Melinda Box, MEd, presenter
Ciana Paye, &
Maria Gallardo-Williams, PhD
North Carolina State University
Melinda’s powerpoint can be downloaded from here.
03/17 Table Read for The Art & State of Safety Journal Club
Excerpts from “Positive Feedback via Descriptive Comments for Improved Safety Inspection Responsiveness and Compliance”
The full paper can be found here: https://pubs.acs.org/doi/10.1021/acs.chas.1c00009
Safety is at the core of industrial and academic laboratory operations worldwide and is arguably one of the most important parts of any enterprise since worker protection is key to maintaining on-going activity.28 At the core of these efforts is the establishment of clear expectations regarding acceptable conditions and procedures necessary to ensure protection from accidents and unwanted exposures[a]. To achieve adherence to these expectations, frequent and well-documented inspections are made an integral part of these systems.23
Consideration of the inspection format is essential to the success of this process.31 Important components to be mindful about include frequency of inspections, inspector training, degree of recipient involvement, and means of documentation[b][c][d][e] . Within documentation, the form used for inspection, the report generated, and the means of communicating, compiling, and tracking results all deserve scrutiny in order to optimize inspection benefits.27
Within that realm of documentation, inspection practice often depends on the use of checklists, a widespread and standard approach. Because checklists make content readily accessible and organize knowledge in a way that facilitates systematic evaluation, they are understandably preferred for this application. In addition, checklists reduce frequency of omission errors and, while not eliminating variability, do increase consistency in inspection elements[f][g][h][i][j] among evaluators because users are directed to focus on a single item at a time.26 This not only amplifies the reliability of results, but it also can proactively communicate expectations to inspection recipients and thereby facilitate their compliance preceding an inspection.
However, checklists do have limitations. Most notably, if items on a list cover a large scale and inspection time is limited, reproducibility in recorded findings can be reduced[k]. In addition, individual interpretation and inspector training and preparation can affect inspection results[l][m][n][o][p][q].11 The unfortunate consequence of this variation in thoroughness is that without a note of deficiency there is not an unequivocal indication that an inspection has been done. Instead, if something is recorded as satisfactory, the question remains whether the check was sufficiently thorough or even done at all. Therefore, in effect, the certainty of what a checklist conveys becomes only negative feedback[r][s][t].
Even with uniformity of user attention and approach, checklists risk producing a counterproductive form of tunnel vision[u] because they can tend to discourage recognition of problematic interactions and interdependencies that may also contribute to unsafe conditions.15 Also, depending on format, a checklist may not provide the information on how to remedy issues nor the ability[v][w] to prioritize among issues in doing follow-up.3 What’s more, within an inspection system, incentive to pursue remedy may only be the anticipation of the next inspection, so self-regulating compliance in between inspections may not be facilitated.[x][y][z][aa][ab][ac]22
Recognition of these limitations necessitates reconsideration of the checklist-only approach, and as part of that reevaluation, it is important to begin with a good foundation. The first step, therefore, is to establish the goal of the process. This ensures that the tool is designed to fulfill a purpose that is widely understood and accepted.9 Examples of goals of an environmental health and safety inspection might be to improve safety of surroundings, to increase compliance with institutional requirements, to strengthen preparedness for external inspections, and/or to increase workers’ awareness and understanding of rules and regulations. In all of these examples, the aim is to either prompt change or strengthen existing favorable conditions. While checklists provide some guidance for change, they do not bring about that change, [ad][ae]and they are arguably very limited when it comes to definitively conveying what favorable conditions to strengthen. The inclusion of positive feedback fulfills these particular goals.
A degree of skepticism and reluctance to actively include a record of positive observations[af][ag] in an inspection, is understandable since negative feedback can more readily influence recipients toward adherence to standards and regulations. Characterized by correction and an implicit call to remedy, it leverages the strong emotional impact of deficiency to encourage limited deviation from what has been done before.19 However, arousal of strong negative emotions, such as discouragement, shame, and disappointment, also neurologically inhibits access to existing neural circuits thereby invoking cognitive, emotional, and perceptual impairment.[ah][ai][aj]10, 24, 25 In effect, this means that negative feedback can also reduce the comprehension of content and thus possibly run counter to the desired goal of bringing about follow up and change.2
This skepticism and reluctance may understandably extend to even including positive feedback with negative feedback since affirmative statements do not leave as strong of an impression as critical ones. However, studies have shown that the details of negative comment will not be retained without sufficient accompanying positive comment.[ak][al][am][an][ao][ap][aq]1[ar][as] The importance of this balance has also been shown for workplace team performance.19 The correlation observed between higher team performance and a higher ratio of positive comments in the study by Losada and Heaphy is attributed to an expansive emotional space, opening possibilities for action and creativity. By contrast, lower performing teams demonstrated restrictive emotional spaces as reflected in a low ratio of positive comments. These spaces were characterized by a lack of mutual support and enthusiasm, as well as an atmosphere of distrust and [at]cynicism.18
The consequence of positive feedback in and of itself also provides compelling reason to regularly and actively provide it. Beyond increasing comprehension of corrections by offsetting critical feedback, affirmative assessment facilitates change by broadening the array of solutions considered by recipients of the feedback.13 This dynamic occurs because positive feedback adds to an employees’ security and thus amplifies their confidence to build on their existing strengths, thus empowering them to perform at a higher level[au].7
Principles of management point out that to achieve high performance employees need to have tangible examples of right actions to take[av][aw][ax][ay][az], including knowing what current actions to continue doing.14, 21 A significant example of this is the way that Dallas Cowboys football coach, Tom Landry, turned his new team around. He put together highlight reels for each player that featured their successes. That way they could identify within those clips what they were doing right and focus their efforts on strengthening that. He recognized that it was not obvious to natural athletes how they achieved high performance, and the same can be true for employees and inspection recipients.7
In addition, behavioral science studies have demonstrated that affirmation builds trust and rapport between the giver and the receive[ba]r[bb][bc][bd][be][bf][bg].6 In the context of an evaluation, this added psychological security contributes to employees revealing more about their workplace which can be an essential component of a thorough and successful inspection.27 Therefore, positive feedback encourages the dialogue needed for conveying adaptive prioritization and practical means of remedy, both of which are often requisite to solving critical safety issues.[bh]
Giving positive feedback also often affirms an individual’s sense of identity in terms of their meaningful contributions and personal efforts. Acknowledging those qualities, therefore, can amplify them. This connection to personal value can evoke the highest levels of excitement and enthusiasm in a worker, and, in turn, generate an eagerness to perform and fuel energy to take action.8
Looked at from another perspective, safety inspections can feel personal. Many lab workers spend a significant amount of time in the lab, and as a result, they may experience inspection reports of that setting as a reflection on their performance rather than strictly an objective statement of observable work. Consideration of this affective impact of inspection results is important since, when it comes to learning, attitudes can influence the cognitive process.29 Indeed, this consideration can be pivotal in transforming a teachable moment into an occasion of learning.4
To elaborate, positive feedback can influence the affective experience in a way that can shift recipients’ receptiveness to correction[bi][bj]. Notice of inspection deficiencies can trigger a sense of vulnerability, need, doubt, and/or uncertainty. At the same time, though, positive feedback can promote a sense of confidence and assurance that is valuable for active construction of new understanding. Therefore, positive feedback can encourage the transformation of the intense interest that results from correction into the contextualized comprehension necessary for successful follow-up to recorded deficiencies.
Overall, then, a balance of both positive and negative feedback is crucial to ensuring adherence to regulations and encouraging achievement.[bk]2, 12 Since positive emotion can influence how individuals respond to and take action from feedback, the way that feedback is formatted and delivered can determine whether or not it is effective.20 Hence, rooting an organization in the value of positivity can reap some noteworthy benefits including higher employee performance, increased creativity, and an eagerness in employees to engage.6
To gain these benefits, it is, therefore, necessary to expand from the approach of the checklist alone.16 Principles of evaluation recommend a report that includes both judgmental and descriptive information. This will provide recipients with the information they seek regarding how well they did and the successfulness of their particular efforts.27 Putting the two together creates a more powerful tool for influence and for catalyzing transformation.
In this paper the authors would like to propose an alternative way to format safety inspection information, in particular, to provide feedback that goes beyond the checklist-only approach. The authors’ submission of this approach stems from their experiences of implementing a practice of documenting positive inspection findings within a large academic department. They would like to establish, based on educational and organizational management principles, that this practice played an essential role in the successful outcome of the inspection process in terms of corrections of safety violations, extended compliance, and user satisfaction. [bl][bm][bn][bo]
[a]There is also a legal responsibility of the purchaser of a hazardous chemical (usually the institution, at a researcher’s request) to assure it is used in a safe and healthy manner for a wide variety of stakeholders
[b]I would add what topics will be covered by the inspection to this list. The inspection programs I was involved in/led had a lot of trouble deciding whether the inspections we conducted were for the benefit of the labs, the institution or the regulatory authorities. Each of these stakeholders had a different set of issues they wanted to have oversight over. And the EHS staff had limited time and expertise to address the issues adequately from each of those perspectives.
[c]This is interesting to think about. As LSTs have taken on peer-to-peer inspections, they have been using them as an educational tool for graduate students. I would imagine that, even with the same checklist, what would be emphasized by an LST team versus EHS would end up being quite a bit different as influenced by what each group considered to be the purpose of the inspection activity.
[d]Hmm, well maybe the issue is trying to cram the interests and perspectives of so many different stakeholders into a single, annual, time-limited event 😛
[e]I haven’t really thought critically about who the stakeholders are of an inspection and who they serve. I agree with your point Jessica, that the EHS and LST inspections would be different and focus on different aspects. I feel include to ask my DEHS rep for his inspection check list and compare it to ours.
[f]This is an aspirational goal for checklists, but is not often well met. This is because laboratories vary so much in the way they use chemicals that a one size checklist does not fit all. This is another reason that the narrative approach suggested by this article is so appealing
[g]We have drafted hazard specific walkthrough rubrics that help address that issue but a lot of effort went into drafting them and you need someone with expertise in that hazard area to properly address them.
[h]Well I do think that, even with the issues that you’ve described, checklists still work towards decreasing variability.
In essence, I think of checklists as directing the conversation and providing a list of things to make sure that you check for (if relevant). Without such a document, the free-form structure WOULD result in more variability and missed topics.
Which is really to say that, I think a hybrid approach would be the best!
[i]I agree that a hybrid approach is ideal, if staff resources permit. The challenge is that EHS staff are responding to a wide variety of lab science issues and have a hard time being confident that they are qualified to raise issues. Moving from major research institutions to a PUI, I finally feel like I have the time to provide support to not only raise concerns but help address them. At Keene State, we do modern science, but not exotic science.
[j]I feel like in the end, it always comes down to “we just don’t have the resources…”
Can we talk about that for a second? HOW DO WE GET MORE RESOURCES FOR EHS : /
[k]I feel like that would also be the case for a “descriptive comment” inspection if the time is limited. Is there a way that the descriptive method could improve efficiency while still covering all inspection items?
[l]This is something my university struggles with in terms of a checklist. There’s quite a bit of variability between inspections in our labs done by different inspectors. Some inspectors will catch things that others would overlook. Our labs are vastly different but we are all given the same checklist – Our checklist is also extensive and the language used is quite confusing.
[m]I have also seen labs with poor safety habits use this to their advantage as well. I’ve known some people who strategically put a small problem front and center so that they can be criticized for that. Then the inspector feels like they have “done their job” and they don’t go looking for more and miss the much bigger problem(s) just out of sight.
[n]^ That just feels so insidious. I think the idea of the inspector looking for just anything to jot down to show they were looking is not great (and something I’ve run into), but you want it to be because they CANT find anything big, not just to hide it.
[o]Amanda, our JST has had seminars to help prepare inspectors and show them what to look for. We also include descriptions of what each inspection score should look like to help improve reproducibility.
[p]We had experience with this issue when we were doing our LSTs Peer Lab Walkthrough! For this event, we have volunteer graduate students serve as judges to walk through volunteering labs to score a rubric. One of the biggest things we’ve had to overhaul over the years is how to train and prepare our volunteers.
So far, we’ve landed on providing training, practice sessions, and using a TEAM of inspectors per lab (rather than just one). These things have definitely made a huge difference, but it’s also really far from addressing the issue (and this is WITH a checklist)
[q]I’d really like to go back to peer-peer walkthroughs and implement some of these ideas. Unfortunately, I don’t think we are there yet in terms of the pandemic for our university and our grad students being okay with this. Brady, did you mean you train the EHS inspectors or for JST walkthroughs? I’ve given advice about seeing some labs that have gone through inspections but a lot of items that were red flags to me (and to the grad students who ended up not pointing it out) were missed / not recorded.
[r]This was really interesting to read, because when I was working with my student safety team to create and design a Peer Lab Walkthrough, this was something we tried hard to get around even though we didn’t name the issue directly.
We ended up making a rubric (which seems like a form of checklist) to guide the walkthrough and create some uniformity in responding, but we decided to make it be scored 1-5 with a score of *3* representing sufficiency. In this way, the rubric would both include negative AND positive feedback that would go towards their score in the competition.
[s]I think the other thing that is cool about the idea of a rubric, is there might be space for comments, but by already putting everything on a scale, it can give an indication that things are great/just fine without extensive writing!
[t]We also use a rubric but require a photo or description for scores above sufficient to further highlight exemplary safety.
[u]I very much saw this in my graduate school lab when EHS inspections were done. It was an odd experience for me because it made me feel like all of the things I was worried about were normal and not coming up on the radar for EHS inspections.
[v]I think this type of feedback would be really beneficial. From my experience (and hearing others), we do not get any feedback on how to fix issues. You can ask for help to fix the issues, but sometimes the recommendations don’t align with the labs needs / why it is an issue in the first place
[w]This was a major problem in my 1st research lab with the USDA. We had safety professionals who showed up once per year for our annual inspection (they were housed elsewhere). I was told that a set up we had wasn’t acceptable. I explained why we had things set up the way we did, then asked for advice on how to address the safety issues raised. The inspector literally shrugged his shoulders and gruffly said to me “that’s your problem to fix.” So – it didn’t get fixed. My PI had warned my about this attitude (so this wasn’t a one-off), but I was so sure that if we just had a reasonable, respectful conversation….
[x]I think this is a really key point. We had announced inspections and were aware of what was on the checklists. As a LSO, we would in the week leading up to it get the lab in tip-top shape. Fortunately, we didn’t always have a ton of stuff to fix in the week leading up to the inspection, but its easy to imagine reducing things to a yes/no checklists can mask long-term problems that are common in-between inspections
[y]My lab is similar to this. When I first joined and went through my first inspection – the week prior was awful trying to correct everything. I started implementing “clean-ups” every quarter because my lab would just go back to how it was after the inspection.
[aa]Our EHS was short-staffed and ended up doing “annual inspections” 3 years apart – once was before I joined my lab, and the next was ~1.5 years in. The pictures of the incorrect things found turned out to be identical to the inspection report from 3 years prior. Not just the same issues, but quite literally the same bottles/equipment.
[ab]Yeah, we had biannual lab cleanups that were all day events, and typically took place a couple months before our inspections; definitely helped us keep things clean.
One other big things is when we swapped to subpart K waste handling (cant keep longer than 12months), we just started disposing of all waste every six months so that way nothing could slip through the cracks before an inspection
[ac]Jessica, you’re talking about me and I don’t like it XD
[ad]I came to feel that checklists were for things that could be reviewed when noone was in the room and that narrative comments would summarize conversations about inspectors’ observations. These are usually two very different sets of topics.
[ae]We considered doing inspections “off-hours” to focus on the checklist items, until we realized there was no such thing as off hours in most academic labs. Yale EHS found many more EHS problems during 3rd shift inspections than daytime inspections
[af]This also feels like it would be a great teachable moment for those newer to the lab environment. We often think that if no one said anything, I guess it is okay even if we do not understand why it is okay. Elucidating that something is being done right “and this is why” is really helpful to both teach and reinforce good habits.
[ag]I think that relates well to the football example of highlighting the good practices to ensure they are recognized by the player or researcher.
[ah]I noticed that not much was said about complacency, which I think can both be a consequence of an overwhelm of negative feedback and also an issue in and of itself stemming from culture. And I think positive feedback and encouragement could combat both of these contributors to complacency!
[ai]Good point. It could also undermine the positive things that the lab was doing because they didn’t actually realize that the thing they were previously doing was actually positive. So complacency can lead to the loss of things that you were doing right before.
[aj]I have seen situations where labs were forced to abandon positive safety efforts because they were not aligned with institutional or legal expectations. Compliance risk was lowered, but physical risk increased.
[ak]The inclusion of both positive and negative comments shows that the inspector is being more thorough which to me would give it more credibility and lead to greater acceptance and retention of the feedback.
[al]I think they might be describing this phenomenon a few paragraphs down when they talk about trust between the giver and receiver.
[am]This is an interesting perspective. I have found that many PIs don’t show much respect for safety professionals when they deliver bad news. Perhaps the delivery of good news would help to reinforce the authority and knowledge base of the safety professionals – so that when they do have criticism to deliver, it will be taken more seriously.
[an]The ACS Pubs advice to reviewers of manuscripts is to describe the strengths of the paper before raising concerns. As an reviewer, I have found that approach very helpful because it makes me look for the good parts of the article before looking for flaw.
[ao]The request for corrective action should go along with a discussion with the PI of why change is needed and practical ways it might be accomplished.
[ap]I worked in a lab that had serious safety issues when I joined. Wondering if the positive -negative feedback balance could have made a difference in changing the attitudes of the students and the PI.
[aq]It works well with PIs with an open mind; but some PIs have a sad history around EHS that has burnt them out on trying to work with EHS staff. This is particularly true if the EHS staff has a lot of turnover.
[ar]Sandwich format- two positives (bread) between the negative (filling).
[as]That crossed my mind right away as well.
[at]I wonder how this can contribute to a negative environment about lab-EHS interactions? If there is only negative commentary (or the perception of that) flowing in one direction, would seem that it would have an impact on that relationship
[au]I see how providing positive feedback along with the negative feedback could help do away with the feeling the inspector is just out to get you. Instead, they are here to provide help and support.
[av]This makes me consider how many “problem” examples I use in the safety training curriculum.
[aw]This is a good point. From a learning perspective, I think it would be incredibly helpful to see examples of things being done right – especially when what is being shown is a challenge and is in support of research being conducted.
[ax]I third this so hard! It was also something that I would seek out a lot when I was new but had trouble finding resources on. I saw a lot of bad examples—in training videos, in the environments around me—but I was definitely starved for a GOOD example to mimic.
[ay]I read just part of the full paper. It includes examples of positive feedback and an email that was sent. The example helped me get the flavor of what the authors were doing.
[az]This makes a lot of sense to me – especially from a “new lab employee” perspective.
[ba]Referenced in my comment a few paragraphs above.
[bb]I suspect that another factor in trust is the amount of time spent in a common environment. Inspectors don’t have a lot of credibility if they are only visit a place annually where a lab worker spends every day.
[bc]A lot of us do not know or recognize our inspectors by name or face (we’ve also had so much turn around in EHS personnel and don’t even have a CHO). I honestly would not be able to tell you who does inspections if not for being on our universities LST. This has occurred in our lab (issue of trust) during a review of an inspection of our radiation safety inspection. The waste was not tested properly, so we were questioned on our rad waste. It was later found that the inspector unfortunately didn’t perform the correct test for testing the pH. My PI did not take it very well after having to correct them about this.
[bd]I have run into similar issues when inspectors and PIs do not take the time to have a conversation, but connect only by e-mail. Many campuses have inspection tracking apps which make this too easy a temptation for both sides
[be]Not only a conversation but inspectors can be actively involved in improving conditions- eg supply signs, ppe, similar sop’s…
[bf]Yes, sometimes, it’s amazing how little money it can take to show a good faith effort from EHS to support their recommendations. Other times, if it is a capital cost issue, EHS is helpless to assist even if there is a immediate concern.
[bg]I have found inspections where the EHS openly discuss issues and observations as they are making the inspection very useful Gives me the chance to ask the million questions I have about safety in the lab.
[bh]We see this in our JST walkthroughs. We require photos or descriptions of above acceptable scores and have some open ended discussion questions at the end to highlight those exemplary safety protocols and to address areas that might have been lacking.
[bi]Through talking with other students reps, we usually never know what we are doing “right” during the inspections. I think this would benefit in a way that shared positive feedback, would then help the other labs that might have been marked on their inspection checklist for that same item and allow them a resource on how to correct issues.
[bj]I think this is an especially important point in an educational environment. Graduate students are there to learn many things, such as how to maintain a lab. It is weird to be treated as if we should already know – and get no feedback about what is being done right and why it is right. I often felt like I was just sort of guessing at things.
[bk]At UVM, we hosted an annual party where we reviewed the most successful lab inspections. This was reasonably well received, particularly by lab staff who were permanent and wanted to know how others in the department were doing on the safety front
[bl]This can be successful, UNTIL a regulatory inspection happens that finds significant legal concerns related primarily to paperwork issues. Then upper management is likely to say “enough of the nice guy approach – we need to stop the citations.” Been there, done that.
[bm]Fundamentally, I think there needs to be two different offices. One to protect the people, and one to protect the institution *huff huff*
[bn]When that occurs, there is a very large amount of friction between those offices. And the Provost ends up being the referee. That is why sometimes there is no follow up to an inspection report that sounds dire.
[bo]But I feel like there is ALREADY friction between these two issues. They’re just not as tangible and don’t get as much attention as they would if you have two offices directly conflicting.
These things WILL conflict sometimes, and I feel like we need a champion for both sides. It’s like having a union. Right now, the institution is the only one with a real hand in the game, so right now that perspective is the one that will always win out. It needs more balance.