Safety Culture Ladder level 2: reactive
Level 2 on the Safety Culture Ladder is the reactive level: an organisation only acts after an incident, and attention fades again once the problem is resolved. NEN summarises it as “attention to safety is ad hoc and short-lived”. It is the second of the five levels of the Safety Culture Ladder (Veiligheidsladder, SCL).
An audit can result in level 2, but for most clients that is too low. Since July 2026, ViA requires at least level 3, and ProRail also requires level 3 from contractors. Level 2 is therefore mainly a starting point. This page helps you recognise whether you are at level 2 and how to make the step up to level 3.
Characteristics of Safety Culture Ladder level 2
The official description of the levels from NEN lists four characteristics of a reactive culture:
| Characteristic (NEN) | What it means in practice |
|---|---|
| The organisation only acts after incidents | Measures arise after an accident, not during preparation |
| Actions are ad hoc and aimed at the short term | An extra sign, a quick rule, an email round |
| Once the problem is solved, attention fades | After a few weeks, everyone works the way they did before |
| Managers point to the rules but do nothing when they are not followed | ”You know you have to wear a helmet” with no consequence |
The difference from level 1 (pathological) is that safety is taken seriously, but too late. The difference from level 3 is that there is no system yet that identifies risks in advance.
What does a level 2 company sound like?
Culture shows in what people say. These are typical statements at level 2, with what lies behind them.
| Who | Statement | What it reveals |
|---|---|---|
| Director | ”Since that accident last year, we have been much more careful.” | Safety is linked to one incident |
| Site manager | ”That barrier has been there since someone fell into the pit.” | Measure taken afterwards, not from a risk assessment |
| Fitter | ”Report it? Only if something really happens.” | Near misses are not reported |
| Project manager | ”Safety is important, but the schedule comes first right now.” | Production wins under pressure |
| Employee | ”The rules are on the wall in the site cabin, but nobody looks at them.” | Rules without enforcement |
An example from practice. A grounds maintenance company with 25 employees has an accident with a brush cutter: a stone hits a colleague. Straight afterwards, the company buys new visors and holds a toolbox talk. Three months later, part of the crew is working without a visor again, and nobody says anything. That is level 2 in a nutshell.
What does the auditor see at level 2?
A Safety Culture Ladder audit is not a document check. Two auditors hold conversations at all levels and look around the office and on project sites. Read more about the audit process. At an organisation at level 2, auditors typically see the following:
| What the auditor examines | Level 2 signal |
|---|---|
| Interview with the board | Can only illustrate safety with incidents from the past |
| Interview with employees | Do not know what happens to reports, or do not report |
| Workplace observation | Rules are followed inconsistently, depending on who is present |
| Incident recording | Only accidents with injury, hardly any near misses |
| Improvement actions | Loose actions without follow-up or evaluation |
The auditor assesses this through the five themes of SCL 2.0. For each theme, the page on requirements per level shows the difference between levels 2, 3 and 4.
Which clients accept Safety Culture Ladder level 2?
Fewer and fewer clients. The two largest users of the Safety Culture Ladder require a higher level:
| Client or framework | Requirement | Source |
|---|---|---|
| ViA (Governance Code Veiligheid in de Bouw) | Level 3 from July 2026 | GCVB |
| ProRail, recognised rail contractors | SCL Original, at least level 3 | ProRail |
| ProRail, contractors not yet recognised | Level 3 within 3 months of contract award | ProRail |
Level 2 can still be useful for clients outside these frameworks, or as an intermediate step. An audit with level 2 as the outcome shows in black and white where you stand. But do not count on it to bid for tenders in construction, infrastructure or rail.
Do you receive level 2 at an audit while your client requires level 3? Then you do not meet the requirement. So first carry out a baseline measurement with the SAQ in the SCL web tool and a gap analysis before you plan an audit.
From level 2 to level 3: what needs to change?
The step from level 2 to level 3 is mainly a step from reacting to organising. At level 3, your company identifies risks in advance and has systems to report and analyse incidents. These are the five changes that deliver the most.
| From (level 2) | To (level 3) | Concrete action |
|---|---|---|
| Measures after an accident | Assess risks in advance | An up-to-date RI&E (risk inventory and evaluation) and task-based risk analyses per project |
| Reporting only accidents | Also report near misses and unsafe situations | A simple reporting system, and feedback on every report |
| Loose actions | Actions with an owner and a deadline | One action list that the board reviews monthly |
| Rules without enforcement | Managers steer on compliance | Agreements on how to address people and what the consequences are |
| Safety as an incident topic | A fixed agenda | Safety as the first item in every work meeting and a fixed toolbox programme |
Already have a VCA certificate? Then you already have many of these systems. Think of the task risk analysis, workplace inspections and reporting near misses. The difference for the Safety Culture Ladder is that the auditor wants to see that people actually use them, not just that they exist.
Common mistakes on the way from level 2 to level 3
Companies that want to move from level 2 to level 3 often run into the same problems.
| Mistake | Why it goes wrong | Better approach |
|---|---|---|
| Only writing documents | The auditor talks to people and looks at the workplace | Let each new system run for a few months first |
| Making reporting mandatory without feedback | People stop when they never hear what happens to their report | Give feedback on every report, even if you change nothing |
| Preparing only the board | Interviews take place at all levels | Discuss the Safety Culture Ladder in the toolbox talks too |
| Planning an audit too early | A disappointing level costs time and money | First the baseline measurement and gap analysis |
How long does the step from level 2 to level 3 take?
There is no fixed timeframe for this. It depends on how many systems you already have and how quickly behaviour changes. A company that already has VCA is often faster than a company starting from zero. In any case, allow time between the baseline measurement and the audit, so you can also show your improvements in practice. Indications of lead time and costs are on costs and timeline.
Frequently asked questions about Safety Culture Ladder level 2
Is level 2 bad?
No, it is an honest starting point. Many companies begin here. It means that safety does receive attention, but too late. If you know that, you can improve in a targeted way.
Can I go straight for level 3 without first going through level 2?
Yes. You do not choose a level at the audit; the auditor determines which level you are at. So you can work directly towards level 3.
Which SCL product fits level 2?
SCL Original, SCL and SCL Light all give a level indication; the Approved Self Assessment does not. For small organisations, SCL Light is a lighter entry point, with a statement up to a maximum of level 3.
Does a VCA certificate help you move beyond level 2?
A working VCA system provides many building blocks for level 3, such as risk analyses, inspections and a reporting system. It does not guarantee a higher level. The auditor checks whether people actually use those systems. Read Safety Culture Ladder vs. VCA.
More about the Safety Culture Ladder
- The 5 levels: overview of all levels
- Safety Culture Ladder level 3: the next step explained
- Behaviour and culture: why behaviour is the core
- Description of the SCL levels (NEN) : the official text