Some more thoughts on Safety Management

I went out on a limb the other day and blogged about zero harm not being achievable. Boy did it trigger significant controversy and opinion with some supporting what I said and others believing zero harm is achievable.  I’m glad these blogs generate such strong opinions and discussion because they shine a light on issues as I see them in the management of risk – not just safety, but all types of risk.

To that end, I’m ready for the next round and this time I feel it is time somebody challenged the current workplace health and safety management practices. Here I go!

Before I start, I need to emphasise one thing – I am a strong advocate for workplace health and safety. If we go to work in the morning, we should not only return home to our loved ones, but we should also be in one piece.

So this is not about questioning or reducing the importance of safety in the workplace, but instead, to examine whether the current methodologies being employed to achieve workplace safety are as effective as they could be.

As you know, I believe there is no such thing as a safety risk – they are just risks that have safety consequences.  But these are not the only consequences.  Even when a risk occurs where there are injuries and/or fatalities, there are financial, reputation and regulatory consequences that will impact the organisation’s objectives, in addition to the potential disruption to operations for the period of investigation.

In this blog, I will explore two other aspects of safety management that I believe are causing issues in the management of the risks.

The current definition of a safety risk is not only misleading, it is just plain wrong

This will not be the last time in this blog that I am critical of SafeWork Australia and, in particular, the Code of Practice: How to Manage Work Health and Safety Risks.  But for now, I will focus on the definition of risk in the Code of Practice.

The Code of Practice defines a risk as:

the possibility that harm (death, injury or illness) might occur when exposed to a hazard[1].

This definition is focussed purely on the likelihood of harm that may come from exposure to a hazard.  It does not even consider the likelihood of the event occurring – just the likelihood of harm if there is exposure to the hazard.  What this definition is implying is that the exposure has already occurred (i.e. the risk has materialised) and what we are assessing is the possibility that harm will occur.

Put this another way, the Code of Practice defines a risk as:

  • the possibility someone will get hypothermia if exposed to cold conditions; or
  • the possibility someone will be injured if struck by a moving vehicle; or
  • the possibility that someone will suffer serious injuries or death if falling from heights.

Of course, if we define a risk like this, we are going to get very skewed risk levels as the likelihood (possibility) of harm is always going to be high if we are assuming the exposure (risk) has already occurred.

If we compare the Code of Practice definition with the definition I have developed for a risk, we can see that the emphasis is more towards that which is most important: stopping the event that may lead to the harm (i.e. the exposure to cold conditions; the vehicle hitting a person; or the person falling from heights):

a possible event/incident/issue that, if it occurs, will result in consequences that may impact an organisation’s objectives

In this definition we are focussed on the event and its likelihood, rather than the likelihood of harm as detailed in the Code of Practice definition.  If you are focussed on the likelihood of harm as opposed to the likelihood of the event that could lead to the harm, the management of the risk is problematic, if not impossible.

As an aside, what I find fascinating is the fact that the Work Health and Safety Act 2011 mentions the word risk 79 times and yet does not define what a risk is.  It also mentions the word hazard 28 times and, once again, does not define the term.  Seems to me to be pretty important terms to define in the Legislation that is aimed at reducing workplace health and safety risk through the minimisation of hazards

A hazard is not a risk

A quick search of the internet and it becomes obvious that there is significant confusion in relation to the difference between a hazard and a risk.  One article highlights that the following are the top 10 safety ‘risks’ in the construction industry:

  1. Working at height
  2. Moving objects
  3. Slips, trips and falls
  4. Noise
  5. Hand-arm vibration syndrome
  6. Material and manual handling
  7. Collapse
  8. Asbestos
  9. Airborne fibres & materials – respiratory diseases
  10. Electricity[2]

Only two of these (slip, trip and fall and collapse [but of what?]) is a risk. The majority are hazards, and one of them (respiratory diseases) is a consequence.

I remember reviewing a risk register for an organisation that had listed a risk as: ladder.  They had assessed the likelihood as Almost Certain and the consequence as Severe, meaning they had an Extreme risk of ladder.  Of course, what they were trying to articulate was a risk: worker falls from a ladder which could be rolled up to be incorporated into the risk: worker falls from heights.

So, why are hazards not risks?  The primary reason is that a hazard is a source of risk, but it is not the event we are trying to prevent from happening.

If we take the hazards listed above, and describe them as risks, our potential for them to be managed more effectively is increased considerably.

Hazard Risk/s
Working at height

Worker falls from height

Item falls from height

Moving objects Worker/visitor/member of the public struck by moving plant or equipment during operations (note: this includes ‘missiles’ released at speed from the plant or equipment)
Slips, trips and falls Worker or visitor slips, trips or falls in the workplace
Noise Worker exposed to short or long-term noise above legislated/recommended levels during operations
Hand-arm vibration syndrome Worker exposed to short or long-term vibration during operations
Material and manual handling Worker lifts weight or undertakes manual activity that exceeds the limit of their biomechanical capacity
Collapse

Trench/tunnel/confined space collapses on worker during operations

On-site crane collapses during operations

On-site scaffolding collapses during operations

Asbestos Worker/member of the public exposed to unbonded asbestos whilst conducting operations
Airborne fibres & materials – respiratory diseases Worker exposed to toxic and/or hazardous substances whilst conducting operations
Electricity Worker contacts, or is contacted by, live electrical source during operations

We are now able to determine the likelihood of the event (e.g. worker falls from heights), given the current controls and their effectiveness, and the consequence should the event occur based on the context of the hazard (i.e. a worker falling from a height of 50 metres is more likely to result in more severe consequences than a worker falling from 3 metres).

It is my firm belief that the Code of Practice How to Manage Work Health and Safety Risks is contributing significantly to this confusion.  One need only look at the example “risk register” provided in the Code of Practice to see how those conducting ‘safety risk assessments’ could be misled into believing a hazard is the same as a risk.

In this register, a hazard is identified.  It then requires the person filling out the form to identify the harm that might come from the hazard and the likelihood of the harm to then determine the level of risk.  The problem is, no risk has been identified – just a hazard.

So, if we use one of the previous examples: electricity, we can see the problems starting to emerge.  Electricity is a thing: it is a hazard.  What this form is asking us to do is to develop a level of risk for electricity. It is simply not possible.  If on the other hand, we were to capture the risk: worker contacts, or is contacted by live electrical source, we can assess the effectiveness of the controls to determine how likely it is that the worker will contact, or be contacted by the live electrical source and, based on the knowledge of the task and the strength of the current, an assessment can be made in terms of the most plausible consequence.

To that end, unless SafeWork Australia changes the format of the template they have provided, this issue will persist, and organisations will continue to identify hazards and not risks.

Summary

As I said previously, I am a firm believer in the safety of workers – I am just not convinced that the definition and the confusion over hazard versus risks is serving us well in keeping people safe.

Stay tuned, I am currently writing a book with my thoughts on this issue and it’s a ‘safe’ bet it will answer many more of your questions on workplace safety.

Learn more about risk management – find a course to suit you!

[1] SafeWork Australia, Code of Practice: How to Manage Work Health and Safety Risks, December 2011, p4.

[2] http://blog.papertrail.io/construction-safety-risks/#.WoQJO6iWY2w

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