Terry Reis has written a terrific article about how occupational health and safety (OHS) requirements can impede his work as a fauna ecologist. Instead of whingeing about green or red tape, Terry has provided examples of the annoyance which allows me to build an article in response. This article is in no way a rebuttal as I agree with most of Terry’s grievances, but there can be reasons behind some of the grievances that are likely to be unrelated to OHS or illustrate poor OHS decisions.
Some of the issues Terry raises include:
- Working Alone
- OHS arguments
- Drug and Alcohol Testing
Terry mentions the irrelevance of many OHS inductions and his article seems to indicate a dysfunctional induction program. The intention of inductions is to outline the safety rules of a workplace or task but most are boring, condescending or include information that is unrelated to the task. The reality of many inductions is that they are a mechanism to have workers sign up and indicate they have understood all of their safety obligations on a site so that there is a clearer line of responsibility in the event of an incident.
Rarely are inductions structured or presented in a manner that maximises the retention of safety knowledge in the participant. Rarely are these undertaken by an OHS trainer or an OHS professional qualified in training which results in inductions being little more than reading a set of PowerPoint slides and generating little interaction. I have seen people complete an induction and be allowed to work on site even when they have slept through part of an induction.
However inductions should also not be training sessions. People already know how to do the tasks; that’s what they have been employed for. Inductions should provide the context in which the worker is set to undertake their tasks. In Terry’s case he does not need to know the risks involved in his surveys or how to do the work, only the corporate context in which to do the work. And this context should be brief and informative.
When done well, inductions are seen as valuable but mostly participants see them as a waste of time and an unnecessary delay between arriving at work and starting work.
Personal Protective Equipment
I agree that the level of personal protective equipment (PPE) required for Terry’s task seems absurd. It is absurd because it seems unrelated to the risks that he is likely to face. Much unnecessary PPE comes from the “blanket” policies that companies apply across their entire operations. Reasons for this approach can be the need to apply the same safety performance measurements across an enterprise. Anomalies are bound to occur when an enterprise is a conglomerate of diverse workplaces and is only likely to be solved when the conglomerate’s executives understand that some performance measurements are inappropriate.
Such anomalies do not only occur in large organisations. One construction site I have worked on had a mandatory policy on hard hats. This sort of requirement is common but the roofers were not complying with the site rule. Instead there was a nest of had hats on the scaffold access to the external roof. When asked, the roofers said there was no need for hard hats in their role as there were no overhead hazards. They were right about the absence of hazards so an exemption was made for the roofers but the PPE rule was policed strongly as soon as they exited by the scaffold. Terry is in a strong position to argue against the need for a hard hat on his surveys by asking the OHS people and supervisors to explain what is the actual hazard the hard hat is expected to control.
This also indicates a major failure of the OHS people Terry has met. Much of Terry’s exasperation comes from the seeming nonsense of protection from hazards that do not exist or that are very low risk. Not only should nonsense be questioned, as mentioned above, but it should also be explained and this is likely to reveal the nonsense to all involved.
There is an obligation on all Australian employers to consult with workers on OHS matters. This has never been about communicating rules or the sticking up of posters but about explaining hazards, asking questions, listening to answers and arriving at safety solutions that are okay with the company, agreed with by the workers and that achieve the hazard control aims. Terry’s OHS people seem to have failed in consultation.
Any profession will have disputes between professionals but a company’s approach to safety needs to be consistent and agreed to by all. This can only be achieved after appropriate consultation. If there are matters of dispute, there are avenues to resolve that OHS dispute constructively. In front of workers on whom OHS has been “imposed” is not a good look.
Much has been said about the need for risk-based decision making but this also needs to be balanced with evidence-based decision making. The two types of decisions are definitely not the same. The former is based on estimates and potential outcomes, the latter on reality and proven hazards. Terry’s article shows a preference for the latter and the conflict and confusion that comes when OHS is ruled by the former.
I have written before about the lack of attention given to the potential hazards of working alone. In most circumstances, working with another person is the best control measure against injuries, illness and isolation (as long as they are not a serial killer) but Terry identifies duplicated and overlapping control measures. Clearly the assessment of risks and hazards has been undertaken in isolation and, again, without consulting the person undertaking the work or the task being done. EPIRB, UHF Radio and a work colleague could all be adequate controls on their own.
Terry also points out that he may not have been as isolated as a map may indicate or us city dwellers think. Being close to a major road, even in the Australian outback, may reduce the geographical isolation or provide sufficient access to help. The work environment must be considered in determining the degree of isolation.
Drug and Alcohol Testing
I am in favour of random drug and alcohol as a control measure for identifying people who may be a hazard to themselves and others at work but, as Terry points out, the context in which this hazard identification is applied is important. Terry is at most risk in the field, so such testing should be conducted in the field. I think the drug and alcohol testing experience mentioned here is another example of a company needing to fulfill a safety performance measurement rather than applying an effective hazard control measure.
It is hard to understand the need for an excavation or working at heights permit for the tasks identified by Terry, other than the corporate need for consistency across a variety of work sites. In an urban environment such permits are standard practice and for good reason but these are hard to justify outside of urban areas.
Other parts of Terry’s article reinforce that safety rules have been developed without adequate consultation and without considering the environment in which the work is to be conducted. In short Terry’s article shows an approach to OHS that is impractical and this impracticality can lead to discipline over non-compliance with safety rules that are absurd when analysed. All of this leads to a devaluation of OHS and valid perceptions of red tape and the nanny-state.
Too much OHS policy and procedure is created without a genuine understanding of the workplace, the work being undertaken and the knowledge and experience of the workers. Terry’s article is unlikely to have been written if OHS was understood by the companies he has worked for. This lack of understanding can result from inexperienced OHS professionals, too much influence being given to risk management, and a lack of consultation which includes a lack of voice from workers and a lack of effective listening from managers.
“The government wants to reduce ‘green tape’ to speed up the decision-making process on development projects. They should at the same time encourage companies to abandon this nanny-state approach to field work, to free us from the OH&S tape that prevents us from properly surveying fauna and flora, and which increases costs to industry when OH&S staff spend their days trailing ecologists in the field….”
To achieve this government needs to educate the community about workplace safety and not simply about compliance with the laws. It needs a mature approach to OHS that acknowledges the mishandling and misinterpretation of OHS by companies and OHS professionals over many years. It also needs to acknowledge that many workers already work safely and that they have learnt to do so through experience and the sharing of wisdom by mentors.
Thankfully Terry wrote his OHS perspective down. He began the process of discussion. Too few people do this and without people talking about their frustrations and the ridiculousness of OHS, the ridiculousness continues and becomes an unnecessary political debate.