The Institution of Occupational Safety and Health (IOSH) conduct and commission regular research, and the latest piece caught my eye as it’s on rule-setting.
To save you ploughing through it, here’s a summary in my own words:
Why have Rules?
Rules – documented or not – are necessary and inevitable where behaviour has to be controlled. Managers are accountable for delivering systems and results that are consistent, while employees in turn need to know what is expected and can use rules to create approved habits.
However, experienced managers will know that creating a rule is only the start. There can be many reasons why rules are simply not followed e.g. complexity, obselescence, lack of practicability, lack of flexibility, lack of motivation to change, lack of supervision and enforcement, old habits, cultural factors etc. These are all additional to the honest mistakes, slips and lapses we are all prone to making!
So other ways of controlling behaviour should also be considered as sometimes they can be more effective e.g. improving work or equipment design to negate the need for a rule (i.e. intrinsic safety), increasing employee competence, use of positive feedback for behaviour you want more of etc.
In Health & Safety, rules should be easy to relate to the risk. If there are complications to this ‘rule’ then they should also be explained, otherwise the reputation of the rule gets off to a bad start. For example, construction workers often operate under a rule to always wear certain gear such as hard hats, even in the absence of risk as it’s simpler for the whole site and negates the need to check each time against the risks present. So what starts off as ‘we don’t want bricks hitting our workers heads’ becomes, additionally, ‘and as hard hats are easy to wear, we don’t want to tempt fate (or debate) by having a complex ‘Hats On for situations A,B,C; but Hats Off for situation X,Y,Z’ rules.
Types of Rule
Rules can be produced by a regulator, an employer, or by rule-users themselves depending on the level of empowerment set.
Good rule management combines elements of ‘top-down’ rule-setting with ‘bottom-up’ rule-development to suit the circumstances. However, ‘bottom-up’ rule-setting is a useful starting point i.e. assume that the operator is capable of making their own action rules, unless there is evidence to the contrary.
Frontline staff are the experts in rule-use. If you involve them in making judgements on rules concerning safe behaviour then they’ll not only adopt them more readily, they’ll also cope better when something new comes up.
However, managers still needs to define, influence, monitor and manage rule-setting (i.e. not totally ‘hands-off’) so that it doesn’t stray into unsafe behaviour.
There’s normally more than one way to carry out a task safely. If you’re over-prescriptive or hyper risk-averse in setting rules, then it’s likely they’ll be broken. Instead, it’s better to outline the boundaries of safe behaviour so that staff can make reasonable adjustments to real-life conditions.
The more competent the workforce, the less prescriptive the rules have to be and instead they can be phrased as guidance.
Try not to over-react if you discover rule-breaking. The intelligent thing to do is to investigate the reasons behind this so that everyone learns from it (after all, it may be a silly rule).
Where different organisations are working together, the rules need to be integrated. This takes a lot of effort and people have to be prepared to compromise.
Where teams need to work together (or in the same place), co-ordination has to take place at a higher level than just the ‘coal-face’ so that each set of workers, and the managers directing the work, knows what the other is doing.
Safety rules are just one type of rule. If you can integrate safety rules with other types you’ll have less rules overall.
Monitoring & Review
To make sure rules stay relevant, managers have to monitor whether they’re being followed and adjust them where needed so that they’re known, understood and followed.
Rules easily become outdated, so setting a strict review time can help.
Auditors will use a differently-worded set of rules to test the strength of the Safety Management System those they are auditing, but both sets need to be synchronized to stay effective.
…Phew! …now where’s my hard hat?