Summary: Behavior Based Safety Accountability works best when observations are used to improve systems, coaching, and learning instead of assigning blame to workers.
To avoid the BBS “blame game,” organizations must build Behavior Based Safety Accountability into their programs through anonymity, root-cause analysis, and a non-disciplinary culture. In other words, they must transform 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 successful BBS implementation.
Specifically, 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. They provide an insider look at how to manage an effective Behavior Based Safety Accountability program.
Behavior-Based Safety programs follow the philosophy that unsafe behaviors and attitudes are behind every workplace incident. In fact, no amount of protective equipment or hazard elimination can protect workers as effectively as knowledge, education, and sound safety decision-making. Furthermore, under ISO 45001:2018 and OSHA’s General Duty Clause, organizations must proactively identify and address behavioral risk factors. As a result, a well-designed BBS program is 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. However, what matters is not assigning blame. Instead, the goal is understanding why unsafe acts occur so they can be systematically eliminated.
For example, it is a worker’s decision to engage in work that may be unsafe. Similarly, it is the worker’s decision to address management about unsafe working conditions. Moreover, it is the worker’s decision to notify OSHA about conditions they find unlawful. Ultimately, it is the worker who gets injured. Therefore, workers should do everything they can to understand 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.”
Behavior Based Safety Accountability Starts with Better Safety Choices
One of the most important things you can do as a safety program manager is to provide employees with an open and non-judgmental forum. Specifically, this means a space for expressing concerns and offering ideas on how to improve workplace safety. In particular, no one understands the hazards of a workplace better than the people on the floor every day.
Additionally, workers often have practical, cost-effective solutions. They may have already implemented some informally that can scale across the organization. By empowering workers to take ownership of personal safety and peer safety, you develop what leading BBS frameworks call “Safety Leaders.”
Notably, 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.”
Consequently, this is one of the strongest outcomes you can achieve with a BBS program. It inspires people to inspire those around them to be vigilant, confident, and knowledgeable about their daily safety decisions.
Behavior Based Safety Accountability Requires 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.”
However, a common pitfall of the BBS “blame game” is treating observations as a mechanism to identify and remove unsafe workers. This approach defeats the purpose entirely. Specifically, the root conditions that drove the unsafe behavior remain unaddressed even after the worker leaves.
In contrast, anonymous observations allow safety teams to focus on the root causes of unsafe behaviors: inadequate training, ergonomic hazards, time pressure, or defective equipment. Furthermore, poorly designed workflows often contribute to unsafe acts. This is precisely the approach supported by OSHA’s Safety and Health Program Management Guidelines. Similarly, the ISO 45001 standard emphasizes hazard elimination at the source.
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The program is not a tool to suppress injury numbers by discouraging reporting. Moreover, it is not for identifying “accident-prone” workers and punishing them. Instead, Behavior Based Safety Accountability works best when used anonymously to identify the root causes of hazards. Most importantly, it empowers and recognizes workers for making positive safety decisions.
Additionally, organizations that pair BBS observation data with a digital inspection and audit platform can track behavioral trends over time. As a result, they 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 systemic root causes. Consequently, this undermines trust and suppresses reporting. Ultimately, it 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 management reviews them. For example, digital safety management platforms like Certainty Software can automate this process. As a result, 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 explicitly promote non-punitive incident reporting. Similarly, ISO 45001:2018 Clause 10.2 (Incident investigation) promotes worker participation. Therefore, a blame-free BBS culture aligns directly with these regulatory expectations. Moreover, it supports stronger audit readiness.
How can technology help prevent the BBS blame game?
A dedicated audit and inspection management platform centralizes BBS observation data and enforces anonymity controls. Additionally, it generates leading-indicator reports that highlight hazard patterns rather than individual behavior. As a result, EHS managers gain the visibility they need to drive proactive corrective actions — without creating a culture of blame.
