Line managers are expected to be generalists. One moment, a sound financial decision, then an industrial relations problem, then a safety related decision.
Gulp. All those stories about personal liability and prosecution! In our experience, the typical manager, who is up to his or her neck in alligators, is only operating on a broad knowledge of the relevant safety legislation. They know that they have obligations, but even with training, the chances of having the ability to make an informed decision are not good, unless they have a corporate specialist to talk to. And for some reason, few people like talking to OSH, although they really should.
We find, more often than not, that managers who are willing to "do safety" are confused by the same sort of quandary that besets environmental decisions: "How far do we have to go to ensure no harm is done?"
There is the perception that safety has to be 100%; that it is about the elimination of all risk, that employees, visitors and contractors are to be wrapped in cotton wool and that if anything goes wrong, it will be "all our fault".
Often, the result is an uncoordinated knee jerking and bum covering, or even worse, a fatalistic throwing up of the hands and failure to act at all.
"All Practicable Steps."
This term, or something similar is typical of all safety legislation. It is a legal consideration and the final decision is with the judge, however, it is, in fact a risk based concept.
In simple language, this is what it says: In considering how much you must do to ensure safety, you must take into account:
- How serious the harm could be
- How likely it is to happen
- Whether you knew about this (or ought reasonably to have known)
- Whether effective means are available to reduce the risk
- Whether the means are available at a reasonable cost
The first two dot points in particular are classic risk assessment methodology. In fact, one of the most popular risk assessment tools (described in AS/NZS 4360) uses those two measurements and a matrix of ascending risk. This can be useful in complex industries and workplaces where it is desirable to prioritise hazards for action.
But does this help the average line manager make good safety decisions while they are on their feet? Do they get out the matrix card and consult it every time they give work instructions or every time it becomes apparent that a hazard may be subtly different?
Our experience is that they do not. They understand the concept that risk is a combination of factors but turning the risk into a number or a nicely colour coded level is not intuitive. It might look good in a system but the human brain cannot easily deal with two or more different factors being combined, however correct it may be.
ACC have certainly identified the flaw in using risk assessment inappropriately, and have briefed their auditors to watch out for misuse. (Some employers try to assist their managers by linking a risk score to the term Significant Hazard. Our legislation requires that we eliminate, isolate or minimize Significant Hazards).
The definition of Significant is in fact only related to severity of injury . If an injury is potentially severe or fatal, but also highly unlikely to occur, it may attract a low enough score to avoid the arbitrary "Significant" label. If, as a consequence, we ignore or neglect it, we have broken the law.
Solutions:
We have never met a manager who did not respond to the concept of injury severity. Some have personally been through the experience of seeing employees seriously hurt or worse. For them, there is no other measure of risk necessary. Even for those without bitter personal experience, the thought of serious injury raises a shudder.
In this context, the concept of "likelihood" (or the even less well understood "frequency of exposure") is immaterial. All that matters is that the activity carries the potential for serious injury.
We believe managers and supervisors are more likely to make good decisions about risk if they are trained in the following approach:
First, assess the most likely injury result if a failure occurs. Then, decide what level of certainty you would require for that injury not to happen. Then, do whatever is practical and possible to achieve that certainty.
This is simply turning the concept of risk into an active decision. We might tolerate a 5% chance of a cut finger, but would need virtually 100% certainty that employees working at height would not fall.
We read a lot of debates in forums and discussion groups about the intricacies of safety management. Often, the main advocates are safety specialists who are aiming for some ideal world. The fact is, however, that even the most intellectual of line supervisors and managers need simple, workable concepts. Senior managers and safety consultants alike should put a priority on humanising decision making so that those in the front line can make natural, intuitive decisions where possible.
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