OHS Professional Magazine December 2023 by Australian Institute of Health & Safety

PROFESSIONAL A US T R A L I A N I N S T I T U T E O F H E A LT H & S A F E T Y P U B L I C AT I O N

DECE MBER 2023

SMEs:

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leading OHS from the front and the top

ESG and ratings agencies: legitimising flawed metrics?

Careless workers, risks and safety metrics: what really matters?

WorkSafe Victoria: leading the regulator with Narelle Beer

OHS in SMEs: leading

from the front and the top: Leadership, culture, communication, systems and process all play a critical role in driving effective WHS outcomes for SME businesses

contents DECEMBER 2023

OHS Professional Published by the Australian Institute of Health & Safety (AIHS) Ltd. ACN 151 339 329

ESG: legitimising flawed metrics? Relying on ESG rating agencies’ preferred safety metrics can blind organisations to their fatal and catastrophic risks, writes Sean Brady

The AIHS publishes OHS Professional magazine, which is published quarterly and distributed to members of the AIHS. The AIHS is Australia’s professional body for health & safety professionals. With more than 70 years’ experience and a membership base of 4000, the AIHS aims to develop, maintain and promote a body of knowledge that defines professional practice in OHS.

Phone: (03) 8336 1995 Postal address PO Box 1376 Kensington VIC 3031 Street address 3.02, 20 Bruce Street Kensington VIC 3031 Membership enquiries E: membership@aihs.org.au Editorial Craig Donaldson E: ohsmagazine@aihs.org.au Design/Production Anthony Vandenberg E: ant@featherbricktruck.com.au Proofreader Lorna Hudson Printing/Distribution SpotPress

Advertising enquiries Advertising Manager Natalie Hall M: 0403 173 074 E: natalie@aihs.org.au For the OHS Professional magazine media kit, visit www.aihs.org.au.

Disclaimer: The opinions expressed within are those of the authors and do not necessarily reflect AIHS opinion or policy. No part of this magazine may be reproduced in whole or in part without the permission of the publisher. Advertising material and inserts should not be seen as AIHS endorsement of products or services

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Features

Do audits provide comfort rather than treatment for serious safety problems?

Audits may be a sophisticated way for organisations to avoid uncomfortable findings

Leading the regulator: WorkSafe

Victoria executive director health and safety, Narelle Beer, discusses trends, challenges and priorities for the regulator

Careless workers, workplace risks and safety metrics: what really matters? A number of long-held premises, theories and metrics in the OHS profession need re-evaluation

Other sections

Addressing chain of responsibility challenges in supply chains: Chain of

responsibility obligations present a number of important challenges for OHS professionals

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From the editor CEO’s message AIHS Board update News report

10 Partnerships 24 Occupational hygiene 34 Book review

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DECEMBER 2023 | OHS PROF ESSIONAL

EDITORIAL NOTE

CEO’S MESSAGE

Some things (technology) change, some things (good leadership) stay the same

While technologies such as artificial intelligence are advancing at a rate of knots, the importance of good leadership should never be underestimated, writes Craig Donaldson more challenging – and the role of leadership, culture, communication, systems and processes all play a critical role in driving effective WHS outcomes for SME businesses including Macco Feeds, Built Environs, and Balmoral Engineering. For the full story turn to page 16.

Craig Donaldson, editor, OHS Professional

s the year draws to a (very fast?) close, it is fair to say that 2023 broke new ground for OHS in many ways. One of the most important developments was in the field of artificial intelligence (AI), which went mainstream with the rise of ChatGPT and a plethora of other AI platforms. This field is fast evolving with new developments (almost daily, it seems). And judging from the amount of LinkedIn posts and comments in response to AI-related topics, this trend is set to continue to increase in importance over the coming months and years. While AI is set to change the landscape of work in many new and important ways for OHS professionals, one thing remains the same: the importance of good leadership and people management. This is evident in our cover story for this issue, which focuses on WHS in small to medium size enterprises. Such businesses are run differently to large organisations, which are usually blessed with well-resourced teams and budgets to match. For SMEs, however, things are often

“While AI is set to change the landscape of work in many new and important ways for OHS professionals, one thing remains the same: the importance of good leadership and people management” Also in this issue, we explore some of the latest trends, challenges and priorities in the regulator space by way of an interview with Narelle Beer, executive director of health and safety for WorkSafe Victoria (beginning page 22). As the head of one of the more active WHS regulators in the country, Beer also discusses the importance of leadership in driving not only WHS outcomes but good business results (as AIHS CEO Julia Whitford also points out on the page to your right). “Safety first culture can’t be mandated or codified – it’s something that must be nurtured and cultivated in every workplace,” says Beer, who has seen first-hand the effect of a strong health and safety culture and

how it allows a person to bring their best selves to the job. On the topic of leadership, another important article in this edition explores the issue of ESG, safety metrics and ratings agencies. Disasters such as the Deepwater Horizon oil rig blowout are a salient reminder that many of the typical safety metrics board directors rely upon to deem their organisation ‘safe’ do not provide a comprehensive picture of risk, according to Sean Brady, a forensic engineer who also authored the Brady Review investigation into the causes of fatalities in Queensland’s mining industry. As he notes in his article, this problem will only get worse because these same metrics (such as TRIFR and LTIFR) have been embraced by ESG rating agencies. “If you’re a board director who relies solely on the preferred safety metrics of ESG rating agencies, you could be blind to your fatal and catastrophic risks,” he warns. Lastly, in our OHS Body of Knowledge article this issue (beginning page 26), we focus on the chain of responsibility. Organisations are generally improving how they identify and manage chain of responsibility risks in their transport activities. However, some organisations may still feel that they can contract out their responsibility and liability to other parties, suppliers or operators, according to Downer Group’s group general manager zero harm systems and projects, Jo Flitcroft, who has authored a new chapter on chain of responsibility in the OHS Body of Knowledge. The National Heavy Vehicle Regulator (NVHR) takes a very active role in such matters, and Flitcroft says organisations should be aware that the regulator will consider the function or activity that is being performed, and not just the role or title used by the organisation. n

The OHS Professional editorial board 2023

CHANELLE MCENALLAY National safety, property & environment manager, Ramsay Health Care

KAREN WOLFE General manager of high reliability, ANSTO

KYM BANCROFT Managing Director, New View Safety

OHS PROF ESSIONA L | DECEMBER 2023

LIAM O'CONNOR HSET group manager, SRG Global

LOUISE HOWARD Director, Louise Howard Advisory

MICHAEL TOOMA Partner and Head of ESG, Hamilton Locke

ROD MAULE, GM Safety & Wellbeing, Australia Post

STEVE BELL Managing Partner – Employment, Industrial Relations and Safety (Australia, Asia)

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Leadership not management: Building a culture that supports safety

By prioritising safety, leaders not only protect their workforce but also foster a more productive and profitable organisation, writes Julia Whitford

Julia Whitford, CEO, Australian Institute of Health & Safety

n a time of a shifting responsibilities, changing workplaces and evolving risks, it’s critical to nurture a work environment where safety is not just a policy but a culture. Now more than ever, safety professionals need to be dynamic, resilient and agile, and these characteristics need to be clearly visible and promoted within your organisation. So much work is done within the profession on influence and the difference between management and leadership. You can educate yourself on as many theories or approaches to safety and safety culture as you want, but if you are unable to meaningfully communicate with buy-in, then that theory will always be ineffective. An important distinction to make is

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that leaders can be found at any level of an organisation. Leaders influence other people’s attitudes and behaviours through personal influence. Leaders must actively engage with their teams to promote a culture of safety. By regularly communicating its importance, celebrating successes and encouraging open dialogue about concerns, leaders shift the culture from ‘telling and directing’ to ‘curiosity and engagement’. Effective leaders recognise that a safety culture is not static; it’s a journey of continuous improvement. They actively seek feedback and adapt safety measures based on evolving circumstances and emerging best practices. Like most things in safety, health and wellbeing, there are frequently conflicting factors at play when trying to affect change other people’s behaviour. While it is no small feat, organisations should be aiming for an informed framework for safety culture, together with leadership and support from the top, active communication, collaboration and accountability, supported by the right tools and processes. Building a strong safety culture is an ongoing commitment that requires consistent effort and dedication. To create sustainable change, leaders must view safety not as a separate entity but as an integral part of the organisation’s overall mission and values. It’s essential to embed safety into the

company’s DNA, making it a part of the way business is conducted every day. By prioritising safety, leaders protect their workforce and foster a more productive and profitable organisation. Safety must be viewed as an investment rather than an expense, as organisations with robust safety cultures tend to experience fewer accidents, reduced downtime and increased employee satisfaction. The AIHS aims to show leadership in promoting a positive safety culture through several initiatives. It is useful to demonstrate other’s WHS successes in their own organisations, which was the basis for the creation of the Australian Workplace Health & Safety Awards. We celebrate excellence and showcase how others have had a positive impact. We are also lucky enough to have an extensive volunteer base made up of individuals with decades of experience in WHS – namely the College of Fellows, Board and Branch Committees – that we can call on to assist in our strategy and future-planning. Complex issues require complex solutions. There is no one size fits all or one be-all and end-all fix when it comes to perceptions, feelings and behaviour. One thing that you can be sure of is until staff feel like they own the safety culture and until leaders provide them with authority and empowerment, organisations will likely experience minimal change on a culture level. n

INVESTING IN HEALTH & SAFETY – GOLD MEMBERS Alcolizer Technology Area9 Lyceum Australian Army BGIS Pty Ltd Brisbane City Council Coles Group

GETTING CONNECTED – SILVER MEMBERS Australian Bureau of Statistics Hitachi Rail STS Pty Ltd Australian Unity HOK Talent Solutions Brisbane Catholic Education Pilz Australia Clough Projects Australia Pty Ltd Port of Newcastle Operations Pty Ltd Cm3 Contractor Management Pty Ltd Safesearch Pty Ltd Codesafe Safetysure Compita Consulting Pty Ltd The Safe Step Convergint Trainwest Safety Institute Downer EDI Ltd Transurban Engentus Pty Ltd Uniting SA Fifo Focus University of Queensland Guardian Angel Safety Vrgin Australia Herbert Smith Freehills Zinfa

COLLAR® Defence Housing Australia Everyday Massive Pty Ltd EY Federation University Jones Lang La Salle (NSW) Pty Ltd

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BEING PART OF THE NETWORK – BRONZE MEMBERS 5 Sticks Consulting Liberty Industrial Airbus Australia Pacific Modus Projects BWC Safety National Storage Complete Security Protection Pty Ltd Office for the Commissioner of Public Ecoportal Sector Employment Employment Innovations Pty Ltd ProcessWorx Employsure Pty Ltd SafeWork SA FEFO Consulting Scenic Rim Regional Council Flick Anticimex Pty Ltd Services Australia Health & Safety Advisory Service Pty Ltd SIXP Consulting Pty Ltd Integrated Trolley Management Pty Ltd Westside Christian College Isaac Regional Council Kemira Australia Ltd

Would you like to become a Corporate Member of the AIHS? Please contact AIHS on 03 8336 1995 to discuss the many options available.

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DECEMBER 2023 | OHS PROF ESSIONAL

NEWS

AIHS BOARD

Workplace fatalities increase over last year: Safe Work Australia

Pressure drives psychological workers’ compensation claims up

In 2022, there were 195 worker fatalities due to traumatic injuries sustained in the course of a work‑related activity, compared with 172 in 2021, according to a recent analysis of data by Safe Work Australia. Overall, the number and rate of fatalities have been trending downward since 2007, however, have been relatively stable in recent years. Over the past five calendar years (2018 to 2022), the average fatality rate was 1.4 fatalities per 100,000 workers and an average of 180 workers died per year. The lowest fatality rate of 1.1 fatalities per 100,000 workers was recorded in 2018, according to Safe Work Australia’s Key Work Health and Safety Statistics Australia 2023 report, which provides a national snapshot of work health and safety in Australia. “While the trends are encouraging, the statistics are still too high. Every work-related fatality is a tragedy, and there’s a lot more work to be done to ensure that everyone gets home safely,” said Michelle Baxter, former CEO of Safe Work Australia.

There has been a 46 per cent increase in workers’ compensation claims related to psychological illness since prepandemic times, according to an analysis by Allianz Australia. It also found there has been a 39 per cent increase in the average number of days taken off work due to mental health in the last four years, with the cost of claims rising 36 per cent in the same period. The analysis, which was based on Allianz workers’ compensation claims data comparing primary psychological active claims for FY19 to FY23, suggested that work pressure continues to be a key driver for primary psychological claims. “Ongoing disruptions have continued to fuel a disconnect between managers, employees and organisations on the most important workplace mental health issues,” said Julie Mitchell, chief general manager of personal injury at Allianz Australia. “This disconnect continues to have a serious impact on workplace satisfaction and employee retention, and in turn, is continuing a worrying trend of increasing mental health claims in the workplace.”

Research highlights the risk of gut issues when working in hot weather

More employers focus on wellbeing and safety postpandemic

Australians working in physical jobs for extended periods in hot weather or environments risk gut damage and blood poisoning that may lead to serious illness. Recent research has identified the point at which people face potentially serious exercise-induced gastrointestinal syndrome (EIGS), and the corresponding degree of seriousness. EIGS can cause a range of debilitating signs and symptoms, as a result of pathogenic agents (e.g. bacteria or bacterial endotoxins) in the gut leaking into blood circulation. The research, which was led by a team from Monash University, found this situation may lead to more serious clinical implications such as sepsis, if the body’s immune system can’t cope with these pathogens in the blood. Published in Temperature, the study found that a rise in core body temperature to 39°C and above from two hours of exercise in hot conditions can predict the onset of gut damage and the movement of pathogens from the gut into the bloodstream, as part of EIGS.

OHS PROF ESSIONA L | DECEMBER 2023

Three-quarters of employers say their workforces have demanded greater support for their health and wellbeing since the pandemic, according to a recent research report. Conducted by international law firm Herbert Smith Freehills, the report also found that 54 per cent say employee wellbeing will shape their workplace policies over the next three years. The report, which drew on responses from about 500 major employers in five key global regions, also found that just over a third (35 per cent) of employers see wellbeing as a significant activism risk, suggesting that their motives might be on the defensive side. In some jurisdictions, legislation demanding increased attention to employee mental health may also be forcing their hand. Nerida Jessup, partner at Herbert Smith Freehills, said there has been an increased understanding of mental ill-health with the prevalence of mental health issues in the community and also at work.

NSW government to introduce industrial manslaughter laws

The NSW Government recently announced that it will introduce industrial manslaughter laws across the state, making it the last mainland jurisdiction to bring an industrial manslaughter offence or legislation to parliament. In February 2023, the former government, with other states and territories, agreed to amend model work health and safety laws to allow for jurisdictions to introduce industrial manslaughter. Industrial manslaughter allows a corporation to be held liable for the death of a person caused by that corporation’s employees within the scope of their work. SafeWork NSW will begin an extensive consultation process which will include work health and safety experts, business groups, unions, legal stakeholders and families of people who have been killed at work. “I hope these laws act as such a strong deterrent that no one ever needs to be prosecuted. We must prevent fatal injuries in the workplace,” said NSW Minister for Work Health and Safety, Sophie Cotsis.

Record $2.1 million fine over apprentice’s serious head injury

An industrial component manufacturer and its director have been convicted and fined a total of $2.24 million and the director placed on a five-year community corrections order after an apprentice was seriously injured in Gippsland, Victoria. Dennis Jones Engineering and its sole director Dennis Jones were sentenced in the Melbourne County Court after earlier pleading guilty to a single charge each under the Occupational Health and Safety Act. In October 2021, Jones directed the 20-yearold apprentice to use a plastic sleeve to steady lengths of steel pipe that he was threading on a lathe at the company’s Morwell workshop. The apprentice, who was holding the plastic sleeve on the end of a pipe that protruded nearly 1.5 metres from the rear spindle of the lathe, was struck when the pipe bent and whipped. He was placed in an induced coma, airlifted to hospital and underwent surgery for serious head injuries.

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The AIHS announces new Board appointments The AIHS recently welcomed a new Chair, Deputy Chair and Independent Directors to its Board

he AIHS recently announced Cameron Montgomery as its new Chair of the Board of Directors. He has served on the Board for two three-year terms and is now one year into another three-year term. He moves to Chair from the position of Deputy Chair and also served as the Chair of the Audit and Risk Committee (ARC) up until the last board meeting. Montgomery has been an integral part of the AIHS for many years and his wealth of experience and leadership skills make him a valuable addition to the Institute’s leadership team. AIHS CEO Julia Whitford thanked outgoing Chair Naomi Kemp for her contributions and welcomed the new appointments. “On behalf of the entire AIHS community, we extend our deepest thanks to Naomi for her outstanding leadership as Chair. Her passion, vision and tireless efforts have been instrumental in shaping AIHS into the influential and respected organisation it is today,” Whitford said. The AIHS also announced the new Deputy Chair as Celia Antonovsky. She has been on the Board for the last three years as a Director and is also the Branch Chair of Western Australia. Antonovsky has been central to the work of the AIHS for many years, having served on the Emerging Leaders Committee and been fundamental to organising and hosting many networking and professional development events for our growing network in Western Australia. Following the Director nominations, AIHS Members have also voted in Rod Maule to serve his first official term on the Board. Richard Coleman has also been re-elected after serving one term from September 2019 to September 2022. Both are respected individuals with proven track records in their respective fields. Their diverse backgrounds and extensive knowledge will contribute significantly to the strategic direction of the AIHS. The AIHS has also welcomed Skye Buatava and Kala Philip as Independent Directors to the Board, to enhance the Institute’s strategy in the areas of policy, advocacy, learning and professional development. The AIHS has ensured

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Cameron Montgomery, new Chair of the AIHS Board of Directors

the constitutional provision to welcome Independent Directors to join the Board to guarantee the diversity of skills necessary to meet strategic objectives. With its latest strategic plan, Vision 2026, the AIHS identified key areas to focus resources and show leadership, with two of those being policy and advocacy and building the capability of those in the WHS profession. Buatava is currently the Director of Research and Evaluation within the NSW Government’s Better Regulation Division. She also founded the internationally recognised Centre for Work Health and Safety and is a long-standing member of the SafeWork NSW Leadership team. Skye co-led and designed a holistic regulatory approach to address issues around the gig economy and food delivery riders throughout 2021-2022 and is also a Director at the

23rd World Congress on Safety and Health at Work. Philip is currently employed as the Executive Director BOD at BSI Learning. She brings to the AIHS her expertise in analysing, designing, developing and implementing learning solutions, along with experience in skills assessment, curriculum development, process mapping and e-learning. Philip will be central in assisting the Board and the national office in growing e-learning products and developing evolving certification processes. “We are delighted to welcome Cameron as our new Chair, Celia as Deputy Chair, and our new directors, Richard, Kala, Skye and Rod. These appointments mark an exciting chapter for AIHS as the Institute continues to grow, expanding our reach, influence and expertise,” said Whitford. n

DECEMBER 2023 | OHS PROF ESSIONAL

NEWS REPORT

The AIHS acknowledges Safe Work Australia recommendation

Complete ban on engineered stone recommended Safe Work Australia recently released a report which recommended that the use of all engineered stone be subject to a “complete prohibition”

he use of all engineered stone, irrespective of crystalline silica content, should be prohibited to protect the health and safety of workers, according to a recent Safe Work Australia report. Developed at the request of WHS ministers and informed by stakeholder consultation, independent economic analysis and an expert review of evidence, the report said the recommendation for prohibition was based on a number of reasons: • Engineered stone workers exposed to respirable crystalline silica (RCS) are significantly over-represented in silicosis cases. Engineered stone workers are being diagnosed with silicosis at a much younger age than workers from other industries. • Engineered stone is physically and chemically different to natural stone. The high levels of RCS generated by working with engineered stone, as well as the differing properties of this, are likely to contribute to more rapid and severe disease. • There is no toxicological evidence of a ‘safe’ threshold of crystalline silica content in engineered stone, or that other chemicals found in engineered stone do not pose a health risk to workers. • Silicosis and silica-related diseases are preventable. However, a persistent lack of compliance with and enforcement of the obligations imposed under WHS laws across the engineered stone industry at all levels have not protected workers from the health risks associated with RCS.

The rise of respirable crystalline silica (RCS) cases

The first Australian case of silicosis associated with engineered stone was reported in 2015, according to the report, which noted that silicosis case numbers in engineered stone workers have risen substantially since this time. “While silicosis cases have been found in workers across a range of industries and silica-containing materials, a disproportionate number of silicosis diagnoses

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are in engineered stone workers. In these workers (compared to workers exposed to silica from natural sources), silicosis is associated with a shorter duration of exposure to silica, faster disease progression and higher mortality,” said the Decision Regulation Impact Statement: Prohibition on the use of engineered stone (Decision RIS).

“It is tolerably clear that historically there has been insufficient compliance activities in respect of the engineered stone industry for the level of risk” One of the key reasons for this is the nature of engineered stone and the RCS it produces. Other reasons noted were: • Engineered stone often has a significantly higher crystalline silica content, resulting in the generation of more dust containing RCS when processed, compared to natural stone. • Engineered stone can be processed more easily than natural stone, meaning more stone can be processed in one shift (leading to higher exposure to dust), and a less skilled workforce can be used. • RCS produced from engineered stone has different physical properties than that produced from natural stone, including a greater proportion of very small (nanoscale) particles of RCS which can penetrate deeper into the lungs • In addition to RCS, other components of engineered stone, such as resins, metals, amorphous silica and pigments, may contribute to the toxic effects of engineered stone dust, either alone or by exacerbating the effects of RCS.

The exposure of workers and others to RCS is regulated by the model WHS laws as a risk to health and safety arising from work. In response to the diagnoses of silicosis in engineered stone workers, the model WHS laws have been amended to remove any doubt in relation to the applicable control measures when working with engineered stone – for example, the prevention of dry cutting. “The workplace exposure level for RCS has also been reduced from 0.1 mg/m3 to 0.05 mg/m3 (8-hour time weighted average), with Members recently agreeing to recommend a further reduction to WHS ministers (to 0.025 mg/m3),” said the report, which also noted that Safe Work Australia and Commonwealth, state and territory governments have undertaken increased compliance activities, education and awareness campaigns and health screening programs to prevent further unlawful exposure to RCS.

Industry fails to act on compliance

The Safe Work Australia report was pointed in its criticism of the engineered stone industry. “It is tolerably clear that historically there has been insufficient compliance activities in respect of the engineered stone industry for the level of risk. Further, there has been, and continues to be, non-compliance with the obligations imposed by the model WHS laws, by both PCBUs and workers,” said the report. Furthermore, the nature of the engineered stone industry has also arguably contributed to non-compliance and the extent of cases of silicosis in the industry, which is comprised of mostly small businesses with few barriers to entry and a lower understanding of WHS obligations. “Relevantly, these PCBUs had limited awareness of the risks of engineered stone and their duties to manage those risks, including to assess the risks and implement the necessary control measures to keep their workers safe. Workers too were often unaware of those risks and duties and their rights and responsibilities,” the report noted. Some of the mechanisms in the model

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WHS laws that assist to better manage health and safety risks in workplaces were also less likely to be present because of the nature of the engineered stone industry and the workforce. For example, the report noted there is unlikely to be a health and safety representative (HSR) or a health and safety committee at these workplaces. “The lack of available and accessible information about the risks of working with engineered stone is also problematic. Importers, manufacturers and suppliers have failed to provide end users with comprehensive up to date health-based data and evidence on the risks of RCS in relation to engineered stone,” the report said.

A complete ban is the recommended approach

Safe Work Australia said it considered all options, including maintaining the status quo (i.e. no prohibition on the use of engineered stone), in the context of the problem statement, consultation feedback, workshop outcomes, an economic impact analysis and an expert review of available evidence on the risk profile of working with engineered stone. “A complete prohibition on the use of engineered stone is recommended. The risks posed by working with engineered stone are serious and the possible consequences of being exposed to RCS generated by engineered stone are severe and sometimes fatal. To date, we – PCBUs, workers, regulators and policy agencies – have failed to ensure the health and safety of all

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workers working with engineered stone,” said the report. “Unfortunately, there is evidence of continued non-compliance with WHS laws by PCBUs and workers in the engineered stone industry, despite significant education and awareness-raising activities as well as compliance and enforcement action by WHS regulators. This means workers will continue to be put at risk from exposure to RCS.” In addition, manufacturers have not yet established (through independent scientific evidence) that these products are without risks to the health and safety of workers and others in the workplace. “There is no toxicological evidence of a ‘safe’ threshold of crystalline silica content, or that the other components of lower silica engineered stone products (e.g. amorphous silica including recycled glass and feldspar) do not pose additional risks to worker health,” said the report. “Given this, a precautionary policy response is appropriate. At present, an unknown number of Australian workers will go on to develop silicosis because of their prior exposure to RCS from working with engineered stone. The only way to ensure that another generation of Australian workers do not contract silicosis from such work is to prohibit its use, regardless of its silica content. The cost to industry, while real and relevant, cannot outweigh the significant costs to Australian workers, their families and the broader community that result from exposure to RCS from engineered stone.” n

The AIHS welcomed the decision to support a consultation on the prohibition of engineered stone with a crystalline silica content of greater than 10 per cent, and acknowledged the decision to recommend a precautionary approach with a total ban. “The AIHS has a long and proud history of working with regulators and other leading health bodies, and will support the Ministers’ decision including the implementation of an industry licensing program,” said AIHS Chair, Naomi Kemp. In a joint statement signed by multiple bodies and organisations including the AIHS, ACTU, Australian Institute of Occupational Hygienists, Cancer Council, Lung Foundation, Public Health Association of Australia and The Australian and New Zealand Society of Occupational Medicine, it was noted that the recommendation to ban all engineered stone, including ‘low silica’ products, is consistent with the findings of the National Dust Disease Taskforce Report to the previous Federal government in June 2021 and the Draft National Silicosis Prevention Strategy. “Current scientific evidence is that a percentage of crystalline silica in engineered stone that is ‘safe’ cannot be determined,” the statement said. Although silicosis is a completely preventable disease, as many as 1 in 4 stonemasons working with engineered stone contract a form of silicosis that develops after relatively short exposure periods, is severe and worsens relatively quickly. “Thus far, the industry as a whole has not been able to demonstrate that workers’ health can be protected,” the statement said. “Our aim is to prevent silicosis in Australia. We urge WHS Ministers to immediately adopt the report’s recommendation to ban all engineered stone and protect workers who are paying the true cost of our shiny kitchen benchtops.”

DECEMBER 2023 | OHS PROF ESSIONAL

PARTNERSHIPS

SaaS synergies: how technology is reshaping OHS for business SaaS technology is well established in functions such as accounting and HR, and is playing an increasingly important role in the OHS function

or many organisations, the integration of SaaS platforms tailored for OHS has streamlined (or even completely removed the need for) manual record-keeping and associated procedural inefficiencies. Cloud-based solutions can augment operational efficiency in safety management while supporting safety protocols, incident documentation and regulatory compliance. There have been a number of important developments in SaaS-based OHS solutions in recent times according to Craig Salter, founder of Safety Champion, a cloud-based health and safety software as a service (SaaS) solution. Compared to five years ago, he said there is greater literacy around both the positive impacts and challenges associated with cloud-based WHS solutions. “As a result, prospects are coming to us more informed, understanding the opportunity and clear on what they want,” he said. This has been accompanied by heightened confidence in cloud-based solutions, which is a clear by-product of the way COVID changed the way organisations worked and used technology. This also led to increased confidence in the cloud. “This, along with commentary around changes in legislation, has been a significant driver in the procurement of cloudbased WHS software solutions,” said Salter. “Not only do management want to provide workers with uninterrupted access to their health and safety program, but our sense is that there is greater awareness by management of their due diligence duties regarding visibility and knowledge of how effectively their safety program is being implemented.” Additionally, Salter said important legislative changes have put safety on the radar for executives. The introduction of industrial manslaughter laws more recently, for example, along with the heightened awareness around psychosocial hazards, has businesses at the leadership level self-reflecting on how effectively safety is implemented within their organisation.

Industry literacy with WHS platforms

Broadly speaking, Salter observed that organisations are at various stages in terms of technology adoption. In the ecosystem

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from the procurement side results from the self-regulated way in which certain safety duties are applied. Salter said the only other cloud-based platform many clients have experienced might be an accounting or HR platform, where duties are often prescriptive and well defined by legislation, as well as the ATO or the Fair Work Commission. “Self-regulation results in there being multiple approaches in how safety can be managed by an organisation,” said Salter. “This means that software solutions like Safety Champion need to provide clients with self-serve code-free configurability, along with an ability to control workflows and access established templates.”

Elements of a successful business case

Founder of Safety Champion, Craig Salter, says organisations and WHS professionals should focus on SaaS platform flexibility to help set themselves up for success

of cloud-based technology, there is an ever-improving awareness of what cloud solutions can do and who the vendors are, he observed. “With this acknowledgement comes acceptance of the benefits, and how these solutions can positively impact operational performance. That said, we understand that cloud-based technology is only the start of the conversation,” he said. “The next wave of technology such as virtual reality, automation, sensors, pattern matching, artificial intelligence (AI) and exoskeletons, while available, is not mainstream and is often cost prohibitive for smaller organisations. Where cost is not a concern, adoption requires forward-thinking leaders – those who want to lead the experimentation process, to allow acceptance to build and solutions to become part of the mainstream vocabulary.”

Common challenges and issues

There is still a learning curve for many organisations as they adopt cloud-based technology. A common challenge observed

When building a compelling business case for adopting a WHS platform, Salter said it is important to focus on objectives rather than getting bogged down in detailed workflows. “Clearly define your functionality requirements, considering factors like incident reporting, document version control, phone apps, offline access, language translation and analytics,” he said. “Ensure that the software prioritises action over administration, as you do not want the issues with your current manual task to transfer over to the management of your software platform (for example, when a user leaves, how are tasks associated with them managed?) Along with demonstrating a strong return on investment (ROI), alignment with broader organisational goals, compliance and risk reduction, scalability and user-friendliness, this will contribute to a successful case for adoption.” In Salter’s experience, successful business cases have focused on the objective benefits of the WHS platform, with a focus on ROI. “When attention is paid to the objective benefits of the software, the vendor can present how their platform can manage the objective. It allows you to get an understanding of how the platform has been designed, rather than the vendor retrofitting workflows which may result in suboptimal performance. Get the vendor to walk you through first, then ask clarifying questions,” he said.

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To map out ROI, it is important to first understand the time taken to deliver current safety work. “Recently, we were able to demonstrate a 26 x ROI, which equated to a $2.2 million net saving in operational time over three years. This is an incredibly powerful motivator for the executive team,” said Salter. While the purchase should focus on the current capability of a platform when building a business case, Salter also said consideration should be given to: 1. Ease of use. 2. S calability. For example, what functionality has been deployed over the last 12 months, and what future plans is the vendor willing to share? 3. W hat integrations are supported, and are open APIs available? Open APIs will allow the procurer to implement integrations. 4. P ricing. Are contracts set for a given term, or better still grandfathered? Or, does the future pricing adjust with the market? “Market pricing can be a concern,” said Salter. “I’ve recently seen pricing jump by over 30 per cent which can result in budget pressures. Being clear on the above builds confidence

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that not only is the WHS platform positioned to grow, but that your future can also grow with it.”

Getting the best value out of a SaaS platform To maximise the value of SaaS platforms such as Safety Champion, Salter said organisations and WHS professionals should focus on platform flexibility to help set themselves up for success. “Ensure there is the ability to configure the platform ‘codefree’. This includes controlling what modules are activated now and for what users, along with the ability to change dropdowns and build out questions in set forms,” said Salter. Salter added that the platform is going to be a long-term investment. “How you plan to use the platform now will be different in 12 months, let alone in five years’ time.” Another important step is to be actively involved in the implementation, setup and commissioning stage. “Turn up focused and present,” said Salter. “Build product familiarity by reviewing available resource materials. Ask lots of questions. Getting the platform set-up right the first

time will support enablement across your organisation.” While it may feel easy to let the customer success team take the lead, Salter said to remember that they will only know your organisation and its challenges based on the information you share. “You’re the subject matter expert of your organisation in the relationship,” he said. Once the platform is set up and running, Salter said it also helps to be curious and share feedback. “Explore new functionality and contribute to the community,” said Salter, who added that the platform’s product team will take on board insights from multiple channels, including customer feedback, when building future functionality. “Report back on what is working and why, along with areas you see for growth. With both of these, the ‘why’ is critically important, as it guides effective product teams in the direction they build. The ‘why’ is likely to be multidimensional and cross-functional across the platform, and your ‘small’ suggestion may allow whole-ofproduct enhancements,” he said. n Safety Champion is a diamond member of the Australian Institute of Health & Safety.

DECEMBER 2023 | OHS PROF ESSIONAL

MEMBER PROFILE

Fiona McCarthy on the link between human factors and WHS outcomes Workplace psychosocial risk management expert Fiona McCarthy speaks with OHS Professional about her professional experience and shares her insights into the future of the profession

iona McCarthy is a workplace psychosocial risk management specialist with a background as an occupational therapist in injury management. She assists organisations and their leaders in understanding their current psychosocial risk profile and uses this information to create an action plan for controlling psychosocial hazards. She is a Certified OHS Professional with the AIHS, a full member of the Human Factors Society of Australia and a committee member of the Tasmanian Association of Rehabilitation Providers and the Tasmanian Branch of the AIHS.

How did you become an OHS professional? I started out as an occupational therapist in vocational rehabilitation, eventually starting my own business in country Victoria. My business quickly grew, and I provided occupational rehabilitation in the Victorian and Comcare jurisdictions and the private insurance market. At that time, I realised just how preventable the injuries were that I was seeing, and in contrast, the huge burden of illness and where that burden landed. The ripple effect through the workplace, the lives of injured workers, their families and the community involves serious losses in economic and social terms for individuals and society. I decided to switch to a career in injury prevention and enrolled in the Master’s program at Latrobe University in ergonomics, safety and health. In 2012, I started working in safety and well-being roles. Occupational therapist Judith McKindley-Hodge has been a great mentor. I highly respect Professor Jodi Oakman and Dr Rwth Stuckey from La Trobe University in Victoria and Professor Angela Martin from the Menzies School of Medicine here in Tasmania, who have all made world-leading contributions to psychosocial risk management research and teaching.

What makes a good OHS professional? My career in OHS has taught me to be a leader and I believe you need to be ready to step

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up to be a good OHS professional. To my mind, Kirstin Ferguson perfectly expressed the skills and attributes of an OHS professional in her book about leadership, Head & Heart. Curiosity, wisdom, perspective, capability and humility, self-awareness, courage, and empathy are all needed.

“The AIHS plays such an important role in providing professional development opportunities, exposing us to new ideas and giving us the confidence to move forward” I would like our profession to be more curious and wise, as it seems to me that advances in research are slow to move into practice. The AIHS plays such an important role in providing professional development opportunities, exposing us to new ideas and giving us the confidence to move forward. I would like to see more take-up of research and theory in the real world of work.

What factors (both personal and professional) are important to be effective in your role? My personal and professional networks here in Tasmania and beyond are very supportive and sustaining. I have a wonderful partner and an amazing, blended family. Experiencing this support enables me to see how important support is as a positive, strengthening factor. Research tells us that support is also a protective factor for workplace wellness and injury prevention. I can be effective as a safety professional only as far as top management allows me to be. There are endless opportunities for organisations to prevent losses through

injury and incidents and to experience the flow-through positive effects on their business. My experience confirms that these positive outcomes are only realised with top leadership engagement.

What have been the most important lessons for you in your career as an OHS professional? I was able to experience the culmination of an OHS project over a five-year period where the first two years, we had full senior leadership support to implement early intervention and an integrated approach to workplace mental health in a safety role in a medium-sized team. Our results were beyond all expectations, and as I focused on each part of the process and how it had unfolded, I learned that it takes a team to get traction and impact. Then, the contribution of the OHS role was really valuable and clear to everyone in the organisation. OHS needs team engagement; the challenge is building that team and keeping that ongoing WHS risk management cycle in motion. The Master’s degree in ergonomics, safety, and health at La Trobe University by distance is a great program of study, and not a day goes by that I don’t apply my knowledge from that course. It is particularly useful now that human factors are so central to OHS practice. Psychosocial hazards, managing hazardous personal states like drowsiness and implementing job design are just a few examples of how human factors knowledge informs OHS.

How do you see OHS evolving as a profession over the coming five years? The OHS profession is a very broad one with so many different professional backgrounds feeding in. This is fertile ground for collaboration, which AIHS supports by being a forum for ideas and knowledge sharing. I think there will be more specialisation and collaboration in future. The world of work entails many hazards, often popping up randomly and unrelated to core business. All have different prop-

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Workplace psychosocial risk management specialist Fiona McCarthy says there are endless opportunities for organisations to prevent losses through injury and incidents

erties, mechanisms and controls. AI may have a significant impact on the resources OHS professionals can utilise in the many projects and challenges we encounter. I believe what we are seeing will continue to grow: more challenging, demanding and rewarding roles for OHS professionals and not enough people to fill those roles. For anyone considering this path, it is a great time to join the OHS professions.

are abundant career opportunities in an area that you find stimulating and rewarding. If you are already engaged in OHS, I would highly recommend the framework promoted by the AIHS–INSHPO self-assessment tool to help identify areas of strength and development. This will give you a roadmap to design your career direction and keep growing.

What advice would you give other safety professionals in planning their individual development?

How do you value the COHS Professional AIHS qualification, and what is your recommendation to others?

The sky is the limit for a career in safety. I would follow your interest areas because OHS applies to every human endeavour, from volunteering to space travel, and there

I have COHS professional registration with AIHS. I believe it is important to maintain professional standards and subscribe to a common body of knowledge. Everyone

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gains from this registration. We attain recognition for our knowledge and experience, and consumers and the community are provided with quality assurance and accountability. The industry has serious due diligence obligations and relies on a quality OHS service to guide its efforts, with far-reaching consequences. We can all contribute to the quality and development of our profession through accreditation processes, which involve a spectrum of skill development, experience and contribution to the profession. I find that I also look for accreditation in colleagues and in collaboration with others who align with those frameworks that apply to their profession, whether it be engineering, psychology or social work. n

DECEMBER 2023 | OHS PROF ESSIONAL

ESG

ESG: legitimising flawed metrics? Relying on ESG rating agencies’ preferred safety metrics can blind organisations to their fatal and catastrophic risks, writes Sean Brady

n 20 April 2010, while BP executives were onboard celebrating its impressive safety record, the Deepwater Horizon oil rig had a blowout. Eleven people died and the incident resulted in one of the Gulf of Mexico’s worst environmental disasters. How did the rig go from exemplary safety performance to catastrophic failure? The answer is, of course, that it didn’t. Rather, its safety performance was illusory – an illusion made possible by BP’s intense focus on the management of personal safety.

The flaws with personal safety metrics

Disasters like these are a salient reminder that many of the typical safety metrics board directors rely upon to deem their organisation ‘safe’ do not provide a comprehensive picture of risk. This problem will only get worse because these same metrics – typically the Total Recordable Injury Frequency Rate (TRIFR) and the Lost Time Injury Frequency Rate (LTIFR) – have been embraced by ESG rating agencies. As their names suggest, these metrics typically count the number of people injured and divide this by the number of hours worked to get a rate. At a superficial level, the rating agencies’ selection of these metrics appears reasonable: if an organisation records fewer injuries, surely it is ‘safer’ than an organisation that records a higher number of injuries?

But this is not the case.

These metrics have a multitude of wellknown issues, the most serious being that they provide very little insight into how effectively an organisation is managing its fatal and catastrophic risk. This is because the causes and management of these risks are significantly different to the causes and management of the risks typically captured in personal safety metrics like the TRIFR and LTIFR.

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Sean Brady, managing director of Brady Heywood, says there is a real danger that an organisation’s already myopic focus on flawed metrics will be legitimised by rating agencies

For example, it would be ridiculous for an airline company to believe they are managing the risk of a plane crash by focusing on reducing the number of slips, trips and falls recorded by their baggage handlers. But this was the approach to safety on Deepwater Horizon. And it’s evident in many other catastrophic incidents, such as the 2010 explosion that killed 29 miners at the Pike River coal mine in New Zealand. In that case, the directors received information on injuries, but no information on the almost daily methane gas exceedances that ultimately blew up the mine.

The dangers of personal safety metrics

As we push further into an era where securing access to finance will be driven by ESG metrics, there is a real danger that an organisation’s already myopic focus on these flawed metrics will be legitimised by rating agencies. This will likely reinforce an organisation’s incorrect assumption that a satisfactory personal injury rate also means fatal and significant risks are being well managed. While a focus on the metrics relating to securing finance is obviously important, it is critical for organisations to also develop and focus on safety metrics that provide information about their more significant risks.

What should these additional metrics be?

It’s disingenuous to suggest a silver bullet exists – the right metrics will vary

depending on the specific hazards an operation is managing, as well as its level of safety maturity. What is key, however, is the importance of collecting information on how an organisation’s most significant hazards are being controlled, and then developing metrics that provide information on the effectiveness of these controls. Managing the personal safety of employees is, of course, important, but personal safety metrics only tell part of the story about how well an organisation is managing safety risk. Ultimately, the purpose of a good set of metrics shouldn’t be to answer questions, but to provoke directors to ask the right questions. The metrics currently used simply don’t do this. n Dr Sean Brady is a forensic engineer and the managing director of Brady Heywood, where he works with business, government and the legal sector to investigate and resolve complex issues that typically require a systems approach. He has acted as an expert witness in numerous proceedings involving a wide range of constructed facilities, and authored the Brady Review into mining fatalities that was tabled in the Queensland Parliament in 2020.

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ESG ratings: a compass without direction? A recent working paper, authored by Brian Tayan and David Larcker from the Stanford Graduate School of Business together with Edward Watts and Lukasz Pomorski from the Yale School of Management, explored a number of important issues about ESG metrics and ratings agencies. The paper, ‘ESG ratings: a compass without direction?’ asked six important questions about these agencies and the implications of ESG reporting for issues such as safety. 1. The purpose of ESG ratings is to provide information to market participants about the quality of a company’s ESG program and potential risks that might arise due to societal or environmental exposure. However, current evidence is mixed on whether these models, which rely on a large number of input variables, predict investment risk or return. It is also increasingly unclear whether they capture or predict improvements in stakeholder outcomes. What is the source of this failure? Is it due to methodological choices these firms make? Or is it due to the sheer challenge of measuring a concept as

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broad and all-encompassing as ESG? 2. ESG ratings are relied on by institutional investors to develop portfolios and attract investment dollars from retail investors. These funds often charge higher fees than non-ESG funds. Are institutional fund managers properly motivated to ensure that the ESG ratings they rely on to create these funds are reliable in predicting risk or performance? What steps do they take to validate ratings before using them? 3. Many retail investors purchase ESG funds in order to ensure their investments reflect certain societal values or environmental standards. Do they know that the ESG ratings used to create these portfolios do not necessarily attempt to measure a company’s commitment to those values or standards? Should ESG fund managers disclose this? 4. Given the substantial research evidence that ESG ratings are unreliable in predicting outcomes, why do individual and institutional investors rely so heavily on them? Despite these weaknesses, do ESG ratings still have

a role to play as a trusted third-party opinion of ESG risk, or as a common language for use in reporting in compliance purposes? 5. A fundamental challenge for ESG ratings providers is access to quality data to use in their models. Would more expansive corporate disclosure improve the reliability of ESG ratings, or would it add noise to already extensive disclosure requirements? Is it possible for companies to effectively report on the vast number of potential stakeholder-related metrics that would be required (carbon emissions, pollution and waste, human capital management, supply chain practices, product use and safety, etc.)? 6. The major credit rating agencies Moody’s, Standard & Poor’s, and Fitch are subject to regulation by the Securities and Exchange Commission which requires covered firms to adhere to certain policies, procedures, and protections to reduce conflicts of interest and improve market confidence in their quality. Should ESG ratings be subject to similar requirements?

DECEMBER 2023 | OHS PROF ESSIONAL

COVER STORY

SMEs: leading OHS from the front and the top

Leadership, culture, communication, systems and process all play a critical role in driving effective WHS outcomes for SME businesses including Macco Feeds, Built Environs and Balmoral Engineering, writes Craig Donaldson

Safety. Complicated compliance processes, ever-changing legislation, excessive paperwork, preparation time for external audits and the need to communicate changes and train employees along the way were cited as examples of the time-consuming (and therefore costly) nature of WHS.

mall and medium-sized enterprises (SMEs) are the backbone of the Australian economy. They account for around 98 per cent of all businesses, employ more than 6.7 million people and generate more than $2.3 trillion in revenue each year, according to the Australian Bureau of Statistics (ABS). Despite their importance to the national economy, SMEs can face particular challenges when it comes to workplace health and safety. Common challenges include limited budgets, lack of awareness and expertise and competing priorities. One of the main challenges faced by SMEs is limited resources, which can make it difficult for them to invest in WHS training, equipment and dedicated staff. Safe Work Australia’s WHS Strategy 2023–2033 also makes special mention of small businesses. The strategy notes that, due to their size, small business owners may have fewer resources to dedicate to understanding WHS requirements and ensuring the health and safety of their workers. As a result, safety risks may not be identified or addressed promptly. Australian Bureau of Statistics data, for example, has

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Improving WHS outcomes at Macco Feeds

SMEs which take a successful approach to WHS have a lot in common with larger businesses. For example, WHS is taken seriously by the leadership of the organisation and this is reinforced through a variety of processes as well as the culture of the business. This is the case with Macco Feeds, a business which manufactures fodder for livestock trade and pellets for farmers. The livestock pelletising mill, which employs 15-20 workers at any one time and has been running for 35 years, is located in Williams, Western Australia. Macco Feeds faces a range of OHS-related challenges, according to its manager Phil Beresford. “Sometimes it is the people, sometimes it is the industry and sometimes it is the rural aspects,” he said. Traditionally, Macco Feeds relied heavily on transient workforce with English as a second language (visa workers) to add workforce capacity during busy months. However, this approach has sometimes led to higher levels of staff turnover of staff and absenteeism (quality staff per capita). “Similarly, with mining in the south-west

John McDonald from Macco Feeds together with Kirsten Borgas, principal of Fostering Safety, receiving the leadership excellence award (199 employees or less) on behalf of Phil Beresford in the Work Health and Safety Excellence Awards 2023 organised by WA’s Department of Mines Industry Regulation and Safety

found that 43 per cent in those industries with higher rates of injury work in small businesses. A key barrier to improving WHS outcomes in SMEs is the perceived time required to stay up to date on WHS, according to a qualitative analysis by the NSW Government’s Centre for Work Health and

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booming and offering more unqualified positions than ever before, we are seeing workers move to more money and even time rosters,” said Beresford, who recently won a leadership excellence award (199 employees or less) in the Work Health and Safety Excellence Awards 2023 organised by WA’s Department of Mines Industry Regulation and Safety. Changes in the live export space have also had a significant impact on Macco Feeds. Supplying live export with fodder had been a significant economic driver for farmers and the broader industry, with increases in grain production required to meet demand for pellet products. “These changes are disrupting local trade relationships that then lead into financial implications for farmers and suppliers,” said Beresford. “Downstream effects on related industries and communities include transportation, logistics, loss of jobs, and changes in the economic landscape of smaller communities and even vital community services, such as the need to navigate the return-to-work process in rural areas where medical services may be limited or strained.” Another challenge is “apprehension in adapting to changes in the WHS space,” according to Beresford. “Changing the mindsets of long-term employees is always testing. However, with good quality communication and consultation with the workforce and understanding work written to work done concepts, the process

DECEMBER 2023 | OHS PROF ESSIONAL

COVER STORY

of change has received better buy-in.” Speaking openly and honestly with workers ensured that the process was there to keep them safe at work and take into consideration their knowledge and experience. This made workers more inclined to be part of the process and Beresford said participation from the team was stronger as a result.

Addressing business and WHS challenges

In January 2023, Macco Feeds and Fostering Safety (a WHS consulting firm led by principal Kirsten Borgas) ran a halfday information and training day at the local community centre to communicate key changes in legislation and impacts on the WHS management system, and gain more understanding and conduct training on key procedures including isolations and hierarchy of control. Before this, Beresford said there was significant work around a priority strategy and actioning non-compliance to be controlled in a timely manner. These included utilising a buddy system for new workers and transfer of learning key risks and opportunities to develop a better skilled workforce. There was also a focus on sharing knowledge of among workers (especially those with English as a second language or language, literacy and numeracy issues).

“This safety leadership is rare in agriculture; conventionally, WHS has not been prioritised or resources adequately” Building a practical WHS management system has been critical so success in the business. The system was geared to AS/ NZS 45001, with a basic paper-based and simple filing system that was easy to access and understand by workers. Fostering Safety collated the Macco Feeds processes and wrote the WHSMS. For example, by keeping a small notebook of chemicals, Macco Feeds accurately knows how much of each chemical is onsite at any one time. Fostering Safety then scaffolded this process with a chemical register, appropriate risk assessments and training for workers. Borgas noted that: “Macco Feeds do some

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Lex Hanegraaf, General Manger of HSEQ at Built Environs (right) onsite

Phil Beresford, manager of Macco Feeds

great things in terms of controls, so it was just a matter of capturing their processes. Because if it’s not broken, don’t fix it,” she said. Beresford also participated in key workgroups to discuss impacts on the agriculture industry – not only for WHS but also more broadly. “These discussions help make external parties aware of what businesses and farmers are seeing on the frontline and what impacts there will be emanating from changes and challenges,” he said.

Innovative approaches to managing WHS on a budget

Beresford has also prioritised approachability and visibility in the workplace, which has helped build a culture of communication and consultation, according to Borgas. “Phil also encourages autonomy and employee responsibility to manage their own workload, but ensures they are safe to do so. This safety leadership is rare in agriculture; conventionally, WHS has not been prioritised or resourced adequately,” she said. Building and managing relationships in

the business also requires a multifaceted approach. Beresford is actively involved in the team’s operations, and addressing any differences or barriers that may arise helps foster trust and create an inclusive environment where employees feel supported. In addition to hands-on management, attending industry workgroups and networking events serves as another valuable strategy encouraged by Beresford. “These opportunities allow for meaningful connections with professionals from various organisations, opening doors for collaboration, knowledge sharing and growth within the business,” he said. By implementing these approaches alongside other best practices such as continuous learning and fostering open communication channels, he said businesses can cultivate strong relationships that contribute to their overall success. Macco Feeds also prioritises the training of its employees. This includes verifying competency levels, identifying potential risks and areas for iimprovement and educating them about their rights and responsibilities under the law. “Most of our training

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programs are conducted in-house, but for activities that involve critical risks, we make sure that employees receive specialised training from external sources. By providing effective training and fostering a culture of information sharing, leaders and workers at all levels can effectively role model good WHS practices,” said Beresford.

Embedding safety into work at Built Environs Built Environs is an Australian construction company that that has been in operation for 35 years. With clients in a range of sectors including sport, health and science, defence, education, residential, commercial, retail, industrial and infrastructure, the company generates annual revenues in excess of $400 million and employs some 200 professional management staff across Australia and New Zealand, in addition to a base of construction workers that varies depending on projects on-the-go at any one time. The company has a number of organisational values, with “safety and care

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being our foremost principle,” said Lex Hanegraaf, GM of HSEQ at Built Environs. “As a principal contractor, managing subcontractors onsite presents a significant challenge, especially in today’s tight labour market, where subcontractor options are somewhat limited,” he said. “We engage various specialist subcontractors with varying WHS and organisational maturity levels. Added to this challenge is the transient nature of the workforce, as well as workers who are young and/or new to the industry.”

“As a principal contractor, managing subcontractors onsite presents a significant challenge, especially in today’s tight labour market, where subcontractor options are somewhat limited” A substantial portion of the company’s workforce is considered long-term, remaining onsite for three months or more as part of core project workgroups. Simultaneously, he said there are tradespeople who are either short-term (less than three months)

or sporadic, working onsite one day per week, fortnight, or month, as in the case of concrete crews. “This latter group typically poses the greatest challenge in terms of embracing the project’s safety culture,” said Hanegraaf, who was a recent finalist for the Australian WHS Leader of the Year Award (less than 1000 employees) in the Australian Workplace Health & Safety Awards 2023.

Addressing WHS challenges in the business

Communication, consultation and collaboration are focal points for Built Environs, according to Hanegraaf, who said WHS is part of standard discussions during the planning and execution phases of any project. “Effective operational planning often leads to improved health and safety performance, making WHS an integral part of task planning, alongside resourcing, logistics, quality and program elements,” said Hanegraaf, who also noted that Built Environs is accredited to the Office of the Safety Commissioner WHS Scheme in Australia with a risk rating of ‘Low’ and certified to the international standard ISO45001. Consistently applying this approach hinges on a clear, well-documented framework that integrates relevant workshops and planning milestones throughout a project’s lifecycle. “However, effective planning alone is insufficient without the dedication of onsite leaders who must be resilient in dealing with issues and adept at managing changes,” said Hanegraaf.

DECEMBER 2023 | OHS PROF ESSIONAL

COVER STORY

Driving WHS outcomes through culture

In terms of systems, Built Environs has embraced a cloud-based WHS operations platform to handle administrative tasks related to running a construction site and meeting regulatory requirements. Hanegraaf explained that HammerTech, a building construction software platform, aligns well with the company’s needs, eliminating the need for office paperwork and register updates. “Having a mobile-accessible system in the field has seamlessly integrated safety management with general site operations, streamlining data automation,” he said. Built Environs has also revamped its standard site health, safety and environmental induction process recently, transitioning from traditional slideshow presentations to engaging, presenter-led short videos. “Recognising the diverse workforce we engage, spanning multiple generations, each with unique learning styles, this induction serves as the first introduction to project expectations,” said Hanegraaf. “We also maintain daily contact with the project workforce through structured pre-start coordination meetings, allowing for regular two-way consultative discussions.” Building relationships (especially trust) on projects is facilitated through externally led workshops, typically scheduled at around 20 per cent into a project, Hanegraaf explained. “The ‘leading safety’ session, facilitated externally, involves frontline supervisors and key members of the project delivery team. Expectations for the project are discussed, workshopped and committed to during these sessions, providing valuable development opportunities for subcontractor leaders,” he said. Built Environs also has a well-structured framework for establishing project HSE committees. Committee members, elected

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as health and safety representatives (HSRs), represent their respective workgroups, ensuring strong avenues for consultation. “HSRs have the opportunity to contribute to the development of various safety strategies, empowering them to lead their workgroups through implementation,” said Hanegraaf.

Leadership and role modelling WHS At Built Environs, Hanegraaf said clear expectations stem from the committed senior leadership team of the organisation. “When it comes to cost-effectiveness, discussions don’t cost anything. Meaningful conversations regarding safe work practices have a significant impact on the overall culture. We utilise various tools, such as ‘safe talks’ and ‘visiting manager reviews’, to prompt health and safety conversations and provide a basic framework for field leaders,” he said. Another cost-effective method of enhancing WHS performance is through a focus on internal training. Rapid organisational growth in recent years has emphasised the importance of equipping workers with the tools they need for success, according to Hanegraaf, who said external training remains necessary for statutory requirements and when a more structured approach is needed. “The construction industry is inherently complex, involving numerous stakeholders, high risks and various constraints. Establishing and maintaining a robust workplace health and safety culture requires multifaceted efforts at all levels. The commitment of the organisation’s executive leadership makes overcoming these challenges much more attainable,” he said.

Balmoral Engineering

Balmoral Engineering is a multi-generation family business which specialises in the

manufacture and supply of safety products for the electricity industry. With a focus on the prevention of power line strikes, these products help prevent damage to utility overhead poles and wires. Specifically, these products cover over or make power lines more visible, and this helps to reduce outages and damage to assets, protects wildlife and decreases workplace injuries. The business, which has been in operation since 1974, takes a long-term view and partnership approach to working with its utility customers, according to Gordon Hedges, national BDM for Balmoral Engineering. The company’s core purpose helps reinforce WHS internally and externally, he explained: “Balmoral manufactures products to mitigate risk from powerline strikes that can cause injury or death,” he said. “Having our team understand and embrace how they contribute to helping save lives, reinforcing pride and quality of workmanship that is required and also teaming harmoniously together are all priorities for our small business.” The business uses a number of in-house quality management systems which are managed internally by Chris Dengate, managing director of Balmoral Engineering, which won the small business (metropolitan) award in the Work Health and Safety Excellence Showcase 2022 organised by SafeWork NSW. “We have policies in place that control just about every aspect of our company, including manufacturing processes. Our business is regulated in relation to everything we supply or do or provide, which comes under scrutiny of different standards – whether they be an overseas standard or Australian standard. So everything we do as a manufacturer, from buying raw materials or even a finished product, has to adhere to a quality process.”

Supporting WHS through systems, process and communication

Balmoral Engineering uses a system called EOS (Entrepreneurial Operating System) to help manage processes, workflows and priorities internally. The system covers the entire business and provides a platform for all employees to discuss issues on a weekly basis first thing every Monday morning. “It is a structured system that gives the opportunity for all staff to bring up any issues within their own job functions, or something that may help in our company processes in achieving better outcomes,” said Hedges. Balmoral Engineering staff contribute to this meeting, which is one hour per week. He said these meetings, underpinned by the system, help gets the job done together with the same objective. Any issues raised

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Chris Dengate, managing director of Balmoral Engineering, which won the small business (metropolitan) award in the Work Health and Safety Excellence Showcase 2022

through the system are addressed, and any improvements for suggestion are also welcomed and discussed. “It’s like an open forum and it really works. It is structured with disciplined steps that we go through. We follow the same process every week, and it might be that a different scenario comes up. Everyone responds with a suggestion or a solution if they’ve got one. We always say, ‘bring a solution to every problem’. That way, if it’s on the table, we can discuss it and solve it and move on,” he said.

“We always say, ‘bring a solution to every problem’. That way, if it’s on the table, we can discuss it and solve it and move on” “Workplace health and safety is a strong focus as we look after each other. We discuss everything from safety issues, manufacturing issues, or maybe improvements to process,” said Hedges, who explained that these are addressed in a timely manner

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through the EOS, which encourages inclusion. In addition to covering all the business basics, from sales, value of invoices, value of orders, back orders, opportunities and quality assurance, the system also tracks actual delivery dates, production capacity, utilisation and staff happiness. KPIs are also tracked through the system, and these range from production targets through to safety targets and are specific to each employee’s own role and function within the business. “We only wish we had found this program years earlier. Having structure and duplicatable system, we have found is far more cost efficient as it becomes second nature to administer,” he said.

Resolving issues through relationships and leadership

While clear and open communication is a priority within the business, Hedges acknowledged that it is human nature that everybody is not going to be on the same page (or in fact in the same mood) every day. “Our company core values play a big part in our company culture, which is one of respect,” he said. “We monitor and rate our staff happiness on a weekly basis this is submitted weekly discretely by all staff. Any issues brought forward are addressed in our start up week IDS (which stands for

Issue-Discuss-Solve) so there is no procrastinating on any issue. They are addressed, and solutions are generally expressed with a plan and we all can move forward.” There are a number of ways the business encourages leaders and workers at all levels to walk the talk when it comes to role modelling good WHS. This includes encouraging all staff to lead by example in their work function roles, while education and development of individual skillsets also plays an important role. “This helps our small busy team contribute to taking up any shortfall, so production continues forward. We encourage our staff to take pride in all they do and to be the best person they can be, at work, home and at play, respecting and looking out for others,” said Hedges. Successes and wins are recognised and celebrated in the business, and communication plays a key role in this process too, he said. “Each quarter we have a company address, where we reinforce all our core values, what we do, why we do it, and address goals and challenges past and next quarter forward. By staff hearing this each quarter, it becomes second nature to execute. Again, inclusion and transparency are the keys in building the business together. We also empower our staff where we give an award for most outstanding company contribution or problem solved in the past quarter,” said Hedges. n

DECEMBER 2023 | OHS PROF ESSIONAL

REGUL ATORY

falls from heights, being crushed or hit by moving objects, interactions with machinery and long-term exposure to chemicals or substances. The highest number of fatalities in Victorian workplaces are still in high-risk sectors such as manufacturing, agriculture and construction, while hazardous manual handling accounts for more than a third of all workplace injuries.

Leading the regulator: Narelle Beer, WorkSafe Victoria WorkSafe Victoria executive director health and safety, Narelle Beer, speaks with OHS Professional about trends, challenges and priorities for the regulator

r Narelle Beer commenced the role of executive director health and safety for WorkSafe Victoria in November 2021. Prior to commencing with WorkSafe, Narelle served as Assistant Commissioner, Regional and Remote Operations, with the Northern Territory Police. This followed 30 years of service as a member of Victoria Police. Her executive leadership role at WorkSafe has enabled her to focus on enhancing workplace safety and embedding harm reduction processes, opportunities and strategies through engagement, education, compliance and enforcement.

What are the priorities that WorkSafe Victoria will be focusing on over the coming 12 months?

“Psychological injuries are often far more insidious and more challenging to tackle than physical injuries”

WorkSafe prides itself on being a world leader in harm prevention and return to work. To maintain this position, we will continue to use evidence, data and research to drive our strategic approach so we can continue to target those workplaces where harm is most likely to occur. We are also enhancing how we support injured workers to recover and safely return to work, by pinpointing those whose recovery isn’t going to plan and providing tailored support when and where it’s needed most. Part of our search for improvement is always scanning for new and emerging health and safety risks across the rest of Australia and internationally. It’s pivotal that we continue to learn and share information.

How is the role of WorkSafe as a regulator currently evolving? As the world of work changes rapidly, so too do the type and breadth of workplace injuries we are seeing. It is crucial WorkSafe evolves so we can continue to be a modern fit for purpose regulator. Here in Victoria, for example, we have

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seen a significant transformation towards a service-oriented economy. In 1985, when WorkSafe was created, Victoria was renowned for making things, building things and producing things. Manufacturing, mining, construction and agriculture accounted for more than 30 per cent of the state’s employment. Today, that share is below 20 per cent, while the delivery of household and business services accounts for well over half of all jobs in the state. Part-time and casual work has also increased significantly with the rise of the gig economy, meaning Victorians are changing jobs and industries more regularly. In addition, more people are working remotely and flexibly than ever before, leaving employers facing the complexity of protecting workforces they cannot always see, in environments they may not be able to control. The range of workplace hazards and risks that employers and workers have to navigate in this modern economy has never been more complex. At WorkSafe, we will need to think beyond our state border and be aware of economic, technological and industrial trends across the world. We need to ask ourselves, what will the world of work look like in 20 years? How will these changes impact workplace safety? Like any workplace, we will continue to rely heavily on our people, who are fully committed to the Victorian community and are willing to go that extra step to make a difference.

How do you see this evolving and what are the major trends that will impact WorkSafe and employers? By far, the biggest challenge we are facing is mental injury. This is an issue impacting every industry, every age group and every demographic, in every sector of the economy and every part of society. Claims for mental injury now account for 16 per cent of all new claims. Each and every claim represents a real person with real world

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What do you notice among ‘best practice’ organisations that consistently have good OHS outcomes? The safest workplaces are those where employers accept that injuries and fatalities are preventable and priority is placed on doing what they can to protect their people. This means listening to your workforce and addressing the hazards and risks inherent in the work they do, regularly reviewing and communicating safety policies and processes and being prepared to act on emerging issues. To do this, it is absolutely critical to have strong relationships with your health and safety representatives or your health, safety and wellbeing team. They are your eyes and ears on the ground in your workplace each and every day.

What advice would you offer organisations to improve their OHS outcomes?

Narelle Beer, executive director health and safety for WorkSafe Victoria, says the safest workplaces are those where employers accept that injuries and fatalities are preventable and prioritise protecting their people

impacts, not only on them but their family, colleagues and workplace, friends and loved ones and the community. Psychological injuries are often far more insidious and more challenging to tackle than physical injuries – not only from the prevention side of things but also in terms of recovery – posing significant challenges for workers compensation schemes across the globe. Another issue that has escalated as a result of the COVID-19 pandemic is occupational violence and aggression. Our nurses, retail workers, police, paramedics, teachers, aged care and childcare workers, food delivery drivers and even our own WorkSafe inspectors are sadly being frequently subjected to violent and aggressive behaviour. Other emerging challenges include work-related gendered violence, including sexual harassment, and silicosis – an often

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fatal lung disease that is having a devastating effect on those working in the stonemasonry industry. Each of these – and more – is having a significant impact on the way we work and how we think about occupational health and safety as a regulator and as a community. The enormous task of tackling these issues will take more than WorkSafe’s knowledge and expertise. Safety in the workplace is everyone’s business.

Are there any common factors in recent workplace fatalities/ incidents? Despite the emergence of mental health especially as a priority, not all of our challenges are new. Sadly, Victorian workers continue to be killed and injured from incidents involving

Employers are one of the greatest weapons or resources we have in the reduction of workplace harm. Employees are looking to employers for leadership, to set the tone and have the right processes, supports and culture in place. But a safety-first culture can’t be mandated or codified – it’s something that must be nurtured and cultivated in every workplace. I have seen first-hand the effect of a strong health and safety culture and how it allows a person to bring their best selves to the job. Employers should understand they are the custodians of that culture and if they get it right, the result can be a galvanised and highly engaged workforce that is productive and thrives. In other words, doing everything you can to ensure the safety and wellbeing of your people is ultimately an investment in your business, not a cost. This investment helps attract and retain skilled and experienced employees, potentially setting those businesses apart from the rest and giving them a powerful and competitive edge. n

DECEMBER 2023 | OHS PROF ESSIONAL

OCCUPATIONAL HYGIENE

Lighting 2.0: indoor workplace lighting for OHS Health risks associated with certain forms of lighting are increasingly diverse and complex and Australian Standards are not keeping up, write Dino Pisaniello and Bruno Piccoli

know that lighting is referred to in OHS Regulations and Codes of Practice and I know how to use a lux meter, but what’s new? Most OHS professionals would refer to AS/NZS 1680.1:2006 Interior and workplace lighting. Here, there are three main considerations: namely safety, task performance and an “appropriate” visual environment. Unfortunately, this standard is now well out of date, and for typical office environments has been overtaken by healthy building criteria and a European Standard EN 12464-1:2021 Lighting of workplaces.

Healthy lighting and risk minimisation

What is currently missing in the Australian Standard is the notion of “healthy” lighting and minimisation of health and wellbeing risks arising from certain forms of lighting. These health risks are diverse and mostly arise from light entering the eye and projecting on the retina, rather than light projecting onto skin.

“Walking around with a lux meter isn’t going to cut it, unless one is looking at relatively simple situations such as checking lux levels for construction sites” Humans are diurnal beings and they need to be synchronised to the daylight cycle. Spending extended time indoors with artificial light might not provide the necessary synchronisation. It is amazing to think that it is only in the last 20 years that we have become aware of a new photoreceptor

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cell in the eye that regulates the body clock. The familiar rods and cones give us photopic (normal light conditions), mesopic and scotopic (dim) vision, but the intrinsically photosensitive retinal ganglion cells (ipRGCs) are important in the regulation of biorhythms. The ipRGCs are a key aspect of healthy lighting, as they trigger melatonin secretion/suppression, hormone production, digestion, increased or decreased muscle strength, core body temperature regulation and immune response. Thus, we need light for vision, and also for general biorhythm (non-visual, circadian) processes. Light for vision is optimal in one part of the spectrum (maximum sensitivity is about 560 nm, yellow/green colour), whereas for biorhythm it is in another part (maximum sensitivity is about 480 nm, blue). In order to satisfy both the visual and non-visual need, we should employ light sources that emit in both bands. If we just provide indoor light that is optimal for vision, then we run the risk of not adequately entraining our body clock. However, there is some uncertainty as to the duration and intensity required for adequate entrainment. Nevertheless, the lighting level needs of older workers are greater than for young workers, both for vision and circadian regulation purposes. This is partly because there is less light transmission through the eye for older workers. Natural light can provide what we need from the neuro-endocrine and neuro-behavioural perspectives, but should be controlled for visually demanding tasks such as “near” work and specifically VDU work. We have tended to emphasise control of illumination for visual efficiency, and so there are recommended illuminance (lux) levels for particular tasks and situations. However, light falling on a surface is not necessarily what goes in the eye, and so there is also a requirement to assess luminance (brightness) and contrast ratios in the field of vision. This is done with a more expensive luminance meter that resembles a video

camera. These direct-to-eye effects often entail glare, or photoreceptor adaptation, reducing visual acuity in a highly directional manner. On the other hand, lux meters are designed to take average incident light over a geometrical area.

Conflicts between visual and biological needs

Fortunately, lighting technology has advanced to the point where we can program the light emission spectrum and light level according to the time of the day and for specific durations, seasonal variations of daylight and specific zones, e.g. near windows. In principle, we should no longer need to worry about unhealthy workplace lighting carrying over to non-work wellbeing. This is important for shift workers, since shift work is classified as a probable human carcinogen by the International Agency for Research on Cancer. There are now building design and certification standards that have adopted the latest thinking. These include the

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International WELL Building Institute (IWBI) and UL standards for office spaces. The WELL standard for lighting covers many aspects and introduces the “equivalent melanopic” lux parameter. Flicker and stroboscopic effect criteria are specified. Again, these standards are for design purposes and may not correlate with what actually enters the eye.

Lighting and the role of the OHS generalist

Since lighting is very interdisciplinary, walking around with a lux meter isn’t going to cut it, unless one is looking at relatively simple situations such as checking lux levels for construction sites. OHS professionals understand the workers and the work, but will increasingly need to collaborate with other professionals at the lighting design stage, as well as during the investigation of lighting complaints. Relatedly, the Illuminating Engineering Society of Australia and New Zealand now has the qualification of Registered Lighting Practitioner.

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Note that the majority of workers have some sort of ophthalmic disorder, and there is considerable individual subjectivity with regard to visual comfort and symptoms. What is perceived as a lighting problem is just as likely to be due to other factors such as air quality and air velocity, humidity, proximity to screen, screen character size and so on. Complaints from an individual require an ophthalmic workup, unless the local lighting environment is obviously unsatisfactory. However, OHS professionals should know that some intense ‘blue-rich’ light sources in the occupational visual field can constitute the so-called blue light hazard, potentially contributing to macular degeneration with long term exposure. These sources may look no different from ordinary white light, and require the use of a spectroradiometer to separately analyse the blue light component. Occupations at risk include stage lighting and video production technicians, where metal halide lamps are common, and dentists using handheld

curing lamps. There are exposure criteria in this area promulgated by the American Conference of Governmental Industrial Hygienists. These are based on radiometric criteria rather than photometric criteria. The evidence derives from short term studies, often animal, and there is some concern about long term human exposures to increasingly bright light sources. There is no occupational exposure standard for blue light in Australia. In Europe, there is Directive 2006/25/EC (2006). Finally, there is a major difference between ordinary light sources and laser light. Lasers can cause immediate damage to exposed tissue. They can also cause problems at a significant distance. Lasers would not be used in traditional lighting. n Dino Pisaniello is Chair of the AIHS College of Fellows and Adjunct Professor in Occupational Hygiene at the University of Adelaide. Bruno Piccoli is Professor in Occupational Medicine at the University of Rome, Tor Vergata and Adjunct Associate Professor at the University of Adelaide.

DECEMBER 2023 | OHS PROF ESSIONAL

OHS BODY OF KNOWLEDGE

Addressing chain of responsibility challenges in supply chains Chain of responsibility obligations in Australia’s Heavy Vehicle National Law present a number of important challenges for OHS professionals, writes Craig Donaldson

n the complex web of supply chains and transportation activities, the concept of chain of responsibility plays a pivotal role in ensuring safety, for the workers directly involved and the broader public. As organisations strive to navigate the intricacies of chain of responsibility, a dichotomy has emerged in their approaches. Some are diligently improving their understanding of chain of responsibility risks, investing in training and recognising the correlation between chain of responsibility and overall health and safety practices. However, some organisations are more interested in outsourcing responsibility or neglecting to address breaches adequately. The Heavy Vehicle National Law (HVNL), a cornerstone of Australia’s road transport regulations, introduces chain of responsibility as an essential component, emphasising the need for all parties involved in heavy vehicle activities to be accountable. “I think that organisations are improving how they identify and manage chain of responsibility risks in their transport activities and how they provide those involved in the transport activity with the required training and information to manage the risks safely,” said Jo Flitcroft, group general manager zero harm systems and projects for Downer Group. “I think there is a growing awareness of managing chain of responsibility risks in the same way or with the same intensity that other health and safety risks are managed. To me, this can only help improve road safety for us all.” Flitcroft, who has authored a forthcoming chapter in the OHS Body of Knowledge on chain of responsibility, also noted that some organisations may still feel they can contract their responsibility and liability to other parties, suppliers or operators. Alternatively, she said they may fail to action to prevent reoccurrence where a breach has occurred. “It is important that organisations identify whether they are a party in the chain of responsibility, the risks that can be eliminated in their transport activities and those that can be minimised. Organisations should be aware that the regulator will consider the function or activity that is being performed, not just the role or title used by the organisation,” said Flitcroft.

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Chain of responsibility and the Heavy Vehicle National Law (HVNL)

Chain of responsibility is one part of the HVNL that applies to businesses that interact with heavy vehicles, according to Denise Zumpe, founder and director of specialist consultancy CoR Comply. “From my experience, there is a real mix out there of organisations not even knowing it exists, others thinking it only applies to ‘linehaul’ (those trucks that run up and down the major highways every night with interstate deliveries) and many who have been trying to do the right thing and be ‘compliant’ based on the information they have received from their internal experts, supply chain partners, consultants and the regulator,” she said.

“Professionals should also be aware that they might be required to monitor risks over which they have limited ability to control” Zumpe observed that the messaging and information around the duties and compliance has been confusing, resulting in many organisations not understanding their roles and responsibilities. “The emphasis has been on transport operators’ compliance, instead of businesses looking at how their activities relating to the heavy vehicle could expose the driver and other road users to risk,” said Zumpe. As an example, a business that has heavy vehicles delivering goods may be preoccupied with confirming the driver (who is employed by a transport operator) has a current driver’s licence, when the transport operator has a legal obligation to ensure drivers have a current and valid licence. “That business should be focusing their attention on understanding how their operations could expose the driver to risk. This could be through unnecessary delays at their site, which can impact driver fatigue and other hazards associated with receiving

goods from a heavy vehicle,” said Zumpe, who is working with the AIHS to help develop chain of responsibility training to accompany the new OHS Body of Knowledge chapter. Zumpe said it is worth noting that the National Heavy Vehicle Regulator (NHVR) takes a much broader view of chain of responsibility with regard to 10 named parties, as evidenced by this statement on their website: “Everyone who works with heavy vehicles – from the business that employs a driver or owns a vehicle, to the business that sends or receives goods – is accountable for the safety of the heavy vehicle, its driver and its load throughout the journey.” “I think it’s fair to say we are still on a learning curve when it comes to chain of responsibility and understanding HVNL,” said Zumpe.

Common chain of responsibility challenges and gaps

As alluded to above, organisations face a variety of complex challenges in managing chain of responsibility through their supply chain networks. Flitcroft said the first step for such organisations is to identify the transport activities that occur within the organisation, consider the arrangements that govern those activities in regard to other parties (such as the transport company) and understand the terms, payments, conditions and the intended and unintended behaviours that these terms could lead to. “For example, are there penalties for late deliveries, or is the timeframe for delivery too short or inflexible?” Flitcroft asked. “The organisation then needs to take a broader look at the transport activity itself and how they are managing the risk.” According to Flitcroft, another potential gap may be in the investigation and reporting that is being made available to officers and executives of the organisation to enable them to meet their due diligence obligations and assure themselves that their organisation is managing the risk effectively and meeting its obligations. She added that organisations can utilise their existing investigation and executive reporting mechanisms to address heavy vehicle transport requirements, and should ensure that these processes extend to

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their heavy vehicle transport activities and address any learnings or improvement opportunities that arise. “Keeping the information and instruction provided to workers will also assist in preventing incidents from occurring and provide for safe transport activities,” said Flitcroft. Zumpe said that, in her experience, inconsistency and conflicting information has been the biggest challenge for businesses. “Organisations have put resources into developing systems and practices that overlook their own risks, so they still have gaps when it comes to demonstrating compliance with the primary duty and reducing safety risks,” she said. “The number one piece of advice I can give to anyone seeking to meet their obligations under chapter 1A of the HVNL is ‘look in your own backyard first’. Businesses need to look at their own operations, identify their transport activities and manage the risks they pose to the safe operation of a heavy vehicle.” The OHS Body of Knowledge chain of responsibility chapter introduces the “circle of responsibility”, said Zumpe, who explained that chain of responsibility has typically been depicted as the 10 named parties linked together by a chain which reinforces the belief that if one party is non-compliant, somehow this has legal implications for all the other parties. “By reframing this as a circle where each party is focused how they can affect the safety of the driver and other road users, it becomes much clearer,” she said. Developing a common and consistent understanding of the duties and concepts underpinning the principle of shared responsibility and the scope of chain of responsibility will also benefit the safety and productivity of all supply chain parties. “The health and safety profession has a lot to offer in this regard,” said Zumpe. “We have a great evidence base around what works with risk management, safety

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management systems and the efficacy of auditing and accreditation systems. We understand the importance of capturing incidents and looking beyond the pointy end at other contributing factors and governance practices to demonstrate due diligence.”

Implications and advice for OHS professionals

OHS professionals may be more familiar with considering risk as it applies to workers and those in their workplace, or within the boundary of their control, Flitcroft observed. “For heavy vehicle risk, they are asked to consider the public risk,” said Flitcroft, who suggested that professionals should make themselves familiar with the Master Code and with other sources of information such as the OHS Body of Knowledge chapter, which is written to assist professionals in getting across key aspects. “Identifying the risk may involve consideration of delivery or service arrangements, and contractual positions and professionals may need to work with their legal teams or commercial teams to put the right measures in place to manage the risk. Professionals should also be aware that they might be required to monitor risks over which they have limited ability to control – for example, because the transport activity is occurring outside of your geographic location,” said Flitcroft. Zumpe also said the alignment of chapter 1A of the HVNL with work health and safety law in 2018 has seen businesses expect health and safety professionals to become chain of responsibility subject matter experts. “We can apply our expertise in risk management and governance, but there are differences in the two laws that health and safety professionals need to be aware of,” she said. “Safety has a particular scope under the

HVNL – public safety, as opposed to worker safety. The duty provisions of WHS law apply to workers and workplaces, but under the HVNL, they apply to a party’s transport activities relating to a heavy vehicle.” Driver fatigue in the HVNL, for example, is strongly focused around compliance and it is acknowledged that limitations within the HVNL currently contribute to ineffective fatigue management. Zumpe also noted that health and safety professionals may already have risk-based fatigue management policies and procedures that contradict the HVNL. “There are two areas of technical expertise here. Operational teams have the technical knowledge about the work, where the risks are and how the risks are controlled – they are doing this every day,” she said. “Transport can be dynamic, things can change quickly and often none of this is written down so the health and safety professional needs to use their skills and experience to extract the information they need to document risk assessments, identify gaps and prioritise actions.”

Chain of responsibility in the OHS Body of Knowledge In addition to the forthcoming chapter on chain of responsibility, there are a number of other chapters and resources in the OHS Body of Knowledge which are relevant for OHS professionals. “Understanding associated risks is really important,” said Flitcroft. “While the chain of responsibility looks at public risk, obviously when the heavy vehicle is within the workplace, the more familiar health and safety risks need to be managed, such as where the vehicle travels, pedestrian workers moving around, and of course safe access and loading and unloading. I would recommend that professionals review chapters on fatigue, risk management and those that touch on fitness for work and safe vehicle and plant activities.” Zumpe also noted that the NHVR promotes safety management systems as one of the most effective ways of meeting safety obligations under the HVNL and encourages operators to develop a safety culture. “There are many BoK chapters that inform these concepts as well as heavy vehicle driver risk reduction and improved safety outcomes,” explained Zumpe, who said these include chapter 30 (vehicles and occupational road use), chapter 20 (fatigue management) and chapters 10 and 12 on the organisation and systems. n

DECEMBER 2023 | OHS PROF ESSIONAL

RESEARCH

Do audits provide comfort rather than treatment for serious safety problems?

What should audits really focus on?

Audits may be a sophisticated way for organisations to avoid uncomfortable findings, blinding an organisation to necessary hard fixes, writes Ben Hutchinson

ealth and safety audits are widely used across industries. Organisations seem to place considerable trust in audits for assuring their business systems and objectives. Despite this, can we actually trust that our audits are working as intended? Prior research has questioned the effectiveness of audits for assuring safety. For instance, Blewett and O’Keeffe (2011) argued that foundational and systemic issues, such as lack of worker participation, an excessive focus on paperwork, confusion of audit criteria and auditing, can lead to intended consequences and goal displacement, and may contribute to audit failures (Blewett & O’Keeffe, 2011). Evidence from major accidents also substantiates these findings, such as audits: • failing to identify or provide feedback about active issues, like with audits before the Buncefield oil storage depot explosion (COMAH Competent Authority, 2011). In the Esso Longford accident , audits provided contradictory feedback by praising safety management performance despite critical deficiencies (Longford Royal Commission, 1999). • identifying but then not relaying intel to people who could resolve the issues, as with the methane explosion in the Moura No. 2 underground mine (Hopkins, 1999), or not effectively flagging the risk of combustible dust as at the Hoeganaes facility in Texas. • identifying corollaries of issues or reframing issues to be less concerning. For example, an external audit before sugar fires and explosions at an Imperial Sugar Company facility in Georgia identified the accumulation of sugar dust, but framed these as food quality issues and not also as combustible dust hazards (U.S. Chemical Safety and Hazard Investigation Board, 2009). • lacking the structural methodologies to identify particular issues or appropriately frame their significance. The internal auditing process before the Waterfall

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train accident was said to focus on occupational health and safety matters rather than broader system safety factors and engineering (McInerney, 2005a). Consequently, audits appear to over-emphasise paper systems over operational work, risk ‘surface compliance’ over ‘deep compliance’ (Hu et al., 2020), and may provide a false sense of safety that critical issues are being managed when they are not.

Research aims and methods

In order to explore the role that audits play in surface compliance and false safety, we evaluated 71 audit reports from a large Australian provider of integrated services employing tens of thousands of workers (Hutchinson et al., 2024). A total of 327 audit findings were extracted and evaluated for their strength of connection to addressing an operational issue, risk or practice, based on their characteristics (for example, finding addresses being a physical issue or administrative issue).

What are the characteristics of audit findings?

• A spread of audit findings involving the rectification of administrative defects and physical corrective actions to rectify hazard-related defects. • The most frequently assigned corrective actions targeting administrative aspects involved the rectification of incomplete or missing documents. Regarding physical defects, the most numerous corrective actions targeted the resolution of missing signage or the inspection, placement or review of emergency equipment. • There is an apparent over-representation of corrective actions involving communication (for example, toolbox talks), even when the underlying issue to be resolved is not related to communication; and • Audits with an espoused focus on site communication practices focused almost exclusively on outputs of communication, and not on communication practices per se – for example, a focus on a signed toolbox talk instead of

questioning what was communicated and how well that information was communicated.

Strength of alignment between specific audit questions and findings

• Weak and moderate strength corrective actions were approximately equal at ~39 per cent. Most of these corrective actions were administrative (for example, incomplete or missing documents). For the weak corrective actions at least, a substantial proportion had little discernible connection to a specific hazard or issue. • Just 16 per cent of corrective actions had a strong connection to a physical hazard or issue and virtually all of these fell under the physical category. Just one example of design or engineering improvement corrective actions was observed. • No corrective action directed attention to the systematic investigation and resolution of a class of issues (e.g. elimination of that issue). • Most stronger corrective actions were related to rather trivial and superficial physical hazards, such as inadequate signage, emergency equipment (first aid kits and fire extinguishers) or slip and trip hazards. Recommendations rated as ‘strong’ were exclusively associated with physical site conditions or observations. These categories encompassed equipment/plant unsuitability, inadequate fencing/delineation/ pathways, subpar chemical separation/ management, electrical safety concerns and risks posed by falling objects.

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Strong physical corrective actions were directly linked to the immediate issues at hand. For example, instances included inadequate delineation of vegetation protection zones, improper positioning of an elevated work platform basket in an open roadway, or a worker standing within a drop zone while another worker performed tasks at height.

“Audits appear to over-emphasise paper systems over operational work and risk” The weakest recommendations consistently involved displaying site signage without clear justification or hazard identification, displaying or submitting various documents (e.g. posters or flowcharts), and inspecting, reviewing or tweaking emergency equipment. Within the category of reviewing or placing emergency equipment, most weakly coded corrective actions focused on minor changes to the contents or location of a first aid kit or sign. Based on these findings and other research, we argue: 1. Audits may focus on surface compliance, where auditing over-prioritises the collection and review of documentation. The shift in auditing away from the

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functionality of systems towards paperwork and demonstrable evidence can be seen as a shift in the ‘depth’ of compliance activities. Deep compliance is a form of compliance that meets the intention and strategy to achieve the organisational outcome. In contrast, surface compliance drives efforts towards “merely [demonstrating] compliance with safety rules and procedures” (Hu et al., 2020, p. 4), where minimal effort is invested in the task. Here, audits may provide an ‘illusion of depth’, with a minute focus on templates, wording and surface conditions while seemingly omitting the evaluation of critical operational risks. 2. Audits may provide a false sense of safety that issues are being managed. When auditing prioritises the collection and review of documents, it can shift the type of work from operational work to administrative work. Under certain circumstances, auditing may optimise performance of documentation and invoke a type of false assurance as a result, as management of documents and processes is conflated with the management of the issues themselves. Stakeholders have little reason to question the situation since the completed and audited management system artefacts, minutiae and all, are verified as present and compliant. Therefore, managing documents and systems provides a false assurance to the business that those issues are being managed. For instance, people mistakenly, but understandably, believe that by revising a permit to work form that we’re actually improving the permit to work process, but these elements are not the same thing.

Overall, we argue that auditing should primarily focus on verifying the effectiveness of a system or component rather than merely confirming its presence, display or documentation. Nonetheless, most of this evidence suggests that audits predominantly centre around checking for the existence of components, with limited critical examination of whether those components are functioning as intended. Therefore, in this sample, audits may be a type of masquerade – a symbolic activity optimised for the confirmation of system artefacts and surface tweaks, rather than an ongoing critical self-examination that is both able and willing to ask substantive questions about what the organisation believes and says about itself and its safety. As a result, audits may be a sophisticated way for organisations to avoid uncomfortable findings, successfully blinding the organisation to necessary hard fixes. In all, we suggest that organisations are clear on what they expect audits to achieve, and to determine whether audits are achieving those goals in practice. n Ben Hutchinson is rail safety leader at Laing O’Rourke. To read the full research paper, ‘Audit masquerade: How audits provide comfort rather than treatment for serious safety problems’, visit https://doi.org/10.1016/j. ssci.2023.106348.

References Blewett, V., & O’Keeffe, V. (2011). Weighing the pig never made it heavier: Auditing OHS, social auditing as verification of process in Australia. Safety Science, 49(7), 1014–1021. COMAH Competent Authority. (2011). Buncefield: Why did it happen? The underlying causes of the explosion and fire at the Buncefield oil storage depot, Hemel Hempstead, Hertfordshire on 11 December 2005. http://www.hse.gov.uk/comah/ buncefield/buncefield-report.pdf Hopkins, A. (1999). Managing Major Hazards: The Lessons of the Moura Mine Disaster. Allen & Unwin. Hu, X., Yeo, G., & Griffin, M. (2020). More to safety compliance than meets the eye: Differentiating deep compliance from surface compliance. Safety Science, 130, 104852. Hutchinson, B., Dekker, S., & Rae, A. (2024). Audit masquerade: How audits provide comfort rather than treatment for serious safety problems. Safety Science, 169, 106348. Longford Royal Commission. (1999). The Esso Longford gas plant accident: Report of the Longford Royal Commission. Govt. Printer for the State of Victoria. McInerney, P. (2005a). Special Commission of Inquiry into the Waterfall Rail Accident. Final Report. Volume 1. January 2005. https:// nraspricms01.blob.core.windows.net/assets/ documents/Waterfall-Rail-Accident/Waterfall-final-report-Volume-1.pdf U.S. Chemical Safety and Hazard Investigation Board. (2009). Imperial Sugar Company Dust Explosion and Fire. https://www.csb.gov/ imperial-sugar-company-dust-explosion-and-fire/

DECEMBER 2023 | OHS PROF ESSIONAL

OPINION

Careless workers, workplace risks and safety metrics: what really matters?

A number of long-held premises, theories and metrics in the OHS profession need re-evaluation as modern safety practice is changing, writes David Skegg

ow that I am no longer President, Chairman or Director of anything, I have the privilege of contemplation, and that has led me to reconsidering what I once thought to be sacrosanct. I have been in this game, on and off, since 1965, which now makes me officially ancient, and I want to share three things that have morphed from absolute truth to at least healthy skepticism. I take comfort from the words of the German philosopher, Arthur Schopenhauer, that: “All truth passes through three stages: first, it is ridiculed. Second, it is violently opposed, and third, it is accepted as self-evident.” I proceed on that basis.

Worker the careless

In Yoda-speak, ‘worker the careless’, or the careless worker theory, has been with us for a long time. In my own experience, the vast majority of accident reports written by supervisors conclude that “the worker should have been more careful” in one form of words or another. And yet, it has been widely accepted for many years that human error is but one part of the accident process. Unfortunately, this is countered by the “Heinrichians” of safety who, with monotonous repetition, keep telling us that 80 per cent of accidents are as a result of the unsafe person. What has been forgotten in that diatribe is that the work of Heinrich (1959) was based on supervisor reports of accidents, building in a tremendous bias to his conclusion. Heinrich’s work was of undoubted value in bringing the issue of accident causation up onto the table of industry but, like all step changes, it has limitations. In this case, the limitations seem to have given way to the mantra of human causation which, in turn, has led to an absolute plethora of misguided thinking and the creation of systems that presuppose the human as a machine that will respond in an anti-fragile way to the task at hand. In his writing on anti-fragility, Taleb (2012) makes clear that

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David Skegg says the “careless worker” notion has declined in value to the emerging safety profession to the point that (in the words of Schopenhauer), it has been “accepted as being self-evident”

we crave predictability in the face of the unpredictable and random ‘black swans’ – the “large-scale unpredictable and irregular events of massive consequence”. Taleb is probably the world’s foremost thinker in risk (he is reported to have made a fortune in finance). He explains in great detail how we live in a non-linear world that contains much unpredictability, in complex systems that are full of interdependencies.

‘Work as imagined’ versus ‘work as done’

A more recent and easily understandable build on this thinking comes from Erik Hollnagel (2014), who delves into the world of ‘work as imagined‘ versus ‘work as done’. He has developed a method to map the ‘work as done’ called the Functional Resonance Analysis Method (FRAM). This resonates very strongly with me. I, like most, have seen and created lots and lots of policies, procedures, standards, codes of practice and guidelines – all of which are really ‘work as imagined’ and, in all honesty, bear little relationship to what actually happens, or ‘work as done’. We have spent countless hours and gallons of perspiration writing all this stuff, and we find it is easy to audit as, if someone doesn’t follow the procedure, they are ‘the cause’. This is nonsense, of course. It presupposes that our procedure is perfect, and can cope with all possible circumstances, even the ‘black swans’. Now, thanks to Professor Hollnagel, we have a methodology to deconstruct ‘work as done’, which gives

us a better understanding of activity in a complex socio-technical system, and can be used to consider how those relationships and the inherent variability of actions and environments can be used to reduce the probability of unwanted outcomes. This is serious stuff. It is already being used in the health sector, air traffic control and nuclear industries. We disregard it at our own peril and to the detriment of those we are trying to protect. Hollnagel’s work does not throw out the baby with the bathwater. The physicality of actual damage (and I use that term to include damage to humans) is well described by Viner (1991) in his work on the energy damage and time sequence models, building on (and translating into the easily understood language of the everyday person) the work of Gibson (1976), Haddon (1967) and Kletz (1990). This was expanded through careful mathematics and further thought in his later work (Viner

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2015). None of this thinking is inconsistent with what Hollnagel is saying; it is a view through a different window, and in the context of complex socio-technical systems. Workers vary their actions to achieve the outcome desired, and in doing so, depart from the ‘work as imagined’ prescription. There is nothing new in this. Authors have considered the idea of having no risk in the workplace, now so popular as the ‘zero’ promotions. I suspect and hope that those notions will follow an epidemic curve as soon as possible. After all, we have known about deviation from expected normal for a long time, and there have been erudite attempts at classification (Kjellen, 1984)

Risks in the workplace

When someone makes a decision about risk in the workplace (as well as in life generally), we ought to be considering what that means. Brauer (1990) talks about risk in terms of gains and losses, and says that

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“most people do not want losses, although they will take a chance at achieving a gain.” For the worker, that gain might be doing the work in a simpler, quicker or easier way, and so they vary from the ‘work as imagined’ and have a successful outcome. To put that into perspective, if we have a frequency of unwanted outcome of 10-3, then 999 times out of 1000, the outcome is as desired, or at least acceptable. Why then, in our consideration of safety, do we interrogate the 1 in 1000 event – most of which go unreported, or are reported as a ‘near miss’? Wouldn’t it be more desirable to understand what is happening in the 999 cases, so that we can better understand how the processes are actually implemented? Let me give you a real-life example. A forklift truck driver, working in a general construction area, was under constant pressure to deliver small items (such as batteries) around the site, so much so that the supervisor told everyone in writing to

lay off, as the expectation to perform was unreasonable. On one occasion, the worker alighted from the forklift, and in doing so, caught the gear lever with his sleeve. As a result, the forklift moved backwards and the outer wheel of the double front wheels ran over his foot, causing significant injury. The investigation showed that: • the forklift was on unmade level ground at the time; • the workload was indeed very high; • the job was the worker’s whole life, as he had rehabilitated himself from a rather nasty time in his life; • the placement of the gear shift of the forklift contributed to the event; • the dual front wheels meant that, on alighting, the feet were always in the firing line; • the driver did not apply the handbrake; and • the driver did not use the seat belt. None of this should have been unexpected. The worker was constantly on and off the forklift to satisfy the demands of the work, meaning it was entirely expected that doing up a seat belt all the time would fail, as could the error of not applying the handbrake. The worker was dismissed, as he was considered to be ‘too great a risk’ to have onsite. The support for this decision was that he had failed to conform to the ‘work as imagined’ rules. The idea that using a forklift in this manner was inappropriate carried no weight, and the solid evidence that the requests for delivery were unreasonable and that the driver tried his hardest to satisfy everyone, because the job was so important to him, was ridiculed. The opportunity to learn from this event was lost, because it is so easy, so convenient and so safe to blame the worker and not the system of work. To me, this is the same sort of codification that was used by King Hammurabi (1750 BCE). Have we not learned anything in 3772 years? Our society is an incredibly complex one, as are our workplaces, and we need to move on from simply admitting human error. We need to understand that the notion of zero harm or risk is unattainable because of ‘black swans’, if nothing else. The work of Viner, Hollnagel and others should be in our current thinking. It is time to remember Heinrich but put his work in an historical context. We were given pointers along the way, such as Singleton (1975), Gillespie (1979) and Rasmussen (1982), but mainstream safety ignored all that and went for the easy option. We can change that and, if we are ever to be recognised as professional, we have to.

DECEMBER 2023 | OHS PROF ESSIONAL

OPINION

Cause the singular

We know that we mostly investigate causes in step with the value of the consequence. The higher the outcome value, the more effort is put into the investigation. That is modified somewhat by the ‘outrage’ factor described by Dr. Peter Sandman (1993), but is essentially true. An interesting sidelight of his work is around the issue of trust (Sandman 1993 at p47), which makes me sometimes wonder why investigators are brought in from outside, when there are already safety staff available internally? The notion of a single cause leading to the effect is, at best, simplistic and is a trap that many in safety fall into as a result of their training and the exigencies of the day. It denies going back to more than one ‘why’, to consider ‘latent failures’ or the identification of ‘preconditions’. These terms, or their equivalent, exist in just about every investigative model, but in the case of low consequence values are almost never used. The real problem is that consequences really don’t matter all that much. It is the event process that matters. The consequences are so variable, they are almost a distraction from serious investigation. The same process can result in a near miss or a catastrophic outcome. In our world of ever-increasing complexity, the enthusiastic blindness of the investigator to the process can lead, at best, to loss of a learning outcome. At worst, it can lead to a repeat of the circumstance with a very different outcome. I was once asked to provide a risk assessment of a walkway that extended over a large open tank of caustic. I examined the gravitational controls and asked if anyone was monitoring the cracks in the concrete supports, only to be told that they were not a safety issue and my brief did not extend to structural components. About a month later, I received a wry call from the company that the tank and attached walkway had collapsed, spilling tonnes of concentrated caustic into a nearby river. Fortunately, there was no human injury, as the exposure data of foot traffic was very low on the walkway and negligible underneath the structures. But it begs the question: what is or is not a safety issue? The collapse of a conveyor structure could have catastrophic outcomes, with little change in the probability of a different scenario. Isn’t it the job of safety to look for the ‘black swans’? As Dr. Geoff Dell once told me, investigation ceases when the money runs out. A bit tongue-in-cheek perhaps, but it is true, and it is consistent with the notion that the level of investigation is dependent on the value of the consequence.

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My belief is that any event has multiple contributing ‘causes’ or inputs, which drives my personal investigation interest in multiple failure mode analysis. We have the tools to quickly look back in time, such as fault tree analysis, which was described in the early days by Watson (1961) and further refined over time until at least the work of Andrews & Ridley (1998), along with all the commercial versions of it that sprouted up under different names.

“We have spent countless hours and gallons of perspiration writing all this stuff, and we find it is easy to audit as, if someone doesn’t follow the procedure, they are ‘the cause’” We now also have the ability to look at what is actually happening, rather than what we imagine should happen in the FRAM methodology. None of this is of any use unless it is used! If you look at the normally-found investigation report forms in the industry generally, you rarely find mention of axioms such as energy type and transfer mechanisms, and the five opportunities for controls demonstrated by the energy damage model of Viner (1991) that were possible in that circumstance. I would argue that a safety practitioner, and certainly a safety professional, should know, or ought to know, at least the fundamentals of these models. I use the phrase ‘knew or ought to have known’ in the legalistic sense, as it confers responsibility on those involved, as it should.

The Lost Time Injury (LTI) metric

So, let’s get a couple of things straight up front. Defining lost time, according to AS1885.1 (1990) is, “those occurrences that resulted in a fatality, permanent disability or time lost from work of one day/ shift or more.” It should be a simple task and maybe it is, but in my experience, that is not the definition used in the safety community at large. There are all sorts of permutations and calculations made from that apparently very simple definition, and hence, all the derivative statistics.

So, let’s look at how this is created. By far the most common way to have a Lost Time Injury (LTI) is to recognise the certification of a registered medical practitioner. So, what are we really measuring? The story given to the doctor, where frank trauma is not involved? The enthusiasm of the employer to return the person to work (especially if they have a place to put injured workers)? The mood of the certifying medical practitioner? We actually don’t know how the notion of a day off work is derived, or at least derived consistently within the medical fraternity. Probably the most worrying aspect of this is to hold managers and others accountable for something they actually can’t control, and where the consequence is intensely variable in any case. We should remember that a person given accountability without control is a very good definition of a ‘fall guy’. I have been arguing this point in the literature for years (Skegg 1975, 1991, 1995) and I have to say, I have failed to make any reasonable dents in its acceptance. Boards and executive management are still slaves to the Lost Time Injury Frequency Rate (LTIFR) and similar. While I think of it, the LTIFR, statistically speaking, is not a frequency rate. A frequency rate is the number of times a value appears in a sequence. It is a derived ratio and bears no relationship to anything other than a random computational value – and even that varies between countries, most notably 200,000 hours in the US and 1 million hours here in Australia. So, who first proposed this figure? Nobody really knows. There is mention of a similar statistic by Wattenburg (1970) in his examination of rail worker statistics in the US from 1936 onwards. To try and understand the weight that ought to be given to this statistic (if you can call it that), a commissioned study by Tulk & Skegg (2001) tried to ascertain what real statistical conclusions could be drawn from the raw data assembled under AS/NZS 1885.1 (1990) and used to derive individual LTIFR for eight worksites. The study reported that “from a total of 1071 recorded occurrences of injury, there were 84 recorded instances of injury requiring time off work. From these injuries, 822 working days were lost over the 30-month period, an average of nearly 10 days per injury… The incidents were examined according to nature and bodily location of injury. Consistency in using the prescribed coding may have contributed to some errors, as different sites interpreted the codes individually. This was evident in the raw data that was entered during this process. Descriptions of injuries sometimes failed to

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match the code that was assigned.” The study concluded: “The injury reporting process needed to be changed to better reflect the types of injury that were occurring. Without this data, resources could be wasted in addressing suspected safety problems that are ‘red herrings’. Although many companies will face this issue, few of them appear to have the motivation or inclination to address it… Finally, even the safest workplace will have some element of the risk of injury. In a commercial environment, the difficulty and cost of reducing risk must be properly assessed if health and safety issues are to be taken seriously” (Skegg & Tulk, 2001). While this now rather ancient study was aimed at a critique of the standard, it highlighted the impossibility of deriving any meaningful conclusion on what to do about ‘safety‘ in forest operations, and showed the danger of relying on the LTIFR as the basis for an incident reduction plan.

Alternatives to LTIFR

So, what sort of statistic should we use, and would it be acceptable in the current political climate? Take a study by Inhaber (1979). Dr Inhaber was the Associate Advisor to the Atomic Energy Control Board of Canada, and looked at the comparative risks for conventional and unconventional (wind, solar) energy sources. His results showed: Energy source

No. of deaths per billion watt-years

Nuclear

2.5 - 15

Solar

80 – 90

Wind

120 – 130

Oil

20 - 1400

He noted that the risks from non-conventional energy sources derive from the large amount of material and labour needed, along with their backup and storage requirements. To use a production metric such as deaths per billion watt-years is uncommon, but the notion of using a denominator of production units has some merit, and it is sometimes seen in the mining and metal refining companies. But even this is not sufficient for society-wide consideration. We need to look for a value that is understood across all sectors and which has a constant relative worth. That is, predictably, money. So, how could we measure ‘safety’ with money, and how will that sit against the big-ticket items such as cost of labour, capital expenditure and cost of raw materials and energy? If we think about the conventions of risk, it is always expressed in annual terms

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to the base 10, and outcomes in monetary units, so that serious student of risk will express loss in dollars/year. Companies do the same, by expressing their results in monetary units. Many years ago in lectures, Derek Viner coined two phrases that have stuck in my mind: kaled (dalek spelled backwards) as a term to describe the event process (as a word does not currently exist for that), and the acronym TCOR (or total cost of risk). TCOR is fascinating, as it is so easy to calculate. It is instantly believable, as it is derived from the financial ledgers of the business entity. You simply decide what is spent on preventing things from going wrong (such as training, safety programs and the like) and what is spent in reacting to things that have gone wrong (insurance costs, fire suppression and so on). It really doesn’t matter too much about what to include or exclude as long as you are consistent, as you are looking for change over time. This can tell you a lot. It is expressed as a ratio: P : R (where P = prevention costs and R = reaction costs). Logically, if R>P, you are a dangerous place, and if P>R, there is room to improve your safety programs. The quantum [P + R] should be reducing if programs are efficient. It is well within the capacity of the ordinary safety manager to produce and report these figures on a periodic basis. It would certainly be more useful that the LTI count, over which the manager has no real control, and which tells them nothing about the integrity of their safety programs.

Conclusions

I believe the ‘careless worker’ notion has declined in value to the emerging safety profession to the point that, in the words of Schopenhauer, it has been “accepted as being self-evident”. It leads us nowhere, as we realistically can’t remove humans from the system. More than ever, especially in the complex socio-technical systems we find ourselves in, we need to accept that us humans are ‘reliably unreliable’, and we need to keep that in the context of it being just one part in the systems at play. Similarly, we have enough tools at our disposal to know, and we ought to know, that, as Hopkins suggests, monocausality is false, and has little, if any, place in the consideration of event analysis. And finally, the way we measure ‘safety’ is, as Hollnagel says, a measure of when safe conditions are absent, not present, and we need to re-think what we are trying to do. The notion of Safety II is one we ought to embrace, learn how to use and apply it with rigour. At the same time, we need to

be able to demonstrate the success or otherwise of our adopted strategies in a form that is acceptable to the receiver, and the Viner notion of TCOR provides that answer. Modern safety practice has changed, is changing and will always be changing. We need to keep up. n David Skegg CFSIA was the former SIA National President, Chair of the College of Fellows and also served as HSE manager for Clyde Babcock-Hitachi (Australia).

References

Andrews. J.D. & Ridley L.M. (1998). ‘Analysis of Systems With Standby Redundancy’. Proceedings of the 16th International Safety Conference. pp80-89 Brauer, R.L. (1990). Safety And Health For Beginners. Van Nostrand Rheinhold, New York. (p527) Gibson, S.B. (1976). “Risk Criteria in Hazard Analysis”. Chemical Engineering Progress. February Gillespie R. (1979). The Concept of Acceptable Risk. Conference Papers – Occupational Health Society of Australia (Vic. Branch) 13 November. Hammurabi’s Code of Laws (1750BC). Translated by L. W. King (e.g. s229) Heinrich, H.W. (1959). Industrial Accident Prevention: A Scientific Approach McGraw Hill, NY, 4th Edition Haddon, W. (1967). The prevention of accidents in Clark DW and McMahon, B (Eds) Textbook of Preventive Medicine, Little Brown & Co, Boston, Mass. pp591-621 Hollnagel, Erik (2014). Safety-I and Safety-II. The Past and Future of Safety Management. Ashgate, Surrey, England Hopkins, A (n.d.). Working Paper 36: What are we to make of safe behavior programs? National Research Centre for OHS Regulation, Australian National University, ACT Inhaber, H (1979). Risk with energy from conventional and non-conventional sources. Science 203, 718-723 Kjellen, Urban (1984). ‘The deviation concept in accident control -1 Definition and classification.’ Accident Analysis and Prevention Vol 16: No.4 pp289-306 Kletz, Trevor. (1990). The application of hazard analysis to risks to the public at large. ICI Limited. Middlesborough, Cleveland, UK Rasmussen J. (1982). ‘Human Errors. A taxonomy for describing human malfunction in industrial installations.’ Journal of Occupational Accidents. 4: pp 311-334 Sandman, P (1993). Responding To Community Outrage: Strategies for Effective Risk Communication. American Industrial Hygiene Association. Virginia USA Singleton. W.T. (1975). ‘Skills and Accidents.’ In: Occupational Accident Research, Stockholm. Swedish Work Environment Fund. Skegg, D (1991). Workplace injury and disease recording standard (AS1885): a critical review J Occ Health & Safety - Aust & NZ. 7; (6): pp509-513 Skegg, D (1995). Measuring safety: using TCOR as a guide. Proceedings of the International Conference on Occupational Health, Brisbane, Australia. University of Southern Queensland. Brisbane, Australia. Skegg, D (1998). The Lost Time Injury Frequency Rate - may it rest in peace. Safety in Australia. 21; 1. pp19 - 20 Skegg, D & Tulk, D (2001). Injuries and Time Lost. Forestry Tasmania [unpublished] Taleb, N. N. (2012). Anti Fragile. Penguin Group, London, England. Viner, D.V. (1991). Accident Analysis and Risk Control. VRJ Delphi, Melbourne Viner, Derek (2015). Occupational Risk Control. Gower Publishing Company, Surrey, England. Watson. H.A. (1961). Launch Control Study, Section VIII Vol 1. Bell Laboratories, Murray Hills NJ Wattenburg, B.J. (1970). The statistical history of the United States of America. Basic Books Inc. NY

DECEMBER 2023 | OHS PROF ESSIONAL

BOOK REVIEW

Right Kind of Wrong: Why Learning to Fail Can Teach Us to Thrive Book: Right Kind of Wrong: Why Learning to Fail Can Teach Us to Thrive Authors: Amy Edmondson Publisher: Cornerstone Press (Penguin, Random House UK), 2023 RRP: $27.75

my Edmondson is a full professor in the Harvard Business School and an international expert on psychological safety. In beginning to discuss failure, she describes how her own PhD research on organisational behaviour in 1993 had hypothesised that better teamwork would lead to fewer hospital medication errors. The data showed the reverse, partly because of higher reporting rates but also due to a lack of psychologically safe team discussion and reflection, which inhibited learning and error reduction. This led to her 1996 paper ‘Learning from mistakes is easier said than done’, which suggested that defining better teamwork to incorporate ‘no blame’ types of open discussion was necessary, with psychological safety being ‘an emergent property of a group’ that led to innovation and learning and enabled higher quality work and performance. Edmondson defines failure as an outcome that deviates from desired results, with errors and mistakes seen as unintended deviations, while intentional rule deviations are violations. Her typology of failure has three failure archetypes: (1) intelligent (good failures needed for progress and linked to self-awareness); (2) basic (single cause failures from mistakes and slips that are considered the most preventable, such as via situation awareness and checklists); and (3) complex (multiple causality and least preventable failures,

ISBN: 9781847943774 Reviewed by: Kym Bills, FAIHS (Life), PhD candidate at Edith Cowan University & Visiting Research Fellow, University of Adelaide with links to systems thinking, uncertainty and situation awareness). For safety professionals familiar with safety/accident models, the discussion of types two and three contains little new information, and some concept usage is contestable. Type three draws on the work of James Reason and Charles Perrow but neglects the earlier pioneering work of Barry Turner, as I have detailed in a recent opensource article (https://doi. org/10.3390/safety9040068). High Reliability Organisation (HRO) theory, including the importance of amplifying weak signals, is also highlighted.

“The real gold in Edmondson’s book is in relation to type one intelligent failures and the importance of context” In my opinion, the real gold in Edmondson’s book is in relation to type one intelligent failures and the importance of context. She explains that there are emotional, cognitive and social barriers to failing well, making this difficult for three reasons: aversion, confusion and fear of social stigma. Amygdala-driven emotional reactions to failures are often

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similar regardless of the level of real danger or context. Avoiding negative criticism is linked to the survival of early humans when tribal rejection could mean death – social media and potential rejection adds a contemporary twist via ego threats and shame. Understanding the difference between failing in consistent, novel or variable contexts can assist us in retraining our responses. Laboratory scientists exemplify reflection and intelligent learning from normalised failure (as it is expected that a large percentage of experiments will fail) in order to make real progress. Edmondson writes that, “Learning happens best when we’re challenged and psychologically safe enough to experiment and to talk openly about it when things don’t work out as we hoped.” We can lessen aversion by reframing to build healthy attributions and challenge automatic thinking, reduce confusion through a framework to discern failure types, and counter fear through psychological safety. A simple Stop-Challenge-Choose framework is advocated, along with humility in choosing learning over more arrogant ‘knowing’. Accountability and genuine apology often facilitate inter-personal learning from failure. Navigating context type and having fun experimenting are easiest while the stakes are low. Edmondson advocates the use of incentives to motivate pilot projects in opportunity-driven new territories

informed by prior knowledge – not necessarily to succeed but to fail well. To limit the size and cost of failure, she also recommends shutting down projects as soon as it is clear that they are not working. Transparency and celebrating ‘good catches’ before real damage is done aids this process. She is careful to highlight the insidious nature of confirmation bias and, among others, draws upon the highly regarded work of Kahneman, Goleman, Argyris and Senge. As an aid to systems rather than linear thinking, Edmondson proposes two simple questions: “1. Who and what else will be affected by this decision or action? 2. What additional consequences might this decision cause in the future?” System design, boundaries, time scale, cycles, judgment and discernment are all emphasised. The idea of ‘learning to fail to teach us to thrive’ is powerful and this well-written and easily read book has plenty of helpful examples and references. These include scientists, chefs, elite athletes, Boeing Max accidents and pithy summaries of important research. The book’s two major parts cover ‘the failure landscape’ and ‘practicing the science of failing well’. Right Kind of Wrong is available in paperback for $27.75 from Amazon Australia and is recommended. n Kym Bills, FAIHS (Life), PhD candidate at Edith Cowan University & Visiting Research Fellow at the University of Adelaide

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