Key takeaways:
Most businesses have a safety program on paper. A handbook, an annual training, a policy folder that no one’s opened in months. But the “right” program on paper might not be accomplishing anything. A gap often exists between the written policy and how leadership treats safety day to day.
When safety is seen as a compliance task, the same types of injuries can recur. When leadership owns safety, the results look different – fewer surprises, fewer injury patterns, and a program that holds up under pressure instead of sitting on a shelf.
To dig into what separates the two, we talked with Brian Fielkow, Executive Vice President of Risk Resources at Acrisure and author of Making Safety Happen. Fielkow spent years running businesses in high-hazard industries before moving into risk consulting, and he’s built a practical framework for distinguishing between a program that’s engaged and one that’s just documented.
5 questions to assess your safety program
Fielkow doesn’t start with compliance or the number of policies in your handbook. He starts with five questions:
- Is it leader-driven? Leaders don’t need to act as the safety director, but safety must be a non-negotiable value that leadership doesn’t compromise on, and the rest of the organization has to see that.
- Are employees engaged? Can your team report hazards, raise concerns, or stop work without fear of retribution?
- Is it anchored in clear process? Documentation alone isn’t enough. Processes only mean something if the people using them understand them and follow them consistently.
- Is there individual and organizational accountability? Not just “who has their hands on the wheel,” but also the training, staffing, and resources the organization has given that person.
- Is there resilience and continuous learning? When something goes wrong, or a near miss happens, does the team get curious about it and teach what they learned, or move on and hope it doesn’t happen again?
According to Fielkow, the key with process is that “it has to be understandable by the audience for whom it’s intended.” When the average American adult reads at roughly a seventh- to eighth-grade level, your policies and communications must follow suit. A 600-page handbook written above your team’s reading level, or in a language most employees don’t speak natively, isn’t accessible.

Responsibility and accountability aren’t the same thing
Who’s responsible for workplace safety? Some people point to the safety department, others say everyone. Fielkow’s take: There’s only one right answer, and it’s the second one. Safety responsibility isn’t something you delegate to a title or team.
Accountability is where it gets murkier. When something goes wrong, most organizations stop at the person whose hands were on the equipment. Fielkow argues that’s an incomplete inquiry.
“The real accountability is grounded in hidden risks that don’t get properly managed.” Rushed training. Ignored near-miss reports. Deferred maintenance. Those are organizational failures that can be unfairly blamed on an individual.
That distinction changes how you investigate an incident. Look past the individual, and you usually find the environment that put them in a position to fail.
Three blind spots that break safety programs
Fielkow named three patterns he sees repeatedly when leadership gets safety wrong, and each one is easy to miss because it can feel like progress to the people doing the work.
1. Treating compliance as the finish line
Passing an audit feels like proof you’re safe. It isn’t.
“Regulations generally prescribe the bare minimum, and safety requires so much more.”
A company can be fully compliant on paper and still be operating well below what real safety requires. Compliance sets a floor, not a target.
2. Making safety a department (or role) instead of everyone’s job
Safety teams exist to teach, train, and coach. They don’t operate the equipment or make decisions on the floor. Fielkow put it plainly: “Operations, and only operations, is responsible for the execution of safety.” The moment leadership rewards operations purely for productivity, safety takes a backseat by design.
3. Calling safety a priority instead of a core value
Language matters, especially when it comes from leadership or appears in official company communications. Fielkow pushed hard on this point:
“Priorities shift. They compete with each other. That’s the joy of being in business; it means if safety is a priority, other things can compete with it. I like to say safety has to be a non-negotiable core value, and only leaders can make that point.”
A priority list gets reshuffled the second a key customer calls with a problem. A core value doesn’t compete with anything, the same way integrity doesn’t. If leadership pushes safety aside when the unexpected arises, employees will too.
Tracking safety before you have incidents or claims
Fielkow’s other must for leaders: Know what you’re measuring. Counting injuries tells you what already went wrong. It doesn’t tell you whether the systems around your team are working. “We don’t measure financial success by the absence of bankruptcy,” he remarked, “so let’s not measure safety success by the absence of injuries.”
High-performing organizations track both.
| Lagging indicators | Leading indicators |
| Loss runs and claims history | Hazard reports and speed to resolution |
| OSHA and DOT audit data | Training completion rates |
| E-mod and premium costs | Safety committee activity and employee engagement |
| Financial statements | Pre- and post-task inspections |
Lagging indicators tell you where you’ve been. Leading indicators tell you where you’re headed – and they’re ignored too often.
📍 Read next: Safety Metrics: How to Measure Your Program’s Success >
Where to start if your program is mostly on paper
If an honest assessment tells you your program lives mostly in a binder, Fielkow’s advice is to resist the urge to fix everything at once.
Start with mitigating SIF (serious injury and fatality) risk. Not every hazard deserves equal attention. Chasing every paper cut in the office while ignoring a situation that could kill someone is a misallocation of resources. Focus where the stakes are highest.
Build processes with the people doing the work. Fielkow’s gap-survey approach is simple: Ask the frontline what they see, what’s working, and what a CEO-for-a-week would change. Answers from a conference room of leaders alone tend to plateau.
And celebrate the wins, even small ones. Fielkow told us about a big-screen TV he promised his trucking company for hitting a quarterly safety milestone: “Believe it or not, we gave away eight in a row.” A visible, achievable milestone does more for momentum than a five-year injury-free goal nobody believes is realistic.
It’s the same logic MEM’s own safety and risk consultants lean on with policyholders working to bring their experience modifier down: Small, provable wins compound faster than sweeping goals.
Owning safety changes everything
Fielkow closed with a story about Paul O’Neill, who became CEO of Alcoa in 1987 and told investors that if they wanted to know how the company was doing, they should look at its safety performance, not its margins.
O’Neill’s reasoning was simple: A company where people are getting hurt isn’t doing well in other areas. Safety is a visible signal of deeper operational discipline, and that discipline drives results. Alcoa’s stock multiplied several times over during O’Neill’s 13 years running the company, before he went on to serve as U.S. Treasury Secretary.
The dollars matter, but as an employer, you also have an obligation to protect your employees. “This is your moral obligation as a leader and a hardcore business proposition,” summarized Fielkow.
When leadership owns safety instead of just signing off on it, people are safer – and everything rises:
- Morale
- Employee retention
- Operational efficiency
- Reputation with customers
- Standing on job bids with e-mod requirements
And, at the end of the day, your company’s bottom line.
Want to build safety leadership that goes beyond compliance and achieves these results? Dig in: Workplace Safety Leadership: More than a Checklist >
Frequently asked questions: Successful safety programs in practice
How do I know if our safety program is working and not just on paper?
Check it against five questions: Is leadership driving it, are employees comfortable reporting hazards, is the process genuinely followed and understandable, is there accountability at both the individual and organizational level, and does the team learn from near misses instead of moving on? If most of those get a no, the program exists on paper more than in practice.
What’s the difference between responsibility and accountability in workplace safety?
Responsibility means everyone owns their role in preventing incidents, not just the safety department. Accountability goes further – when something goes wrong, it means looking past the individual involved and into the training, staffing, and conditions the organization put in place.
Why isn’t OSHA or DOT compliance enough to guarantee a safe workplace?
Regulations set the minimum legal standard, not the standard for excellent safety performance. A company can pass every audit and still have gaps in training, process, or leadership follow-through that put employees at risk.
Should safety be called a priority or a core value?
Treat it as a core value, not a priority. Priorities compete with daily pressures like deadlines and customer demands, so anything labeled a priority can get pushed aside. A core value doesn’t compete with anything.
Where should a business start if its safety program mostly lives in a handbook?
Start with serious injury and fatality (SIF) prevention rather than trying to fix every hazard at once. Build or revise processes with input from the frontline, not just leadership, and look for small, visible wins to build momentum instead of setting a long-term goal that doesn’t feel realistic.
Does treating safety as a leadership responsibility affect a company’s bottom line?
Yes, both directly and indirectly. Companies that treat safety as foundational tend to see better morale and retention, stronger standing on job bids with experience modifier requirements, and lower claims costs over time.