11 February 2009
Duncan Spencer

Managers are rarely judged by their safety performance; their operational efficiency and effectiveness is usually far more important to an organisation. Yet it's the safety practitioner's role to point out that there are many hazards out there, all requiring some degree of control and management.

This fact is exasperating enough for a manager, but if they are also led to believe that legal requirements are to be rigidly enforced - "You can't do that because of health and safety" - it is no wonder that many managers see health and safety as separate from the day job, or even as a severe and unwelcome restriction that hinders real-world operation.

So how can safety practitioners connect with frustrated and seemingly uninterested management? How can they sell health and safety as a positive force, founded in reality rather than just high ideals?

Though being dogmatic is one way to achieve managers' compliance with safety standards, quoting law at them is also the fastest way to lose their goodwill. Unfortunately, the more you use this approach, the more managers will believe that safety is a separate issue from the reality of day-to-day operation. It promotes an unhealthy disconnection between managing safely and operational effectiveness.

Sell the spirit

Our umbrella legislation, the Health and Safety at Work Act, is based on the principle that it is employers (and their agents the managers, the decision-makers) who should predict risk so that they can identify and implement preventative measures. It prompts organisations to have management systems for ensuring that people act safely, and use safe equipment in safe environments. However, it is up to us to decide what safe looks like - broadly speaking, "the rules are: write your own!"

The handle to the umbrella is the Management of Health and Safety at Work Regulations. These Regs use the language of risk, but what does it actually mean?

• You must carry out risk assessment: identify your problems and make records of those that really matter.
• You must implement risk reduction: find solutions to manage these problems.
• You must monitor risk: keep an eye on the problems to make sure they don't grow any worse, and on the solutions to make sure they continue to work.
• You must consult: recognise that employees should be part of the solution and that specialists may provide useful advice.
• You must provide information, training and instruction: make sure that employees know what the problem is and their part in managing it.

In other words, it's just about basic problem solving. All the other regulations are built on the same principle. Getting managers to understand this truth helps them connect with what the law requires. A problem-solving approach allows managers to be compliant with much of safety law without ever having read it - thankfully not quite all of it, or safety practitioners would be out of a job!

Regional variations

There are some interpretation issues though. The reason we have to tussle with the weasel words like suitable, sufficient or adequate is because most of this legislation was drafted in Europe to apply equally in all EU member states. Adequate ventilation in the UK is different to that in Greece.

To understand how to interpret requirements, the HSE has given us approved codes of practice, which are meant to be guidance and not law (though they are commonly misinterpreted as law). Provided you can demonstrate that you are doing something equally effective or better, then you are likely to be compliant.

Again, this need for local interpretation can be helpful in engaging managers and guiding them to define what is suitable, sufficient and reasonably practicable. Managers would be more likely to engage, discuss and understand. This would go a long way to deciding pragmatically what can be done and why.

The challenge is to use language that managers understand. Simply describing hazards may be seen by them as safety techno-babble, especially as they may think "If this hazard is such a problem, then why aren't lots of people being injured?" Almost anything has a potential to cause harm, therefore potentially hundreds of things can make the hazard list. Promoting safety purely from a  hazard perspective is therefore unhelpful.

One of the most effective methods of engaging managers I know is to involve them in a task-orientated discussion rather than a hazard-focused one. Managers understand tasks; that's what they ask people to do. A task-based approach helps them decide whether to worry about the hazards in the environment or not. Why worry about the falling-from-the-roof hazard if you don't send people up there? Analysing the task gives you and the manager an easy route to picking out the significant hazards and controlling the risks they cause.

Using a task discussion approach with managers enables the safety practitioner to be seen to be seeking understanding before offering advice or imposing new rules. The message that managers will welcome is that "we don't have to worry about everything conceivable".

Can managers eliminate hazards (see Figure 1)? Not usually; hazards are related to operational tasks. If we do send people onto our roof to clean out the guttering, then they will be exposed to the hazard of falling. The hazard can't be managed; it is what it is. It can't be eliminated by lowering the building for an hour. But the degree to which the person is exposed to the hazard, in other words the likelihood of a falling accident occurring, can be managed. In this case, the use of a hydraulic platform provides easier access which, when supported by training and the provision and use of a fall-arrest harness, reduces the likelihood of a fall.

Figure 1: Risk assessment methodology

So management focus should not be on the hazard, but on the likelihood of an accident. If the safety practitioner can use this approach, it places the safety concept back into the operational considerations of the task. Managers can't usually eliminate hazards, but there is plenty they can do to manage likelihood. Likelihood discussions help the safety practitioner connect better with managers, who quickly come to understand how they can influence it.

Also, discussing hazards has a negative feel: "This is a problem, that's a problem." Discussing likelihood has more of a positive aspect: "But we prevent accidents by doing this, and this, and this, and if we wanted to we could do this too." Any method that keeps discussion constructive supports the safety practitioner's quest to engage managers.

Managing disagreement

One of the key problems with risk communication comes when a manager informs the next level of management that there is a problem, but the boss perceives it differently and disagrees. If the risk report leaves the receiver to apply their own interpretation or opinion, then this can leave the person reporting frustrated because they are refused help or worse still they hear nothing at all.

Descriptions of risk should include data. If the answers to the likelihood questions are provided either quantifiably or as statements of auditable fact, then management discussion will be more precise. See 'Likelihood questions' below.

Consider the example in 'Sample risk assessment' below. Any disagreement is unlikely to be about the whole risk, but about aspects of the data in the risk assessment that need to be checked. It enables the safety practitioner to first identify what the manager does agree with in the risk assessment, and then narrows the disagreement to specifics that can be verified. It is not about opinion versus opinion, but about establishing data and fact. This makes it difficult for managers to use disagreement as an excuse to fudge things and therefore do nothing. It forces a decision - even if it is that we can't do anything at the moment because we don't have the resources.

One of the ways of engaging managers is by selling the risk assessment tool as a means of telling whether the wool is being pulled over their eyes. Managers are full of stories of how problems have been dressed up as a safety risk thereby forcing them to act. One of the benefits of teaching them how to carry out a task-based risk assessment is that it can assist them to reveal charlatan issues.

Selling benefits

Of course the more a safety practitioner can do to learn the language of business and the organisation's operational process; the easier it will be to converse with the managers. This is further enhanced if better safety can be sold to managers in terms of improved efficiency, business protection, benefits to sales or quality issues, improved morale and enabling the fuller engagement of employees etc.

The safety practitioner understands more than most the poor name safety has in our society. As a profession we have to work hard to find ways to reconnect with line managers. Hiding behind the law and safety techno-babble doesn't help. We have to learn their language and teach them ours to assure better dialogue. A pragmatic task approach to identifying safety issues added to a focus on the control of the likelihood of accidents occurring goes a long way towards keeping safety "real".

Likelihood questions

• Frequency of task?
• Duration of task?
• How many people do the task?
• Competency of operators (training, experience, knowledge and skill)?
• Pressure on operators?
• Effectiveness of existing controls (safe systems of work, guarding, signage, PPE)?
• Environmental conditions (lighting, temperature, floor type, space, distractions, and so on)?
• Previous history?

Sample risk assessment

Task: using sharp implements at delicatessen counters.

Hazard: staff use sharp knives and other implements, such as fish descalers, to prepare and serve food to customers. Lack of attention or distraction can lead an employee to slip while using the knife, which could easily result in a cut needing stitches. Hazard is graded as medium.

Likelihood: employees are trained in the safe use of knives during induction. Local managers supervise new employees closely for two weeks to ensure they are complying fully with the requirements of procedures. The area is well lit. As far as is reasonable we manage staffing on these counters to reduce customers waiting and the pressure for employees to be so quick that they make mistakes. Trays are provided for storing dirty knives which are then transferred directly to the dishwasher. Although we carry out between 500 and 1000 knife actions a day, we only average one incident every three months. Likelihood is graded as a low.

NB: the grading of hazard and likelihood and the calculation of risk level depends on the scales used by the organisation.

Duncan Spencer is head of health and safety at Waitrose.

Categories:
Management skills, Risk assessment, Risk assessment, Accident reduction, Article, Accident reduction