You can have your cake and eat it

file0001645959371Safety is Our Number One Priority!

Do they think we are stupid or what? Such a company slogan is one of the most illogical and naively transparent statements to make. If not hurting people in the workplace really was the number one priority the company would shut down and voluntarily go into liquidation – and then we would starve to death. As a former construction manager now turned academic my cynicism is founded on experience. What the companies really mean is that they are afraid of having to report bad statistics to a parent organisation.

This was neatly summarised by one of my fitters who, in sheer frustration at the many petty restrictions placed on him, burst out with “Too much safety makes you unsafe”. He was right. Fear of having accidents was inhibiting the men’s ability to exercise judgement and use their skills, and they were having accidents because of it.

Implicit in the statement that ‘safety is our number one priority’ is the assumption that you cannot be both productive and safe. Nothing could be further from the truth.

Across a range of industries it has been possible to demonstrate that the higher the levels of work output per man the lower are the injury rates (1). The reasons for this are not completely known but we have been able to identify many and make a good guess at many of the rest. Investment in technology is the most obvious one. Bits of kit that produce more also move people further away from what might hurt them.

But the fascinating reasons are the non technical ones. In the construction world that I come from experience tells me that, if you work with your men, work output goes up and injury rates go down. It is a novel thought that is lost on most senior managements and the health and safety profession. But, if you trust your workforce, they will eventually take the lead in solving the nut and bolt nitty gritty everyday problems that happen on a construction site.

At a site level, how the site is organised has a dramatic effect on both productivity and safety. For example we have been able to identify that the provision of local material ‘lay-down’ areas reduces injury rates as well as improving work output.

At an organisational level companies with a flat management structure and an empowered management have lower injury rates and, in these days of recession, surviving.  Surviving and thriving is the key. Health and Safety Institutions and regulators focus on avoiding accidents; it is a negative ‘away from’ strategy. I believe they should be trying to understand the relationship between good productivity and good safety; it is a positive ‘towards’ strategy.

Note (1) Data is presented in Figures 10.4 and 10.5 of ‘Safety Can’t Be Measured’ by Andrew Townsend due to be published by Gower in August

About Andrew Townsend 

Andrew was a self confessed ‘late developer’. When most people were carving out careers in management he was having “more fun surfing, sailing, skiing and managing a construction site”.  He attributed his instincts for protecting his workforce and his love of the English language to his schoolmaster father. When becoming physically disabled, his efforts focused on researching the link between safety and construction performance. Andrew Townsend passed away in September 2013.


  1. Les Henley Reply

    Hi Andrew,
    I’m afraid I have to disagree strongly with your opening statement. The concept of safety being number one priority is not necessarily “illogical and naively transparent”.
    I can understand your frustration with this type of slogan when it is used as a ‘butt covering’ value statement in a given organisation. But this is not the case in every organisation that adopts this particular ‘mantra’ or philosophy.

    Too often one organisation establishes a novel approach to WHS management and it works for them because they properly thought through, developed and implemented the system to suit their circumstance. Then when others hear of the succes they adopt the words without the substance thinking they’ll achieve the same outcomes. we’ve seen it with any number of ‘flavour of the month’ management philosophies – and not just in the WHS arena.

    In an organisation where ‘safety IS the number one priority’ it doesn’t mean safety is the ONLY priority. It shouldn’t mean we don’t accept any risk, or that we don’t have other priorities.

    Rather it should be taken as a recognition that there are many conflicting priorities in any business decision, but that we won’t decide to take a particular action if we can see that someone may get hurt.

    I developed a model some years ago that I refer to as ‘the Six Key Business Systems’. Basically it identifies the six functional business ‘silos’ of 1: Human Resource/Industrial Relations, 2: WHS & Workers Comp, 3: Operations, 4: Corporate Services (including Finance and asset management), 5: Records and Information Management, and 6: Environments – includes socio-political (eg: law, community) and green (resources and waste maangement). Overarching these six systems are the Continuous Improvement/Quality Assurance and Information Technology philosophies and processes. (I’d be happy to send you a copy if you send me your email address. Mine is You can adjust the titles and content of the six ‘silos’ to reflect any given organisation but essentially every organisation is structured around six.

    The model then shows a line between each system where a decision in one will have a direct impact on another. In fact it shows that a single decision in any system will have direct impact on all 5 other systems to varying degrees.

    For an organisation to say that Safety is our number 1 priority is not dismissing the other priorities. It is just indicating that in decision making processes Safety will have precedence over the other priorities which may put peoples’ safety at risk if the other ‘functions’ are given number one.

    Quite rightly, you indicate a direct link between safety and productivity. In some organisations I’ve worked for, production has taken priority over safety and yes, they may get more PRODUCTION but not necessarily better productivity, or even better quality outcomes. Because – in a unit cost model – every accident or machine breakdown has a direct impact on productivity.

    Rather than throwing the baby out with the bathwater, by decrying the poor use of a term or applicaiotn of the idea, we shoud be seeking to educate the uninformed so that the outcome is an overall improvement.

  2. Jon Temby Reply

    Hi Andrew

    You are right on the money, I totally agree that safety as the number one priority is a nonsense. Logically, if looking after our people is an accepted core value, then that value permeates all our decision-making and we generate safer and more productive workplaces as we integrate safe ways of doing things within every priority.

    Like you I have helped create and seen this in construction many times. I have also seen it working very positively in transport, manufacturing, warehousing and other sectors. In all workplaces, people usually respond positively to a positive and logical message delivered with integrity, especially in an environment where we encourage workforce engagement and help them to solve their own daily challenges.

    Our role as health and safety managers, consultants or whatever our title may be is to ‘teach people how to fish, not give them a fish’. Safety as the top priority insults our workforces and reflects badly on us, it is nearly as stifling and negative as Zero Harm is as a target rather than as an aspiration.


    1. Daniel Hummerdal Reply

      Jon, your comment made me realise this site is missing a ‘like’ function.

      If safety is defined as success, then the need for prioritising safety becomes a non-question – safety will align with other organisational goals.

      In any case, it makes a lot more sense to have goals/aspiration/values positioned ‘outside the temporal’ (Kierkegaard), ie not as a destination, but as a guiding principle for decision-making and practices. Unfortunately, organisational efforts to look good in the eyes of others may cloud such ideals. But perhaps not necessarily so..

      1. Jon Temby Reply

        What a great discussion, Andrew, Mike and Daniel have made great contributions but Mike I am trying to move from a Hierarchy of Controls you mention to Daniels ‘Hierarchy of Solutions’. The Hierarchy of Solutions appears to build greater engagement at all levels and therefore the likelihood of better, quicker and more sustainable solutions – and I have just tested it with a client with positive results.

        With safety as a core value integrated into the way we manage the organisation and with our thinking and language focussed on forward thinking approaches to resolve daily challenges, we are in a position for controlled innovation and greater success.

        The priority we place on something becomes immaterial to its safe and effective solution.

        1. Zinta Satins Reply

          Hi Jon,
          I often talk about solutions instead of controls when discussing safety. When coupled with a focus on success it has a way of opening up the discussion and opening up thinking. Lately I have been thinking about risk management and the hierarchy of control. I am starting to think that there isn’t a hierachy, even when focusing on the positive. In fact, I am starting to think that there shouldn’t be a systematic approach to safety in most aspects. I appeciate that this idea may be unnerving. But when looking for solutions that support success how can one solution be ranked in comparison to another using an external method? I find that the people involved in doing the job have an idea of what will work and what won’t. Listening to them will essentially replace a hierarchy.

          1. Andrew Townsend Post author Reply

            Zinta Hi – What got you into that way of thinking?

            How do people know you are prepared to listen?

  3. mikebehm Reply

    Les, perhaps what you’re saying is that safety is a value. Priorities, by their very definition, take precedence or order over other things; they can shift daily, hourly, sometimes more frequently. Values, on the other hand, are inherent to the organisational culture; they are intrinsic or integrated into the organisation; they fluctuate only very slightly. I am of the belief that if we mange safety as a value integrated with other functions, we are more likely to develop that consistent culture we desire. Furthermore, if we can instill that value throughout all levels of the organisation, then the OHS function may be more likely to get invited to the meetings that really matter where they can effectively utilise the hierarchy of controls. These are board meetings, finance meetings, design reviews, and other upstream decision making activities. Priorities can too easily be traded off against one another during the constant reevaluation processes. I think it might be just the wording.

    1. Les Henley Reply

      Hi Mike,
      No I’m actually saying that Safety is ALWAYS the top priority. So for example: when a decision is to be made and either safety OR production could take precedence (conflicting priorities) – safety is ALWAYS given top priority. Hence it may cost more in the short term to achieve a particular production or service output, productivity is protected because we make sure we don’t incur all the direct and indirect costs associated with hurting people.

    2. Les Henley Reply

      Hi again Mike,

      I was just thinking further through your comments and I can agree that ‘Safety is a value’. However unless it is quantified by giving it ‘top priority’ how do we value it in relation to the other values.
      For instance, alongside safety, we may value ‘delivery within promised timeframes’ as a quality standard to our customers.
      These two values may then, from time to time, become conflicting values.
      If something has caused a production holdup – maybe even raw materials not turning up on time – if we give precedence (top priority) to on-time delivery we may inadvertantly give the impression that on-time delivery ‘at any cost’ is acceptable.

  4. Andrew Townsend Post author Reply

    Hi Les and Mike – Thank you for your posts. ‘Value’ is a word often used in safety debates. Is value an organisational thing or a personal thing?

  5. Les Henley Reply

    Hi Andrew,
    I belive that values can be held by both individuals and organisations. In some instances the 2 can be conflicting.
    The organisational value is far more difficult to establish because you need to get everyone to ‘buy-in’.
    One example is the value of non-discrimination. As an individual I either hold this value and it guides my day to day actions towards people who are different to me or I don’t and my behaviour reflects my (non)value.
    An organisation involves lots of people, some of whom will hold this value intrisically and others who will not.
    Those who openly discriminate will stand out – often bullyng and harassment behaviours will be associated with this type of person. Their behaviours will clearly not be aligned with the organisational value.
    Then we get the ‘masking behaviours’.
    Other people, who in their private lives may be discriminatory, may act in a non-disciminatory way in order to ‘fit in’ to the organisation. We may still see some expression of ‘unacceptable’ behaviours from these people but in the main they will behave in manner compliant with the organisational value.
    The same with Safety as a personal and/or organisational value.
    I had a conversation with someone just this morning and it came up that there are still lots of people out there who think ‘safety is a joke’ – they won’t value it as I do, and they’ll struggle to implement the organisational value that ‘safety is our top priority’.

  6. Andrew Townsend Post author Reply

    Les – Thanks for that
    Can I assume that the level of buy in affects safety outcomes or am I being too simplistic?

    1. Les Henley Reply

      I don’t think you’re being too simplistic.
      Buy-in affects commitment, commitment affects compliance with implementation of established saftey standards – whether that is formally documented work procedures (SWPs) or application of processes for risk management in ‘novel’ situations.
      I’ve been in the workforce for 40 years. I started work as an apprentice fitter machinist. I’ve worked as a supervisor and a middle manager in heavy manufacturing (aluminium industry) and I’ve been both a consultant and practictioner of WHS for the last 20+ years.
      I’ve lost the last joint of my left middle finger (as a third year apprentice) and I have a significant burn scar on my right leg (as a fitter).
      I’ve seen all sorts of situations arise because one or other (or more) people didn’t ‘buy-in’ to safety. Often a manager or supervisor failure to ‘buy-in’ results in injuries to subordinates who don’t know any better.
      But to be fair, I don’t believe all injuries are directly attributable to ‘buy-in’. I have seen situations where subordniates have been injured simply because they were naive in thinking they could save time and dollars by cutting corners but failed to identify the hazards that bit them, where ordnarily they would comply wiht the saftey standards. I think the motive is admirable but the outcome all too often ends in some degree of tragedy and ends up costing far more than following the establsihed standards. I knew one man, I’d worked side by side with him as a fitter, who was killed as a result of this process.
      I’ve also seen fatalities that occurred because at the time no-one knew any better. My knowledge and experience of ‘killer’ confined spaces precedes any regulation in Australia – we just didn’t recognise the hazard and its risk that killed a 21YO lad just out of his apprenticeship.
      But yes ‘buy-in’ is an imperative that directly affects safety outcomes in every workplace.

        1. Les Henley Reply

          Nice try Andrew – but No, not just buy-in to compliance with standards – buy-in to managing safety as number one priority, which will encompass establishing and implementing acceptable and agreed standards in a given organisation.
          Legislation and regulations establish MIMIMUM standards for our society, but they do not tell us HOW to achieve them. They need to be interpreted and applied in each given circumsatnce or situation.
          See my reponse to Zinta below re Systematic Management of safety.

    2. Les Henley Reply

      Hi Zinta,
      Like you, I didn’t start in safety but came to it some 20+ years ago. (a precis of my experience is in my previous response to Andrew above).
      But I believe there is a systematic aproach to managing safety and I believe the system is embodied in the harmonised legislation in Australia.
      First we need to define what we mean by system – I understand it to mean a finite set of inputs/processes/outputs. Systematic management will focus on ensuring an acceptable balance between costs and benefits across the system. Injuries are generally unacceptable costs.
      So a safety system will involve inputs(people, knowledge, time, technical resources) /processes (identify, assess, control, monitor & review – usually established as policies and procedures) /outputs (reduced losses arising from incidents and injuries).
      And a systematic approach to managing safety will examine the finite sets of operational inputs/processes/outputs for hazards and associated risks, assess whether the risk is acceptable or not, and if not find suitable ‘controls’ (which is just another way of saying ‘find solutions’) to bring the risk to an acceptable level.
      Further, the section 19(3) establishes more details for a systematic approach for identifying hazards – I call them the 4Ps – Place, Plant & Substance, Process and People.
      Every task involves Inputs(place, plant & substance, people)/processes/outputs (product made or service completed).
      So a systematic approach to managing safety will involve examining the task’s 4Ps to identify hazards that may result in unacceptable costs in the form of injuries.
      We can categorise hazards further into groups or classes – the most common being: electrical/mechanical (machines and power related), Physical (affecting the body’s systems (noise, vibration), biological (usually involving invasion or attack by animals and/or microbial organisms), chemical, and psychological (stress, phobias). Some people expand the list to include others.
      Basically we use these categories (knowledge inputs) to etsbalish suitable processes to identify the hazards in each category. For instance, as an industrial hygienist, you would know that we identify airborne chemicals exposure using a different process to that for identifying noise exposure (technical resources). And we use different processes again for identifying mechanical/electrical hazards, and so on.
      Next we apply the hierarchy of controls, (again embodied in the regulation to reduce the likelihood that ‘cost managers’ will jump to the cheapest cost option) in conjunction with cost/benefit analysis, in order to find the optimum cost (reasonably practicable) controls (or solutions) to eliminate or reduce the risk to an acceptable level.
      So, in 20+ years, and living through 3 legislative changes in NSW (1983, 2000 and 2011), this ‘systematic approach’ whilst being more finely tuned each time, has stood the test of time.
      Every time I have taught people to apply this approach they have recognised significant reductions in adverse costs and improvement in productivity outputs.
      I will remain a champion for ‘systematic management safety’ until someone can show me a better outcome using an alternate approach.
      And my ‘teaching style’ varies depending on the context – I have taught WHS in TAFE classrooms, and I have taught ‘Risk Management’ on contract in multiple workplaces in multiple industries, and I teach people daily through conversational interactions.

      1. Andrew Townsend Post author Reply

        Les – I think I am beginning to understand. When you talk about boundaries, inputs/outputs and controls, it sounds very similar to the operating envelope, heat and mass balances and the control theory used in process plant. It all can be simulated?


        1. Les Henley Reply

          That’s right Andrew – You’ve got it.
          A really simple example I use in training for ‘task risk analysis’ was examining the process (task) ‘make a cup of tea’. A task most of us take for granted every day without considering it’s potential for harm.
          Depending on the group the inputs/process/outputs were defined differently. Some goups use an electric jug/kettle, other use a zip water heater. Some might use a teapot with loose leaves other might use a teabag in a cup.
          The differences affect the range of inputs, and details of the steps in the rpocess – whether to fill a jug and boil the water or simply add water from the zip heater.
          Once the steps are agreed in this way the hazards can be idenitified. Eg filling and carrying a jug of water involves higher risk manual handling than filling a cup with hot water from a zip. And whether the jug has a top handle or a side handle changes that again. But depending on where the zip is mounted (and how high) exposure of face and arms to splashes from hot water is higher for the zip.
          So you see that ‘buy-in’, to at least examine the safety of the plethora of workplace processes is the only way we’ll get the resources to to do the analysis, and once complete the commitment to comply with the agreed outcome which may be in the form of a safe work procedure.

          1. Andrew Townsend Post author Reply

            Les – Thanks. Given that I used to be a chemical engineer I think you are describing a closed system where all the inputs are known and the processes can be predicted? How close am I? Are the safety management processes the same for all industries?

            1. Les Henley Reply

              In my experience the systematic approach that I follow and teach to others sapplies to all industries that I have worked in.
              The variables are in the different resources, processes and outputs and their associated hazards and ‘controls’ or solutions.
              1: define the system/task/process to be analysed – this establsihes the ‘boundaries’ for the analysis.
              2: identify the inputs, processes and outputs
              3: identify the hazards associated with each inputs, processes and outputs – some outputs are inherently hazardous eg: petrol when it is refined from crude oil.
              4: assess the likelihood that something could go wrong and the likely consequences that may result (some people use worst case consequences, I prefer most likely as in a fire in a buiilding may cause death (worst case) or smoke inhalation and/or burns (most likely).
              5: For any unacceptable risks – identify a range of options to control – I use the hierarchy to get people thnking beyond PPE (which used to be a first reaction every time) and to consider 2 or more alternatives
              6: cost benefit analysis for each option – start with potential for risk reduction – if it doesn’t change the likelihood or consequence discard it. Also consider whether the control will introduce different hazards. and repeat steps 4-6.
              7: Select the best cost option – reduces risk to acceptable level at a reasonable cost, rather than most expencive for only a marginal further risk reduction.
              8: Implement to preferred option
              9: Monitor then review the outcomes – did we achieve what we aimed for?

  7. Zinta Satins Reply

    Hi Andrew,

    What got me into my way of thinking? Safety was not my first choice for a career. Like many of us of my vintage I started falling into safety 20 years ago when I went from being a chemist to an industrial hygienist. None the less I fell in love with safety and there are 2 reasons why. The first is that I love helping people and second is that I love problem solving (I can do both of these in safety). I think that this is why I have always been solution focused. The switch to using positive language is a more recent change and mostly thanks to Daniel.

    My current thinking on safety is that there isn’t a systematic approach to safety. I believe that safety is about creating an environment where solutions are developed that contribute to success. If you take that thought through to its conclusion it stands to reason that you can’t even begin to provide an approach. The local context will determine the approach needed to create a solutions focused environment.

    People may not initially know that I am prepared to listen. But through my approach, the way I speak, the way that I work with them to come up with solutions, ask questions, change my ideas – people get the idea pretty quickly.

  8. Andrew Townsend Post author Reply

    Les – I am away to my bed now. Question for while I am asleep. I think you are describing a quantitative relative risk assessment.(similar to epidemiology). Where does the source data come from? Databases, experience, research…other?


    1. Les Henley Reply

      Andrew – I like to think to think that the risk assessment is a combination of quantitative and qualitative.
      Firstly – we do a risk assessment to determine whether we need to act to reduce risk and Secondly the assessment result allows us to ‘rank’ multiple risks for allocation of scarce resources for addressing them.
      The quantitative component covers the likelihood – 1: number people exposed, 2: number of exposures per person, 3: duration of each exposure. This allows a semi-objective assessment of likelihood – but the numbers are provided by those at the operations level that have some knowledge of the workplace and who may be present there. The 3 vales are summed to give a raw likelihood score (there may be some subjectivity or arbitrary choice over some numbers and often result in large numbers if many people/many exposures are anticipated).
      For comparison purposes the likelihood scores are then ranked into 4 quartiles and scored 1/2/3/4 (4 being highest).

      The qualitative component is used to assess the Consequences –
      first – describe types of injuries/illnesses that may arise as a result of an incident. This information may come from ‘brainstorming’ and/or experience.
      Next translate them to one category from the following list: first aid/medical treatment/lost time/permanent disability or fatality. We use scores for each of the consequence ‘ratings’ being 1/2/4/8 – notice the weighting radically elevates the more serious consequences. This allows the consequence component also to be compared with other risks.

      We then multiply the likelihood score (1/2/3/4) by the consequence score (1/2/4/8) to arrive at a quantitative risk score between 1 & 32 (significantly more widespread (for differentiation) than the old WorkCover NSW Risk assessment matrix of 1-7. (if you are aware of that).

      In my current organisation this process is automated in a ‘risk register’ database. The oprator simply inputs the values (number and words), selects the consequence level and the database calculates, ranks and sorts all risks into an ordered list based on the risk score.
      The beauty in this is that the information used to arrive at the risk score is captured to enable analsyis if something goes wrong and we need to review the assessment.

  9. Andrew Townsend Post author Reply

    OK – That gives a relative risk score which allows prioritising of resources. How about absolute risk? How much does that reduce injury rates by?

    1. Les Henley Reply

      Andrew, I have to admit I’m not familiar with the term ‘absolute risk’. What do you mean by it and how is it defined?
      It strikes me that any reference in WHS matters to an ‘absolute’ would be fraught with danger – eg: cehck out all the adverse press that ‘zero harm’ gets – zero being an absolute that we are convinced we cannot achieve.
      On the basis of human differences – incorporating stuff like knowlege, skill, experience, etc – how could re rate ANY risk as absolute?
      Aside form this, when I read the WHS act and regs I don’t see that we have any need to identify ‘absolute’ risk. We just have to make things ‘as safe as reasonably practicable.
      And it’s not the risk rating that results in reduced injury rates. It’s the implementation of corrective actions (controls or soultions) that achieves the reduction.
      In some instances it’s not a reduction in number of injuries so much as reduction in severity that indicates some success with risk management outcomes.
      In other instances we do see reduced incident rates too.

      1. Andrew Townsend Post author Reply

        Les – my apologies. I was using terms from epidemiology [I was taught my stats by an epidemiologist].
        There are three types of risk
        Relative risk e.g. you are 28 times more likely to die from natural causes
        Attributal risk – what proportion of total risk is represented by (say) getting fingers caught in machinery
        Absolute risk – i.e. there is a 0.05% probability of dying at work.
        It strikes me that the techniques you describe can be used to estimate relative risk and attributal risk but not absolute risk.
        However calculation of absolute risk involves comparing the safety performance of organisations that do not use you use your techniques [the control group] with those who do [the study group].

        I am not sure I am explaining myself very well.


        1. Les Henley Reply

          Andrew – although I’ve not seen these definitions before – I do understand what you’re saying.
          But I’m still puzzled by the use of the term ‘absolute risk’ in conjunction with the term ‘probability’.
          In my understanding the term ‘absolute’ indicates a specific condition/score that doesn’t involve probabilities – either it is or it isn’t.
          The following is from by way of example:
          1. free from imperfection; complete; perfect: absolute liberty.
          2. not mixed or adulterated; pure: absolute alcohol.
          3. complete; outright: an absolute lie; an absolute denial.
          4. free from restriction or limitation; not limited in any way: absolute command; absolute freedom.
          5. unrestrained or unlimited by a constitution, counterbalancing group, etc., in the exercise of governmental power, especially when arbitrary or despotic: an absolute monarch.
          And as my previous response, there are no absolutes when dealing with people in relation to risk.

          1. Andrew Townsend Post author Reply

            Les – I definitely didn’t eplain absolute risk very well.

            Just to make sure I have understood, I will recap. The techniques you describe are similar to the processes I know from my days as a chemical engineer in an oil refinery. Within the limits of our ability to measure and simulate they follow immutable physical laws – they are very precise. We can do heat and mass balance calculations and reconciliations to +/- 0.5%.

            The word ‘control’ for me is very precise – it comes from process control theory and practice.

            I am beginning to get confused – we are appplying very precise techniques to very imprecise animals “there are absolutes when dealing with people”.

            Or am I confusing a management technique/tool with an engineering metaphor?


            1. Les Henley Reply

              Andrew – I think your last sentence may be the case.
              At its base, WHS and systematic management is about managing the risk to an acceptable level – what’s acceptable to me may not be for you based on our human differences. But we can agree together (consultaiton) on what is acceptable for ‘us’ (the organisaiton).
              Then we manage the variables (inputs and processes) to achieve the agreed reduction in risk.
              When we consider the hierarchy of controls we can see that:
              1: PPE does not directly affect the hazard to reduce the risk. It simply places a barrier between the hazard and the PPE user (like knights wearing armour) – this doesn’t prevent incidents but results in reduced severity of outcomes. But only if the PPE is appropriate to the hazard, maintained in good condition and fitted correctly by the wearer – again many points where the ‘control’ can fail.
              2: Administrative controls (including training, licencing, permits, written procedures) rely on people complying with the defined administrative process. And we know that even individual people vary day by day in their attention/application, etc of these types of controls.
              Hence relying on People to properly fit/maintain/store PPE, or follow administrative controls, is still likely to be significantly variable even day to day for one individual, much more if many individuals need to comply. So we can’t rely on those approaches to reduce risk with any certainty.
              Hence we need to find controls further up the hierarchy which directly modify the hazard resulting in a more certain and durable risk reduction that does not rely on people, who by their nature, are fallible.
              I usually refer to these two groups of controls as ‘soft’ (relying on people) and ‘hard’ (making phsyical changes to hazards).
              Finally, can I encourage you (and anyone else reading this lengthly exchange) to not focus too heavily on the ‘risk assessment’ phase of managing safety.
              The laws don’t specifically require ANY formal process in risk assessment. Rather they require us to ‘ensure health and safety so far as is reasonably practicable’.
              The aim then must be to agree on what is acceptable (reasonably practicable) or not, then make changes to bring all risks to an acceptable standard. As in one of my earlier replies, the risk assessment methodolgy only assists in measuring ‘acceptability’ and then ranking risks for attention with scarce resources.

  10. Andrew Townsend Post author Reply

    Les – Slight correction in detail – UK regulation revolves around ‘risk aassessment’ as opposed to statute which revolves around duties of care and SFARP. Unfortunately the UK regulator cannot quantify just how much the law and enforcement reduces injury and fatality rates and its budgets are being cut. Same thing is happening to regulators all over the world. H&S is the survival game.

    Unless it can at least estimate how much it reduces injury rates by its scarce reources will become even scarcer! Hence I am interested in how much your techniques reduce injury rates by!


    1. Les Henley Reply

      Andrew – I’ve written elsewhere on this and other blog sites that I am unable to ‘prove’ that my interventions have been contributing to reduced incidents.
      I defy anyone to ‘prove’ that they have caused a reduction. Just like a doctor cannot prove that the immunisaitons I had as a child actually prevented me from contracting the diseases that I was immunised against.
      All I can do is show that incident statistics have changed in a positive direction during the period that I have been applying my approach. We can reasonably ‘infer’ that the approach has influenced the change but can’t prove it is solely responsible.
      If you’re not familiar with it, google the ‘hawthorn experiment’ to assist you in understanding why sometimes just paying attention to employees has a positive influence on their behaviours.

      1. Andrew Townsend Post author Reply

        Les – It is a point that I feel strongly about. There are in fact accesssible stats via the International Labour Organisation in Geneva, the United Nations Economic Commission for Europe and the Bureau of Labour Statistics in the USA that suggest (you are right you can’t prove anything with stats) that rules based formulaic approaches to H&S acheived great things during the seventies and eighties but have now levelled off. Without them we would not be where we are today. However the qualitative evidence is that clumsily applied (present company excepted) they now engender fear of reporting at a corporate and a national level.

        The stats strongly indicate that rules based societies have two or three times higher fatality and injury rates than societies with a facilitating approach. I owe you an apology. I am aware of the Hawthorn effect, mainly because I have been studying the social psychology and sociological links to safety for almost ten years but, since many H&S professionals are openly antagonistic, towards social sciences, I chose to initially keep quiet about it.

        Of course a doctor can prove immunisation prevents children from contracting diseases – it is what the profession of epidemiology is all about.

        I will stick to my views that what epidemiology has achieved in community medicine H&S ought to be able to achieve. No kidding – governments around the world are savagely cutting the budgets of regulators: industry is becoming p—-d off with the bureaucracy. The moral imperative to reduce harm remains but unless the H&S communities around the world wise up to the fact they have to produce stats to show they are effective they will beco,e marginalised. It is already happening in the UK!


        1. Les Henley Reply

          Andrew – just to be provocative in order to keep you thinking and reasoning – how does a dr PROVE that an immunisation actually prevented someone from contracting a disease? They would first have to prove that the specific person would have been exposed to the disease AND that they would have contracted it from such exposure. Even during the plague in London there were people exposed to the disease that did not contract it.
          I understand that the statistics show that the incidence of such (immunisable) diseases has fallen radically, with some even being eradicated completely in some parts of the world. But there may be other contributing factors that have also contributed apart from immunisation. Education in general hygiene, and modified behaviours including isolation of infected parties are 2 such contributors. Not to mention increasing immunity through genetic transfers.
          As for the slashing of funding – I’m with you. Regulators may not be able to prove statistically that they have contributed to reduced incidence, but even the focus on WHS, through changes and improvements to legislation, and with the associated media coverage, would have made some contribution.
          As per one of my earlier responses – there may be organisations (and managers of them) that do not intrinsically value safety but have complied with the laws due to ‘fear’ of prosecution (we call these ‘cowboy’ organisations in Australia), these organisations are likely to be the first ones to cease complying as the media coverage indicates that they are less likely to be caught and prosecuted as result of a reduction in regualtor resources.
          The ‘fair dinkum’ organisations will keep doing the right thing anyway because it makes good business sense.

          1. Andrew Townsend Post author Reply

            Les – You are not being provocative at all. It is a very relevent question. I do not believe that you can prove that any one person will/will not have an accident. That is about as stupid as Du Pont’s ‘all accidents are preventable’ . The best one can do is to use stats to establish a principle.

            The way that confounding variables are eliminated is to do ‘cohort studes’ . The best example is the work done by Richard Doll on smoking. The first cohort he studied was doctors.

            The way to check that is to then repeat the study with another cohort or to do a study over a period of time.

            The checking or validation process is important – for example we can be reasonably sure that there are strong external influences on work place accidents from the relationship between workplace accidents and automobile accidents. The relationship exists at a UK regional level, an EU national level and at a USA state level.


  11. Andrew Townsend Post author Reply

    Les – I am not sure what the Australian accounting conventions are in annual financial reports but one way to spot the difference between the ‘cowboy’ and ‘fair dinkum’ organisations is….

    Cowboys have lower turnover per employee and a higher proportion of ‘light and fluffy’ press releases in the style of “Fred Nerd of our XXX office does sponsored cycle ride for local school”

    Fair dinkums have higher turnover per employee and stick to reporting business facts.

    “Empty vessels make the most noise” ; either that or I have become a miserable cynic in my old age!


    1. Les Henley Reply

      Andrew – I have to confess that I don’t take a lot (any) interest in the ‘bigger picture’ of Australian economic matters.
      But I’m aware that cowboys also have higher turnover of employees and higher incident rates, though the latter will rarely be reported.
      It stands to reason that Fair Dinmkums have a higher productivity – as before they know that safety is its own reward – lower incident rates results in lower costs(compared to cowboys) and better morale further resulting in lower staff turnover, in turn making more cost savings due to lower recruitment/replacement costs.
      I’ll never understand why cowboy executives and managers don’t get this.

  12. Andrew Townsend Post author Reply

    erratum – ‘turnover’ should reead ‘financial turnover’ i.e. volume of business
    Also see figs 10.4 and 10.5 which I have emailed separately.

    You are still thinking avoidance of unplanned costs; that is an ‘away from’ strategy. I believe you should be asking the questions ‘ what organisational actions give both improved work output per man and reduce risk?’


  13. Les Henley Reply

    I realised that about turnover – based on the per employee. I was drawing the distinction re employee turnover being higher for cowboys – either they are killing/maiming their employees or smarter ones walk before they die once they realise their employer treats people as expendable.
    One of the key issues I always raised when I do any public/general teaching in H&S is to encourage people to consider the conflicting risk of ‘my job or my (quality of) life?’. Why would you work for someone who doesn’t value your life over the $$$$profit margin? And if you’re dead or maimed what good will your job be then?.
    An no, my thinking is that actions that achieve improved productivity and improved (reduced) risk of incidents results in reduced unplanned costs. Fair Dinkum operators have recognised this, cowboys haven’t.

    1. Andrew Townsend Post author Reply

      Spot on – for reasons which we haven’t yet fully idenified (but we are about to start researching them) the companies that have the lowest injury rates also are the most stable and consistently produce higher levels of profitability.


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