There are Safety Rules and there are Golden Safety Rules.
Following the news about two BHP workers sacked for breaching “Life Saving Rules” then being reinstated when the courts determined that their sacking was unfair (see the story here). I thought it may be timely to republish this article I wrote a few years ago and would love to hear your thoughts.
It is no secret that Health and Safety and its associated systems and procedures has become way over complicated. The result is frustration and confusion for those who must comply and those who must enforce, particularly for the poor old Contractors who encounter different rules, or variations of them at every site they go to. Imagine the mental gymnastics by a Manager or Supervisor who sees his best worker breach one of these Golden Rules and all eyes are upon him waiting to see what he will do.
Many companies (co-incidentally those who have created these convoluted behemoths of safety systems) have tried reduce the confusion and the new risk this has created by introducing “Golden Safety Rules”. Some have fancy names like: “Fatal Risk Protocols”, “Life Saving Rules”, “Cardinal Rules” and “Safety Non-negotiables” – why we cant all be consistent I do not know???
To quote Dr Rob Long:
Rules are parts of systems and systems serve humans not humans serve systems. Unfortunately, safety engineers seem to think that humans serve systems.
People don’t die because they break Cardinal rules, you can die just as easily by keeping all the rules. This is the nature of turbulence when rules don’t fit context, change and adaptability. Decision making and human judgement is not simple nor black and white and because risk is all about uncertainty there is no formula for every context as change and randomness alter the landscape of choice and decision. So what is a rule one minute can just as easy be a burden in the next. This is the nature of human decision making and the social shaping of culture and environment. A culture built on absolutes has to be ruled absolutely, what a fearful and terrifying culture.
The premise is to develop a set of critical rules for the site or organisation that reflect the inherent high risks. Whilst recognised that all safety rules are mandatory there are always some that have the potential to seriously injure or kill and should come with increased consequences if they are deliberately breached. It is not an easy concept, considering we are all human and the last thing a company should be doing is taking away the ability or rights of people to think for themselves, identify and understand risk and use initiative. The process must be done properly and in consultation, as for all effective safety initiatives.
Some Golden Rules for Making Golden Safety Rules:
- Keep the number of rules to as few as possible.
- Allow for some flexibility and the reality of human fallibility.
- Make them personal ie “I will not” rather than “Do not”
- Consult, Communicate, communicate, communicate, educate and ensure ALL understand
- They must be very relevant to the actual workplace
- They should cover high risks and situations or behaviours that can cause serious harm
- Responsibilities must be clearly defined
- The rules must apply to everybody
- Define not only what they are but also how to comply
- The rules must be within an individuals control
- Make them clear and concise
- Make the penalty fit the crime.
- Be fair and consistent in the application and enforcement.
- Establish an out for when there is no way forward identified without breaching the Golden Rules ie stop work and consult with Manager
- Clearly communicate the punishment for breaches and who will determine – using words like “may result in disciplinary action or termination” will dilute the importance
A few examples of GOLDEN SAFETY RULES (these are not models but actual examples – would you use these or modify them?):
- Do not operate any mobile plant unless It has been assessed and Authorised in writing by the Site Manager or the Site Managers representative.
- Prior to working on any equipment, it must be isolated and de-energised.
- All work at height above 2.0 meters must use fall protection/fall restraint equipment.
- Do not stand under a suspended load.
- I will not enter a Confined Space or Restricted Area unless Authorised.
- Look after each other, health and safety is a team game
- Think before you start work, do a TAKE 5 – know the risks
- Report ALL accidents and near misses
- Wear all PPE as required by signage
- Only undertake work for which you are trained and competent
- Do not work under the influence of drugs or alcohol
- Use the correct equipment for the task
- No cutting of corners
- Must have a Permit to Work when required;
- Use energy isolations when required, do not tamper with or remove unless you installed or are authorised
- No removal or disabling of safety equipment, devices or signage
- No walking or working below suspended loads
- No smoking outside designated areas
- No use of mobile phone when operating vehicles or walking at any time in production areas
- Do not bring a weapon on site (other than a necessary tool of trade for work)