Workers’ OSH improvisation need not be scary

Former editor, IOSH Magazine

The idea of workers making up their own safety procedures unsupervised by specialists in their organisation could sound like heresy to many OSH practitioners.

But that’s exactly what researchers from Loughborough University have found is happening in sectors such as logistics and healthcare.

What’s more, they say practitioners should recognise these “workarounds” are happening and support them where possible.

When you break this down, it may not be as alarming as it first sounds.

Aside from high-hazard activities, there is seldom just one right way of doing things safely. Risk-based regulatory frameworks give room for flexibility. Most UK OSH law, for example, allows dutyholders to devise their own methods of managing risk, which will be tested for fitness in the event of accidents or sickness. Approved codes of practice offer compliant methods but state that, if you can devise an alternative way to achieve the same level of protection, it is valid.

Most regulations require risk assessment by a competent person but, for smaller tasks and more obvious hazards, the frontline staff will know them better than anybody.

There may also be an element of necessity to some of these workarounds. The Loughborough academics highlight home delivery drivers as one group whose highly-variable, unsupervised workplace make dynamic risk assessment and an element of improvisation both necessary and inevitable.

By coincidence, home delivery staff are cited by Neil Lennox, head of safety at Sainsbury’s, as an example of the changing world of retail in our January 2017 issue leader interview.

The supermarket chain gives these lone workers equipment and training to work safely but, as Lennox admits, relies on their judgement out in the field to manage a shifting combination of hazards.

Most of the leaders interviewed in this magazine try to encourage the OSH specialists in their organisations to cede day-to-day risk control to those who are best able to manage it at close range, whether that is managers, supervisors or, in this case, the frontline workers.

The OSH professional’s role then becomes more akin to a consultant’s, providing training and advice and stepping in when the hazards are too complex for a non-specialist to assess.

Practitioners can gather details of local adaptations, systematise the best of them and adapt or replace the ones that introduce unforeseen hazards.

All of this is a long way from the idea of workers “going rogue” and inventing their own OSH rules. It may bring practitioners new challenges, but also new opportunities.

Wishing you a happy and healthy 2017.


Louis Wustemann is former editor, IOSH Magazine. He was previously editor of Health and Safety at Work magazine and Environment in Business. He has written, edited and consulted on health and safety, environmental and employment matters for more than 25 years.

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  • I think we need a lot more

    Permalink Submitted by Anonymous on 19 January 2017 - 12:55 pm

    I think we need a lot more accuracy and a lot less journalistic interpretation. Firstly the semi legal standing of an ACoP does not equate to or even imply that "if you can devise an alternative way to achieve the same level of protection, it is valid". They do say that alternative methods of compliance may be used but with the codicil that it will be for the defendant to prove that the alternative method used was at least as good as the recommended method. There is a world of difference between "if you can devise an alternative way to achieve the same level of protection, it is valid" and 'However, the Code has a special legal status. If you are prosecuted for breach of health and safety law, and it is proved that you did not follow the relevant provisions of the Code, you will need to show that you have complied with the law in some other way or a court will find you at fault'.
    Before advocating even partial acceptance workaround methods perhaps a read of the Wilko court report specifically "The investigation also revealed evidence that supervisors had not had adequate roll cage training themselves, so could not be properly relied upon to provide new employees with the necessary and comprehensive training. To compound matters, staff were expected to make a visual assessment of whether the lift floor was levelling."

    Managers and especially safety managers must establish and understand why a workaround is necessary, what is it about the safe system of work that is not working for those it was should have been designed for. It must also be remembered that often those at the front line may not have their own or other persons health and safety at the front of their mind but may well be concentrating on achieving the end making the delivery, getting things out on the shop floor I doubt very much the people who loaded the Wilko roll cage gave a thought to the fact that they way they loaded it made it top heavy.

    I am not against involving workers in producing Safe Systems of Work in fact I think it is the only way to produce a workable safe system of work, but I am against allowing workers to invent their own to suit the circumstances, to put a lighter twist on it would it be ok to ask the delivery worker to make the delivery if in his/ her assessment they think they can run faster than the dog I think not I bet that Sainsbury's (and others) advise if the dogs are loss Don't get out of the van.


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