polynomial clogging: Safe Work Method Statement templates cause concern ...

On 30 November 2012, SAI Global announced a commercial arrangement with SafetyCulture for the sale of generic Safe Work Method Statements (SWMS), particularly for high-risk industries. This has caused something of a stir with some Australian safety professionals who claim that this runs contrary to good safety practice. The controversy of SWMS in Australia is a hot topic and one that is unlikely to be resolved soon, as it goes to the heart of some of the safety red-tape objections from the business sector.

SAI Global announced:

?SAI Global Limited (ASX: SAI) has signed a distribution agreement with SafetyCulture Pty Ltd one of Australia?s leading providers of Occupational, Health and Safety information and materials, to publish and sell their ?Safe Work Method Statements?.

These Safe Work Method Statements, developed by SafetyCulture, are templates documenting procedures and methods for safely executing common tasks and operations on construction sites.

These templates cover a wide range of potentially dangerous tasks and activities which:

Save construction companies time and effort drafting various OH&S procedures for different applications.
Are available in Word format and can be easily tailored to meet the requirements for specific construction sites.
Are based on industry expertise and latest OH&S best-practice for high-risk construction work.?

SafetyAtWorkBlog has written previously about the commercial situation and strategy of SAI Global and its relationship with Standards Australia. SAI Global has always been a commercial organisation that has marketed the work undertaken by Standards Australia. This has never sat well with many safety professionals as some, including SafetyAtWorkBlog, have argued that any Standards referenced in workplace safety legislation should be free or at a reduced cost due to their role in preventing incidents and harm.
It has been argued that if the Australian Government wants to reduce safety costs to small business, it should consider providing safety management standards at no, or little, cost.

What has raised the ire of many safety professionals is that the source of the generic SWMS has come from another commercial body, SafetyCulture. Describing any company as ?leading?, as in the above quote, only ever describes market position and never product quality. At one point Enron was a leading energy company and Lehman Brothers was a leading merchant bank and Madoff was a leading investment adviser. ?Leading? is a red flag for more analysis on a company or organisation.

SafetyCulture provides a timeline of the company?s development on its website but no information about the technical OHS resources and expertise used for its product development. The company has certainly made some inroads into the online safety app sector but many of the safety professionals? concerns could be assuaged with more background on expertise and SWMS development.

SAI Global has only ever claimed these products to be templates which should be tailored to the needs of construction workers, a point that SAI Global?s Simon Berglund is at pains to stress in some OHS discussion forums. There is a growing trend to step away from the generic SWMS to the more relevant Job Safety Analyses or a simplified SWMS that is handwritten by the work crew on the day prior to commencing work in an area or a shift. In this way some construction companies are reinforcing the need to have SWMS live up to their intentions and not be an administrative task that someone in an office wrote weeks or months earlier.

Cover of Getting_Home_Safely_report_-_Construction_Safety_Inquiry_Nov_2012 Very recently Lynelle Briggs and Mark McCabe, the WorkSafe Commissioner for the Australian Capital Territory, investigated the safety performance of that territory?s construction industry and devoted a page on the matter of SWMS (withe the best use of ?embuggerance? seen for some time). In the report, Getting Home Safely, Briggs and McCabe wrote:

?Safe Work Method Statements are, basically, a set of instructions for how to complete a prescribed task as safely as can reasonably be expected. The current Work Health and Safety Act 2011 only requires such documents for eighteen specific high-risk construction activities. [SAI Global offers many more than eighteen] The current mythology, however, which has proved enormously difficult to dislodge, is that all risks must be managed, and documented, and have a corresponding SWMS that can be produced when an inspector calls or if the employer ends up in court.

This mythology has been perpetuated by some in the industry for varying reasons, few if any of which are valid. Auditors, safety consultants and inexperienced or less qualified safety managers have all been culprits in perpetuating this myth, despite attempts by the local industry to lay most of the blame at the feet of the Federal Safety Commission.

Some of the Territory?s most senior safety managers are still yet to be convinced, despite protestations by WorkSafe ACT to the contrary, that they are not required to have a SWMS in place for workers walking over uneven ground on a construction site, or walking up stairs on a multi-level site. This is despite the fact that most people mastered such activities in early childhood.

Perhaps what the perceived issues surrounding SWMS actually represent is the inability of the local industry to see beyond the most basic of responses to demands for safer worksites. Whether this is due to an undue focus on profit margins, with safety seen as a mere ?embuggerance?, or whether the responsibility for this lies more broadly among all of the stakeholders, it nonetheless has become an obstacle to seeing the bigger picture??.

For this specific issue, the answer is to comprehensively debunk the SWMS myth. To do this alone, however, and not shift the focus from paperwork to work practices, from systems-based controls to behavioural and cognitive controls, will not achieve the safety outcomes we must all expect from the construction industry.? (page 44)

Further to the mention of the Federal Safety Commission (FSC) above, the FSC states in its factsheet on SWMS that:

?As SWMS form the primary source of documented OHS guidance for workers, it is essential that they are involved in its development and clearly understand the material. Whilst some of the core information contained within a SWMS may be relevant across multiple projects, much of the information should relate to the specific situation on each project. As such, site specific SWMS should be developed for all projects.? (emphasis added)

The concerns of safety professionals comes largely from their experience that safety templates often become a default process that is diverted to become an SEP (Someone Else?s Problem) or simply a piece of paper that is never looked at and one that everybody hopes is never asked about.

An earlier incarnation of SafetyCulture, Wades Business Solutions, provided the following context to SWMS that is missing from the SAI Global site:

?Main Reasons Why Staff Do Not Adhere To Safe Work Method Statements

Safe work method statements are implemented without involvement with staff.

Different policies or work procedures don?t seem to be well-communicated.

Work procedures and improvements aren?t thoroughly enforced.

Employees openly accept a policy and independently neglect it.

Personnel do not think the principles affect them.?

Templates without context may be the basis for many of the safety professionals? concerns.

Briggs? and McCabe?s quote above displays their frustration with how the myth of the SWMS has grown out of control and is seen as a joke by some, an inconvenience by most and a useful safety tool by few. The SWMS system and regulatory expectations need a reboot across Australia and particularly in the high risk construction sector where SWMS could be of the greatest practical use. Issuing templates is not helping in this need for revision but SAI Global has long been a commercial leopard that seems to have no intention of changing its spots and needs to develop more commercial products to rebuild its profitability. Sadly it seems to be a short-sighted leopard.

Kevin Jones

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