What do I mean by ‘Confetti Health and Safety (‘H&S’)?
It seems to me that there are certain words and phrases that are just thrown about by people who have little experience of what they mean, or the real-world implications of what they’re suggesting.
People are very used to the idea of owing a ‘Duty of Care’, but for most non-legally trained people the limits of such a duty are a complete mystery. All they know is that something is owed to them, or their loved ones, and someone let them down.
It reminds me of a Charlie Brown cartoon featuring the ‘Lucy’ character saying: ‘When you’re down and out, lift up your head and shout: Somebody’s Going To Pay For This!’
In a similar way to ‘Duty of Care’, ‘carry out a Risk Assessment’ is thrown about like confetti whenever a fault or risk is found to exist – either in an at-work situation, or in society in general.
There’s often very little thought into what such a document or process would look like.
Examples of potentially complex risk assessments could be assessing:
- Assessing the transfer of a one-to-one counselling meeting to an online provision due to COVID
- Employee stress – especially differentiating work-related from other, personal, causes
- The provision of social services protections
- Releasing of certain prisoners back into society
- Involving volunteers in a maintenance or renovation project
- Arranging outdoor adventure trips
- Continuing to provide a vital service during times of low staff provision during the pandemic
It’s easy to say ‘You should have done this or that’ with the benefit of hindsight – so much so that it is a known phenomenon of human nature (hindsight bias).
Much more difficult is to say, ‘And this is what it should look like as I’ve been through the process myself’.
What are people actually expecting when they ask for a risk assessment?
Well, something that – if produced beforehand – would have prevented the accident from happening.
Clearly, people who think that just haven’t seen many risk assessments!
‘Show me your risk assessment’ can actually mean:
- I’ll show that you didn’t comply with it yourselves OR
- I’ll demonstrate my hindsight bias by showing how it didn’t cover every eventuality
So, in other words ‘show me your risk assessments’ after an accident has happened can be the handy hook on which to invisibly hang your hindsight bias. Probably this is invisible a lot of the time to the individuals themselves.
Then, once the fault in the risk assessment had been established, campaigners often focus all their attention on the specific missing risk controls that may never arise again.
A more effective strategy might be to focus on improving risk assessment practices all round.
Endless Support…Always Available
Linked to these tasks is another ‘confetti’ phrase: the use of the word ‘Support’. Normally directed at time-poor employers who should always make sure that their staff are supported in everything they have to do.
Training, in particular, can be particularly tricky for employers to organise. What courses are expected or recommended? Are e-learning courses good enough? What H&S knowledge should managers have? How should skills training be recorded for new trainees?
A very common issue for H&S Consultants – which I’ve certainly been guilty of – is outlining H&S duties and saying that managers should ‘Ensure that this happens’ without thinking about exactly how a manager could do that, and what ‘support’ they themselves would need.
We’re all guilty…but some more so
We’re all prone to falling into using ‘hindsight bias’ and throwing around duties like confetti without thinking first: ‘Well, how would that be done…in the real world?’
It takes a good deal of experience to recognise these traps and know enough about what the limits of duties actually are, plus be able to give genuine duty-holders options or resources to help.
This is why I find it endlessly disappointing to see reports of H&S prosecutions which invariably are concluded by an HSE inspector saying how obvious it all was that it was going to happen. Sometimes, they’re right and the managers appear to have been grossly negligent.
However, with cash-strapped inspectors focussing on only very high-risk inspections and taking prosecutions you can’t help but wonder if more help and less platitudes would be a better strategy.
Needless to say, there’s always hope that things can improve.
Our approach has always been to try to encourage the ‘continual improvement’ philosophy (so often quoted in H&S standards) in our Clients as well as for this H&S Consultancy.
As the ancient Italian bricklayer might have said: ‘Rome wasn’t built in a day…but we are building Rome’.