Comments on: Safe Work Method Statements – their role, their use and their curse

By: Kevin Jones

Kevin Jones — Tue, 17 Jun 2014 01:41:21 +0000

Luke, you know I always appreciate a dialogue on safety issues. Thanks very much for your comment.

By: Luke Anear

Luke Anear — Tue, 17 Jun 2014 01:12:07 +0000

It is good to see some robust discussion around the use of SWMS and the dependence the safety industry has on documentation, and although some of the criticism is targeted towards SafetyCulture, (I am the CEO of SafetyCulture) I\’ll do my best to provide a balanced response.

Generic SWMS will never be the complete solution, and as I\’ve stated previously, like any tool, they need to be used in conjunction with qualified expertise, either internal expertise or external.

Originally, in 2004, SafetyCulture only produced a set of OHS Policies for small business operators, and as clients requested further documentation such as SWMS, we produced them, and subsidised the cost.

Quickly, it became clear that there was much confusion in the marketplace, with regulators in different states using a variety of terminology to describe safety documentation. In some cases, clients were told they need a Safe Work Procedure, but then would find out later, they actually needed what others would call a Safe Work Method Statement. Other terms such as Safe Work Instruction, Safe Operating Procedure and Safety Procedure were also used, sometimes relating to the same document, and sometimes relating to different types of documents. It was very confusing for business owners.

We started out naming most of our documents Safe Work Procedures, but clients were more frequently referring to them as Safe Work Method Statements and a consistent was required.

So in response, we chose to standardise our products to one common term, being Safe Work Method Statement. Technically, as this article indicates, many tasks do not require a Safe Work Method Statement, but it then becomes confusing for small business operators to understand what they actually require.

They don\’t want different formats, and different requirements for the various tasks. The want one format, one type of document that is effective in confirming a worker is aware of how to avoid the risks and hazards associated with the work they are conducting.

The intention behind all documents is essentially the same – to help people work safely. To that end, we used the one term for all documentation in order to simplify what we offer.

I also asked Julia Collins, Director of Safe Work Australia in October 2010 if she would introduce a standard SWMS template for all workplaces to use, to assist with the ongoing debates in relation to formatting and content to be contained in a SWMS. She indicated they would not be providing a standard template.

Something that I feel is missing from this discussion is a variety of proposed solutions for the future. I agree with the comments that SWMS have outlived their usefulness and a new paradigm is required.

People are often quick to find fault, but sometimes struggle with suggesting a better solution.

The industry is still operating around a compliance mindset, where the focus is on complying with the local legislation. It would be great to see workers move towards an awareness model, where compliance is a given, and solutions are more integrated into the daily workflow and the lives of the workers.

More solutions are becoming available as technology and in particular smart phones become more affordable. The team at SafetyCulture are doing our best to reduce the costs associated with safety compliance, therefore making safety available to the larger workforce, particularly in developing countries, where desktop computers and printers are not available to many workers.

We will continue to innovate and hopefully provide better solutions than SWMS over time, and although Kevin Jones (author of this blog) reviewed our iAuditor app and didn\’t rate it particularly highly in 2012, it is now the most used safety app in the world, with over 5 million inspections completed since it was released in February 2012. The free public library in iAuditor now has 34,000 different inspection forms in it, and overall the app has done more in two and half years to help people work safer than our previous 8 years combined of developing SWMS.

These solutions take considerable time and energy to develop. Our team of engineers is working hard to bring new innovations to the market as quickly as possible, and I know other companies are also innovating their way forward.

I hope this provides some perspective to the argument and an optimistic tone about the future.

Luke Anear
CEO SafetyCulture

By: Robert B

Robert B — Tue, 10 Jun 2014 07:15:56 +0000

Both Dane and Rob are right on the money. Rob especially in his criticism of the Federal Safety Commissioner. The emperor has no clothes and everyone involved as a safety professional in the construction industry knows it but is too scared to raise it in public because of the power that this single public servant holds over their business and ability to undertake government work. The FSC and their FSO\’s are oblivious and belligerent to the thinking and psyche of the workers on the ground is a this is a shocking missed opportunity for an organisation that should be driving innovation and progression.

By: Rob Long

Rob Long — Fri, 06 Jun 2014 22:29:39 +0000

Kevin, I find it hard to believe this nonsense continues. Even the simplest understanding of Herbert Simon\’s Bounded Rationality (Gigerenzer) demonstrates that most of what is being pushed in SWMS us useless. Unless a SWMS is used as a thinking tool it is rubbish, SAI Global and all these people making money out of templates etc, should be prosecuted under anti-safety legislation. What these people don\’t realise is the culture they are creating by maintaining this stupid regime of SWMS religion. This movement to SWMS addiction simply dumbs down the workforce and devalues thinking and consultation at work. As for regulators and the OFSC, my god, give me a break, they believe their own spin and certainly neither want to debate the issue or consider contrary evidence. I have met with the commissioner on 3 occasions and each time it was clearly demonstrated the usual patronising public service worldview that they know best and contrary research doesn\’t need to be listened to. Even the most scant research in social psychology clearly demonstrates the toxicity of this trend to workplace culture. So, once the smoke and mirrors and SWMS magic has been done in the office, how are decisions really made on site? This is the real question that needs to be asked, and let me tell you, the average worker on site knows that SWMS are bullshit and they make their decisions on heuristics, biases and implicit knowledge.

By: CC

CC — Fri, 06 Jun 2014 01:06:20 +0000

I was a GM of a very large civil and construction company and pushed our organisation through AS4801 and FSC. The \’added\’ requirements for SWMS for all trades has clearly been rooted from the OFSC and their auditors requirements. If a subcontractor wishes to work for a Tier 1 or a larger Tier 2 they need to supply a SWMS for their works no matter what. I think you raise a good point between the definition of an OP vs a SWMS which is principally/legislatively intended to control high risk activities and associated hazards.
If you look at the legislated high risk activities it would appear that working with hazardous substances tends to be a \’catch all\’ for the requirement to provide a SWMS for most construction site activity, even though a lot of substances are not hazardous, yet most, if not all builders require a Haz Sub RA on all substances brought to site.

I think the awareness of safety requirements in the construction industry has significantly improved over the past 10 years and I can state from my personal company experience that injuries have reduced and workers do think a little more. However I believe the missing factor is a behavioural and psychological one as all the paperwork and planning in the world can not predict/control a dumb act or an individuals perception of risk. This determines workers behaviour towards what they do and how they do it. The big stick approach is still engrained in the industry and while this is around, workers will continue to meet this requirement to keep food on the table.

By: Dane Brown

Dane Brown — Thu, 05 Jun 2014 22:32:13 +0000

Kevin,
I see a lot of SWMS come across my desk for all manner of activities. A good proportion of which are not required by legislation. Some amde over years of misunderstanding by a subcontractor, some \”off the shelf\” from companies such as the one you describe. I find it interesting that when I press subcontractors on why they have a SWMS for a certain activity instead of a standard operating procedure, or work procedure etc they provide a lot of push back. I think there is a general fear in subcontractors (or at least the ones I deal with) that if they dont have a SWMS for absolutely every aspect of their work, they wont be allowed on site.
When pushed on reshaping their safety packages to be more usable and meaningful to their workers by only having SWMS for work that involves one of the 18 classes of high risk work, they seem dubious and I hear things like \”but such and such builder wont let me on their site without this, so Im wasting my time changing my documents\”. Im not sure what the solution is, but, surely it should stem from a cross industry push that we need usable, meaningful documents, not \”off the shelf\” systems that dont actually help the safety cause and can seemingly harm it, by breeding contempt in the very people that these documents are trying to help!
There also seems to be confusion in the construction industry about the difference between high risk construction work, and work that requires a high risk work licence. I have lost count of the amount of conversations I have had to have explaining that they are different things.
I heard Paul Breslin talk at the conference in Canberra and agreed with a lot of what he said. However, until the requirements and limitations of SWMS is better understood amongst those that arent safety professionals the prevailing attitudes of the SWMS being the safety net for businesses will be hard to change.