Safety Policy Statements – compulsive reading?
Cast your mind back to the last time you entered the reception area of a business. You have 5 – 10 minutes to sit and wait, so your mind wanders, idly seeking something to occupy it. The “occasional table” is overflowing with old dog-eared sailing and golfing magazines. (The MD needed somewhere to retire them). The place is sterile, apart from the obligatory Safety Policy Statements and their cousins, so you must read them: Quality, Environmental, EEO, Harassment, Smoking and of course Health & Safety. Perfect! At least 5 – 10 minutes reading material, right?
Except you already know what they say. Why? Because they are all the same – everywhere – give or take a few words. Our own organisations have them too. They have dates going back to the beginning of the century and the name of the MD has changed for the most recent ones. They are boring and vaguely fatuous. In fact, we feel slightly nauseated by them, don’t we?
I used to half believe in businesses making a series of commitment statements all about things that show responsibility and integrity. Because it might at least encourage the business to “put its money where its mouth is”. But it doesn’t, does it? Why?
Because no one reads Safety Policy Statements and no one cares
- If anyone did read them, they were the people who wrote them. Or an auditor, during a game of smoke and mirrors.
- Employees simply don’t read that sort of stuff. First, they don’t think it has anything to do with them. And it doesn’t. It’s tokenism. Secondly, employees just intuitively classify it as management bullshit.
- Management don’t read them. They have far more legitimately important things to do. Like sales. And making a profit.
- The public don’t read them. To the public, it’s just corporates being pompous.
- The MD, who signed it, actually skimmed through it. That was to ensure he/she was not signing up to any unwanted personal liabilities. And now they cannot, off the top of their head, recall more than one thing it says. It was given to them to sign by the safety person and it seemed like a good idea at the time. Anyway, it was lunchtime.
- Shareholders don’t read them. Nor do they believe for one moment the MD’s claim in the Annual Report that safety is his/her number one priority. Because it just isn’t. I believe many senior managers do see the value in safety but it’s not number one. And nor should it be. It should be genuinely integrated into the whole system of management. If we can be adult about it, then we don’t need to pretend safety is “special”. Safety is a quality imperative. We are having people harmed because mistakes are being made. And if humans are being damaged by mistake, then so are our products and property. That’s a certainty.
And also because:
- Safety Policy Statements are written generically. So no one can ever tell if anything in them is being achieved or even maintained. In fact, the wording never fundamentally changes. It doesn’t need to. If it looks good on the wall, why mess with it? The Top 8 commitments (not in any order) are:
- Compliance with relevant legislation, codes and standards
- Management and Officers’ responsibilities
- Duty of care to maintain a safe workplace for employees and others
- Employee responsibilities
- Training and supervision
- Support for employee consultation
- Recording, reporting and corrective actions for accidents
- Support for rehabilitation of injured employees
- The statutory authority doesn’t care whether the business has a paper commitment to ensuring “no hazards harm any person” etc. So we don’t get prosecuted for making statements we forgot about and failed to execute on. Because the authority has a whole Act and Regulations to pin us down with, so why would they even worry about pulling our Safety Policy Statement out of its frame? They’ll leave it on the wall, just like we do. That’s right, it’s invisible.
Just as an aside:
In my research for this article, I came across a fairly standard safety policy statement by a well-known New Zealand based company. Somewhat better written than most, so I was marginally impressed. For a standard policy, at least they had written their own words. So a possibility of minor Brownie Points until I reached the end of the page. There it was! Two ugly paragraphs that undid any good that may have been done and brought it all crashing down in a pile of offal. Someone just hadn’t been able to control themselves. They had shown the whole organisation up in its true colours:
“Employees should make themselves familiar with (Business Name Limited) policies, standards, procedures, guidelines and business rules, (Oh, is that all then?) particularly those which govern and guide processes and functions in relation to their specific role. Ignorance of any (Business Name Limited) policy or process is not an acceptable excuse if a breach occurs.Breach of a (Business Name Limited) policy may result in disciplinary action being taken against employees, up to and including dismissal and the termination of a representative’s agreement/arrangement with (Business Name Limited).”
That’s a staggeringly awful postscript. Not the way to win friends and influence people. It isn’t just the dictatorial and threatening language coughed up gratuitously on the same page as statements of good intent and employee inclusion. No, it’s the expectation that it’s up to employees to “make themselves familiar” with policies and rules etc. That is stupifyingly misguided in my opinion. Good luck with that one in a court of law. If you need any clue as to the so-called safety culture of that organisation, look no further.
About 30 – 40 years ago, Safety Policy Statements perhaps had some value. At that time, it was thought rather brave to come out and make a bold statement about your values, let alone putting a signature on it. Hence the tradition of a reception area being the display location of choice. A public place, you see. Look on it as directly comparable to every truck on the road these days having some sort of “green” claim for its business. This is now known as “virtue signalling”. So let’s stop posing. Actions speak louder than words.
We’ve had Chernobyl, Union Carbide, Exxon Valdez, Piper Alpha, Deepwater Horizon, to name a few. Couple that with hardening public attitudes and less tolerance/higher suspicion of corporates. Safety Policy Statements start to look shallow, inflated and meaningless. In fact, I’d suggest that having a traditional wiffly waffly Safety Policy Statement these days is asking to be interrogated.
- Think carefully about why a Safety Policy Statement is needed for your organisation. Need it for an audit? OK, bah! Just do it. You know the wording. But make sure the date is OK. Tick the box.
- If you don’t need it for an audit, then why do you do it? What purpose does it fulfill for you? Is it to impress someone? Then who? Does it form the basis of your continuous improvement planning? Really? Then why does it have the same wording every year?
- What about a step further than the original intentions? Instead of broad statements of good intent, how about something real? Heart on the sleeve stuff. Someone’s got to be the first. So here we go!
- Compliance with relevant legislation, codes and standards: “We scored 81% in the March independent audit, which isn’t acceptable. We are taking advice from SafetyPro Limited (yay) and will not have done enough unless the next score is 90% or above. If it isn’t, we will sack SafetyPro Limited.”
- Management and Officers’ responsibilities: “The above audit found that only one of five Board members fully understood their duties under the Act. We ran a training session and the Chairperson has made it clear that all five must be assessed again at the next independent audit. Updates in the Safety Committee minutes. “
- Duty of care to maintain a safe workplace for employees and others: “The above independent audit suggests we have good processes with the exception of routine inspections of some critical equipment. Actions were prioritised and all Priority A items completed within a week. Work is ongoing and under monthly review. Updates in the Safety Committee minutes.
- “Recording, reporting and corrective actions for accidents: “The audit also found that an incident in December where a 20 kg box fell off a shelf was a Notifiable Incident and should have been reported to the authorities. It has been retrospectively reported and our Manual updated along with re-training.”
The human factors
- Employee responsibilities: “The above independent audit found that employees generally did not understand their duties under the Act. In particular, their duty for the safety of others. We have decided not to use training courses. Instead, we have made it a topic for Toolbox Meetings, using examples and Q&A. Updates in the Safety Committee minutes. “
- Training and supervision: “The audit also found that training in some Safe Work Procedures where correct operation of equipment is critical, need to be refreshed regularly. We have added bi-annual refresher training to these and have taken employee advice as to the use of more diagrams and photos. Updates in the Safety Committee minutes.”
- Support for employee consultation: “We found that 36% of employee requests that had been approved were taking over 12 months to implement. While 100% is not the aim, we have improved to 45% in the last 6 months and we are aiming for 60% at the end of this financial year, with 75% the following. Updates in the Safety Committee minutes.
- Support for rehabilitation of injured employees: “We questioned whether it was ethical or reasonable to only offer rehabilitation opportunities to employees with work injuries (not sport or home injuries). Consequently, we changed the policy, in consultation with the employees in the safety committee. We also asked them for a review in August. Updates in the Safety Committee minutes. “
- We welcome any information that may be relevant from employees, management, members of the public, clients, contractors or other affected people. You can address your information confidentially through our appointed independent advisor at (email, phone and postal).
Well, it’s worth a thought, isn’t it?
Contact me if I can help you with any safety stuff. Call 0800 000 267 for a welcoming chat, or email firstname.lastname@example.org
My 10 Health & Safety Myths. Planned topics and dates.
- # 1: Passion for Safety – Please no! 29 August 2019
- #2 Lost Time Injury Rates – Dark Arts in the Boardroom. 18 September 2019
- #3 Zero Harm – Stop Taking it Literally! 9 October 2019
- #4 We Have a Safety Culture – Yeah. Nah! 30 October 2019
- #5 Safety Audits – Smoke and Mirrors 20 November 2019
- #6 Safety Manuals – You’d Think it Would be Simple 31 January 2019
- #7 Safety Policy Statements – You Are Committed to What? 21 February 2020
- #8 Hazard/Risk Registers – What Are They Really For? 13 March 2020
- #9 Accident Investigation – Tick & Flick 3 April 2020
- #10 Contractor Management – The Thin Paper Wall 24 April 2020
Simon Lawrence is Director of SafetyPro Limited.
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