Given the current focus on competence in, and accreditation for, the health and safety profession, James Pomeroy and Tony Boyle, in the first of a two-part article, consider four technical competencies pivotal to the practitioner’s work and how well they are executed, and outline how practitioners can enhance their approach.
If you have been practising for a while, or have attained professional qualifications and recognition, you may take professional competency for granted, but experience and qualifications alone are rarely enough to ensure professional competence. Managerial competencies and soft skills, such as communication, engagement and planning, are often overlooked.
The four topics at the heart of modern safety management, and which form the significant proportion of a practitioner’s work, are: risk assessment, training, accident investigation, and auditing. There are common pitfalls in undertaking all of them, but there are also various solutions that can be implemented to improve competence and thus avoid those pitfalls.
Risk assessment
This is the backbone of what we do: the decisions we take, the advice we provide, and the strategies we lead are founded on it. Despite our familiarity with the process, however, the application of risk assessment remains a problematic issue, as was identified in a HSE review in 2003.1 Building on the findings of this review, we consider some of the common problems found in three elements of the risk assessment process, starting with planning and process management.
Planning and process management
Planning is a pivotal component of risk assessment and when done correctly, it should establish the “who, what, where and how” of the risk assessment process. Done incorrectly, however, it will undermine many risk assessment programmes.2 Some of the more frequent problems include:
- Failing to ensure that risk assessors are competent, e.g. appointing individuals who have insufficient knowledge of the process being risk-assessed, do not understand the hazards, or have limited knowledge of proven risk-control measures;
- Not establishing common processes and methodology for conducting the risk assessments. This often results in poor co-ordination of the risk-assessment process and makes managing and evaluating the findings extremely difficult;
- Failing to define the scope or boundary of the task being risk assessed, resulting in inadequate and inappropriate assessments;
- Poor control of the findings of the assessment, often because an effective process for tracking and closing-out risk improvements is not established.
Improving the competence of the risk assessors is the most obvious way to improve the process. This does not necessarily mean more training, but ensuring that the training is made more relevant to the hazards being assessed and provides information on the proven ways of controlling a hazard.
This is particularly important given that most risk-assessment training is generic and lacks specific information about the types of hazards present and proven ways of controlling the risk. The latter is particularly effective in stimulating the risk assessors to identify ways of improving the control of a risk.
The composition of the assessment team is also important. A well-structured team should include individuals with the necessary expertise to identify the hazards and those who are prepared to challenge the status quo with the most important questions of all: what? how? and why?
Ensuring that a standardised approach to the risk-assessment process is taken, using common tools and methodologies, is essential. This sounds obvious, but it is still common to find a fragmented approach in an organisation’s risk-assessment programme. Similarly, it is important to consider how best to define the scope and boundary of more complex risk assessments so there are no overlaps, or – more concerning – omissions.
The methods of managing and monitoring the risk improvements are essential, but are frequently overlooked. In addition to defining a risk-assessment methodology, the policy should establish the ownership and accountability for each stage of the process and define the framework for monitoring, reporting and auditing of the results.
Identification and assessment
Identifying all the hazards and the possible hazardous situations presents a number of difficulties. While there is no panacea, understanding the common pitfalls will help ensure a more effective hazard-identification process. Some of the more common problems include:
- Overlooking human factors, long-term health hazards and abnormal activities that are conducted in the work area, or associated with an activity;
- Failing to engage with the personnel involved in the process, potentially missing hazards and variations from the approved procedure;
- Not considering the accident and ill-health data within the assessment, or, at the other extreme, creating a false sense of security by placing too much reliance on the lack of an accident as a justification for not acting on a hazard;
- Risk-assessing the procedure versus the actual working practice. There is often a large variance between the operating procedure and the informal way in which a task is actually completed. In some cases, significant gaps between the two are actually identified, but overlooked; and
- Some of the more profound problems in the identification stage tend to be intangible and result from the interaction and communication that does, or does not, occur throughout the assessment process.
Consultation is central to a good hazard-identification process and ensures the expertise of the workers is obtained and hazards fully understood. This may sound obvious but there are still many examples of risk assessments conducted with little consultation with the workforce. Very often, the simplest forms of hazard identification are the most effective, such as informal interviews using an open questioning technique to walk through each stage of the process and draw out the hazards.
Many practitioners make great use of checklists in their risk-assessment processes. These can help the risk assessors identify hazards, but they can also lead them to consider only the items listed. Moreover, they do not encourage engagement, which may help identify different hazards, or reveal a significant variance between practice and procedure. Where checklists are used in risk assessment, the training should outline how to use them effectively.
Both these points lead us to one important but often overlooked skill in risk assessment: interviewing technique. A fundamental skill of every practitioner is obtaining information from people. However, interviewing technique is not normally covered in a practitioner’s training and it is not something that comes naturally to most people. Consequently, many practitioners are not proficient interviewers and often fail to draw out the right information.
Given the importance of interviewing in all elements of safety, practitioners need to ensure they are competent interviewers. Where weaknesses are identified, specialist training can assist in developing interviewing competence.
Implementing and monitoring
Weak management of corrective actions and, specifically, high-risk findings is a factor in many programmes. Some of the more frequent problems identified include:
- Overlooking high-risk corrective actions, in preference to addressing lower-risk issues. Sometimes, this is because the former are difficult to resolve so actions that are quicker and easier to complete are emphasised;
- Failing to establish interim measures for high risks while a longer-term solution is developed. Often, this is because the need for interim controls gets lost in the discussion over the design, cost and practicality of implementing longer-term controls;
- Not aligning the monitoring processes to reflect the reliability of the risk-control measures; and
- Failing to review the effectiveness of the measures introduced.
Reducing a high risk should always be prioritised over lower-risk issues. Where this is not possible in the short-term, then interim risk control measures need to be taken, management informed and updated of the issue (perhaps through a risk register), and the checking processes, such as auditing, inspection and supervision, need to be increased. Although this process is relatively straightforward, it is often overlooked for the reasons outlined.
Where control of a significant risk is achieved solely through conformity and compliance (and is therefore subject to human error), monitoring should be increased. This is particularly critical where the outcome could be severe if the risk control were to fail. This is a principle that every practitioner is taught, but the link between the risk-assessment findings and the monitoring programme is often found to be weak.
Training
Training is a fundamental component of modern safety management and is a common feature in organisations that benefit from low rates of accidents.3,4,5 There is, however, an increasing body of thought that safety training has developed a bad reputation: tedious, poorly-delivered and with few measurable results.6 Cox,7 for example, agues that much training is reactive and instituted as a fire-fighting response, while Booth8 has questioned the effectiveness of a lot of safety training, arguing that much is fragmented, ad-hoc, and with little evaluation.
Are these criticisms fair? They certainly highlight the following common pitfalls:
- A lot of safety training continues to be conducted without clearly-defined outcomes, or any requirement to change, the most obvious example being awareness training. Furthermore, where objectives are defined, they are often poorly selected, unquantifiable and ambiguous – e.g. “reduce accidents” or “reduce risk”;
- Safety training is often poorly designed and lacks imagination and engagement. The most obvious example of this is training that involves long drawn-out presentations, often regurgitating the legal requirements, with little engagement of the audience. If you think this is harsh, think about the number of times you have experienced safety training that was genuinely engaging, imaginatively developed and highly informative;
- There is also limited evaluation conducted post-training to check if it was effective. Very few organisations undertake even rudimentary evaluations.
Because training is such a central component of what practitioners do, there is an assumption that it comes naturally. However, transferring knowledge in an informative and engaging way is a specialist skill and everyone involved in the development and delivering of training would benefit from learning how to train. This is particularly important where the subject matter can appear dry, technical, or legalistic, and key messages need to be effectively communicated.
When proposing to deliver training, identifying from the outset what you are trying to achieve, and why, are critical first steps. If these questions cannot be answered in clear and unambiguous terms that can be measured, it is unadvisable to proceed until they can. Safety training should be seen as a transformative process, where objectives are established from the outset that will enable the impact of the training to be evaluated.
Care needs to be taken in selecting the appropriate objectives. It is advisable to avoid objectives that focus narrowly on reducing accidents because of the multi-factorial nature of accidents. Objectives that are aligned to more predictive and manageable changes, such as those that relate to behaviour or measurable outcomes, are always preferable.
Accident investigation
Most practitioners would consider accident investigation an area of professional strength. After all, the average practitioner has experience of investigating accidents and would have studied the topic in their professional training. But are we fooling ourselves? After all, our professional training is actually generic and tends to focus on the procedural and legal elements of accidents – e.g. recording and reporting.
A HSE study9 found that few practitioners have actually received dedicated training in accident investigation, or root-cause analysis. The same study found poor standards of accident investigation, with some of the common pitfalls including:
- Poor quality investigations, where insufficient focus is placed on gathering and analysing the evidence. This is often compounded by poor-quality interviewing;
- Failure to identify the indirect and underlying cause of an accident. Consequently, inappropriate corrective action is recommended/undertaken; and
- Confusing accident reporting and accident investigation, in that it is incorrectly believed the existence of the former demonstrates the latter.
Practitioners are advised to first evaluate the adequacy of their organisation’s accident-investigation process. One of the key tests is the degree to which an investigation identifies and evaluates indirect and underlying causes versus the immediate causations of an accident. A similar test is to consider how much focus is given in the investigation to the “what” and the “how”, as opposed to the “why”. The reasons why an accident occurred should form a significant proportion of a good-quality investigation.
Many accident-investigation procedures describe everything about recording and reporting an accident, but very little about investigating it. It is advisable, therefore, to review the investigation procedures and ensure they establish a logical and clear process to conduct an investigation. An effective process should define the individuals who will lead and conduct an investigation, the required levels of competency, how evidence will be gathered and secured, and the investigation protocol that will be followed.
Conducting interviews post-accident and encouraging people to open up requires a particular skill, where knowing how to ask something is as important as knowing what to ask. Accident investigation requires a unique set of skills that, as with training, do not come naturally to most people and usually require specialist training.
Audit
Audit10 is a tool that has been adopted widely by practitioners over the past two decades and there are multiple forms of safety audit available, such as auditing of risks controls, compliance audits, and management-system audits that evaluate the safety management system as a whole. Because audit is a flexible, effective and reliable tool it provides a good means of evaluating health and safety performance.11 There are, however, some common problems with safety auditing, several of them relating to how the profession approaches the subject of audits, including:
- Conducting audits without defined audit criteria;12
- Not directing the audit towards the significant risks. It is common to find low risks being regularly audited, while significant risks are overlooked. Often, this is because of a poor link between the audit programme and the risk assessments;
- Allowing an audit programme to stagnate and, consequently, reducing the overall value of the process to the organisation;
- Not using the audit findings to drive the performance of the safety management system; and
- Failing to analyse the audit findings to identify systemic areas of weakness.
ISO 19011 provides some useful guidance on establishing an audit programme,13 and one of the first considerations is deciding what to audit, and why and how this is best achieved. This initial step is often overlooked and, consequently, the significant risk controls are not monitored.
The findings of the risk assessment, accident data and known areas of weaknesses, such as frequent non-conformities, or high-risk controls that are reliant on behaviour, are essential considerations in determining what to audit and how often. The link between these elements and the audit programme needs to be strong; if it is not, it is possible that the programme is auditing the wrong things.
The audit criteria, such as standards, policies or procedures, should be established at the outset. While it is common practice in the safety profession to conduct audits based on legal requirements or best practice, such requirements are open to interpretation and do not take a management-systems approach.
Once established, the effectiveness of the audit programme should be periodically reviewed. Often, this review is limited to assessing the completeness of the audit programme, i.e. is the programme up to date, and are corrective actions closed out?
Competence in audit, however, also means taking a strategic view, such as ensuring that the scope of the audit programme continues to be aligned to the significant risks, that any systemic findings of the audits are identified, and that the audit programme is driving continual improvement.14 Where an audit programme has demonstrated conformity for a prolonged period it is also advisable to review the scope and focus to ensure it continues to enhance the adequacy and effectiveness of the organisation’s safety management system.
Summary
There are multiple reasons for the problems we have outlined. Some relate to the limited training requirements to become a practitioner; others stem from the heavy emphasis that our professional training places on legal and technical matters, with insufficient focus being given to the development of soft skills and managerial competencies.
Take the findings on risk assessment, for example. These are hardly surprising, given that most of the time spent studying risk assessment in the diploma route, or even some of the degree programmes, focuses on the technical application of the assessment. There is limited consideration given to how best to plan, manage and monitor what, in many organisations, can be a large and complex process.
Similarly, with training, knowing the intricacies of a technical subject is very different from being able to impart that knowledge to others in a form that they can understand and act on.
The intention of this article has been to prompt discussion and encourage practitioners to consider where and how best to enhance their professional competencies. This is particularly important given the spotlight that the profession is currently under and the increasing prominence that practitioners are gaining within the management of their organisations.
Building on this theme, next month we will consider the managerial competencies that a practitioner should be focusing on, and how we could have a more transformative impact on our organisations.
References and terminology
1 HSE (2003): Good practice and pitfalls in risk assessment, Research Report 151 – www.hse.gov.uk/researcH/rrhtm/rr151.htm
2 European Agency for Safety and Health at Work: ‘Common errors in the risk assessment process’ – http://osha.europa.eu/en/publications/e-facts/e-fact32
3 Zohar, D (1980): ‘Safety climate in industrial organisations: theoretical and applied applications’, in J App Psych, Vol. 65, pp96-102
4 Cohen, A, Smith, M and Cohen, HH (1975): ‘Safety Programme Practices in High vs Low Accident Rate Companies: An Interim Report’, US Department of Health, Education and Welfare, Publication No.75-185, NIOSH
5 Pfeiffer, C, Stefaniski, J and Grether, C (1976): ‘Psychological, Behavioural and Organisational Factors Affecting Coal Miner Safety and Health’, DHEW Contract HSM 99-72-151, NTIS PB 275 599
6 Cooper, M and Cotton, D (2000): ‘Safety training – a special case?’ J Euro Ind Training, Vol.24, Issue 9, pp481-490
7 Cox, S (1988): ‘Employee attitudes to safety in a European industrial gas company’, – unpublished MPhil thesis, University of Nottingham
8 Booth, RT (1986): ‘Education and training in health and safety: current problems and future priorities’, in Clark, R. (Ed.) ‘Proceedings of a Conference held by the British Health and Safety Society at The Senate House, University of London, 5 June
9 Henderson, J, Whittington, C and Wright, K (2001): Accident investigation – the drivers, methods and outcomes, HSE Contract Research Report No.344/2001, HSE Books
10 There is no standard agreed definition of audit, but we have opted for the definition outlined in ISO 19011: “A systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled”;
11 Niven, K (2005): ‘Impact Evaluation of Health and Safety Management in the National Health Service: A Literature Review’, HSE Research Report 280
12 Boyle A J (2008): Health and safety: risk management (3rd edition), IOSH Books
13 ISO 19011: 2002: Guidelines for quality and/or environmental management systems auditing
14 Asbury, S, and Ashwell, P (2007): Health and Safety, Environmental and Quality Audits: A risk-based approach, Butterworth-Heinemann
Continuing professional development is the process by which OSH practitioners maintain, develop and improve their skills and knowledge. IOSH CPD is very flexible in its approach to the ways in which CPD can be accrued, and one way is by reflecting on what you have learnt from the information you receive in your professional magazine. By answering the questions be posed below, practitioners can award themselves credits. One, two or three credits can be awarded, depending on what has been learnt – exactly how many you award yourself is up to you, once you have reflected and taken part in the quiz.
There are ten questions in all, and the answers can be found at the end of this article. To learn more about CPD and the IOSH approach, visit www.iosh.co.uk/membership/about_membership/about_cpd.aspx
QUESTIONS
1 Which of the following is not at the heart of safety management?
a Risk assessment
b Hazard identification
c Auditing
d Training
2 What is the pivotal component of risk assessment that, when done incorrectly, can undermine the whole programme?
a Hazard spotting
b Developing risk matrices
c Planning the processes required
d Recording the risk assessment
3 Risk assessors’ competence can be improved by?
a More training in techniques
b Training with relevance to the hazards to be controlled
c Using generic tools and methodologies
d Keeping the status quo
4 A common problem associated with risk assessment is?
a Defining a framework for monitoring
b Risk-assessing a procedure but not the actual working practice
c Using a team of people rather than an individual
d Looking for long-term health hazards
5 A check list is useful in risk assessment because?
a Only specific items requiring attention need to be identified
b It reduces engagement with the workforce
c It helps identify hazards
d There is no need for training in its use
6 When implementing the results of risk assessments it is necessary to prioritise:
a The risks that can be most easily dealt with
b High risks over lower risks
c Longer-term solutions to problems
d Checking processes
7 When training is necessary it needs to be?
a Reactive to identified problems
b Very generic, covering a range of risks
c A transfer of knowledge that is informative and engaging
d Emphasis on the legal requirements for safety
8 Accident investigation is necessary for?
a Recording and reporting an accident
b Making a rapid conclusion about the causes of the accident
c Defending the company against the HSE
d Identifying and evaluating indirect and underlying causes
9 There are various forms of audit but which of the following is NOT an acceptable audit criterion:
a Risk control
b Compliance
c Management systems as a whole
d Inspection of a workplace
10 The article recommends that practitioners focus their professional development on?
a Wide technical knowledge
b Having a wide and in-depth legal knowledge
c Softer management skills relating to planning, managing and monitoring
d Risk assessments
Answers
1) b
2) c
3) b
4) b
5) c
6) b
7) c
8) d
9) d
10) c
James Pomeroy is Group HSE manager for Senior plc, and Dr Tony Boyle is director of HASTAM
