HSE Strategy 2016…more waffle, anyone?

HSE have recently released their latest strategy – Helping Great Britain work well 2016

There were several main titles and images I could have used for this blog. For a while I was tinkering with images of deflated balloons, and before that, a nice sign I found saying ‘Warning – Complacency’, but in the end the waffle had to win. And after reading the document over several times, I started wondering if anyone had ever expired after taking in too much waffle…

Of course, when you start reading any strategy document, you’re not expecting a high degree of specificity, but I think it is reasonable to expect to feel a little bit inspired…maybe energized?…re-focussed?…confident in the direction your profession is taking? But my first reaction was one of frustration to be reading through a document full of such ‘sunshine’ statements as:

‘The new strategy is built on a basic premise – by acting together in a supportive and encouraging environment, complemented by effective and proportionate regulation and risk management, the system can be greater than the sum of its parts’

And

‘The result will be greater and wider ownership of the issues, with businesses able to enjoy the improved productivity that a strong health and safety culture will generate, while workers will be healthier and safer’

For such a short document, the writers have managed to cram in so much padding they might have been preparing for a game of American Football.

However, to ‘cut to the chase’, the strategy basically comes down to 3 short pages, half of which are uninspiring ‘Case Studies’ – these seem to be all the rage these days when you’ve got some space to fill, and the beauty is that the study doesn’t even have to demonstrate anything concrete…people just love stories with happy endings. I didn’t find the case studies at all convincing, often being based in higher-risk areas that should already be being targeted or managed, thereby failing to demonstrate an example of a new direction.

Here are a few comments on the 6 themed sections:

Acting together

The key bit here is ‘Everyone collaborating to reach those who may have been less engaged’. Who wouldn’t agree to us all working together? Those that have been less-engaged have been waiting long enough! Apparently, reading the case study, there’s been people in the high risk electricity network business who can’t be bothered to try reduce fatal and major accidents – and they have employee representation from no fewer than 4 trade unions. It’s not exactly clear how the HSE is going to influence things to get ‘everyone collaborating’ in the multitude of lower risk businesses that have slightly less pressing risks and absolutely no organised worker representation.

Tackling ill health

The document wants us all to ‘Seize the opportunity to give health the same priority’ (as safety)

Again, the case-study focuses on a high-risk example which is well-known and should already be happening.

Trying to switch more attention to the ‘Cinderella subject’ of long-term ill-health is an idea that has been around for a long time, but as we all know human nature is such as to discount long-term future effects – especially in younger people. In SMEs young employees are still not getting the message re: wearing PPE and protecting themselves, and too many employers don’t take the time to find out why and work on encouraging willing compliance in their workforce. The HSE suggests ‘coordinated action across all sectors, bringing in additional partners such as the NHS’ – is this the same NHS which is struggling with budgets and keeping basic medical services going?

Managing risk well

For the first time in the document, health and safety professionals get a mention as a resource…yay! It looks like HSE is finally realising that some of us are not just petty pen pushers and actually promote sensible, proportionate risk management. OK, it’s hard to argue against the sentiment that we should be aiming to manage risk well, so I’m half on board already.

Of course, the business case for health and safety has already been repeatedly made – and some businesses don’t find it as ‘compelling’ as HSE suggests, but in the absence of much of a ‘stick’ in the shape of enforcement these days, I’m left wondering if this donkey has the motivation to move close enough to see the ‘carrot’. As expected, the case study against ‘Managing risk well’ is not impressive – basically a good way of training apprentices, but a very tenuous link to the text in the main ‘strategy’ part.

Supporting small employers

Yet again, HSE is banging the drum for ‘quick and easy’ health and safety for SMEs. They’ve been promoting this for years, so one has to question whether their previous strategy is working.

As I’ve written in previous blogs, for many people ‘quick and easy’ means ‘cut and paste’ – regardless of the truthfulness of the pasted text.

And HSE’s record of simplifying things for SMEs (e.g. in their ‘example risk assessments’) repeatedly fall foul of the maxim attributable to Albert Einstein:

EVERYTHING SHOULD BE MADE AS SIMPLE AS POSSIBLE, BUT NOT SIMPLER

SME’s generally don’t find the time to read HSEs caveats or background notes and so can often produce something sub-standard, normally missing the point of the whole exercise i.e. an examination of risk and controls.

The impression for many is still that the paperwork of itself is the important thing, not the connection between the writing and actions or intentions. “Yes, we’ve got H&S – look here’s the folder”.

The case study here implicitly calls on other services to help e.g. it mentions, amongst others, fire services being involved in offering free support – would this be the same services that have been cut-back and were doing that anyway pre-recession? So now, offering a temporary reinstatement of a service previously withdrawn through budget-cuts is re-presented as an ‘initiative’.

‘Keeping pace with change’ and ‘Sharing our success’

These two strategic aims are full of things already being done, very complacent, and full of waffle such as:

To remain a world leader is risk management, Great Britain needs to develop high-quality capability, anticipating the workplace challenges of tomorrow and using the flexibility of our goal-setting approach to solve them in ways that enable innovation and the use of new technologies’

Overall

The strategy alternates between being complacent – basically saying ‘we’ve solved it’ and non-specific ‘let’s all pull together’ nonsense.

The feeling here is that HSE strategists have been seduced by the H&S successes of big businesses who have got themselves well organised, generally having larger resources, internal professionals, and bigger reputations to protect. To my mind, the case studies presented show that applying the right amount of time, investment, thinking things through etc. in proportion to the risk level WORKS. There is no longer a question of whether it’s wasted effort to organise for health and safety.

In the SME market, the question is ‘how to encourage SMEs to put in the effort needed to organise for H&S. It’s only by actively applying brain power that one can figure this out…so how to convince SMEs to apply their minds OR employ someone internally or externally who has already studied and knows how to organise for H&S is the imperative.

Those doing H&S successfully are supposed to have an attitude of ‘healthy paranoia’ and despite the document saying ‘Now we need to move forward at pace’ – this doesn’t look like there’s anything active or urgent. And although H&S has got better over the decades – it might be argued, partly to with de-industrialization and the lack of construction activity – there is still much to do lest we enter a ‘lag’ phase and confirm the feeling that many have that ‘it’s all just about meaningless paperwork’.

An alternative approach

I don’t like being critical (well, alright, maybe just a little bit), so I’d like to suggest a way forward –  just in case they want to revise the strategy that they’ve spent ages, and so many lunches, putting together.

So I would keep some of the headings, but get rid of the waffle.

Gone would be the ineffectual bits that will happen anyway or lack focus i.e. Acting Together, Keeping pace with change and Sharing our success

Concentrate instead on Tackling ill health, Managing risk well and Supporting small employers

Be more specific about what strategic things can be done on Tackling ill health – give some idea about what the biggest health challenges are. Use better examples than the well-known isocyanate paint issue.

Under Managing risk well ‘Making it Real’ should be the central message. In some instances, too much paperwork is passed around for too little effect, whilst other sizeable businesses still use the HSE’s quick-and-easy toy-town-templates and end up not examining, or tackling, the real risks or the organisational failings of their business.

For Supporting small employers, it seems to me that there’s much more that can be done to highlight the support that is already available i.e. health and safety professionals.

A quick jump onto HSE’s website shows how difficult it is to be directed to anyone who can help (no one expects a direct recommendation, but an obvious link to the OSHCR search website might be helpful). I can imagine that countless small business owners visit the HSE website, find themselves lost and then give up.

And although the document says that HSE will increasingly act as an ‘enabler’, supporting businesses particularly small and medium enterprises, we still have to consider that there might be a cost to the business via the ‘Fee for Intervention’ system, whereas most health and safety consultants will at least visit and find out what the business needs for free. The type of ‘support’ that enforcing authorities can offer is also likely to be limited to the issuing of ‘read-it-yourself’ leaflets or website links, rather than actual hands-on analysis, coaching and document writing.

To conclude, my  favourite bit in the whole document says ‘…we need well-thought-out measures to be applied that are tailored to each business’ and unfortunately I’m not getting the feeling from this ‘strategy document’ that this will be the key driver to achieve this very laudable aim.