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I couldn’t help but be amused about an article in the New York Times reporting the latest citation by Federal regulators for safety violations in the Broadway production of Spider-man: Turn off the Dark. OSHA “regulators” have been “citing” the play for over a year. Why they call them “regulators” I don’t know because their citations change no behavior, they regulate nothing. One thing they do is keep the play in the public eye, a plus for the production company. The total sum fined over the past year is $12,600, considerably small in terms of the value the play received in free publicity.
When will “regulators” learn that the citations don’t work? Massey Mine had 1300 citations, BP had 360, and the company involved in the egg recall also had a long history of citations over the years. OSHA keeps giving citations, but in many, many cases nothing changes. As the New York Time article points out, the Spider-man production was in violation last year and they are still in violation today. Let me put it this way. The closest thing we have to a behavioral law, as gravity is a law of physics, is that behavior is a function of its consequences. Consequences change behavior not citations. Telling them they are unsafe, although meant to be a punisher, is apparently a reinforcer- the behavior continues.
Although OSHA attempts to punish violators with citations and fines, they are not punishers since punishment stops behavior. If OSHA invested the small amount of time it would take regulators to become fluent and develop skills in behavior change, workplace safety, or in this case the safety of everyone associated with the production of Spiderman, would be significantly improved. I believe that OSHA should focus on increasing safety compliance. (I’ll bet they think they do that now.) Only reinforcement increases behavior.
If companies experience with OSHA was to help them improve safety while decreasing cost and improving the quality of their products and services, the agency would be inundated with requests for help. As it is, when OSHA regulators appear on site, employees don’t rush to show them items of concern, they hide them or try to steer regulators away from them. There is a better way to improve safety. Punishment or attempts at punishment won’t. Because of that, OSHA’s efforts are of little help to Spider-man. Nevertheless, as they say in the business, citation or no citation, the show must go on.
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