Professional standards – Page 17

OHS writing is awful too often

We’ve all done it: slipped into auto-mode when putting together OH&S documentation for a punter. Cut and paste, slam together a whole bunch of references, lots of assumptions that the reader will “get it’”.

And we’ve all probably seen one of those sets of OH&S documents for a safety management system that impresses only by its thickness. Packed with stock phrases that make us OH&S lot feel all comfy, but leave the punter scratching their head over what the hell we are on about and what it is they are actually expected to do.

I plead guilty to having done that occasionally. But it grates on me when I re-read something I’ve done from the past that has all those lazy characteristics that bad OH&S writing can drop into; particularly grating since I’ve becoming increasingly dismayed at the frustration punters have with OH&S and how it seems so impenetrable.

A few years ago I put together a guide on writing OH&S stuff (mostly focussing on guidance material). I’ve altered it a bit to fit all sorts of OH&S writing but it is available for download (and free) by clicking on the image on this post.

Feel free to use it. If you’re going to quote bits from it in your own stuff I just ask that I be acknowledged as the author.

Col Finnie
col@finiohs.com
www.finiohs.com

Being competent is more than just passing the competencies

The SafetyAtWorkBlog article on OHS professional competence has generated some lively debate on a discussion forum of the American Society of Safety Engineers. Jim Leemann makes a fundamental point

“Determining if someone is competent to do a job is totally different from determining if someone has mastered the competencies to do the job”.

This is an important element in the discussion on qualifications versus experience. Often it is the case of the technical qualifications gaining one an audience but experience that keeps the audience listening. Jim expresses it this way

“My empirical research on competencies that distinguish superior performance has revealed that performance is driven more by behavioral competencies than technical competencies. In fact, mastering technical competencies only earns an OHS pro a seat at the decision-maker’s table; it has nothing to do with distinguished superior performance. In fact, technical competencies do not do anything to distinguish superior performance because decision-makers expect OHS pros to have mastered their technical competencies before engaging them in any decision-making processes; hence the reason they have been invited to the decision-making table.”

One engineer expressed views that often come up in discussions in this area – the feeling that experience is less valued than technical qualifications or, in some cases, one’s sphere of influence.

“…I have been in the EH&S field in some form or another for 25 plus years. I believe there is much to be said of the school of hard knocks or on the job learning. Bottom line I would find it very hard at least in North America to have a new regulator show up at my door with text books in hand and try and explian(sic) some of the regulation that I have worked with for years and determine I don’t know my job.“

Jim’s points may be the issues that have underpinned concerns about the Australian processes for establishing a safety profession.

There is nothing uniquely OHS about this dichotomy but because health and safety in Australia has not matured to the extent it has in other countries the conflict is continuing. Australia needs, and deserves, someone to cut through the political and personal agendas to implement much needed reform. A good opportunity could have occurred with the establishment of Safe Work Australia but the heavy reform agenda of the Rudd government means that no department is going to taken on more than they have to.

Kevin Jones

Should OHS regulators be involved in the competence of professionals?

WorkSafe and the Safety Institute of Australia are at the forefront of pushing for a defined level of competence for the safety professional. WorkSafe identified this need many years ago and has been working on establishing alliances with safety professions since then to achieve its aims.

Significantly similar issues have been discussed in the United Kingdom over a similar period however, in that process the WorkSafe equivalent, the Health & Safety Executive (HSE), have chosen not to participate. According to a recent article in HEALTH AND SAFETY AT WORK, the HSE has stated its position

“Speaking at IOSH’s recent conference, HSE chief executive Geoffrey Podger was adamant that the general description of competence in the Management of Health and Safety at Work Regulations 1999 (MHSW) Approved Code of Practice (ACoP) is sufficient. “I don’t think it helps the whole health and safety system if HSE tries to over-define the area,” he said, adding that there is still a “huge opportunity” for the professional bodies to work on their own definition.”

This position is considerably different from that in Australia where WorkSafe is now closely working (some would say too closely) with the SIA in developing standards and protocols that it and its partners want to operate nationally. Its aim seems to be similar to one the HSE and Health & Safety Commission established in 2007 – “Mapping Occupational Safety and Health (OSH) Professional Body Activities in Scotland”. It is worth looking at the page to see the list of safety professional bodies who are listed, the services offered and the membership databases.

A crucial HSE document is the “HSE statement to the external providers of health and safety assistance”. Its statement that competence should be a goal rather than a benchmark should worry the Australian competence lobbyists. In the Ponting article above, IOSH calls for more clarity but, as discussed elsewhere in SafetyAtWorkBlog, OHS legislation clearly states it is the employers’ ultimate responsibility to establish a safe and healthy work environment. They may choose assistance from competent people but why should it be the regulator that establishes this? The professional bodies such as IOSH and SIA have existed for decades. Have they not determined levels of competency for their own members by now?

Geoff Hooke of the British Safety Industry Federation says

“when you ask how you measure competence, the simple answer is: with great difficulty”.

In general, shouldn’t the response from OHS professional associations be along the lines of

“we believe that all members of the XXX Association are competent within their fields and we would not hesitate in recommending our professional members in providing competent advice to companies…”?

These organizations who are calling for a clear definition are often the same organizations that are in support of “as far as is reasonably practicable”, a vague management concept that can be defined and re-defined depending on which judge hears which OHS prosecution. – the antithesis to the prevention principles of OHS. One cannot call for certainty in one area while advocating flexibility in another.

The UK Works and Pensions Committee was right in saying that more control is required on external consultants and clearly lobbed the responsibility on the professional bodies.

Ponting’s article concludes that it is the job of the professional bodies to organize accreditation and the maintenance of that accreditation but acknowledges that it is politically fraught. That is not enough reason to look to the regulator to solve the problem as it only makes the regulator the target of criticism over the process and the results. The professional bodies themselves must work to a commonality of purpose and relinquish years of demarcation and, sometimes, schism.

The Australian safety professions would ultimately gain far more credibility for themselves and their professions if they too took it upon themselves to define accreditation, audit their members’ competencies and assist in the maintenance of skills. In that way Australia may gain a safety profession of which everyone can be proud.

Kevin Jones

A vision for the OHS profession

WorkSafe Victoria is very involved with moves to improve the professionalism of OHS practitioners in Australia. There is no doubt that improvements are required but the role of a state-based regulator in a non-regulatory system is curious. Surely such changes should be run from a national perspective

Safety professionals often look at the prominence, influence and market share of professional organisations for the doctors or the accountants. In Australia, at the moment, the health care profession’s accreditation/registration process is having a new structure introduced. After a long review process the Australian Health Workforce Ministerial Council identified these areas for change

Accreditation standards will be developed by the independent accrediting body or the accreditation committee of the board where an external body has not been assigned the function.
The accrediting body or committee will recommend to the board, in a transparent manner, the courses and training programs it has accredited and that it considers to have met the requirements for registration.
Ministers today agreed there will be both general and specialist registers available for the professions, including medicine and dentistry, where ministers agree that there is to be specialist registration. Practitioners can be on one or both of these registers, depending on whether their specialist qualification has been recognised under the national scheme.

This third point is an excellent one and so easily applied to the safety profession and the practitioners. “Specialist” and “generalist” seems to reflect the composition of the safety industry in Australia. There are those on the shopfloor or offices who deal with hazards on a daily basis. There are those who research and write about safety. And there are those who are a bit of both. The two category system of accreditation seems simple and practical and readily understood by those outside of the profession.

Both categories will attract experts in various fields but the categories themselves don’t relate to specific areas of expertise. The Ministerial Council has agreed that there will be a requirement that, for annual renewal of registration, a registrant must demonstrate that they have participated in a continuing professional development program as approved by their national board.
Assistance will be provided to members of the public who need help to make a complaint.
The Ministerial Council agreed that national boards will be required to register students in the health profession
…boards will be appointed by the Ministerial Council with vacancies to be advertised. At least half, but not more than two thirds, of the members must be practitioners and at least two must be persons appointed as community members.
There will be a new “Australian Health Practitioner Regulation Agency”

These points deal with matters sorely lacking from many areas of the safety profession – independence, transparency, skills maintenance, a clear and independent complaints procedure, diverse representation and a formal regulatory agency.

To this SafetyAtWorkBlog would add the concept of a Safety Industry Ombudsman for it is always necessary to have someone watching the “watchmen”.

Currently the Australian safety profession is part way through a mish-mash of a process of professionalisation. Surely it would be better to follow the most contemporary of processes being implemented by health care and others. Such a process would take some time and require support from the various disciplines of safety and the government. More importantly, it may require “vision” but during this time of substantial change in OHS legislation and regulatory structure, it is surely the right time to bring in long-term structural change to a profession that would benefit business and the public very well indeed.

Kevin Jones

Blue Card training needs a review

Most workers meet OHS training through short courses, perhaps even inductions. Few have the time, the desire of the finances to pursue a tertiary qualification.

Australia has recently achieved a uniformity in its “card system” of OHS training for construction workers. The card concept originated from the Safety Passport used in some European industries and is intended to provide a common set of OHS skills to workers so as to reduce on-site induction time and costs. It is a worthy initiative and has improved safety awareness on work sites however any training program needs to include self-improvement.

(A national OHS induction system should be part of the Australian Government’s response to the recommendations of the model OHS law review panel.)

Current training seems to have reached the point where too much is trying to be done in too little time. Blue Card training can be undertaken in 6 hours and covers over 50 workplace issues!! Yes the training is only for “safety awareness” but 50 issues in around 5 hours is absurd unless the training runs something like

Smoking in the Workplace – DON’T DO IT
Job Safety Analysis – GOT TO HAVE ONE
Fatigue Management – GO TO BED EARLY
Alcohol and Drug – MAKE SURE THE EFFECTS ARE GONE BY MONDAY MORNING
PPE – WEAR WHATEVER THEY GIVE YOU

One would have to ask if this training is really worth it. The main reason the training is offered at all is that it is a mandatory requirement for many worksites and the construction industry. But what good is having a Blue Card if the training is too simple, too generic?

A universal/national level of safety awareness or induction would be ideal but the current system and its implementation leaves a lot to be desired. Let’s hope that reform of this process is on the agenda of the new Safe Work Australia organisation.

Kevin Jones

Below are the components of a Blue Card safety awareness training program currently offered in Australia:

Module 1: OSH – The Law, Your Employer and You

legislation, regulations, codes of practice, guidelines and standards
right to refuse work
responsibility for regulation by WorkSafe
general duties of care – public safety, employee, employer, manufacturers and suppliers
safety and health representatives and safety and health committees
resolution of safety and health issues
workplace policies and procedures
reporting of serious occurrences, injuries and hazards
workers’ compensation

Module 2: Managing Risks in the Workplace

understanding the meaning of hazard and risk
risk assessment/management
control methods for managing risks
job safety analysis worksheets
five steps to complete a JSA
emergency procedures and response plans
emergency situations
emergency response training

Module 3: Staying Safe in the Building and Construction Industry

employee responsibility
effects of shift work
how to manage the effects of shift work
fatigue
your personal alertness
diabetes
obesity
depression
safety management systems
benefits of a safety management system
examples of safety rules – equipment and tool safety
performing high risk work
housekeeping
personal protective equipment
prevention of skin cancer, eye damage and mosquito born viruses
safe manual handling
alcohol and other drugs at the workplace
smoking
alarm systems and emergency exits/escape routes
responding to emergencies
fire equipment
first aid

Module 4: Environment and Other Considerations

the working environment and weather conditions
heat stress
hypothermia
safety signage
tag and lock out isolation procedures
environmental issues and responsibilities
vegetation
native fauna
water pollution
atmospheric pollution
entry into confined spaces
working at heights
safety rules for working on ladders
electrical safety
hazardous substances

Safety In Action Conference

For three days next week, SafetyAtWorkBlog will be reporting from the Safety In Action Conference in Melbourne. This is the 12th annual conference and it remains the dominant OHS conference on the Australian circuit for duration, affordability and credibility.

More information on the conference is available at www.siaconference.com.au. Check out the videos below on this page for an introduction to some of the speakers.

Contact me through my email if you are going to be at the conference and want to meet up.

Kevin Jones

A sport’s culture of excessive alcohol at work functions

Each November safety publications carry guidances and warnings about unacceptable conduct at company Christmas parties. Often these warnings are around moderating alcohol consumption and showing due respect to others. One of the most recent legal advisories was issued in late-2008 by Maria Saraceni of the Australian law firm, Deacons.

This week in Sydney the National Rugby League (NRL) faced its latest controversy when Brett Stewart of the Manly club was charged with sexual assault at a work function. The NRL today issued harsh penalties on both Stewart (five match ban) and the club ($100,000). To understand the context of the penalties and the media hoo-hah surrounding this it would be necessary to look at the many instances of assault and abuse associated with rugby league, and other male-dominated sports, in Australia.

The issue has remained largely on the sports pages of the newspapers except in New South Wales. The fact that a sporting club was involved and a sport with a sad history in this area has dominated reporting and the OHS, safety management and employer liability angle has been lost in the rush.

The NRL media statement (no direct link available), quoted in part by the ABC, shows that the NRL CEO, David Gallop, is well aware of the safety management issues.

“Brett could not have been in a more high profile position of trust for the game on the eve of a season than he was last week and we believe he should have recognized the honour that he was given and the responsibility that went with it,” NRL Chief Executive, Mr David Gallop, said today. “By any estimation there was an abuse of alcohol in the aftermath of a club function that has led in some part to the game being placed under enormous pressure.

“The players and the clubs need to know that we are not going to accept that.

“The Manly club has today delivered its report into the function and the measures simply weren’t sufficient to stop drinking getting out of hand in the case of some of the players. Brett was both refused service of alcohol and asked leave the premises.”

Section 20 (2) of the NRL Code of Conduct which states:

“Every person bound by this Code shall, whether or not he is attending an official function arranged for the NRL, the NRL Competition, the Related Competitions, Representative Matches, the ARL Competitions or a Club, conduct himself at all times in public in a sober, courteous and professional manner.”

Peter Fitzsimmons explains why the general conduct of rugby players needs changing.

“They [rugby league clubs] must fix it because they are a powerful tribe within our community, and that community has had a gutful not just of the atrocities, but of the NRL promising to fix it, to educate them, to discipline them, blah, blah, blah, year after year, with no results.”

Kevin Jones

Category: Professional standards

OHS writing is awful too often

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Being competent is more than just passing the competencies

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Should OHS regulators be involved in the competence of professionals?

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A vision for the OHS profession

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Blue Card training needs a review

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Safety In Action Conference

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A sport’s culture of excessive alcohol at work functions

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