This article was published in the September 2010 issue of The Synergist, the journal of the American Industrial Hygiene Association, pp. 29–31. It was written in early July, 2010.

If the worst marine oil spill in U.S. history happens on your watch, you’re obviously due for some serious reputational damage, no matter how skillful your risk communication advisors may be.

In that sense, BP’s problems are far more fundamental than its risk communication failures.

But in at least two ways – ways that are crucial to your job as an industrial hygienist – risk communication is at the heart of the April 20 explosion aboard the Deepwater Horizon drilling rig in the Gulf of Mexico. I’ll talk about those two first, then draw some other lessons from BP’s risk communication performance so far.

Don’t Drink Your Own Kool-Aid

Long before the Deepwater Horizon catastrophe, deepwater oil drilling was a major public controversy. Along with the rest of the oil industry, BP advanced two risk communication arguments in support of ramping up deepwater exploration: (a) A major deepwater oil spill is vanishingly unlikely; and (b) if there were such a spill, the industry is prepared to cope so as to assure minimal damage.

These claims were made not just by PR people and lobbyists, but also by risk assessors filing emergency response plans with the Minerals Management Service (MMS) – plans whose patent inadequacies are now fodder for comedians.

I can’t assess the truth of the first claim; maybe BP was just profoundly unlucky. But the whole world now knows the second claim was false. It’s not just BP that couldn’t cope; the heads of other major oil companies have since testified that they don’t know how to deal with a deepwater oil spill either. So either they all knew they were unprepared for a spill and simply lied, or they all convinced themselves they were adequately prepared for a spill.

The strongest evidence that it’s at least partly the latter is the long list of obvious things BP could have done if it had secretly known it was woefully unprepared. It could have stockpiled more booms, commissioned a physicist to guess how oil entering icy water under high pressure might behave, etc. Or if it were secretly convinced a deepwater spill would be an immitigable disaster, it could have taken steps to reduce the probability of such a disaster – testing its blowout preventer more often, for example, and installing a backup acoustic switch, etc.

The oil industry’s leaders drank their own Kool-Aid. The industry’s techies produced what were essentially false PR documents, and ended up believing them. How certain are you that your own organization’s emergency response plans are not similarly contaminated with false PR influences that you have unwisely come to believe?

Make Sure Workers Feel Empowered to Blow the Whistle

It will be years before there’s anything like a consensus on what went wrong aboard the Deepwater Horizon rig. But it is clear already that a lot of things were going wrong in the run-up to the disaster.

Some of this is undoubtedly hindsight bias. After every disaster, investigators find warning signs that were ignored. If there were just as many “warning signs” at facilities that had no subsequent disaster, then the warning signs lacked predictive value and ignoring them wasn’t necessarily culpable.

It is equally unsurprising to find people who now say they “always knew that rig was gonna blow up.” That could be hindsight bias too.

But in the case of the Deepwater Horizon, it really does look like a lot of warning signs got ignored and a lot of people aboard the rig were worried about those warning signs.

So why weren’t they raising hell? Everyone aboard Deepwater Horizon – Transocean people and Halliburton people as well as BP people – had Stop Work Authority (SWA), a right and an obligation long enshrined in offshore drilling operations. That is, anyone who believed a practice to be dangerous was entitled to force a halt without risking retribution (at least formal retribution), even if the brass wanted the work to proceed.

Whistle-blowing opportunities aside from SWA ranged from internal complaint hotlines to story-hungry journalists; even the MMS might have been interested.

The most damning thing we know about BP’s safety culture is that nobody blew the whistle.

What about your safety culture? Would you raise hell to stop something that looked like a disaster waiting to happen? And if you missed it, or were too cowed to blow the whistle, would others at your operation raise hell anyway?

Crisis Communication Failures

The two failures I have discussed so far were pre-crisis precaution advocacy failures inside the industry. Once the crisis was underway, the focus shifted to external crisis communication.

For the first couple of weeks after the Deepwater Horizon explosion, I actually thought BP was doing a pretty good crisis communication job. In a May 3 BBC interview I gave the company a B.

Either BP’s crisis communication performance plummeted soon after or I was giving it too much credit in the first place, bending over backwards not to blame the company’s communicators for the impossible situation in which they found themselves. As I write this column in early July 2010, a D seems more like the right grade.

Maybe the grade will improve by the time you read this column some months hence, especially if the relief well effort succeeds in August and BP finally has something good (and true) to report: no more oil gushing into the Gulf of Mexico. But I doubt it. Deepwater Horizon now seems a sure bet to become a case study of how not to communicate during an environmental crisis.

So it’s time to harvest some lessons. Here are four.

1. Don’t over-reassure.

Crisis communication experts advise their clients to err on the alarming side, especially early on when uncertainty is highest. Later messaging that “It’s not as bad as we feared” goes down a lot better than “It’s worse than we thought.” Ignoring this advice (or perhaps never even receiving it), BP endlessly repeated the rookie mistake of over-optimistic over-reassurance.

Leave aside CEO Tony Hayward’s blithely tin-eared claim that a “relatively tiny” amount of oil was spilling into a “very big ocean.” BP’s quantitative estimates of how much oil per day was spewing into the Gulf had to be raised time after time, while its estimates of how much oil it was managing to recover had to be lowered.

In July the company belatedly started to catch on. It replaced earlier near-promises that relief wells would end the spill by August with more pessimistic assessments: hoping the relief wells would be ready by August and hoping they would work, but warning about the possibility of snafus and even detailing backup plans (and backups to the backups) in case the relief wells failed altogether.

2. Make contrition credible.

BP has apologized early and often for the oil spill – sort of. Why are its apologies unpersuasive? Consider this excerpt from Hayward’s June 18 testimony before the House Energy and Commerce Committee. “The explosion and fire aboard the Deepwater Horizon and the resulting oil spill in the Gulf of Mexico never should have happened, and I am deeply sorry that it did.”

I’m sure Hayward is also deeply sorry that people get cancer and start wars. But apologies require more than regret. They require acceptance of responsibility. The Committee kept pressing Hayward to concede that BP had contributed to the disaster by cutting corners and ignoring red flags. Or, indeed, that BP had done anything wrong, anything that contributed to the disaster, anything at all.

He wouldn’t go there, insisting that we should all await the conclusions of the many ongoing investigations rather than speculating on what went wrong.

That may be good litigation strategy, but it isn’t good risk communication. Perpetrators can’t simultaneously apologize and refuse to “speculate” on whether they did anything wrong. The first step in an effective apology is to say what you did that you’re apologizing for. “The investigations will add to the list, but here are five serious mistakes we feel we made that helped bring about this horrific spill….”

Or if your lawyers won’t let you go that far: “The investigations will identify mistakes that helped bring about the spill. Preliminary evidence suggests that these five will probably be on the BP portion of the list that emerges….”

Even when BP has acknowledged specific blameworthy facts, it has done so without emoting, without any credible expression of shame or contrition. In an interview with the Financial Times on June 3, Hayward agreed it was “an entirely fair criticism” to say the company had not been fully prepared for a deepwater oil leak. “What is undoubtedly true,” he conceded, “is that we did not have the tools you would want in your toolkit.”

This significant admission comes across as bloodless, almost casual. If Hayward and his BP colleagues are angst-ridden by what the company did and failed to do – as I assume they must be – they have yet to find a way to make it show.

3. Make compassion and determination credible.

Besides contrition, a company that messes up big-time needs to demonstrate at least two other responses to its own misbehavior: compassion for those who were harmed and determination to “make it right.” On both counts, BP has tried … and failed.

My best guess is the compassion really isn’t there at the top. There have got to be plenty of BP employees who really feel for the people and creatures of the Gulf region. But from “what the hell did we do to deserve this?” to “I’d like my life back,” top management keeps leaking its sense of its own victimization. The corporate expressions of compassion for the real victims ring false, I suspect, because they are false. Compassion is hard to fake.

But maybe BP management does feel for the victims, and just can’t communicate it. At least part of the problem is that compassion isn’t credible (even if it’s real) when it’s expressed by a perpetrator who’s unwilling to express contrition first. Almost everything BP has said about what Gulf Coast residents are going through could have been said by a sympathetic third party. BP is a bit like a rapist trying to sound compassionate without admitting the rape.

Determination is a different story. BP hasn’t just expressed its determination to make things right. It has acted on that determination.

Days after the spill began, BP announced that it wouldn’t try to hide behind the $75 million statutory liability limit for marine oil spills but would pay all legitimate claims.

Instead of praising this decision, commentators complained that the word “legitimate” was a loophole that could let BP out of paying some claims. And they pointed out that the $75 million limit wouldn’t apply anyway if BP or any of its contractors had been grossly negligent or had violated any federal safety regulations. The latter, at least, is a safe bet. There are so many regs it’s inconceivable that none were violated. So BP may have been smart rather than generous in forswearing the limit rather than giving the government yet another reason to document the violations.

In the months that followed, BP set up a claims payment procedure that critics have grudgingly conceded was fast and fair. (Even fishermen who had cheated on their taxes were allowed to submit “informal” evidence that their lost income was higher than their tax forms showed.) Then BP and the Obama administration negotiated a $20 billion claims fund, with more money to come if it turns out to be needed.

It’s not especially surprising that a company run by engineers would be more genuine in its determination to fix the problem than in its contrition for having caused it or its compassion for the victims. Fixing problems is what engineers do; contrition and compassion are the sorts of things humanities majors go on about.

But BP hasn’t been able to convince anyone of its determination either.

At least one reason is that normal people think like humanities majors. Certainly victims do. We rightly sense that BP isn’t really contrite or compassionate. That exacerbates our outrage. It makes us doubt the evidence that BP is determined to plug the leak and clean up the mess. Worse, it makes us want to see BP as the kind of company that will try to wriggle out of its cleanup obligations unless the government keeps its boot firmly planted on the company’s neck.

We think like humanities majors in another way as well. The unfolding drama of the Deepwater Horizon spill has revived the public’s sense of the tragic: our sense that not all problems have solutions. People realize that nobody can “clean up the mess” in the Gulf of Mexico entirely. One source of our unwillingness to trust BP’s determination to “make it right” is our understanding that making it right is relative.

4. Say how stupid you feel.

When a company misbehaves, there are only two possible explanations for its misbehavior that don’t sound like excuses: evil/greed and stupidity/incompetence.

Which is more common, corporate evil or corporate stupidity? I’d say stupidity, by a mile. Which does the public think is more common? Evil. Which does the company’s reputation more harm? Again, evil.

These facts are the basis for what I call “the stupidity defense.” Unless you aggressively claim stupidity, the default explanation for your misbehavior is evil. If you were in fact stupid, therefore, you should say so.

Having lost roughly half its shareholder value, BP pretty obviously was stupid. On clearheaded days, I’ll bet BP management feels it was stupid (on less clearheaded days management no doubt feels it was unlucky and victimized). But the company isn’t saying so, and evil has become the almost universally accepted explanation … as if an oil company would greedily twirl its mustaches while it intentionally destroyed half its shareholder value.

Smart companies assess the probability and magnitude of various risks, and the assessment helps them decide which risks to take and which to avoid or mitigate. Almost by definition, a company that loses half its shareholder value in an oil spill did a faulty risk assessment (or none at all). It was stupid. A lot of precautions BP didn’t take look pretty obviously cost-effective now. And not just in hindsight: It’s obvious now that it should have been obvious then.

The stupid-versus-evil question is more complicated than I’m making it sound. If BP thought it was properly prepared to cope with a deepwater spill, it was stupid. If it thought the rudimentary spill response plan it submitted to the MMS was sufficient, it was incredibly stupid. Insofar as we can’t believe BP could be quite that stupid, then it was pretending to think the plan was sufficient … which really is evil.

BP is joined in that evil by the rest of the oil industry; their spill response plans were largely carbon copies of each other. It is joined in the evil by the Bush and Obama administrations, both of which claimed confidence that the oil industry was ready for a deepwater spill. And maybe it is joined in the evil by all of us who willfully look the other way when environmentalists warn of the costs of cheap oil.

Another complexity: An excessive focus on share price and quarterly earnings instead of the long-term viability of the company may be where evil meets stupid.

And a third: When the public finds out about the risk assessments smart companies do, it sometimes considers them evil too. “You knew this defect could kill people and you consciously decided it was cheaper to pay for those deaths than to get rid of the defect.”

But put the complexities aside. BP took a company-threatening risk on deepwater oil exploration while cutting corners on safety. That was stupid. People think it was evil. Letting that happen is stupid crisis communication.

Note: I have consulted periodically for BP since the 1980s, including work on its 1990 American Trader oil spill in Huntington Beach, California. In 1992, BP published an admiring profile of me in its house magazine, Shield. My most recent work for BP was in 2003, on the Baku—Tbilisi—Ceyhan pipeline.

Copyright © 2010 by Peter M. Sandman