Dr Dominic Cooper CFIOSH argues that the ideological new take on Safety Differently raises questions.
Should companies cease to manage safety, ceding all control of it to the workforce? This ‘New View’ is based on the premise that traditional OSH (Safety I) treats people as problems to be controlled, arguing ‘people should have complete autonomy over their work and be viewed as essential contributors to solutions, as they possess adaptive capacity to cope with problems at the sharp end’.
But its claim appears to be that the workforce knows best when it comes to managing safety. Indeed, Safety Differently states: ‘It is time for Safety Anarchists: people who trust people more than process, who rely on horizontally coordinating experiences and innovations, who push back against petty rules and coercive compliance, and who help recover the dignity and expertise of human work.’
While most OSH professionals don’t like anarchy, we would – and do – advocate and encourage employee engagement in safety. And this is underpinned by the law – at least in the UK, EU, US, Australia and New Zealand. How many follow the participation laws is a different debate but, in principle, workers should already be involved in safety.
A costly approach?
The real question is whether this ‘state of anarchy and disorder’ could deliver a safe workplace. When people have safety decision-making freedom, evidence shows the risk of a fatality rises to about one per 100 exposures. Vessel-masters as sole decision-makers in the deep-sea fishing industry might chase the fish in ever-treacherous conditions, resulting in lives lost. But when formal safety structures are implemented and followed on such vessels, the death rate halves. The contrast and potential impact of New View versus traditional philosophies should not be taken lightly.
The argument in John Green’s article ‘Leading light’ in the May/June 2020 edition of IOSH magazine that ‘safety should be seen as the capacity of the organisation to get things right, rather than simply the absence of things that go wrong’ appears to be based on Hollnagel’s Safety II premise, which states: ‘The presence of positive capacities can help assure a system’s continued functioning even under varying circumstances, so that the number of intended outcomes is maximised.’
However, this concept is based not on OSH but on resilience engineering, which is concerned with operating as close as possible to the boundaries of failure without falling over. In other words, Safety II’s philosophy of pushing the envelope is diametrically opposed to Safety I’s ‘defences-in-depth’ principles.
Even if a company does things right 99% of the time, one person will still get hurt for every 1000 risk exposures
The right/wrong debate
The traditional focus on what goes wrong is partly due to regulators’ requirements (for example the Health and Safety at Work Act 1974) and partly because companies want to monitor the effectiveness of any risk controls, provide lessons to avoid repeat incidents, trend important safety issues, and provide real-time monitoring of their safety culture. We also know that locating and fixing negative aspects of safety can improve associated management systems and deliver sizeable returns on investment.
Though looking at what goes right provides a different perspective, it is not necessarily any better than focusing on what goes wrong. The US Nuclear Regulatory Commission demonstrated, for example, that analysing positive or negative features of the same system often produces the same result, yet analysing the positive takes longer, so is less efficient.
People also find it easier to agree what failure rather than success is in any given situation. Research in the Australian construction industry examining the use of positive performance indicators in OSH since 1994 found that injuries did not reduce.
Even if a company does things right 99% of the time, one person will still get hurt for every 1000 risk exposures. It only takes one unsafe behaviour for someone to fall from a roof and die.
The principle that safety should be ‘an ethical responsibility, not a bureaucratic activity’ suggests the New View approach sees safety practices as coercive. Yet it doesn’t seem to consider that rules and safety systems might enable and help people in their work.
By necessity, some elements of a safety management system are bureaucratic in order to help companies meet regulatory requirements – such as standard operating procedures – while others are enabling. It’s important not to over-emphasise ‘heavy-handed’ bureaucratic practices, since bureaucracy and documented procedures have brought progress, avoided recurrent mistakes and encouraged best practice.
Procedures can also have positive psychological effects on employees in the clarity they offer. Of course, rule effectiveness depends on a link to the desired outcomes and on people understanding their purpose.
The Safety Differently New View involves using mindset and philosophy changes to guide the next stages of safety development – yet it is silent about injury reduction. Three decades ago, I was asked constantly whether behavioural safety reduced injuries: I could say yes, and prove it. So, I asked the same question of the New View approach. Without peer-reviewed scientific evidence, I viewed corporate sustainability reports (CSRs) of companies known for taking this approach.
They appeared to show either plateaued accident frequency rates, variable effects in fatalities or lost-time incidents, repeated annual increases in serious injuries and fatalities, or in one case a doubling of incident rates.
Meanwhile, other companies adopting a more traditional safety philosophy have reduced fatalities by 80% within three years.
These CSRs reinforce the view that incident and injury reduction must remain the central focus of OSH practice and research. They also raise ethical questions about whether the acceptance of danger on the shop floor within New View companies is normalised.
Tried and tested
IOSH and the global OSH profession need to refocus on evidence-based solutions. Britain has reduced minor injuries by about 66% over the past 32 years, while serious injuries and fatalities have plateaued. The ideologies that have emerged recently, such as resilience, mindfulness, mental health and Safety Differently, are not supported by scientific evidence that shows they reduce the problem. Evidence-based solutions – such as behavioural safety – are made ‘lean’ to reduce time and costs. The poor results, in turn, create the climate for a never-ending supply of untested solutions sold as the next magic bullet. Readers should reconsider John Green’s article, study the evidence and make up their own minds.
Dominic Cooper PhD is a Chartered Fellow of IOSH who has recently been elected to the IOSH Council and a professional member of the American Society of Safety Professionals.
John Green responds: Moving forward
It’s doubtful if Dominic and I will agree on how safety should be created and managed in organisations, but I think it’s important that readers get the opportunity to judge for themselves the respective merits of the different approaches. It is not unusual for a new or different approach to be misunderstood, and Dominic’s piece misunderstands the intentions, principles and practices of Safety Differently, Safety II or the New View.
We are not anarchists (although Sidney Dekker did title his book The safety anarchist), but we do believe that the bureaucracy has gone too far with rules for even the most trivial risk. This diminishes the importance of those rules that really matter and makes the system unworkable simply because of the volume of paperwork. Safety Differently focuses on high-risk tasks, its practitioners obsess about how we go to work in high-risk situations, and much of our day is spent in ensuring alignment between how work is actually carried out (work as done) and how that work had been planned and laid out in the associated paperwork (work as imagined). It’s in that gap where the messy details of significant events begin to emerge.
This new approach is not silent about injury reduction and neither am I. There’s a common misconception that we only care about successful outcomes and that accidents or incidents don’t interest us. It’s certainly true that we find success interesting, but we find all outcomes interesting. Good, bad, normal – if we can learn from an event then we are interested. The beauty of this approach is that these things are happening every day, all around us. We don’t have to wait to play ‘whack a mole’ with incidents to keep learning.
'No matter how well the tried and tested methods have served us in the past, they are inadequate for the present'
I have never advocated simply ditching everything we have done and it’s always been Safety I and Safety II, never Safety I or Safety II. I have always acknowledged the successes of the past in reducing incidents, and I have similarly stated that whatever we do moving forward cannot be at the expense of increased injury rates. However, I have also witnessed first-hand the frustration within organisations and frontline workers at the way safety turns a blind eye to the difficulties of doing work in the real world, the stifling effects or bureaucracy and the blame and shame game – one CEO refers to this as ‘two-speed safety’. This disillusionment leads to disengagement – if you involve the people standing in the middle of risk in the management of that risk and you will develop trust through mastery and autonomy.
It’s easy to cherry-pick studies, ‘facts’ or statistics in support of a point of view (you can’t compare Laing O’Rourke industry-leading incident rates with Vodafone’s fatality rates), but no matter how well the tried and tested methods have served us in the past, they are inadequate for the present. What is ‘true’ and what is ‘fact’ changes over time.
The world of work has changed. It has become volatile, uncertain, ambiguous, and immeasurably more complex and we need to respond with an effective approach.
I have been involved in safety for more than 40 years, and I care deeply about the organisations I work for and the people within them. I believe all safety professionals feel the same, but we need to have the courage to look for new ways if the tools of the past are no longer serving us.
John Green is vice-president, global HSE, at SNC-Lavalin. Read his original article at bit.ly/IOSH-Green-leading-light