HR Governance: Employee Relations

Just Culture and Life Saving Rules Procedure

Purpose
To support the evolution of a Just Culture at BC Hydro which emphasizes learning rather than blame and seeks to
improve the system rather than discipline people for human error. To provide focus on the high risk activities that carry
the greatest threat of serious injury or death.
Procedure Specification
The Life Saving Rules focus on the high risk work activities that carry the greatest threat of serious injury or death. To
successfully implement the Rules, employees need to believe that BC Hydro is actively engaged in reducing system
risks. If an employee fails to follow a Life Saving Rule or a safe work procedure, we need to know why and if the incident
could be prevented in the future. Employees will only feel comfortable reporting incidents if they know that they are not
going to be disciplined for a human error or a system flaw. Just Culture is a way to build trust between BC Hydro and its
employees, and in turn encourage increased reporting of safety incidents.
Procedure Application
In a just culture, safety incidents and rule-breaking are viewed as opportunities to learn how safety can be improved.
People involved in safety incidents and rule-breaking are encouraged to report their mistakes and to feel comfortable
doing so because discipline is not the end result in the large majority of cases. Safety incidents are investigated
thoroughly to determine whether the root cause is a system failure or human behaviour (or a combination of the two). The
investigation provides input to help determine the type of behaviour involved, such as an honest mistake, at-risk behaviour
or reckless behaviour (as defined below).

The objective of Just Culture is to improve safety performance by:

• Increasing reporting of safety incidents and rule-breaking, so that there is more knowledge about the risks within
our system;
• Reducing accidents by learning from the reporting and improving the system.

Three Key Behaviours1

HUMAN ERROR AT-RISK BEHAVIOUR RECKLESS BEHAVIOUR
Inadvertent action – doing other than what A behavioural choice that increases risk A conscious choice to
should have been done; a slip, lapse, or where the risk is not recognized or is disregard a substantial and
mistake. mistakenly believed to be justified. unjustifiable risk.

Manage human error by making changes to: Manage by: Manage by:
• Processes • Removing incentives for at-risk • Applying disciplinary
• Procedures behaviours action where
• Training • Creating incentives for safe appropriate
• Design behaviours
• Environment • Increasing situational awareness

For repetitive human error: For repetitive at-risk behaviour:

• Determine whether the person is • Determine whether the person
competent or not, and address through requires further education, counseling
training, move to another job or other or possibly discipline
action.
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Source: The Just Culture Community

Reference #: HRA4.G8.01
Release Date: August 2016 BC Hydro Internal Use Only
Just Culture and Life Saving Rules Procedure
Just Culture Principles2
BC Hydro acknowledges that our systems are not perfect and does not hold individual accountable for
System system flaws beyond their control. We put priority on the issue resolution (“fix-it”) process to address
system flaws by implementing timely and effective solutions.

We acknowledge that any employee can make a human error. We also acknowledge that over the
Human
course of time, individuals drift into at-risk behaviour, as do organizations – both of which need to be
Behaviour
proactively managed to reduce and eliminate risk. Reckless behaviour is unacceptable.

BC Hydro is accountable for providing systems that enable people to work safely and to address flaws
Accountability when they are identified. Employees are accountable for working safely, which includes following rules
and procedures, and stopping work when it can’t be completed without violating a rule or procedure.

Intervention We have the courage to intervene when we see an unsafe act or condition, and to accept intervention.

We foster an environment where all employees and contractors feel comfortable reporting incidents and
Reporting unsafe acts or conditions, so that we will have as much information as possible to improve the system
and worker safety.

We commit to investigate safety incidents using a consistent approach that determines why an incident
Investigation
occurred from both a systemic and behavioural perspective.

BC Hydro recognizes employees who demonstrate safe work behaviours. We ensure that
consequences to individuals are based on investigation findings and are aligned with our principles.
Employees who make an honest mistake while trying to do their best, and employees who occasionally
Consequences
exhibit at-risk behaviour, are coached towards safer behaviours. Repetitive human error and at-risk
behaviour also require a deeper analysis and corrective action. Employees who are found to be
reckless will be disciplined where appropriate.

BC Hydro commits to sharing learnings from safety incidents across the organization and with
Learning contractors, and in turn we work to learn from our contractors. We ensure any associated corrective
actions are implemented to reduce the possibility of future incidents.

Leadership We lead by example by using these principles to guide our decisions.

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Just Culture Principles developed by the Life Saving Rules Team (2012)

Life Saving Rules

The Life Saving Rules replace the pre-existing Cardinal Safety Rules on January 23, 2013. The Cardinal Safety Rules,
where ever they are documented or discovered, are to be removed and replaced by the Life Saving Rules.

The Life Saving Rules apply to BC Hydro employees and contractors.

The expectations are that:
• Everyone will follow the Life Saving Rules.
• If you can’t complete a job without breaking one of the Rules, you must stop work, advise your work leader or
manager of the situation and obtain an approved work procedure before proceeding.
• BC Hydro will develop timely and effective solutions to system conditions that prevent compliance with the Life
Saving Rules.
• Everyone accepts intervention.

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Reference #: HRA4.G8.01
Release Date: August 2016 BC Hydro Internal Use Only
Just Culture and Life Saving Rules Procedure
BC Hydro Life Saving Rules:
Overarching Value: Have the courage to intervene if you see an unsafe act or condition or you observe someone
unfit for work.
• Life Saving Rules https://hydroshare.bchydro.bc.ca/sites/safehub/Documents.aspx?
resultType=topic&t=Life%20saving%20rules

Safety Responsibilities

Management and Supervisors

Management and Supervisors are accountable to be safety leaders, and to provide a safe workplace. Responsibilities
are:
Management
• To communicate expectations for worker safety and health performance and public safety through specific
responsibilities and direction to employees, contractors, service providers and external first responders.
• To ensure that a safety culture exists in the workplace that promotes open, honest and transparent
communications where all employees are encouraged to question work practices without hesitation or concern.
• To develop and implement systems to identify and control hazards.
• To ensure employees are capable and competent to work safely.
• To be aware of conflicting messaging and goals within the company and how these impact workers and actively
work to resolve.
• To undertake thorough investigations of incidents and near misses when they occur, seeking to better understand
and correct causes.
Management and Supervisors
• To provide appropriate tools and adequate resources to safely carry out the work.
• To recognize safe work behaviours and demonstrated leadership in safety.
• To demonstrate personal leadership in safety through their actions.
• When in disagreement with an approved safety rule or procedure, to nevertheless follow it while recommending
changes.
• To responsibly carry out the intent of this procedure, including the application of discipline when appropriate.
Supervisors
• To ensure workers have the necessary qualifications to perform assigned work safely.
• To provide employees with sufficient instruction and supervision to safely carry out their work and fulfill their
health and safety responsibilities.
• To identify and correct unsafe work behaviours, including actively seeking out and addressing issues that enable
these behaviours.
• To openly and in a timely manner respond to safety issues raised by employees or arising from work oversight.
Workers
Workers are accountable to work safely. Responsibilities are:
• To ensure that they obtain the knowledge necessary to perform their work, and understand their safety and health
responsibilities including the safety rules that apply to their work.
• To conduct their work activities in a manner that minimizes the chance of harm or injury to themselves, other
employees or to the public.
• To identify, report and where possible correct unsafe working conditions and behaviours.
• To support other workers who report incidents, near misses and unsafe working conditions.
• To know and act in accordance with BC Hydro's safety rules and work procedures and WorkSafeBC rules and
regulations including the right to refuse to perform unsafe work or to engage in unsafe work procedures.
• To identify safety concerns and work with Managers to implement changes that will improve safety.
• To demonstrate personal leadership in safety through their actions.
• When in disagreement with an approved safety rule or procedure, to nevertheless follow it while recommending
changes.
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Reference #: HRA4.G8.01
Release Date: August 2016 BC Hydro Internal Use Only
Just Culture and Life Saving Rules Procedure
• To work cooperatively to prevent incidents and occupational diseases.
• To participate fully in incident investigations and near miss investigations when required.

Recognition
BC Hydro will recognize individuals and employee work groups for safety achievements, for safe work behaviours and for
the demonstration of leadership in safety. A number of examples are as follows:
• Intervening when witnessing unsafe acts.
• Demonstrating safety performance achievements that meet and improve on targets.
• Identifying and implementing initiatives that lead to safety improvement.
• Raising public awareness of electrical safety.
• Engaging youth in electrical safety awareness.
• Leading a crew or work team to safety issue resolution.
• Describing “at risk” behaviours and engaging crew or team members to find solutions.
• Implementing new approaches to daily tasks that mitigate risk of injury.
• Participation in providing first aid to employees or the public in serious or life threatening situations.

All employees are encouraged to recognize safety achievements of others that demonstrate leadership and safe work
behaviours.

Prevention and Near Miss Reporting

The identification of unsafe conditions, procedures or work and taking immediate corrective action is essential to ensure
the safety of employees, contractors and the public.

The reporting of near misses or unsafe conditions is important to identify and correct root causes in order to prevent a
future incident.

To encourage all employees to report near misses, there will be no disciplinary measures taken against employees who
report their own near miss safety violations where, without their report, the violation would otherwise have been
undiscovered.

Repeated violations may, for the safety of the individual and co-workers, result in the need for recertification,
reauthorization, or reassignment, dependent upon circumstances.

Commitment
BC Hydro, COPE and the IBEW recognize the need to commit to the Just Culture Principles and demonstrate the
leadership necessary to ensure the successful implementation of Just Culture, and believe that we all play a role in
making the Life Saving Rules a success. Our shared commitment sets us on a path to a safer workplace.

Copies of the Just Culture Principles and the Life Saving Rules signed by the leadership of BC Hydro, COPE and the
IBEW can be found at the following links:

• Commitment Statement – Just Culture Principles

http://hydroshare/sites/safehub/PublishedDocs/SafeHub_131.pdf

• Life Saving Rules

https://hydroshare.bchydro.bc.ca/sites/safehub/Documents.aspx?
resultType=topic&t=Life%20saving%20rules

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Reference #: HRA4.G8.01
Release Date: August 2016 BC Hydro Internal Use Only
Just Culture and Life Saving Rules Procedure
Related Documents and Links
• Conduct Expectations Policy
https://hw.bchydro.bc.ca/Documents/bch-code-of-conduct-policy.pdf
• Safety Policy
https://hw.bchydro.bc.ca/Documents/bch-code-of-conduct-policy.pdf

• Occupational Safety & Health Standards

https://hw.bchydro.bc.ca/basicpage/osh
• Safety Practice Regulations
• https://hw.bchydro.bc.ca/basicpage/safety-practice-regulations

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Reference #: HRA4.G8.01
Release Date: August 2016 BC Hydro Internal Use Only