ALARP, The Regulator and Alt-Facts
Post by Hayden Collins, First published here
Don’t you just love ‘fact sheets’? Especially when they don’t contain ‘facts’. (Sound like something you may have heard recently?) I recently picked up a ‘fact sheet’ from the NSW Department of Industry on ‘Mine Safety’ that was packed with contradictions about the fundamentals of risk and safety, proposed as ‘fact’.
The two-page flyer is loaded with the favourites of the Regulator and Safety – ‘obligations’, ‘elimination’, ‘control’ and ‘assessment’.
The stated concern of the flyer is about managing fatigue; but the real (and covert) agenda is centered on fear, risk aversion, the manipulation of the meaning of the WHS Act to suit a hidden agenda. Why would the Regulator – the supposed ‘Guardian of the Act’ do this?
The flyer is entitled ‘Managing Fatigue in the Workplace’ but the document is not at all about the process of ‘management’. The concept of management denotes the juggling of complexity yet embodies as a process ‘no absolute solutions’. When we manage a household, we do our best to tackle the problems, juggle competing activities and numerous multi-layered issues. We know there is no perfect outcome, that things change and we do our best to ‘manage’ that change. So, the management of fatigue is not about the elimination of fatigue; because it cannot be eliminated for real humans in a real world. Fatigue is everywhere; cars get fatigued and need servicing, my body gets fatigued and needs a rest, and the stressors even on metal create weakness. Managing fatigue in humans is about managing volatility, fallibility and the nature of the human body, mind and spirit.
What is interesting in the ‘fact’ sheet is that it commences with a discussion of ALARP (As Low As Is Reasonably Practicable). ALARP is the go to guide for how to manage risk (https://safetyrisk.net/alarp-what-is-reasonably-practicable/). ALARP acknowledges that risk cannot be eliminated, it can only be ‘managed’ through Risk Intelligence. ALARP anchors the Act and Regulation to the reality of subjectivity. ALARP disowns the nonsense of objectivity, the nonsense of elimination of risk, and the nonsense of Zero. ALARP recognizes the fallibility of humans and that humans are not a problem to be fixed (Dekker). If you want to know what ALARP is really about then maybe have a look at the newly released video from the series Risky Conversations – The Law Social Psychology and Risk. Long, Smith and Ashhurst dispel the absolute nonsense in the safety sector about what ALARP means (https://safetyrisk.net/new-free-video-release-alarp/). Isn’t it refreshing to hear a lawyer put the utter nonsense of this ‘fact’ sheet in its place?
Here we have a ‘fact’ sheet that acknowledges ALARP and then immediately follows up that presentation with the nonsense of ‘elimination’. In the same paragraph the Regulator then talks about minimization as if it is the same concept as elimination. How do people possibly read this stuff and think that it makes sense? This is not a ‘fact’ sheet but a propaganda tool for the crusade of fear, risk aversion and ‘dumb down’ safety. Misinformation such as this ‘fact’ sheet shows just how the regulator contributes to the mis-education of the safety industry. Maybe the Regulator doesn’t understand the regulation?
When your thesis is fear and risk aversion, then your message must be ‘subjective humans are the enemy’. I saw this this week in a safety campaign for a tier one organization that described the challenge of safety as a ‘battle against humans’. The concept of ‘humans as the enemy’ through the philosophy of Zero Harm is also illustrated through the bullying and dehumanizing action carried out by this large organization in the utilities industry that advocates “Triple Zero”; or Zero Incident, Zero Harm and Zero Compromise.
http://www.personneltoday.com/hr/unfair-dismissal-health-safety-grounds-of-long-serving-employee/. When fallibility and uncertainty cannot be tolerated, humans are the ultimate adversaries.
So, here we have a non-fact sheet from the Regulator providing confusion and contradiction; where is the guidance and leadership? What can people and organisations do about ALARP? There are a number of things that can be done to provide leadership and support on this issue (fatigue and ALARP).
- The first thing that is needed is greater consistency with the Act and Regulation, not some made up agenda based upon an ideology of control and binary opposition.
- There is the need to ‘unlearn’ some of the nonsense that floats about the industry as projected truth, regardless of the source. Unquestioning compliance is dangerous.
- There is also a need for critical thinking to deconstruct the pervasiveness of nonsense in the sector. (The video series by Smith, Long and Ashhurst are a good start in this). The work of Richard Paul may also be helpful here: http://www.criticalthinking.org/files/Concepts_Tools.pdf, http://www.criticalthinking.org/files/SAM_Analytic_Think2007b.pdf. Safety people should be the experts at discerning alt-facts from facts, sadly this is not the case. Snake oil finds a ready market in the safety industry.
What really levels the reality from the nonsense is grassroots engagement at the coal face (something I do in my on-site culture audits). The process of ‘praxis’ (https://en.wikipedia.org/wiki/Praxis_(process) is key to uncovering hidden agendas and challenging safety nonsense and has been an integral tool introduced and used in organisations which I have worked with.
One of the best tools for deconstructing nonsense from the truth is the test of experience (in my case 13 years as a safety manager within tier 1 organisations).
Another important challenge is understanding the ‘spin’ of safety and the reality of safety. If fatigue is the issue, then understanding social politics, human judgment and decision making is the key; humans are not the enemy.
One of this things I have picked up over the years is a radar for regulator ‘double speak’. This has come though experience but also through my studies in critical thinking.
We also need to move beyond the tokenism of wellness’ and well being discourse to being ‘fair dinkum’ about people in our business. I worked once for a tier 1 mob that bragged about a ‘culture of care’ yet it was a culture of systemized dehumanizing. Wearing a ‘fit bit’ and placing a bowl of fruit in the lunchroom doesn’t constitute ‘care’ (https://safetyrisk.net/care-ology-in-the-work-place/)
The foundation for managing fatigue is not more rules but better community. Understanding people, the nature of decisions and the realities of the wear and tear of work, is the beginning of fatigue management.
Unfortunately, the power of the regulator packs quite an intimidatory punch. It takes a lot of guts to challenge the auditor, measurement heroes or a safety crusader. This is where a ‘learning’ community is helpful, for example with people on the Social Psychology of Risk leadership group. https://www.facebook.com/groups/152071534818549/ (not for those afraid to play in the mud)
So, there you go. Not all ‘fact’ sheets are fact and don’t buy safety nonsense projected as fact. Go to the source or consult a thinker like Greg Smith who understands risk, and keep away from ‘Professionals’ peddling fear and contradiction.