One of the best safety articles I’ve read on Linkedin in a long, long time. By Greg Smith and first published here: https://www.waylandlegal.com.au/blog/proving-safety
Proving Safety
Here is an interesting question. What would safety management look like in your organisation if you did not have to “prove” it?
- Would you still make your workers do Take 5s? And if your workers had to do a Take 5, would you collect and file them?
- Would you document a pre-start, safety review of a job in a JHA? Would you make your workers sign it? Would you collect, and file completed JHAs, and then keep them for years?
- Would you think a safe work method statement added any value to the management of hazards?
- Would you make workers sign a Permit to Work, and then collect, file and keep those?
- Would you keep your hazard reports on file, even though the hazard has been closed out?
- Would you make your workers document and sign pre-start and other workplace inspections? If you did, would you collect, file and keep them?
- Would you make managers document their “safety” conversations with workers?
- Would you make workers sign a document to say they have attended a pre-start meeting?
- Would you make workers sign a document to say they have read and understood all of your safety procedures?
- What would safety look like in your organisation if, instead of focusing on the collection and collation of pieces of paper we focused on training, competence and supervision?
What if we said to workers:
- We have given you the skills and knowledge to understand the hazards associated with your work and how to manage them, and we trust you to apply those skills and that competence diligently
What if we said to our supervisors:
- We do not expect you to do any administration.
- Your job is to be in the field with your teams helping them to identify, understand and manage hazards. Our expectation of you, as a supervisor, is if we come and talk to you about a job, you will be able to tell us what the job is, what the hazards are, how the job is being done, and how the hazards are being managed. And we expect all of the members of your team will have that same level of understanding.
What if we said to managers and leaders in our organisation:
- Your job, whenever you are in the field and having conversations with supervisors and workers, is to confirm they understand the hazards associated with their work and how they are meant to be controlled.
What if, instead of focusing on whether 100% of the paperwork has been completed, we focused on building confidence that everyone in our organisation understood the hazards and how they were meant to be controlled?
What if we accepted we cannot “prove” safety with completed documentation – we can only prove safety through the understanding demonstrated by our people? We can only prove safety when our people, through their conversations and actions, demonstrate an understanding of the hazards associated with their work and how those hazards are controlled? Because this is what happens in practice. After an accident, you need to be able to demonstrate your people understood the hazards in their business, how they were meant to be controlled and the hazards were consistently managed in accordance with the controls. It is not your documentation and processes which prove this – it is what your people did and what your people say.
If we accept that all this, what would safety management look like in your organisation?
Spot on Greg. These are the right questions that no one else is asking and that people are afraid to answer.
Greg has certainly challenged some worldviews with this one. Most responses on linkedin have been positive and supportive but others have been like this one:
“I’d have to say that I would still continue to do all the things listed. Not because it’s habitual or I want/need historical evidence or data but because I want everyone (employees, volunteers, visitors, contractors, sub-contractors, everyone) to be safe. Not so far as reasonably practicable but just bloody safe.”
Greg’s response:
“Regardless of the impact on your workers? And what evidence is there that the processes make workplace safer – could they undermine safety I practice I.e. the Safety Paradox?”
And the comeback:
Greg, don’t try to degrade my work or that of my organisation and the enormous and important work we all do.”
Most of this nonsense is driven by the PQ and insurance industries. Companies are falling over themselves to comply and people like the last correspondent think they are doing a good job. I despair.
This tyranny of bureaucracy including SWMSs, JSAs, JSEAs, THAs and Take 5s is an otiose attempt to prove due diligence and merely supplements the concrete blocks, which were used as kentledge or ballast during the Westgate bridge disaster:
https://www.parliament.vic.gov.au/papers/govpub/VPARL1971-72No2.pdf
Almost 50 years on and it appears little has changed:
https://www.theage.com.au/national/victoria/new-crane-was-on-its-first-job-company-at-centre-of-box-hill-tragedy-denies-safety-concerns-20180907-p502d1.html
The carousel of culpability has created a foreboding culture of compliance and enforcement underpinned by fear with increasing psychosocial risks. This is exacerbated by standard operating procedures for mundane activities such as tying safety boot laces, climbing stairwells or even documenting safe work method statements, which merely protect the writer.
Projects are festooned with mindless warning signs supplemented by indoctrinating inductions and certificates or verification of competency nostrums from an accredited witchfinder general with ominous warnings about hell and handcarts….Hasta cuando?
A great read, and nothing to argue with, but my approach is that of the young Mexican girl in the advertisement for Tacos; ‘Why Not Both”.
Ultimately we must ensure our people understand the hazards associated with the job they are doing, and that they are managing the risk. However, there has to be evidence of this, and as such, that lay in the training and competency, skills and knowledge of those people, but even that has to be tracked, demonstrated, measured and reported to the big man paying the bills? Can we simply allow ourselves to rely purely on the training provided? Id love to believe so! Isn’t it the One Per-centers we allow for? or do we accept one percent as the nature of doing business? Most of these targets, reports, inspections etc are driven heavily by client expectation and contracted into terms. And so, to not do them would put many Tier 1 businesses into the ground. Often we talk about the culture of a business, to truly bring about change in the over reporting structure of large construction businesses, it would require a culture change to Industry…
Adam, the idea that one can ‘track, measure and report’ comprehension is part of the measurement myth. No amount of numerics or metrics can ‘prove’ safety. Ultimately it will be a court that demonstrates safety and all of their ‘measures’ are qualitative.