In this episode, we’ll discuss the Australian Work Health and Safety (WHS) Strategy for 2023–2033 put out by Safe Work Australia - an Australian Government statutory agency established in 2009. Safe Work Australia includes Members from the Commonwealth, and each state and territory, Members representing the interests of workers and Members representing the interests of employers.
Summary:
The purpose of the Australian Work Health and Safety (WHS) Strategy 2023–2033 (the Strategy) is to outline a national vision for WHS — Safe and healthy work for all — and set the platform for delivering on key WHS improvements. To do this, the Strategy articulates a primary goal supported by national targets, and the enablers, actions and system-wide shifts required to achieve this goal over the next ten years. This Strategy guides the work of Safe Work Australia and its Members, including representatives of governments, employers and workers – but should also contribute to the work and understanding of all in the WHS system including researchers, experts and practitioners who play a role in owning, contributing to and realising the national vision.
Discussion Points:
Quotes:
“The fact is, that in Australia, traumatic injury fatalities - which are the main ones that they are counting - are really quite rare, even if you add the entire country together.” - Drew
“I really see no point in these targets. They are not tangible, they’re not achievable, they’re not even measurable, with the exception of respiratory disease…” - Drew
“These documents are not only an opportunity to set out a strategic direction for research and policy, and industry activity, but also an opportunity to educate.” - David
“When regulators fund research, they tend to demand solutions. They want research that’s going to produce tangible results very quickly.” - Drew
“I would have loved a concrete target for improving education and training- that is something that is really easy to quantify.” - Drew
Resources:
The Safety of Work on LinkedIn
David: You're listening to The Safety of Work Podcast Episode 107. Today we're asking the question, what research is needed to implement the Safe Work Australia WHS Strategy? Let's get started.
Hi, everybody. My name is David Provan. I'm here with Drew Rae, and we're from the Safety Science Innovation Lab at Griffith University in Australia. Welcome to The Safety of Work Podcast.
In each episode, we ask the important question in relation to the safety of work or the work of safety, and we examine the evidence surrounding it. Drew, this was your idea. What's today's question?
Drew: Safe Work Australia, and we'll explain in the episode who Safe Work Australia is, have published a document, which is their strategy for the next 10 years. We had a bit of a look at it. We thought that rather than critique the strategy, we would talk about what the strategy needs in terms of support from research in order to be able to advance safety in the direction that it wants to.
David: My original question just for our listeners was, to what extent can the Safe Work Australia strategy impact on the safety of work? Let's come at it from a research angle. I guess we'll talk about who Safe Work is. I think you can only pull on the levers that you can pull on. This is a statutory body that has a few levers, we'll talk about what those are. Do you want to give a little bit of a background to the publication and to Safe Work Australia?
Drew: Sure. I'm not quite sure where the best place to start is. This document is a 10-year strategy that was released in late February this year. It covers 2023-2033. It follows on from a previous strategy that covered up to 2022. Just to explain who's producing this, for our international listeners—do we have international listeners, David? I think we've got some.
David: We do have. Actually, Drew, we've got quite a few.
Drew: In Australia, Workplace Health and Safety is regulated at the state level. That's an organization that basically likes to swap backwards and forwards between Safe Work and Work Safe. In Queensland, we've got Workplace Health and Safety, which is part of industrial relations. In New South Wales, they have SafeWork New South Wales, which is part of the Department of Customer Service. In Victoria, they have WorkSafe Victoria.
Australia is a commonwealth of states. There is a federal government, there is a federal version of the Workplace Health and Safety, Work Health and Safety Act. There is a federal regulator, but they've got very limited jurisdiction. Basically, the federal regulator Comcare takes care of government departments and government-owned corporations, and I think they have some authority in the Australian Capital Territory.
We've got, additionally, this federal body called Safe Work Australia, which despite the name, is not a regulator at all. They're a policy body. They've got a very small budget around 22 million, which is tiny compared to the state regulators. Just by comparison, the workplace injury compensation schemes run in the billions. I think WorkCover Queensland has something like $5½ billion.
$22 million is basically enough to fund a small number of employees and run a few consultancies each year. They've got zero power to implement a strategy. What they're doing is they're providing policy guidance and the strategic nudge to everyone else in the direction they think things should be going.
David: That sounds like a lot of regulation for 30 million people in Australia. I guess they established Safe Work Australia in 2009. At the time, there was a lot of work going on to try to harmonize and make consistent WHS laws across the country. At the time, the federal government was really trying to promote collaboration, coordination, and alignment across the various states. It can be hard to operate a company in one country when you've got to comply with seven different forms of WHS legislation, and they've continued on.
I guess this 10-year strategy document is the second version of their 10-year strategy document. Like you mentioned, Drew, the first one was 2012-2022. It's interesting to see when, I guess, a body or a topic tries to actually forecast out what we're going to do over the next 10 years.
The national vision that Safe Work Australia positions the strategy underneath is a vision of safe and healthy work for all, which I don't mind. I think that's not too bad. I guess the first point that is made in the introduction of the strategy document is over the last 10 years, and particularly the last 10 years of the Safe Work Australia strategy, that injury and fatality rates have fallen significantly over the last decade. They make the comment that progress has slowed. How do we feel about claims such as that?
Drew: I've been looking around at various documents. I've come to the conclusion that if we actually believed the introductory claims that things made, then we would be in a constant state of safety drastically improving, but miraculously slowing just before the production of any new report, policy, or strategy. It's almost like a ritual performance that you need to start off your safety document with. Look at how we've come so far, but we need to justify why we still need to do some more work. Either things are slowing down or conditions are changing.
The fact is that in Australia, traumatic injury fatalities, which are the main ones that they're counting, are really quite rare, even if you add the entire country together. By rare, we're talking around 160-200 a year. Occasionally, you'll have a really good year, which drops down to 140 or 130.
Occasionally, you'll have a really bad year, which peaks up at about 300, which is exactly what you'd expect, given the underlying statistical distributions that drive these things. When numbers are fluctuating like that, you can basically make the number go up or down just by exactly which year you start. When they claim a reduction, they're comparing the year 10 years ago and saying last year was different to then.
David: Whether you pick 2011, 2012, or 2013, you just pick your starting point for the year that has the highest number so you can show the greatest reduction.
Drew: Exactly. If you happen, for this one, to pick 5 years, you'd be saying injuries have drastically increased in the past 5 years because we had a particularly good year at the 5-year horizon, we had a particularly bad year at the 10-year horizon.
David: I think I saw on the website today in Australia that there were 23 fatalities so far in 2023. Each of these individual events are hugely impactful and distressing. At the same time, I guess, our strategy always needs to look forward.
I guess the claim that they make around the strategy document after that context is that, "The strategy sets a clear, unifying national goal to reduce worker fatalities, injuries, and illness. It sets out forward-looking actions to work towards with tangible and achievable targets to focus our efforts." What are these targets that they're talking about? They've got six targets that they call out, and I'll get your thoughts on them.
The first is that they want worker fatalities caused by traumatic injuries to reduce by 30% over 10 years, the frequency of serious claims resulting in one or more weeks off work to reduce by 20%, the frequency rate of claims resulting in permanent impairment to reduce by 50%, the overall incidence of injury or illness to be below 3.5%, the frequency rate of work related respiratory disease, which is very topical now, is 20%, and there was an extra one about no new acute cases of respiratory disease as well, or no new mechanisms around that. How do you feel about these as a set of targets, the quantum of these targets, and even the nature of them?
Drew: To be honest, these targets, if you were genuine about achieving them, you would basically need to change the national industry mix. The things that achieve a 30% reduction in traumatic injuries is if we have a drastic scale back in either mining or agriculture. Deliberately causing a recession would probably do it or redefining some of our ways of counting fatalities have in the past achieved those reductions. When we have, for example, done things, whether we include certain types of travel to and from work can achieve a statistical reduction, but none of these are really what they're after.
I really see no point in these sorts of targets. They are not tangible, they are not achievable. They're not even unmeasurable. With the exception of the deliberate targeting of respiratory disease, I think it's interesting and important.
Is the type of thing you can do in this strategy to say, this is something that really is an aberration in the statistics that has an underlying cause that we should be able to deal with? It just seems to have accidentally got out of hand because we weren't focusing on it. Including something specific like that in the national strategy lets us focus on something that really should be systematically preventable.
David: I agree. I don't know. The critique point is that, again, they've fallen into the trap of measuring lagging indicators and using that as a way of measuring the overall strategy, when really what we're going to talk about in a moment is five areas that the strategy sets out as clear focus areas. It would have been a great opportunity to set some really specific and measurable targets in relation to those five areas where they actually want to make specific improvements, as opposed to saying we're going to improve in these five areas, and we're going to measure the effectiveness of the success of our strategy by these lagging indicators, which are impacted by a whole bunch more than what's in this strategy.
Drew: Yeah, I agree. I think these targets are probably going to be the last really negative thing we say about the document because the things that they then decide to focus on are really positive. They're just totally disconnected from these indicators.
David: There were a few other bits of context. I don't know whether it's necessary for the podcast or just a little bit interesting, but am I allowed to do one or two more critiques before we get stuck into it?
Drew: Okay, sure.
David: I need to point it out because this is a national WHS strategy. It's read by a lot of people who are maybe from a broad range of starting points or competency points in relation to safety management. Let's go straight into this. The four most common causes of workplace injuries are vehicle incidents, false slips and trips, being hit by moving objects, and body stressing. I think we can all agree to that, but these things aren't causes. They're mechanisms of injury, they're not causes at all.
I think not only have the strategy fallen into the trap of setting lagging indicators to measure its effectiveness, they've also fallen into the trap of actually just classifying types of incidents as causes. I find that a bit of a shame because these documents were not only an opportunity to set out. I guess it's a strategic direction for research and policy, an industry activity, but also an opportunity to educate around how we might want to think about what creates safety.
Drew: If I was grabbing an MP in the elevator for 30 seconds, I would not choose as my one thing to tell them how the 4 most common mechanisms of workplace injuries are these 4 things. I understand they're trying to put some factual context behind the strategy, but the selection of things to focus on are a little bit weird.
David: There's a range of other things in the front of this document and it's publicly available. We'll link it in the show notes and in the comments on LinkedIn. You can see all that, but maybe we just talk about the goal and the action and get into the details.
The overall goal they just have is quite simply, there was that vision earlier about a safe and healthy workplace for all. Now we've got this goal of reduced worker fatalities, injuries, and illnesses. It's interesting to see the policy of one of the strategies because we've got the traffic accident commission that has really locked, which is obviously the Road Safety Authority in Australia. They've really locked in behind this zero accidents mantra in all of their strategy work. Here, we don't see zero in a 10-year strategy. We just see reduced, and we're talking in the order of 15%, 20% 30% type reductions.
Whether that's a good thing or a bad thing, that's the direction. They outlined three enablers at a very high level. They want the strategy to embed good practices across all industries and really encourage all organizations to take more ownership of safety. When they say organizations, they mean the owners of companies.
They really want to innovate and deepen the knowledge of WHS risks. They specifically call that improving the evidence base for how to manage it, so a direct throw to the contribution of safety research, and then a third enabler around collaborating consistently and effectively to respond to these challenges. They're talking about collaboration across business owners, workers, government, industry, associations, and unions. These three enablers of ownership, the evidence base and collaboration, I didn't mind them at a high level as the direction of the strategy was going to take.
Drew: I really like them, to be honest, particularly what's included and not included. Notice that at that high level, they don't have enforcement. Particularly, even the word compliance doesn't make it in at this stage. It comes in a few places later in the document.
At the broadest level, the improvement in safety comes from better knowledge, better practice within individual businesses, and better collaboration between various people involved, including government, industry, and unions. If you think of that as a mission statement for safety legislation, regulation, and high level strategy, that's almost radical in its focus on positive efforts rather than on enforcement.
David: I agree. I thought that was a good place to start. We move into five what they call specific actions. What I'm going to do is I'll call out the action, and then we'll talk a little bit about what might be required from a research point of view in order to support this strategy over the next decade or so. The first action is about information raising and awareness. The specific actions are developing joint campaigns, specifically with materials and checklists to improve small business WHS awareness and compliance.
This comes up quite a bit, this idea of small business that we might talk about in a moment because the second point is to consult with small business about their communication preferences for how to receive WHS guidance, training, and to fill gaps in their knowledge. The third action is to collaborate with worker representatives in industries, I guess trade unions and industries with diverse workforces to reach groups of workers with a higher health and safety vulnerability in high-risk industries. I guess particularly at small business, raising awareness in small business and within marginalized or vulnerable parts of the workforce. Your thoughts?
Drew: Firstly, I'm not a fan of the idea that what we need to do with small business and diverse workforces is find better ways to communicate to them. I think the fact that this is an obvious need, but this is the only solution we can think of to fill the need, itself immediately points to a research gap, where we need to be doing better as researchers to provide just better things in the toolbox for government and organizations like Safe Work to reach for other than providing campaigns with materials and checklists to support small businesses.
In defensive research, our funding models don't really help us there. Most safety research gets funded directly by big businesses, which of course supports the needs of big businesses, not small businesses. When regulators fund research, they tend to demand solutions. They want research that's going to produce tangible results very quickly, which doesn't help with coming up with new knowledge about small businesses. It's a model of research that supports top-down interventions with short-term evaluations.
Really, we need a better understanding about, genuinely, what would help small businesses, which is a challenge because they typically lack the time and resources to engage with anyone. They don't have the time to talk to regulators. They don't have the time to talk to researchers. They don't have the time to read the pamphlets and checklists we like to throw at them or the websites we like to produce for them.
David: Even if they have any desire at all to access that. I've got a question for you because it didn't mention this idea of a vulnerable workforce. Earlier in the paper, Safe Work Australia calls out being a younger worker, a job that involves working alone, being from a culturally or linguistically diverse background, so maybe English as a second language, or working in a more complex contractual supply chain, being a labor hire worker or a subcontracted worker.
These four areas, they specifically call out of being a vulnerable worker. Drew, your work in the Safety Science literature, that is actually supported. Do we know that those people are more at risk of incident or injury?
Drew: That is a surprisingly complex question, David, because measuring which workers are directly at high risk is really, really hard to do and get into all weird questions about categorization and measurement. What we can say is that we know for sure that most of our traditional strategies for managing and improving safety, very obviously don't apply to these workforces.
If you think of someone who is switching from employer to employer, then any approach that's using things like safety culture is not going to help. If you think of someone who is working alone, then any strategy that involves supervision, work method statements, or processes, isn't going to help. You're talking to someone who doesn't speak English or at least doesn't read English, then anything involved in documents is not going to help.
I think the intuition that these are a highly vulnerable workforce is pretty self-evident. The direct evidence that they have a higher injury rate is controversial, but only insofar as all measurement of injury rates is difficult and controversial.
David: Thanks, Drew. Thanks for such a nice, eloquent answer on the spot. I guess in this first action, there are two points, where the research needs to support the strategy by filling that gap. How do we think about managing safety and supporting safety in small businesses? What are the ways that some of these vulnerable sectors of the workforce can be better supported with different strategies?
I know you mentioned the funding. There are two areas of industry, which are probably the least likely to receive funding. I think maybe there's a place for the government or even Safe Work Australia in support of this strategy to fund some research in those areas.
Drew: I'm aware of the Center for Excellence in New South Wales funding a project into community care workers. There's been some good work done out at UQ, but these are just like scratching the surface. We need entire careers of work to focus specifically on some of these particularly difficult work situations and just give us a really good understanding about what's going on so that we can come up with better solutions than just trying to reach out.
There's a sense that if we could only fill the information gap and get to the person with the right spot of information, that would make them safer. We know that it's not information, that's the problem. They're working in a dangerous work environment, they're working alone, they're doing difficult variable work. Of course, that's risky. Telling them that it's risky and telling them to think about the hazards isn't going to fix that for them.
David: I should have looked it up. I know New Zealand has a very high percentage, but in Australia, it might even be 80% or 90% of the workforce actually working in small to medium enterprises. We are talking about a very large part of the working population that work in relatively small businesses.
Drew: This is below the level of a broad strategy like this. But once it comes to implementing this thing, what counts as a small business covers a very broad spectrum. It's likely that our strategies for dealing with small businesses who almost exclusively subcontract to larger businesses, is going to be very different from our strategy dealing with small businesses who reach out directly to consumers.
David: Family-owned businesses, hospitality, there's a whole bunch of it. You're right. It is a big, complex type of operating context that probably would need specific strategies around them. But again, I think what we conclude in that first action seems like a reasonable idea, but we probably don't have a great evidence base to support that action in the strategy at the moment.
The second action that they go for is called national coordination. I guess this is part of their role as Safe Work Australia. The first action is to share insights across jurisdictions and industries so that successful initiatives can be replicated and scaled in other jurisdictions and workplaces to work with researchers, to identify emerging WHS challenges, and to engage with national employers, to better understand impediments, to working across jurisdictional lines, and to coordinate on monitoring and improving the WHS framework at the national level, including Safe Work Australia preparing regulations, code of practice, and other materials. This seems very much like the position description of Safe Work Australia for the next 10 years.
Drew: Yes, it definitely does. Let me point out a couple of areas, where we need research to directly support this coordination effort. For overseas listeners, I mentioned this is weird. We've got Occupational Health and Safety fractured as a state responsibility. We managed to successfully put in place what is sometimes called the model safe work. Basically, this is harmonized legislation. Even though they're different states, each state has exactly the same legislation in place, which was supposed to help with the problem of companies that have to work in multiple states, that at least they'd be operating under the same laws.
What we've discovered is that that wasn't the only problem. There are lots of unintended effects when you both work between states, but also when you try to standardize between states. David, our own safety clutter work talked about some of the unintended effects of national standardization that actually, standardization can, in places, increase unnecessary safety work because it tries to be uniform instead of trying to be specific to the needs of a particular person at a particular place at a particular time.
David: Standardization is really important to understand. The value that that creates in the eyes of a Safe Work Australia body, having a consistent framework across a national level, and then trying to look at companies working across jurisdictional lines, it feels a little bit like the garbage can model of organizational choice. Safe Work Australia's solution is trying to craft this problem. I don't know your problem currently. Maybe at a company level, it's a problem, but I think at a frontline level, working with lots and lots of Australia wide companies, then I think about this too much.
Drew: That's interesting. I know I've had companies complain about specific aspects of standardization, but it's not been at the legislative level. It's been things like national audits that they need to comply with or obtaining particular certifications that have caused problems. I guess that's one. I guess it's good that they've got here one of the direct bullet points, directly talking to national employers to understand what are the difficulties because they may not be what people are assuming.
David: In this one, it talks about preparing regulations, codes or practices, and other materials. You made a comment here that we need to understand and research what makes a good coding practice, and then we also need to research how these codes of practice get used. If we've just made one statement earlier that we've got a huge challenge with vulnerable workforce and small business workforce, I'm not sure how those companies are picking up and reading the regulations and the codes of practice.
Drew: David, I genuinely don't know the answer to that. Our whole regulatory regime is based around having three tiers, legislation at the top, then regulation, and then codes of practice below that. There's a lot of work that goes into producing these codes of practice, but I've got no idea who reads them or uses them. Except if you do something wrong and you get prosecuted, they'll use failure to comply with the code of practice as part of the evidence that you weren't managing safety like you weren't supposed to.
When you pick up the code to practice, some of them, we know they're not being used because they're useless. The entire code of practice is just generic information that's copied from the regulations. I know the National Construction Code of Practice folds into that. The entire document is just repeats of information that's found elsewhere. You find other ones. There's one for abrasive working that's got to do with when you're doing things like grinding stone benches, and this has got to do with some of the respiratory problems.
The first third of the document is just entirely generic information about risk management. Suddenly, it dives into a chapter that's filled with specific information about hazards, controls, percentages of material, what to watch out for, how to lay out your workspace, and stuff that I imagined would be really quite useful if you were trying to check that your business was doing everything it should be to manage dust in that work.
I think there's both general work we need to do on how people use codes of practice and then a very specific evidence-based review of the current codes of practice, decluttering them, getting rid of all the generic stuff, making sure that everything in them is genuinely evidence based, and then where there is not enough evidence for a code of practice, either getting rid of the code of practice or doing the research to make sure that it's now evidence-based.
David: I like that, Drew. I think even that initial research question, which is a fair challenge because I made a lot of assumptions about how I think people consume safety information, I think there's an initial question. How do different types of businesses actually access information about safety? When do they access it? Where do they access it? How do they use it? A lot of those people say they get their information, their codes of practice, then it's a great strategic opportunity to invest in those.
If no one says that they get it from codes of practice and they get it from Google searching or something like that, then maybe focusing your efforts in Wikipedia or something different is a better way of actually getting information out there. I think it's a good point that before we can talk about all of the things in these national coordination topics and the levers that are available, we actually need to know how people access them and use safety information.
Drew: David, you've now got me imagining the state regulators employing people as guerilla Wikipedia editors and answering questions on Quora, just to increase the amount of good information and decrease the amount of misinformation that people get from a Google search. If that's genuinely how people are accessing information, then that's a genuinely good use of resources, better than a code of practice that no one reads.
David: Absolutely. The third action here is data and intelligence gathering, the third action area. The two specific actions under that are to identify new data sources from industry, social surveys, and other sources that supplement official Workers Compensation Claims statistics, and to collaborate across government, social partners, and research communities, to ensure that national surveys and other data collection efforts include WHS measures and occupational information where possible. Super ambitious, 10-year strategy for data and intelligence gathering. Excuse the sarcasm.
Drew: We can pat ourselves on the back here and shout out to our PhD researcher, Kevin Geddert, who is quite literally doing a PhD that includes mapping other sources of information to Workers Compensation Claims statistics as a way of improving company internal information. At the same time, Kevin is advocating for much more company openness of information.
This is something where if we combine this goal with the next action, they mention in the next action, the idea that the government should be a model employer when it comes to workplace health and safety. What I think would be a genuine opportunity is if the government tried to be a model employer, not just in compliance, but in things like sharing internal safety information. If they're willing to put out some of their internal statistics in the same way that we would hope all employers do and share information on accidents, the government has the least worry about liability or prosecution than any organization.
They should be the most open to sharing and should be the most willing to take the lead here in being the people who make better use and provide better access to the information we already have on safety. Extra surveys, including safety questions on general social science surveys, are not going to generate good information. Lots of companies have good information internally, if only we could find ways of better sharing and making use of that information.
David: Commonwealth departments and government departments in Australia still take out legal privilege just like every other company when there's an event and don't share just like everyone else. But I agree with you, I think there's a huge opportunity there as well. I'm just a little bit surprised that this data and intelligence gathering action is in the same month that everyone's talking about artificial intelligence and ChatGPT. Now we're casting forward to 2033, I just find this a little bit weak and nearsighted.
Drew: Given the timing of when they were preparing this strategy and when the big awareness of ChatGPT came out, you can't really expect them to have reacted that quickly to it. What is there really to say? In a 10-year strategy, you don't want to try to guess what's going to happen next with AI. The most you can put in is a statement like, look for opportunities to use new data technologies. That said, we'd be skeptical about what are the actual capacities of AI to analyze bad data.
David: Maybe. I don't know. I'd be more ambitious than that and put a flag out there within the next decade to be using AI to be predictive in different ways that we're not able to be predictive today. I think that's the data and intelligence gathering one.
The fourth action is about health and safety leadership. There's a few specific actions here around jurisdiction developing and refining their own strategies. It's just a bit like each state has their own strategy to liaise with the vocational education and training sector. This is the trade skills sector about the future health and safety requirements for workers, how to promote the importance of WHS through vocational education, and then increasing the training of WHS officers, representatives, managers, supervisors, as key leaders of a healthy and safe workforce.
Drew: This is the flip side of those targets about reducing the number of injuries. You would have loved them to say something more ambitious about AI. I would have loved them to be putting a concrete target for improving education and training. That is something that is really easy to quantify. Why not just do it?
We've got a desperate need for more safety professionals and more professional safety professionals in Australia. At the level of a national strategy, that's the way that we get there, not by increasing training or liaising with the vocational education and training sector, but by actually committing—again, this is where the government could take the lead as a model citizen, committing to employing postgraduate qualified safety managers. Within 10 years, that's going to be the standard that we're aiming for when it comes to safety professionals.
That's long enough to start phasing out the people who don't want further qualifications. It's time to give people education who want it. It's the time to train new people coming up from university. We could achieve an actual transformation in our WHS officers, our inspectors, if we wanted to. I'm personally sad that we're not willing to commit to that step change in professionalism in safety.
David: I think we can see it in our climate actually now that you can do those things. In some parts of Australia, they're saying that from 2035 onwards, it will be illegal or against the law to buy an internal combustion engine or petrol vehicle. That's 12 years away. You can say those things and give you time to build the structures around that.
I still also think they should extend the company directors, particularly with that small business challenge. The government knows, by the Australian Security Investments Commission or ASIC, every single person who's a director of a company in Australia, expecting every one of those directors to have some qualification by some point in time is an unrealistic thing to have in a national strategy. This strategy lacks those big points in time over a decade that you'd want to try and orientate your funding, your policy, and your system towards it.
Drew: Beginning to our research focus, one of the real gaps here is we find consistently in existing research, this talk about the weakening of apprenticeship as a way that people learn about hazards and learn how to be safe in the workplace, mostly just because overall awakenings of apprenticeship as a way to get into vocations. I think that's an area where we genuinely need research. We've still obviously got the people in trades, despite the weakening of apprenticeships. We need to understand how those pathways are currently working, how people are acquiring the early socialization into vocational trades, and work out how to properly influence that.
Maybe the answer is better training, but I doubt it. At least we need to take a very broad idea about what training involves. Certainly, training would not be training courses, it would be how do we manage that early time in the workforce in order to get people starting off on the right foot with understanding hazards.
It's a little bit like driving. You've got this danger period the first few years you're in a new job. You want to protect people from that danger period, but it's also when you learned your lifelong habits, and we want to make sure that people establish good habits when we're relying on behavioral controls at that level. That's an area where in order to improve things, we need to understand things, which means we need more research.
David: You're right. Adding safety training here and there is not the same as understanding how people acquire their understanding of safety prior to and early on in their vocational careers and training. It's a great point, Drew.
The fifth action—and this is where we get compliance and enforcement I mentioned—specific actions around the different jurisdictions in Australia collaborating to improve compliance across supply chains of goods and labor. Obviously, these national networks, particularly since the first mechanism of injury they spoke about were vehicle accidents and there's lots of nationalization of supply chains for road transport, targeting national compliance and enforcement campaigns to poor performing sectors, including the high-risk sectors identified in this strategy, and developing insights from the data on prosecutions, notifications and breaches, and increased knowledge sharing across the WHS system, and then to strengthen compliance with consultation, representation, and supervision to improve worker health and safety.
Drew: Bravo for putting compliance and enforcement last. Bravo for the focus on consistency because I think one of the challenges we've got in Australia, particularly at the moment, and I think different countries go through a cycle of this, is we've got a race to be the strictest state when it comes to prosecutions. It ends up in this weird situation, where it's not about what you as a company did, it's about where you were located and when the next election is, what the likely consequences for your company are, even to the point of directly changing away from our unified legislation so that states can put in individually harsher penalties and more personal liability for safety.
I'm glad that this strategy doesn't buy into that. I think consistency is a politically safe way to fight back against some of that. But it also raises some really interesting research questions because we can't have stronger compliance on things like consultation, representation, and supervision, until we have some idea of what good consultation, good representation, and good supervision looks like.
The legislation got specific provisions for workplace safety committees and worker representatives. We've got no idea what those people are supposed to do. Often, there's strong anecdotal evidence that those people don't have any idea what they're supposed to do either when they get appointed to those positions.
We really need to understand what good looks like before we start strengthening compliance against that. Otherwise, we're forcing people to have a committee. They've got no idea what to actually do with that committee, just tick the box that we've got it, fine, we comply with the legislation now.
David: Drew, I guess you've also got a comment here about, what do we know about the different types of enforcement?
Drew: Yes. State regulators have got all sorts of different tools. They mentioned some of them here. Prosecutions, notifications, breaches, all different types of things a regulator can do. But we don't have good evidence about what the effect of doing those things are, their internal guidelines inside the inspectorates on when to do each one and how to decide when to do each one. Those aren't evidence-based, they're more about establishing internal consistency and being able to defend your decisions.
In particular, we've got no evidence as to whether things are half prosecutions or particularly, personal accountability in prosecutions, whether that has a positive or negative effect. David, I've got a pretty strong opinion about it. I'm sure you do, too. But the evidence is genuinely mixed, and there are sort of theories that point in each direction. There are theories that genuinely suggest that making directors personally liable should improve safety. There are theories that say, no, that will actually make things worse.
We haven't done nearly enough research on what the actual effect is. What happens to a company when they fear prosecution? What changes within the company? What additional documents do they produce? Does it create safety clutter? Does it remove safety clutter? Does it improve sharing of information? Does it hurt sharing of information?
Lots of different effects that might be going on that we're not currently measuring. Until we know, we should be very cautious about trying to get stricter on prosecutions or trying to be lax on prosecutions. We should be as neutral as possible until we have the evidence.
David: I agree. I was just thinking of this tension. Where would I rather invest my time and effort? Would I invest in education or enforcement? If we circle back to the very first comment about small businesses, how and where they access information, I'm not sure a lot of small businesses even know if anyone ever gets prosecuted in their sector, unless it's on the radio in the morning on the way to work. I'm not sure they know.
This idea of a deterrent effect is maybe not real. Even if it is, I think we know from a fear and compliance point of view, it's not necessarily a motivator of behavior in the workplace or for business owners who are faced with a whole bunch of other contextual factors that are informing their decision.
It's interesting now that where we've got this whole section on enforcement and compliance that the word education doesn't appear here. I thought we'd learned over decades, particularly in road transport, that a big part of enforcement was education, or a big part of regulation was both enforcement and education.
Drew: To be fair, their previous item was about education. It's not like they've ignored education. Maybe there's separation of compliance and enforcement as If compliance and enforcement are something that you build a campaign around, as opposed to it might be one part of a campaign in order to support, bolster, or draw attention to even other things that you're doing.
David: It sounds like you're doing a good job of playing good cop today. Maybe it's my turn to play bad cop a little bit, but I guess I'm just a little bit underwhelmed if this is maybe the next decade. But in any case, practical takeaways. Do you want to just help our listeners with what the practical takeaways might be here?
Drew: My first practical takeaway was actually just a question for you, David. What do you think about just this idea of having a national strategy? Good, bad, indifferent?
David: I think it's credible and it provides direction. If you look at the logos on the front of the strategy, you've got every state regulator in the country and a whole bunch of other bodies. If this provides a direction for investment in policy, in research, in industry support, then I think that's far better than having 7, 8, 9, 10 different organizations doing a whole bunch of different things. I'm very much in favor of having a national strategy, just perhaps not this one.
Drew: I suspect that that is the trade-off that we're facing. In order to build consensus, consensus is often weaker and less specific than any individual might do, but at least we have consensus rather than 10 different strategies. One of the really good things about this document, though, and I'll put this as a practical takeaway for everyone, is it lists out these six challenges that it thinks are going to affect safety over the next 10 years. There may be other ones, but I think every one of these six is spot on and something that people should be thinking about strategically, whether they're a country, a regulator, or just managing safety within a business. On your strategy board should be these six things.
Just a reminder from the start, the six things were, increased AI and automation and what effect does that going to have on the business, changing types of work and what effect that's going to have, changing demographics, which in Australia is an older and more immigrant workforce, but maybe different in where you are, but still, everyone faces changing demographics, hybrid work and the effect that has on safety, climate change and the effect that has on the business, and then therefore on safety, and more complex supply chains.
I think that if every year, you went through and thought, how are those six things going to affect us, every five years, you thought about, let's have a plan for how the business is going to change and how we're going to adjust our safety accordingly, that would be something that is worth doing at the strategic level.
David: I agree. We skipped over those, but I think that's important in any strategy document to talk about, what's the context that you're responding to? Drew, your last takeaway here.
Drew: My last takeaway is just that, we always need this balance between trying to improve safety by doing the stuff we're currently doing better, which you would think of just as increasing compliance, and changing what we're doing by innovating and increasing our knowledge of what actually works. I think it's important in any strategy to think about where that balance currently is with your country or your business.
Are we in a state where there's lots of stuff that we know that we're just not implementing? Or are we in this state where we're actually doing fairly good compliance with what we've got, but we have real uncertainty about whether we're doing the right things, and maybe we need better evidence about what would actually work? It's good for every strategy to have some balance of those two things.
David: Great. Thanks, Drew. The question for today was what research is needed to implement the Safe Work Australia WHS strategy? Your answer?
Drew: I don't have a one sentence answer this time, David, but I've got two suggestions. The two biggest things I could find after I went back through and thought about, what's in the strategy what we said, firstly, understanding how regulators interface with different types of organization. We need more research that doesn't just say, hey, let's research small business, but that dives into particular workforces. The second one is that we need to get specific about some of our big practical problem areas, look at the codes of practice, and look at what's the actual evidence base behind how we're currently approaching specific industry problems.
David: I think in this strategy, my one word answer for that would have just been lots of research. I think there are a lot of assumptions in this strategy. I think there's a lot of big underlying research questions in here.
Shout out to Safe Work Australia. If you want to spend some of that $22 million, Drew, we'll be happy to take that money off your hands. That's it for this week. We hope you found this episode thought provoking and ultimately useful in shaping the safety of work in your own organization. Join us in the discussion on LinkedIn or send any comments, questions, or ideas for future episodes to us at feedback@safetyofwork.com.