Any safety conference involving the Australian construction industry will have some discussion on Safe Work Method Statements (SWMS) and this weekend’s Building Safety conference was no different. During the presentation on Saturday by the Federal Safety Commissioners, SWMS was bubbling along underneath many of his words and statements. Sadly, the audience (now) seems to have been too polite to ask him questions about the elephant in the room. There was no such hesitation following the presentation by Brookfield-Multiplex’s Paul Breslin on the Sunday.
Several delegates stated their belief that the Office of the Federal Safety Commissioner (OFSC) is largely to blame for the over-emphasis on SWMS in the construction sector and for the bloating of SWMS into a document that does little to improve safety and is more related to meeting the audit criteria of the OFSC.
As part of the presentation Breslin showed several examples of SWMS templates from around Australia issued by various OHS regulators. He admired the templates that were simple, plain and readily applied but pointed out that none of these would comply with the requirements of the OFSC.
The OHS absurdity of the template preferred by the OFSC requires, amongst other elements, the assessment of risk and allocation of a risk rating. Breslin pointed out that that OFSC acknowledges that the construction industry has already been deemed a high risk workplace already and asked why such a risk assessment approach is needed. In some ways this matter ties in with the de-masculinisation of safety observations discussed by Laplonge at the same conference by removing the freedom of choice of the worker.
Several years ago WorkSafe Victoria caused some concerns by saying that risk assessments are not required for common risks for which well-established control measures already existed. It believed that many risk assessments were unnecessary and complicated the hazard control process. The same logic can be applied to the SWMS requirements of the OFSC.
Breslin and the conference audience are not the only critics of the SWMS requirements of the OFSC but in the Getting Home Safely report, the authors, Lynette Briggs and Mark McCabe pointed out that SWMS are being applied too broadly and dispute the accusation that the OFSC is solely to blame.
Breslin sees the current problems as being:
- There is not one single recognised SWMS template across Australia;
- SWMS are being expanded to levels that are nearly impossible to control or enforce;
- SWMS have been modified to meet the requirements of third parties, such as the OFSC;
- Principal contractors are struggling to know if they are complying.
Breslin’s arguments were persuasive and clearly there needs to be some leadership on a national basis in Australia for change to occurring this dominance and mythology of SWMS. The logic of the argument may not be sufficient a motivation for change but Breslin outlined some research he has undertaken into the costs associated with developing, writing and managing SWMS on around 15 Australian construction projects. He determined that over $7 million had been spent in these projects specifically addressing the obligations for SWMS in their current configuration. Breslin stated that SWMS do not, by themselves, save lives and in fact could increase risks by diverting important OHS resources and supervisors away from monitoring and helping work practices on the construction site.
It was implied that substantial project cost savings could be achieved by a review of the structure, purpose and operation of SWMS on high-risk worksites. However such savings could not be contemplated as long as the existing OHS, political and regulatory status quo continues.
As well as undertaking a cost analysis, his research included a review of all the incidents on the projects to determine the role of the SWMS in those incidents. Of the over 200 incidents SWMS were found to be inadequate in around 30 incidents and around 80 incidents involved breach of the SWMS. The data is significant in itself but of broader interest is the type of data that can be obtained by a targeted review of incident investigations. Such an activity should be undertaken on other large construction projects.
Breslin also asked why so much attention is being given to SWMS which are, fundamentally, an administrative control on the Hierarchy of Controls, a level control that others have categorised as an “active” control requiring human intervention to be effective.
It was said at Building Safety that the issue of SWMS could justify a conference of its own but such a conference would likely be little more than a whinge-fest if none of the OHS regulators show leadership on reassessing the need, role and application of Safe Work Method Statements in the Australian construction industry.