Strengthening safety decision-making 5


Any professional sees elements of their profession in other walks of life.  Police notice infringements when they are off duty.  Teachers often continue to instruct or educate when outside of school.  Journalist’s conversations with friends often contain pointed questions.

Safety professionals, commonly, extend safety principles to their own behaviours and lives.  This can sometimes lead to a heightened intolerance of unsafe behaviour in others but also desires that life operated on safety principles.  Today I wondered about the application of the concept of “Reasonably Practicable” in prioritising corporate and personal safety objectives.

I simplified (bastardised, some may say) the Safe Work Australia guideline on reasonably practicable into questions that we should ask in our non-OHS lives but, most importantly, the priority of the reasonable practicable process is retained.  The questions, in order of priority are:

  • How important is it?
  • How harmful could it be?
  • What do we know about it?
  • How can we control it?
  • How much will it cost?

Self-help aficionados may see these as life lessons or criteria that can be applied to many decisions.  I agree to some extent but the priority of the questions is of most importance in the decision-making process because it places the issue of cost last.

Frequently we choose not to do something because we cannot afford it.  This may be the reality but this shuts down creative thought and restricts critical analysis.  Too often the cost factor encroaches on our decisions even when we acknowledge it as the least critical criteria.  It takes a conscious effort to put cost considerations at the end.  This is as relevant in workplace safety considerations as it is anywhere else.

By following the “Jonesian” concept of reasonably practicable, we may come to the decision that a safety initiative is unaffordable but the decision and its rationale are that much stronger for having applied the process.  In workplaces, this may generate a more robust defence when an OHS inspector calls.  In life and work, people may come to a better understanding of a hazard or problem if a process of analysis or assessment has been conducted.

But this may also reduce the likelihood of paying too much attention to inconsequential hazards and issues, a tempting diversion for safety people undertaking hazard inspections of workplaces.  One must determine the importance of an issue to the organisation or project.  Just how essential is the issue to the company’s operation?

Then one considers the consequence of allowing the issue to exist. Doe sit generate harm and how much harm?  This allows us to look at the issue from outside our own perspective, corporate priorities or organisational baggage.

We also need to understand the issue, to research, to investigate.  This is often provided a cursory look and can lead to misunderstandings because information exists but we do not look at the information or, more commonly, we choose not to look too closely at the issue.  It is often easier to rely on half-truths or dominant cultural norms than looking at an uncomfortable issue and learning about it.

From understanding a hazard or issue, we can then think about how to manage the issue and how to control it.  This is likely to require more investigation but from this new perspective of understanding but more often control will generate innovative approaches, if innovation is allowed and encouraged.

Then we come to the cost of management or control.  Frequently this stage leads to the dismissal of an issue or hazard but what reasonably practicable should encourage is not the establishment of a cost figure, a barrier, but the encouragement to investigate ways of covering or reducing that cost.  Rarely is this step undertaken and this illustrates the dominance of cost in our decision-making.

One of the difficulties with “reasonably practicable” comes from Safe Work Australia’s statement that:

“What is ‘reasonably practicable’ is determined objectively.”

Objective assessment provides the bones of a decision but decision making is far more complex than this.  Subjectivity needs to be acknowledged and integrated into safety decisions in order to recognise the human element of safety and management but to also provide a decision that is more acceptable and understandable to our colleagues and workforce.

This Jonesian concept, or broad application, of reasonably practicable may simply be the foolish ruminations of a tired safety professional but rigidity in thinking about safety management needs to be countered, just as much as the dominance of cost in decision-making must.  Too often safety professionals and managers rush to the end and miss the educational process of investigation.  Hazards needs innovative controls but by applying the Jonesian concept we may also gain some organisational and personal enlightenment and add value to our culture.

Kevin Jones

5 comments

  1. Hi Kevin,
    I thnk your analysis and explanation are really well done. Can I offer a couple of points that I believe may enhance it even more?

    – Firstly, I was struck by your reference to our ‘non-OHS life’ in the third paragraph. Surely we need to be encouraging ourselves and those we lead to integrate safety into all of life. I thought that was one of the points of your article after all. Surely a better phrase would have been non-working, or life outside of work? That’s certaily how I see myself in relation to safety. People who know me think I’m in OHS mode all the time. The truth is that OHS is part of who I am. (Note: I do still take calculated risks on occasions).

    – Secondly – I think the last question should be further divided into:
    How much will it cost if I/we do?
    How much might it cost if I/we don’t?
    This may balance the thought of not doing it ‘because I/we can’t afford it’ against ‘maybe I/we can’t afford not to’. That is in reality the motivation behind taking out insurances, and shouldn’t we be insuring ourselves against personal injury?

  2. Les, you are right about the “non-OHS” point but I think we also need to be careful not to apply some of the rigidity of OHS thought to non-work situations and, of course, consultation with family and partners is essential.
    We know that people take shortcuts on safety. I fear that sometimes we take shortcuts on thoughts.

  3. I agree. That’s why I made the note about my personal risk taking.
    I believe that ‘thrill seeking’ enhances social life by adding some excitement. If we wrap oursleves in cotton wool life will become dull and boring, and we’d probably suffocate.
    The difference is in who bears the cost if it goes wrong? I don’t believe employers (PCBUs) should necessarily be held liable for an individual’s risk taking behaviours, so let’s keep work as safe as reasonably practicable and leave thrill seeking to our social lives.
    But thrill seeking still needs a reasonable assessment of the risks and potential outcomes so that it doesn’t become ‘death seeking’.

  4. Hey, nice work Kevin. The “reasonably practicable” concept needs regular review. For years I thought it let cost get in the way of improved OHS, but I have a new slant on it …

    What was once “reasonably practicable” can quickly become obsolete as the state of knowledge grows, as new research is rapidly disseminated and as new control technologies become increasingly common and increasingly cheap.

    For that reason, it is worth regularly revisiting OHS decisions that have been based on what was reasonably practicable at the time the decision was made – particularly if the risks involved and the potential for harm are high – like they often are for, say, Manual Handling.

    It might be time for “reasonably practicable” to be the trigger for reviewing risk controls, as new and better controls become reasonably practicable, rather than being used as an excuse for not making OHS improvements!

  5. “control” is ambiguous. To some it means preventing or eliminating the harm from the workplace.

    For others it means it’s OK to have the harm in the workplace as long as it doesn’t make contact with flesh (this is the PPE approach to minimise consequences.)

    Try:
    How can we prevent it from being in our lives?
    If we can do something to prevent or eliminate it, why haven’t we done it already?
    If cost is an issue, and we can foresee that someone could be hurt, why have we decided that’s it’s OK to have matters arranged in a way that could see someone harmed by our inaction?

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