Promoting safe behavior at work is a critical part of the health and safety management, because behavior turns systems and procedures into reality. On their own, good systems do not ensure successful health and safety management, as the level of success is determined by how organizations ‘live’ their systems. The behavioral programs currently in use focus on promoting safe behavior among frontline staff. These programs therefore exclude a large proportion of other behaviors that influence health and safety performance. There is potential to extend the behavior modification principles and strategies currently used, to encourage and promote behaviors which support the health and safety management system (HSMS) and the development of a positive health and safety culture. Behavioral programs have become popular in the safety domain, as there is evidence that a proportion of accidents are caused by unsafe behavior. Whilst a focus on changing unsafe behavior into safe behavior is appropriate, this should not deflect attention from analyzing why people behave unsafely. To focus solely on changing individual behavior without considering necessary changes to how people are organized, managed, motivated, rewarded and their physical work environment, tools and equipment can result in treating the symptom only, without addressing the root causes of unsafe behavior. Given that it is the behavior of management that is most critical in creating a culture of HSE in any organization, behavioral safety observations are likely to have their greatest impact if directed upwards, at managers. This paper provides a critical look at the assumptions that underlie such programs and identify some of their limitations.