“Put risk assessment at the absolute heart of everything you do, rather than compliance, and you won’t go far wrong.”
This was one of the central messages that Duncan Spencer, a safety manager at John Lewis Partnership, delivered as part of a case study on how Waitrose had brought about a risk-led, evidence-driven approach to health and safety.
He explained that when he took on the job in 2007, he found the supermarket had more than 750 risk assessments, despite “only being a shop!” These documents were driven by hazard spotting; an extreme emphasis on diligence; an over-reactive approach to isolated incidents; and a culture where every whim of every enforcement officer was catered for.
He lauded the HSWA 1974, and Robens as its ‘chief master chef’, for the way it has given safety practitioners the opportunity to learn and identify what safety ‘looks like’ in their organisations, rather than be dictated by government, as was the case pre-1974.
But he warned practitioners to be careful when considering the various HSE guidance, ACoPs, industry best-practice advice and British and international standards, in case they make things overly complex and divert practitioners away from applying the HSWA’s principle of duty-holders making their own judgements and assessments.
He identified that many organisations generate mountains of paperwork and unnecessary risk assessments because they want to ‘feel’ they are more compliant. But he described the preoccupation with health and safety compliance as an ‘all you can eat buffet’ warning: “If you’re not careful and implement all the controls other people are doing, you can inadvertently go over the top.”
By placing risk assessment at the centre of everything businesses do means that they reduce getting buffeted by different forces. It also reduces the number of decisions that need to be made, as your procedures and policies will depend on your risk assessment, as will the competence and training requirements of your workforce.
Spencer also stressed that it is necessary to create a systematic method for identifying what your risk assessment should cover. “If you don’t know what you have to worry about, you end up carrying out risk assessments until kingdom come.”
With this in mind, he encouraged practitioners to be confident, realistic about what can be achieved, and know when to stop. He also took issue with companies that look to eliminate all risks, or strive for ‘continuing improvement’, suggesting that such an aspiration moves companies back into the territory where compliance is at the heart of decisions and operations, as you can always do more.
By adopting these principles, explained Spencer, Waitrose reduced its risk assessments to between 25 and 30 for convenience stores and around 70 for core branches. These documents are further broken down according to people’s roles, so, for example, section managers only have to deal with about six or 12 risk assessments. The effect has been to see a substantial reduction in the organisation’s employers’ liability claims.
Summing up, Spencer suggested practitioners should ask themselves some simple questions when considering of their risk assessments are relevant and necessary, including: ‘Does this act make or keep people safe?’; ‘Does this show how we keep people safe?’ and ‘Is it simply a legal requirement?’
Interesting approach.