For some time, several countries have had legislation that require Environment Impact Assessments. Why don’t we have Safety Impact Assessments?
Often safety issues are applied retrospectively in project development. Often the application is impeded by actions or pathways that are already in place, although embryonic.
There is evidence that safety performance can be greatly improved by having safety considerations at the very early design stages of projects. Perhaps, rather than simply stating “safety is important”, the commitment to safety be more overtly stated in a formal manner at the project design stage.
It should be possible at each design/review stage to undertake a Safety Impact Assessment (SIA) of the decisions being undertaken.
At each stage, before passing the project draft on, the development team would formally ask themselves (perhaps with the assistance of safety advisors) to outline any safety impacts the decision may have on
- (Environment, perhaps)
The assessment may contain the following questions:
- During the life of this project, in what ways could harm be generated?
- In what ways could such harm be eliminated or minimised (not just reduced slightly)?
- What safety issues could the surrounding community perceive as harmful?
- What safety issues can be expected from the experience of other similar projects, here and abroad?
Initially, the responses will come from the experience and knowledge of the project development participants rather than from a formal research project or literature review.
The content of each SIA will vary at each stage of the project draft as more project detail appears and personnel consider the questions above. The European Union’s approach to environmental impact assessment, the EIA Directive, could be tweaked to apply to safety:
- Description of the project
- Alternatives that have been considered
- Description of the work environment and work tasks
- Description of the significant effects of these on people and the community
- Non-technical summary
- Lack of know-how/technical difficulties
It should only be in the Mitigation stage where risk management concepts would be relevant.
Safety Impact Assessments vs Risk Management
The Safety Impact Assessment should not be absorbed by Risk Management. Risk assessment is limited by the risk management concepts and by the risk minimisation process of insurance. Safety needs to take back ownership of itself and place safety as the core consideration of the assessments. In this way the Hierarchy of Controls and other assessment processes can help provide clues to what is safe and unsafe, what will cause harm and what will not, without the uncertainty created by “as far as reasonably practicable” and other legal and insurance confusions.
In modern safety management people jump too soon to the complexities of the implementation of control measures and as a result we succumb to risk management. In many circumstances safety gets shunted aside because the implementation of a control measure, perhaps, the elimination of a particular risk seems to absurd.
As an example, let’s consider the elimination of the traffic accidents at level crossings. Collisions between cars and trains can be eliminated by grade separations. (Collisions between people and trains are more complex as people usually don’t limit themselves to roads, as cars must). In Australia the grade separation of level crossings was dismissed as too expensive. These costs were determined, principally, by identifying an average cost of a grade separation and applying that to all existing level crossings or, at least, those in metropolitan centres which still proved too expensive. Whatever the economic reality, the safety process of grade separation is sound.
Elsewhere I have argued that applied science is of much more use than pure science but that is not what I am discussing in this post. There is an ideological turf war between safety and risk and insurance and lawyers in which safety is the weakest combatant. In fact, it may be giving it too much credence by calling it a combatant as combatants are not usually on their backs with paws in the air getting their tummies rubbed by its competitors. The safety profession has caved in to other lobbyists and disciplines that have a longer history, stronger institutional connections, a stronger “brand” and a legal legitimacy of their own.
Arguing for the introduction of Safety Impact Assessments and their application in infrastructure projects, government decision-making and corporate planning, could allow safety to regain some of its pride and relevance by standing on the shoulders of the gains made in the environmental sector. The role of environmental assessments in decision-making has been established largely without the interference of risk management which allows for, and sometimes strongly advocates, compensation for things for which no compensation is adequate. There is a core integrity to the environmental assessment process that safety should also possess.
To my knowledge, the concept of a safety impact assessment is a new one but one that has a legitimacy and could provide the base for safety professionals to establish a solid presence not only in safe design but in the project management’s decision-making process.
As identified above risk management has a place in Safety Impact Assessments but should not be allowed to dominate. The safety profession, discipline or whichever category one wants to apply, has been too complacent and has relinquished its decision-making significance. Safety may also have been distracted by alternative approaches that have allowed an easier fit in decision-making. But what this has allowed is for safety to be the poor cousin to risk management and yet it has more of an important social role than other disciplines. What could be more important than the integrity of one’s mental health, the quality of an individual’s life and that of a family’s life?
A Safety Impact Assessment may just make decision-makers reconsider their sidelining of safety for short term economic gain.