What level of compliance should we be satisfied with?
Posted by Tracy Seward
Well the answer can depend on who you ask.
Let’s start with the senior management of an organisation, the collective group that may be prosecuted under the Corporate Manslaughter and Corporate Homicide Act or individually under the Health and Safety at Work Act or be barred from holding an office as a Director. They have a vested self interest to set the highest level of compliance and to proclaim that to the organisation. They may also see that compliance is a core value of the organisation and those of their shareholders and stakeholders. How Senior Management engage in making it all happen by applying the correct level of funding, demonstrable support and measurement of compliance is often disconnected from original intent unless a sound corporate governance or oversight programme is put in place. Compliance needs managing.
At the management level then things get a bit more blurred. The old mantra is ‘Managers are there to manage’ and in that context managers feel liberated and empowered to do what is necessary to succeed. Being a successful manager can be measured in a number of ways and controlling costs or increasing revenues or both are often the main metrics. This can of course influence health and safety compliance decision making adversely. Add to that a manager may be incentivised by recognition, the possibility of promotion and perhaps a bonus then all this can drive some unhealthy behaviours which also impact on compliance. The fact that managers will have responsibilities set out in the organisations policy and arrangements and have a raft of organisational standards that are developed to set a compliance level can often be overlooked or questioned by managers. If compliance is not measured or valued as part of being successful then it will not become part of their job.
So what about the people who suffer the accidents and ill health perhaps due to a lack of compliance with the organisations standards? These are workers directly employed, outsourced or contacted. It also includes those who may be visitors, passersby or the general public. They will generally have an expectation that organisations will operate to high standards of compliance however workers often observe that what is said and what is applied are different things. This in turn generates a culture in which lack of compliance and risk taking is an accepted norm and as a result the organisations performance is impacted.
As has been written about, analysed, researched, published and legislated for over many years the buck stops with senior management and therefore the question ‘What level of compliance should we be satisfied with?’ is their decision and not for general debate or interpretation in the organisation.
The Institute of Directors and the Health and Safety Executive publication ‘Leading Health and Safety at Work – Leadership Actions for Directors and Board Members INDG417’ gives some pretty clear guidance and has some interesting quotes from senior management across the public and private sectors:
“Board level involvement is an essential part of the 21st century trading ethic. Attitudes to health and safety are determined by the bosses, not the organisation’s size.”
“Health and safety is integral to success. Board members who do not show leadership in this area are failing in their duty as directors and their moral duty, and are damaging their organisation.”
“An organisation will never be able to achieve the highest standards of health and safety management without the active involvement of directors. External stakeholders viewing the organisation will observe the lack of direction.
“Health and safety is a fundamental part of business. Boards need someone with passion and energy to ensure it stays at the core of the organisation.”