Safety Documentation: Leave Out The Kitchen Sink

As an editor, when reviewing my own or anyone else’s work, one question that always runs through my head is: could I improve this by simplifying it?

Removing any unnecessary repetition, replacing jargon and making sure the main points are clearly made is a courtesy to the readers of anything published on my watch; it’s also part of the job.

If it’s good practice in journalism, ensuring conciseness and clarity is even more important in communicating workplace safety information, because there is so much more at stake. But there are too many examples of bloated documentation getting in the way of worker protection.

The construction scheme for the venues and accommodation for the 2012 Olympic Games is often held up as one of the most safe and healthy building projects of recent times. It was the first modern Olympiad to register no work-related fatalities. The so-called “big build” of the Olympic Park in east London, had more than 12,000 workers on site at its peak, the largest construction project in the world at the time.

The arrangements to protect workers were closely monitored by the Health and Safety Executive, which took what its chief inspector of construction called a “curiously critical” approach to the works, but the buildings topped out with no regulatory intervention, except to serve two prohibition notices. They both covered the same operation, a tandem lift involving two cranes hoisting a structural component. The HSE stopped the lift because it believed the contractor had planned it inadequately and issued confusing documentation. The confusion came partly from its length; the method statement for the lift ran to 90 pages, with no summary of the most critical points.

Lawrence Waterman, who oversaw safety arrangements for the client body the Olympics Delivery Authority (ODA), said to me that this everything-but-the kitchen-sink approach was like saying “I’ve got all the requirements in this document so I don’t have to think about it anymore.”

The enforcement action prompted a review of all the risk assessments and method statements on the Olympic site, and many were revised to shorten them or, where they needed to be very detailed, to highlight the key instructions.

Anyone putting together instructions that will be read by a non-specialist has to consider not just what is relevant – there may be a lot of that – but also what is really important and to make sure the first doesn’t obscure the second.

A more recent example of the risk of over-provision comes from a prosecution reported this February after a senior linesman working for the rail arm of infrastructure services and engineering contractor Amey sustained 55% burns and sight loss when he touched a live 25Kv overhead cable while carrying out snagging works at Kensal Green in west London.

Office of Rail and Road inspector Matthew McNeal, who led the prosecution, told IOSH Magazine that the works around Kensal Green were part of a much larger package of remedial work around Paddington station. In most areas the power to the overhead lines had been cut for the work to take place.

“The problem is that rather than the permit to work focusing specifically on the area the team was working in and clearly spelling out which bits of line were safe and where the isolation limits were,” McNeal said, “instead, the workers were briefed about the entire area of works around Paddington – a huge area. The briefing document was very complicated with only one part specifically relevant to the job these guys were doing that night. Their heads were spinning by the time they heard and read it all, so their takeaway understanding was that it’s all safe, all the lines were dead and earthed.”

It can be hard to see the wood for the trees when you have detailed knowledge of al the hazards involved in a process. But these examples show there is no virtue in completism; in the Amey case it severely impaired a life and landed the company a fine of more than half a million pounds. If your instructions fall at the last fence – at the point of use – because they are too comprehensive then at best all your work was for nothing and at worst you will have failed in your duty of care. So it’s worth keeping that question front of mind: could I improve this by simplifying it, and giving the finished text to somebody else to see if they can grasp the important parts easily.

“Never mind the quality, feel the width,” goes the old tailor’s joke. It was never a good maxim for judging cloth and it’s an even worse one for safety information.

Guest blog written by writer, editor and speaker, Louis Wustemann.