The Safety of Work

Ep.80 What is safety clutter?

Episode Summary

In today’s episode - our 80th episode no less-  we do a deep-dive into a term coined by Dr Drew Rae himself, namely, Safety Clutter. Clutter in safety procedures are a thorn in the side of many employees and contractors. We discuss the different types of clutter, what causes these procedures to become cluttered and why it's a good idea to declutter.

Episode Notes

The paper we reference today is our own research paper published in 2018 named; Safety clutter: the accumulation and persistence of ‘safety’ work that does not contribute to operational safety. So we have done ample research when it comes to this particular topic and we’re excited to share this knowledge with you. Hopefully you will take away from this episode a better understanding of where to start looking for (and clear out) clutter in your own workplace.





“Clutter by duplication - when you literally have two activities that perform the same function, then you know that at least one out of the two is going to be unnecessary. - Drew Rae

“They ended up having to create a hazard on the work site for the manager who was doing the critical controls inspection to check that they had properly managed the hazard.” Drew Rae

“I found a 28 page work page work instruction on how to spray weeds on a concrete pathway with a weedspray that was biodegradable and commercially available at any supermarket.” - David Provan

“It’s harder to remove anything that is there for safety than it is to add something that’s there for safety.” - Drew Rae

“Did you know that some of the things we do in this organization, specifically for safety, may make our organization less safe. - David Provan



Griffith University Safety Science Innovation Lab

The Safety of Work Podcast

Research paper

Episode Transcription

David: You're listening to the Safety of Work podcast episode 80. Today we are asking the question, what is safety clutter? Let's get started. 

Hey, everybody. My name is David Provan and I'm here with Drew Rae. We're from the Safety Science Innovation Lab at Griffith University. Welcome to The Safety of Work podcast. In each episode, we ask an important question in relation to safety of work or the work of safety, and we examine the evidence surrounding it. 

Our regular listeners would know that every 10 episodes we give ourselves permission to talk about our own research. We're a bit surprised that it has taken us this long to talk about safety clutter given how popular the topic is in industry. Here we go. 

First of all, being at 80 episodes, a big thank you to all of you who listen, who share episodes with colleagues, and also who follow along in the evidence based discussion that we've been working to facilitate mainly via LinkedIn. Follow along to the Safety of Work page on LinkedIn and join in the conversation. 

Drew, at the time we're recording, I think I just checked today, we have over 125,000 of episodes that we've done the last 80 episodes. We sort of cracked the top 15 management podcasts of all time on at least on Australian charts, but also on many other charts around the world. That's a lot of people in businesses that are taking an interest in what works and what maybe doesn't work when it comes to managing safety. Drew, what's today's question? 

Drew: David, I think you've already mentioned. Today we're going to talk about safety clutter. The general idea of clutter is something that is pretty well-known across industry. It's something that people complain about a lot. They talk about tick the box safety, safety bureaucracy, or the rise of bureaucracy and safety, but it's not something that actually gets talked about a lot in safety research. It seems to be more of a practitioner complaint. 

It's interesting, at least to me as a researcher, because I find it really interesting that we've got this thing that everyone complains about but no one does much about. It's not just the general phenomenon. People will complain about specific safety activities and call those specific activities a waste of time, but that's not enough for them to stop doing them. 

Investigating safety clutter is a way to try to understand how this comes about. How do we get to the point where we're doing work, and perpetuating work, and making other people do work that we ourselves don't believe in? And why is it so hard when we want to get rid of it that it keeps coming back or doesn't even go away in the first place? Why is it that red tape reduction initiatives create red tape? 

David, perhaps we should throw in the definition of safety clutter? 

David: Yeah. How about you do that definition and then I'll sort of reflect on some of the introductory comments you just made?

Drew: Sure. In writing the paper, we actually had to think a lot about the exact definition. This is the product, probably of many many rewrites. We've defined safety clutter as the accumulation of safety procedures, documents, roles, and activities that are done in the name of safety that doesn’t contribute to the safety of operational work. 

David: Yeah, that definition, Drew, I think takes a long time to short speech and we thought quite a lot about that definition. Again, the name I think, Drew, it was you that coined this term safety clutter, and it was like the clutter that's around your house. It's in your house, you're not using it. Maybe you bought a treadmill and it worked for the first week and then you just kept tripping over that treadmill for the next 12 months. 

You never actually got rid of the treadmill. You like the idea of the treadmill, even though it was doing nothing for your actual current state of fitness. 

I think we thought of safety clutter as being a little bit like that. Maybe it had an intention at one point in time and maybe it might have actually contributed something at a point in time, but it just happens. You know and others know in the organization that it doesn't add any value to operational safety, yet it's still there and still maybe being done every day. 

One of the important aspects of the definition that I think gets a little bit misinterpreted by others is people think that addressing safety clutter or decluttering is all about having less things. It's all about getting rid of things or taking stuff away, yet the definition is really specifically about the effectiveness of the things that we do in relation to their impact on operational work. It's much more of an effective conversation than it is a volume conversation. Would you agree with that? 

Drew: Yes. In fact, I would say that I'm agnostic about what is the right amount of safety work to do. Talking about clutter isn't a way of telling other people what you're doing is clutter. That's often a judgment for the people who are doing the work to decide what is and isn't clutter. 

What I'm most interested in are things that people themselves think are clutter and the reluctance to get rid of them. The reluctance to stop doing things that even we, ourselves, don't think are effective. I mean, sure, there are some activities that we might want to evangelize and tell other people to stop doing, but there are so many things that we need to give ourselves permission to stop doing first before we even get to that stage of needing to have arguments about what needs to be removed.

David: Drew, in this paper which we'll introduce in a moment, we talked about safety clutter as potentially having three dimensions. In trying to understand that question about your organization about a specific safety procedure, safety document, safety role, and safety activity that you are performing, you might like to think of it as three questions. We named these the three C’s, and I'll just briefly introduce them, Drew, if you like. 

The first one being a contribution. When we look at this document, activity, role, practice, to what extent can this activity contribute to safety? We need to understand what extent this can actually impact operational work and operational safety. 

Then when we've actually got an understanding of what that contribution could look like. Then we've got to ask ourselves this confidence question, which is like, what gives us confidence that that value is actually being added through the work? Do we have evidence? Do we have specific data? Or is it a belief? Is it an assumption? What is the confidence that that particular activity or practice role document is actually making the contribution that it has the potential to make? 

Then what is our consensus around that? Drew, you mentioned that the person performing the tasks has probably a weight of opinion about how effective the activity is because depending on how they conduct it may do a lot to the effectiveness of it. 

We talk specifically here about what's the level of agreement between the people who require the activity to be performed, the people who perform the activity, and then the people who are supposedly kept safe by the activity being performed, which creates some dialogue around the activity. 

Drew these three C’s is a great framework in talking with people in the industry. Look at anything you do in your organization for safety and say, what contribution can this activity really make? How do I know if it's making that contribution or not? And what do all the people involved in that particular activity think?

Drew: Yes. It's those three things that give us a guideline as to when to start suspecting activities. If there are activities that only some people think are working and that other people don't think are working, activities that we think work but that we don't have good evidence for, or activities where we think they work but we're just unsure whether the value they offer is proportionate to the amount of time and effort we spend on them.

Anytime we find ourselves having conversations about any of those three things, that's the time to start asking ourselves, is this in fact, safety clutter? And something that obviously scores poorly on all three dimensions, those are our prime candidates—the low-hanging fruit to think about removing if we can. 

David: Drew, would you like to introduce the paper? I think it's your job to introduce it as the lead author. 

Drew: Okay. The paper itself is called Safety clutter: the accumulation and persistence of ‘safety’ work that does not contribute to operational safety. The lead author is myself. The other authors are David, David Weber who was working in our team at the time, and Professor Sidney Decker.

This is one of the most across the lab endeavors. It wasn't a single project. It was multiple people working on multiple projects coming together to pull the evidence for this paper. It was published in 2018 in a journal that actually doesn't exist anymore called Policy and Practice in Health and Safety. 

We put it into that journal to try to target it a little bit more towards practitioners and to get a bit of practitioner feedback on the review. Yeah, that was a great journal and it's sort of sad that it died away, but it was becoming a very one-man effort to keep it sustained. 

The paper is structured basically around four questions. What are the mechanisms that create clutter? How does clutter come to be? Then slightly more deeper, what are the underlying causes of that as opposed to just the straightforward mechanism? And what makes it hard to get rid of? What are the effects of clutter? Should you even worry about it? Is it good, is it bad? Then assuming that we want to do something about it, what can we do about it?

I think it would be fair to say that the paper gets more and more speculative as it goes through those four steps. We're very confident about what safety clutter looks like. We're fairly confident about what causes it. The evidence for the effects is a little bit weaker and harder to show, and then what can we do about it is more in the aim of suggestions and aspirations rather than evidence-based. David, would you say that's fair? 

David: Yeah, I think absolutely, Drew, and maybe if I talk about the method and how the paper came about for a moment, and then we'll talk about each of those four subsections of the paper that you mentioned there. This is the first time I've been involved in a paper like this, Drew. 

You mentioned that there were several studies going on in the Safety Science Innovation Lab at Griffith. One of those studies was my Ph.D. project and there were a number of other studies that were going on. They're all largely ethnographic studies being performed inside real organizations within retail, logistics, construction, and oil and gas sectors, and really looking at the impact of certain safety activities and practices on work, risk, and operational safety. 

In that regard, the paper wasn't entirely conceptual. In fact, I liken it to a real-time grounded theory, where you were the one who was mainly sitting across—at least yourself in Sydney—all of these projects happening in the lab. The lead researchers, such as myself, were coming back with very similar perspectives on the relationship between safety activities in real organizations and operational impacts, maybe sometimes lack of operational impacts, or even negative operational impacts. 

You sort of pieced these all together and said, I actually think we need to try to conceptualize and explain this idea. It was a theory-building process that was actually based on data that was being gathered across multiple seemingly unconnected projects, but all arriving at some consistent conclusions.

Is that how you describe the process of saying, hey, I think we need to write something about what's going on here?

Drew: Yes, definitely. Just thinking of the way you described then almost sounds like the way that people originally came up with HRO theory. It's different people doing different case studies in different organizations realizing that there are similarities between these, and we can do a better job of explaining it if we create one thing and talk across multiple organizations. 

I don't want to claim that safety clutter is remotely the next HRO. In fact, I hope it is a much more precise and smaller concept because I prefer smaller things rather than big grand theories of safety. But it's a similar process of multiple researches, multiple case studies, and using those to see what is specific to an organization and what is common across different organizations in different contexts. 

David: Yeah, Drew, but it might be equally as hard. It's been three years since the publication of the safety clutter paper. I don't know about you, but I've at least spoken somewhere every month on this topic. We're starting to get a few decluttering projects in organizations or organizations that are really interested in trying to do this well and do it (a bit normative to say properly) consistent with the theory. But then yeah, lots of organizations have gone off themselves and done this as well in the last couple of years, probably with mixed success. 

Let's talk about the sections of the paper because it might give people some ideas about what to do and maybe some ideas about why some of their efforts might not be yielding what they hoped. Drew, the first section, which is titled Characterising Safety Clutter. This is really also thinking about how it gets created. What is it and how does it get created? Do you want to kick us off with how the paper frames safety clutter? 

Drew: Sure. Basically, we're looking at what does safety clutter look like? And there are two broad categories of clutter that we found. The first one is the most, I think, obvious and noncontroversial. This is the idea of Clutter by Duplication. When you literally have two activities that perform the same function, then you know that at least one out of the two is going to be unnecessary. 

In the extreme case, these are literally you go to walk onto a site, and the supervisor fills out a risk assessment, takes you through it, then flips the page over, and does the same, but now it's the subcontractors’ version of the exact same risk assessment with the exact same content. But both organizations require that it be filled out. Or someone wants to go down a hole and before they can go down they need a work permit, and they need two separate permits for that exact same activity. 

Your duplication whenever you see it is incontrovertibly clutter. The weird thing is it's often one of the hardest ones to get rid of because there are sane/insane reasons why we have two forms for the same activity. 

The first reason is this idea of inter-organizational duplication. We've got a contractor and we've got a client, and each one has forms that need to be filled out. You'd think it might be nice and simple. We just tell one of them they don't have to have the form, but the auditor doesn't agree with us. The auditor wants to see the form exactly as they've specified it in their safety management system.

David: Drew, this might be two inductions or a risk assessment in the company's format, but also then redoing those risk assessments in the client’s format, or like you mentioned multiple permits. It's just doing the same thing twice without adding any value from the redundancy. 

Drew: The other place that I hear this one a lot is with reporting. People after an accident need to write three separate reports to satisfy three separate audiences, all with the same material in each one. Slightly more insidious is Multiple-relationship Duplication. 

This is the idea that you've got a subcontractor who wants to work for a principal contractor, but they're doing jobs for two parts of that same company and each one of them requires you to fill out the company's paperwork. They might literally be filling out the exact same forms twice just with a slightly different job number on each one, or they might be having actually different systems because the company's own systems are slightly heterogeneous. 

I don't want to name names here, but I'm working for big company A. Big company A department to do with infrastructure needs me to fill out one form, big company A to do with construction needs me to fill out a different one. I'm just doing the same electrical work for both of them, but I need two forms. 

It could be Inter-system Duplication. HR has one set of forms, procurement has another set of forms, safety has another set of forms, and each one of those forms often asks the same questions, but they're slightly different for different purposes.

David: I know of one example where an individual who was driving a company vehicle, if they had an accident would have to complete four accident report forms. One that went to insurance, one that went to the fleet, one that went to finance, and one that went to safety. In their glove box, they had four different incident reporting books to go to the four different departments within their own organization.

Drew: Another one of them is Within-system Duplication. This one is the slightly more embarrassing one. This is the one where the company literally has multiple versions of the same form or activity within the same system. 

I'm definitely not going to name names here but I know you're listening. The company is transferring from a paper-based system to an electronic-based system, and they're trying to decide whether the management site visits to inspect critical controls in the electronic system. Whether that should line up with the site visit to inspect critical controls on the paper form, except they find that they've got three separate paper activities, all of which could match up. 

Inside the electronic system, they've now got two new activities, neither of which match up with any of the three paper activities. All of which is the same thing about managers going to sites to inspect critical controls. We end up with five versions. The three legacy forms, the two electronic ones in the system, and presumably, the attempt to reconcile them all is just going to create a new form, which is the unified form.

David: Yeah, Drew, I think this is one where there's multiple within the same system. Your control at work system, you might require people to have a work instruction, but then also do a JSA, then also do a take five, and then also get a permit that requires a task risk assessment and this infinite loop. 

The most duplicated I've seen are seven separate risk assessment processes to get a hazard activity performed. I think this is where you've got one management system that you keep adding to over time and you actually end up duplicating processes that look different on the surface but actually are designed to deliver the exact same thing.

Drew: Then the final one with duplication is where the industry attempts to get rid of some of this by creating industry standardization. The classic case this happens is with inductions. We realize that the contractors are having to go through the exact same induction for five separate companies. Instead of them doing five different inductions, we create an industry white card, and now all they need to do is get one white card and that takes care of the problem. Except it doesn't because each of the five companies still ends up insisting on doing their own induction including checking that the worker has a white card. 

The extreme case is that a person has to do an induction for their own company, an induction for the client, an induction for the specific project that they're doing for their own company, and an induction for the specific project they're doing for the client. Plus, they need to complete the annual update refresher for both of them, all of which before they're allowed to go on site. 

If people actually follow the rules, it gets ridiculous how many times people need to sit through the same induction. Each one is slightly different, but with many, many slides in common.

David: These five aspects of duplication, I don't think they're that controversial, but still amazingly prevalent today inside organizations and we'll talk a little bit more about that later on in this episode about why that might be the case. But even if people are thinking that, okay, that's not my organization, I don't have that duplication. 

The second way we've characterized clutter is this idea of generalization, which is this application of safety activities and processes more widely than they need to be or more widely than the opportunity to have a meaningful impact on operational work. Do you want to kick us off here? There are also five things that we want to sort of briefly talk about in relation to generalization.

Drew: Sure. The one I'll start with, I'm hoping is going to take care of anyone who is listening to all that duplication and gloating. Go right now to your break area and check the hot water tap. If it has a little sign above the hot water tap warning you that the hot water is hot, you've hit the problem of generalization. 

The number one problem is over-conservatism. Instead of making risk-based decisions, we expand safety activities to cover things that don't need the protection of those things. Permit starts off being just required for specific high-risk tasks, but our definition of what is a high-risk task gradually expands until it covers everything. 

We started off just having PPE in areas where we need PPE, but it became too hard to police the boundaries of those things so we ended up having people wearing PPE in the offices, and then we started requiring people to wear PPE in the offices.

David: Drew, an example of that I heard today from an organization was that their site prepares 30,000 work permits a year. If you just did a math about how many permits are being done every day on a site like that, you go, well, how much time and attention are constrained resources spending on those permits?

Drew: I will guarantee that there is some clever person who has worked out that the way to check the permits have been filled out is to weigh them because it's the only way to actually count how many work permits have been done.

David: I think hopefully, as we're going through some of these people are starting to go okay, well, I can see not just some reasons to worry for when we get to that section. 

The second one is symbolic application. This idea that we're applying a rule and a process to low risk activity as a way of maybe not specifically changing work, but as a way of reinforcing our commitment to safety. We might call it social safety work in the safety of work model. 

We're saying, okay, well, I'm going to do a risk assessment for traveling on a Qantas, American Airlines, or a commercial airline. I'm going to do a toolbox talk in my office, which is the same information that I'm giving in my toolbox talks to people in the field.

People are sitting in an air-conditioned office doing low strenuous activity being told about heat stress and heat illness because that's what the field is being told about. This is applying this risk in process to a low-risk activity, not to change work, but we assumed to maybe have some symbolic application for safety.

Drew: I think this is the point where we begin to see that some of this apparent insanity does have a rationale behind it. That sort of thing starts off with someone not wanting to be a hypocrite. They realize that they're making other people do risk assessments and they think, why should I be going out to the site to make people do risk assessments and I don't do a risk assessment for my own work? 

Now, maybe some people would think, okay, am I going to stop making other people do risk assessments? Other people think, well, I got to do the risk assessment too, and so we end up at the head office with a sign on the stairs warning people to make three points of contact because that's what we do out on site. That's what we do in the office. 

David: I’ve seen them, Drew, and if you've ever tried to walk down a wide flight of stairs, maintaining three points of contact, it's a challenging exercise.

Drew: A beautifully architected wide spiral staircase still with all of the signage as if it was a ladder on an oil rig.

David: You start to struggle once you get to the second step, let me tell you that, and you got to lift your first foot up.

Drew: The next one, which is really frustrating, is attempted simplification does this. People see that there are too many rules and we think, okay, we got to simplify this. But when you simplify, what you tend to do is you tend to make things more broadly applicable. Instead of making people work out what counts as a confined space, you make a general rule that all manholes—sorry, what's the politically correct term for manhole?

David: Person access point.

Drew: All access points are counted as confined spaces. But then you end up with a situation where you've got one of these round things on the road that's only got 30 cm below it before someone can open it. Suddenly, they need to put in all of the fall protection things and all of the confined space permits because your blanket rule has now made people apply things that are sensible in some cases in situations where they're clearly not sensible at all.

David: Dew, the next one is the least common denominator, if you're happy to move on. This is where we apply a conservative process that we might want to think about in relation to some tasks or even some aspects of the workforce but applied to everyone. 

We think that, for example, a certain piece of equipment like chainsaws is dangerous, so we put in a rule that says all chainsaw activities must be directly supervised by a supervisor at all times. We require a 30- or 40-year experienced arborist to call a supervisor every time they want to use a chainsaw, which maybe, if it's the first day on a job, you might want to supervise a person using that equipment, but an experienced operator probably doesn't add any value to.

Drew: The final one is the idea of over-specification. This is where we start to record rules into things like safe work method statements. But instead of recording just the minimal set of rules that's necessary, we record the entire way of doing the job, and that then becomes a set of rules. Or sometimes it'll happen where we start off with a simple list of hazards for people to think about, that's mostly a blank form, but then we start to give people extra guidance. 

Before we know it, anytime someone thinks of a new type of hazard, it has to be a new line on the form that someone has to specifically check for. The most bizarre case of this I saw was where someone had to demonstrate that they were checking for all the types of hazards. They ended up having to create a hazard on the worksite for the manager who was doing the critical controls inspection to check that they had properly managed the hazard.

David: That's crazy. I think the most clear example of this, which has since been beaten, but I won't name it in case they are listening, was I found a 28-page work instruction on how to spray weeds on a concrete pathway with a weed spray that was biodegradable and commercially available at any supermarket or shopping center. It was almost like a university-level education in occupational hygiene.

Drew: Sorry, David, my pause there was just not knowing what to say. 

David: That's okay. 

Drew: No, no, let's go on to the next section because at least this is probably heard of some hints behind some of these things about why it's happening. What I really like as a clear explanation for the underlying cause of all of this safety clutter, and it's the thing we call the ratchet effect. 

The idea is that there are two things that are asymmetrical, so they're harder in one direction than in the other direction. The first one is that it is harder to remove anything that's there for safety than it is to add something that's there for safety. 

It's harder in a number of ways. Usually, it needs more evidence to get rid of something than it took to put the thing there in the first place. Usually it requires someone higher up in the organization to get rid of something than put it there in the first place. And it is psychologically much harder to stop doing something that's there in the name of safety than it is to stop doing something for safety. 

David, I don't know about you, but I am very, very curious about what's going to happen with all of the COVID protections because I think the ratchet rule is going to apply absolutely to all of these. When we put in place a lot of the protections, there wasn't that much evidence that they were needed or that they were effective, but it was important to just get them in as quickly as possible. Often they were done at a very local level. They were spontaneous, they were reflexive. All of that is fantastic, but how hard is it going to be to get rid of some of those things again?

David: Yeah, Drew. I think if we just think for a moment, when I talk about this, I talk about the almost infinite opportunities to add safety practices and activities into your organization. The obvious ones, anytime there's an incident, anytime there's an audit, anytime there's a safety committee meeting, management safety meeting, improvement planning session, or a manager attending an industry meeting around safety—any conversation ever with a safety person in your business is an opportunity to add something new. 

If an organization is really, I suppose, genuinely intent on improving safety, then it's going to have a very low bar to approve or accept additional safety work activities into their business. This ratchet effect is, the easier it is for companies to put in place safety things, the harder it's going to be for that same company to actually take anything away because of that perceived commitment or that perceived lowering of their commitment to safety by taking absolutely anything away to do with safety. There's this psychological admission that we care less about safety if we're taking something away. 

Drew: There are these two imbalances. There are opportunities. There are far more opportunities to put things in than to take them away. Then there's the difficulty. It is far easier to put things in than to take them away. You combine those two things, you realize that actually, it's inevitable in the organization that the amount of safety stuff we're doing is just going to gradually grow and grow and grow until we specifically try to create an opportunity to go back the other way. 

You see things like safe work method statements, every version gets longer and longer and longer until the organization says, okay, we're going to go through now and streamline all of our safe work method statements. They all go back to being shorter again. Then they grow and get longer and longer and longer. 

You see the number of forms increases, increases, increases. Until someone has a deliberate red tape reduction exercise, the number of forms goes down again, but then gradually just goes up again over time.

David: Drew, we made the comment in the paper that even attempts to simplify some of these safety work activities are likely to result in the generalization idea that we set above rather than a genuine improvement in the effectiveness of this safety work. 

An example I gave is I know of a company that realized they had seven work permit processes—a permit for confined space, a permit for hot work, a permit for working at heights, and a permit for electrical work. I said, actually we have seven different permits, seven different permit forms, and seven different permit procedures. I said, let's just write one permit procedure and have one permit form for these seven activities. 

They wrote one procedure that was seven times the length by the time they included everything that needed to be in there. Then they had one form, which was seven times as long because depending on what the activity was, the person had to go to the right section of the form. What they actually found through that process was actually they made the ministry of work much harder and made the identification and the discussion around the hazards much harder because they had a form they didn't do and a process that didn't actually do one of those seven things well. It actually did nothing well. They ended up reverting back to the work that [...].

Go back to the seven processes and look at the effectiveness of each one of those seven processes. Don't just think that bringing them all together into one standardized approach is actually decluttering.

Drew: I'll give you another example, David, which I think also illustrates just how hard this is. You know how Sid likes to talk about nonsense safety sometimes in his talks. One of the things he complains about is people wearing hard hats in car parks. Universal site rules that wherever you are on-site, whenever you're on-site, you have to be wearing a hard hat. It seems ridiculous, seems over-generalized. 

After he'd given one of these talks someone sent an email and said, okay, we agree. It’s ridiculous. Can you send us a two-pager on why it should be risk-based where we wear the hard hats? Can you just give us some evidence we can show to our management and we'll get rid of these stupid rule?

Sid, as he tends to do, sent it along to me and said, Drew, can you write a two-pager to give them the evidence? I sat and thought about it, I looked up all the evidence for hard hats, and obviously hard hats do actually work to prevent some injuries and reduce the size of others. But then I thought about how you would cross a rule as to only having to wear a hard hat someplace on-site? 

It became obvious that you would have to have a risk assessment as to where you could and couldn't wear the hard hat. If we switch from these over-generalized ridiculous wear the hard hats in car parks, we'd end up replacing it with an equally ridiculous, risk assessment to decide whether you should or shouldn't be wearing a hard hat.

We just end up transferring one type of overgeneralization to another type of bureaucratic clutter having to do the risk assessments instead. Obviously, we’d love to say, just be sensible. Wear the hard hat where there's likely something that falls in your head. But companies don't like relinquishing that level of control and that need for some sort of control over the situation means either the rule is blanket or there's a risk assessment. They're never going to say, workers, use your own judgment.

David: I think that's why when we next talk about worrying about safety clutter and what are the effects, and we’ll talk about it soon. We need to worry about when our safety activities might actually be having a negative effect on safety, which we’ll talk about that irony soon. If they’ve got a neutral effect, which is someone wearing hard hats in a car park doesn't actually create any problem, then maybe that just actually makes life easier elsewhere and avoids clutter somewhere else. 

You might still want to go with that. I think what we’d be saying to organizations is in your company, you'll find things that should be addressed. We'll talk about why they should be addressed soon. But I think some of those things are really actually hard to think about what the best course of action is.

Drew: Talking about things that we are going to talk about soon, David, I think this might end up having to be our first two-parter episode because we've still got stuff to talk about the causes of safety clutter before we even start to get on to the effects and what we can do about it.

David: I think we can do that, Drew. I'm confident.

Drew: You're confident we can get through it?

David: Yeah, I'm confident. Let me talk about the causes and then it's nice to talk about worrying about safety clutter. I think we can go quite quickly because as authors, anyone who wants to read the paper can just contact us so we can send copies. I actually don’t know how intellectual property works with journals that no longer exist, Drew. We’ll see. The publisher still exists though. 

Underlying causes of these asymmetries. We know that organizations need to respond to incidents, which creates a lot of pressure to introduce new safety activities. We know that we need to demonstrate safety to others—to clients, to communities, and to regulators—so that creates a lot of safety activity.

We know that we've had this separation of the safety professional role and organizations have expected their safety teams to introduce safety work activities at scale in their organization. We know that goal-based regulatory regimes—like those that exist in the most commonwealth countries—have put the burden on organizations to decide how much safety is enough in their situation. Which has created this conservative approach to just being seen to do lots of activity in the name of safety. 

Drew, do you want to say anything else about those causes? I think they'll make a lot of sense to most of our listeners.

Drew: Just to sum up the causes by saying think about the activities that you do in each of those spaces. Every time you do an investigation, it's always going to have recommendations. Those recommendations are almost never, this accident was caused because we were doing too much safety stuff. Our recommendation is just that we ease back a little bit and give people a bit more freedom. It doesn't happen. Our recommendations are always going to be either adding something new or adding some new line or text to something that already exists.

Every time we do an audit or have to do a prequalification, that never comes back and says, we've ticked all of the items in the audit, but there are too many ticks here. In order to pass the audit, you got to have fewer forms—simplify your systems. Never does a pre-qual say, we'd love you to work for us, but you're doing too much safety. Do a bit less and then you can come and work for us. We never have safety professionals who say, I could have a better effect on this organization if I sit in my office and don't do anything.

I'd love to get out there and do stuff, but that's just going to make extra work for the people, so I’m going to put my feet up. All of these are really well-intentioned things like crate engines for generating recommendations for how to improve safety. By improve, that almost always means adding extra things that we're doing.

David: Drew, let's talk about the effects, and why I want to do this in one episode is I want this to be one place people can go to to get this start to finish perspective on safety clutter. Let’s talk about why we should worry because I mentioned earlier, what's the problem? If a company wants to keep doing all the safety work in the hope that some of it makes a contribution, it's our choice if we want to put resources into all of these safety activities. 

If we want to invest the time and we want to invest the resources, that's our decision. Safety is our number one priority. Let’s just keep doing all of the safety stuff. That might sound like a reasonable argument and it probably would be okay if the worst case of the safety activities was that it was neutral, which means it didn't do anything positive, but it didn't do anything negative.

But the irony, what we started to see in the research that our ideas here were drawn from. is that there may be some ways that safety clutter can make your organization less safe. The irony is you can try—and you can try this line with the stakeholders in your company, and if you’re a safety official try this on with management. Did you know that some of the things that we do in this organization specifically for safety may make our organization less safe?

That's what we want to talk about in this section, which is we need to address safety clutter because ironically, it might be making organizations less safe.

Drew: These are reasons that apply across different theories of safety. This is not just a safety differently, Safety II, or resilience view that says that clutter is bad. It applies under multiple theories that all of these things hold. The first one is to do with ownership, which is a cross-theory thing. Which is that when workers are thinking about safety, if what they are thinking about are activities that they themselves do not think are effective, then that changes their response to all safety. Even things that are effective.

Because we can't ask workers to differentiate and say all this stuff that safety departments are nonsense, except for these three things which I really value that I feel that I've got control over. I feel really listened to about these three things. Having lots of clutter says to workers that we are not interested in their time. We do not value the time or their opinions. We are just expecting them to do things without thinking about them. It damages employee ownership.

David: I was just going to say with that ownership, I think that's a big point. If you've got a high level of safety clutter, I suspect you're likely to have a lower level of engagement of your workforce and even your frontline leaders around safety management. Which is why it'll be like, oh no, here we go. Another safety meeting or another safety program. Here comes a safety person again. They won’t see any value in the stuff that may actually be valuable because of just the overwhelming lack of value in the rest of the things that you're asking them to do.

Drew: We have a specific measurement for this, which is the idea of locus of control. Locus of control is about whether you think that your safety depends on your own actions, on the actions of other powerful people like management and the safety department, or just on fate and the universe whether you're going to get hurt or not. One of our studies showed that as you remove some of the clutter, then workers feel more responsible for their own safety. The extra rules are making them think, safety is just this thing out there. It doesn't have something to do with me.

Unfortunately, we weren't able to replicate that result in some of our latest studies. Not because he doesn't exist, just because of data collection issues. But the general idea of ownership definitely applies across different contexts.

David: Drew, the second here is what are the effects that safety clutter is bad for adaptability? We know that work is infinitely variable as tasks, conditions, and resources change. Safety clutter really limits firstly time because the completion of those safety activities needs time. And also flexibility, which is the extent to which workers can actually adapt their work to deliver safety and operational outcomes. Drew, you tell me your thoughts and then I'll give an example.

Drew: Sure. I was just going to say that I think the biggest example of that that I saw was directly out of your own study, which is just how much time safety practitioners get taken up with nondiscretionary activities like filling out reports and forms and doing risk assessment type work? Just think how much of your own time you would be free to do things that you think are more effective if you didn't have all of these safety activities.

David: I think as work changes, it’s bad for adaptability. An example that I've seen recently was we're involved in a vehicle rollover. It was a speed-related incident vehicle rollover. The organization couldn’t understand why the person sped on this particular road. When we got involved, what we learned about is they actually had a specific rule where you weren’t allowed to drive at night. Australia’s a very big country. We travel long distances.

This one particular crew that has been on shift for two weeks at a remote site, it was the end of their 14 days away and they were driving back into the capital city. It was a 10-hour drive. They're in a convoy. They had some problems with one of the vehicles during the day. It got to the point where they're going to be about 20 minutes short off after two weeks getting back into their own bed at home for that night versus complying with the rule, which meant 20 minutes from time after 12 hours on the road and two weeks away. They were then going to have to stop 20 minutes from home, stay the night, and then drive back that last 20 minutes at dawn.

They were driving considerably over the speed limit on the basis to avoid breaking this rule to be driving at night. When their situation changed, the rules in place just had no capacity for them to adapt their work. You might say, well, that's fine. Safety should come first. They should have stopped 30 minutes from their destination. But let's all maybe walk in the shoes of our people for a moment if that's our view. Drew, do you want to know about that story? I think I've shared that story with you before.

Drew: Not that particular one. But it reminded me of another story. I've actually heard the same story with different facts and different industries, so it's obviously something that happens in more than one place. What happens when the process for getting a permit is onerous or requires too many steps or too many people, or there are too many permits that you need. What we would love to do is for people who need to quickly do a small job to put basic safety precautions in place. But the trouble is that they don't have time to get the permit so they can go through all of those steps.

If they take any safety steps, that's going to alert people that they're doing something for which they should have had a permit. Instead, they go and do the task themselves when no one else can see them and watch them. This is where we have workers coming back to work on the weekend because if they did it during the week, they’d need to get a permit. It's a lone worker down a hole with no one else around just because the permit process was too hard. If you don’t like your workers doing things in the shadows, your workers trying to get the job done need ways of doing it within the system, within the rules. The more rules we have, the harder that is.

David: Yeah. This is the story of night shift for a long time, Drew. The third point here is that it erodes trust. It’s this idea of this constant big brother serving the organization, auditing, observations, backside covering of managers. A lot of the safety activities are literally surveillance activities. What does that do for the nature of the relationship that safety teams and managers have with their workforce and their frontline supervision? Trust is I think really important in psychological safety. Well, it is really important in psychological safety and open communication, and safety clutter erodes that trust.

Drew: Trust is about more than just surveillance. The more rules, procedures, and processes we have, the more you can guarantee that if something goes wrong, someone will be found to have been breaking one of those rules. We’ve literally found cases of duplicated systems where it's impossible to do the work without breaking at least one rule because two different permits required the work to be done in two different orders.

You create those situations, workers know that no matter what, if an accident happens, people are going to go back and find that some rule somewhere has been broken. The more rules there are, the more that's an absolute guarantee that that's going to happen. It means that workers then can't trust management not to blame them, can't trust management to keep them safe in a legal and work sense, rather than just a physical sense.

David: Drew, the last one here is creating a tradeoff between safety and productivity. The time, attention, and expertise to do these safety of work activities conflicts with the time, attention, and expertise that could be directed towards operational work. 

Some of these ideas are if we work out that we’ve actually given people an hour of safety-related work during an eight-hour shift, then have we changed their work to be only seven hours of work instead of eight hours, or have we given them an hour safety work and still giving them an eight-hour workday? What does that do for the remainder of the day? What does that do for the goal conflict for the remainder of the day? 

Drew, one of the other examples of this I've seen is just that the paperwork to actually get work done is so onerous in terms of preparing all those permits and activities. I've seen one example of a supervisor being able to do a toolbox talk in the morning, set the workgroup out into the field to do the activities, then need to spend the whole rest of the day in their office preparing all of the paperwork and all the permits for the following day, and not doing any level of supervision of the work outside of just doing the toolbox talk in the morning and then retreating back into the office. This is this tradeoff between safety and productivity and role performance in your organization.

Drew: David, I don’t know that I've ever personally seen the having to spend the entire day, but I've certainly seen cases where it is routine for supervisors to spend after lunch preparing for the next day. I think that's actually quite common in some industries is supervision in the morning, afternoon doing paperwork to get ready for the next day. That's genuine harm to your organization because those are experienced supervisors who are not supervising in order to do this supposedly harmless paperwork.

David: This situation was a toolbox at let’s say 6:00 AM. Then 7:00 AM was a particular dialing daily meeting across all of the operational areas. Then 8:00 AM was dialing back with the head office of the engineering teams. Then 9:00 AM until about lunchtime was updating all of the various information systems that needed daily updates on the progress of work activities. Then you're right, then after lunch, it was all of the operational control of work processes for the following day, and then repeat every day.

Drew: This is something that we have directly seen also that you can improve because we saw this in the decluttering projects that we did for Logan Water. The biggest change was, for reasons that I won't go into, the safety activities were costing the team half an hour every day. Mostly due to where they had to be in order to do the induction, the toolbox talk at the start of the day. That extra half hour meant that the moment we changed that, the number of instances of people visibly rushing decreased. Every single task that was done just had that little bit of extra time that people could take to do it safer.

If you think of every accident that mentions people were rushing, people were cutting corners, it makes people safer when you give them an extra 10 minutes to do the task. That's 10 minutes that we’re taking away sometimes by our safety activities.

David: Drew, conveniently because it's our writing style in papers, but also the structure of the podcast. The final section of the paper was titled, Dealing with Safety Clutter, What Can We Do About It? We do a practical takeaway section in every one of these podcasts. We’re going to talk about the final section of the paper and add a few extra thoughts into our practical takeaways. Do you want to kick us off with how we might start thinking about what we do about everything we spoke about in relation to safety clutter?

Drew: Okay. The general principle of all of these suggestions is that clutter exists for reasons. You can't fix clutter just by identifying clutter and trying to take it away. You have to address it by thinking about the reasons that cause it to be there and by relieving those pressures that create the clutter. 

The first idea is to create an evidence-based mindset in your organization. This is letting people have open conversations about questioning the point of safety activities. This is trying to address the idea that they’re not opportunities to remove safety activities. If we can have conversations, then we can have open discussions about where we don't like safety. That is creating extra opportunities to remove things that don't work in order to make more room for the things that do work.

David: Drew, this is so valuable and so wholly done in businesses. I know so many organizations where it is so socially unacceptable for anyone to question anything about safety. If you were to walk along as a manager and say, you know what, this risk assessment process that my team needs today for every job adds no value. I think many organizations would consider that leader to not be taking safety seriously enough. 

For a worker to come back and tell a safety officer or a senior manager that, we never do these forms. We just fill them out on a Monday for the whole week, put them in our pocket, and add the date every day. Organizations just don’t have those open conversations about their safety practices.

Drew: David, this is I think is probably the single thing that I'm proudest about in my career as a safety professional so far. The deliberate choice of the word clutter because what that does is it creates an acceptable word that people can use in conversations to complain about safety. I think it has been shown that that does in fact work. That it's easier to have a conversation about clutter than it is to have a conversation complaining about things like safety bureaucracy or too much safety. 

Not everyone reacts positively to it. There are some people who will get extremely agitated at the idea of trying to reduce safety clutter, but it does seem to let people speak up a little bit more.

David: Yeah, Drew, and I think if you are a leader or a safety professional listening to this and think you might want to explore this in your organization. If you can talk to people who participate in safety practices and activities, anything that you do in the name of safety in your business—safety training programs, safety audit, safety investigations, safety risk assessments. If you can get an honest perspective about the value, the contribution going back to those original three C’s, the contribution that that activity is making to safety, and have an open conversation then you're a long way toward starting to understand a deal with the causes of clutter in your business.

Drew: The second contribution, I think, originally actually comes from an author who's not credited in these papers—our field researcher, Jop Havinga. This is the idea that clutter isn't just about removing things. A lot of these activities had an original purpose. If we can identify what that original purpose either was or could be, then we can redesign based on the purpose. You can almost triage activities. 

There are activities that are never going to help, activities that definitely currently help, and activities that plausibly could help but aren't working at the moment. A lot of working with clutter is about finding that third category thinking about, what were we trying to achieve when we first put this in? Why isn't it achieving it? Can we make a change that will in fact achieve that purpose?

David: I think the third one here is to have a go at removing something. We said it's going to be challenging because there are no planned opportunities in your business to remove things like there is to add things. You'll run up against some interesting organizational and social challenges when you try to do this, but you will know in your mind now something that you know is of little value and could be of little value and have a go. I think that's the advice that we gave this paper.

Find a low-hanging piece of fruit, rally some support from some stakeholders for doing something about it. Remove it, show your organization the improved engagement and trust that comes when you're actually doing something to remove something that doesn't add value. And use that to create some momentum to keep taking bigger steps in the rest of your safety activities.

Drew: David, this is just like teaching your kids to clean up their room. The room is an absolute mess, it's overwhelming. You're never going to get it tidy. What you do is you pick up the first thing in front of you on the floor. You see what you can do about finding a home for it and put it away. Once you've done that, you do the next thing, and your success drives success, gets you to keep going, and before you know it, the room is a lot tidier.

David: You can do this yourself quite quickly. Think of an activity where you've got some assumptions that might be not adding the value that you want. Have a think about what value you think it's intended to do. Go and talk to the people involved in the activity. Get some data. Get some feedback about what they think, and then figure out what you’re going to do next. Do you remove it, do you redesign it, or do you reinforce what's already there together with the people involved? I think we need to just take action.

Drew: My favorite pet strategy for people who feel that they don't have a lot of authority—find something that's taking up your own time, just stop doing it, and wait and see what happens. Just wait and see if anyone ever actually makes you do it.

David: All right, Drew, now that a lot of management teams are not getting their safety reports anymore, we’ll go onto number four. Reversing this burden of proof, I think you conceptualized this one in that, we don't really need to prove that what we’re going to put into an organization works for safety could just be any old idea that we can come up with, that we've seen in another business, or that we think might do something.

But when we try to take something away because of some of these moral and perceived aspects, to prove that we should stop doing something. Okay, we’re now not going to do a toolbox talk every day. To try to remove something or to try to significantly change something like that requires so much time and organizational effort and proof to try to get it done. 

One piece of advice is to have the same level of proof requirement when you’re putting a new thing into your business. This is this idea to fix clutter, we've also got to stop the bucket from being filled up again every time. We want to stop things going into the bucket as well as try to empty the bucket a little bit as well. 

If you can have an approach in your organization where every time there's an incident recommendation, an audit recommendation, a safety plan, or a committee action, actually having a burden of proof on the initiator of that action demonstrating the contribution, the confidence, and the consensus that that activity is going to add value or it's not going to get done would be a great starting point to not make the problem any worse.

Drew: David, I think we need to really strategically pick our battles here because there is sometimes this fight I think is easier than others. If you've got a workplace health and safety inspector who is giving you an improvement notice, that's a hard time to push back and say, where is the evidence that this is going to help? Where you need to pass an FSC audit and the auditor is stinging you for not having a document. Trying to ask them for proof that you need that document other than because the audit says so is going to be hard.

But our internal investigation reports, I think, are the spot where this should be easy. We look at the recommendations and we just push back and say, where is the evidence that implementing this recommendation is going to do positive good for safety in our organization rather than harm by adding clutter? Because those are things we voluntarily take on ourselves when we accept recommendations.

Audits, improvement notices—those are not voluntary. Those are sometimes pushed on us. We can look for all those times when we voluntarily add stuff ourselves and be strict about enforcing where is the evidence that this is worth doing?

David: I agree. I mean, you don't need to show any of your workers those actions that you do for regulators and the FSC. But definitely incident investigations, we’ve recorded a couple of episodes about incident investigations getting to root causes and how to learn from incidents. I think listeners who want to do something with their investigation process, specifically around not introducing safety clutter, those episodes might help as well.

Drew: Yes. Naming no names, I want to see the evidence that the onion is less likely to fall off your sausage on a roll if it's under the sausage instead of on top of the sausage. Where are the experiments showing that that is actually going to make it safer?

David: Great. That’s an Australian media example for some of our local listeners. The last one is close to my own heart about redefining the role of safety professionals. Organizations—together with their safety professionals—creating an expectation that is not the role of safety professionals to introduce safety work activities in their organization. It’s the role of safety professionals to support and understand the way that work happens, and find ways to actually have an impact on that work as done in a way that is more likely to create safety as an outcome.

Any safety of work activities that do get introduced is directly connected to the reality of work and has a meaningful impact on that work.

Drew: Absolutely. If our job is helping other people do the work that we have imposed on them in the first place, we are not being helpful. Our job should be making other people's work genuinely easier and safer.

David: Okay, Drew. We got there a few minutes late. The question that we asked this week was safety clutter. We gave a big definition at the start, but I’d have to go with a practical definition. I'm going to roll that out and see what you think of it if that's okay.

Drew: It’s got swearing in it, so I think it's up to you to say it, David.

David: No, it doesn't. It doesn't have swearing in it. I'm not going to get one of these little E’s next to our podcast because then no one can actually download it on company systems because your IT departments got rid of all of them. I'm very careful about that every week. But a practical definition of safety clutter would be, it's all that safety (expletive) that adds neutral or negative safety value to frontline work.

Drew: I love that as a definition, David. I think it's a little bit late, but that's it for this week. We hope you found the episode thought-provoking and ultimately useful in shaping the safety of work or maybe the reduction of the work of safety in your own organization. As always, send any questions, comments, or ideas for future episodes to