Why safety training fails when it becomes a checkbox instead of a commitment
Contributed by Jim Brigham, LCG VP of Risk Management, Former Operations Chief, State of Vermont, Office of Safety and Security
Series context. This is Part 5 of the Mindset Shift series, moving from individual readiness toward organizational culture. After exploring personal preparedness, time and distance, Run–Hide–Fight, and threat anatomy, this installment explains why safety programs fail without cultural reinforcement across leadership, environment, and daily practice. [1]
Why Safety Culture Fails on Paper but Matters in Practice
Many organizations believe they have a strong safety program because they have policies, training modules, and an Emergency Operations Plan (EOP). Yet during real-world incidents, these same organizations often experience communication breakdowns, slow decision-making, and a lack of coordinated response.
The problem is not the absence of documentation. It is the absence of a safety culture that activates those documents. Culture determines whether people speak up, whether leaders reinforce readiness, and whether employees trust the systems designed to keep them safe.
Federal guidance reinforces this reality. OSHA emphasizes that safety programs fail when they are treated as compliance artifacts rather than shared responsibilities. [2] FEMA’s Comprehensive Preparedness Guide makes clear that plans must be exercised, validated, and continuously updated to remain effective. [3]
A plan that lives in a binder is not a plan. It is a placeholder.
LCG perspective. Written plans create structure, but culture creates capability. Organizations that rely on documents alone discover, in the moment of crisis, that procedures without ownership collapse quickly.
When Reporting Becomes Safe, Culture Changes
The gap between policy and practice becomes visible only when systems are tested over time. During my tenure as Operations Chief for the State of Vermont, one of the most challenging tasks was changing a deeply embedded reporting culture that discouraged employees from speaking up.
Under the legacy model, employees were instructed to report concerns through their supervisors, with the expectation that issues would move up the chain of command. In reality, they rarely did. Complaints routinely stopped at the supervisory level, where fear, discretion, or discomfort prevented escalation. On paper, a reporting process existed. In practice, it quietly failed.
To address this, we designed and implemented a centralized Risk Management System (RMS) that allowed employees to file complaints directly, without supervisory gatekeeping. The system was intentionally structured to reduce fear of retaliation and to normalize direct reporting as an organizational expectation rather than an act of defiance.
The impact was measurable. Annual complaints increased from approximately 400 to more than 1,400. This was not evidence of worsening conditions. It was evidence that fear was diminishing and trust was growing. Employees were reporting because they believed it was safe to do so.
Leadership behavior reinforced the change. When supervisors attempted to file complaints on behalf of employees, we acknowledged both the supervisor and the employee, then removed the supervisor from the process, sending a clear message: the organization needed to hear directly from the individual with firsthand information. Over time, supervisors adapted. Emails began arriving stating, “I have encouraged my employee to file a complaint directly through the RMS system.”
The system worked not because it existed, but because leadership consistently reinforced its purpose. Reporting was normalized. Silence was no longer the default. Culture, not policy, became the driver of safety.
This experience illustrates a broader truth: safety programs fail not because systems are missing, but because culture determines whether those systems are trusted, used, and reinforced.
The Three Failure Points of Most Safety Programs
- Safety Plans Are Static Instead of Practiced
Emergency Operations Plans require rehearsal, not just approval. Yet in many workplaces, drills occur annually, if at all. Employees never build muscle memory, supervisors never validate procedures, and leadership never tests assumptions under simulated stress.
FEMA notes that preparedness is inherently dynamic and must be built through recurring exercises that expose weaknesses before a crisis occurs. [3]
- Leadership Endorses Safety but Does Not Model It
Announcements or policies do not create a safety culture. It is made by leadership behavior. Employees mirror the priorities they observe. When leaders treat drills as optional, dismiss early warning signs, or delegate safety entirely to one department, the culture follows.
OSHA identifies management commitment as the strongest predictor of safety performance and incident reduction. [2]
- Employees Do Not Feel Safe Speaking Up
The most overlooked element of organizational readiness is psychological safety. Employees often hesitate to report behavioral concerns, environmental risks, or procedural gaps out of fear of being dismissed or penalized.
DHS prevention guidance emphasizes that early reporting is the most critical factor in identifying pre-incident indicators. [4] When people remain silent, organizations lose their earliest warning system.
From Awareness to Action: What Successful Safety Cultures Do Differently
- Leadership Engagement Translates Policy Into Practice
Effective leaders:
- Attend the same training as employees
- Communicate safety expectations consistently
- Reinforce that reporting concerns is encouraged and protected
- Allocate time for safety discussion in routine operations
When leadership models the behavior, participation becomes normalized.
- EOPs Become Living Documents
Resilient organizations:
- Conduct regular tabletop and scenario-based exercises
- Update EOPs through after-action reviews
- Integrate lessons learned across HR, Facilities, and Safety
- Align plans with FEMA CPG 101 and DHS guidance
Plans must evolve with operations, staffing, and emerging threats.
- Reporting Channels Are Clear and Multi-Layered
Employees must know how and where to report concerns. Best practices include:
- Anonymous and confidential reporting options
- Multiple reporting paths
- Documented escalation procedures
- Feedback loops that confirm concerns were received
These practices align with DHS guidance on building reporting cultures. [4]
- Drills and Training Are Frequent, Realistic, and Trauma-Informed
Training should:
- Use realistic but safe scenario-based learning
- Incorporate Run–Hide–Fight decision-making
- Teach behavioral threat indicators
- Account for trauma sensitivity
FEMA and CISA emphasize that training transforms passive awareness into active capability. [3][5]
- Culture Recognizes That Everyone Has a Role
Safety culture becomes real when:
- Leaders reinforce readiness daily
- Supervisors practice decision-making
- Employees understand their role in early recognition
- Facilities staff identify environmental risks
- HR integrates behavioral threat assessment into case handling
The most resilient organizations treat safety as a shared operational responsibility, not an annual requirement.
Frameworks, Common Pitfalls, and Mitigations
Relevant Frameworks
- OSHA Safety and Health Management Systems [2]
- FEMA Comprehensive Preparedness Guide (CPG 101) [3]
- DHS reporting and violence prevention guidance [4]
- CISA Active Shooter Preparedness resources [5]
Common Pitfalls
- Plans not exercised or updated
- Leadership delegating safety ownership
- Unclear reporting processes
- Inconsistent departmental responses
- Drills are conducted only for compliance
Mitigation Strategies
- Quarterly tabletop exercises and annual full-scale drills
- Cross-functional safety committees
- Clear reporting tools and escalation paths
- Integration of behavioral threat assessment
- Routine facility walk-throughs using CISA guidance
Quick Checklist
- Make your EOP a living, exercised document.
- Establish visible leadership reinforcement.
- Build psychological safety so employees feel safe reporting concerns.
Final Thought
Culture, not compliance, determines how people act when moments matter. When safety becomes a shared value supported by leadership behavior, repetition, and trust, organizations gain what no document alone can create: a workforce capable of acting decisively, confidently, and collectively when seconds count. [6]
References (Endnotes)
[1] LCG Discovery. Mindset Shift Series Outline. Internal planning document.
[2] Occupational Safety and Health Administration (OSHA).
Recommended Practices for Safety and Health Programs. U.S. Department of Labor, 2023.
https://www.osha.gov/sites/default/files/publications/OSHA3885.pdf
[3] Federal Emergency Management Agency (FEMA).
Comprehensive Preparedness Guide (CPG) 101: Developing and Maintaining Emergency Operations Plans.
U.S. Department of Homeland Security, Version 3.0, 2021.
https://www.fema.gov/emergency-managers/national-preparedness/plan
[4] U.S. Department of Homeland Security (DHS).
Foundations of Targeted Violence Prevention. 2023.
https://www.dhs.gov/foundations-targeted-violence-prevention
[5] Cybersecurity and Infrastructure Security Agency (CISA).
Active Shooter Preparedness Action Guide. Updated 2025.
https://www.cisa.gov/active-shooter-preparedness-action-guide
[6] Brigham, J., and LCG Discovery Research Team. Applied risk management field experience.





