The Safety of Work

Ep.70 Is OHS management a profession?

Episode Summary

Every ten episodes or so, we give ourselves permission to discuss some of our own research. We thought it was about time we discussed another one of David’s papers.

Episode Notes

So, on today’s episode, we discuss Occupational Health and Safety management and if it can be considered a profession. 

We’d love to hear from our international listeners if our findings match their experiences.





“A profession should have an established hierarchy, it should have some consistency in role titles, and it should have a career path.”

“We’ve got this wonderful project called the body of knowledge, but in the professional sense, we don’t have a stable body of knowledge; we have a really contested body of knowledge…”

“Either you put up barriers to entry and say ‘safety work should only be done by recognized professionals’. Or you say ‘we want to grow as an organization and anyone can be a recognized professional, just send us the cash’. And either way, you end up diluting what it means to be recognized as a safety professional.”



The Emergence of the Occupational Health and Safety Profession in Australia

Episode Transcription

Drew: You are listening to the Safety of Work podcast, episode 70. Today we're asking the question, is OHS management a profession? Let's get started.

Hey everybody, my name's Drew Rae. I'm here with David Provan. We’re from the Safety Science Innovation Lab at Griffith University. In each episode of the podcast, we ask an important question in relation to the safety of work or the work of safety. We have a bit of a look at the evidence surrounding it. In every 10 episodes, we give ourselves permission to talk about some of our own research.

Today we're going to be talking about a paper that David bottled and I wasn't, so he's going to be the expert. David, what's today's question?

David: We’re going to reference a lot of the Australian context for the profession during this episode. It would be really great to hear from our international listeners whether you feel like the context that we describe is also applicable in your country as well. But when I talk about a paper, it was specifically a paper from the OHS profession in Australia. Personally, in my experience working internationally, many of the issues are consistent in most of the developed world. But I'm sure that there are some nuances with some of the individual criteria. 

I thought we’d just go through a bit of the history of the profession in Australia and also the history of safety more broadly and how it has shaped the profession. I might get your thoughts on the way through, but this might be a little bit dry but I think it's useful context because not often we think about what's occurred over the past that shaped and created (if you like) where we are today. 

Regulation of safety in Australia commenced largely in the 1850s within the coal mining industry, and this was directly in relation to some investigations and reviews that we’ve done in two coal mines in England. I think specifically, Drew, the [...] South Shields Committee, which was formed sort of a decade before this legislation got passed in Australia that I know that you’re quite familiar with. But then, not much happened in safety for about 100 years until the post World War II establishment of a number of associations to focus effort on health and safety both in Australia and around the world. 

We got IOSH, the Institute of Occupational Safety and Health formed in 1945. We got the WHO, the World Health Organization formed in 1948, and what is currently the AIHS or the Australian Institute of Health & Safety which was formed as the accident prevention group in 1949. It was the formation of these bodies and associations which had really started driving a dedicated agenda within countries.

Drew: David, this is a fairly similar decision to the one you made in your own thesis, limiting the scope to generalist professionals in drawing this line between generalists and other types of safety people. I think it’s a really useful way of thinking about us particularly when we’re thinking about professional issues because it gets us away from some of the more convoluted discussions about the relationships between safety as a profession and other professions. 

Safety engineers usually have formal engineering qualifications, which means that they’re engineering professionals first and safety professionals second. Similarly with medical people or psychology that have a sort of parent profession. I think zooming in and saying we’ve got this whole class of people who are not engineers, they’re not psychologists, safety is what they do. 

What sort of professional identity do they have is a very useful and clean way of looking at it. Then we can broaden out from that then look at how does that then links to other professions that have safety in the name.

David: In 1949, Drew, the first specific education course was developed in Victoria for safety education. I'm not quite sure exactly of the scope, but it was a certificate program that was then expanded to other states. It was really the 1970s where we started to see this major shift in the management of OHS. It was probably driven in Australia, but I think in many parts of the world, by the trade union movement and organized labor. 

Health and safety were becoming a broad issue for the workforce and a broad issue for society. The people who are exposed to those health and safety risks were really starting to form ways of getting organizational action around those health and safety issues.

Drew: David, it's probably worth pointing out for our international listeners that Australia is made up of a bunch of different states. We have seven states, most things related to health and safety are organized at the state level rather than at the federal level. 

But when we’re talking generally about stuff across Australia, that's because as far as I'm aware and it seems to be true from what you and Pam have written in the article as well. The way we manage safety has been fairly consistent between each of the states—largely driven by organizations that stretch across the country. Companies that do business across the different states. There are local idiosyncrasies, but there hasn't been a lot of major differences in what health and safety looks like in the different states.

David: Yeah, I’d agree with that. In the 1980s, we saw a lot of legislation come out, and there was commonwealth legislation like you said across the whole of Australia. Each state, I suppose, published its own nuanced regulations. But it was heavily informed by the Robbins review and the Robbins style of legislation out of the UK. it was very much consistent around the country in a lot of ways.

We started seeing whole OHS departments form in larger organizations and government organizations. And then from about 2000 onwards, things started getting a bit murky for the profession because we started seeing these different safety approaches in organizations. Some continued their compliance focus. Some expanded to safety culture and safety leadership approaches. This demand for the university education of safety people that really exploded in the 1990s seems to disappear and in some ways cease.

By about 2009, 2010, a number of the OHS University programs that commenced in Australia in the ‘90s were no longer available. We saw the Australian Institute in Health and Safety in 2009 develop and start implementing this national professionalization strategy. There were five core elements to that strategy. I might run through these because these flow into when we start talking about professional criteria.

These five programs of work where the first was about developing and maintaining an OHS Body of Knowledge. Our profession needs to have a body of knowledge. The second was having some education insurance standards through a process by which the institute could accredit OHS tertiary education programs. The third was working with INSHPO and working with other professional associations globally in defining the knowledge and the skill requirements of OHS professionals are within what was published in 2015, I think is the global capability framework.

The fourth was certification standards and processes for individuals to enable individual OHS professionals in Australia to be certified by the institute. The fifth was establishing a career learning framework for the continuing professional development of OHS professionals. That was a five-element program of work that commenced in 2009. It’s largely been delivered by The Australian Institute of Health & Safety over the last decade or so.

Drew: Just before we jump into the paper and the meat of it, I noticed that that list of five things seems to mirror the activities that just professional organizations do for more recognized or more established professions. This looks very much to me like it's called a professional strategy. It really does sound like a strategy to make health and safety at least look like or have the same activities, the same sort of structure as activity, as professions such as teaching, engineering, medicine, or nursing.

David: I agree. I think it's heavily consistent with core professional strategy. I think they're all reasonable things to do. I think in the next part of the podcast, we'll see how effective it's working out. 

The paper today that I titled I co-authored it with Pam Pryor. It's titled the emergence of the occupational health and safety profession in Australia. I assume, by now, most of the listeners know who I am. Pam Pryor AO was awarded the officer of the order of Australia for her services to health and safety. She has a very long and distinguished career in practicing safety and teaching safety, particularly in supporting the health and safety profession. 

She's currently the manager of the OHSBody of Knowledge for the Australian Institute of Health & Safety. We’ve also done a fair bit of work with Pam—you and I separately, and then together in supporting the authoring of other chapters of the Body of Knowledge and things like that.

The paper was published as part of a special issue in the Journal of Safety Science in 2019. We’ve talked about special issues before on the podcast, but the title of this special issue was the Evolution of the role and status of the occupational safety and health professional towards a Global Capability Framework. This was a dedicated special issue of the journal devoted to OHS professionals, the status of OHS professionals, and other factors relevant to the profession.

It was edited by Andrew Hale, Dennis Hudson, and also Pam Pryor who was my co-author. A number of countries, as part of this special issue, were asked to write a paper that describes the current status of the OHS profession within their country through the application of recognized professional criteria that we're going to talk about shortly. I think there were about 10 or 12 countries that provided a paper similar to the one that I provided for Australia.

Drew: It was a very interesting special issue and interesting how you could provide these standardized structures to people and say write a paper and it talks about your own country, and we’ll try to make each paper look roughly similar by basing it around these same topics. Then just how very different each of the papers is in their tone and substance.

David: Yeah, I think there's a number of other aspects of work associated with the profession that hadn't been formally published about the development of the global capability framework with INSHPO and a few other things. Actually Drew, the main ethnographic paper from my Ph.D. research, which we haven't spoken about on the podcast. We might save that for episode 100 or something. I think I had submitted it to Safety of Science at about the same time. I think it ended up being published in this special issue as well.

Drew: We had a little bit of a discussion before the podcast about how we’d handle this. Whether we’d go through each of the professional criteria to explain them, or just interleave them with the discussion of the OHS profession in Australia. I think what we’ve ended up deciding we'll do is we'll go through each one of the criteria. We’ll tell you what the criteria are, and then we'll have a discussion about what the paper says about it. Maybe just some reflection on how that fits in with current thinking in Australia. 

There are three broad categories that we’ll lay out in advance. There's a bunch of individual criteria. What makes a person a professional? Collective criteria, what makes a group of people a profession together? Then external criteria, from the outside, how do you tell if something is a profession or not based on how other people see it and how it interacts with other stakeholders? Should we leap into the individual criteria? What makes a person a professional?

David: Let's do that. There are four aspects associated with the individual professional criteria in this model. The first is role and career path. A profession should have an established hierarchy. It should have some consistency in role titles and it should have a career path. It should be clear how senior a person is in their career by their role, their role title, their responsibilities, where they sit in the hierarchy.

If we think about medicine, law, accounting, engineering, teaching, we see the way that the hierarchies exist, the role titles progress, and the role functions change with that seniority. I’d argue that this is not consistently the case for safety professionals.

Drew: I think that this is something that definitely characterizes professions, but it's hard to find a clean example of it. If you think of something like teaching, you know that you start off as an entry-level teacher. You become a senior teacher. You probably become the head of the department. Then there’s almost a career track decision that people make whether they go on to go into teaching admin or whether they want to stay primarily focused on doing the teaching.

You can tell from the job title that the principal of the school is the one in charge, but that doesn't necessarily mean that they are the most experienced or the senior teacher in the school. That person might have a title like the dean of learning or something like that. They've decided to go up there. In another profession like medicine, there’s a traditional hierarchy that splits doctors from nurses. But the fact that someone has a nurse title doesn't mean that they're not more experienced and in charge of the person who has a doctor title.

We've seen with the professionalization of nursing, in fact, separate career tracks that you can get to the same level of seniority either as a nurse or as a doctor, and you have different responsibilities along the way. There are lots of professions where this can be quite complicated in its structure and confusing in its structure. The important thing is whether it's well understood as a structure how it works. That's what we’re really lacking in safety. 

INSHPO, the international consensus, had this idea of almost two tiers—professionals and practitioners. You sometimes see that language used, quite a deliberate deployment of the word practitioner, deliberate deployment, or the word professional, which is similar to in engineering the idea of technologists versus engineers.

But that's only something that the professional bodies do. As far as I'm aware, it's not something that really works in terms of actual career structure. You see people who meet the qualifications for professionals who are at entry-level just out of university, and you see these people who don’t meet the qualifications for professional being the senior experienced person in charge of safety for a large organization.

David: Yes. I agree, Drew. I don’t think it matches the career structure in safety very well. I think we could benefit from having a look at how the profession is structured consistently across different organizations, but we'll talk about why that might not be an easy thing to do with some of the other criteria. 

The second criteria was that a profession should have a defined knowledge and skill base. What this means is that you have a body of knowledge. There is a domain. There is a body of evidence, literature, or decisions and processes that are owned and understood best by the individual professionals.

For Australia, at least, we do have an OHS Body of Knowledge. It has been progressively developed over the last eight years or so. This body of knowledge is used to accredit tertiary education programs. It’s used to certify individual practitioners. While I think there will always be a lot of debate on the scope of the body of knowledge for safety—what's in, what's out, what is the domain, what are the decisions that OHS professionals are best placed to make? I think in Australia, at least, in regards to this aspect of the profession, we do have a foundation developed.

Drew: David, I find this one personally a fairly hard thing to just wrap my head around how to think of it. We've got this project in Australia called the OHS Body of Knowledge. It's an attempt to encapsulate and put in place almost like a grand textbook of things that safety practitioners should know—at least the minimum standard of things that they should know—presented in an easy to consume form.

But that's not really what professional literature means by a body of knowledge. That’s almost like a very overly literal manifestation. We need a body of knowledge, so here it is. Whereas in other professions, the body of knowledge is much more nebulous in concept but much more certain in content. There's no way where you can say, what is current medical knowledge? Can I go and see the body of knowledge, please?

What shelf is it sitting on? But on the other hand, most doctors would have a much better idea of what is true and not true compared to safety professionals arguing about what is true and not true. Most doctors would have a much better idea of what is the minimum required medical knowledge for any doctor compared to the safety information and what is the minimum required knowledge for any safety professional.

I think in that sense, we've got this wonderful project called the Body of Knowledge. But in a professional sense, we don't have a stable body of knowledge. We have a really contested body of knowledge that's almost cyclical, more than a steadily progressing and growing body. That's one of the real challenges if you want to create gateways to entry and say who is and isn't a safety professional.

You can’t really do it based on what's the minimum knowledge that the safety professional holds inside their heads, what the safety professionals know and believe. We argue about that, we don't have a consensus.

David: I agree, Drew. I think part of this, we would also have to debate that it's because of the transdisciplinary nature of safety, it's very hard tonight what is actually the body of knowledge within safety if for nothing else just an understanding of the partial bodies of knowledge in a whole range of other disciplines. There are many things in our body of knowledge, which are actually psychology from a psychology body of knowledge, the engineering body of knowledge, the chemistry body of knowledge, or the organizational institutional theory body of knowledge.

All of that together is directly relevant for a safety professional in their role, but it's also not really our domain in terms of the knowledge—managing the knowledge base of the domain.

Drew: I think that is the real challenge that safety has faced in being a profession. It would be so, so neat if we just said, look, safety is a specialty all of engineering. We can adopt all of the existing frameworks of engineering, all of the existing education, and we’re just going to create this special separate area which is safety. It’s a subspecialty.

But if we did that, we would lose out on this huge amount of stuff that safety professionals are expected to know and to do, which is not engineering, which isn't in common with other engineers, which possibly even has different ethics as we'll get on to with a moment. We have this neat solution, which doesn't work, and this messy solution, which is to treat safety as a separate thing that is sitting in the middle of these other professions. That it might almost belong to you but doesn't quite fit.

David: I’d sort of test this with you, but my thought is that if you strip all of the knowledge and skill base of a safety professional, I can almost point every single part of it back to the parent profession. Whether it's training, whether it's a risk, all those things. Probably the only one that we could keep a sole claim over would be an incident investigation. What may be the only one that we could have some kind of claim over from a safety incident investigation point of view? But even that is a bit nebulous when it comes to engineering, root cause investigation, and things like that.

One of the tests for this is a term that came up in the professional literature called claim over decisions. Every profession should have a claim over certain decisions. Their decisions that that profession is best placed to make above anyone else. When it comes to engineering design, you go to an engineer. When it comes to medical diagnosis, you go to a doctor. When it comes to the treatment of the financial accounts of an organization, you go to an accountant. 

The open question that I’d ask is what are the decisions in an organization that the OHS professional is better placed to make than any other person in that organization? The Body of Knowledge should be associated with those decisions.

Drew: David, I really like that test because I think it gets at the heart of what does make safety genuinely different. If you look at teachers, you can look at plenty of things from other domains that teachers need to know. Teachers need to know their topic area, which clearly doesn't come from teaching. It comes from mathematics, studies of English literature, history, or languages.

Teachers need to know psychology. That clearly doesn't come from teaching that belongs to the field of psychology. Teachers need to understand the social interaction that comes from sociology. They need to understand the administration of large organizations. But at their heart, teachers still have these particular decisions that are exercising their professional judgment as teachers. They bring all that other knowledge to bear specifically to the problem and domain of teaching.

I think you're right that there is very little that safety professionals do that falls into that category. The times when we do it most, we’re not even making the decision. We’re advising someone else to make the decision. That makes it really difficult to then lay claim to what is the specialist knowledge we hold.

David: Yes, the body of knowledge or all that domain should be a reference to those decisions or those pieces of advice that the OHS professional is genuinely best placed to make or to provide for their organization. 

Drew: I was actually going to quickly move this on to the ethical code of practice because this links in actually really quite closely, given that you can think of ethics as to how do you make decisions properly. We should be clear here that there are existing codes of practice for safety. In particular, the Australian Institute of Health & Safety has a clearly stated ethical code of practice. 

David, do you want to say a little bit about some things you said in the paper?

David: Yeah. There is an ethical code of practice, although this ethical code of practice is only applicable to members of the professional association. If you've signed up as a member, then you are bound by that code of practice. 

We know that somewhere between maybe as low as 10%, maybe as high as 30%—that's being generous of professionals, at least in Australia—are members of the professional association. There's no reference to OHS professionals and therefore no ethical code of practice enshrined in any legislation or in any legally enforceable processes. 

By and large part, the profession really doesn't have any enforceable ethical code of practice or obligations. There's at least no mechanism to revoke an OHS professional's ability to practice due to any ethical incidents or any ethical issues.

Drew: I'm not certain that that is as much of a deal-breaker as the paper makes it sound. I think it is possible to have a strong ethical code of practice, even without enforcement mechanisms because you socialize the code of practice. 

Fairly famously, for example, it's really hard to get struck off as a lawyer for ethical violations. Unless you have misused client funds and things to do with money very quickly get you into trouble. There are all sorts of other rules that lawyers absolutely treat as sacred that are really hard to actually have consequences for, and certainly, there is no legislative enforcement of those things. 

Things like the cab-rank rule, lawyers take very much to heart—they talk about it, they think about it. It’s very hard to actually prove that someone has violated. It doesn't mean it's not real as an ethical obligation. But I do think that the code of practice for safety is really nebulous. Even though it is clearly stated, it's really just a list of values that everyone could agree with, even if they’re not safety practitioners.

Most of our listeners probably are not doctors, but they could probably state really clearly what doctor’s ethics look like. Everyone's heard of the Hippocratic Oath. Everyone knows that when you go and see a doctor, they put a lot of emphasis on respecting the autonomy of the patient. It's the patient's own decisions about their care that matter. 

We know that doctors are supposed to do what's best for the patient in front of you, not for the medical system as a whole. We know that doctors can be reasonably expected to keep their patients' information confidential and not blab it even to other family members unless you want them to. We know what doctors consider to be important.

Engineers, similarly. When I was trained as an engineer, we just had drilled into us this order of priorities: the safety of the public comes first, the duty to your employer comes second, your own interests come third. It's drilled into you. Only perform services within your area of competence. You're an expert in this, you're not an expert in that. The moment you get asked about that, you stop being an engineer. 

You want to hold yourself out to be an engineer, it's only in the areas where you're competent. When we're communicating particularly about risk, we have to be objective and truthful. That's at the heart of what it means to be an ethical engineer. 

You look at the OHS code of practice, it's a set of values that talks about balancing different concerns, and that's fundamental to safety. Safety doesn't put one thing emphasized over other things. Safety has to weigh up what is the long-term interest versus the short-term interest. Do I speak up now or do I hold quiet about this one in order to be more important about that one? Who am I really representing in this situation? Is it the worker, is it the public, or is it the management? Whose side am I supposed to be on? 

Those all are really difficult questions that safety people face on a regular basis. We don't have really clear rules to tell us how to navigate those situations.

David: Drew, are you advocating that we should have or that we shouldn't have?

Drew: I am saying that we currently don't. I actually honestly don't know whether it would be helpful or not. I think most of these things are not black and white. I'm guilty, I have to admit. Since I've been working as an academic instead of an engineer, I accuse engineers of black and white thinking because I think they can. 

When you're dealing with very technical problems, you can have very technical rules that wrap around those problems. When you're dealing with very social and organizational problems like safety people do, you can't have black and white rules about what's the right thing to do, and then accuse people afterward of breaking those black and white rules.

David: Yeah, I'd love to have a go at it, though. I think engineers inside organizations deal with the same sort of complexity of budgets, schedules, and engineering quality. Even doctors, we see the autonomy of the patient. 

In some of the discussions I've had with lots of OHS professionals, I still get a lot of value in going, okay, always put the person exposed to the risk first. A little bit like what you said, the safety of the public comes first. I always talk about the person exposed to the risk of being the primary customer of the OHS profession. When you're making decisions or taking action in your business, what does this mean for the person who's exposed to the risk? 

We could do something similar all the way through that provides a really clear direction for how to think about it. If we had that drummed into the entire OHS profession and was practicing in accordance with that, we might actually see an impact.

Drew: I can imagine a different world where safety people did have those sorts of ethics. I think you're right that we would be much more professional. I think it would have to be at that level like saying, okay, here are the order of priorities. Your number one priority is to the person exposed to the risk. That's black and white, absolute. Your number two priority is to act as a faithful agent of your organization. Your number three priority is to act as a representative of the safety profession. That would be fairly similar to the engineering obligations. 

Your own ethnographic work has shown that that is not currently how the role description of safety people plays out. I think we would then really struggle with the fact that we don't have control over those decisions. The decision about the risk that the worker has faced is not ours. That's an operational decision. We don't have provisional ownership of that. 

If we thought of ourselves as professionals like that, we would be in constant ethical conflict. If the number one obligation is to the person exposed to the risk and we can't stop the person from being exposed to the risk, what is the reasonable expectation from us? Do all safety people become whistleblowers? Do we have to just constantly just keep resigning en masse until people stopped?

I've literally seen that happen in an organization. I've seen four safety people resign from the safety manager job in a row because they felt that ethical obligation to have the hazard dealt with and it wasn't being dealt with. I knew the end result is just that the fifth person doesn't feel that same ethical obligation

David: Yeah, it is a good point. This hand-off of decisions and processes that maybe doesn't happen in engineering design, maybe it doesn't happen elsewhere. But in operations, it definitely does. Engineers hand-off decisions to operations managers all the time. 

I'd like to have a go at it. If we move on to the fourth criteria here, which I think is also a nice segue, it talks about professional status. The fourth element of this individual professional criteria is called professional status. This is really relevant to our conversation, Drew, because it relates to the structural position of the professional within the organization and how well the profession is referenced within regulation.

What we're talking about here is the reality that OHS roles and structures are extremely varied. Sometimes they're in operation, sometimes OHS is in human resources. Often, it's integrated with the environment, security, quality, risk, or compliance. This feels very different to the way that other professions are structured within organizations. We have a legal department, we have a finance department, we have an engineering department, but there's no real consistent home or boundary around the OHS structures within organizations. 

We've mentioned there are no direct references to the OHS profession in regulations, nor are there any obligations on companies to engage OHS professionals in a lot of ways. Drew, I really don't think that we've got a clear and consistent professional status.

Drew: No, I agree absolutely with that, David. I'm honestly struggling to see what the path is to get to that point. I've been watching with interest, within Australia at least, engineering is still fighting for that professional status. Certainly, when it comes to the legislative side of things. I may get my information wrong here, but my understanding here is that there are still places in Australia where you can hold yourself out to be an engineer. That it's not a protected term in any way.

I think Queensland is one of the few places where there are specific things that cannot be done except by someone who is a chartered engineer. But for most of Australia, there's no limit on who can provide that advice or make those decisions. Engineers in Australia have been fighting for a long time to actually get that protected status without full success. 

On the other hand, within organizations, engineering definitely does have that status. In most large organizations, they have something akin to a chief engineer position who, regardless of where they sit within the hierarchy are the final arbiter of technical decisions. Anyone within the organization with a technical decision can always refer it to the chief engineer. If the chief engineer says no, the answer is no, regardless of other management considerations. It would be very interesting to have that with safety—to have a safety person with that responsibility.

David: I have seen in a few organizations the chief safety officer, but mostly it's by title only, not by role, as it would be built into business processes like with the chief engineer. That technical authority type of role would be a good thing to see in OHS. I totally agree with you, Drew. 

That's the individual professional criteria. In summary, we talked about role and career path, defined knowledge and skill base, ethical code of practice, and professional status. I think what we'd say is there are some foundational elements in those four areas within the OHS profession.

I'd conclude that it's underdeveloped when it comes to the criteria and what it would take to consider ourselves a profession. 

Drew, we'll move on to the collective professional criteria. Here we start to talk about the profession more broadly—what it means to be a profession as a group of professionals. 

The first two criteria, professional organizations and professional entry criteria. Professional organizations are organizations like the Australian Institute of Health & Safety and others that support, advocate, and coordinate the profession. The professional entry criteria are the minimum criteria required to gain access or gain entry to the profession.

Drew, do you want to talk about those two and how we might think about those two together in a lot of ways?

Drew: Sure. The question at the heart of it is, who is part of the professional organization? To answer that question, you need a clear answer to start with of what is a professional organization? In Australia, we've got a number of different organizations that are claiming to be the place that you should belong to if you are a safety person. 

David, correct me if I'm wrong, I think you and Pam were a little bit modest in the way you represented things in the paper. I would go out on a limb and say that AIHS—what used to be the Safety Institute of Australia—is probably the premier generalist organization. But I understand why you wouldn't want to claim that in the paper. Because Pam, being a representative, wouldn't want to hold out and say, yes, it's us. 

Safety people could also belong to the Australian Institute of Occupational Hygienists, the Human Factors and Ergonomics Society, the Australian & New Zealand Society of Occupational Medicine, and the Australian Faculty of Occupational & Environmental Medicine. Those are just the ones you mentioned in the paper. 

I would also add that Engineers Australia has specialized subgroups. Weirdly, the Computer Society has the Australian Safety Critical Systems Organization as a chapter of it. There are all sorts of different places that you could belong to, and none of them have the majority of safety practitioners within that organization. 

You estimate in the paper there's between 20,000 and I think it's actually 40,000 safety practitioners in Australia. We don't really know. We're just going off via statistics categories. Whereas AIHS has between 4000 and 5000 members. You take the highest number of one, the lowest number of the other. Your best case is 25% that belong to AIHS, your worst case is actually more like 5%. 

That's not enough to create a closed shop because all these organizations are trying to get new members. The last thing they want to do is say, sorry, you can't be a member, you're not qualified. Which means you got this—it's not a Catch-22, but it's a real tradeoff. Either you put up barriers to entry and say, the safety of work should only be done by recognized professionals. Or you say we want to grow as an organization, anyone can be a recognized professional, just send us the cash. Either way, you end up diluting what it means to be recognized as a safety professional.

David: Yeah. This one is a genuine tradeoff. The professional associations, there's no real need for safety OHS professionals to join their professional associations. There's no real advocacy need for the majority of professionals. There are no professional development requirements. There's no mandatory certification. There's just no need for professionals to engage with the professional association. It does make it quite difficult for the professional association to get any critical mass. 

When we talk about the professional entry criteria, I still feel like this is the biggest barrier to OHS professional status. I'm probably going to upset some people with my next comments. Drew, I, for one, absolutely believe that we need some kind of minimum educational qualification, a requirement of some kind to be an OHS professional, or to have certain designations to do with OHS within the profession, even if it's not the entire profession. 

I'm not necessarily saying here it has to be tertiary education or something like that. I think without some sort of requirement, then it's very hard for us to think about our professional standards, our certification, and any kind of minimum level of performance of the role across the profession. 

Drew, I thought about this a few times. I can't think of another occupation that has the potential to impact the health and well-being of people in a society where there's no formal qualification. You need a qualification to be a security guard. You need a qualification to be a personal trainer. You need a qualification to do nutrition or any of the allied health professions. Even to be a financial adviser or any of these things. 

You can apply for the safety manager of an airline or mine site with not a single qualification of any sort, and it would be perfectly acceptable for you to do that job as far as the profession is concerned. I just don't feel good about that.

Drew: David, I'm going to agree with you for reasons that I'm not quite sure are the same as yours. Very often, the moment people make that argument, the debate gets into, what sort of skills and knowledge do you need to be good at a safety practitioner? We get into arguments about people who have got degrees but no people skills, or people who have been working in the profession for 20 years. All of that is irrelevant. 

One of the fundamental personal attributes of a professional that I don't think actually makes the list of four things you have in this paper, but just a commitment to basing your practice of a body of knowledge. Developing your own skills through education, continuous improvement is part of what it means to be a professional. 

Even if you think that tertiary education in safety is worthless, if you think of yourself as a professional, you should still be committed to getting that education because that's what professionals do. Professionals challenge themselves with ideas and knowledge that they don't currently have. Professionals don't believe that they already know stuff and don't need to know more stuff. 

Everyone I hear fighting back against the idea of the minimum education, the way they fight back just tells me they don't want to be professionals. Now, that might seem harsh. There are plenty of jobs that aren't professionals. There are plenty of good people who aren't professionals. There are plenty of fantastic leaders who aren't professionals. But part of being a professional means a commitment to your own education.

David: I think we don't necessarily have to be. I mean, if the OHS profession doesn't want to be professionals, there are other occupations within organizations that also are probably quite similar like human resources, information technology, marketing, or corporate communications. There are lots of other occupations that go on. But there seems to have been—from a lot of the professional associations and the direction of the profession (if you like) to become more of a profession. 

These are some of the difficult hurdles that we're going to have to get over if we want to be professionals like teachers, accountants, lawyers, doctors, nurses, or if we want to be occupations. These are the challenging hurdles we need to overcome.

Drew: David, there are still some people who might be listening to the podcast we haven't offended yet. 

David: Oh, good luck. 

Drew: I just want to go a step further here. The AIHS made a serious tactical mistake when they split things into practitioners and professionals. We don't do that in real professions anymore. There's no such thing as a teaching professional and someone we also teach, but they're just a teaching practitioner. There are teacher aides, there are specialist assistants to teachers, but they are not teachers. They don't get to do the same things that teachers do. They do other different stuff in a school. 

I think throwing out this bone to say, well, education matters, but it only matters if you're dealing with senior management. It only matters if you're dealing with strategic decisions, not if you're doing safety with real people. That undervalues the whole project of becoming a profession. If we are a profession, then we don't want to have safety practitioners and safety professionals. We just want to have safety professionals.

David: Yeah, Drew. I think you know a little bit of the history second-hand because I've asked that question as well. That was more of a compromise than a tactical mistake of trying to get 12 or 15 professional associations around the world to agree on a single framework. But I agree with you. 

When you look through the knowledge, the skills, and activities, there is not one knowledge, skill, or activity where the framework says the practitioner needs to be more skilled than the professional. It actually doesn't make any logical sense when you look at that distinction in that framework. But I understand it was a political compromise as opposed to a useful distinction.

Drew: Something can be a political compromise and be a mistake.

David: Yeah, yeah, absolutely. Good point. I might move us on, Drew, for the one or two people that are still listening. The third collective criteria is around professional education. 

There need to be professional education programs that exist. There is, in Australia, an accreditation pathway. For the Australian Institute, there is an Australian Institute of Health & Safety. It has an independent OHS accreditation board. The first university-level programs were accredited in 2012. By 2018, there were 12 universities offering a total of 27 accredited programs. I believe the Graduate Certificate of Safety Leadership at Griffith is an accredited program.

Drew: David, no. That is embarrassingly not correct. I don't know if this counts as a conflict of interest. We made a decision not to seek accreditation for our programs at Griffith due to the fact that we were offering something that we considered to be substantially different from the other OHS programs, and we didn't want to be in that same basket. We didn't want to mislead our people who might come to us. We didn't want to mislead people about equivalence between different things. That shows some of the difficulty in accrediting education. 

I think the hope was that providing accreditation would be a two-way street. It would improve the quality of programs, and it would help those programs market themselves to the world and to universities to help the programs become more established through this external recognition. It didn't seem to happen.

The number of university offerings has decreased over time, not because they've been weeded out through this accreditation, but through market forces. Accreditation, I think, actually helped with the marketing, it helped support them, and it helped them survive, but it wasn't enough. There’s just a lack of consistent demand across Australia for education.

David: What would be interesting to do would be to simplify this all down into a kind of a fault tree because what you talked about there with the industry demand which is there is just no demand for university education in safety. There's no demand because organizations aren't asking for university-trained professionals, and because they're not asking for them, there's no demand.

There are a few that go and get extra qualifications, but not enough to sustain some of these programs. These university programs aren't getting 100 or 200 students a year like some of the other programs in their schools. There's just no reason to keep those programs around.

Drew: But there was an interesting statistic you had in the paper, a safe search survey that said that 54% of managers, 63% of national managers, and 62% of general managers have university-level safety qualifications. Do you think that's representative?

David: Well, it's hard to know what's representative and what's not because we know that we've got access to 5% of the profession through the professional association. As members, we know that this survey is maybe surveying 100 or 200 people who actively engage with safe search remuneration surveys. These are generally mature, large organizations, and maybe they wouldn't be representative of the population of organizations either.

This stat of 50%-60% of safety people being tertiary qualified in safety, I probably don't believe it. But, hey, that's kind of all the access to data we've got.

Drew: At the very least, it does show that there are places—even if they're not universal—where there is a strong value being placed on education. These figures might not be representative, but they are certainly going up over time.

David: Yeah, I agree. Drew, let's move on to the final section, which is the external professional criteria. Then we can round out with a bit of a summary and practical takeaways. The first is a legal requirement. How does the law look upon the OHS profession? 

There are currently no legal regulations in Australia that regulate the OHS profession. There are no licensing requirements, no registration requirements, no qualification requirements. There are no specific obligations placed on safety professionals, except just recently in one of the states of Australia, which has put a requirement on the responsibility for people providing safety advice.

There's been an obligation for 15 years or so in another state in Australia that companies need to engage suitably qualified advice, but there's no advice around when to engage or what is suitably qualified for that advice.

Drew: That sounds like a pretty clear no to the legal recognition of the profession. How about societal recognition of the profession?

David: Societal recognition, this is where we think about what is the OHS professional status within Australian society more broadly. 

If you go to a barbecue at someone's house and you say, I'm an engineer or I'm a doctor, it's your turn and you say, I'm a safety or an OHS professional. The societal recognition is what is exactly that? What recognition does society see? How relevant and important does it see the profession? How does it see the contribution that that profession is making to society more broadly? 

Drew, I see that the status—at least within Australia—is that the profession is probably regarded lower than other professions. People will always have a story about how they see the formalization of safety management impacting their everyday life, how much this must be driven by the OHS profession, and how much of a nuisance that we've become to everyone who tries to go about their daily lives in a normal and fun kind of way. That would be my view. How would you see recognition within society?

Drew: David, I was just imagining any other group of people having this same conversation. Teachers asking themselves, are we really a profession like those other real professions like doctors, nurses, engineers, safety? 

I just cannot imagine safety being included in a list of professions that people would aspire to also be a profession. We tend to get portrayed very negatively. I mean, it's not just at the barbecues. In the media, most people only hear about safety after an accident. What you usually hear is, oh, they were safety people, but they were undertrained, incompetent, possibly even said that things were safe before the accident happened. 

We don't see people wanting to come out of high school and be safety people. You talk to any safety professional, their origin story is they sort of got into safety by accident. The only people I have ever talked to who deliberately got into OHS have been when I've talked to undergraduates in the current programs. These small programs—10 people in the program—you talk to them, they say, oh, I decided to do this as a profession. That's a very small minority of people in the profession coming out of high school aspiring to be part of safety. 

David, you've said there are only four undergraduate safety programs left.

David: At the time of the paper, it may be less. There are four undergraduate programs left in Australia running across two of the states. Almost all tertiary OHS education occurs at a postgraduate level. They predominantly are going to be students who are already employed in OHS roles. 

Drew: Yeah. I know a lot of people in those undergraduate programs are of mature age or coming from overseas. They're not necessarily school leavers coming straight into the programs either.

David: Drew, we talked about a bunch of individual, collective, and external criteria about a profession. We've been up and down and offered our own views. Let's do some practical takeaways. 

I thought one of the practical takeaways that might be interesting for our listeners, if they can get a hold of this paper, is to think about the application of these professional criteria just within your company. You don't necessarily need to tackle the profession as a whole, but you can start to ask yourself these questions about the people in these roles in your organization. The definition of these roles, the career path, and the entry requirements to be an OHS profession in your organization. It would be a good exercise for you to do.

If you have some gaps, then the question becomes, are you comfortable with those gaps in the professional criteria within your organization?

Drew: David, I really like that framing. One way to look at it is that professions exist from the inside and from the outside. We can't do much about the outside as a practical takeaway, but we can certainly do stuff about how we see ourselves as professionals. 

Do we treat ourselves like we're professionals? Do we focus on having a clear standard of ethics? Do we know what our ethics are? Do we have a body of knowledge? Do we approach our work as an evidence-based practice applying a body of knowledge to the local work? Do we seek to constantly improve our own education? Do we undertake continuous professional development?

David: This allows you as a professional or within your organization to focus on your own quality and consistency of advice to approach your role and your organization with an evidence-based practice lens. Hopefully, The Safety of Work podcast helps in some way of that. But it's also not a replacement for a clear OHS education pathway, which I'm not sure how well it exists at the moment. I still think that's a lot of work that we need to do as a profession.

Drew: Questions to the listeners from this week, I've talked in a couple here. I'd be just interested in whether other safety practitioners think of themselves as professionals. Would you consider yourself to be a professional? Where does that identity come from? Does it come because of the work you do in safety? Or do you consider yourself to be part of some other profession—psychology, engineering, or some sort of other professional identities?

Then what things make you feel more or less professional? What things do you do that make you feel professional? What things do other people treat you as that make you feel more like a professional? 

David, before you can get in, I'm going to throw the question of the week to you since you wrote the paper. We asked the question, is OHS management a profession? The answer?

David: It’s a simple not yet from my perspective. In the conclusion of the paper, we talked about being an emerging profession where it'd be almost like we're trying and we’re putting in place some of the foundational aspects, but we just don't have established fundamental building blocks that we need to be a profession yet. But who knows?

Drew: Thanks, David. That's it for this week.

We hope you found this episode thought-provoking and useful in shaping the safety work in your own organization. As always, join us on LinkedIn or send any comments, questions, or ideas for future episodes to