Work Health and Safety Regulation Impact Statement could do better

[Originally submitted as a comment to a “safety costs” article]

I’ve spent a coupla hours dipping into what looked to me like the important bits of the WHS reg RIS, and I gotta say it don’t add up. I’d also say that the RIS does, in general terms, do what it should do, in terms of making the reasoning processes it uses relatively clear. The merit of the conclusions is up for debate of course, but at least the RIS seems to have made a fair fist of explaining how the conclusions were reached.

For mine there are 2 key flaws.

1. The options to the proposed reg (chapter 4 pg. 19) are just not sufficient. I don’t think it’s at all reasonable to provide 2 “options” which are: do nothing or make the regs. Roger, it might be reasonable to conclude that a big public consultation exercise has happened with the WHS Act, so why revisit a lot of other options? But the fact is the COAG RIS guidelines say a “range of options” should be included, and it’s common practice in RISs to at least have a few genuine alternatives to consider. (See link to the guidelines: ).

The agreement (as it is) by jurisdictions to put the WHS Act into operation doesn’t come with an all-or-nothing conclusion that the WHS regulations is the only option. We have to acknowledge that when it comes to Regulations, we are getting down to tin-tacks when it comes to statutory obligations; it’s that thing about Regulations “giving practical effect to an Act.” That means a big effort is needed to get it right as far as options go. Continue reading “Work Health and Safety Regulation Impact Statement could do better”

Religious wisdom on workplace safety

It is rare to visit the Bible when thinking about occupational health and safety but this week Australia’s Uniting Church, its Creative Ministries Network and the United Voices trade union released a report on the working condition of shopping centre cleaners.  In the report “Cutting Corners” there are many references to the Bible’s and the Church’s thoughts and actions on labour issues.

For instance, according to the report:

“…God is ‘against those who oppress the hired workers in their wages, the widow and the orphan’ (Malachi 3:5).”

and

“…the Prophet Muhammad underlined the importance of the just wage by saying, ‘give the employee his wages before his sweat has had time to dry’.”

The Uniting Church has strong arguments to justify its involvement in social equity matters.

“Cutting Corners” was a broad report based on hundreds of telephone interviews with cleaners.  The major safety-related findings of the survey were:

“The key violations borne by shopping centre cleaners constitute a litany of injustices, from low rates of pay, pay that is not commensurate with their Continue reading “Religious wisdom on workplace safety”

Safety costs of harmonised laws revealed

The Regulatory Impact Statement (RIS) on Australia’s Work Health and Safety laws has been released and will be available through the Safe Work Australia website shortly (probably today given the media attention).  Much attention will be given to the cost estimates of the laws’ introduction but the 336-page RIS seen by SafetyAtWorkBlog  emphasises in the Executive Summary that

“While monetary values of impacts are estimated and an appropriate sensitivity analysis is undertaken, these results should be treated with some caution given the uncertainties associated with estimating changes in work health and safety benefits. Greater weight should be given to the general direction that the estimates suggest is the likely outcome from these reforms.”

This important point is likely to be lost in some of the expected argy-bargy over economic impacts and cost v benefit.

The core figures provided in the RIS are:

“While there will be one‐off implementation costs, the quantitative analysis undertaken at the national level for adopting the model WHS Regulations indicates net benefits (i.e. after implementation costs) of around $250 million per annum to the Australian economy over each of the next 10 years. This estimate does not include expected productivity benefits. While noting the difficulties Continue reading “Safety costs of harmonised laws revealed”

Is the trickling down of safety information sufficient?

A recent article in the Journal of Health Safety Research & Practice (JHSRP) quoted the findings of some research into construction and safe design by the National Institute of Occupational Safety and Health (NIOSH).  One of the NIOSH recommendations listed was that “… the trickle-down concept is appealing.”  The “trickle-down concept” may be appealing in many areas of policy, practice and the advocacy of leadership but its effectiveness is questionable.

It has become a mantra of some areas of the safety professional that safety can only be improved when introduced from the top.  A whole sector of safety leadership sellers has been created on this belief and an important element of the salesmanship is that good safety practices will trickle-down.  This sounds logical but it is necessary to analyse this concept, a concept that originated well outside of safety management.

Trickle-down has been described as a marketing concept, which seems based, partly, on envy.  Wikipedia says that, when applied to fashion,

“…this theory states that when the lowest social class, or simply a perceived lower social class, adopts the fashion, it is no longer desirable to the leaders in the highest social class.”

If this can be applied to safety leadership, it may be that by the time the leadership values reach the shopfloor workers, the leadership advocates, the executives, may be no longer interested.  The transience of trickle-down should be considered when leadership is applied.  How can safety change be sustained through leadership?  What can keep leadership fresh and relevant? Continue reading “Is the trickling down of safety information sufficient?”

Professor Niki Ellis speaks about OHS, CSR and resilience

Next week the National Comcare Conference is held in Melbourne Australia.  One of the keynote speakers at the conference is Professor Niki Ellis, a prominent Australian OHS researchers and consultant  who is also heading up the Institute for Safety, Compensation and Recovery Research (ISCRR).

On a sunny September 5 2011 I was able to spend half and hour with Niki at a noisy cafe outside Victoria’s State Library talking about:

  • The profile of OHS is Australia as a profession
  • The importance of a practical application for OHS research (what Niki refers to as “interventionist research”)
  • The need for innovation in tertiary institutions
  • The legacy of Dame Carol Black’s UK report “Working for a Healthier Tomorrow
  • The challenge for OHS professionals to cope  with emerging psychosocial hazards
  • The role and importance of Corporate Social Responsibility to workplace health and safety
  • The deficiencies of applying resilience to workplace mental health issues

Kevin Jones

OHS will eventually need to address the big climate change impacts

The latest edition of the Journal of Occupational Medicine (JOM) (Vol 61. No 5 Aug 2011) includes a short article on the occupational impact of climate change, an issue that must be addressed in the work context and one that places additional challenges for those involved with safe design.

The JOM article lists the following hazard categories that are likely to affect workplaces and activities:

  • “Increased ambient temperature (global warming) and resultant climate changes,
  • Increased air pollution (resulting from increased temperatures, ozone levels and airborne particles),
  • Ultraviolet (UV) radiation,
  • Extremes of weather (resulting from global climate change),
  • Vector-borne diseases and expanded habitat,
  • Industrial transitions and emerging technologies,
  • Changes to built environment.”

It is unlikely that employers will try to tackle climate change through OHS considerations as there are far more important economic pressures.  OHS, in this context, can only be reactive but several of the issues mentioned above are likely to substantially change work methods and planning. Continue reading “OHS will eventually need to address the big climate change impacts”

Where is the evidence for the safety benefits of high visibility clothing?

Recently a local council in Australia suggested that bicycle riders should be required to wear high visibility jackets.  Bicycle Victoria was not impressed:

Bicycle Victoria spokesman Garry Brennan slammed the idea.

“Unfortunately there is no evidence that so-called ‘high-visibility clothing’ is of any benefit to bike riders,” Mr Brennan said. “Whether the rider is dressed in bright fluoro or black, or is stark naked, matters little when drivers are not paying attention.  The good news is that as more bikes crowd the roads, most drivers are paying more attention.”

In another article Brennan said

“It’s redundant and potentially misleading,” Mr Brennan … said.  He said high-visibility clothing would give cyclists a false sense of security.  “All it does is make you feel more visible,” he said.”

High visibility clothing is an established element of personal protective clothing on construction sites and in the transport industry.  It was introduced as a way of increasing the visibility of workers where traffic on- and off-site interacts with pedestrians.  A UK article by BrightKidz summarises the logic on high visibility clothing but is there any evidence that bright clothing reduces serious contact between pedestrians and traffic? Continue reading “Where is the evidence for the safety benefits of high visibility clothing?”

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