"In the fullness of time I believe we'll get some direction as to where we will go as operators and individuals, but right now, our thoughts are in other places." - Tim Barrow, Volcanic Air Safari director and chief pilot

https://www.stuff.co.nz/national/118111491/multiple-casualties-multiple-victims-man-who-flew-last-survivor-off-whakaariwhite-island-speaks?rm=a

"If you don't take a risk you don't get anywhere." - pilot Mark Law on making recovery flights

Recovery plan under way as volcanic ash threatens to entomb bodies on Whakaari/White Island
https://www.stuff.co.nz/national/118138376/recovery-plan-underway-as-volcanic-ash-threatens-to-entomb-bodies-on-whakaariwhite-island?rm=m

Yes - your comment really highlights the most important point: users need to conduct their own risk assessment and determine what is appropriate.

I can well imagine with all the heavy-handed threats of prosecution if an injury incident occurs, it's common for people preparing SDSs and those managing the SDSs at the user end to default to 'err on the side of caution' and just assume the highest level of controls for constituent materials.

One of the things that is most ironic about HSWA's approach to holding people and businesses more personally accountable for safety is that their use of fear tactics often takes them further off track and discourages them from doing their own thinking, which is ultimately counter-productive to genuine and effective workplace safety management.

Some more relevant stories about this event (keeping in mind that everyone is now likely to either be in the camp of '20/20 hindsight' or throwing up their hands in exasperation over a force of nature they could not be expected to control).......

https://www.nzherald.co.nz/index.cfm?objectid=12292857&ref=twitter

https://www.nzherald.co.nz/index.cfm?objectid=12293369&ref=twitter

https://www.stuff.co.nz/business/118098320/whakaari-white-island-three-helicopter-companies-all-unregistered-for-adventure-activities

Exactly. And I would suggest that SDSs produced in such a way would actually not meet the legal requirements and could potentially be a breach of the regulations because they don't accurately represent the hazards of the actual substance.

I recall when I used to deliver training about the HSNO that there was among the penalties a provision for fines that could apply if a substance was labelled or otherwise identified as hazardous when it was not, and the example we used to discuss is when a substance was transported with labeling and signage that indicated it was more hazardous that it actually was. Is that your understanding as well?

The difficulty with SDSs is that there is currently very little meaningful policing of the quality of information. When I worked with chemicals in the past, many were sourced from China, and those often were accompanied by the barest skeleton of information, rarely anything close to the ISO standard format, and often little more than the technical data sheet, which is more like a product specification, without safety information for handling, storage, use and disposal.

It would be interesting to find out how much review and vetting is done by organisations that provide hazardous substances information for emergencies - e.g., Chemwatch. Even so, these service providers are often not used by smaller companies who may be in a position of 'you don't know what you don't know'.

Or Elf decides to manage a hazard by substitution, so they engage a contractor to do the work instead of their own employee.

- yes! And nearly as bad are those SDSs that warn of all sorts of possible risks that don't relate to the product at all - especially when they are based on the hazardous properties of the pure ingredient that might be present in only very diluted form or as a possible trace contaminant!

That probably happens either when people don't really understand the hazards information, or forget the intent of that section of information, and / or just can't be bothered to think it through and figure out what is needed.

FYI - Rebuttal from Amazon via EHS Today:
https://www.ehstoday.com/safety/amazon-responds-criticism-high-injury-rates?NL=OH-05&Issue=OH-05_20191205_OH-05_634&sfvc4enews=42&cl=article_1&utm_rid=CPG03000008027398&utm_campaign=38854&utm_medium=email&elq2=c78ffd2fa17848d0aabef10168e40dc0&oly_enc_id=4569F5190945A3Y

This is another topic in which it is vitally important to connect all the dots and don't just criticize a worker for appearing to be overweight, with the assumption they must be very unfit (I have met some people who look overweight but are incredibly athletic!!).

1. Consumer demand is a key driver of many products and services, many of which we complain are unethical - for example, many people speak out about the dangers of genetic modification, yet growers are like any other business and want to achieve more profitable crops, while the general population typically aims to keep its expenditures as low as possible. It's kind of like a 'game' where everyone is seeking the opportunity to have some kind of break-out advantage. The needs of these two groups are essentially diametrically opposed, resulting in some experimentation with methods that will allow both to get what they want, and without taking the full set of consequences into account because we don't yet have enough information to really quantify the health risks and other potential consequences.

2. The cost of compliance is an interesting matter. I have often heard the comment that NZ is among the most highly regulated countries in the world. I will resist the urge (for now at least!) to delve into some of the values and perspectives underlying the urge to make rules for so many parts of life, and just have a look at the issue of cost.

Rigid compliance requirements are often imposed as a knee-jerk reaction, typically with a relatively superficial aim (a bit like assigning a root cause without having done appropriate root cause analysis), often accompanied by a raft of ambiguities and omissions that further muddy the waters. Without sound foundations, compliance is often implemented based on inefficient and bureaucratic assumptions that ultimately add costs that no one really knows how to justify, other than "because WorkSafe said so". So the 'good' guys do their best to comply, and the 'bad' guys either look for every loophole or wait for someone to come along and catch them, happily counting the dough they have saved by holding out.

HSNO itself is a very interesting example of how a regulatory framework comes into existence - it took the ICI fire to get the public to sit up and take notice, and then politicians needed to be seen to be taking prompt action. The history of HSNO included a crazy patchwork quilt of regulatory frameworks, with separate regulatory agencies that didn't work with each other and each had its own inspectors - I used to work with a chemical company as HSEQ & Regulatory Manager, coordinated Dangerous Goods Licenses, Poisons Licenses, Building Warrant of Fitness, Air Discharge Consent, etc. When HSNO became law, substances registered with the Ministry of Health were turned over to ERMA, who had been expecting only a few thousand substances to be registered, but there were so many flaws in the systems that there were HUNDREDS of thousands of substances to wade through, requiring resources they had not anticipated! The board of ERMA included a number of people with very little practical knowledge of chemicals or chemical production, so they imposed their own 'zero-risk' approaches and created very rigid and impractical frameworks, with most of their advisors brand-new university graduates with no real-world experience - when they didn't know much and were not sure of the facts, they rigidly applied limits and there was no room for discussion unless a company wanted to take on an expensive and time-consuming appeal. I experienced it all first hand!! They became too focused on perceived differences between the substances themselves and lost track of the overarching intention to regulate the hazardous PROPERTIES of those substances - classic case of not seeing the forest for the trees!

I am please to note that much later in the piece, with those worry-worts gone from the board, regulators finally realized the sense in implementing what we tried to suggest right at the beginning and implemented generic approvals for groups of substances, which is much more sensible on all fronts and also supports innovation and improvement, which goes some way as an incentive to make those substances safer.

3. It seems very hypocritical for NZ government to impose more and more regulatory requirements on New Zealand businesses, while at the same time holding the back door open and encouraging businesses to move their manufacturing to China. We all KNOW that China does not operate by the same standards for workplace safety, environmental protection and sustainability. Eve those companies that audit and produce reports that verify 'compliance', it is very well known that most Chinese businesses will agree to whatever is asked of them, sign any required documents, and then just go on and do what they like. There may be some of those businesses that do comply, however I can imagine that most, exactly like their NZ counterparts, are more concerned about the bottom line and not missing opportunities, so they just cut corners where they can as they try to survive and hope to thrive.

NZ businesses that set up those business operations in China still have obligations to ensure worker safety and environmental protection. Just because we can't see it with our own eyes here in NZ doesn't mean it isn't happening, and it doesn't mean it doesn't affect us.

Not only do we all share one planet Earth; we now operate in a global economy. Asian countries have stopped accepting waste from western countries, and we can probably expect them to push back on unsafe work activities, too. So we really should be starting to think about new paradigms.

I agree with Michelle about re-thinking the role each of us plays in all of this. My partner and I have been actively simplifying and streamlining how we live, growing as much of our own food as we can, making more environmentally-friendly and sustainable choices about what we buy and consume, including the ethics of producers, the materials used, the waste produced, packaging, safety, durability, etc. and scaling down as much as we can. I can't solve the whole system, but I can make better informed and more conscientious decisions within my own sphere of influence, and if each person did just that, we could really make a difference.

Unfortunately yet another example of NZ regulators setting up a razzle-dazzle compliance framework that is not supported with appropriate means of following up to ensure compliance.....any compliance framework is only as robust as its enforcement.

I recall some years ago listening to a speaker from NZTA at an NZISM meeting, who observed that much of NZ's legislation seems to assume that simply putting a law or regulation in place was automatically going to result in the desired behaviours - rarely have meaningful considerations been given to enforcement actions and resources. It's exactly the same as posting a hazard sign or notice in a workplace and thinking you have the hazard under control!

Anything purporting to represent Values will ultimately fail if imposed from the top down - workers will always look for examples where your own behaviours and actions don't match your rhetoric, which will result in losing credibility and trust.

"Agreements" generally work better than "Rules" because workers generally place very high priority on having a say in matters affecting their work (and there is a famous leadership study that verified this - I just don't know the specific details).

Smart organisations facilitate dialogue and discussion (this is what the regulations on employee engagement and participation aim to achieve, too), listen and respond to employees in meaningful ways. No one wants to come to work and be treated as if you were a clueless child being ordered around by an authoritarian parent!

You're amazing Tania! Congratulations on completing your Graduate Diploma of Professional Practice (OH&S), and thank you for your commitment to improving safety practices in NZ.

I agree - more often than not, many managers focus on passing the audit to get the auditor's badge of approval, rather than genuinely achieving appropriate safety management practices. I've seen the same happen with other audits, too - e.g., ISO9001.

It doesn't help when managers - including the OHS / compliance managers themselves - set up their management systems rigidly following the standard, often mirroring the standard clause by clause.

A standard sets out the essential requirements; it is a checklist, NOT a template! But it takes some time and effort to grasp the underlying intentions of each requirement and apply them to the organisation. It's very common to see a safety / compliance management system in ways that seem primarily aimed at making the audit easier for the auditor, while completely overlooking the accompanying lack of coherence in this approach with the organisation's core business processes and needs.

When I advise client companies on their management systems, I like to tell them, "The auditor doesn't live here - YOU do!" I aim to interpret requirements for the organisation, to be 'the bridge' and facilitate solutions that make sense for the business, rather than being the tail trying to wag the dog.

If the systems don't make sense for the overall business, and even more importantly if they don't make sense to the workers required to carry out workplace safety processes, management systems are unlikely to gain any depth of traction, and they are much more likely to fall over due to enduring resistance and neglect.

It doesn't help when senior managers impose performance KPIs on safety practitioners that include passing an audit without providing appropriate support from the top and sufficient resources to achieve it. It all becomes quite a rort then, doesn't it?

Any organisation that rigidly mirrors a standard should definitely be questioned on its leadership and authenticity of commitment. Such an approach signals loudly that they are setting out to do the least possible and mainly want 'the badge' to provide the right kind of appearances to their customers, rather than genuinely doing those things.

Ports of Auckland used to have different colours of hi-viz vests for different functions across the business, as well as clearly labelled VISITOR hi-viz vests. That meant the only remaining h--viz colour left for fire wardens was fluro pink, which the mainly male workforce clearly did not want to wear every day. The mostly male fire wardens also complained loudly at being required to wear a fluro pink hi-viz vest, even just for the short and infrequent experiences of fire evacuation (thankfully only drills and smoke detectors set off by burnt toast and food remnants in kitchen ovens!).

A further useful identifier was used in addition to hi-viz vests. Workers were required to wear hard hats in that environment, so visitors and newbies (first 6 months, I think) wore white hard hats to inform others in the area that they may not be as familiar with the hazards and risks so their workmates could keep an eye out for their safety. In addition, with manufacturer recommendations to change hard hats every two years to prevent deterioration of their protective function, an orderly system was used to rotate a series of colours, with two colours being considered 'current' at any given time.

This colour system made it easy to identify hard hats that might be too old (i.e., UV exposure, wear, etc, as per manufacturer recommendations) to reliably provide adequate worker protection so they could be changed out for new ones.

Major near-misses may be easier to grasp and may be more likely to be reported. Smaller scale may not be reported either because people don't really think they are important enough to report, or they may not recognise the experience as really having been a 'near miss', or because they are minor, they may be more likely to just move on with the next activity. Another possibility I have seen at times is that they may just be reported as a hazard, without reference to a near miss.

- What about those with MORE experience, including adjunct essential skills and competence in disciplines such as leadership, business, management, communication, neuroscience, learning and development, risk management, business and compliance management systems. communication, team-building, coaching, etc - developed through real world experience rather than studying theory and theoretical models - who don't have the MEANS to undertake formal studies that are likely to be much more 'siloed' / tunnel-visioned by comparison?

What are safety training programs doing to ensure they are keeping pace with the real-world demands of businesses in today's context, where business leaders have a lot more on their plates than just traditional safety management and compliance requirements?

- Check out Sarita McLean of Bedrock Safety Solutions. She has been an accredited ACC auditor as well as a range of other accreditations - highly experienced as a consultant, auditor and training provider. https://bedrocksolutions.co.nz/System%20Audits/

- great clarifying questions - important information to provide context to these statistics.

And maybe migrants are more willing to accept lower rates of pay and more challenging workloads / conditions than Kiwis - that happens in a lot of roles, not just S-roles (I don't even want to use the S-word any more!).

- I love this! Thank you for the inspiration!