• Peter Bateman
    96
    In the Jan/Feb edition of Safeguard magazine, Daniel Müller says too many companies still reply only on PPE and administrative controls.

    How best to persuade managers to look further up the hierarchy of controls? (If you have an example from your personal experience, by all means include it.)

    You can respond in public here on the Forum, or privately here via a Survey Monkey form.

    An edited selection of responses will be published in the March/April edition, but with no names attached. One randomly selected person will receive a prize, namely a copy of the latest book by Andrew Hopkins, Organising for Safety - How structure creates culture.
  • EmmaB
    7
    From my experience there are 2 barriers to looking at better alternatives - awareness and perception of cost. I am pleased to say that the management I deal with regularly pushes the team to look at more permanent options to admin and PPE, engineering and isolation are common for structural issues. I have one example where the team are working together to substitute non-toxic alternatives to chemicals in use, supported by the management who are enthusiastic about the positive knock-on effects and I think that is the key - make the positive impact on personnel health, reduction in lost time and positive reputational effects, along with ease of use and offset of costs clear for 1 or 2 quick wins and they get onside with better improvements...
  • Simon Lawrence
    85
    I'm assuming we are talking about managers who actually do give a monkey's about safety? (Because even being hammered by the law won't change those who don't give a monkeys and never will).

    Assuming it's the former, it may seem simplistic, but my feeling is that managers don't understand the meaning of what is now called "Reasonably Practicable". It hasn't really changed from "All Practicable Steps". It's the only real guide we have that's set in stone. If I wanted to assess if there is a duty to go to the next level up the hierarchy, that's where I'd go. But in my experience, managers mostly do not "get" this.

    Primarily, it's a risk based decision, how likely, how severe. But it's also a bit more: What controls are available and how effective they would be looking. Finally, there is an available cap on it by allowing for the cost of controls being grossly disproportionate for the risk.

    I suggest managers really don't "see" this. They either err on the side of caution and wrap in cotton wool, or they don't recognise their obligation because they just don't understand the risk-based duty. And the opportunity it gives to apply common sense.
  • MattD2
    64
    The main issue I have seen is the "risk based" approach being applied incorrectly - most systems are focused around a risk matrix and risk reduction to an acceptable level, rather than an actual focus on reasonably practicable controls. Simply put the focus of the former is "what is the minimum we need to do" while the later is "what is the best we can do".

    The other issue is the complete misunderstanding of the "hierarchy of control" which could be down to the simplified version normally portrayed pictorially. And actually illustrated in this question itself - "How do we move up the hierarchy of control?" - this implies that the starting point is Admin controls and PPE, not what is actually required in the legislation to start at elimination and then move down if it is not reasonably practical:
    30 Management of risks
    (1) A duty imposed on a person by or under this Act requires the person—
    (a) to eliminate risks to health and safety, so far as is reasonably practicable; and
    (b) if it is not reasonably practicable to eliminate risks to health and safety, to minimise those risks so far as is reasonably practicable.
    — Health and Safety at Work Act
    6 Hierarchy of control measures
    (1) This regulation applies if it is not reasonably practicable for a PCBU to eliminate risks to health and safety in accordance with section 30(1)(a) of the Act.
    (2) A PCBU must, to minimise risks to health and safety, implement control measures in accordance with this regulation.
    (3) The PCBU must minimise risks to health and safety, so far as is reasonably practicable, by taking 1 or more of the following actions that is the most appropriate and effective taking into account the nature of the risk:
    (a) substituting (wholly or partly) the hazard giving rise to the risk with something that gives rise to a lesser risk:
    (b) isolating the hazard giving rise to the risk to prevent any person coming into contact with it:
    (c) implementing engineering controls.
    (4) If a risk then remains, the PCBU must minimise the remaining risk, so far as is reasonably practicable, by implementing administrative controls.
    (5) If a risk then remains, the PCBU must minimise the remaining risk by ensuring the provision and use of suitable personal protective equipment.
    — HSWA General Risk, etc. Regs
  • Simon Lawrence
    85
    While we are quoting the law, Part 2 of the Purpose of the Act is also worth throwing in. If, indeed managers do care to be inspired by legislation, this makes it clear that looking up the hierarchy or down, the highest practicable place is what's required:

    "(2) In furthering subsection (1)(a), regard must be had to the principle that workers and other persons should be given the highest level of protection against harm to their health, safety, and welfare from hazards and risks arising from work or from specified types of plant as is reasonably practicable."

    Some would argue "why stop there?" My answer is that interpretation of "Reasonably practicable", if applied properly, gets you to a perfectly good place. Exceed it if you will, but I'm just not a believer in the literal meaning of Zero Harm. If I'm flying in a plane, or even sitting in my house, I have a tiny chance of harm. We must continue to improve controls where effective new measures become available that are in proportion to the risk. But doing things that are frankly ridiculous and cause no significant reduction of risk is what you do if you are somewhat mad.

    I guess I'm agreeing with the premise of being as high up the hierarchy as practicable, but the other side of the coin is reaching a point of fully diminished returns for all concerned. So we need also to know when to say "If a little was very good, more isn't necessarily better".

    I've always believed that intelligent people respond better to a balanced set of rules where pragmatism is part of the answer. My suggestion is if we want managers to get to the optimum level in the hierarchy, instead of exhortations to be better just for the sake of it (they see right through that), we give them the whole story. And the whole story also says "Here's where you can stop, at least for now".

    Safety is too often treated as a crusade where we tell managers myths and porkies to manipulate them.
  • MattD2
    64
    Some would argue "why stop there?" My answer is that interpretation of "Reasonably practicable", if applied properly, gets you to a perfectly good place.Simon Lawrence
    I agree with this completely - and my comment regarding "what is the best we can done" was meant in this context; i.e. "what is the best we can do with the resources we have available (and also without sacrificing something else more in the process). But I do think the process should start "at the top" (for want of a better description) - is there anything we can reasonably do to eliminate this risk? No... ok, lets move down to any reasonably available substitutions...

    My suggestion is if we want managers to get to the optimum level in the hierarchy, instead of exhortations to be better just for the sake of it (they see right through that), we give them the whole story. And the whole story also says "Here's where you can stop, at least for now".Simon Lawrence

    "at least for now" brings in another good point - sometimes work needs to continue with what we have in hand while we wait for more complex solutions to the issues to progress. This is one reason why PPE and Admin controls are the typical solution - they are reasonably quick and simple to implement. Not very often do risk assessments look at the immediate, interim and long term solutions as a staged appraoch to manage risk - generally it is a single pass "what can/should we do (or have to do) right now to manage this risk"; we can't wait 3 months for the guards to be designed, fabricated and fitted - we need to protect our teams now... so make sure we have trained them and give them some good PPE as that is all we can do right now.
  • Simon Lawrence
    85
    Agree in principle we can move up the hierarchy when opportunities arise to improve, but "all we can do right now" sounds a bit sketchy!
  • Rachael
    34
    It also depends on who you are talking to. At the end of the day 'he who markets better wins', no matter what the law says.

    You have to tailor the story for the recipient you're talking to. So a manager focussed on the mighty $ has to see actuals in the form of cost of engineering/substitution'isolation controls vs ACC/Lost time and fines,

    Production teams tend to like the story where they can use engineering to limit waste and improve yield tonnage (that it also happens to enclosure a system and isolate it is a bonus - but hey, we take the wins however we can.)

    We've also started actively recognising when we have failed safely (thanks Mr Conklin) when we can hand on heart say that [insert minor incident] occurred because we were good, not lucky.

    As an industry we have to get better at marketing these as something other than 'it's legislative compliance so we HAVE to do it' then getting frustrated when it doesn't happen.
  • MattD2
    64
    Agree in principle we can move up the hierarchy when opportunities arise to improve, but "all we can do right now" sounds a bit sketchy!Simon Lawrence

    I agree that wasn't the best example (took it too far probably). To get a bit more confortable I guess it is usually more of a case of moveing from controlling the seveirty of an injury to preventing the injury from occuring in the first place (whether than it by preventing an incident outright or, more likely, preventing people coming into contact with an incident)
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