The Corporate manslaughter legislation and recent HSE guidance on directors' duties has focused the minds of many executive boards on the needs to have at least a basic grasp of their businesses' safety policies and performance.

The supplier of half the UK's sugar (see box below) has developed a model of director responsibility that goes way beyond any guidance, where board members are each responsible for discrete areas of safety such as fire or contractor management. The model has helped the firm cut accidents by 60% in five years.

Before 2003, British Sugar attracted attention from safety organisations and the enforcing authority for only the right reasons. Gathering awards from the Royal Society for the Prevention of Accidents and the British Safety Council, and accredited to the OHSAS 18001 safety standard, the company was recognised in the industry for the importance it attached to safety and its excellent record.

Health and safety had long been a business priority and a source of pride for the firm, so the death of a female employee in a workplace transport accident in 2003 was all the more devastating.

"It shocked the whole company down to the core," says company safety manager Ash Solanki. "We'd had OHSAS 18001 for a couple of years, we'd got awards, accidents rates were going down, so everything was looking good. But the reality is that you're never far away from the risk - just crossing
the road in the car park you have a potential fatality. So you can never switch off."

British Sugar

British Sugar supplies approximately half the UK's sugar, processing more than a million tonnes each year, derived from home-grown sugar beet. It has 1,324 employees and 1,100 contractors, working across eight sites.

There are four sugar beet processing sites - the largest at Wissington in Norfolk and others in Bury St Edmunds, Newark and Cantley near Norwich - plus two distribution centres, a conference centre and a head office in Peterborough.

The business of sugar production involves some high-hazard processes. The scale of the company's operations is a challenge in itself: every day a thousand lorry-loads of beet are delivered to each manufacturing site, bringing with them the transport and management difficulties associated with having numerous contractors and hauliers on site.

The work activities involve a large amount of heavy machinery, such as dumper trucks. Inside the processing plant, on top of all the risks that come with any heavy manufacturing site, there are around 300 confined spaces, 70 items of scaffolding in place at any one time, and precautions to contain the potentially explosive sugar dust.

Each manufacturing site has a power station for exporting electricity, and the Wissington site boasts the UK's first bioethanol plant.

The safety management team is represented at all eight sites. Each processing site has a full-time safety coordinator who has obtained the NEBOSH Diploma or equivalent, while the other sites have part-time safety coordinators who have the NEBOSH Certificate.

At head office, Ash Solanki is one of three full-time safety managers charged with responsibility for policy, strategy, projects and management systems.

Behaviour gap

The fatality prompted the company's senior management to carry out a full-scale review of the firm's safety management systems. Working with the HSE and with outside consultants, British Sugar took a new approach to safety management, changing behaviour from the top down.

Up to 2003, director leadership of health and safety at British Sugar ran along traditional lines: one board member - the operations director - had formal responsibility for safety. The fatal accident provided the impetus for change.

"We decided to take a fresh look at safety," recalls Solanki. "The chief executive officer said 'Right, we're going to do this differently - we need safety to be an integral part of every department, wherever they're based.'"

The CEO, the operations director and Solanki carried out a comprehensive internal review of the existing management systems.

"What we couldn't understand was why this fatality happened when we had the procedures and we trained people," says Solanki. "What we found was that there was a gap between training people in the procedures and people following them every time. It was a behavioural issue.

"The other question was, if someone was behaving unsafely, why was it that nobody noticed? The problem was that over a period of time managers had become so busy - they were so focused on their own jobs - that we weren't giving them time to stop and think about safety."

As well as bringing in consultants to help develop objectives, the firm sought help from the HSE. The executive asked questions about the firm's safety permit system: What is a permit? When do you use it? Why do you use it? 

Working together, Solanki says, they discovered the permit system had lost some of its value, and in some circumstances had become little more than a paperwork exercise - an end in itself rather than a means to an end.
"People thought, 'If I've got a piece of paper called a permit, then I must be safe,'" says Solanki, "which just isn't true."

Standard approach

The review prompted a fundamental change in strategy. With support from consultants at DuPont, the safety team devised a new business model for safety management at British Sugar.

Traditionally the board devised policy - outlining the firm's general aims in health and safety - and stopped there. The new business model created a loop so the board would receive feedback about how far policy was being followed.

As a first step, the board spent quite a lot of time defining leadership criteria and the behaviours they expected from people.

Solanki and his team produced a booklet outlining these behaviours - how to manage risks, how to demonstrate exemplary personal safety such as by holding hand-rails or using proper walkways - and visited each site to roll it out.

"We got everybody together," he explains, "and said, 'We're going to draw a line under whatever happened before; from now on, if you don't follow these behaviours, you could be disciplined.'"

The process took around three to six months, and was carried out in consultation with the unions.

The next step was the creation of "safety standards teams". Previously, whenever the firm wanted to implement a new safety standard or procedure, Solanki and the safety department would present the sites with the finished procedure and explain why it had to be followed.

What  the review revealed was that this approach made managers in the factories feel they were being dictated to, and that safety processes were being imposed on them.

Under the new business model, the firm established seven safety standards teams, led by senior managers and factory managers, which are tasked with formulating and reviewing procedures and deciding how the company should comply with new legislation, such as the revised Noise at Work Regulations.

"Being factory managers, they are a lot more practically minded than anyone in the safety department," says Solanki. "They have a better understanding of what their people's capabilities are and a better understanding of the business structure going forward."

Role of honour

Each team focuses on a discrete area of safety and comprises a cross-section of employees from different sites to ensure procedures are relevant company-wide.

There are standards teams for contractor management, permits to work and occupational health and, when necessary, teams are set up for short periods to consider new concerns or areas of regulatory impact, such as noise or the EU's REACH chemicals regulation.

Every team has an allocated safety officer on hand who can provide advice and support and who ensures new procedures are compliant with the relevant legislation.

A measure of the success - and the high profile - of the groups is the perception in the company that "if you want to get on in the business, you need to be in one of these safety standards teams," notes Solanki. "It became an honour to join one of the teams. Those that demonstrated good safety leadership found that they stood out."

On the suggestion of the firm's finance director, the teams get input from external consultants so that they don't become too inward-looking; Solanki says this outside influence stops them trying to reinvent the wheel.

The approach has given ownership of safety procedures to the people who have to implement them, and removed the resistance to change that was sometimes a feature of the old system.

On the beet

Perhaps most significant about British Sugar's business model for safety management is the commitment it requires from the board.

Rather than simply appointing a director to oversee safety matters as a sort of figurehead for the cause, the company decided that individual board members would have specific areas of responsibility for which they would be accountable - and on which part of their bonuses would depend.

Each director "sponsors" a safety standards team, monitoring its work and providing board-level guidance as necessary. Monthly board meetings always begin with a safety briefing, and the sponsors take it in turns to report back to the CEO and the rest of the board on progress in their particular area.

The director with responsibility for contractor management issues, for example, might report to the board that the safety standards team has decided to use only competency-assessed contractors who are on an approved list. "The directors rolled up their sleeves and got stuck in," says Solanki.

Solanki sat down with the CEO to allocate areas to individual directors. While initially he found some of the decisions surprising - you wouldn't immediately associate a sales director with contractor management - the results have been good.

"What I've found is the directors are very capable people," he says. "No matter what subject you give them, they've got the ability to think things through strategically.

"A fresh pair of eyes also meant there was no baggage. There was no, 'Oh we can't do that, that'll never work' - those kind of thoughts never occurred to them."

High visibility

To prepare them for their safety roles, all of the sponsors attended the Institution of Occupational Safety and Health's Directing Safely course and took the exam at the end, which all passed first time.

They also spent a day with advisers from DuPont, learning how to conduct behavioural audits; "they explained what the role of the director is in terms of leadership, visibility, things like that," says Solanki.

The sponsors had access to the consultants whenever they needed advice, and Solanki and his team have provided ongoing support.

Managers carry out behavioural audits at their own sites, but there is also a rota for board members to carry out audits; this completes the feedback part of the loop in the firm's business model (see above).

When the director arrives on site, the local factory manager gives a short presentation, explaining what jobs they are carrying out that day, when their last accident was, and any other significant issues.

The director can then decide which job they want to go and look at. They stand and observe the job being done then talk to the operator, first reinforcing good behaviours ("thank you for wearing your hard hat") before discussing any potentially unsafe actions.

"The board forms policies, and they have a vision of what they want," says Solanki, "but they also have to put their safety shoes on and their high-vis jacket and get out and talk to people doing the jobs. In this way, they come back and modify their policies as appropriate.

"The other benefit we've found is that when employees see a member of the board putting on their personal protective equipment, they think 'Maybe it is important then'.

"It also reduces frustration, because people have access to the board - they're not just these people setting policy without any practical knowledge. It's made a big difference."

Keeping it real

When British Sugar implemented its business model for safety management, it set up a new software system called RIVO Safeguard for recording accidents and near-misses.

As soon as a lost-time accident is recorded on the system, an email is automatically sent to a hierarchy of relevant staff, up to and including board members. This is known as "reality feedback".

"When they get an email, a board director can immediately pick up the phone to the factory manager and say, 'How's it going? Do you need any help?'" explains Solanki. "That sort of level of involvement and commitment really makes a difference."

The director asks the factory manager to investigate the accident so that they can avoid a recurrence at any of the company's other sites. This encourages the manager to talk to other sites and pass on important safety information.

Sweet success

Solanki estimates that on average each director spends around half a day a month on safety. Directors are expected to carry out a minimum of four behavioural audits a year (ideally seven) and twice a year they conduct all-employee briefings which begin with a safety update, reviewing recent developments and explaining future plans.

A steering group meets almost monthly to coordinate the standards teams, pacing their work, ensuring consistency, allocating extra resources as necessary and resolving any problems that arise. It is chaired by a board member and comprises a factory manager and a company safety manager, plus other members from time to time.

While the company's initial aim was to give each board member equal responsibilities, Solanki concedes that it's better to acknowledge differing levels of safety skills and interest. "It's about being realistic," he advises.

"You can't expect all directors to have the same level of safety skills as, say, the operations director."

Every quarter, the HR director requests nominations for the company's safety awards scheme, which is open to employees and contractors. Winners receive a £500 prize and nominees each receive £50.

There's also an annual safety awards scheme specifically for contractors to apply for, where the prize is a donation to charity: £1,500 for first place, £750 for second and £250 for third. Applicants are asked to demonstrate the ways in which they have helped to improve safety at British Sugar.

The scheme is managed by a board member, who is also responsible for judging and presenting the awards. The sponsorship tasks rotate, so currently the head of supply chain sponsors the behavioural awards and the finance director sponsors the contractor awards.

Solanki says the firm has seen a step change since the new business model for safety management was introduced. As well as a 60% fall in all injuries, British Sugar has recorded a 75% drop in RIDDOR accidents (those reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations).

"Strategically we're a lot more focused and we're getting a lot more benefit from the way time is spent," he says. "It's made the business more efficient."
Central to the model's success, believes Solanki, is the commitment and leadership of British Sugar's directors.

"People see the directors carrying out an audit and they think, 'if the board makes time to carry out an audit, I'll do mine'... You can't quantify that benefit."

View from the top 

British Sugar's managing director, Gino De Jaegher, is sponsor of the "policy and organisation" standards team and has overarching responsibility for safety at the firm. As well as conducting safety performance reviews at board meetings and high-level safety reviews monthly, he conducts around five behavioural audits each year.

"The buck stops with me," he says. "I believe very much in leadership from the front: people will behave how the leader behaves.

"Safety is absolutely critical in our business, which is highly industrialised. The challenge is changing people's behaviour. What we're trying to do is put systems in place that manage and measure safety, but you're constantly battling to ensure safety stays in the forefront of everybody's minds.

"As much as it is important to have safety procedures and policies and toolbox talks, at the end of the day everybody comes to work to do their jobs. You're battling for a share of people's minds.

"As I walk the floors in the factories, I do see people more and more paying attention to safety - to what they perceive as being extremely important to me."