The London Luton Airport Safety Differently Journey

I hear lots of people saying how much they like the principles of safety differently, but just do not know how, or where to start with this as none of the books tell you how to do it.

As my time at London Luton Airport draws to a close, I’m going to try to summarise the journey from a traditional approach into embracing a new focus based on the safety differently framework.

When I first started at Luton, there was plenty of work to be done. After initial review, a new management system was produced and safety started to improve. Indicators at the time were 30 LTI’s a year and 20 RIDDOR’s. OHSAS18001 was awarded in 2013 which was a huge achievement at the time considering where we had come from. It was largely traditional methods that achieved this and gave some consistency to provide a springboard for our next journey.

It was 2016 when the business first bottomed out at zero for RIDDOR’s and LTI’s, when another Senior Manager commented that it was ‘pipe and slippers’ time, as we’d cracked it and there was nothing left to do! I felt like I was hardly getting started, but I knew deep down (due to my high level athletics career) that there must be something out there that could still take us further. I constantly asked myself the question ‘are we really safe?’ and does the absence of accidents really mean we are ultimately safe? I felt an aura of inactivity for learning as numbers were so low.

This was further intensified when I saw Albert Einstein’s quote on insanity: ‘doing something over and over again and expecting different results’. I started challenging myself and my beliefs along with speaking to a wide variety of people within the industry which only intensified my craving for another method or focus. One day I heard REM – Losing My Religion on the radio and thought ‘that’s me with safety’.  It was just after this point that I met with some truly inspirational individuals, first Daniel Hummerdal, then John Green and finally Sidney Dekker.

It was after a masterclass and plenty of discussions with Daniel that I knew I was going to try my interpretation of safety differently, but that all so popular question was present – Where do you start? Here goes……..

Selling the new approach was first up, I met with my boss Nick Barton, the CEO who listened intently and questioned rigorously. I think the main penny drop moment for most is when asked the following question: Is it progressive for a business to only learn after a negative outcome event? Following this conversation, I would regularly challenge in meetings about not focussing on negatives and learning from successful outcomes, empowerment and innovation. The seeds were starting to sow! I wanted to plant these seeds before going live to the business.

If we were to successfully decentralise, devolve and declutter, there was some additional work to be done. If I was to ask employees to self manage risk then I had to ensure that everybody had a base level of dynamic risk management skills. This is where I engaged with Justin Hughes from Mission Excellence who used skills ascertained as a fighter pilot and Red Arrows pilot to roll out some dynamic risk management under pressure training. I had to build trust in my team so we were viewed as ‘enablers’ and not ‘constrainers’. This lead me to changing the behaviours of my team and renaming them ‘HSE Coaches’ with the sole intention of coaching, mentoring, developing and facilitating. In many places it is habitual to blame the person involved in any accident or incident without looking deeper for the drivers which influenced that person’s course of action. This is where you usually find the real root cause, which is often an organisational failure. Traditionally safety people look to ‘detect and correct’ but I tried to re-programme the coaches to view variation as an insight instead. Follow three simple words when viewing variation…….. Ask, listen and understand. The result was a success, with the coaches viewed more positively and trust being built.

I started the roll out in our Cargo Centre by presenting on the broad principles of safety differently which progressed on to appreciative investigations and then going out and doing some with the team. In our first batch, we uncovered some great finds with operatives being put at risk and not working to the agreed safe systems as they said it was not possible to do so. This particular scenario was the transportation of coffins in a confined trailer. The operative would need to climb in beside and use finger tips to move the coffin so that the other operatives could manoeuvre the coffin out at the other end. The outcome of this is a redesigned trailer (by the operatives) which is totally fit for purpose. The Cargo staff said that the only way historically that this would have been resolved, would have been if there was an accident or incident, and this would have probably resulted in somebody being disciplined. From this point the Cargo staff were very enthusiastic when seeing the benefits of proactively looking at their tasks, most importantly with their input as the expert.

Another interesting find was when a work as imagined vs work as done review was undertaken. This task involved the decanting of large cargo pallets to split the loads and reallocate to other loads. This involves the use of a lowering work platform. We were about ten minutes in when one of the operatives asked if we could stop. I asked why and he said ‘we don’t even do it like this’. I asked why and he said they do it off the floor as there is a fall from height risk on the platform which cannot be guarded without affecting the operation of the platform. We talked through the actual ‘work as done’ and agreed that this approach had different risks but no higher than the work as imagined way. A new safe system of work was developed and implemented only for a different team to say they preferred the original method. I then made the decision to empower the team to undertake the task in either of the agreed methods as they are the expert and are competent enough to choose how they undertake that task. This was our first dual system task at the airport which is working very well.

When approaching the first revision of the H&S policy, I only subtlety introduced a few of the theories as I did not want to bombard the workforce with another ‘management fad’, which they felt may disappear in time. I did this so, when I produced the second more defined policy, people would look and think ‘we already do a lot of that’. This proved to be a great success. I’ve just prepared version three, which I would say is practically the finished article. When defining these policies I needed to come up with a strap line which people could associate with, so we opted for: ‘“Safety is not about the absence accidents, it’s the presence of trust, ownership, engagement and positives”. This fits in with our belief that the currency of safety is ‘information’ (Thanks Ivan Pupulidy) and that there are many things that can affect the flow of information, that’s why we value ourselves on ensuring that ‘information’ is as honest and free flowing as possible within all levels of the organisation.

Another area that needed to be changed was our KPI’s. Historically they were all negative outcomes such as RIDDOR’s, LTI’s and number of accidents etc, so in year one we agreed to split these 50/50 and year two went 100% positive outcome. I generally devise this from the output of the employee survey as I ask specific questions to ascertain what is important to the employees and then devise appropriate KPI’s from the feedback. Before you think it…….. I still know how many negative events there have been, I just don’t tell the employees how badly they are doing as it doesn’t really provide motivation.

One of the biggest hurdles to overcome was transitioning from the practice of habitually blaming the person when anything happened, as do plenty of businesses that I’ve come across. If I had a pound for every time I’ve heard ‘if only they had followed the safe system of work’ I’d be a rich man! How about thinking along the lines of ‘who actually comes to work with the intention of getting injured?’ How about another deeper cause that it could be an organisational failure? Have we failed the person organisationally which drives and influences the individual to make a decision to get the job done? This could be operational pressure, bonus related, target related, lack of resource, inaccurate process/procedures or incorrect equipment etc. I needed to enable people to learn differently by not jumping to conclusions, talking to the frontline employees without a ‘detect and correct’ or blame mentality. I needed them to view variation as an insight and then let it be explained fully by following the ‘ask, listen understand’ methodology. This way the real expert was giving their perceptions and rationale of how they manage risk and the reasons why. We could also learn from positives by undertaking work as imagined vs work as done reviews, appreciative investigations and learning reviews which significantly contributed to altering to a learning culture from a blame culture. This also assisted in building trust at all levels as the fear of retribution was gradually diminishing by us following Sidney Dekker’s restorative just culture model for all health and safety events.

Employees at all levels have enjoyed the empowerment, trust and autonomy afforded to them and ability to use their natural risk management skills whilst performing tasks that they are the expert in. There is no fear of retribution when one of the coaches are present as it’s always constructive conversation rather than telling them that they are doing something wrong or telling them how to do their job. Bureaucracy has been rationalised in some areas so only what is needed is present.

Plenty of impact has been made just by the pure use of language as certain words carry stigma. Here are some the changes: Advisors to Coaches, Accident to learning event, accident investigation to learning review and audits to continuous improvement opportunity.

One addition that has had a great impact is that when undertaking a traditional accident investigation (learning review here) a work as imagined vs work as done is undertaken with various other operatives to understand if what the injured person was doing was normal practice across the board or an isolated incident. This has to date provided some great learning opportunities that would probably not been identified if this exercise was not added to the learning review.

One question that I’m always asked about this approach is ‘what does the regulator think?’ I can honestly say that every regulator that I’ve discussed this with has been very supportive, as much to popular belief we don’t just say ‘crack on boys and make it up as you go along’ and ‘we are not bothered about smaller accidents and injuries’. We are still fully compliant with regulatory standards and requirements, we just go about meeting that compliance from a different viewpoint. We are not obsessive about continuous audits and inspections to find fault, we examine normal work to identify collaborative improvement which meets those requirements. Regulators have actually disclosed that they are supportive of this approach as it takes collaboration and engagement to another level by using the skills and knowledge of the experts who actually perform the role.

I was also challenged by many who said it was impossible to get the new ISO45001 standard using the safety differently model. I am very pleased to say that in October of 2018, we were recommended for accreditation with zero non conformity actions raised against us. To our knowledge, this makes us the first UK Airport Operator to achieve the standard and one of the first businesses globally to get the standard using this model.

Below is part of the feedback in our report:

A positive approach to health and safety is clearly embedded within the company this was demonstrated across all levels and functions. Collaboration of information discussed with the leadership team confirmed this.

There is a unique philosophy of “Safety Differently” that is led from the top and cascaded down throughout the organisation. The approach that gives people autonomy, trusting their staff, listening to them and engaging with them.

The company are achieving their strategic goal of running LLA in a proactive, positive, safe and responsible manner.

Positive findings from this visit include:

  • Establishing, monitoring and communicating objectives bases upon the employee engagement survey
  • Communication channels and collaboration with interested third parties
  • Leadership commitment to achieving a positive health and safety culture throughout the organisation.

The company have fully reviewed their management system to meet the requirements of ISO45001:2018, this has been subject to full assessment during this visit and is confirmed as meeting the requirements of the standard.

As my time at London Luton Airport draws to a close, I’m immensely proud of the journey the airport is now on. I thank my team, all employees and former CEO Nick Barton for having the trust and belief in me to take H&S in another direction.

I’ve tried to keep this paper relevant to answer the question of how to do it, but if I included everything it would turn into a short novel, so hopefully it’s given you some direction and pointers in the right direction. I’ll be moving into the rail industry to replicate this approach in the New Year and will be open to sharing my next journey.


  1. Bud Hudspith Reply


    The various disputes at Luton airport have thwarted all of my attempts to visit, and now I read that you are leaving!

    I would still like to keep in touch since the practical application of Safety Differently” remains a major issue for me. I would be very interested to keep in touch and hear how you plan to apply “Safety Differently” in your new post.

    I have been talking to HSE about their approach to “Safety Differently”. Unfortunately it is very slow going, although they have been very strong for years on involving the people doing the job and carrying out complete and good risk assessments by finding out what actually happens in the workplace.


    Bud Hudspith
    National H&S Adviser
    Unite the Union | 128 Theobald’s Road | Holborn| London | WC1X 8TN
    07881 588917
    020 7611 2533

  2. Paul Bussey Reply

    An excellant report on Safety Differently, Simon.
    The RIBA are developing CDM Differently on all our architectural projects which is empowering architect designers to be positive with H&S decisions whilst securing innovation and good design.
    Good luck in the rail industry, they need a big wake up to get them away from traditional H&S,
    Paul Bussey

    1. Simon Bown Post author Reply

      Thanks Paul, this is the beauty of this framework…….. it can be applied to virtually anything
      I’ll do another piece on the rail journey!
      Good luck and I hope it goes well

      1. Paul Bussey Reply

        Simon, I can sense a growing synergy with Safety Differently within the UK but everyone is too scared to embrace it except for a few pioneering types such as yourself and the respondees.
        How about we try to get a UK momentum with inter-disciplinary support and a conference? I might be able to set something up in the RIBA main conference hall or something smaller if required?
        Any support for this initiative?
        Paul Bussey (Architect . Principal Designer , CDM Differently)

        1. Simon Bown Post author Reply

          Hi Paul

          Happy to be involved, your right there are many people who want to do this but just do not know where to start as none of the books tell you how.

          Let’s have a chat when convenient


  3. Barry Nelson Reply

    Fantastic article Simon, thanks for taking the time to document your journey for us.

    You mention an employee engagement survey used to establish, monitor and communicate objectives. I’m curious to know if the content of the survey is something you developed in house, or did you rely on a pre-existing survey available to your industry?


    1. Simon Bown Post author Reply

      Hi Barry
      Thanks for the feedback
      I developed this myself as everything off the shelf was too long and traditional so I couldn’t get the output that I wanted. It was 10 questions based around how the employees felt towards safety and their frustrations whilst performing normal work.
      Give it a go and you’ll be amazed at what you learn from the feedback!

  4. Richard Abbott Reply

    Thanks Simon for this report. I’m especially interested in examples of practical implementations of “safety differently” concepts and their acceptance by regulators. As a former FAA safety regulator and current safety professional, it’s hard for me to envision the FAA transitioning away from the traditional safety model. Your story gives me hope!


  5. carrilloconsultants Reply

    Hello Simon, You have a great story that will encourage others to step into Safety Differently. In my experience the most difficult piece is building the supportive relationships you need to move forward with initiatives like retraining HSE into coaches and so forth. Do you feel that Nick Barton, the CEO, was open to listening because of his own predisposition or did you have to work on the relationship with him first?

    1. Simon Bown Post author Reply

      Historically Nick was as traditional as they come but he is an intelligent man and once I shared the theory, backed it up and then demonstrated the mini experiments he was more than comfortable to go with it and even spoke about it at our shareholder conference!

  6. Simon Bown Post author Reply

    Thanks Rean
    I think I’ll leave the books to Sidney etc for a while! I will try to post more though to share my experiences

  7. Steve Picton Reply

    Thanks Simon,
    Like Bud, never got the opportunity to visit you at LA but would welcome the chance to keep in touch and learn ways to practically apply Safety Differently.

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