Keystone Clearwater Solutions Behavior Based Safety Foundation of

Keystone Clearwater Solutions Behavior Based Safety Foundation of a Safety Culture Shell RT Contractor Forum Keystone Clearwater Solutions, LLC | 34 Northeast Drive| Hershey, PA 17033 P: (717) 508 -0550 | F: (717) 298 -6916 www. keystoneclear. com

Behavior Based Safety Foundation of a Safety What. Culture is Behavior Based Safety? Behavior Based Safety (BBS) is the application of behavioral psychology to promote safe behavior in the workplace using employee involvement. BBS focuses on what people do, analyses why they do it, and then applies targeted intervention to improve the organization as a whole. At its core, BBS is not just about Safety it is about your People, your Processes, and ultimately your Culture!!

Behavior Based Safety Foundation of a Safety Culture Why BBS? Compliance Based Safety or Behavior Based Safety? As contractors we know the importance of being “in compliance” not only with the numerous regulatory requirements but our customer requirements as well. We are constantly required to update our metrics on sites such as ISNet, PICs, and PEC Safety, and with each new customer that we look to build a relationship with there seems to be a whole new level of compliance requirements that need to be addressed before we can even bid on prospective work. Compliance is important, but it is only one very small step in the process and has limitations: • • • Typically driven top down. Very little true employee involvement No employee ownership Emphasis changes as leadership changes Often falls short of understanding the true conditions in the field. Question: Once you’ve addressed compliance what’s

Behavior Based Safety Foundation of a Safety Culture Why BBS? Answer: Your processes, your people, and ultimately your culture!! Why does BBS Work? BBS works because: • Employees are actively involved and own the processes that affect them everyday. • Allows the organization to gain a true understanding of the conditions of the work, the associated hazards, the at risk behaviors and why those behaviors are occurring. • The program is driven by the employees and does not change or regress with changes in leadership. • Employees are empowered knowing that they are truly able to recognize hazards and at risk behaviors and the that they have the ability to directly address them. To be successful a BBS program must include all employees, from the CEO to the field laborer.

Behavior Based Safety Foundation of a Safety Culture Elements of a Successful / Effective BBS Program Accountability… Management must be willing: • to provide the resources and allow employees the time to participate in the program, • to accept that in some cases management practices may be a contributing factor, and, • to hold themselves as accountable as all other employees. Employees: • must believe in the process and want to be involved. Strategic Planning… Everyone involved should understand what the desired results are and agree that BBS is simply a means to assist in achieving that end result; it is a part of the answer but not the whole answer. Compliance… Compliance is still an essential element to be included in a BBS program, however the approach may be different than in the past. • More employee involvement in the development and modification of programs, • more employee involvement in developing and conducting training, and • more employee involvement in identifying and correcting safety issues when discovered. BBS is not a “Quick Fix”. It is a commitment that is shared by everyone within the organization.

Behavior Based Safety Foundation of a Safety Culture for a Key Factors Successful BBS Implementation Process Customization… • Your program must be fit for purpose. • There are very few out of the box prepackaged programs that will fit your organization. Perception of Change… • The majority of people do not like change. To successfully implement any change you must do so while at the same time minimizing the perception of change. • Utilize and integrate via your existing infrastructure. This will minimize resistance from both senior management and front line employees. Participation… • Participation in the process must grow steadily and be regularly measured. Discipline… • A careful separation needs to be maintained between the BBS program and any disciplinary measures. Review and Continuously Improve… • Make sure that the program has a review and continuous improvement process to ensure its long term sustainability. Trust and Credibility… • Trust and credibility is the lynch pin for success. Employees must know that the purpose of the

Behavior Based Safety Foundation of a Safety Culture BBS Journey Keystone’s • – The Early Years 2010 through 2011 o Keystone began its BBS journey in late 2010, early 2011 per a client requirement. At that time we had less than 30 employees. o Initial program was cumbersome and not wholly integrated into our overall HSE Management System, yet, with 30 employees “it worked”. o Observations were regularly made by both senior leadership and field employees and shared directly with Senior Operations and HSE leadership. o These initial observations and feedback were further used to refine and develop the Keystone HSE Program. • 2012 through 2013 o As hiring increased, more and more employees completed BBS Training, but as the workload increased, we began to see fewer and fewer observations. o Full time HSE Staff was increased and one of their primary tasks was both completing observations and assisting others with the completion of observations in the field. o Completed observations were submitted directly to HSE senior leadership for review and action.

Behavior Based Safety Foundation of a Safety Culture BBS Journey Keystone’s • – Review and Reinvigoration In early 2014 it became clear that the program was no longer fit for purpose and a full review was conducted. From that review, the following was learned: o During our growth to over 400 employees and the addition of new business lines (Construction and Transportation) we had outgrown the “prepackaged” program that we had been using. o In our attempt to make wholesale change during the growth period and force participation, employees became confused about what was expected. The program became more about an arbitrary number of cards submitted as opposed to the process itself. o We found ourselves in competition with customer requirements and it was learned that employees where drowning in “Alphabet Soup”. o New employees who were not familiar with BBS viewed it to be an extension of the disciplinary process and they did not trust the process. o The submittal of the Completed Observation Cards to the HSE staff for review and action often resulted in delays and therefore a breakdown of credibility.

Behavior Based Safety Foundation of a Safety Keystone’s Culture BBS Journey • – Review and Reinvigoration To address the concerns identified during the review, Keystone committed to Reinvigorating the program. o BBS Training was revised to focus strictly on the fundamentals of the BBS Process and the employee’s role. o Observation Cards, now known as “Safety Cards” were simplified and where customers have their own process / form / card it was made clear that employees could utilize those in place of our cards. o The BBS process was incorporated into other existing elements of the HSE Management Program. ü Keystone’s Stop Work program ü Keystone’s Weekly Toolbox Talk program and Weekly Operations Meetings ü Keystone’s Process and PPE Assessments / Reviews (aka JHA’s) ü Keystone Employee Competencies and Employee Training ü Keystone Star Performer Program o Completed Observations are now submitted directly to field leadership at the location where they are working so that immediate action can be taken. Senior Field leadership then submits to HSE staff for review and trend analysis.

Behavior Based Safety Foundation of a Safety Culture BBS Journey Keystone’s – The Next Step • With continued growth there have been continued challenges. • Participation has improved but still varies from Region to Region and Business Group to Business Group. • Keystone has developed and will be deploying a Weekly Safety Scorecard at the start of the 2 nd Qtr 2015, which will track several leading and lagging performance indicators and assign a weekly grade per each Region / Business Group. Three grades will be assigned each week: o lagging indicators, o leading indicators, and, o overall grade. • Weekly grades will then be used to calculate each region’s / business group’s Yearly HSE performance that will be used as part of year end assessments and reviews. • This scorecard will be shared with the Field Leadership group each week, along with our CEO and COO. • The goal of this exercise is to demonstrate where field leadership is paying attention to the leading Indicators (completion of Toolbox Talks, Field Staff Self Audits, and Safety Observations), the lagging indicators (spills, injuries, property damage) will self correct.

Behavior Based Safety Foundation of a Safety Learnings to Date Culture • BBS should be a tool used to empower employees to take ownership for their and their coworkers personal safety and as a means to identify process safety concerns. • BBS needs to be managed from the field by the field leadership. They need to be granted the authority to make the necessary changes to address concerns as identified. • BBS as a tool is only successful when fully supported by Senior Leadership. Inaction in addressing identified concerns will derail the whole process. • Rewards based on quantity can be dangerously ineffective. Focus on quality observations and not just observations for observations’ sake. • BBS is not defined by a card, it is defined by the actions of your people. BBS needs to be more than a program. To be successful it must be part of the fabric of your culture.