Avoiding Unintended Consequences in the Evolution of Safety

By Dwight Miller, CLCP, CUSP Director of Safety, Ohio's Electric Cooperatives

In 1912, the Titanic sank and many people died because it failed to carry enough lifeboats. Deck space and aesthetics had been prioritized over the capacity of lifeboats, and more than 1,500 people died. The public outrage was immediate, and regulators responded swiftly. Within three years, new maritime laws required sufficient lifeboat capacity for every soul on board.

Certainly, that was the proper thing to do, right? Seems kind of like a no-brainer, honestly.

But in the summer of 1915, the Eastland, a passenger vessel now loaded with the required lifeboats, capsized while still docked in the Chicago River. The added weight had shifted the ship's center of gravity. 844 people drowned. More than had survived the Titanic in lifeboats.

The Safety Paradox had arrived: well-intentioned regulations, implemented without full understanding of the consequences, created new and unforeseen dangers.

This is the central challenge facing safety leaders today. And it is more relevant than ever.

Safety Has Evolved and We Need to Celebrate that

The history of workplace safety is a story of hard-won progress. It has moved through three recognizable phases, each one a genuine improvement over what came before.

Phase 1: Fear-Based Safety. The model was simple — workers who broke the rules got hurt, and workers who got hurt faced punishment. Fear was the primary motivator. For a time, it reduced certain visible incidents. But it drove organizational failures underground. Problems went unreported. Questionable work practices were kept secret, and what happened on the crew stayed on the crew. Safety and production became adversarial. Workers were seen as the problem.

Phase 2: Compliance-Based Safety. The industry got more structured. Policies were written. Procedures were developed. Formal programs with audits and training emerged. We got very good at checking boxes, but not always at changing behavior. Documentation improved. Real-world behavior in the field didn't always follow. Many utilities are still fighting this mindset.

Phase 3: Culture and Engagement. Now many cooperatives are evolving into something better — what might be called enabling success. The shift from compliance to culture represents a fundamental change in how we view people. Instead of enforcing rules from the outside, we are building workplaces where doing the safe thing is simply how work gets done. Workers are seen as resources, not liabilities. Leaders coach rather than catch. Problems surface before they become incidents. A genuine professional standard of care travels with the worker to every job site, in every condition.

Most every one of these improvements has been a huge gain in our safety programs. And every one of them, if left unchecked, can stress something we didn't intend to break.

The Unintended Consequences We Need to Watch

"People Seen as a Resource" — But Are They Still Accountable?

Valuing workers as contributors rather than liabilities is a genuine game-changer. But the line can blur. I’ve been asked more than once by operational and safety leaders across the industry: Is it still okay to hold our people accountable?

The answer must be yes(!!), but with fairness and context. Valuing people is not counterintuitive to holding people accountable. When "resource" quietly becomes "not responsible," we have created a new problem. Investigations begin to focus on systems, paperwork, and external factors while the critical interaction between the person and their work goes unexplored. Researchers from the University of Colorado call this "new blame" where responsibility is displaced onto abstract concepts like procedures or culture, which ultimately limits real organizational learning.

“No Blame” Methodology vs a “Just Culture”

A “Just Culture” draws a clear line between acceptable human error and unacceptable willful violations of life-saving rules and other reckless behavior. It's not about eliminating accountability. It's about applying it fairly. And clear expectations must precede accountability where it’s not "it's in the rules," but rather, "We've set you up to succeed. Now let’s hold the standard together."

Mercy toward error. Correction toward violation. Real consequence toward recklessness. And systemic examination with incident analysis in all three, because understanding context is critical in understanding the true root cause of all types of behavior.

"Coaching, Not Catching" But how well does the Coach know the Game?

Moving from catching workers in violations to coaching them toward excellence is absolutely the right approach. But coaching only works if the coach understands the game at a high level because in electric utility work, losing is not an option.

A crew knows within thirty seconds whether the guy with the clipboard actually understands the work or not. When they sense a gap, the process loses its power and the safety program loses credibility in the minds of the workers as cynicism sets in. Not because anyone did it wrong, but because we’ve asked people to be the head coach when they might make a better assistant.

The shift from compliance-based to transformational safety means stopping the counting of observations completed and starting to ask whether the conversation actually changed anything. Part of our measurement of observations should be asking the crews’ opinions of the process. But beware of the dynamics involved in that as well. We always need to assess with the wisdom that experience offers. In other words, we don’t always take things at face value.

"Open Communication" But to What End?

Creating an environment where workers can safely bring organizational failures to the surface and talk about true work practices in the field is one of the most important advances in our industry. We’ve seen tremendous improvement in this area particularly with the Commitment to Zero Contacts program where we have honest conversations without fear of reprisal, allowing us to address tough issues and discover operational barriers to safe work practices and actually do something about them rather than wait for the incident to occur.

But open communication without boundaries can become a license to complain rather than a tool for improvement.

Without respect, conversations lose professionalism. Without ownership, problems get raised but not solved. Without expectations, everything becomes someone else's fault.

We need our people to speak up. We also need them to speak up in a way that moves us forward where they offer solutions, not just frustrations, and leave every conversation with the team better positioned to work safely and effectively.

Psychological safety has opened doors to communication that were once firmly shut, and it has been amazing to watch. If just one thing needed to change, it was certainly that. But opening the door is not the same as knowing how to walk through it.

In other words, have we trained our crews how to create structured, open communication such as debriefing at the end of the day through after action reviews where we can actually get better each day? Where new guys learn how to own up to their mistakes and move on? Are we creating small groups of four to engage our guys in the SAFE Talks which also teaches them to embrace the after action review process? Do we create structured discussions where we all talk openly about near misses and issues that have come up in the field?

I believe we have a lot of low-hanging fruit here. It is our job as leaders to point our folks in the right direction with their open communication. We should have some minimum expectations in this positive environment that has been created, and also have some guardrails in place so that the open discussion moves us in the right direction, not the other way.

Procedural Drift

Perhaps the most dangerous unintended consequence that can occur in what appears to be a healthy safety culture is maybe the quietest. And that is procedural drift. This happens when the human organizational performance (HOP) approach gives the impression to workers that safety standards have become soft.

When safety expectations are enforced inconsistently, lineman adapt better than anyone because that’s what great linemen do - adapt. And drift is a trait that naturally flows from adaptation. Small deviations develop. Workarounds become habits, which then becomes the new norm. Before anyone recognizes what has changed, the gap between policy and practice has grown dangerously wide. In other words, our best linemen – the ones who can figure out how to get every job done – are also the ones who will be most prone to drifting.

Lineworkers are wired to adapt. That adaptability is often a strength. But in safety-critical environments, it becomes a liability when it quietly erodes the boundaries that keep people alive. The answer is not more rules but rather deeper engagement, and that’s on leadership.

The Narrow Road

Safety leadership has always required navigating between two dangerous ditches. On the left: a fear-based culture built on hard, inflexible rules and blame where problems are driven underground. On the right: a soft culture of drift — no blame, excessive lenience, and the gradual normalization of deviation.

The narrow road between them demands something no policy can manufacture: constant, intentional leadership that is built on a foundation of trust and respect, and committed to balance in both directions.

Every improvement in safety culture will stress something we didn't intend to break. Every generation will overcorrect the one before it. The road between fear and drift is too narrow to stop paying attention.

The goal was never to arrive. The goal is to never stop navigating.

Know the vessel you're building on.

Dwight Miller, CLCP, CUSP, is Senior Director of Safety Training & Loss Prevention at Ohio's Electric Cooperatives. He presented this material at the 2026 NRECA Safety Leadership Summit.

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