Stuart Bower describes the process his organisation undertakes to ensure that it is confident in its performance on health and safety.
What does good health and safety look like? I had been asked this question on more than one occasion by my line manager, who has the allocated responsibility for day-to-day management of health and safety for Dorset Fire and Rescue Service (on top of his ‘day job’!)
What he wanted was quite reasonable – just some form of assurance that our current performance was acceptable and that the activities we were engaged in were relevant and on track. He knew we weren’t perfect, and was fully supportive and engaged with plans to move forward. Nevertheless, he needed assurance so that he could, in turn, give the same assurance to the chief fire officer and our elected members.
Even though I’ve been working in the health and safety business for more years than I remember, it was a question that caused me to pause for considerable thought. How could I give a single, simple response that would provide the sort of assurance my line manager required?
I even posed the question on the IOSH website back in October 2007, which generated an interesting range of answers, such as:
But none of these really tripped off the tongue, or seemed to answer the question in a meaningful way.
Health and safety generally has a good profile in the Fire Service and, in many respects, is well integrated within other processes. However, this can pose a challenge when trying to identify and measure exactly what health and safety activities are going on because it’s often ‘just the way we do things’. Consequently, there is a need to separate out some of these processes and activities to help measure progress.
Is independent auditing the answer?
Dorset Fire and Rescue Service is currently committed to RoSPA’s Quality Safety Audit (QSA) process and has adopted a target of Level 3 by 2012. A ‘gap analysis’ carried out by RoSPA in late 2008 indicated that we were making good progress and should exceed this target. Clearly, independent auditing is a good thing to do but we simply can’t afford to repeat the process too frequently, which leads to a lag between our activities and the results. Even ‘in-house’ auditing would take us too long to achieve the relevant results within the sort of timescales we want. So, while the gap-analysis result was good news in itself, I didn’t feel that this was enough to provide the overall level of assurance being sought.
Like many public organisations we also ‘suffer’ audits from a variety of drivers and we generally appear to be dealing with the preparation for, or the results from, different corporate assessments on an almost constant basis. While health and safety has a part to play in these audits, it does not form part of a major focus to enable us to draw serious conclusions. Furthermore, none of the auditors appears to have the depth of experience or knowledge in health and safety management systems to scrutinise them as well as we would like, which doesn’t instil confidence.
So my thoughts turned to some of the more ‘traditional’ safety indicators. I unearthed an old SHP article on safety management performance indicators1 and used it to consider my options. This reinforced my view that, while the ‘accident statistical’ approach was certainly part of an assurance process, it couldn’t be used in isolation. There are simply too many variables and it’s impossible to determine if ‘good’ results are being achieved as a result of good management, or good fortune.
At the same time, other options were considered, including external auditing and attitude surveys. However, the former is, frankly, expensive and, with shrinking budgets, something of a luxury; and, while the latter might provide useful information, it wouldn’t provide anything like the assurance we were looking to achieve.
What approach did we take?
It was clear that no one single approach would answer this question, so we needed to bring many aspects of these together. And so, our ‘Health and Safety Assurance Framework’ was born.
The model we’ve developed for this part of the process is layered, with our ultimate goal – our desire to keep people healthy and safe – sitting at the very top. We believe in, and want to use, our assurance framework as one of the main tools to help us achieve this, so it sits at the second ‘level’. The headings in the third level are intended to show how we’ll achieve the top layer – through the robust application of our health and safety policy and our health and safety improvement plan.
The last level shows what we’re hoping to achieve through the overall implementation of the assurance framework. There is a final layer (not shown) that illustrates all the separate activities undertaken within the organisation that link to, and impact upon health and safety performance. For example, staff development programmes, consulting on change, induction training, and organising to meet our policies and procedures.
It is actually encouraging and worthwhile to sit down and carry out such an exercise. When considering all the areas where health and safety has had – and continues to have – a positive impact on organisational activities, it is a cause for celebration.
So, how does the assurance framework help us deliver our objective of ‘keeping people healthy and safe’? In essence, it is used to ensure that the commitments contained within the health and safety policy statement are translated into practical actions, and any ‘gaps’ found as a result of the assurance process fed into the improvement plan.
Most safety practitioners can produce safety policy statements in their sleep, and commercial audit scoring packages can be used to back-engineer a policy so that it ticks all the right boxes and scores maximum points for the organisation. What those packages tend to be less good at is measuring what is then done to translate those policy commitments into action.
This is where we decided to concentrate our effort – how could we make sure we were delivering against those policy statements and have some assurance that they actually make a difference? To do this, we looked at each statement and identified:
The process made us revisit the wording of our policy to ensure we were making realistic, responsible and measureable commitments. Overleaf is an example of a statement to illustrate how the assurance process works: We take the basic statement, in this case the commitment to ensure that competent health and safety advice is readily available, and determine exactly what we want that statement to deliver.
The organisation will be assured that this is in place through the provision of a health and safety section (the small but perfectly formed ‘in-house’ team) and through making sure that there is clear understanding of managerial roles and responsibilities in relation to health, safety and welfare.
The assurance that these are in place and providing the right level of advice and guidance comes from one main indicator for each. This is the measurement of competence against job descriptions and ensuring Continuing Professional Development (CPD) through our Personal Development and Performance Review (PDPR) process, which takes place on the basis of six-monthly reviews.
The responsibility to provide assurance for this area currently rests with our director of people services, who can use information from the PDPR process in making the overall judgement.
We have taken every policy statement – 26 in all – and applied the same criteria to each. Interestingly, apart from in a few cases, we haven’t invented a whole range of new indicators to help us measure performance but have instead tried to use the indicators and processes already in place.
An ‘assurance statement’ is devised for each policy area and completed on an annual basis by the relevant director. These statements require an overall judgement of progress based on certain criteria (see table below). There is a requirement to provide a script outlining how the judgement has been reached and, although subjective, this is accompanied by supporting evidence.
It is then necessary to list outstanding or maintenance issues and set them a priority rating (high – within 12 months; medium – within 24 months; and low – within 36 months) for that issue. Each issue is then handed over to an identified lead officer, who is responsible for taking it forward.
Completed assurance statements are collated and used to form the basis of our annual health and safety report. The beauty of this method is that, in effect, the report is now largely written by our directors.
This draft report then goes before our governance forum, on which the majority of directors responsible for completing assurance statements sit. Each of those statements is moderated to ensure that it reflects organisational rather than individual views. As part of this process, I allocate an overall grading for our health and safety performance based on the criteria outlined in the panel below. Again, this is subject to moderation by the directors and I have to justify my position.
The final report is then presented to the fire authority to show that we are delivering towards its policy statement.
All the issues identified in the assurance process are fed into our health and safety improvement plan which, in turn, feeds in to our overall planning process. This should ensure that we prioritise and deal effectively with issues within reasonable timescales, and that progress can be monitored.
Early lessons
Initial indications suggest that the process has resulted in a higher level of ownership and understanding at a senior level. It also provides the assurance we are looking for in relation to the delivery of our policy commitments.
It is still early days and difficult to say if it gives an ‘overall’ level of assurance, but it is a good start, better than anything we have had before, and a framework we can improve on.
We need to make sure that the issues identified for action are managed within reasonable timescales – otherwise the process could soon become overloaded and progress will be slow, or non-existent. At present, work is underway on a prioritisation process to see if this will provide greater definition and clarity on how to meet this challenge.
We are also committed to review our policy statement every year, and we’ll need to make sure that any changes are fully reflected within the assurance process.
Conclusion
So, what does good health and safety look like? I can’t answer this with 100-per-cent certainty but our assurance framework brings together many processes – most that are already in place – and allows us to make judgements to give us a clearer ‘feel’ for where we are positioned.
What is certain is that the process of getting from where we were to where we are now has led to an increased level of ownership and understanding of health and safety across the organisation and our delivery against our policy intentions.
Rather than being nothing more than a nice set of words, our approach has breathed life into our policy.
Reference
1 Budworth, N (1996): ‘Indicators of performance in safety management’, Safety and Health Practitioner, November 1996, pp23-29
Stuart Bower CMIOSH has spent the last 14 years working for Dorset Fire and Rescue Service.
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Good article, Stuart.
You should have a look at this software to help you manage your health and safety (http://www.theactionmanager.com/index.php?phs). Whilst it obviously can’t guarantee the content quality of your health and safety documentation, it is a powerful tool to manage your health and safety obligations.
Also, the dashboards that The Action Manager sends out ought to provide your line manager with the “… assurance that [your] current performance was acceptable and that the activities we were engaged in were relevant and on track.”