SAFETY MANAGEMENT – SYSTEM OR CULTURE?

C J King can develop their own system based on Bechtel Australia Pty Ltd models contained in Australian and international standards. SUMMARY Despite the fact that many mining companies There is much talk and action around the have adopted SMS, mining still kills people. development and application of Many of these deaths have occurred in sites comprehensive safety management systems with detailed SMS in place, which begs the (SMS). A range of commercial systems is question: Are SMS necessary and sufficient for available, most of which cover health and managing safety? safety and many also cover environment. In Australia, many companies have adopted a THE NEED FOR IMPROVEMENT IN commercial SMS or developed their own, yet SAFETY NOHSC figures show that every day there is a fatal work-related injury in Australia. This There were thirty-three deaths due to paper examines some of the perceived workplace injury in Australian mines in 1996/7, advantages and disadvantages of SMS and nineteen in the following year and seven in the attempts to “demystify” the management of nine months to March 1999. [1,2] This loss of health and safety. It is suggested that some life alone should be sufficient to convince commercial SMS may make safety people of the need to improve safety in management look technically complex while Australian mines, yet it is only part of the offering a “paint by numbers” solution that picture. appears to be managerially simple. It is argued that the reality of safety management Any death due to workplace injury is is the opposite – technically simple while unacceptable, however the concept of demanding strong management and workplace fatality is foreign to many sites – “it leadership. The importance of culture is won’t happen here” may be the refrain. Yet all discussed and its impact on safety examined. sites have injuries of some sort, the majority of A twelve-step guide to achieving substantial which should not have occurred and many of safety improvement in the workplace is which could have resulted in a fatality. offered, which acknowledges the need for Worksafe Australia statistics on workplace SMS but provides an appropriate contextual injury and disease for the year ending June framework. While the steps are conceptually 1994 reveal that mining had the highest rate of simple, they require clear and committed new compensation cases, at 67 lost time leadership and substantial management effort cases per thousand employees. This was to achieve. over twice the national average rate for all industries.[3] INTRODUCTION For the year ending June 1998, the lost time Much attention has been directed at improving injury frequency rate (LTIFR)1 across the safety in the mining industry in Australia and whole mining industry in Australia was 15. [1] throughout the world. The need for This is down from 27 in the year ending June improvement in self-evident: mine-site 1994, from which the workers’ compensation incidents killed thirty-three people in Australia statistics quoted above derive. For the nine- in the twelve months ending June 1997. This months ended March 1999, the LTIFR for the does not include the number of people killed mining industry was 10.[2] by workplace induced illnesses, such as due to exposure to . The direct financial cost to the mining industry of these injuries and illnesses is significant. In Many sites have introduced safety 1993/4, the average insured cost of each new management systems (SMS) to improve safety claim was A$7,900 [3], equating to a bill of performance. A number of proprietary around A$41 million in total. This does not systems are available from organisations such as NOSA, DNV Technica, Orica, HSE and 1 NSCA. These systems are generally Defined as the number of lost time injuries per comprehensive in their coverage of safety and million hours worked. A lost time injury is health issues and provide sound procedural where the injured person is unable to work and management tools for the management of their next rostered shift. Note that some use health and safety. Alternatively, companies 200,000 hrs as the denominator

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include the hidden cost to industry for one or more levels of detailed work replacement labour, lost opportunity, retraining instructions and forms below each procedure. and so forth, estimated by some to be five or more times the insured cost. The statistics Claimed System Advantages cannot show the other costs, both financial and emotional, to the injured persons and their Proponents of SMS make various claims families. regarding the advantages of SMS in general and their system in particular. In general Mining industry medical treatment injury terms, the claimed advantages are: frequency rates (MTIFR)2 are not available, however a rough estimate would be around • Comprehensive coverage of OH&S issues two to ten times higher than the LTIFR. • Auditable system – the SMS defines a To put these statistics into focus some standard and protocol to audit against comparison with other industries can help. In the chemical industries in Australia in 1996, • Measurable – can be scored to provide a there were no fatalities due to workplace measure of input to safety injury, the LTIFR was 6.3 and the MTIFR was 18.7.[4] • Best Practice – built on the collective experience of others in similar or related Some may argue that such cross-industry industries comparisons are not valid because the • inherent are different. Mining has a • Improvement-focused – from both audits greater inherent of falling rock and and user forums moving machinery. The petrochemical industry has a greater inherent hazard of injury • Effective. Some of the claims of the due to chemical agents, high-pressure steam effectiveness of implementing SMS [7] and other fluids. Simplistically, the difference include: in the nature of the industries might account for a difference in the ratio of fatalities to LTI to − Reduced injuries and damages MTI. It does not explain the much higher − Reduced direct costs of injuries rates, for all indicators, found in the mining − Reduced workers’ compensation industry. insurance costs − Improved morale, productivity and Performance in Australian mines is also poor profitability when compared to the best performing mines − Improvement communication between elsewhere. The average LTIFR for surface management and staff coal mines in the USA was 9.2 in 1996, while six international Rio Tinto mines achieved Specific vendors will make more detailed LTIFRs of zero. [5] The benchmark performer claims as they seek to differentiate their of the mining industry is Phelps Dodge product. Yet few, if any, point out the potential Corporation, with an overall LTIFR of less than pitfalls. one. [6] By any measure and any comparison, safety in Australian mines has to be improved. Potential Pitfalls of SMS

SAFETY MANAGEMENT SYSTEMS One of the problems with some systems is their complexity. For example, the NOSA All SMS involve detailed procedures in an system for mining contains over 70 elements. overall system, aimed at ensuring compliance Other systems have a similarly large number with a set of rules regarding safety, health and of elements, each of which may then have a environment management. There is an statement of intent or standard, a more overarching policy statement and there may be detailed statement of requirements, perhaps in a procedure, with any number of work instructions, forms and other tools supporting it. The sheer volume of paperwork associated with many SMS is significant. 2 Defined as above, where a medical treatment This complexity has two potential drawbacks. injury is one that involves treatment that can First, it makes safety and health management only be provided by a physician. seem more technically complex than it really is. Senior management may therefore leave it

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to safety professionals to implement it rather and long term. This implies that some SMS than taking direct ownership themselves, if may not suit some sites. A SMS that is they start at all. Such direct ownership and isolated from the company structure and drive by management is essential for success, culture will fail to deliver results.[8] however. There has also been recent criticism of the Second, it makes the SMS appear to be “the effectiveness of commercial SMS. A review of answer” that people seek to improve safety. It the ISRS, based on experience in several is easy to be awed by the apparent technical countries, concluded that “there is little support complexity of the system and miss the fact that for the claim that the ISRS is an effective management and leadership are the essential means of accident control.” [9] ingredients to making it work. In summary, potential areas of concern in SMS System gaps are another significant concern, are: the more so if the SMS is seen as a cure-all. If a site manager feels that the SMS will do • System complexity – implies safety everything, he or she is unlikely to look further. management is technically difficult Yet few commercial SMS pay sufficient, if any, attention to several areas of major potential • System thinking – implies safety hazard. The design of new plant on a management is managerially easy greenfield site is not a topic covered in most SMS, yet getting it right here is critical to long • Significant system gaps, despite claims of term performance in all areas. Similarly, being “comprehensive” modification to existing plant has the opportunity to introduce major safety issues, • One-size-fits-all approach – the apparent yet this area is largely ignored. The overall belief that the same SMS can work in any management of such projects and of the workplace, regardless of industry type and construction and commissioning phases are existing workplace culture also important but often left out or treated minimally. • Not delivering safe workplaces

That new plant design, modification and The underlying problem is that the SMS is construction are left out of a commercial SMS seen as “the answer” rather than as part of the may not in itself be a problem. Suppliers overall approach. SMS are necessary, but would argue they are outside the scope. The they are not sufficient. They may not even be problem arises if an organisation’s at the top of the priority list. management fails to note the gap and take appropriate action. SAFETY CULTURE

Another potential pitfall of commercial SMS is Culture can be defined as that mix of “shared the “one size fits all” approach. Substantial values, attitudes and patterns of behaviour that effort is expended in creating a system and, in give an organisation its particular character”, most cases, most of the information in them is or simply “the way we do things round here”. valuable. This does not mean that it should be [9] Culture serves as a “control mechanism applied equally to all workplaces. Each site is that guides and shapes the attitudes and different and will have a unique set of needs behaviour of employees” and as such defines and opportunities. the way that employees approach safety. Culture can be dysfunctional if the shared Most suppliers recognise the need to pay values of the employees are not aligned with close attention to the initial implementation and the values and objectives of the organisation. scoping, but the danger remains that the SMS [10] If the workplace culture does not can be seen as a universal cure. encourage, support and value safety, no SMS can succeed in improving. As each new safety Similarly, each site has a unique culture. It procedure or initiative is introduced, the may be positive – in that it helps the business reigning culture will determine new ways to achieve its objectives – or destructive. avoid complying and continue doing things Regardless, it must be taken into account “the way we do things round here”. when implementing a change program. The intervention used, such as a SMS, must work Culture operates at several levels that must be with the existing culture and drive towards the considered when driving safety improvement. desired culture for it to be effective in the short The culture established within workgroups and

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teams can be very strong. It must be socially safety if people do not want to follow it. To acceptable for people to do things in a safe achieve significant improvements in safety a manner but culture can prevent this. Changing change in workplace culture is required, so culture at this level involves resetting norms that safe behaviour becomes the way things and standards at the group and individual are done. levels. Commitment Another level of culture is how the organisation is managed and what systems and processes The commitment of senior management is an are in place. One of the key factors that drives absolute requirement for the success of any culture within a workgroup is how people are change program. This is more critical where rewarded for performance. Many companies people are involved – being seen to be still operate on the basis that reward is committed is as important as commitment primarily pay, while additional praise and non- itself. Unless people see their leaders financial rewards may be given for productivity. consistently living the safety message they will Such rewards are the “personal profit” that treat the new drive as another fad. Leaders people derive from selling their labour. [11] must also carry commitment through to ensure The organisational culture can set people up to that other management systems and be injured if the of losing a reward (or procedures are consistent with working safely. being punished for lost production) is greater Senior management commitment is vital in any than the perceived risk of an unsafe act. health and safety program.[12] Change at this level is about leadership and management systems and practices. Involvement

If the current culture in an organisation works Given that people are a necessary part of the against safety then the implementation of an success of a SMS it would appear to be SMS alone will not markedly improve safety. sensible to involve them directly. Too often, Cultural change is essential but, as with SMS, the implementation of a SMS is a top down it is not sufficient on its own. There are affair. The first thing that the majority of several other essential principles involved. employees know of the process is when they are whisked off for training and told to comply PRINCIPLES OF MANAGING with the new two volume set of doorstops they SAFETY are issued with.

Before trying to implement a SMS to improve As with any change process in the workplace, safety, it is important to understand the the people must be involved at the start. essential principles of safety management. Involvement should include all people in the The first point to recognise is that organisation – rank-and-file employees, management of safety is fundamentally the supervisors, managers, the CEO and the same as the management of any other board. If there is a union present include it workplace issue. It is equally important to also. If there is an industry representative realise that it is fundamentally different to the body, involve it too. Substantial improvement management of strict business issues with no in safety – and other factors – can flow from (or little) impact on the workplace. involving the workforce even without a SMS.

They key point of difference is people. Cultural Change Management of foreign exchange risk, for example, is a technical exercise. It can be To improve safety it is necessary to change done without involving the workforce at large. culture, as discussed above. To change A strategy can be chosen and implemented culture in an organisation is not easy to virtually by one person, based on sound achieve, but a consistent and considered advice, study of the market conditions and approach will produce results. First, perhaps a degree of educated guessing. The understand the existing culture and how it is success or failure depends on the actions of different from what is desired. Are people those managing the process and market thinking about safety? What do people think is forces. acceptable – ten injuries a year? One? Zero? What do they think is achievable? What are Management of safety is fundamentally the rewards and punishments that impact on different because people are inextricably safety? Look at the formal structures as well involved in the process. Regardless of how as the informal. Few companies openly good a SMS is it will fail to deliver improved sanction violation of safety rules, yet many

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push for increased production or quality in the Training knowledge that it cannot be done without taking . People at all levels of the organisation need to be equipped with sufficient and appropriate Second, create the drivers for change. Unless knowledge for them to contribute to people feel more uncomfortable with the way maintaining a safe and healthy workplace. At things are than they do about the perceived the management and supervisory level, pain of the change, nothing will happen. training should cover: Management must model the required behaviour. Create dissonance between the • Managing people for safety. How to way things currently are and the way they motivate people to work safely, both at should be by making changes. Change individual and group levels. reward systems; establish and enforce new rules; shake up dysfunctional culture by job • Safety supervision skills. Especially for rotation and targeting of natural leaders. line management. This should cover basic Create a climate of trust and select and auditing skills, training and coaching skills, promote people who have the right values and and the correct use of reward and attitudes. [10] Weaken the appeal of the punishment. existing culture to create dissatisfaction. All employees, including managers, should Third, create the environment for lasting receive appropriate training in: change to occur. Implementing the SMS is only part of the equation. Review all business • Legal responsibilities. This should cover and management systems to consider how common law obligations (general duty of they impact on safety. Reward and care under common law) and specific punishment systems must be consistent with obligations under the applicable what is trying to be achieved. Examine occupational health and safety act and systems for promotions, pay rises, bonuses related legislation. and other less structured systems of recognition and praise. • Moral and ethical drivers for safety. This will be a reflection of company values and It is important to ensure that the SMS – and should recognise that different ethnic and other systems – recognise that people are not social backgrounds can yield different robots. It is not a matter of issuing instructions views on morals and ethics. and then expecting it to happen. People generally want to be actively involved in work • Hazard identification, risk assessment and and to use their brains and creativity. Too control tools appropriate to their role. often, this is stifled by systems that allow no These can range in complexity from flexibility. One response is to become a robot, simple observation methods through to requiring detailed programming for every task detailed quantitative methods. thus making the job of management harder. A more sinister response is to find ways of • Job-specific safety requirements. The causing the system to fail, or to find new and emphasis is on job-specific. This training creative ways of beating the system. Both should make employees aware of the responses can result in increased injuries. To known hazards in their area or line of avoid either of these responses, the SMS work. should only be strict and inflexible when the risk warrants it. It should also be as simple as • Behavioural programs. There are several possible without compromising standards. . programs available that focus on developing safe behaviour. Many Goal setting and feedback programs are companies find that after two or three effective interventions for driving cultural years with one program the returns change. [9,13] Such programs are proactive diminish, so changing to another program rather than reactive. Clearly defined, may be appropriate. measurable and achievable goals are set in cooperation with the workforce. Prompt, • Workplace observation and auditing skills. accurate and meaningful feedback is then This focus should be on the individual’s provided on progress towards the goal. own working environment. Change in behaviour and attitude – or culture – has been shown as a result of such programs.[9]

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Hazard Management been discussed. Other stakeholders may also play a part or have some interest and With the exception of some of the training should be at least informed if not invited to elements, the above three principles do not participate: the statutory authorities; relate specifically to safety. This is deliberate shareholders; local community; – there is nothing mystical or special about employees’ families; customers; suppliers safety management. The specific technical element is hazard management, summarised 3 Strong leadership. Leadership can be using the abbreviation HIRAC – hazard positional, such as the CEO or a identification, risk assessment and control. supervisor, or personal – someone people This should be the heart of any safety and look at to set the pace. Ensure that the health management system. There are three formal leadership in the organisation is elements: fair, honest and firm, and that all leaders share the same values and goals for the • Identify the hazards in the workplace program. Identify informal leaders and gain their commitment and support. • Assess the risk – qualitatively is usually sufficient, but quantitative methods are Establish a System available A safety management system is required. It • Eliminate, reduce and control – apply the should be as simple as possible and should hierarchy of controls: eliminate, minimise, not be seen as The Solution. It is a necessary protect part, but only a part.

This basic HIRAC model can be applied 4 Identify the controls. Apply HIRAC to equally in routine operations, changes to the operation through appropriate existing operations, design and development workshops and studies. The controls will of new plant and during construction. The be organised into a SMS. Ensure existing SMS should derive from the control measures controls – both formal and informal – are identified for the site, not a preset list of identified. Building on existing controls elements. Note that the SMS is therefore increases ownership and reduces towards the bottom of the hierarchy of resistance. controls, not the top. 5 Develop the system. Look at commercial 12 STEPS TO IMPROVED SAFETY SMS packages and choose one that is 80% right for your industry and your Many of the following steps are difficult and culture, or develop your own. If using a complex and have no universally correct commercial package, add and subtract method to follow. They are not necessarily elements as required. Simplify as far as chronological, although there is some logic to possible – the second draft should be half the flow. In implementation, however, the size of the first. Focus on concepts management will find that it has to work on and on asking people to think about more than one step at a time, or return to an safety. Be prescriptive only when earlier step that appeared to have been necessary and explain why. completed. 6 Implement. The structure and enabling Workplace Culture policies and training should be implemented with some clear signal and Get the workplace culture right, or at least fanfare. Don’t wait until all the details are moving in the right direction. Focus on: in place before launching – prepare people for a staged implementation based on 1 Management commitment. Unless there identified risks. is clear, visible and communicated absolute commitment from the entire Make it Work management team, employees will see it as just another fad. Management must be Don’t expect overnight success. Be prepared effective role models of desired behaviour to work at it for as long as it takes. Some tips: at all times 7 Ignore the ratings. For example, if the 2 Involvement of all stakeholders. The package chosen uses a five star rating importance of involving the employees has system or gives scores out of 100, ignore

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them. Get the audits and the feedback but element. Basic training in auditing focus on implementing the things that skills should be provided. They focus matter. A “three star” rating can be on ensuring that what the system achieved without actually improving safety requires to be done is being done. – and the workforce will see through this immediately Each type of audit will generate actions, which should be objective, specific and based on 8 Be honest and open with the workforce. clear evidence. Management must ensure Share the successes and failures that appropriate systems are in place to honestly. Involve people in examining ensure actions are implemented appropriately. failures and identifying alternatives. Note that actions can be rejected if clear reasons can be provided. 9 Be consistent and diligent. When things don’t change overnight, don’t give up. 11 Improvement teams. There are many Many cultural change programs take years ways to structure these. They may be ad- to bear fruit. Expect some opposition and hoc in response to a perceived opportunity prepare to resist it. Be careful in or routine. They should not be allowed to evaluating progress – use a range of take control of the agenda on safety, indicators including surveys of employee however, or become too bureaucratic. attitudes and perceptions. 12 Celebrate wins and learn from losses. Review and Improve People – including managers – tend not to notice progressive changes. Ensure that The final three tips focus on the ongoing effort changes for the better are noted and required to keep the safety program alive. publicised. Small “celebrations” for each step are appropriate and may be as simple 10 Audits. There must be regular audits of as a paragraph of text and a photo in the the program, of which the SMS is a part. company magazine. Avoid being too Three types of audits should be dramatic or glamorous – people tend to considered: have adverse reactions to glossy publications that sing the praises and are • A management system audit focuses silent on the problem areas. Ensure that on overall system “health” and problems are acknowledged and management involvement and action. investigated so that they can be Initially these should occur every six to capitalised on. twelve months, reducing to perhaps every two years. They are largely CONCLUSION desktop and interview based with minimal field verification. The current level of safety performance in Australian mining is unacceptable by the • Specialist audits focus in on what the standards society applies today. It may not be system actually requires. They ask the worst performing industry overall, but the two key questions: is the system number of deaths due to injury and illness element appropriate for the hazard at alone demand action. this site? Is the system element being implemented effectively? A frequency The management of health and safety requires of once a year initially, stretching out strong leadership and commitment from the to once every three or four years once management team. Technically, the process the system is well established, is is simple: identify the hazards, assess the risk recommended. These audits require and implement controls. Specialist expertise is people with specialist skills in the required for only a small part of it. The fields being examined together with challenge is in the leadership – making it sound auditing skills. These audits happen. require substantial verification effort. Substantial and lasting improvement in safety • Local audits carried out by employees. requires a cultural change in most workplaces. These are verification audits and can Yet it is not appropriate to accept the current often be done using checklists. The level of death and injury on the basis that frequency can be set individually for improvement will take time. Management each element, depending on the risks must accept the responsibility of leading their involved and the strength of the organisations’ through the changes necessary

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to achieve change. It starts by saying that the Practitioner, Mar 1997, vol 15, no 3, pp26- current situation is unacceptable. 32

Management commitment is a far more 10. Robbins, S P, et al (1994) Organisational significant factor than the brand of SMS Behaviour – concepts controversies and chosen. Second to this commitment would be applications, Prentice Hall, Sydney management honesty throughout the process, followed by the open involvement of the 11. Whiteley, A (19950 Managing Change – a workforce and other important stakeholders. core values approach, Macmillan, Melbourne The process is technically simple as the 12- steps outlined above show, but demands 12. Worksafe (1994) Implementing OHS in commitment and leadership. There is no point the workplace, in Submission to the starting unless you’re serious. Given the state Industry Commission Inquiry into OHS of safety in Australian mines, it is clearly time arrangements in Australia, Sydney to get serious. 13. Marsh, T (1998) “Behavioural Safety – an REFERENCES Overview”, Ryder Marsh Occupational Psychologists, at www.rydermarsh.co.uk. 1. MCA (1998) Safety and Health Performance Report of the Australian 14. Hurst, N (1997) From research to Minerals Industry – 1997-98, Minerals practical tools – developing assessment Council of Australia, Canberra tools for safety management and safety culture, J of Loss Prevention in the 2. MCA (1998) Australian Minerals Industry Process Industries, Jan 1997, vol 10, no 1, Safety & Health – Safety Survey Report pp63-66 for 1 July 1998 – 31 March 1998, Minerals Council of Australia, Canberra.

3. Worksafe (1996) Compendium of Workers’ Compensation Statistics, Australia, 1993-94, National Occ. Health and Safety Commission (Worksafe Australia), AGPS, Canberra

4. PACIA (1997) Chemical Companies Safety Performance – 1996, Plastics & Chemicals Industries Assoc, Melbourne

5. Rio Tinto (1997) Health, safety and environment report 1996, Rio Tinto Ltd, Melbourne

6. Dotson, K B (1996), An International Safety and Health Measurement Strategy: Corporate programs, systems and results, Minesafe International Conference, September 1996, Perth, Western Australia, pp17-26

7. NOSA (1994) Guidelines for the Implementation of the NOSA Safety System (for CRA Ltd), NOSA Australia

8. Greek, D (1995) Accidents will happen, Professional Engineering, 5 Dec 1995, vol 8, no 21, pp28

9. Cameron, I (1997) A social learning approach to the practice of safety management, Safety and Health

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