5,000 Shades of Grey
A chance telephone call led risk consultant Nick Bell to reflect on how health and safety strives to strikes a balance between rigid rules and flexibility.
Last week I was asked: should a structural engineer have an asbestos survey before visiting a commercial building? My immediate answer was “It depends”. The engineer (who has asbestos awareness training) was visiting a 1970’s property that was in reasonable condition to get a sense of its’ dimensions and structural form in order to plan more intrusive surveys. He was not poking around in nooks and crannies. A survey was unnecessary. It would be completely different if the engineer was visiting a crumbling edifice or breaking into cavities to inspect steelwork.
It is easy to issue and measure compliance with a black-and-white instruction that “No Asbestos Survey = No Visit”. If taken to extremes, the rule could prevent someone from visiting a client’s office! Even if an asbestos survey was available but it was out-of-date and full of gaps, it would be of little help. We could decide not to work with clients who do not fully comply with all their legal responsibilities (e.g. as dutyholders under the Control of Asbestos Regulations). Few organisations have the luxury of vetting and cherry-picking their clients.
IOSH-sponsored research states “in reality, the way that OSH plays out is not straightforward and we have described it as ‘fog’” (Gibbs et al. 20161, pg. 25). The research points out that few situations have obvious solutions: We must deal with shades of grey.
The train to nowhere
My favourite story about nonsensical rules – which may be an urban myth – involves a train line that had almost been swept into the sea by a storm. The sea wall and land had been washed away along a section of the line and the track was left suspended above a gaping chasm. Trains were not being sent down the track and plunging into the sea. A civil engineer turned up to assess the damage. He was denied access because he did not have a permit proving that train movements had been halted. No Permit = No Work.
A black-and-white approach may partly arise from a perception that the ultimate goal is to prevent risks to the individual or organisation. That mind-set, however well-intentioned, can quickly turn health and safety into a preventer.
Some individuals (or organisations or communities) are also naturally inclined to be risk averse and find a sense of security in formal rules. The IOSH research1 suggests this could be due to a lack of competence or experience. Schwartz2 instead proposes that it is a product of human values. If someone is strongly oriented towards conforming, and less motivated to seek stimulation and creativity in their work, then they will feel uneasy – even threatened – in situations where formal protocols do not exist or function.
One rule for me, one for you
Many people believe that effective training is one component of supporting safe working practices. Bad training could contribute to incredibly unsafe practices. Therefore, why not issue trainers with detailed instructions about how to deliver training?
As a Probation Officer, I was coached and trained to deliver groupwork to high risk offenders. It was an apprenticeship that taught me how to manage groups. Now, designing and delivering interactive training is a key element of my trade. A lesson plan, with reminders about timings, objectives and delivery methods can be useful. However, I would feel bemused and mildly insulted if I was given a long list of rules telling me how to do my job.
Rules, for example, cannot describe how to evaluate and respond to delegates’ body language or how to acknowledge delegates’ comments and link them to previous contributions: “that’s a really good point, Fred – Bob, that reminds me of what you said about…”.
Incidentally, this technique demonstrates you are really listening, and value delegates’ input, and forges connections within the group. Training by rote would lead to a one-sided flow of information and an inflexible, unresponsive experience which is best left for e-learning.
It would feel arrogant and hypocritical to propose that I can rely on my own training and experience but everyone else needs detailed instructions to practice their own trades.
The IOSH-sponsored research proposes a third way. Some work environments and risks warrant more structured sets of rules, but these should still be shaped by workers’ knowledge and experience. At the same time, dynamic or complex scenarios may be better managed by offering overarching frameworks or principals (a bit like my lesson plan) but allowing and trusting individuals to determine the precise method of work. ‘Safety differently’ uses this flexible approach. Health and safety professionals then morph into facilitators and coaches, helping build the confidence and capability of staff to navigate their own way through the fog.
On reflection, “it depends” was an OK answer. “What do you reckon?” could have started a much more empowering conversation.
After completing his degree in Psychology in the early 1990’s, Nick began working in a project offering support and advice to young people during which time he took further courses in counselling and transactional analysis. He then worked and trained as a Social Worker before joining the Ministry of Justice as a Probation Officer. Eventually he was invited to be part of a Public Protection unit, supervising high risk offenders. He used a range of cognitive-behavioural interventions to help offenders gain insights into, and empower them to change, unhelpful patterns of thoughts, feelings and behaviour. In 2002 he took a sideways move into Health and Safety. He went self-employed 18 months ago as he explained in his recent ‘lone wolf’ article https://www.shponline.co.uk/lone-wolf-going-it-alone-in-health-and-safety/
Nick is a Chartered Fellow of IOSH and a Fellow of the International Institute of Risk and Safety Management.
Through his on-going PhD Nick is examining how worker engagement can be used to improve health and safety performance.
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