‘Paper Systems’ and Safety Management Systems
By Matt Thorne from WHS Concepts
I have been consulting in risk and safety in Adelaide for over 10 years and am often asked to help ‘revitalise’ an organisations Safety Management System. Most people contact me about ‘risk and safety issues’ but people rarely understand either what the problem is or where to start. So they start at systems and this seems to make sense.
An organisation that asked for help has 15 employees doing highly specialised work so they needed compliance to AS/NZS ISO 9001, 14001 and 18001, so they could operate with some Tier 1 building companies.
In my first meeting the questioning started with: ‘What is a safety management system’? ‘What does it look like’? and, ‘How big does it have to be’? There is nothing unusual here, this is generally where I start with small to medium businesses. Most often they simply want to comply but don’t know where to start. One thing that stands out is and is common, is that people remain are confused by all the fear mongering and snake oil being peddled in the risk and safety market. It seems remarkable that this level of heightened confusion continues and is even propagated by the safety sector itself. The level of myth making and anxiety making is astounding. Most think that all systems have to be paper-based systems and that systems are only systems if they are written down.
So, let’s dispel a few myths around paperwork.
· There need to be reams of paperwork to make an SMS valid. In fact, the more paperwork you have, the harder it is to understand your management system. Your management system needs to be understandable and useable, by the board, managing director and any employees who utilise it. There is no evidence to show that a 15 kg SMS is any more valid or effective than a 3 kg SMS. Most regulators are asking employers to just keep Safe Work Method Statements to just a few pages and only to document SWMS for high risk tasks. It’s finally dawned on people that creating a ‘tick and flick’ culture actually makes the workplace less safe.
· Paperwork will save my arse in court. Hit the panic button people. Paperwork will most likely be the thing that hangs you in court. As Greg Smith states: ‘sometimes your paperwork is your biggest legal liability’. Of course Greg tells us that the court knows the uselessness of systems that are not useable and calls these ‘paper systems’. If at any stage the paperwork is not filled out correctly, or doesn’t reflect what you actually do, you are simply compiling a data base that can be used to demonstrate a lack of Due Diligence.
· A comprehensive management system will help create the safety culture that we need. It has been shown time and time again that the bigger the system, the larger the failure. People make a culture, not a system. Systems are only one small part of culture, systems are not culture.
· Paperwork will show that we are consultative. One of the big problems here is that many organisations either buy a generic SMS or copy a SMS from another organisation. Switching brands on a poor SMS simply makes it a poor SMS with a new badge. Unfortunately for organisations that do this, it all unravels in court when people demonstrate that the SMS was not used except for a door stop or collected dust on a shelf
· Management Systems rely totally on paperwork. I am delighted to announce that this is not necessarily the case. There are businesses out there who run low level paper systems, because their culture and management strategy. They have a low staff turnover and so knowledge is easily retained, and they constantly discuss how work is performed, and everybody is consulted before anything is changed. They can all tell you, in their own style, how their system runs. In such organisations risks are managed through consultation and effective communication, reflection, dialogue and conversation. Most often if they do have to appear in court, their testimonies are consistent and sufficient to demonstrate systems effectiveness.
· Paperwork will keep me in a job. This is getting further away from the truth as Boards of Directors start getting savvy as to what a Safety Management System should look like. The futility of the endless take 5 being entered into systems, costing hours of labour, and not actually showing any discernment in risk, it is at best a ‘tick and flick’ exercise and as a result contributes to making the workers less intelligent about risk.
· Paperwork will protect my workers. A sad truth of most of the paperwork out there is that it often causes the opposite effect. Workers are surrounded by so much ‘safety cosmetics’ they become blind to real risk and develop hubris (overconfidence) and this gives them a false sense of security.
· My paperwork is understood by everyone that works for my company. Would you like to bet your job on it? The industries that carry the most risk such as farming, mining, transport and construction, are a workforce that is more inclined to the verbal than the written. The expectation that everyone will fully comprehend everything that is put in front of them is naïve at best. All people are individuals and have a variety of needs, I know a truckie that can quote Byron, a carpenter that can play violin, but they will run at the sight of book, they get their information from radio, television and multimedia. Most of these workers are visual and verbal learners yet the common strategy is to flood them with paper-based systems.
So, where does this leave us with Safety Management Systems.
· We need to be able to communicate on various levels, to a multitude of audiences. The focus needs to be on skill development not more forms and checklists.
· We need to focus more on skills in effective communication, listening, observation and consultation. You simply don’t get such skills in any WHS qualification I know.
· Systems need to be understood more as ‘what we do’ rather than ‘what we have written down’.
· A system needs to be understood as a flexible process that allows for mistakes, innovation and change.
So after a session with the organisation leadership they were relieved that I wasn’t about to thrust the Encyclopaedia Britannica on them or spend 30 days creating a system so large no one could use it. Instead I spent a day or two just watching what they did and worked out what their system was and what things required documentation. They were surprised by just how much they were doing well and how little needed to be documented.