This article by Ray Prest was orginally published in the
October 2023 issue of Occupational Health & Safety
OSHA might have only been legislated into existence in 1970, but the concept of workplace safety is at least a few thousand years older. In fact, the central concepts of incident prevention — risk and hazards — can be found in the ancient Greek term “rhizikon” and the Latin term “risco,” both of which refer to reefs and other potentially dangerous obstructions lurking below the water’s surface.
As author Astra Taylor says, the term was “used by sailors and traders navigating treacherous routes, [and] risco conveyed the prospects of a venture’s success or failure and degree of danger.” Success and safety, failure and hazard, all rolled into one word that, over the years, morphed from a maritime reference to a signifier for a whole host of metaphorical shoals.
Most people now think of risk in terms of likelihoods and probabilities. Maybe we’ve all been conditioned by playing Yahtzee as kids, or by hours spent watching the odds flash across the screen during the World Series of Poker. For many, risk is now a term that heavily connotes chance and cold, hard probability. But hiding in the word “risk” is a sense of real, tangible danger.
This is an article about HazCom. At its most basic level, HazCom is about making clear what something is rather than what workers think it might be. It’s about showing that a hazard is unavoidably near and that the likelihood of encountering it and the potential harm it can cause is, if not the same thing, at least intertwined.
Yes, this is an article about HazCom, and it’s also about shifts in the meaning of words and the unavoidable fog of ambiguity. The term “risco” was useful to sailors because it took something that was hidden and made it more conceptually visible. Utter the word on a ship, and everyone understood that there was a big pointy rock that might damage the boat. Because risk is often shared in a workplace, every sailor knew that risco affected them all.
HazCom works in the same way: a label makes clear that a danger is present, out of sight but nearby, and explains the need for caution. If there is an incident with hazardous materials, it could potentially endanger everyone in the surrounding area.
Ask any experienced sailor, and they’ll pile on all sorts of adjectives about the open sea — it can be majestic, awe-inspiring, and sometimes dangerous. Often, it’s also very boring. Stare at the water long enough, and it can feel like watching paint that never dries. Suddenly, the water seems like a nondescript feature in a nondescript landscape, even though it’s just as deadly as ever. Very real hazards can stop appearing dangerous. And if you’ve been in open water for a long time, it can become easy to forget just how cautious you have to be in shallower areas.
The same can be said about HazCom labels. When workers have to handle the same materials every day, the relentless grind of familiarity can turn people’s attention to danger into dust. And then the hazard seems much less hazardous, even though risk is just as present as before. The words on the label say the same thing every day, but after a while, they become both literally and metaphorically less legible.
Workers become more apt to overlook them and, when noticed, more inclined to ignore what they have to say. And then the hazard is suddenly ambiguous, in that it’s open to multiple interpretations — there’s what the safety data sheet says, and then there’s what workers remember (or don’t remember) it saying. You can’t blame someone for making a mistake; people are naturally fallible and captains need to offset the prevailing winds of human error by trimming the sails with clarity, context, and effective communication.
The risk of HazCom incidents depends on a workplace’s ability to make risco — the physical hazards that are unseen but close at hand — more visible and understandable. Putting it on a HazCom label or a nautical map isn’t enough.
In Six Leadership Skills for Improving Safety Climate: a Human Factors Management Perspective, safety researcher Pandora Bryce argues that, “the existence of acceptable technical systems and processes isn’t enough; people have to use those systems safely and follow the processes consistently to achieve the desired safety and performance… and that requires effective communication that accounts for human factors in reporting and analysis.”
HazCom procedures are only as good as the people who follow them, and often, those people need a great deal of support to ensure they clearly and unambiguously understand what to do.
The human brain has a habit of filtering out unchanging elements of its surroundings, whether it’s a rock in the water or a label for hazardous chemicals. And whatever you call it — the complacency curve, habituation, desensitization to risk, inattention blindness — it’s a problem for HazCom.
The solution is to look back to the ancient Mediterranean sailors and their attention to risco. So often, HazCom is treated as an issue of individual compliance — once standards have been implemented and training has been conducted then it’s up to each worker to comply with requirements and ensure they attend to the hazardous material they’re working with. (With that said, HazCom violations were the second-most cited OSHA standard during workplace inspections in 2022, and it’s no sure thing that an employer’s hazard communication program meets regulatory requirements.) But the sailors understood that risco was a shared feature of their workplace. The dangers it posed were collective, and so their response to it had to be equally collective.
First, supervisors need to keep their crew’s attention focused on hazardous material. Once safety labels have become visual white noise, it’s up to frontline leaders to find new ways to keep every worker thinking about their HazCom training. This requires a constantly evolving repertoire of toolbox talks, informal safety chats, story-sharing and other communication tactics – all of which should be two-way interactions.
Workers have the right to understand how to manage the risks, and it can be surprisingly tricky to know whether they actually do or not. Watching for head nods among a group of listeners is not as reliable as having detailed verbal confirmation during a conversation. This also means that safety professionals will need to provide a steady stream of support to crew supervisors to shore up their safety and soft skills capacities.
‘It’s Your Ship’
In a more recent nautical example, the legendary success of the USS Benfold was made possible not by the Navy’s cutting-edge systems on board but by the crew led by Captain Michael Abrashoff, who realized he had to improve his own leadership skills before he could improve his ship’s competence. He learned to balance the typical top-down command approach with soliciting sailors’ suggestions and listening aggressively to build accountability with the slogan “It’s Your Ship.”
Second, it means fostering a much greater sense of workers looking out for one another. It takes an entire crew to keep an eye out for shallow reefs and then to navigate the ship away from them. Workers are most likely to overlook warning labels and come into contact with hazardous materials when they’re affected by complacency and other human factors. Training and a no-blame mindset can help workers look out for themselves, but even after a good human factors program has been implemented, coworkers are often best positioned to spot early signs of potential safety issues with their colleagues.
One of the keys for safety professionals is to establish a culture in which workers are willing to speak up when they notice something concerning. This becomes more important with less visible hazards and more complacency-prone issues like HazCom. Some safety situations are much easier to navigate when you have an entire crew looking out for risk.
Ray Prest is the Director of Marketing at SafeStart, a safety company focused on human factors solutions that reduce preventable death and injuries on and off the job. A columnist for Safety Decisions since 2015, Ray’s been helping people learn about safety and training for over 20 years. Read more at safestart.com/ray.