I have spent hundreds of hours talking to safety and health leaders about bold initiatives to boost worker protection in their businesses. Sad to say, that boldness was often licensed by the fact that their organisations had experienced disasters. Serious incidents, usually involving fatalities, had shocked them into the realisation that there were gaps in their OSH systems that needed plugging or that there must be a safer way of doing things.
But in businesses fortunate enough not to have had such a wake-up call face the perpetual challenge of how to avoid complacency, and to find and close the gaps (there are almost always gaps!) without that drastic impetus. James Reason argued in the late 1990s that organisations need to maintain a “chronic unease” about risk when things are going well.
As more organisations manage down their recordable incidents to rump levels and more people in the workforce have no direct experience of a serious incident, it is harder to maintain that unease. Hazard reporting programmes can help, as can tighter scrutiny of the lower-level incidents and near-misses for the lessons they offer. But that focus on the sharp end isn’t going to help you see the structural weaknesses that might contribute to a hazard being overlooked.
Most organisations are in an extended state of flux. The pandemic, a string of economic upheavals and structural shifts in many sectors bring reorganisations with increasing frequency; one large public corporation is on its third restructuring exercise in six years.
The Management of Health and Safety at Work Regulations sets one of the triggers to update a risk assessment as “a significant change in the matters to which it relates”. Scaling up that principle to a whole corporate (or even divisional) safety system, would involve working back through any changes in departmental structure or reporting lines in recent years and checking that the flow of responsibility for safety and health, from C suite to shopfloor, had not been interrupted. It’s a good conduit for an OSH practitioner’s unease, since pieces missing in the jigsaw of responsibility are often a factor in major incidents.
In his book Spills and Spin – The story of BP (Random House, 2011) Tom Bergin tells the story of how Lord John Browne reengineered the oil company’s upstream division, which handles exploration and production, stripping out hundreds of specialists at the centre of the business and making the individual oil fields separate business units (BUs), each responsible for project managing the exploitation of their field, contracting in expert services such as seismic surveying or well drilling from wherever they thought offered best value. When it was pointed out to him that there was a risk that the BU heads, charged with maximising returns, would be tempted to put off plant maintenance and other costs that dragged down the bottom line, Browne agreed to appoint regional vice presidents, to check that the BUs met BP’s environmental and safety standards.
After the company bought Amoco another restructuring round axed these regional VP posts and pushed their compliance duties down to the BU heads, though the conflict of interest created by those heads’ overarching priority to drive revenue had not diminished. Just over ten years later a blowout at Deepwater Horizon, a BP-owned well in the Macondo prospect in the Gulf of Mexico, killed 11 people and spilled almost five billion barrels of oil into the ocean. The US National Commission on the disaster’s final report highlighted that BPs management process did not adequately identify or address risks.
You don’t need to be worried about the prospect of an incident on the scale of the Deepwater Horizon catastrophe – which cost BP an estimated £52 billion in clean-up costs, compensation and legal penalties – to absorb its lesson about missing safety links. At the most mundane level, a failure to appoint replacement fire marshals when employees who previously volunteered at a site have left, could leave employees with disabilities vulnerable in an emergency evacuation.
If you review the OSH dependencies in your organisation and find holes higher up the hierarchy, it’s obviously unrealistic to expect you will reverse the changes that caused them to open – and may not even be desirable for other reasons. But they can be compensated for, as long as you know they are there.
Shakespeare’s observation “Uneasy lies head that wears a crown” translates to the non-regal sphere – prosaically – as those with a lot of responsibility have a lot to worry about. OSH leaders, especially when there seems least to prompt that worry, should cultivate their own unease, and, rather than losing sleep, channel it into systematic checks that they aren’t missing something.
Guest blog written by writer, editor and speaker, Louis Wustemann.