FRONTLINE TO DIRECTORS:

HOW TO GET YOUR ENTIRE WORKFORCE

ENGAGED WITH HEALTH & SAFETY
INTRODUCTION

The new ISO 45001 includes a statement about Occupational Health and Safety (OH&S)
that we probably already knew: 

“  The success of the OH&S management system depends on leadership,

commitment and participation from all levels and functions of the
organization.”
ISO 45001 goes on to define “participation” as “involvement in decision-making” and
urges leaders to make sure that they are “engaging health and safety committees  and
workers’ representatives.”  Engaging is not defined, but it’s clear that it’s about more
than issuing procedures and asking for comments.

The UK Health and Safety Executive (HSE)
had realised for a long time that alongside
“compliance activities” based on legislation
and approved codes of practice, there is a
need to consider the safety culture of an
organisation.  Again, a key element of
success has been identified as “workforce
participation and ownership of safety problems
and solutions.”
Recognising the benefits of participation is
not new. The 1918 annual report from the
British chief inspector of factories and
workshops explained that “if a real reduction
in accidents is to take place, it can be affected
only by the joint effort of employers and
workers.”
Whether looking at your OH&S
management system from the perspective
of standardisation or of culture, worker
participation and engagement is therefore
an essential component.  
But what is safety culture, and whose job is
it to change it?  If it’s not just a feeling, but
about people doing the right thing, is
behaviour-based safety the answer? And
does all of this just mean more work for
over-worked safety professionals? 

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AREN’T WORKERS PARTICIPATING
WHEN THEY DO AS THEY’RE TOLD?

There has been a historical division between So, having determined that to stay safe
those who decide what needs to be done, and workers should lift carefully, wear goggles
those who do the work.   and hard hats, and wait until the power is off
before removing a guard, why don’t they
The land owner says plant corn on Monday, just do it?
the farm workers plant corn on Monday; Mr
Ford says assemble this part of the motor car, Many consultancies take this attitude in
workers assemble the parts of the motor car selling Behaviour Based Safety (BBS)
assigned to them. programmes to make workplaces safer.

Here are some examples of their claims:

"These days, most organisations do  the physical and systems parts of safety well
and injury rates have fallen. But not to zero and here’s why.  Sometimes people
decide not to put on their hard hats in a hard hat area. Sometimes they cut corners
just to get the job done… Even though physical and systems approaches to safety
are working well, people are behaving unsafely.”  
www.lattitudesafety.co.uk

“One way to improve safety performance is to introduce a behavioural safety

process that identifies and reinforces safe behaviour and reduces unsafe behaviour.” 
www.thinkactbesafe.co.uk

“80 of every 100 accidents that happen in the workplace are ultimately the fault of the
person involved in the incident... Workers are not taking the proper precautionary
measures before working, or they are simply too lazy to be bothered with it.” 
www.safetypartnersltd.com

“Over 80% of injuries at work are a direct result of decisions made by people, which is
why we really need to understand why people behave the way they do!” 
www.behaviouralsafetymentors.co.uk

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AREN’T WORKERS PARTICIPATING
WHEN THEY DO AS THEY’RE TOLD?
The Behavioural Based Safety  approach
assumes that“organisations” are getting it
right, so all we need to do now is “fix” worker
behaviour. Reinforce workers if  they wear
goggles and hard hats and punish them if they
cut corners.
There are many problems with this way of
treating workers.  First, it assumes that the
employer is already doing enough – that
“most organisations do the physical and
systems parts of safety well.”  Even if you
had it right a few years ago, workplaces
change.  
Are our systems adapting quickly enough to
new ways of working?  Can any of us, hand
on heart, say there is no room to improve
our systems?  
This is rather like setting a rat in a maze.  If
the rat heads to the left, it will get an electric
shock; if it heads to the right, it will get a lump
of cheese.  It learns to head to the right;
“Shall I do the right
thing, or shall I
harm myself?”
the BBS view of
workers
The late, great Professor Trevor Kletz,
known as the founding father of inherent
safety, summed up the attitude.  “Managers
and designers, it seems, are either not human or
do not make errors."
The second problem is that BBS ignores the
fact that people are not rats. 
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AREN’T WORKERS PARTICIPATING
WHEN THEY DO AS THEY’RE TOLD?

Look at the scenarios below to see the real reasons why people don’t “do the right thing.”

SCENARIO ONE 

In case fragments are ejected by the drilling, Sami has been

told to wear goggles.  However, the goggles provided fog up
easily. Last time he was drilling he mis-positioned the work
piece because he couldn’t see properly.  The supervisor gave
him a dressing down for wasting materials and time.

SCENARIO TWO

Jan knows that the procedure says “lock out the power and
wait for the machinery to cool down before removing the
guard.”  However, the supervisor made it clear the job needed
to be completed before anyone was allowed to clock off.

SCENARIO THREE

Rose’s manual handling training emphasised the use of a

trolley when moving deliveries from the loading bay to the
post room.  When she’s in the loading bay on another task she
gets a call that a delivery is needed urgently.  The trolleys are
all in the post room – there are no spare ones in the loading
bay.  The delivery looks bulky, but she could probably just
manage to carry it - if she’s careful.

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AREN’T WORKERS PARTICIPATING
WHEN THEY DO AS THEY’RE TOLD?

The reality can be more like the second maze,
where the preferred procedure is harder to
follow, and has short-term negative
consequences, whilst the “dangerous” option
is reinforced – until an accident occurs.
The rats stopped pressing the lever –
sacrificing their own reward for the sake of the
other rat; other rats learnt to press a lever just
to help another rat in a water trap. 

It turns out, even rats think about the problem If a lab rat can do more than behave, and can
in a more complex way than the behaviourists think about a problem, why would we treat
believed. 
  people as though they were just a box that
responds to inputs? 
In one study rats were given a lever which, as
well as providing them with food, caused
another rat to receive a shock. 
 

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AREN’T WORKERS PARTICIPATING
WHEN THEY DO AS THEY’RE TOLD?

People who should know, in academia and industry, have criticised the way that BBS has
been used in the worklplace:

“As behavioural safety focuses on the end point of a chain of events that lead to a
worker doing something, it does not address the question of who makes the decisions
about work speeds, productivity levels, shift patterns and how they relate to safety…
the decisions made at board-room level can have much more effect on injury rates than
what individual workers do.” 
www.TUC.org.uk 

“The tendency is to focus on individuals and fail to address management behaviour,

thus excluding activities that have a significant impact on safety performance.” 
HSE Specialist Inspector

“Everyone, and that includes you and me, is at some time careless, complacent,
overconfident, and stubborn. At times each of us becomes distracted, inattentive,
bored and fatigued. We occasionally take chances, we misunderstand, we misinterpret,
and we misread… Because all these traits are fundamental and built into each of us, the
equipment, machines and systems that we construct for our use have to be made to
accommodate us the way we are." 
Professor Alphonse Chapanis
Former Professor of Human Factors engineering

www.safetypartnersltd.com

“Beware Behavioural Safety: Fix the hazard don’t blame the workers.” 
www.unitetheunion.org
Unite, UK trade union

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AREN’T WORKERS PARTICIPATING
WHEN THEY DO AS THEY’RE TOLD?
Not only does BBS ignore the organisational
problems, it can have the opposite effect on
behaviour to the one intended.   workforce which can adapt as situations
It can drive reporting underground, meaning
that the very information you need to make
the workplace safer is hidden from sight.  Or
imagine for a moment that it works – that you
could train people to behave as obedient lab
rats at all times, regardless of other social or
practical factors.
What would happen when flexibility of
thinking was needed, to solve an unusual
problem, or to avert disaster?  If you’ve
watched Apollo 13 you’ll know how vital it is
to know how and when you can change the
rules.
Do we want workers who follow
instructions, to the letter, or do we want a
change?  
The workers need to see what the maze
looks like from above. You want people to do
the right thing when you’re not watching,
and to feel able to explain without fear of
punishment when they can’t do the right
thing.  
You want them to use their own knowledge
and experience to make suggestions when
they believe they know a better way of doing
something.
If you want the right things to happen, you
need the right SAFETY CULTURE.
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WHAT IS CULTURE?
The definition of culture in ISO 45000 is “the
product of individual and group values, attitudes,
managerial practices, perceptions, competencies
and patterns of activities that determine the
commitment to, and the style and proficiency of,
its OH&S management system.”   These people will avoid alcohol (or get a taxi)
That’s a lot to take in, so we’ll start with some
simpler definitions – and return to this one
later.
The HSE define culture as the “ideas and beliefs
that all members of the organisation share about
risk, accidents and ill health.”   the speed limits when there are cameras –
But can all members of an organisation share
the same beliefs?  Whilst we might share the
 same view about accidents and ill-health – we
don’t want them for ourselves or our
colleagues – we don’t share the same view of
risk.  
I don’t drink and drive because I want to stay
safe, and I believe that even after one pint, my
reaction time is reduced. Others, who think
they are better drivers than me, might believe
they can drive quite safely after two pints.  
For them, the perceived risk of having an
accident is not significant, so the state tries to
replace fear of an accident with fear of being
breathalysed and penalised.  
not because of the same belief about the risk
of an accident, but because of a belief about
the risks of getting caught.
A more colloquial description of safety
culture is “what happens when no one is
watching.”  The over-confident driver sticks to
and speeds when there are not.  
So, is changing the culture about getting
everyone to see that something is dangerous,
and that the precautions defined should be
applied, even when no one is watching?
Perhaps, for some processes (such as driving)
that might be the solution, but workplaces
are more complicated than that.
 
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WHAT IS CULTURE?
Too often, the problems have come about
because it is the management who are over-
confident about the ability of the
organisation to manage the risk.   didn’t accept there was a significant risk and
The disasters that struck the Challenger
Space Shuttle in 1986 and the Colombia
Space Shuttle in 2003 have both been
attributed to the NASA safety culture, where
management ignored the concerns of the
engineers and technicians about risk.
The report into the 1987 capsize of the
Herald of Free Enterprise, which resulted in
188 deaths, revealed that crew had raised
concerns in the past about the pressure to
leave port early, and about the lack of
controls over passenger numbers (which
meant the ship sat lower in the sea than
planned for).   our role as OH&S professionals in making
Three captains had previously asked for
indicator lights to be fitted on the bridge to
show the status of the bow doors (which had
been left open on departure from
Zeebrugge)
Captains had also made requests for high-
capacity pumps, which might have given
more time for rescue.  Senior management
dismissed suggestions as too costly.
Accidents at Grangemouth, Flixbororough,
Piper Alpha, Kegworth and Clapham have all
been blamed on management and
organisational factors.
But no manager, however senior, wants a
disaster on their hands. Surely they would
listen if someone told them what was wrong?
Somehow, the information must get from
those who understand the work to those
who manage the work.  Which brings us back
to worker participation and engagement, and
that engagement happen.
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"CULTURE CHANGE SHOULD COME
FROM THE TOP- IT'S NOT MY JOB"

In an ideal world, safety leadership comes from ISO 45001 (Clause 5.4) suggests that
the top.  ISO 45001 declares that top barriers to participation include “failure to
management are responsible for “developing, respond to worker inputs or suggestions,
leading and promoting a culture in the language or literacy barriers, reprisals or threats
organization that supports the intended outcomes of reprisals.”  
of the OH&S management system.”  But if they
don’t, does that mean you should do nothing? In the case of the Herald of Free Enterprise,
 And if they do lead, what is your role in people had raised problems and offered
supporting that process? solutions.  Nothing was done.  People learnt
to get on with their work.  
Other managers will use the workers as the
excuse – they just don’t want to participate.  Is
that true?  Or have they stopped participating
because they felt no one was listening?  Or  
worse, because they feared what would happen
if someone listened?
 

CASE STUDY
In 2012, the Office of Rail Regulation (ORR) carried out a safety culture audit of Croydon
Tramlink and concluded that “it appears a reasonable level of safety culture exists within
Croydon Tramlink.”  However, it noted that “some front-line management are considered
as being more approachable and/ or receptive than others.”  

When a tram crashed in 2016, killing seven people, the Rail Accident Investigation Branch
(RAIB) sent a questionnaire to all tram drivers working for the organisation.  On a scale of
1 to 10, where 1 indicates a manager is difficult to talk to, and 10 indicates a healthy, open
relationship, the average score drivers gave to senior management was 3.6.  For
relationships with immediate line managers, the score was only a little better, at 3.8.  

Other drivers before the accident had suffered a temporary loss of situation awareness in
the tunnel just before the crash site; other drivers had used heavy braking or used the
hazard (emergency) brake to control their speed at the same location.  They did not report
these issues for fear they would be criticised.  The risk assessment team had not identified
the possibility of overturning on a curve at speed as a hazard and had received no
information to change their mind.

The RAIB report on the Croydon tram crash made an important recommendation: 

“THERE NEED TO BE IMPROVEMENTS TO SAFETY MANAGEMENT SYSTEMS,

PARTICULARLY ENCOURAGING A CULTURE IN WHICH EVERYONE FEELS ABLE TO
REPORT THEIR OWN MISTAKES.”  

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"CULTURE CHANGE SHOULD COME
FROM THE TOP- IT'S NOT MY JOB"

There is a chicken and egg situation here.  If your current culture makes it difficult for people to report
problems, how will you get the information you need to change the culture?

Is one solution to shorten the communication

path between the people who witness the
difficulties on a daily basis, and those who are in
a position to do something about it?  Rather than
expecting everything to go via line supervisors
and middle management, the decision makers
and frontline staff need to communicate directly.

Inviting employee representatives to

management meetings to discuss safety is a
positive indicator, but it restricts the type of
person who contributes to those who like going
to meetings and speaking out. Further, it can
delay information sharing if everything is saved
up for the monthly safety meeting.

Another solution of BBS is to have “trained

observers” who are taught to make
observations.  The essence of participation
and engagement is that everyone can make
observations, and feels a commitment to
doing so.  “I’m not a trained observer” could
be a great excuse for apathy, leaving it to
someone else.

If workers can raise concerns or make suggestions when it’s convenient for them, perhaps they will
participate more.  If they get great feedback as a result of their participation, perhaps they will
continue to participate.

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“OK, SO IF WE DO GET THE WORKFORCE
TO PARTICIPATE MORE, I WON’T BE
ABLE TO MANAGE THE EXTRA WORKLOAD”

You are of course absolutely correct. Imagine you have this app and people are
reporting both hazards and suggestions for
 If the workforce start to fill in observation improvement.  How would you like to manage
cards by hand and post them into a box for you it all?  Perhaps you’d start with a simple
to collect, or they start sending you summary of everything that’s going on – like a
observations by email, text or even Twitter, you dashboard provides a summary of all the
will be overwhelmed.   complex processes going on under the bonnet
in a car.  
You might spend the first part of everyday
transferring the details into an unwieldy You could see how many issues had been
spreadsheet (but do make sure you use the passed to each department, and monitor
right version, and that someone hasn’t edited progress.  You would only need to get involved
and renamed it since you last opened it), and if a department wasn’t managing issues.  You
the rest of the day chasing emails with actions could drill down where you see hot spots.
in response to a few of the observations that  Why are there suddenly lots of problems in
you noticed first (you haven’t had the time to the loading bay?  Are some managers better
prioritise). than others at closing out actions?  Have more
Wouldn’t it be great if workers could report health topics been raised since the awareness
 issues directly, with the minimum of effort, campaign?
using the phones they always have with them?
 
 Imagine that the worker can snap a photo (that
saves 1000 words) to explain the problem, with
the location, time and the name of the reporter
automatically included (without some tortuous
login process).  That they can pick a category
from a list so that the report is automatically
copied to the right people (like the facilities
manager, or the head of a department) without
waiting for you to get out of a meeting and
forward it.  

And then imagine if it’s so easy that instead of

just reporting problems, people start reporting
suggestions which not only improve safety, but
perhaps increase productivity, reduce waste, or
save time?  

The app would have to be simple enough that

everyone can participate in observations – not
just the BBS trained observers.

  Effective Software's ENGAGE app in action

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“OK, SO IF WE DO GET THE WORKFORCE
TO PARTICIPATE MORE, I WON’T BE
ABLE TO MANAGE THE EXTRA WORKLOAD”

Amidst the listing of virtues in the ISO 45001 Staff must believe that there is a just culture,
definition of culture were some useful levers – where the response will concentrate on the
in particular, “your activities and the learning opportunity rather than disciplinary
management system you are responsible for”. action.

If you want to drive safety culture up and
down the chain, perhaps you need to review
your activities, and get some new tools to
support your management system.  Tools that
engage workers by treating them as
participants not maze rats - and engage senior
management by providing them with
information they can’t ignore.
As ISO 45001 describes it, safety culture
should be “founded on mutual trust.”  
ISO 45001 concludes “Processes for the
receipt of suggestions can be more effective if
workers do not fear the threat of dismissal,
disciplinary action, or other such reprisals,
when making them.”  

What the software can’t control is how your Obvious really.

organisation responds to reports.  If someone  
admits to falling asleep on the job, of needing  
to brake too sharply, or of forgetting a critical
step in a procedure, will they be punished?  Or
will someone consider whether shift patterns
are causing fatigue, whether automatic speed
limiters would be effective, or whether a
procedure is too complex?

 
 

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