Practitioner viewpoint- March 24

THE CONCEPT of ‘reasonable practicability’ has been central to effective management of health and safety risk since the Health and Safety at Work etc Act was introduced in 1974. It’s facilitated a step change in workplace safety, and the UK now reports among the best performers world wide. Continual improvement has been absolutely key to that journey, and the Plan, Do Check, Act cycle is well established across business and industry.  

However, as performance gets better it becomes harder to identify new areas for improvement, and of course, people still form a key part of most work processes, so there will always be the potential for judgement errors, lapses and mistakes. There will come a point where the level of control in each system or process is effectively optimised. Further improvement may be possible, but not without significant - possibly disproportionate – investment. Identifying this point requires skill, experience and confidence.  

Once an optimised condition is identified a business has a number of options, including, just keeping the system under review and reacting if anything changes; going back to the very beginning and seeking opportunities to design out risk and remove the need for lower level control measures; investing in redesign of the task, system or process to drive further improvement.

In many situations the most appropriate response may well be to keep the situation under review – however our commitment to minimising harm sometimes leads us to keep layering on more and more low level control measures, procedures, PPE, task briefings etc, so that we feel like we’re still driving improvement.

In fact what we are probably doing is upsetting that delicate balance of risk and control. Making the task more complicated, difficult or time consuming. This can drive an increase in violations as workers become disengaged with control measures which they can see add no benefit, and at worst might even unintentionally increase other areas of risk, for example, adding additional PPE which impedes movement or manual dexterity.

Every safety professional knows that workforce engagement is key to achieving effective risk control, but it’s a fine balance, and once it’s lost the impact is likely to be felt across all areas of the business, not just in the one area where the risk control balance has tipped beyond optmisation.

I met with a PPE supplier recently, and they commented that clients are increasingly seeking products that ‘have everything’.  We talked about the unintended consequence of creating a situation where workers feel ‘protected’ all the time, and therefore lose focus on residual and dynamic risk.  There is something to be said for selecting specific PPE for a particular task.  It’s part of a thought process which acknowledges the risk and the necessary actions to control it, putting safety back in the ‘thinking’ part of the brain and avoiding a situation where a worker coasts through their day without engaging in keeping themselves safe.  Small nudges like this can be really helpful in maintaining optimized risk control.

We need to be brave and confident in our risk control judgements. As experts our employers look to us to be the conscience of the business in relation to safety matters. We must continue to seek just the right level of control for every process, engaging with workers, suppliers and expert advisers to help us find, and maintain the right balance.

Louise Ward is safety & sustainability director at G&W UK – Safety. For more information, visit www.gwrr.co.uk