Could It Happen Here? Talking about Somebody Else’s Accident

When I started drafting this column in mid-June 2017, the news was full of stories about London’s deadly June 14 Grenfell Tower fire. While much is still unknown about the fire’s causes, it may have spread as quickly as it did, engulfing the 24-story apartment building, because recently added cosmetic exterior cladding was not fire-resistant. More expensive fire-resistant cladding would have been required in the U.S. and some other countries, but apparently wasn’t required in the U.K. and wasn’t used when Grenfell Tower was refurbished.

Imagine you lived in an apartment building someplace else – anywhere in the world – that has the same or similar cladding. You would immediately want to find out whether your home faces the same fire risk as Grenfell Tower. Knowing that, what if anything should apartment managements have said to their residents about the Grenfell Tower fire?

I don’t know how many apartment managements put out some sort of announcement about their cladding in the wake of the fire. In a brief Internet search I failed to find any such announcements.

I did find news stories with titles like “London fire: Grenfell Tower cladding ‘linked to other fires’” (BBC) and “London tower fire could happen here: Australian buildings cloaked in flammable cladding” (The Age). The stories I found quoted safety and fire-fighting experts, government records, planning agency officials, and worried residents. I didn’t see any quotes from apartment managements.

So are apartment managements biding their time, waiting for the results of official investigations before communicating with their residents? Maybe. But my best guess is they have no intention of ever talking to their residents about the Grenfell Tower fire unless local activists force their hand.

In this context, it’s worth noting that the Grenfell Tower fire was not a one-off. The same or similar flammable exterior cladding had been blamed for previous apartment disasters in other cities, including Melbourne and Dubai. I don’t know whether the London authorities responsible for Grenfell Tower took note of these precursors. If so, they didn’t talk to their residents about them … just as apartment managements now haven’t talked to their residents about Grenfell Tower.

I think they should talk. And so should you in comparable circumstances. Whenever something bad and newsworthy happens to a facility that resembles your facility, it’s time to communicate with your stakeholders – with employees, neighbors, journalists, and whoever else is likely to notice the resemblance and start to worry.

I’m going to make a case in this column that good risk communication requires talking to your stakeholders about somebody else’s accident – proactively, even if nobody is asking awkward questions and demanding answers. But I have to concede at the outset that this is a minority opinion. I can’t find anything in the literature that agrees with me. In fact, I can’t even find literature that disagrees with me. Apparently it’s such a weird idea that nobody even debates it.

And I fully realize that many readers of The Synergist are probably on the side of the apartment managers. It’s easy for an industrial hygienist to sympathize with another industrial hygienist employed by an organization where something has gone badly wrong (perhaps because top management ignored the IH professional’s pleas for higher safety standards). It’s hard to feel okay speaking out about what went wrong without knowing the whole backstory.

Harvesting lessons learned

When a facility similar to yours has an accident, it’s established best practice to look for lessons learned that might apply to your facility as well.

This isn’t necessarily easy, since you can’t do your own investigation (let alone a root cause analysis) but have to rely instead on information that’s available publicly or through your professional network. Some industries have a good record for harvesting industry-wide lessons from accidents, especially if there are regulatory agencies or industry associations that insist on it. Aviation and nuclear power come immediately to mind as good examples.

In other industries, companies do pretty good accident assessments internally but are loath to share them. Over the years I participated in a handful of such “hotwash” analyses. (The term “hotwash,” initially military, now describes any after-action assessment of an accident or a training exercise.) Nearly every time I was pledged to confidentiality. And of course in some industries even internal accident assessments are uncommon or slapdash.

But at least all safety professionals agree in principle that there are always lessons to be learned from an accident – and that ideally the people responsible for similar facilities elsewhere should learn those lessons, not just the people whose accident is under the microscope.

There is also widespread (if not yet universal) agreement that members of the public who were or might have been endangered by an accident deserve to be told what lessons were learned. My clients typically hated briefing neighbors on what went wrong and what needs to be done so it won’t happen again. But they pretty quickly understood that stakeholders who knew the accident happened and felt threatened at the time were entitled to at least a brief summary of the accident investigation findings. Many of my clients even got it that waiting for the investigation to finish was a mistake – that it was best to communicate immediately, however tentative those early communications needed to be.

This column is about a much more controversial question: When something goes wrong at somebody else’s facility that’s similar to yours, what if anything should you tell your stakeholders?

What you might say

The key question in your stakeholders’ minds, of course, is whether what happened there could happen here. If you’re going to talk about the accident at all, that’s the question you need to answer.

I see four possible answers. Here they are, expressed as bluntly as I know how:

You’ll almost certainly want to make your answer less blunt (especially if it’s number four). And early on, when your knowledge of what happened is preliminary and incomplete, you’ll want to make your answer tentative (“judging from what we know so far”). But these are the four basic options. Which answer you give should obviously depends on which is true.

A more nuanced, composite answer is also possible. “There were some things they got wrong that we’re really quite sure we get right. And there were some lessons we learned from their accident that have led to improvements we’re already implementing here. So our risk was lower than theirs to start with and it’s even lower now. But the risk is never zero. That’s why we’re always on our guard, always looking for ways to increase safety.”

Answering the “Could it happen here?” question is the main task when you’re talking to your stakeholders about somebody else’s accident. But there are a few other points worth making:

• Acknowledge the reasonableness of your stakeholders’ questions and worries. Of course people were upset when they heard what happened. Of course they want to know if it could happen here.
• Express compassion for the victims and their loved ones. What happened isn’t just a warning to you and a concern for your stakeholders. It’s also a tragedy for the people it happened to. (Make sure your compassion is mostly for the accident’s victims, not the organization’s management. “I’d hate to be in that executive’s shoes” is the wrong message.)
• Review your emergency response recommendations for your stakeholders. Should they have a “go kit”? Should they agree on an evacuation route? Do they know what the various emergency signals from the facility mean?
• Outline some precautions your stakeholders might take on their own. Articles about the Grenfell Tower fire, for example, often talked about fire extinguishers and other individual preparedness measures.
• Consider offering your own commentary on the accident – being careful never to downplay its seriousness. Can you be confident of coming across as a disinterested expert, not as biased or self-serving? If you can, you might want to seize the opportunity to bring people who haven’t paid much attention up to speed, to correct any misimpressions stakeholders might have gotten from the media coverage, and to establish your own expertise and safety-consciousness.

Explicitly or implicitly, your comments on another organization’s accident will either blame that organization or absolve it. “They did a bunch of things wrong that we do right” casts blame. “It could have happened to anybody” grants absolution. You can try to split the difference, but you can’t really avoid the issue. To one extent or another, the accident either signals a risk and a problem that’s industry-wide (including your facility), or it signals that that other organization is a bad actor that’s unfairly tarnishing your industry’s reputation.

Over my years as a consultant, I periodically found myself, just by chance, working with one company when another company in the same industry had a serious accident. Invariably the accident became a major internal topic of conversation. Sometimes my client expressed genuine shock that such a disaster could have befallen a sister company with a sterling safety reputation within the industry. Other times my client viewed the accident almost as if it were overdue, given that sister company’s abysmal safety reputation within the industry. Everyone knew which companies were the safety leaders and which were accidents waiting to happen. Nobody ever said so publicly.

My clients wanted to have it both ways. They didn’t want to criticize the organization that had the accident, and they didn’t want to admit that even a well-run organization like their own could have such an accident. That’s one reason why they were disinclined to talk publicly about another organization’s accident in the first place.

Why you don’t want to comment

How resistant you are to responding to your stakeholders’ concerns about somebody else’s accident will depend partly on what an honest response would be. Managements are understandably most comfortable explaining why it couldn’t happen here (#1 above) and least comfortable explaining why it could and there’s not much they can do to prevent it (#4).

But as I just noted, claiming such an accident couldn’t happen to your organization amounts to criticizing the organization it happened to. And there are other reasons why it’s tempting to leave the “Could it happen here?” question unanswered, even if your answer is no.

For one thing, horning in on somebody else’s disaster just to point out that “It couldn’t happen here!” is likely to get you accused of schadenfreude (joy in the misfortune of others). And if it’s unlikely to happen here but not impossible, horning in may feel a bit like tempting the gods, virtually asking for an accident.

Nor will it make you many friends in the organization whose accident you’re talking about. If you seem to be dancing on their grave, they may see fit to get back at you when something goes wrong in your shop (as something inevitably will, sooner or later).

An even more compelling reason not to comment on somebody else’s accident is the undesirability of attracting attention from journalists and regulators. If you say it couldn’t happen here, some reporter or official may decide to look into whether that’s really so. If you say it could happen here, you’re just asking for journalistic and regulatory scrutiny. Even if you keep mum, it’s possible a local reporter or official might turn up on your doorstep in pursuit of a local angle. But why offer yourself up voluntarily as the local angle of choice? (Even just volunteering a disinterested, third-party expert opinion on somebody else’s accident can boomerang if a reporter or official notes your name and decides to look into whether your organization has had any similar accidents, whether it could, etc.)

The same disincentive exists with regard to activists. Like journalists and regulators, activists often have more possible targets of their attention than they have resources to invest. Sometimes they think hard about whom to go after. Other times a prospective target unwisely calls attention to itself.

Finally, it’s usually better to avoid attention from the general public as well, especially if an accident has provoked widespread public outrage. Outrage shifts all too easily from one target to another. So unless you have a good reason to get involved, it’s wise to stay away from high-outrage controversies so you won’t become a lightning rod for outrage. In the language of psychiatry, it’s generally wise to “stay out of the projective field.”

In short, there are some pretty good reasons not to comment on somebody else’s accident.

Why I think you should comment anyway

There are also some pretty good reasons to go public.

The case for speaking out about somebody else’s accident is especially strong if your stakeholders are already aware of the accident and wondering what you’ve got to say about why it happened, what it taught you, and above all whether you’re vulnerable to something similar.

Of course if your stakeholders are wondering those things aloud, you may have no choice but to go public. Asking tough questions about other organizations’ accidents is a common (and entirely legitimate) activist tactic. So if your community advisory panel or your union or a local ENGO keeps raising the issue, refusing to respond really isn’t an option.

More often than not, however, somebody else’s accident is in your stakeholders’ minds but not necessarily on the table for discussion. They’re wondering and maybe they’re worrying, but they’re not actually asking. That’s when I see the most benefit in responding to their unvoiced concerns.

The main benefit is simply the opportunity to address those concerns. Even unvoiced, your stakeholders’ concerns are affecting how they relate to you and your facility. They’re a latent liability waiting to become manifest.

This is pretty much a risk communication axiom: If people are concerned, the fact that they’re not (yet) voicing their concerns is a foolish excuse for not addressing those concerns. Raising them yourself is far wiser than waiting and hoping they’ll just go away.

Note however that it’s not empathic to accuse people of concerns they’re not (yet) ready to voice. I think it’s best to raise the issue yourself if your stakeholders aren’t raising it, but you need to find a way (such as deflection) to raise it without being overly intrusive. “I know you’re all really worried about that accident at XYZ Corp.” isn’t empathic. “A few people have contacted us to ask about the XYZ Corp. accident,” if it’s true, is a much less intrusive way to raise the issue. Or: “There was an accident last week at XYZ Corp. that some people may be worried about, so I thought I should brief you on what it means for us here.”

The case for raising the issue yourself is much weaker when you doubt your stakeholders are even aware of that other organization’s accident, or doubt they see it as a reason to worry about your organization. If it’s not in their minds already, why put it there? But bear in mind two lessons from my 40+ years of consulting. First, organizations are far likelier to underestimate how worrisome an issue is to their stakeholders than they are to overestimate it. And second, it does far more harm to let a significant problem fester by ignoring it than to raise the visibility of a non-problem by unnecessarily addressing it. As I used to say to clients: By the time you start thinking it might be wise to address an issue, odds are you should have been addressing it long ago.

Now put that aside and assume that your stakeholders are genuinely unaware or unconcerned. Assume there’s no latent liability. So you really don’t have to talk about that other organization’s accident. Should you anyway?

The answer depends on what level of stakeholder concern you consider optimal over the long haul. It may be tempting to answer “as low as possible.” But unrealistically low concern is unsustainable. Eventually there’s a correction. And when it comes it typically overshoots; people rocket from insufficiently concerned to excessively concerned. The results can be devastating to your organization.

The wiser course is to educate your stakeholders so they understand the risks, are used to them, know what precautions are being taken, feel empowered to help decide what additional precautions should be taken, and feel comfortable with the risk management decisions that have been made so far.

In 2013, there was a deadly ammonium nitrate explosion at a fertilizer storage facility in West, Texas. A reporter for a fertilizer industry trade magazine sent me a series of questions, including questions about how fertilizer retailers around the country should handle the disaster. My answers included this advice:

The wise goal for the fertilizer retailing industry isn’t a public that is unaware of the risks; that’s a recipe for later over-reaction when people belatedly learn the truth. The wise goal is a public that understands the risks and considers them well-managed. This advice is even truer for stakeholders – a retailer’s neighbors, for example – than it is for the general public.

From that perspective, the West explosion created a teachable moment. For a week or so after April 17, people who live near where lots of fertilizer is stored were avidly interested in fertilizer risks. It was an ideal time for the fertilizer industry and fertilizer retailers to do some teaching. Of course it was an even more ideal time for proponents of greater regulation to make their case. But that doesn’t mean the industry should have gone silent. At a time when public and media interest was briefly high and critics were aggressively vocal, the industry needed to be vocal as well, nationally as well as locally – not defensive, not over-reassuring, but thoughtfully explaining the realities of fertilizer risks.

I added:

There are only three post-West choices for a fertilizer retailer that sells ammonium nitrate:

1. Duck the teachable moment. Hide. Pass up the opportunity to frame the issues thoughtfully, and wait to see how your critics will choose to frame them sooner or later.
2. Misuse the teachable moment. Over-reassure. Tell a one-sided story. Maybe you’ll get away with it for now (or maybe not) – but for sure the moment of truth will be all the more painful when it comes.
3. Seize the teachable moment. Explain the risks thoughtfully, and launch a mutually respectful dialogue about what precautions are being taken and what additional precautions, if any, might be worth taking.

I thought the third option was the way to go for fertilizer retailers in the wake of the West disaster. I thought it was the way to go for apartment managers after the Grenfell Tower fire. And though mine is a minority position, I think it’s the way to go for you, whenever there’s a newsworthy accident at a facility similar to yours.

Among the many benefits of raising stakeholders’ unvoiced concerns yourself:

• Your stakeholders may have misconceptions about the accident or its applicability to your facility. You can’t correct those misconceptions without talking about the accident.
• Similarly, your stakeholders may be more worried than the actual risk at your facility justifies. Without over-reassuring, you may have genuinely reassuring facts to offer them. You can’t do that either without talking about the accident.
• You are in fact paying attention to the accident and trying to learn lessons you can use to make your facility safer. It’s good for your stakeholders to know you’re the kind of organization that does that. (They may well imagine that your organization is blissfully oblivious or that it doesn’t dare take this new information onboard. They may not even know there are safety professionals like you on staff.)
• Over time, you need your stakeholders to understand the basics of risk assessment and risk management: that risk isn’t dichotomous and is never zero; that the goal is always to find feasible ways to reduce risk; etc. Another organization’s accident is an opportunity to teach these basics. It’s a teachable moment.
• Another organization’s accident is also a teachable moment vis-à-vis emergency preparedness and emergency response. Most of the time, most of your stakeholders aren’t interested enough to absorb what you want them to learn about these topics – so your safety pamphlets and the like go unread. A newsworthy accident elsewhere briefly piques their interest. Don’t waste the opportunity.

It’s not just accidents

Everything I’ve said about other organizations’ accidents is also true of other organizations’ misbehavior. In fact, it’s true of anything bad and newsworthy that has happened to another organization that you suspect may have raised stakeholder concerns about your organization.

In 2014 when Volkswagen was caught faking its diesel emissions, for example, other automakers should have added pages to their websites on the scandal. The questions they needed to answer were obvious. Are our emissions numbers honest? Are we sure they’re honest? What makes us so sure? Regardless of legal technicalities, do any of our cars have secret software like the VW diesel software that turns off emission controls on the road in order to improve performance, then turns them back on for laboratory emissions testing?

I didn’t check at the time, but I’d be willing to bet that few if any car companies answered these questions publicly until reporters, regulators, and activists explicitly demanded answers. That was a lot later than optimal … both for the companies whose answers were embarrassing and for those with nothing to hide.

The choice between casting blame and granting absolution is even starker for misbehaviors than it is for accidents. It invariably infuriated my clients that entire industries were damned in the public’s eye by the misdeeds of those industries’ worst performers. But my clients were almost never willing to name the worst performers, much less criticize them. “Either you break ranks,” I endlessly hectored client after client, “or you accept that you’re going to be painted with the same brush.” They hated being painted with the same brush. But they hated breaking ranks even more – for all sorts of reasons, from the desire to avoid awkwardness at trade association meetings to the fear of retribution if the tables were ever turned to the reluctance to undermine recruitment opportunities by alienating that other company’s executives.

The lessons of this column also apply to your own organization’s historical record – your predecessors’ accidents and misbehaviors. I wrote about that at length in a 2012 entry in my website Guestbook entitled “Apologizing for your predecessors.” With regard to your predecessors, of course, the key question is “Could it happen today?” rather than “Could it happen here?” And if your basic answer is no, it couldn’t, you face the same blame-versus-absolution dilemma: Either you defend your predecessors on the grounds that the times were different (different technical knowledge, different values, different regulations, etc.) or you accuse them of stupidity or even of evildoing.

The only significant difference is that your predecessors aren’t “somebody else.” You may feel like they are; you may have been in grade school when they ignited the neighborhood or contaminated the groundwater or whatever. But from your stakeholders’ perspective, the continuity is what’s salient. It’s your organization’s accident or misbehavior we’re talking about. So whether you’re mostly blaming or mostly absolving, either way you should be apologizing.

In a nutshell

Back in 2003, I wrote an article for the U.S. Centers for Disease Control and Prevention that tried to create a typology of kinds of emergencies and outlined the communication needs for each type. I entitled the article “Obvious or Suspected, Here or Elsewhere, Now or Then: Paradigms of Emergency Events.”

In terms of that typology, my core recommendation regarding somebody else’s accident is to turn an “obvious/elsewhere/now” emergency into a “possible/here/future” conversation.

As I have noted several times already, sometimes you have no choice. Regulators, journalists, or activists are raising the issue aggressively, and you’d be a fool not to respond.

My more controversial contention is that you should raise the issue proactively even if no one is forcing your hand. My case is strongest if your stakeholders are silently worrying (or if they might be – a possibility you’re all too likely to miss). But even if your stakeholders are calm, there are things you should want them to understand about the risks at your facility, and a newsworthy accident elsewhere is a teachable moment.

Copyright © 2017 by Peter M. Sandman

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