Originally posted on June 16, 2020 @ 7:11 AM
The excesses of paperwork in the risk and safety industry is evidence of the mythology that paperwork demonstrates safety. Similarly the idea that numerics and metrics demonstrate safety is based on the same delusion. All data whether quantitative or qualitative is interpreted, there is no such thing as objective data.
The delusion that volume and weight of paperwork demonstrates safety is what drives new risks of ‘tick and flick’, paperwork fatigue and misguided notions of evidence. If people get to court they get a huge shock to see their paperwork being used against them (https://vimeo.com/162034157).
Those that drive this delusional mythology such as Regulators and the Federal Safety Commission are plainly out of step with what the courts and leading lawyers in WHS declare (https://www.amazon.com.au/Paper-Safe-triumph-bureaucracy-management-ebook/dp/B07HVRZY8C). Indeed, it is sometimes the Regulator who gets castigated by the court for a misguided sense of what comprises evidence. If testimony contradicts paperwork, the court is most likely to dismiss the validity of the paperwork, what it now calls ‘paper systems’.
Moreso, any sense of understanding human decision making or the social psychology of influence would show that the by-products of excessive paperwork drive: Toxicity in culture; deficit views of safety and load up safety as a workplace embuggerance. I run training groups across industry every week and the feedback is loud and clear, workers detest excessive paperwork and ‘tick and flick’ is alive and well in the workplace. Indeed, we have a company in the ACT that makes a fortune out of selling generic SWMS. You can even buy generic SWMS at Officeworks (https://www.officeworks.com.au/shop/officeworks/c/facilities-supplies/workplace-safety-equipment/registers-compliance-documents/safe-work-method-statements). Such is the delusion that paperwork is an end in itself. All this nonsense and delusion is driven by the Regulator and regulation mythology.
Paperwork in itself does not ‘prove’ compliance, it proves one is good at completing paperwork. Similarly, completing some method of incident investigation doesn’t mean one has conducted a thorough investigation, it means one has completed a commonly agreed investigation process. The Danny Cheney investigation is a classic example of commonly accepted biases in investigation techniques. Many popular methods have more holes in their assumptions and design than swiss cheese. In the SEEK program (https://cllr.com.au/product/seek-the-social-psyvhology-of-event-investigations-unit-2/) I demonstrate how many of these popular methods overlook dozens of elemental factors in investigation.
All paper work, including investigation methods are only as good as the ideology of the designer. If the design methodology is positivism, such as the regulator assumes then, critical analysis in human, culture and social psychological factors will be missing. Paperwork design is not neutral, it is the embodiment of the bias of the designer. This ideas that iCAM is some industry standard contributes to the mythology.
Isn’t is strangely predictable how any investigation or enquiry by a Regulator ends up in more regulation and inspection regimes? The Boland report is a classic example (https://www.safeworkaustralia.gov.au/system/files/documents/1902/review_of_the_model_whs_laws_final_report_0.pdf). This was also the case with the Getting Them Home Safely Inquiry (https://www.accesscanberra.act.gov.au/app/answers/detail/a_id/3048/~/getting-home-safely-report) in the ACT. Of all the recommendations in the Report it was the cultural issues that were ignored and the employment of more regulation through audit and inspection was implemented. When your problem is a nail then the only solution is a hammer.
Here are some positive suggestions in how to make paperwork effective to support other evidence that your actions for safety ‘works’.
- Get away from this idea in safety that paperwork design is neutral.
- Explore the biases of the paperwork design and use such paperwork critically. Then amend the paperwork to pick up on gaps.
- Think much more about confirming that safety works by observations, conversations, visual evidence and verbal evidence.
- Dump this idea that the existence of paperwork is a defense in itself, its not.
- Understand that the Regulator has an agenda and a political imperative and that this shapes their thinking and demands. Regulators are not neutral, neither is the Regulation.
- Think more about ALARP (https://vimeo.com/162637292). What is your defendable position should something go wrong?
- Be very careful of the language you use in inductions, posters, policies and training. Ensure you don’t refer to things like zero because this also will be used against you in court (https://vimeo.com/163648220).
- Think more about how you will give account of your actions to tackle risk than reporting it in paper. If something goes pear shaped your testimony will be required.
- Remember that any attention to petty detail is a waste of time (https://vimeo.com/163499152). Indeed, just focus on high risk and ensure that your paperwork accurately reflects what you do.
- Remember that quality is better than quantity. Your paperwork needs to be useable not a burden. If it’s a burden, you won’t do it well.