The Arse-Covering Myth
One of the most dominant myths in industry is that paperwork is an ‘arse-covering’ exercise. People seem to accept and tolerate paperwork for this reason when the reality is opposite, no amount of paperwork saves your arse in court. If there is no relation between your paperwork and what you really do and the culture of your organisation, the paperwork is useless. Most situations in which I have been involved where people have been either seriously injured or killed, the paperwork have always been signed. It eventually comes out in court that the paperwork was simply symbolic, irrelevant, ‘tick and flick’, not believed in and ineffective. Guaranteeing a safe workplace is not about ensuring the right volume of paperwork is in place. If paperwork is not an indication of meaningful practice it is useless. This is the delusion of the arse-covering myth. The first rule of systems is not its volume but whether it is meaningful.
See also: https://safetyrisk.net/lessons-from-pike-river/ where this was the finding of the Royal Commission into the tragic death of 29 miners.
I come across many people who don’t even understand the philosophy of a Safe Work Method Statement (SWMS). I think this is because SWMS have been made an object and, an ‘end’ in themselves rather than promoting the SWMS as a thinking tool. The regulators, safety textbooks and especially the Federal Safety Commission simply make things worse. Nothing is more damaging to safety than the Office of the Federal Safety Commission (OFSC) fixated and consumed by petty, ‘pissy’, insignificant issues in paperwork. I have a colleague whose organisation got a non-conformance from the OFSC for not having a safety data sheet for a toner cartridge! The OFSC was originally charged with the mandate to change culture in building and construction industry, and they have. The building and construction industry is more cynical, skeptical and negative about safety when the OFSC is around than it was 9 years ago, well done OFSC.
Far too often regulatory agencies have an emphasis on SWMS in technique, design, presentation and ‘getting it right’. When SWMS are often rejected safety power brokers then inject further mystique into the mix as if to protect the ‘secrets’ of their profession. This says more about territory and power than any sense of helping others better manage risk. When industry gets consumed by the ‘technique’ of SWMS, rather than the purpose of SWMS, we might as well be writing about the magic of boomerangs. Nothing is worse than a safety crusader stuck in the anal retention of SWMS technique. It is amazing how many organisations now pay someone else to write their systems as if thinking about risk is something someone else does. Thanks to this crazy mindset we now have the most absurd excesses in SWMS that have no relevance to the real process of thinking about and managing risks at work. Unless the regulators get their head out of the SWMS excess cycle, the arse-covering myth will simply get worse.
The last thing organisations need is to go to SWMS school and learn how wide a margin should be or be corrected on grammar and spelling. When people ask me for help on SWMS and show me what was rejected by the OFSC it often looks like a primary school teacher from the 1960s has attacked their work. Now a whole industry has been born making money out of selling generic SWMS. Generic SWMS are a disaster for safety and risk thinking and contradict the very philosophy of the SWMS. So, call up whoever, buy your SWMS pack, get it through the maze of safety nut jobs and get on with work. Have they really thought about risk, no! Has safety really been considered, no! Did they get a perfect SWMS, no! Will they ‘save their arse’ in court, no! Generic SWMS are about as useful to safety as buying sausages for a vegetarian picnic, and generic SWMS are sausages. Many organisations now have generic safety systems and paperwork that they don’t understand (http://stesafetyandlegal.com/2013/08/24/delphic-motherhood-statements-part-2-safety-documents-that-nobody-can-understand/) and this mismatch is what really gets one in trouble in court.
The challenge is to the regulators and OFSC to get a new approach, they have created this absurd arse-covering mythology and it should be up to them to change it. A start would be to for regulators to develop some understanding of culture and the psychology of risk. The recent Hazardman campaign in the ACT indicates that regulators still have a long way to go in understanding what the problem is let alone tackling the mistruths of the arse-covering myth.
Richard Doherty says
Never a truer piece written, but try explaining to directors that ask for SWMS, then ask you to put in more corrective actions. The real reply should be, put less corrective actions, but make sure they will work.