Having a safety system doesn’t mean that people will follow it. It’s a general truism, but also one that can have very specific, and deadly, consequences. To see it in action, one needs to look no further than hazard communication.

In his latest article for Occupational Health and Safety Magazine, safety author Ray Prest takes a look at the impact of human factors, and especially complacency, in HazCom. In particular, he discusses what it means to have hazard communication systems that are used by millions of workers every day—and the unavoidable fact that some of them aren’t following it. As Prest says, this is partially because the language on safety data sheets often:

… inadvertently downplays the seriousness of any potential incidents. This isn’t the fault of the sheets and labels, as that’s just how language and the human brain work. And while workers tend to remember the general bargain—in exchange for a paycheck they must work with hazardous substances they should be mindful of—they often forget the devilish details of what can happen if something goes wrong. Not to mention forgetting all the various chemicals, classifications and components within the system that can lead to potentially serious incidents. 

Which is to say that workers can very quickly become complacent to the dangers of hazardous materials, even when the information about those dangers is right in front of them. People see the labels every day and after a while, they start tuning them out. The hazard labels and data sheets become visual white noise.

Prest goes on to point out that there are no structural solutions to the problem, no tweaks that can be made to the HazCom standard, training or data sheets that will eliminate the dangers of complacency. Instead, the best way to combat the issue is to embed human factors management principles into your HazCom safety plan.

The goal here is to highlight the same hazards (like dangerous chemicals) and the same safety features (like proper labeling) but in a way that allows workers to recognize how their mental and physical states affect the way they handle the material or interact with safety features.

One example of a human factors intervention is conducting toolbox talks that are about HazCom topics but focused on the need to disrupt complacency. For example, if safety data sheets contain important but technical language about hazards, then these talks should discuss the issues in layperson’s terms. It should also focus on putting HazCom issues into everyday contexts that workers are familiar with. In short, it should make the hazard as visceral and real as possible. After all, there’s a reason the FDA researched and finalized 11 new graphic warning labels on cigarette packaging like “Tobacco smoke can harm your children.”

Many human factors-centric techniques are built around the need to get workers’ buy-in, but if you pop open the hood on these safety tactics then you’ll see there’s more to it than simply revving the engine on employee engagement. Rather, they’re part of a more robust approach that has everyone playing their part in combatting complacency. Just like a contract needs two parties to sign it for it to be valid, toolbox talks, informal safety chats and methods techniques require both sides of the conversation to be able to hold up their end.

Supervisors are on one side of the contract. Do they have a rigorous understanding of HazCom standards that is sufficient to let them talk about? And do supervisors have the safety skills and comfort level to communicate with workers in a variety of ways, using clear and unambiguous language?

Don’t forget that complacency isn’t constrained by job title, and that frontline leaders, managers and others in a leadership position can all suffer from complacency. If these folks haven’t had a reminder about HazCom issues in a while, as well as refreshed on the need to communicate them regularly in plainspeak to workers, then it might be time to underline that for them.

Lastly, because complacency cannot be entirely engineered out, you need multiple layers of protection. From co-workers looking out for each other to well-trained supervisors. And while you can’t eliminate it on a personal level, you can reduce structural causes of complacency that are embedded in your organization. 

It’s worth noting that all these techniques are industry agnostic and the benefits aren’t confined to HazCom. So if, for example, you work in a construction-adjacent industry and want to manage human factors, then disrupting complacency on HazCom can potentially have positive spillover effects that will mitigate workers’ complacency while driving or operating dangerous equipment.

There are no iron-clad structural solutions to complacency. There’s no set-it-and-forget-it option that will eliminate complacency from your HazCom process. In fact, the set-it-and-forget-it mindset is part of the problem to begin with. One of the core goals of human factors management in safety is the need to stay ever vigilant in the battle against complacency and other states.

When it comes to HazCom, what’s needed are people-oriented processes to support the presence of safety data sheets and to shore up existing training. The most effective approach is to use a suite of commonly used refreshers on knowledge and hazard awareness. This includes measures like toolbox talks, one-on-one conversations with supervisors, encouraging stronger peer-to-peer communication, and re-training on HazCom standards. It also includes foundational education on human factors for everyone, from frontline workers to the folks in the corner office.

These types of safety tools can be particularly effective because they’re flexible and can be deployed in an ad hoc way. They’re low-cost. And they can do a great job of bringing hazards and safety processes to the front of people’s minds in order to keep complacency at bay.