Nippin Annand and Greg Smith’s webinar discussed meaningful compliance and the use and abuse of safety bureaucracy. They asked a perilous question – does filling out forms do more harm than good? Generations of safety professionals, government regulators and legal experts would say form filling is important and the foundation of good safety practice. Although, is it?
Nippin raised the first challenge. Forms, especially ones written by safety professionals are populated with terms that often mean little to the workers filling them in. Also, there is no room for discretion. If the options are yes, no or not applicable where does a real-world ‘maybe’ fit in?
There is also a sense of double jeopardy if a worker signs a form, they have essentially entered into a written obligation that whatever is being checked is correct, even if they are not quite sure what ‘it’ is. When something goes wrong, the signature is inevitably the first step in the name, blame, shame chain of causation.
The second challenge occurs when a form is used ‘problem’ reporting mechanism. The space provided on a typical form is insufficient. It provides neither the information nor the context to define what the real ‘problem’ is. Instead, corrective actions are created and become items to be closed out before the next audit occurs rather than effective solutions.
Nippin’s call to action was that we need to move beyond form filling and other ‘tick and flick’ activities towards meaningful compliance. Supervisors need to go beyond the form and take the time to understand what their workers ‘problems’ are. By connecting with the people involved they can then support them to find effective solutions.
Greg’s part of the presentation was a little like watching train crash TV. You knew the stories were not going to end well, but could not look away. He ran through recent court cases set in various jurisdictions from around the world. Some of the more salient quotes were:
- The process undermined safety, as the form created a gulf between what they said they would do and what they actually did.
- Workers had repeatedly said they found the forms of limited relevance.
- Management has a responsibility to
- make sure workers comprehend and understand the processes, and
- whether the process itself is relevant.
The case law points to safety bureaucracy at best creating a disconnect between processes and purpose and at worst actively causing harm. The forms inevitably create a false level of comfort and eliminate the need to have meaningful conversations with workers.
Another challenge associated with forms are that once they are filled in, a worker can then cease to think about hazard management altogether. Ultimately, if a paper process is not fit for purpose and not followed, the courts will publicly call out the problem. As Greg pointed out, “everyone reverts to command and control when there are bodies on the ground”.
The flicker of hope is that an organisation can stand in court and defend its actions if the team can discuss the hazards associated with their work and how those hazards were controlled on the day. Overall, yes forms and checklists are relevant as aide to memoirs; however, the form has to be relevant, connected to the workplace and the knowledge of how to manage and control risks needs to be consistently applied and actively discussed.
To learn more about meaningful compliance and see the webinar follow the link:
Webinar – The dangers of safety bureaucracy: Aligning process with purpose