation data, enforces anonymity controls, and generates leading-indicator reports that highlight hazard patterns rather than individual behavior. This gives EHS managers the visibility they need to drive proactive corrective actions — without creating a culture of blame.
