The safeguard debate team (Robert Powell [@Robert Powell], Moni Hogg, Grant Nicholson [@SafetylawyerNZ], and I [@Jon Harper-Slade]) recently had a meeting to reflect on the debate and think about how we can continue this conversation.
I personally would like to thank those who provided feedback on the session and to thank those that submitted questions.
The intention here is for debate panel to contribute to a continued discussion on this topic, so feel free to fire in any questions you have for us or any comments you have on the subject.
As I said in the debate, it is important where the work is complex or high risk. It is also important to bear the principles of reasonableness and appropriateness in mind, therefore you probably do not need a risk assessment for making a cup of tea. If it seems over the top to have paperwork associated with a low risk task, chances are that you do not need it, but if you are heading out in the bush to do some field work, you do need to plan where you are going and what you are doing, and leave contact details with someone.
Documentation is an important part of any safety management system, but shouldn't be an end in itself. As the panel discussion at the Safeguard conference demonstrated, it's all about context and thinking about how to make safety meaningful and useful. Demonstrating compliance is always a necessary evil, but hopefully we are past the days of having long (and turgid) documents posted on walls for everyone to ignore.
In my work with Rocket Lab over the last 18 months and Fletcher Innovation (house-in-a-day project), I’ve learnt that giving the teams as much ownership, trust and autonomy as possible has the best outcomes both for safety and business productivity. There will always be some need for documentation however it needs to be fit for purpose and supportive of the team’s efforts. To keep people engaged with safety, as a profession, we need to rethink how we meet the documentation requirements in more creative ways.
So what I am thinking about a lot are the four types of safety work carried out by safety professionals defined by Drew Rae and David Provan in their 2019 safety science paper 'Safety work versus the safety of work' and referred to in their more recent study (along with Sidney Dekker) 'An ethnography of the safety professional's dilemma: Safety work or the safety of work?':
-Demonstrated safety work - Satisfying stakeholder demands for safety
-Social safety work - Re-enforcing the organisation's commitment to safety
-Administrative safety work - Complying with safety requirements
-Physical safety work - Changing the work environment for safety
The latter study shows that safety professionals tend to focus on 'blunt end safety work' (demonstrated, social, and administrative safety work), for many reasons, which is where the majority of safety documentation is produced. The same study shows that 'sharp end safety work' (physical safety work) is where a safety professional's work should be prioritised, however it is worth noting that the most effective application of physical safety work aligns with managing safety risk using the 'hierarchy of controls' and shows that paperwork (administrative controls) are the least effective remedy to improving the 'safety of work'.
Bottom line is:
-'Blunt end safety work' is important to an organisation but shouldn't be disproportionate to the 'Sharp end safety work'.
-Safety professionals require a degree of separation and autonomy from the internal management pressures to prioritise 'blunt end safety work' and ensure they are sufficiently connected to the organisation's operational work and the safety of that work.
-Safety professionals need to better leverage current safety science knowledge in the application of their work to achieve this.
Thanks Jon for mentioning the concept of "safety work". As a H&S consultant what I produce is paperwork. But even this paperwork can be defined using types of safety work - both from the motivation of the client, and the focus that I use. It triggered a train of thought.
A lot of my work specalises in hazardous substances, an area that can be very compliance driven. I see plenty of evidence with organisations focused on the blunt end, making sure that all their SDS are less than 5 years old and having signs up for staff to wear PPE, but the workers don't know about the chronic harm properties of the substance they use, or what the PPE is protecting them from. In most environments there are few risk assessments or SOPs around substance use, and those I do see are often cut and paste. This has lead me down the path of using safety differently principals as a lens.
I often ask workers what most concerns them/what makes them uncomfortable. This can dramatically shortcuts the process of working out what real risks abound in a workplace. However, sometimes they simply do no have the knowledge to really understand the risks that they are taking. SDS go along way in providing hazard information, but they are not the most user friendly for workers, and do not cover the use context. I think that the "administrative control" of training/informing is really the "sharp end" here. Especial if we truly want to empower workers.
When an organisation is dealing with more than a handful of substances it can be difficult to maintain good risk assessment processes. The real risks become lost in the morass. Rather than compliance, the lens needs to be "risk": what is really nasty; what do we use in big quantities; or in ways that result in exposure; what could realistically go wrong/has in the past gone wrong. Then part of what needs to be documented is your triage process, keeping the risk management documentation as simple as possible so it is usable by everyone. Management/leadership can then focus on the triage process and the top risks for assurance - via listening and understanding rather than another mountain of paper.
So as a Safety Differently leaning person who works in a area that is often a critical risk for organisations: does safety documentation save lives? - absolutely YES, but only when there is not so much of it that the important stuff gets lost. You need to empower workers by giving them necessary/useful knowledge, and you need to use realistic risk scenarios to focus risk assessment, management and assurance processes.
The most useful framework I’ve come across so far to help with the ‘social construction’ of this debate about documentation is Cynefin, developed by Dave Snowden. It’s well worth looking him up on YouTube. He’s also a guest on the Boss Level podcast. The framework helps us locate work in various domains of knowledge and activity, and also allows us to consider how movements between these domains happen. The framework suggests that only knowledge and activity in the ‘obvious’ domain lends itself to proceduralization. The complicated domain calls for guidelines. Story-telling and metaphor might be useful forms of documentation for the complex domain, whereas the ‘chaos’ domain calls for fast, rehearsed action.
Go have a read, have a listen, have a think, and record your thoughts here. I’m interested to know if anyone else can find value in the Cynefin framework relevant to this debate.
Hi Susan, I agree that the information that goes to workers needs to be easily digestible. Thankfully we have access to a good chemical management database, and we can print out the one page "mini-SDS" for workers at point of use. These summarise what they are working with, what the hazards are, and what protective gear they need. We also took this concept and developed "Safe Work Instructions" for much of our machinery, and the buy-in has been good (they are treated as aide memoires)
You have some valid and interesting comments and as a H&S advisor we find ourselves being stuck behind the desk trying to complete the blunt end safety work when we really want to be out completing the sharp end safety work. It is certainly a balancing act to ensure we focus on the right things.
Susan Edwards I also agree with your comments that sometimes they simply do no have the knowledge to really understand the risks that they are taking. SDS and SOP's go a long way in providing information, but they have to be user friendly for all levels of workers.
As Dan mentioned the Cynefin framework is good to understand the complexity of knowledge/activity relationships. If you google Sketch of the Cynefin framework, by Edwin Stoop theres a great diagram. I also recommend showing it to anyone if they state H&S is "simple" or "black and white"
@Dan Davis's reference to Cynefin (pronounced 'Kunevin' thanks to the gorgeous Welsh language) is a great one. My own experience with H&S problem solving is the confusion between Complex and Complicated problem solving (e.g. my iPhone is complicated and requires an expert to fix it; the construction site next door to my office is complex and requires a diversity of knowledge and thinking to solve problems which arise).
If we accept that most of the world of work is more complex than complicated, then it is probably useful to have access to means of learning/problem solving in this space.
I have found learning about both Human and Organisational Performance (HOP) and Design Thinking useful to help me understand how we might co-design solutions with those who do the work to solve complex problems.