Serious questions raised over the role of Safe Work Method Statements

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.

Kevin Jones

reservoir, victoria, australia
Categories construction, Duty of Care, economics, guidance, hazards, hierarchy of controls, law, OHS, research, safety, Uncategorized

17 thoughts on “Serious questions raised over the role of Safe Work Method Statements”

  1. Yes, whatever happened to the \’Statement\’ in Safe Work Method STATEMENT. Get rid of the rest of the complicated smoke and mirrors and just stick to: Step 1 … Step 2…. Step 3 ….. The Construction Safety Plan and attached Project Risk Assessment takes care of the rest. K.I.S.S. Ownership comes from understanding and at the moment its all way to complex for the crews to grasp.

    Vote 1 for a national SWMS template and clear set of instructions how it must be completed.

    .

    Gloria where will the construction forum be held?

  2. This is a topic that is close to my heart. 2 years ago I wrote a paper on this topic. On 2nd September i am running the 11th SIA OHS Construction Forum and the topic of this forum is \”SWMS- Are we swmsing or sinking?\” I have a panel of representatives from WorkSafe, CFMEU, FSC, SIA and industry and we will be discussing the current problem. I have been working as an OHS Expert in the construction industry for many years and have witnessed the demise of the JSA and Work Method Statement and the introduction of SWMS which have had a detrimental impact on health and safety management standards, understanding and motivation in the construction industry. The problem must be addressed in order to improve on health and safety management in construction.

    1. Gloria, great to hear from you. Please email me any booking details of the September 2 meeting. Last year\’s event was excellent.

      The experience of many of the delegates at the Canberra conference would support your position that the mishandling of SWMS has had a \”detrimental impact on health and safety management standards, understanding and motivation in the construction industry\”.

  3. Big problem when there is no reference by the FSC to the style of SWMS considered \”on the money\” by the OHS/WHS regulators. The notion of allocating a risk rating particularly seems to threaten practical development of an SWMS. I\’ve noticed suggestions in some \”off-the-shelf\” SWMS formats and examples of principal contractors criticising a lack of risk ratings. Seems nuts to me.

    An initial risk rating, I\’d suggest, is the particularly curious one. What is that supposed to be evaluating beyond the obvious decision that the nature of the task and its associated risk warrants risk control. More pointedly, what does it contribute to making risk control decisions? An initial risk rating delivers no insights into good risk controls because there is nothing to measure against.

    Or do people who want initial risk ratings assume the initial risk rating is based on what effect an operator\’s existing, standard risk control procedures are likely to have on the identified associated risk? Dunno. Either way it seems like a step that diverts energy away from the critical thing: what is actually going to be done to control the risk?

    Perhaps the dilemma here is the failure to distinguish between a complete risk assessment, vs the summary assessment being documented in a SWMS? Surely the logic of a practical SWMS infers the production of the site-specific assessment is informed by preliminary risk assessments of all of a business\’s work, previously established safe work procedures and good understanding by the author/s of the key skills of hazard id., practical risk assessment and knowledge of the risk controls expected by the law and consistent with the business\’s established safe work procedures? And overlaying all that is we are talking about a document that just has to cut-to-the-chase.

    Or is this thing about wanting risk ratings about giving the SWMS reviewer an easy \”tick and flick\” solution to deciding if the SWMS is any good? If that is the case I\’d suggest that is unacceptable; surely the reviewer must have sufficient skills to know whether nominated risk controls are up to scratch or not?

    For mine, evidence that the SWMS author knows what legislation they are dealing with and what guidance material is informing their decisions, clear identification of the major tasks, obvious capacity to know which of them present a risk and obvious sensible risk controls that you can reasonably expect the workers using the SWMS understand (and are capable of implementing) – well that there is where a SWMS begins and ends; surely all that is enough to do all the good things we\’d expect from a SWMS.

  4. Guys, I am surprised at the content of some of the SWMS at my site. They do not focus on the steps of the work method and focus a whole lot on things like snake bite etc. on the matter of manual handling injuries, risk assessment on repetitive work cannot be done with out the inclusion of exposure. Frequently people are not injured from one even but repetitive actions over hours or many days.

  5. What was not covered in the blog was the comments of the Federal Safety Commissioner (FSC), words to the effect that \” the FSO\’s will only audit what a contractor states it will do in it\’s safety management system and to legislative requiremnts\” What we need now is the FSC to amend their SWMS guidelines that is avaialble on their website. Then contractors need to review their safety mamangement systems to state that SWMS will comply with legislative requirements. Another point that could have and should have been debated with the FSC was his comment that the FSO\’s were not responisble or making SWMS grow into mini manuals, shame the FSC departed and was not available to discuss this matter further.

  6. It is wonderful to know about these insightful debates. I have always respected the writings of Paul Breslin. Good to see he highlighted the hierarchy of controls. Thanks for the continued excellent information.

  7. The truth sometimes hurts…
    – Management see SWMS as an arse covering exercise and will \”knock them up\” just get them out of the way.
    – Workers don\’t want to sit and think about what they actually do.

    SWMS\’s are only ever worthwhile if people give a damn in the first place. That\’s pretty rare in my experience. Let\’s all be honest…

    Then you get the misguided people that think if as long as they have them in place, they have a safe workplace. They\’re good to go! We\’ve all seen them before.

  8. Interesting that a document designed to assist in the systematic review and identification of workplace hazards – especially when completing work in unfamiliar surroundings – could be much maligned and held to ridicule.

    Like everything in OHS the intent is to ensure that workers are kept safe and processes are inherently minimal in risk amongst other aims – but if individuals abuse the process – why do we blame the templates and tools??

    We risk throwing out the baby with the bathwater if we move away from the SWMS process. Here is a genuine chance to OHS professionals everywhere to review their SWMS documentation not only for compliance but whether there is ownership by the people doing the work as well.

    To me all commentators seem to be saying the process has been gutted and SWMS are now just admin requirements for compliance – what a waste of a great process and how sad that companies and individuals don\’t consider these documents to be an important frontline defence against inherent ignorance in the tasks being completed.

  9. Fergus Robinson posted the following comment earlier today, elsewhere on SafetyAtWorkBlog:

    Regarding the Building Safety Conference and Paul Breslin\’ s commentary on safe work method statements (SWMS) –

    Paul is correct. SWMS have become too complicated and onerous. Some of the templates require a residual risk column and then a re-assessment of the risk. Often the risk assessment table on the templates underestimates risks because they do not take exposure into account.

    SWMS statement suffer from the following.

    They often fail to provide a sequential break down on how a task is to be performed. They appear as risk assessments.

    They often have too much extraneous detail. One \’cannot see the wood for the trees\’. The major traumatic hazards are lost among details about training, manual handling and so on.

    In many case they are not site specific. They are churned out to meet formal OHS documentation requirements.

    Often they lack specific detail on how a particular control measure is to be applied. Typically, in relation to falls from height, the word \’safety harness\’ will be used instead of actually describing the totality of the individual fall protection system.

    They are not properly reviewed for relevance and adequacy.

    What is ultimately important is not the paper work but the actual doing of the task safely. This requires supervision, commitment to safety and knowledge. Site supervision can get bogged down in paperwork in the site office when they are really needed out there, watching and controlling what is actually occurring on site.

    1. Hi Kevin (and yes – acknowledging I am coming to this conversation really, really late). I have begun some informal research into SWMS’, which has drawn me – again – to your (excellent) blog.

      I have been professionally involved in the safety space for close to two decades engaged, primarily, on construction projects. Over that period of time I have critically reviewed 100’s of documents purporting to be a SWMS (or any other number of similarly acronymised documents that represent safety assessment: e.g. JHA, TSA, JSEA, etc). Some have been brilliant, while some have been the polar opposite. Some have obviously been cut-‘n-paste from earlier work, with little obvious effort to tailor the document to the specific work it is designed to cater for. So I reckon I am like most other safety professionals who enjoy your blog: we’ve seen good, bad and downright ugly SWMS’.

      Bumping into Fergus’s comment, which look to be responding to Paul Breslin’s commentary on SWMS, I felt I’d throw in my two-pennies worth.

      Are SWMS too complicated and onerous? I believe that a poorly constructed and managed SMWS could be, but that outcome speaks more to the process underpinning how the SWMS was constructed, than the SWMS itself. Manage the process, enjoy the outcome.

      Fergus spoke of the use of inherent and residual risk columns. I appreciate how one could conclude they clutter a document. But, in my experience if risk analysis is applied – as best it can be – to determine risks, then presenting inherent adjacent to residual risks provides a simple visual means of expressing how we believe we can deal with the risk(s) of doing ‘something’. If our residual risk column suggests we can achieve a goal more safely – i.e. with reduced risk – we’re heading in the right direction.

      I 100% agree with Fergus that SWMS can fail to provide a sequential work/process flow, or can (sometimes) provide too much extraneous detail. But again, I feel those outcomes speak of the process underpinning the construction of the SWMS, rather than the SWMS itself. Manage the process, enjoy the outcome.

      If I am presented with a SWMS with content that goes something like ‘Wear a safety harness’ as the sole expression of how an entity proposes to manage a legitimate fall-from-height exposure, that provides cause for that SWMS to be rejected. Seriously… the only solution people could think of to manage work being planned aloft is to ask employees to don a safety harness??? I accept that wearing fall-arrest equipment may provide a slice of the overall package designed to protect folks working at height, but what are the other pieces of that pie?

      A poor SWMS reflects poor application. Don’t accept poor product. If the SWMS is out of sequence; or something like ‘Wear a harness’ is tabled as the sole method an entity proposes to manage work at-height; if the document you are being asked to review shows the hall-marks of being little more than a Ctrl+C, Ctrl+V outcome (etc)… hand it back to the SWMS’ author.

      As Fergus said, what is of critical importance is doing things safely. IMHO a carefully considered, relevant and constructed SWMS will provide an excellent foundation for that outcome.

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.