Dear Health and Safety Consultant
“…I’m in self-isolation because of the pandemic and have been asked by my boss to review all our risk assessments. The trouble is, I have been doing things the same way for so long I seem to be stuck and can’t think out of the box – can you help?”
Of course, this is a totally made up enquiry – unfortunately most of us who can’t think outside of the box on any particular subject don’t realise that we’re trapped ‘inside the box’ i.e. we’re not even aware of the famous Donald Rumsfeld ‘Unknown Unknowns’.
However, it does illustrate one of the key difficulties of being a Health and Safety Adviser.
Advisers have to know about health and safety law – obvs(!), but it is so much more than this, it also involves asking people to be self-analytical about the methods used for their work and how they express the controls they have in place in their risk assessments.
Many managers can think ‘outside the box’ when it comes to the day-to-day complexities such as machinery breaking down, deliveries not arriving etc. but at the same time can be totally incapable of considering alternative actions to control risk.
Add to this the prevailing background opinion of most managers that they’re already working as safely as possible and that Health & Safety is just about installing some useless paperwork. Alternatively, some think that health and safety is a trap waiting to spring on the unlucky and ‘there’s nothing you can do about it’.
Conversely, Health and Safety Advisers are trained to think broadly about hazards and risks and this ‘have you thought about this/that’ approach can add to the general sense that doing health and safety well is some kind of mysterious art.
In Rumsfeldese, risk assessment is the process of moving through his phrase to the ‘Known Knowns’, and Consultants will initially be helping their clients to start checking the ‘Known Unknowns’. Those who are inclined towards being egotistical can let this go to their heads, but should remind themselves that this is only one field of many.
As standards become more generally known, available, accepted, the role of a Health and Safety Consultant is changing from the traditional person who knows all the standards and checks them, to a coach and information organiser whose main task it is to nudge the client towards a fuller and wider consideration of their risk scenarios.
The Curse of the ‘Red Tape Busters’
The theory goes that employers only need to go so far as is reasonably practicable to reduce risks to an acceptable level. And while the facts of the actual practices that were in place before a serious accident all relevant, the onus is still on the employer to carry out a suitable and sufficient risk assessment.
Clearly for activities where there are a myriad of risks, the paperwork will have a tendency to expand. This expansion will definitely freak some people out, particularly those whose minds tend towards the catastrophic – ‘we’ll be risk assessing bumping into a door frame next’!
The Health and Safety Executive has not always helped things in the past by giving in to the ‘red tape busters’ and claiming that risk assessment is an easy process. ‘Yea! We’ve now discovered that it’s all an easy task after all! All you have to remember is ‘If a jobs worth doing, it’s worth doing badly’ (so badly, it’s not worth doing).
Those who access the most basic Health and Safety Executive guidance have enthusiastically taken on board the apparent simplicity of risk assessment.
This has led to operations that have many serious risks being dismissed with controls that are often one sentence long. Normally these are easily spotted as they have the characteristic of reliance on the very controls that HSE have advised are the last ones to consider in the hierarchy of risk control….PPE and training.
So, what’s the answer?
I was speaking to a fellow Health and Safety Adviser about the new online forms technique that ‘Just Health and Safety’ have been developing.
Being an internal H&S Adviser for an organisation, her opinion was that risk assessments should be a team effort and be guided by someone who is health and safety trained.
In general terms, I agree with this. However, the reality is that many people – trained or otherwise – still struggle to carry out risk assessments and think outside of the box. Left with a blank form, the right answers don’t always surface by magic! The ‘Unknown Unknowns’ often stay hidden!
The purpose of adopting an online technique is that it allows almost limitless possibilities for the risk assessor to get credit for things that they already have in place, and have that recorded. For time-strapped managers, being able to tick boxes to create sentences rather than have to think carefully about how to phrase things is a definite advantage.
Plus, it also creates the opportunity for them to be nudged into considering other suggestions for controls that might be a good idea to adopt.
Brainstorming risk assessments in a group is also a valid technique and there’s no reason that a decent online system cannot accommodate both techniques.
If the Health and Safety Executive and Local Authority inspectors are to be satisfied when they turn up to investigate a serious accident at your workplace that your risk assessment was thoroughly thought out, then it is clear that these cannot contain simple one-line answers to potentially complex situations.
The conclusion we have come to is that by using online tools, checklists etc, organisations can rapidly produce content–rich assessments which are worthy of that name. Plus, if they are in the right mindset, they can readily see the areas of improvement they should be looking into.
Whilst it’s true that boxes can be thoughtlessly ticked – at least that can be examined at a later ‘audit’ stage. It’s much more difficult to see what might be being missed by looking at a few pages with ‘PPE’ written all over them, than to see which boxes haven’t been ticked or to double check the truth of the ones that have.
Online forms such as our ‘Activity Risk Assessment Form‘ are, of course, complex to set up and will always need updating and improving, but compared to the ‘blank form’ approach commonly used they are far superior.
The tide has turned, and Health and Safety Consultants and Advisers need to adapt away from being wizards of the unknown to providers of techniques, and stimulators of ‘thinking outside of the box’.