Col Finnie has provided the following article in response to OHS compliance checklists:
It’s gotta be time to bite-the-bullet. The wish-fulfilment approach – that people will apply some sort of system to how they look after safety because that’s the only sensible way to do it – well, that’s not working, particularly it seems, in the small business area.
Time to regulate for the obligation to have something that can, at very least, lay the foundation for a comprehensive systematic approach. Seems just a bit whacked to me that a demonstrable systematic approach is required once a worker is injured (with the return-to-work obligations) and yet there is nuthin’ for the prevention stuff.
Getting a slapping from a magistrate for having no safe work procedures (as one part of a systematic approach) would work as an incentive if people were busted as often as they are for road traffic naughtiness; but we know that frequency of OHS busts are just not going to happen.
The Great Leap Forward (Into The Bleeding Obvious) would have to be regulated in a smart way. No silliness that infers every workplace will have a full bells and whistles safety management system in say, a year. Instead the reg could do what people often don’t expect laws to do (but laws can do) and that’s be realistic about what can be expected. Yes, describe expectations of what it means to manage safety systematically, but provide scope for a business owner not to be flogged when it’s demonstrable that adequate stuff has been done to deal systematically with risks that can kill and maim and there is evidence that the full SMS is moving in a good direction. Have 12 month (or more) formal compliance Notices where a sensible dialogue goes on between the employer and the Regulator about what can be expected in that period. (It’s just more silliness to equate the time needed to put together a bunch of SMS material with having an SMS that really matters.)
And get unions and employer associations in on the Great Leap Forward (ITBO). They could work as resources with a good feel of what is “real” for their industries: fund them to whack together templates, guides and “how-to” stuff. Each already have a huge pool of expertise to draw on and serve informing realistic, sleeves-up information on managing safety. The tricky bit will obviously be managing funding to minimise the shit-fights that are likely to crop up if funding is seen to be unbalanced. But my guesstimate is that the grief that’s bound to occur every now and then will be countervailed by the high credibility resources that will be available to everyone. I suppose what I’m talking about here is creating a vigorous, high cred “state of knowledge” market that works as a type of knowledge engine for really getting fair dinkum about managing safety systematically.
Clearly the Regulators have to stay in the picture, and that should include making sure the “state of knowledge market” stays on track (in addition to the funding and normal enforcement stuff of course).
A pipe-dream? Well, I suppose it depends on how big we’re game to make our Big Picture.