Excellence in Hazard Management
Many people get excited about this - apparently, agonizing over the exact definition of words is a particular pastime for specialists. The reason for this is to separate out clear decision points and clarify cause and effect issues. The end result is really only useful to the purists. What they forget is that the line managers, supervisors and employees need "everyday" working knowledge, so they (the people who actually do things instead of talk about them), can take action.
So, with all due respect to the purists, if there's a vertical drop, you have a hazard. Let's not worry if a person is actually standing on the edge of it or not, because while we're arguing about it, someone may just walk up and fall off.
In Plain English, a hazard is something that can cause harm, even if it's not immediately obvious or takes a while to have an effect on you.
When we (SafetyPro) do training courses, we always ask participants to subjectively prioritise 5 hazards they have chosen from their work. We ask the groups to reach consensus about this. In the ensuing discussion, we always hear (sometimes heated) debate, usually along the lines of: "This one's worse. If it happens, the person could be seriously injured", followed by the riposte: "Yeah, but it'll never happen".
This, of course is the very point. The concept of risk usually includes two irreconcilable factors: Severity of injury and probability of it happening. It's why most of us don't hesitate to get on a plane but put on shoes before crossing a gravel road. The first example is high severity, low probability and the second vice versa. Risk assessment tools simply quantify severity, probability (and sometimes frequency of exposure), and then use an arbitrary method to balance these out and calculate a risk level.
Risk assessment models were really invented to take subjectivity out of this balancing act when we're doing it on behalf of other people (employees), but at the end of the day, we still have to justify our actions to the Beak if there's an accident.
Our opinion? Managers need to understand risk in order to make good decisions but they should leave the risk matrix at home. It's only good for settling arguments or prioritising actions.
What does the HSE Act say about risk? Well, we must decide if the hazard is Significant (can cause Serious Harm) and if so, eliminate, isolate or minimise it in order of preference.
Some people think this is too broad a brush but not so. The risk decision is still there, bundled up in the degree of action you are required to take to control the hazard. You are required to take "All Practicable Steps". The definition of this includes consideration of the likelihood and severity of harm.
So, there you go. People forget that until they get to court, when the judge will remember it for them and tell them there were practicable further steps they could have taken to prevent the harm.
In our experience over approximately 500 audits, the following are the most common actions and beliefs that detract from a good Hazard Management System:
- "Hazards are things that have gone wrong". Here, the dominant belief is that a hazard is already a failure of some sort, such as spillages, broken equipment and housekeeping issues. Of course these things are hazardous and should be fixed, but they should never be listed on anything but a temporary hazard register. They are sometimes indicators of system failures but essentially, they are aberrations that need fixing straight away.
- "The Hazard Register is to be hung on the notice board". Well, yes, OK, but it's not what a Hazard Register is primarily all about. It is not, in our opinion, a good warning or training device. That's what SOPs and induction training is for.
- Generic Hazard Registers. Many consultancies and providers of safety systems pride themselves on their ability to provide generic hazard controls for a wide range of hazards. Large employers with many similar sites and activities also promulgate cloned information. A Hazard Register of this type is often meaningless. You can hang it on the wall for as long as you like.
- "Hazards are bad things". The belief is often that hazards are things that the Department of Labour will judge you on, so best not to admit to them. Not so. Driving your car is potentially hazardous but it's a good way of getting around, so we have all agreed (some more than others) to abide by a range of rules that reduce the risk to an acceptable level. In the same way, work hazards are part of essential processes that are justified by the need for the goods or services. We are judged not on the hazards but the methods we use to reduce the risk. (Footnote: Imagine, however, if cars were only just invented. Do you think the idea of a white paint line to separate two streams of opposing traffic traveling at 100 kph would have been considered "all practicable steps?")
- "We need a Hazard Register to pass an audit". Yes, you do (or something similar). And you also need to be able to show the auditor that everything you say you are doing in the Hazard Register is being done (within reason).
- Spend time on the Hazard Register: It is an analytical tool and a generator of the critical activities in your safety system. For example, it should not only generate immediate hazard management actions, but also elements such as training, monitoring, and maintenance. Even emergency procedures, contingency measures, inspection requirements and supervision needs. This is why we were determined to ensure our SafetyBase e-system had a hazard analysis tool at the very centre.
- Be specific: No good listing "Noise" and the control measure "Hearing Protection". Let's say "Noise levels typically >110 dBA in Press Shop" and control measures "Grade 4 hearing protection within marked area to be worn". (We should also have a noise reduction plan in place if possible).
- Take ownership: The reasons for generic hazard information being used are quite compelling but the problem is that unless local managers take an interest and both customise the procedures AND wholeheartedly adopt them, nothing whatsoever has been achieved. There may be a Press Shop (see above) at many sites but you can bet the noise characteristics are very different and may well require particular site specific procedures that are effective, respected and therefore meaningfully supported.
- Make it real: We often find during audits that employers include such indefinite statements as "awareness" or "care to be taken" or "use appropriate methods" as part of the hazard controls. What does this really mean? If it's worth saying, make it something tangible, such as a specific training module, a standard or SOP that can be verified (and might even influence behaviour for the better).
- Understand the role of risk assessment: Use it as a guide to the meaning of "all practicable steps", when determining the extent to which you should justify hazard control measures. It's a guide to action, not a neat little number or letter to add jewellery to the Hazard Register.