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"If there's one thing I've noticed over the last ten years it's that you have those safety risks that are clear for everybody to see," says Paul Wright. "If there are trip hazards on a walkway, you can see them and do something about them. But quite a lot of what we do brings up risks that are only noticeable for a few seconds or only come to light at some stages of the activity or the day.
"Part of my job is to make sure those risks are properly understood. Then you can start to devise how you are going to control them, whether it's eliminating them or putting in control measures."
Recently arrived at the top OSH job in the UK's biggest waste contractor, Wright spent his first months working out how to build on the company's hefty cuts in accident rates over recent years.
One of the answers he has come up with is to apply process safety principles to some of the less- considered hazards.
Paul Wright Career file
2018- present, Group health and safety director, Biffa
2015-2017, Director, Holly Tree Consulting
2014-2015, Divisional safety, health and environment director, Costain Natural Resources
2013-2014, Divisional safety, health and environment director, Costain Infrastructure
2011-2013, Divisional safety, health and environment manager, Costain Infrastructure
2011, Group safety, health and environment manager, Costain
2009-2010, Head of Health and safety assurance manager -- Athletes Village, CLM Delivery Partner, London 2012
2007-2009, Senior health and safety assurance manager, CLM Delivery Partner, London 2012
2004-2007, Regional safety, health and environment adviser, Costain
2003-2004, Safety manager, Bovis Lend Lease
Process safety, developed for the oil and gas sector, uses a set of well-established techniques to analyse the hazards in a system, the risk of them triggering a major event such as an explosion or hydrocarbon or chemical release and the controls, both physical and procedural, that are necessary to control the risk.
It seems an unusual move to apply its principles to a service industry, albeit one with some industrial elements -- Biffa deals with hazardous waste streams such as acids, alkalis and flammable residues, and generates energy through chemical reactions in anaerobic digesters and from landfill gas recovery.
"When you knit together the relationships between each stage of the waste management spectrum, I see that as a process. There is a benefit from sprinkling the principles of process safety on to that system of work activity. Because if we have a low-probability, high-consequence event in any one of those stages the people who will be affected by it are our employees and the public."
I ask for an example of the hazards he believes the approach would help the company manage better. In the waste collected from civic amenity sites and industrial premises taken to Biffa's material recovery facilities "you can have items like unused flares and petrol canisters, things that can explode or create fires. When that gets picked up by a grab or by any machine that can puncture it that could be a serious near-miss or worse.
These things are transferable because we are employing people from the same human race
"We had an incident earlier in the year where we were processing used aerosol containers. They were within an enclosure. Some of the aerosols exploded, resulting in a fire. This was in close proximity to people, so if anyone had been nearby there could have been serious injuries."
A process safety approach would look not just at the aerosol storage but its context, he says. Would that mean reconfiguring the space so the store was well away from heavily-trafficked areas?
"We might redesign the process, the space and the whole operation. You also have to look at the pre-dictable unsafe behaviours that might happen and how you control for them. You look at the components in isolation, then you have to put them together again."
Another of the more rarefied risks is that caused by organic waste left undisturbed too long at treatment sites overheating and combusting.
He was inspired by experience at a previous employer, construction and engineering contractor Costain, which brought in process safety manager Richard Roff in 2013.
I note that process safety methods can be complex and demanding on OSH advisers, let alone site operatives.
"It doesn't mean we are going to do full hazop studies and failure-mode effect analyses," he says, citing two of the more involved techniques. "It's just asking an enhanced set of risk identification and assessment questions in scenarios that haven't been put under that level of scrutiny in the past."
Other process safety tools, such as bow-tie analysis, could be applied to waste work, he believes. (Bow-tie diagrams fan out the barriers to a threat eventuating and the barriers to recovery either side of the central "knot" of a serious incident fed by the hazard. See IOSH Magazine's Gamification feature for more.)
Members of his team attended the annual Process Safety Management summit in Manchester in April. Two are now being trained as process safety champions. He plans to task them with identifying the top ten process safety risks in the business.
In the scheme of things
As Biffa's group health and safety director, Paul Wright reports to the group chief executive. He has five direct reports, one safety, health, environment and quality lead coach for each of the four divisions: industrial and commercial waste, municipal waste, resource recovery and treatment, and energy; plus a central head of SHEQ policy and performance.
Below those leads are 17 OSH professionals, 13 coaches -- advisers supporting the operational teams -- and four in the corporate centre. Wright's policy and performance head has two auditors who monitor compliance with group standards. The remainder oversee and update policies and procedures.
"The function is quite a traditional one, it's very close to how SHEQ departments work in the construction industry, he says."
External audit is carried out by NQA for the ISO 14001, 9001 and 18001 standards(see the "Towards 45001 box below") and by the British Safety Council through its annual five-star audit programme.
Asked what it is that his position contributes to the organisation, he says there is a technical and a non-technical answer. "The non-technical one, though it's not explicitly written in my job description, is that I have to come into the workplace every day with influencing energy, drive, resilience and guidance to support everyone who works in the business to do their jobs in a safe, healthy and responsible way."
And the technical answer?
"I report to the chief executive officer and serve the executive team. I also report to the PLC board to give them the fact-based confidence that we have all the necessary arrangements to deliver our services in a responsible and ethical way. Day to day, my team is charged with developing policy and standards and working behind the scenes to make sure they are always in line with the latest thinking and turning those into practical tools."
I ask him to predict a few of those that will make the ranking. As well as the explosion and fire risk from puncturing containers he notes that there is a lot of dust generated at materials recovery facilities, "which can settle and create an explosion risk, especially combined with static electricity".
Transport and handling of hazardous waste is another contender (the new techniques will be piloted in Biffa's hazardous waste division) as is the interface between the company's thousands of vehicles and members of the public.
I observe that this last one does not sound as much like a process safety risk -- even if you visualise the road network as the pipes between the processing activities in the waste collection and treatment system. Nevertheless, it is one of Biffa's critical hazards - one of its refuse vehicles fatally struck a member of the public in Edinburgh in April -- and its inclusion suggests there will be no let-up in the pressure on the most common hazards in favour of the overlooked ones.
Wright emphasises this point: "We will continue to focus on keeping people safe in everyday tasks, some just need a more considered risk assessment," he says.
"We have a lot of people walking daily on the public highway. The pavements and paths are littered with trip hazards and a lot of our people are still sustaining serious injuries like broken or sprained ankles. We'll always be taking steps to learn lessons and eradicate them."
Process safety techniques will be "Not a silver bullet, but an enhancement ... We adopt a holistic approach to management of risk."
Nevertheless, he hopes that the process safety overlay will promote consideration of the business's risks in "high definition" and create a greater consciousness among frontline staff that will generate greater benefits.
The hazardous waste business was chosen for the pilot not just because of its risk profile but because it employs many chemists who have a grounding in process safety principles. "We are lucky to have many people who are ready made to go and refresh themselves on these principles."
If the trial delivers, the programme will be extended to the other divisions over the next 18 months. The success of the subsequent extension company-wide will depend on the way the process safety tenets and techniques can be translated into language the managers and operators are comfortable with.
In 2013-14, Biffa's lost-time injury (LTI) rate was 0.68 per 100,000 hours worked and its over seven-day injury rate -- those notifiable under the Reporting of Injuries Diseases and Dangerous Occurrences Regulations (RIDDOR) -- was 0.34. By 2017-18, the rates had been reduced by at least half, to 0.27 and 0.19 respectively.
Wright says this was due to a sustained pressure to improve the foundation elements of OSH management. "We have put that management framework and structure in place. We have the processes in place. People know their responsibilities."
The achievement was recognised in 2017 by the British Safety Council's award of its highest OSH prize, the Sword of Honour -- an impressive piece of steelware which lies on the desk in front of Wright during our interview (see photo below)
He says the company is naturally proud of the accolade. But doesn't that pride and the success that generated it make his job harder in making a case to double down on safety and reduce the rates further?
He agrees: "It's going to be hard work to get improvements ... our accident rates are beginning to plateau and the prediction for our LTI rate over the next five years is that it will flatline."
But he says the challenge that forecast presents is a welcome one and that it spurs him on to find ways to breathe even more life into workforce engagement with safety and health: "You need to create some virtual injection points for positive energy."
The process safety initiative is one such insertion point, he hopes. Another is a new initiative starting in September.
The Biffa Safety Step-up will be a six-monthly week-long event at which employees across the divisions will discuss safety and health with two emphases: celebrating success and embedding what the company does well, and finding improvements to safety standards and learning from others.
"It's an event that will challenge and encourage all our sites and employees to take part in a big discussion about those themes and how to apply them locally," Wright explains.
Kicked off by a company-wide teleconference from the chief executive, the week will continue with local events and discussion groups coordinated by site managers and safety improvement teams.
Wright's central team is developing a toolkit to help the managers prepare for the first Step-up week, including promotional materials, calendar planners to schedule events through the week and a guide to OSH successes achieved by Biffa staff, including examples of high-quality near-miss reports. The team has called for best-practice nominations from the sites to feature in the guide and there will be rewards for those whose work is included.
He wants to encourage the workers and managers to ensure that their discussions focus on issues that really count, rather than "just talking about stuff for the sake of talking about stuff. The quality of conversations has to hit the right level."
Though Biffa has brought its accident rate below the average for its sector, that sectoral rate is still notably high. In 2016-17 the non-fatal reportable injury rate was 1,788 per 100,000 workers; the construction industry's rate was 397.
Waste management and recycling shares many of the same hazards as construction: heavy plant operates close to workers on foot; large volumes of material are shifted around sites daily.
The Health and Safety Executive (HSE) has paid special attention to the sector but its efforts have not been as concentrated -- partly due to reduced resources -- nor as successful as in construction. Despite more than a decade's work by the sector safety body the Waste Industry Safety and Health Forum, the HSE's recently issued waste sector plan is unusual in stating it still wants to see "ownership of the challenges by industry and leadership on implementing solutions".
I have to meet the people I am supporting in their world and see things through their eyes
Biffa's operations have been certified to the BS OHSAS 18001 safety management standard since 2005. Paul Wright says the company plans to start its shift to 18001's successor ISO 45001 next month.
"We are just in the process of finishing our transition to ISO 14001 2015 and ISO 9001 2015. After that in September we will begin our process of transition to 45001."
Wright calls the transition "project streamline", the title reflecting his view that the move is an opportunity to declutter the company's OSH arrangements and policies.
"From previous experience, companies that have been operating many years always have a huge volume of procedures and processes and tools. From time to time a bit of strategic spring cleaning will help tidy them up and make sure they are fit for purpose and appealing to use, and provide structured guidance on how to do things well."
I ask what his own informal gap analysis suggests Biffa will have to focus on to reach the new standard.
That mental gap analysis of OSH arrangements is "never turned off", he says, as an aside. "You can have a great day as a leader, doing things you need to do and the following day things may not go according to plan."
On my question, he says the top managers in Biffa are undoubtedly committed to safety and health, demonstrated by the firm's recent successes and achievements. Maintaining leadership alignment is essential to good OSH performance. "Without that alignment you can't generate the leadership horsepower that's needed to drive a safety agenda that has to be super-intelligent to address some of the opportunities in the organisation.
"I've observed situations during my career where sloppiness can creep in where you have misalignment," he says. He gives the example of performance analysis: "If there isn't alignment to the commitment to make time to review health and safety performance in the business at an appropriate level of detail, there is the potential for performance not to receive the level of leadership engagement it deserves, either to positively reinforce the good things we do or to determine what we are going to do to address gaps in our arrangements."
As a newcomer to the sector, Wright believes it has lacked a "John Prescott moment", referring to the galvanising effect of the 2001 summit of construction executives called by the then deputy prime minister to address the industry's high fatality rate.
"That was the time when the government and the HSE gave a clear indication of the standard of leadership they expected from the construction industry. Over 15 years that has driven improvements and we now have ownership of solutions by industry," he says.
"We aren't going to get that opportunity in waste so what can we do to create a similar impact?"
The challenge is an urgent one, he says, because the industry has grown so fast in recent decades, driven by the demand for recycling. "And it's only getting bigger. It's one of the reasons I went for this job. Landfills are closing; the likelihood is we will only have around 50 in the country by 2020. We had over 500 in 2012."
As in his own case with the process safety transposition, the waste companies' safety experts have to look to the successes of other sectors and replicate them, he believes.
"Mental health has been an issue as long as we've been on the planet," he says by way of an example. In the past two years construction contractors "have all decided to switch the light on together. What we can't do in the waste industry is wait years to come across the issue; it applies to us as well. These things are transferable because we are employing people from the same human race."
He is positive about the prospects for improvement. "I think the waste industry is on the eve of a new era of performance. I would relish the opportunity to be part of that and to facilitate those sort of discussions and engagements."
He is looking forward to talking to his opposite numbers in the other big contractors: Viridor, Veolia Environmental Services, Suez Environment and FCC Environment: "I will see what we have in common in terms of safety standards and what we do differently."
Wright started his new job in January after 15 years in increasingly senior OSH posts in construction and engineering, most recently for EDF at the construction of two new nuclear reactors at Hinkley Point C nuclear power station in Somerset.
What was it like arriving not just in a new business but in a whole new sector?
"I didn't know a single person who worked in the company who I could call on to talk about how the job was going in the first few days. It was daunting for the first week."
He was helped by a warm welcome from his colleagues and a detailed four-week induction schedule -- "that's not a given, based on my past jobs where I've had to effectively onboard myself" -- the company sent him on a month before he started. Those weeks were spent meeting staff in Biffa's contact centres and waste transfer and processing sites up and down the country. He says he found a robust culture in which people were encouraged to report both good and bad conditions.
"Seven months in I feel part of the team and I'm really happy to be here."
He believes he brings a "reality check" to the organisations that employ him. "I started working life completing a modern apprenticeship in steel fabrication and did that for a few years, so I understand what health and safety needs to look and feel like at ground level."
In 2007, while working for Costain as a regional safety health and environment adviser, Wright was seconded to help provide OSH assurance for the "delivery partner" joint venture set up by Mace, Laing O'Rourke and C2HM to run the construction of the main venues and Athletes Village for the London 2012 Olympics.
Like most of those who worked on the project, he talks of being privileged to have been part of the much-studied safety operation for the first modern Olympiad without a work-related fatality.
"I was there for about four years and I felt as though I got 15 years' experience," he says. "I felt that I was working with the best management team that's ever been assembled. You had people from all over the globe together on one concentrated school of excellence on mega-project design and delivery."
What does he believe made the safety culture so strong?
"What stood out was the strength of commitment to put into practice simple things. People were encouraged all of the time to work safely and responsibly, to speak up and raise concerns.
"There was a clear understanding of the vision for safety, which was for it to be the safest and healthiest project we had ever worked on. To deliver that there were clear arrangements overlaying a massive number of people from different organisations, all of them aligned to achieving these clear goals."
He says the project gave him the opportunity to deepen his soft skills, working closely with operations managers to translate safety objectives into practice. He was also mentored to develop his professional understanding by Mark Thurston, then CH2M's head of structures, bridges and highways and now chief executive of High Speed 2 rail link, designed to cut journey times between London and Birmingham, Leeds and Manchester.
What does he see as the key to good safety and health leadership?
"The desire to understand the risks associated with the work you are responsible for. I've seen some risks managed in a way that's quite superficial and with no proper understanding of them."
I ask if he means leaders have to spend time on research or direct observation of working practices.
"It includes both of those things. It means making sure you are up to date with the latest thinking on risk management techniques. One thing that has served me well is rolling my sleeves up and getting alongside the teams and seeing how they see risk and find out if there are any limitations there so I can support them to see the risk in its entirety.
"I have to meet the people I am supporting in their world and see things through their eyes. It's what I call empathic leadership."
This approach works all the way up the chain of command. Before presenting plans for OSH improvement to fellow directors "I have one-to-ones, cups of coffee, meetings, sometimes in the evening, just to see how the leader sees these challenges.
"You can't take it for granted that the leader sees the opportunities and the need for improvements the way the safety practitioner does. I've had to step into the shoes of the chief exec or the MD because then I can construct my business cases, my reasons why we should do things, in a language that will resonate with them. I might have to do six different versions of the same message."
He doesn't worry about work, he says. "But I've learned to be comfortable being uncomfortable. I wake up most days thinking that there will be something a little bit unplanned that will require me to provide support, guidance and direction."
This positive attitude extends beyond the immediate challenges of his job.
"I've never known a better time to be working as a safety professional," he concludes. "I've been doing it for just under 20 years and when I started you didn't have as much access to people to discuss how safety should be done in companies. Now you have LinkedIn, you have IOSH, you have so much opportunity to put your view across and to talk to people who are a few years ahead of you in their careers. I think it's fantastic."
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