therowersraspberry

Note: original article posted on Kevin Jone's excellent (honestly, it is a brilliant source of info for anyone dabbling in the OHS profession) SafetyAtWork.blog on Monday June 3rd, 2013.

For this page, written in May, 2020, I've posted bits and pieces from Kev's article below, to provide context for the series of pages coming up about Safe Work Method Statements.

As with many of Kevin's articles, it generated an initial flurry of activity and comments from those with skin in the game. To recognise copyright protections I cannot post them here in their entirety, but have penned a few words about some of the main themes they highlighted, where that seemed sensible to do.

My comment found its way onto Kevin's site about three-and-a-half years after he wrote the article. (And as I write this, I still haven't the foggiest about what prompted me to throw a comment into the mix so long after Kevin's article first hit the newstands).

Over the first weekend in June 2013, the ACT Government hosted a Work Safety Conference titled Building Safety - Bridging the Gap, in Canberra.

Kevin attended, and published his article the following Monday. For a conference titled Building Safety it was inevitable that Safe Work Method Statements would gain airtime.

For reasons I continue to struggle to really grasp, SWMS seem to be extremely polarising within the safety and health game. Some seem to love them, others the polar opposite.

Having read Kevin's SafetAtWork blog for longer than I can recall, I get the feeling he resides in the latter camp. But, he's a professional and to his persistent credit offers views drawn from across the spectrum about them.

Serious questions raised over the role of Safe Work Method Statements

The article, as its title makes clear, suggests conference attendees carried serious concerns about SWMS. I presume those concerns came, mostly, from folks who spend time dabbling in the dark-art that is OHS. I cannot imagine why too many, if any, other professionals would invest much time with this subject.

Personally, I don't have concerns about SWMS but can understand why some would, or do.

Paraphrasing what Kev said, several delegates felt the Office of the Federal Safety Commissioner (OFSC) could be to blame for an over-emphasis on SWMS in the construction sector and for the bloating of SWMS into documents that do little to improve safety and are more related to meeting OFSC audit criteria.

Firstly, SWMS are a critical and ubiquitous element within construction. In Victoria, the OHS Regulations demand that a SWMS is prepared before you commence High Risk Construction Work. There are 19 work activities considered to be HRCW. Some of those are very specific (diving, for instance) and others are far broader. For example, you could interpret "workplaces where there is any movement of powered mobile plant" as almost any construction site which would, depending on how you view the tea-leaves, prompt you to craft a SWMS. But from all of that, the point is that leaning into the SWMS space should not be an unusual outcome for anyone involved in construction. They are an everyday tool of the trade. Or, should be.

But, if a SWMS was doing little to improve safety I'd be looking - hard - at those who crafted the document, and the process used to create content.

As for meeting an auditors criteria, I have never seen an issue with whatever the raft of questions an audit happens to present, as long as they and the subsequent lines of enquiry prompt thinking about how to reduce risk.

One of the presenters at the conference was Paul Breslin. Paul's LI bio says he's the Regional OHSE Manager for Multiplex Construction. He looks like a bloke with vast experience in the profession, and comes across as some who is not afraid to tell the world the emperor is not wearing clothes.

During the conference Paul showed "several examples of SWMS templates from around Australia issued by various OHS regulators." He "admired the templates that were simple, plain and readily applied but pointed out that none of those would comply with the requirements of the OFSC".

Looking back at this now, I am tempted to ask, now, why does that matter? If the OFSC decided to a version of what they felt was a half-decent SWMS template, let them fill their boots.

The OFSC - as far as I can deduce, and despite what seems like a lofty title - can only hold sway on a project funded by the Australian Government. To my way of looking at this, that would allow the OFSC to perform pretty much as a client on those projects. So if they wanted to provide a SWMS template that asked responders to do way more than what most bog-standard SWMS templates ask for, more power to them.

They're the client. They get to make their rules, within reason.

Paul went on to touch on what he felt was the "absurdity" of templates that required the assessment of risk and allocation of a risk rating.

"Breslin pointed out that that OFSC acknowledges that the construction industry has already been deemed a high risk workplace and asked why such a risk assessment approach is needed." I write about that in my November 2016 comment but, in a nutshell I feel that if a risk assessment process 'forces' its audience to pause and consider how best to deal with an issue (i.e. a hazard exposure), and make them think about what would be a reasonable way of controlling that hazard, I feel we've struck a winner.

Kevin wrote about research Paul undertook into the costs associated with developing, writing and managing SWMS on around 15 Australian construction projects. (As a side-bar, this is an area I hold distinct interest in and is, I feel, a place where those with an ounce of penmanship skill can add value).

Paul "determined that over $7 million had been spent in these projects specifically addressing the obligations for SWMS in their current configuration."

I don't know the research Paul spoke about, but it would have been an interesting exercise to calculate the other side of that equation: what would be the opportunity cost of not addressing those obligations?

Kevin also wrote that "Breslin stated that SWMS do not, by themselves, save lives and in fact could increase risks by diverting important OHS resources and supervisors away from monitoring and helping work practices on the construction site."

A well crafted SWMS - one that involves the people it should and that's been thoroughly and ably communicated - would, IMO help to save lives. As for diverting resources away from the coal-face, one could argue the same for almost any activity that drains resources from the field.

The research Paul undertook also "included a review of all incidents on the 15 projects, to determine the role of the SWMS in those incidents." Those 15 projects had experienced 200 incidents.

(Note: basing this on experience I feel that number is a shade on the low side. Naturally I don't know the projects Paul looked into, but would expect more than 200 'things' to have gone wrong across the breadth of 15 projects. Of course, this begs the question about how something that did go haywire eventually became classified either as, or as not, an incident - which is in itself a subject I could gab on about, for ever).

In his research Paul found that "SWMS were inadequate in around 30 incidents" and that "around 80 incidents involved a breach of the SWMS."

In other words, 15% of the SWMS Paul reviewed were not good enough. (Wonder whether that meant the SWMS content was not up to scratch, or whether there was a deficiency in the application of what that content asked for?)

And 40% of incidents involved a breach of some aspect of the SWMS. I know it is impossible to be sure that had the SWMS not been breached, the incident wouldn't have occured, but for the sake of this article I'll make that presumption. (So, basic lesson is: follow the SWMS?)

Kevin closed his article by (rightfully, IMO) saying SWMS could justify a conference on their own. He also asked for more leadership from regulators on "reassessing the need, role and application of SWMS in the Australian construction industry."

From my POV, given the attempt across Australia to harmonize OHS 'stuff', I would have loved to have seen a harmonized approach to something like SWMS across the country.

They are a simple planning tool-of-the-trade that are not hard to get right, but can so often be warped and made wrong.

My comment - posted November 8, 2016

Hi Kevin (and yes – acknowledging I am coming to this conversation really, really late). I have begun some informal research into SWMS’, which has drawn me – again – to your (excellent) blog.

I have been professionally involved in the safety space for close to two decades engaged, primarily, on construction projects. Over that period of time I have critically reviewed 100’s of documents purporting to be a SWMS (or any other number of similarly acronymised documents that represent safety assessment: e.g. JHA, TSA, JSEA, etc). Some have been brilliant, while some have been the polar opposite.

Some have obviously been cut-‘n-paste from earlier work, with little obvious effort to tailor the document to the specific work it is designed to cater for. So I reckon I am like most other safety professionals who enjoy your blog: we’ve seen good, bad and downright ugly SWMS’.

Bumping into Fergus’s comment, which look to be responding to Paul Breslin’s commentary on SWMS, I felt I’d throw in my two-pennies worth.

Are SWMS too complicated and onerous? I believe a poorly constructed and managed SMWS could be, but that outcome speaks more to the process underpinning how the SWMS was constructed, than the SWMS itself. Manage the process, enjoy the outcome.

Fergus spoke of the use of inherent and residual risk columns. I appreciate how one could conclude they clutter a document. But, in my experience if risk analysis is applied – as best it can be – to determine risks, then presenting inherent adjacent to residual risks provides a simple visual means of expressing how we believe we can deal with the risk(s) of doing ‘something’. If our residual risk column suggests we can achieve a goal more safely – i.e. with reduced risk – we’re heading in the right direction.

I 100% agree with Fergus that SWMS can fail to provide a sequential work/process flow, or can (sometimes) provide too much extraneous detail. But again, I feel those outcomes speak of the process underpinning the construction of the SWMS, rather than the SWMS itself. Manage the process, enjoy the outcome.

If I am presented with a SWMS with content that goes something like ‘Wear a safety harness’ as the sole expression of how an entity proposes to manage a legitimate fall-from-height exposure, that provides cause for that SWMS to be rejected. Seriously… the only solution people could think of to manage work being planned aloft is to ask employees to don a safety harness??? I accept that wearing fall-arrest equipment may provide a slice of the overall package designed to protect folks working at height, but what are the other pieces of that pie?

A poor SWMS reflects poor application. Don’t accept poor product. If the SWMS is out of sequence; or something like ‘Wear a harness’ is tabled as the sole method an entity proposes to manage work at-height; if the document you are being asked to review shows the hall-marks of being little more than a Ctrl+C, Ctrl+V outcome (etc)… hand it back to the SWMS’ author.

As Fergus said, what is of critical importance is doing things safely.

IMHO a carefully considered, relevant and constructed SWMS will provide an excellent foundation for that outcome.