Intelligence

HOW SHOULD ONE ACT?

In the last of our series on management systems we come to ACT. We could have started with it and indeed we could have started anywhere around the PDCA circle, in truth. But at the end of a calendar year and prior to the start of the next financial year, now would be the time to have a review. The reason I say we could have started with ACT is that the review should be about preparing for the future not about wrapping up the past in a nice neat know. If your CHECK activity hasn’t thrown you a few curveballs and made you rethink your policy and strategy, you maybe haven’t been doing it right. The recipe for a Management Review should has the following ingredients:

• Senior Management involvement.
• Genuine consideration for the widest group of interested parties and the involvement of frontline workers, operational managers, HR, Finance, and Legal advisors as well as H&S Team.
• An accurate but concise visual summary of your performance indicators (PI).
• Your current objectives writ large and how you’ve gotten on with them.
• The power to make, resource and commit to a new set of objectives and targets going forward.
• A critical appraisal of the fitness for purpose of your H&S policy and procedures given what you now know.

SENIOR MANAGEMENT INVOLVEMENT

There is too much comfort on the boards of many of the organisations I meet and speak to. They are very able to tell you how good they are at H&S. “It’s the number one item on the agenda”. Listen closely to the proceedings of that board meeting, though, and you hear: “OK. Item 1. So has anyone got any H&S stuff? No? Anyone? No. OK, moving on to Item 2…”. If you listen to the rest of the meeting though, you’ll hear mergers and acquisitions discussed, redundancies and hirings, profit and loss, expansion into new markets and contraction in areas of low growth or opportunity, shares issued or bought back, new products proposed and old lines discarded. I promise you every single one of those discussion as has a health and safety impact.

If you want to smash it as a lazy board member there’s one killer question you can ask: “yes but how much is all this going to cost?”. Bang! Now everyone else is on the back foot and you can go back to sleep. It’s such a good question. And so is: “yes, but how safe is it?” or “yes, but how healthy is that?”. Integrate H&S into your business, not as a line item but as currency. Imagine your level of H&S as something liquid. Let your performance data inform you about the risk environment you are in or moving into. You should be making plans with the H&S risk as a known and quantifiable thing you, as leaders, can judge honestly and precisely.

One of the responsibilities of a management review is to become more resilient. There is a brilliant book calle  The Ostrich Paradox: Why we underprepare for Disasters by Robert Meyer and Howard Kunreuther. They identify six biases that stops us from planning correctly:

• Myopia: a tendency to focus on overly short future time horizons when appraising immediate costs and the potential benefits of protective investments;
• Amnesia: a tendency to forget too quickly the lessons of past disasters;
• Optimism: a tendency to underestimate the likelihood that losses will occur from future hazards;
• Inertia: a tendency to maintain the status quo or adopt a default option when there is uncertainty about the potential benefits of investing in alternative protective measures;
• Simplification: a tendency to selectively attend to only a subset of the relevant factors to consider when making choices involving risk; and
• Herding: a tendency to base choices on the observed actions of others.

You can structure your management review information to head off these biases from the outset

1. Pose the sustainability question. Get management thinking about sustainability in the longer term “Where are we going to be in 10 years time? Where do we want to be in 20 or 30 years?
2. Use data trends and go back as early as the data allows. Share the Root Cause analysis of failure again as “Lessons Learned” bullets.
3. Refocus optimism where it should be: taking effective measures to manage risk
4. Disallow inertia: every Director must have one new H&S objective or initiative at each Review.
5. Don’t skimp on your PI’s. Keep it concise but you must get more indicators of performance than just accidents, and you must have proactive indicators
6. Use benchmarking but sparingly. We’re not copying our competitors, we’re trying to be better than them.

INTERESTED PARTIES

Margaret Heffernan in her brilliant book Wilful Blindness writes: “Corporate governance in general needs a profound reappraisal; the governing boards of organisations need now to acknowledge their routine structural failures. Tesco, BHS, Volkswagen, GM, Mirror Group Newspapers, Kensington and Chelsea council, Rotherham council, the BBC, Facebook, Virgin East Coast rail, South Yorkshire Police, Uber, the Weinstein companies, Lloyds Banking Group, Carillion: these and many more had boards or trustees who failed to do their jobs… That the boards of private companies and public organisations are filled with like-minded individuals, often selected because they can be relied upon to agree with one another, explains many institutional failures we have seen in the last twenty years”.

You must have noticed the swing away from using the term stakeholders. There’s a good reason for this. It implies the only people who have an influence on you are those who have a direct measurable interest in you: a stake. That leaves a lot of people, including future customers, with no say. Cast the net widely. Find out what your employees think. Do they feel safe at work? Do they recognise the messages and feel the benefits you’ve been sending them? How about those pressure groups? Have you ever listened to them? Do they have a point?

Your competitors may also be interested parties. I have found that the best way to overcome corporate inertia is to tell Directors what the competition are up to. As I said, use benchmarking sparingly. Instead encourage leadership to leapfrog. Ask them to consider why their competitors didn’t go further. Did they just drop the ball by lacking ambition? Can we out do them?

PERFORMANCE INDICATORS

ISO 45001 has a good set of contents for what goes into a management review:

1. a) the status of actions from previous management reviews;
2. b) changes in external and internal issues that are relevant to the OH&S management system, including:

                1) the needs and expectations of interested parties;

                2) legal requirements and other requirements;

                3) risks and opportunities;

1. c) the extent to which the OH&S policy and the OH&S objectives have been met;
2. d) information on the OH&S performance, including trends in:

                1) incidents, nonconformities, corrective actions and continual improvement;

                2) monitoring and measurement results;

                3) results of evaluation of compliance with legal requirements and other requirements;

                4) audit results;

                5) consultation and participation of workers;

                6) risks and opportunities;e) adequacy of resources for maintaining an effective OH&S management system;

1. f) relevant communication(s) with interested parties;
2. g) opportunities for continual improvement.

That’s everything but of course, it’s not really because you have to think about which legal requirements and how to consult workers and how to present objectives and opportunities and so on.

Here’s one way. The engineers adage goes: you can fix anything with grease and duct tape. If moves and it shouldn’t, tape it. If it doesn’t move and it should, grease it. Data can to be treated in a similar fashion; as a set of fixed norms and moving variables.

Fixed (information that already exists and is fairly static, foundational and measurable). These represent the initial conditions, designs, policies, plans, objectives, attitude to risk. This is the state of play upon which we will base our decisions.

Variable (information arising as a result of changing conditions or being added to the system), the things we want to see altered: management, culture, values, sense of mission, behaviour, entropy, competition, financial conditions, mood, reaction to events, accidents and incidents, trends. These are the levers to pull and buttons to push to move us to the next level.

As you can see there are A LOT of variables to play with. If accident stats are Kansas, these indicators are the Yellow Brick Road.

What also we need to do here is present management a dashboard. Consider the dashboard of a car. It has been through countless design iterations to reach the stage where you can tell a number of things about past and future performance with just a single glance: current speed, future range, potential obstacles, how far you’ve been, the current state of various systems and where problems might arise. Senior management are time poor. Don’t aggravate them by making it hard for them to follow.

OBJECTIVES

There should be new ones. Build on the old ones by all means and keep the ones that are still valid or unfulfilled. As I mentioned, it’s good to get objectives from everyone. They should be a narrow wishlist from the H&S dept. It should be a desired outcome from each of the senior leaders in the organisation. What do they want to see change? The IOSH Leading Safely approach is for Leaders to have Performance and Process Goals as well as Outcome Goals. The OG is like saying you want to run a marathon. The Performance Goal is like setting yourself a milestone to run 2K first, then regularly, then move up to 5K then 10K and so on. The bitesize chunks with their inexorable progress will keep you on track. Targets, including numerical ones, can be set from here. The Process Goal might be to eat healthier and get down the gym. It will help towards your goal OG but it will also be good for you even if you don’t make it to the start line of an actual marathon.

Everyone’s heard that objectives need to SMART: specific, measurable, achievable, realistic and timebound. But when your communicating them they also need to be HARD:

• Heard by everyone, not just management. Publicised.
• Aspirational for those that hear them. Your teams should want to go out and make them happen.
• Robust so that they stand up to criticism. When you launch them you want to be taken seriously. No lip service, no greenwash, nothing that only sounds good for marketing purposes.
• Defined and distinctive, so that people know they’re yours (they fit with the culture) and know whether or not they have been achieved when the time comes.

POLICY

The basic test of a policy statement is the date and signature. Everyone knows this. An out of date policy signed by a Director who retired last year is almost a cliché amongst HSE Inspectors. It’s not a mistake I expect smart companies to make. But here’s a challenge for you. Compare Policies over time and identify what the changes actually were. From one year to the next. If only the dates and names changed, your policy is stagnant. It may past the languid scrutiny of some supply chain management systems but it won’t do for you. Policy fills in all the holes that legal and other requirements leave for you to fall through. Policy sets out your stall. For one thing, I don’t trust a policy that won’t grasp the nettle and talk about discipline. Directors and Managers are accountable – and vicariously liable, too – for what their employees do. That only seems harsh if you aren’t using the natural authority of the employment contract to ask for high standards from your staff (in return for the comfort and protection of working for you rather than someone else). Your policy should clearly tell everyone what is OK and what is not OK.

The standard is pretty clear about what goes into a policy:

• responsibility and accountability
• strategic direction
• integration of OH&S into business practices
• resources committed
• communication established
• outcomes expected
• people involved
• culture known
• protection from reprisals
• consultation

Get all of these ducks lined, up you’ll have a policy that has to grow and change to keep up with the commitment to continuous improvement implicit in them.

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