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Swimming Up Stream and the SWMS Dilemma
I was with an organisation this week that was being inspected by the regulator. The regulator had the unenviable task of assessing whether this organisation was appropriately managing risk. The regulator generally uses several tools to determine the management of risk: observation, conversation and documentation. It’s pretty easy to see this mob were not an organisation but a dis-organisation. However, organisation in itself does not guarantee professional risk management.
Conversation is an excellent tool for assessing culture and the psychology of risk but you have to know what you are listening for. Unfortunately, the psychology of risk is not the core business of regulators and so I can’t imagine them being skilled enough to use this tool well. The conversation tool relies on skilled knowledge of pitching, framing and priming language. Understanding cultural discourse is much more complex than doing some HR communications course. Listening and ‘speaking into’ cultural discourse requires a sophisticated knowledge of human mentalitie. This is not a spelling mistake but indicates a special understanding of the mental equipment humans use to make judgments and decisions (from Annales School and Lucien Le Febre). Skilled conversations about risk culture doesn’t come without some coaching and study. Most people know that if your tell the regulator what they want to hear then you will pass the inspection.
This leaves the final tool and this is where the dilemma really intensifies. The primary tool for evidence in managing risk for the regulator is documentation. Documentation is wonderful evidence in court, although photos are pretty good too. The primary tool of documentation for the regulator is the Safe Work Method Statement or SWMS (pronounced ‘swims’). Some industries call this document a Job Safety and Environment Analysis (JSEA). SWMS are intended to serve as a front line tool for the documentation of thinking about risk and hazards at each stage of work and the controls used to minimize risk at each stage.
SWMS have now become an industry in themselves. I know several large projects which have more than 2500 SWMS for every conceivable activity on site. The organisation I started this discussion with failed on their SWMS because the format wasn’t right? It’s now got to the stage in some industries where SWMS are completed for the most trivial activities. Some industries, unions and regulators are so paranoid about SWMS today that they have become the new Bible for risk management.
Here’s the dilemma. Most SWMS are completed by professionals, trained safety officers and office-based people who have a certain level of bureaucratic literacy. Many organisations construct their SWMS by copy and paste from successful SWMS from other organisations. They then tweak it a bit, see if it gets over the line and then edit until it is passed by the regulator. Once this is done everyone on site sign on to the SWMS, the classic example of ‘tick and flick’. No-one other than the official really digests or comprehends the SWMS because some are in excess of 30 pages for even quite simple activities. Of course the assessment and management of risk requires high levels of imagination and creativity, the very qualities which are generally absent in bureaucratic mentalities but present in worker mentalities. So the people preparing the SWMS are constrained in their creativity about risk in the SWMS and besides, the regulator doesn’t want imagination anyway, just conformance to acceptable type and style. Many SWMS processes between a company and regulator remind me much more of a Primary school teacher correcting a grade 6 project than a purpose driven safety tool!
Most people ‘on the tools’ have low levels of bureaucratic literacy and just want to ‘get the job done’ so they sign it off believing it is simply and ’arse coving exercise.’ Results for the MiProfile Survey show that 75% of all workers believe this is the fundamental purpose of SWMS.
The real dilemma with SWMS concerns the gap between ‘projected risk’ and ‘attributed risk’ in the SWMS and ‘actual’ or ‘real risk’ in the field. Whilst the SWMS are intended to be a safety thinking tool, this is not how they are used. They are used more and more as an end in themselves and are quickly becoming meaningless in the battle against reckless risk taking behavior in the workplace.
Author’s Resource Box
Dr Robert Long
PhD., (UWS) BEd., (USA) BTh., (SCD) MEd., (Syd) MOH (La Trobe), Dip T., Dip Min., MACE, CFSIA.
Executive Director – Human Dymensions Pty Ltd
Rob has a creative career in teaching, education, community services, government and management.
Rob is engaged by organisations because of his expertise in culture, learning, risk and social psychology. He is a skilled presenter and designer of learning events, training and curriculum.
Web Link: www.humandymensions.com
{ 4 comments… read them below or add one }
I’m at a loss as to why SWMS are seen as the ‘primary tool of documentation’ except in the construction industry where work sites, and work areas within the sites, are changing rapidly every day.
I have worked (only briefly) in construction and, as I understand it, SMWS are intended to establish a safe approach to managing a variety of sequential tasks within the changing work environment – hence, although the sequence of steps rarely changes, how can a SWMS be ‘pre-prepared’ to suit every worksite? This is where the dearth of ‘paperwork’ is required and rightly so due to the ever changing hazards and associated risks.
However I currently work within the disabilities services industry and also have significant experience in manufacturing and mining (quarries) industries. (In fact I have in total over 20 years experience in OHS/WHS across multiple industries along with a trade background (fitter machinist) and front line/middle management experience prior to specialising in OHS).
In each of these industries my approach is to restrict SWMS to contractors (who do basically standard jobs on different worksites) and encourage managers and supervisors to develop Safe Operating Procedures (SOPs) for instruction on using items of plant safely and Safe Work Procedures (SWPs) for standardised/routine/repeated tasks, that may or may not involve the use of plant – hence include reference to relevant SOPs as necessary. SOPs only need to be changed if the plant is changed and SWPs only need to be changed if any change occurs within the workplace or task – otherwise both types of document are relativley static in content.
This approach then reduces the need to constantly write and rewrite documents that are capable of being standardised. The finished documents are also extremely useful for training personnel in safe use of plant and in performing tasks safely.
Well said and am totally in agreeance with the overabundance of paperwork that is out there. I also place giving everything a risk score in the same category as well. Ask the workforce what risk score they give everything and the answer is low. Why, because that usually means less signatures and they can get started with the job and usually means it has defeated the purpose.
One point that I would like to add is that the prime reason (IMO) this overabundance of paper has occured is that organisations are nailed to the wall in the event of a prosecution if they don’t have it as this appears to be the only thing that proves they are managing safety.
These sorts of articles are preaching to the converted for the most part but we don’t seem to have any linkages or influence with the legal system and how it is applied.
Dr Rob
Your article is on the money. May be you could re-title it to be “Sink or SWMS”.
There is a plethora of key documentation in play today that adds little or no value when in such quatity and completed remotely from those undertaking the actual work (by professional in a corporate or site office). Why not stop and ask the workforce what they see as adding value to the risk management equation?
We may be shocked to hear that all this “preceived key documentation” is nothing more than toilet paper rather than actually helping them understand how best to complete the job task safely to a quality standard in a reasonable space of time. The old expression of let me “plan my work and work my plan” rings true.
Regards
Dr Ian
Totally agree, I’m trying to stop the panic in one of my entities now due to regulators visiting soon and their lack of SWMS’s for everything. Saw one reecnlty on how to sweep a path with a broom (it must have been a joke, but they were serious).