The need for a safety philosopher

It is very hard to be an OHS professional and not feel like one is part of the “nanny state” approach to personal choice.  There is a fundamental disconnection between the responsibilities on business for a safe workplace and the responsibilities on an individual to make themselves safe at work.

When the work processes are seen as mechanistic, where workers are part of that process, safety management is easier.  Hazards are known because the work process and environment are fixed and have no variation.  The employer’s area of responsibility is clear and can be said to be from the engineering/production perspective.

But at different points in history, the spotlight of humanism becomes bright enough that the workers get attention.  Safety management becomes complex because humanity is acknowledged in the work processes; one must consult, talk, listen and engage with the worker who was, previously, an element of the production process.

This is the Manicheism of safety management – the machine or the human.

This rumination occurred in response to an article reported by the Australian Broadcasting Corporation on the union representing Sydney bus drivers “asking the New South Wales Government to pay for personal trainers and Weight Watchers programs.”

The union’s bus secretary, Raul Boanza, says, according to the ABC report,

“the union wants the Government to formalise an existing 50 per cent Weight Watchers subsidy by including the provision in enterprise agreements” and

“it will also seek gym memberships or personal trainers on a case-by-case basis on the advice of a medical specialist.”

Apparently

“the Rail, Tram and Bus Union says drivers must pass strict medical standards every two years to keep their licences”.

SafetyAtWorkBlog contacted the union this afternoon and were advised that the person who raised the issue initially “is making no further comment on the matter.”

This is a shame as one of the first questions would have been, “should an employee be held responsible for making sure they are fit for work?”

Let’s indulge in some late-Friday afternoon silliness.  If a widget in a mechanical process is faulty, it is fixed or replaced.  In a mechanistic perspective, if a worker is too fat to undertake the tasks they have performed previously they should be fixed or replaced.  This seems to match the position of Raul Boanza.

But if the widget had a consciousness and the means and responsibility to maintain their own suitability for work, should that widget be fixed or replaced?  This seems to be what each worker in any workplace needs to regularly ask themselves.

As mentioned above these two differing perspectives reflect our society’s (internal) debate on personal responsibility to one’s self and one’s society.

The leading safety academic in Australia is a sociologist.  Perhaps we are in need of a safety philosopher or at least a safety profession that considers safety in its social and personal contexts, that discusses, debates and progresses, rather than worrying about the latest corporate logo.  Perhaps we just need people to take responsibility for their own actions and be accountable for their own errors.

Kevin Jones

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’”. 

Cutting to the chase- April 2009 revision #2_Page_1And 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.

Pages from externalproviders[1]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.

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

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