Our discussion today centers around a 2017 Journal of the Australian Petroleum Production & Exploration Association (APPEA) paper, Golden safety rules: are they keeping us safe? by Samantha J. Fraser and Daryl Colgan. Although the paper was published in a trade journal and not an academic one, the research is solid, even though they could have made it semi-structured and somewhat open-ended to find out even more from the interviewees.
We will discuss the pros and cons of “Golden Safety Rules” and a punitive safety culture vs. a critical risk management approach, and analyze the limitations of the methods used in this research.
The paper’s abstract introduction reads:
Golden safety rules (GSR) have been in existence for decades across multiple industry sectors – championed by oil and gas – and there is a belief that they have been effective in keeping workers safe. As safety programs advance in the oil and gas sector, can we be sure that GSR have a continued role? ERM surveyed companies across mining, power, rail, construction, manufacturing, chemicals and oil and gas, to examine the latest thinking about GSR challenges and successes. As we embarked on the survey, the level of interest was palpable; from power to mining it was apparent that companies were in the process of reviewing and overhauling their use of GSR. The paper will present key insights from the survey around the questions we postulated. Are GSR associated with a punitive safety culture, and have they outlived their usefulness as company safety cultures mature? Is the role of GSR being displaced as critical control management reaches new pinnacles? Do we comply with our GSR, and how do we know? Do our GSR continue to address the major hazards that our personnel are most at risk from? How do we apply our GSR with contractors, and to what extent do our contractors benefit from that? The paper concludes with some observations of how developments outside of the oil and gas sector provide meaningful considerations for the content and application of GSR for oil and gas companies.
Discussion Points:
Quotes:
“People tend to think of rules as constraining. They’re like laws that you stick within that you don’t step outside of.” Dr. Drew
“Often the type of things that are published in trade associations are much closer to the real-world concerns of people at work, and a lot of people working for consultancies are very academically-minded.” - Dr. Drew
“One way to get a name in safety is to be good at safety, another way to get a name in safety is to tell everyone how good you are at safety.” Dr. Drew
“They’re not just talking to people who love Golden Rules [in this paper]. We’ve got some companies that never even wanted them, some companies that tried them and don’t like them, some companies that love them. So that’s a fantastic sample when it comes to, ‘do we have a diverse range of opinions.’” - Dr. Drew
“In many organizations that have done life-saving rules, they saw this critical risk management framework as an evolution, an improvement, in what they’re doing.” Dr. David
“I think that’s the danger of trying to make things too simple is it becomes either too generic or too vague, or just not applicable to so many circumstances.” Dr. Drew
Resources:
Link to the Golden Safety Rules Paper by Fraser and Colgan
The Safety of Work on LinkedIn
Drew: You are listening to the Safety of Work podcast, episode 93. Do the benefits of life-saving rules outweigh the negative consequences? Let's get started.
Hey, everybody. My name is Drew Rae. I'm here with David Provan, and we're from the Safety Science Innovation Lab at Griffith University in Australia. Welcome to the Safety of Work podcast. In each episode, we ask an important question in relation to the safety of work or the work of safety and we have a look at the evidence surrounding it. David, would you like to tell us a bit about today's question?
David: Today's question is actually one that we've been asked almost right from the start if we do a podcast on life-saving rules. I've had a couple of go at trying to find some decent research and there really isn't a whole lot around. We'll talk about that on the way through.
But Ben Hutchinson, who many of our listeners would know does a great job summarizing research on LinkedIn and his own webpage, posted this paper this week. I kind of thought, well, it's probably as good an opportunity as ever to make sure that we get a life-saving rules episode inside the first hundred episodes, so that's what we're going to do today.
Right back in episode two, we asked the question why don't people follow the rules? It's been a while before we talked sort of directly about rules, compliance, and safety. Do you want to give us your initial thoughts on this topic? Surely you think about it a little bit.
Drew: Growing up in system safety, the idea of life-saving rules, or golden rules, or even sometimes literally called 10 commandments, didn't crop up so much. We don't have those rules around the engineering of safety, so for most of my career, I've really just considered it one of these weird things that health and safety sometimes do. It's sort of like mild curiosity.
I really ran head smack into them when I was doing some consulting for a major mining company that had directly asked us to come in and design some courses for them around the new view of safety. We were simultaneously delivering these courses to management about new ways of looking at investigations, understanding work, and understanding why things go wrong other than through the sort of lens of human error.
Right in the middle of this, the company launched a new sort of 10 Golden Rules Program where the CEO just laid down the law and said here are 10 rules, and thou shalt not, no matter what else we're doing in safety, break one of these rules, and you're out. It was bizarre because the safety team knew that some of those rules were things that could not be followed, that were being routinely broken in a company that was trying to understand why people do what they do at work, and yet it made sense to management to have this lay down the law and do not admit to us that you do not follow these 10 things.
David: I think many of our listeners, I suppose, are sort of nodding along, and I'm sure many of our listeners were nodding along with that as well. You mentioned some companies do this. Look, these are very popular safety rules, call them golden rules, cardinal rules, life-saving rules, lifesavers. I haven't actually heard them called the 10 commandments, but maybe in some places, they are.
There's not a lot of research. What it is there is a lot of pontification from within the safety science community and within the practitioner community, on the role in the usefulness of safety rules. We might try and break that down, but I did try and find a bit more research on this, and like I said, most of the studies are case studies, and most of the studies tied to incident rates, and none that I really want to talk about, except for one survey that was done back in the early 2000s with 500 frontline workers across 33 mine sites just asking about the rules, the value, following them and so on.
Basically, one third of these 500 people said we regularly don't follow the rules and our managers support us not to follow them. The reasons are the rules lack application to the real world, they're too complex, there are too many of them, they're too rigid, the workforce aren't involved in the development of these rules.
Basically, the conclusion of that research, which is over 15 minutes ago, was that management and regulators should not continue to just keep producing more rules. Yet, that's really what's happened since that research was done in the early 2000s that we'll talk about today. There is some other research around, do you want to give us your thoughts?
Drew: I'll talk about the specific research in a moment, but I thought it was worth pointing out that I think one of the motivations for having the idea of golden rules or 10 rules, originally comes from rule simplification. Your first response when you think oh, my company's got too many rules is boil it down to just those ones that are absolutely essential and get rid of all of the complexity. Let's put in these ones that at the very least we can all agree on they're all going to be hard and fast.
I think that also feeds in when organizations are trying to move towards notions of organizational justice in their investigations. They think it's important to draw these bright lines and say, it's not fair to punish people if the expectations are not clear so let's make the expectations really, really clear.
There are other rules that might be negotiable, other rules that aren't clear, but these 10, we've kept them simple, we've made them clear, we've told you what the consequences are. If you break them, you can't complain that we're punishing you for something that we made absolutely clear.
That sort of rests on a notion of rules that I think is contested a lot in the academic literature. To that, a work worth pulling out, one of them is some work by Andrew Hale, Working to rule or working safely? If I recall correctly, that's actually published in a volume called Trapping Safety into Rules, which is an entire volume of essays about the different roles that rules play in safety. It's one of those ones that I think should be on any practitioner's shelf, even though it's an academic book, just every chapter is just a different way of thinking about how rules fit into your organization.
David: It was also published as a two-part paper series (I think) in Safety Science as well. It really has a good discussion around rules, not so much as what to do, but just all of the considerations around what can be managed through rules, what can't be managed through rules, how rules should be developed and designed? What are the different types of rules? What's the intention and the outcome behind those different rules? Nothing about just culture, nothing about the implications of it, but just essentially a really big open discussion about how rules may or may not be applicable in different situations.
Drew: Just to give a flavor of the types of discussion people have around rules, one of our colleagues, Guido Carim, was looking at rules when it comes to in-flight emergencies. One of the things that he showed through his work is that even when we write things down as very strict procedures, that's not how people think about rules or how they use rules.
Often, when we give people instructions, those instructions for more of a resource, Guido calls it the resource for action rather than constraints on action. That's sort of the general debate about what is a rule People tend to think of rules as constraining. They're like laws that you stick within that you don't step outside of. As we'll see in this paper today, most golden rules aren't written like that. They're not rules about what you shouldn't do so they don't set clear boundaries.
The other way of thinking about rules is that they're guidelines for action. They're things that you draw on. They tell you how to do things. They give you capacity. They give you ways of doing things. But those two different sets of rules give very different notions of what it means when someone doesn't follow the rule. Is it that they're simply not choosing to use a resource that's not helpful in this particular situation? Or are they actively breaking something that they weren't supposed to break? It depends on how you see the rule in the first place.
David: I like Guido's paper title, I think from memory it was Using a procedure doesn't mean following it. I think that the idea about rules is, are they a resource fraction? Or are they something that is a constraint on work? Or both. We wrote a chapter of the Australian Institute of Health and Safety body of knowledge titled Rules and Procedures for Safety a couple of years ago and did a sort of big scan of this literature.
I think one of the interesting things in there is where rules become very empowering for people because they sort of set margins for safety. They empower people to act, to stop their work, and adjust their work because that safety margin has been made very clear. I don't think we're here today to say you shouldn't have safety rules in your organization. We're here to have a broad discussion around how might they help and how might they hinder your overall safety objectives.
Drew: I think for golden rules, in particular, the question isn't so much around the fundamental purpose of rules. The question is, is it possible and reasonable to distill rules down into a small set of things that have a sort of special status because even though other rules might be negotiable, can you decide that some rules are not? That some procedures are there to help. We accept that sometimes there might be valid reasons to break rules or at least valid reasons to not follow rules and to adapt the rules to match the way work is done.
Is it both true and useful that there are some situations you can just say regardless of context, this is so obvious, so universal, so absolute, that it should always apply and that it is a good way to protect the workforce by setting that up as a perimeter fence around people's behavior?
David: Even things that may seem always entirely fit into that category like (say) wearing your seatbelt while you're driving a car. In some workplaces, in some situations, you'll find the messy realities of work can conspire against even the seemingly most black and white workplaces rule.
I thought about the experience that I had in my career when the company I was working with had sort of a really deteriorating safety performance. Again, managers in their company thought we need to put in place more rules. We ran a project for a week where we sent leaders and safety people into the field to engage with workers. I think we hit about 70 sites in a week, all over the business, and just with a couple of key questions about what do you think works well for safety? What do you think's not working well? What could the organization do to help your site be safer?
We visited 70 sites, engaged with hundreds and hundreds of workers, and not one person said can we please have more rules? It's kind of interesting, the things that they asked for were things about communication, resources, equipment, workforce capability, and a whole bunch of stuff that in their mind would make their workplaces safer. I guess I just reflect on that a lot at the frontline. There was no one asking for more rules or to be more disciplined around the rules that we had.
Drew: That is fascinating because workers will often sometimes impose these expectations on other workers that they won't on themselves. It's fascinating that they don't see rules in that category even to control other people. We ought to have more rules about this.
David: Yes, good point.
Drew: Before we dive into the paper, just to illustrate where we're going, I really would like to hear a little bit more about the seat belt story because I think this is one of those things that is behind the rationale for having golden rules is that often we can't conceive of a context where that would be okay. Ever since you said that I've been sort of sitting struggling through it, I'm thinking although seatbelts are universal, surely there is no context where that shouldn't be a universal rule.
David: I think it comes to how to make work easy and goal conflict around work. As I've been involved in a couple of scenarios and one is in very rural and remote outback locations where you're driving through farmland to access remote oil and gas wells and rigs. Through the course of a two-kilometer trip, you might have to go through 15 or 20 farm gates, get out of your vehicle, open the farm gate, back in your vehicle, drive 100 meters at a speed restricted limit of 10 kilometers an hour. That journey takes maybe twice as long. Putting your seatbelt on often means you do that all day every day.
The question becomes after you turn off that public road, is it okay for that driver to make their work easier and more effective to have a situation where they don't have to wear their seatbelt for that period of time? Or if you take an absolute safety point of view and it doesn't make sense to put alarms in place on seat belts. Then if people don't wear their seatbelt and they're moving more than three kilometers an hour, they get a written warning from the company? Or do you then have people connecting the seatbelt behind their back and just jumping in and out of the car anyway?
This idea of how you work with your people about the realities of how work happens, what the risks are trying to control this, and what other operational goals they have. I've had the same situation with forklift operations as well. Companies putting seat belts under forklifts and still expecting the same pick rate for manual picking activities. I think that's sort of some of the scenarios that were in my head when I was thinking about once you get into the messy details of work, even seemingly very clear things can become pretty messy pretty quick. Does that answer that sort of question at all? Or have I traded off safety?
Drew: It has me honestly conflicted because I'm hearing that story and I'm still thinking, okay, but the safest thing is still to wear the seatbelt. I would say the extent you've got me convinced is not that this is a rule that wouldn't be desirable, but it's definitely stopped being one of my top 10 things that the company that I think are so inviolable and so important that it should hold a special status. I guess, you've at least convinced me that the rule shouldn't have that high status but almost still wanted to be a rule, just accepting that sometimes people break it.
David: I just kind of think something like that doesn't need any organizational effort or attention. Maybe the forklift is a bit different, but it should drive different types of conversation. If we've got manual picking activities in and out of forklifts and pedestrian pockets, why don't we invest in different pick and pack arrangements? Why don't we actually redesign the work to make it easy for people?
I always try to put myself in a position where I would want to be doing that 15 or 20 times and still be expected to do the same amount? I think when work gets hard, we just create a divide between management and the safety professionals in the workforce because we're just [...].
Drew: That part of it, I definitely agree that I think the imposition of the rule has stopped that conversation from happening. Once the rule is there, no one can admit that they do drive without the seatbelt, so they can't even tell you about this circumstance where they have to open the gate every 50 meters.
David: Another example I had Drew was reversing trucks. The alarms would go off if the truck, delivery type trucks, and the alarm would go off and the person would get penalized if they went forward or backward more than two or three kilometers an hour without a seatbelt on. Yet in reversing trucks that people said to us, actually they need to twist their whole body around to have good vision and visibility backward. They take their seatbelt off while reversing.
I actually think from a legal perspective, you're allowed to do that. In the law, you're allowed to reverse with your seatbelt off to twist your whole body around and get good vision. The rule was actually making them reverse heavy vehicles in places like schools and workplaces in a less safe way to comply with the seatbelt rule while reversing, which was different to everything they've done in their whole career.
Drew: I like that example, because it's unquestionably actually a safety trade-off. One of the ones I was thinking of was I guess I'm at risk of identifying the company, but I guess if they feel identified, then they deserve it. Talking of big trucks, we're talking about genuinely big trucks now. The company had a couple of incidents where mining trucks had gone over the top of utes just like Monster Truck style just drove straight over the top and crushed it beneath.
One of their golden rules was that you shouldn't be allowed to park light vehicles within the operating area where they operate the mining trucks. Basically, light vehicles could be driven down into the pit, but they couldn't ever be parked except in very specially designated areas. What confused me is they implemented this rule without first checking how often are vehicles parked.
Why not just send up drones, and pretend the rule exists, and just check all of the places where the rule is currently being violated and find out why because there might be very good reasons why that rule is currently not universal. It turned out that a parked ute is your only air-conditioned office in a lot of circumstances.
The reason why the utes were getting parked up is the supervisors needed some way to do the paperwork so they'd park it out of the way and do the paperwork. You make it suddenly as a cast-iron rule, you've now got a direct conflict between the safety rule that says you got to complete the risk assessment or you got to complete the deck five and the rule about parking up the ute. You have to choose between one or the other.
David: Yeah. The paperwork is done in the office instead of at the work front, I had in my mind when you said that. A light vehicle is hard enough to see, but if someone's parking somewhere else and they're walking across an operational area. We've had a pretty long conversation about seat belts in driving, but I guess this is the complexity of rules and how they actually hit the work fronts, and the workers, and create unintended consequences. Drew, do you want to introduce the paper now?
Drew: Okay. The paper is called Golden safety rules: are they keeping us safe? The authors of this paper are safety consultants, Samantha Fraser and Daryl Colgan. Because they're consultants, I don't have a lot of background info on the authors.
The paper was published in a thing called the Australian Petroleum Production and Exploration Association (APPEA) Journal. Essentially, this is a trade publication, not an academic journal. That doesn't necessarily say bad things about what's published in it. Often, the type of things that are published in trade associations are much closer to the real world concerns of people at work.
A lot of people working for consultancies are very academically-minded. One way to think of consultancy is it is commercially paid-for research rather than research, which is conducted within the university zone, where there's a lot of government subsidy. It tends to be less academically rigorous, but that doesn't necessarily make it less rigorous in a practical sense. And it tends to be far more focused on direct practical questions.
The downside is consultants almost always have their own products, their own ax to grind. I don't think that applies in this particular case. I, honestly from the paper, couldn't tell whether the authors were pro or anti golden safety rules. They seem to be fairly straightforwardly representing what they'd been told by their participants without putting any sort of spin on it.
The participants definitely had spin. I think the authors are just in a very balanced job of reporting what they were told. Any bias would be in exactly how they've structured the questions. Unfortunately, the questions that they asked aren't included in the publication.
David: This was, like you mentioned, published by APPEA, the Australian Oil and Gas Industry Association, if you like, and probably would have been presented at a conference .The research was done in about 2015–2016.
Life-saving rules were very, very topical. It started in Shell in the early 2000s. You come across the industry and then the big publication, I think, went out in 2013, where IAOGP (the International Association of Oil and Gas Producers companies) made up about 60 of the largest oil and gas majors. They had analyzed 332 fatalities between 2005 and 2008 and then spent a couple of years working through these fatalities.
They concluded that 83% of them were related to human factors to do with occupational safety–related human factors. Only 16% of these fatalities were process safety–related. They were seeing all these rule based errors, where it wasn't skill-based errors that workers didn't know how to do work, but there are rule-based errors. People were doing things that they shouldn't have been doing.
The industry published these rules that are very widely adopted. I guess we started seeing case studies come out. There's a paper that's cited in this one, again, to do with Shell saying that they've had a 75% reduction in fatalities since they implemented the rules and was attributing that 75% reduction to the life-saving rules.
I was in the oil and gas industry at the time. I was actually on the IAOGP safety committee just after this publication was released. Everything in the industry at the time to do with safety was centered around these life-saving rules. That was really the only discussion that was happening.
Drew: I was fairly careful about saying that I thought the consultants who wrote this particular paper we're talking about took a fairly neutral stand. When it comes to companies reporting on their own safety record and giving attribution for it, I don't think we need to be that charitable.
When a company tells you by the people who implemented the program, hey, we put in place this program and it is responsible for this drastic reduction in injuries, then I think we need to take a very skeptical look at both how they determined that reduction and how they determined the attribution. I think that a lot of the reasons why life-saving rules were being plugged so hard was to do with companies that were trying to show themselves as good at safety through some of this very non-reflective self-aggrandizement of their safety programs.
One way to get a name in safety is to be good at safety. Another way to get a name in safety is to tell everyone how good you are at safety. Some companies take the first strategy and some companies take the second strategy.
David: When it comes to safety, I think with all these safety practices, there's so much going on. In our Safety of Work, why do we talk about demonstrated safety in these need for organizations to feel safe and tell everyone else that they're safe? It's the nature of the stakeholders that organizations have.
What Erik Hollnagel said, and we've probably mentioned this on the podcast before, organizations need to feel safe and be safe. The shame is when the former gets in the way of the latter or the former takes all of the organization's attention. I guess that's what we have in these types of situations where people claim victory over safety and let a simple lie be believed rather than trying to understand the complex truth.
Drew: Yup. I think we can distinguish between the companies that implemented it and the overall goal of life-saving rules. We're going to see through this paper some direct association of life-saving rules with some particular strands of safety thought, but I don't think they have to be. I think there is almost like a new view argument in favor of things at life-saving rules as a simplification and as a way of dealing with clutter.
I think it's an open question whether it's effective or not in doing that, and something that is worth better investigation than we have at the moment. I guess what I'm doing is teeing up in advance, so I'm going to be fairly critical throughout this paper. That's one particular line of thought supporting life-saving rules. The idea itself just hasn't been properly investigated enough to draw firm conclusions.
David: I'll let you play that role and I'll make sure that everyone's got your email address to send any about it. There's the main lines of inquiry and some of these lines of inquiry are, I think, pregnant with their own answer. There are a few lines here.
The question is, are life-saving rules associated with punitive safety cultures? Have life-saving rules outlived their usefulness? Has the role of life-saving rules been replaced by more maturing operational risk management programs? Do we actually comply with the life-saving rules within our companies and how do we know? Do life-saving rules continue to address our major hazards? How do we apply life-saving rules to our contractors?
I guess the people involved in this research would have been hearing all of these things across industry and packaged all these things up into some interview questions. From a method point of view, there were 15 companies involved. They came across the mining, power, rail, manufacturing, chemical, and oil and gas industries. I guess this is where we start to get really narrow, really fast.
There was a one-hour interview conducted with one representative of each of those 15 companies. The participants were either a senior health and safety professional or one of the operations managers. What we're going to talk about is just one person from each of 15 companies in a management position asking about their company's experience of life-saving rules.
Drew: I actually don't have a problem with that as a methodology. Fifteen interviews is quite a large amount of data. Depending on the questions you're asking, if you want to find out the story of life-saving rules in a company, then finding someone who's relatively senior in safety who's been around for a while in the company to tell you that story (I think) is actually a reasonable way of doing it.
Where we fall into the problem of non-academic researchers is they thought they were doing a good thing by holding the set of questions consistent. That's what you call a structured interview. With this inquiry, we would always do what we call a semi-structured interview, which allows the researchers to give the participants a bit more freedom to tell the story.
The more you stick to a very consistent set of questions, the more you can't ask follow-ups or get people to expand or follow down the interesting details that get revealed through the study because you're being careful about always asking the exact same questions in the exact same way. The study doesn't fulfill its potential, but I don't think that this is a bad method for the types of questions that they're trying to address. I just wish they'd given themselves the opportunity to hear more.
David: Let me throw some numbers so we know what's going on in these companies we're talking to. Five of the 15 companies had a consistent set of life-saving rules that applied to all of their site operations everywhere. I might say, I think, 14 of the 15 companies had operations in multiple countries.
Four of the companies had designed local sets of rules. They had a rule framework but different rules at different sites. Six companies had either never had this idea of life-saving rules or previously had them and had removed them.
I guess in those companies, there are 10 or so companies that had rules or had them and removed them. Five of them said that they were critical to their improvements in safety measured by their lagging indicators, and five companies who said they were moving away because they evaluated their potential benefit and decided not to implement them.
All of a sudden, right off the bat, we've got 50% of companies with rules saying they're absolutely watch-driven all about improvement and 50% of companies going unhelpful, moving away.
Drew: It's hilarious that the authors think that these numbers matter. In the paper, they've even got little pie charts about what percentage of people said what. With a sample like this, you just can't draw any quantitative conclusions. You want to sample the oil and gas industry in Australia, you have to properly sample the oil and gas industry in Australia, not just pick out 15 companies.
What this does tell us is that they've got a fair sample when it comes to the diversity of opinions. They're not just talking to people who love golden rules. We've got some companies that never even wanted them, some companies that tried them and don't like them, and some companies that love them. That's a fantastic sample when it comes to, do we have a diverse range of opinions here.
That just explores how people are thinking about things. That's all it can tell us, though. Fifty percent is meaningless because we could have picked a different set of companies and had 100% or 0%.
David: I think that flows through, too. Again, the same thread goes through even some of the other lines of inquiry. It's the same group that likes them that say they continue to be relevant. It's the same group that doesn't like them that says they're not as relevant.
One of the things that this paper had put together is 15 success factors that came out of these interview questions. And like you said, we don't have the interview questions, but we do have these 15 factors that (I guess) the researchers had themed up from the discussions as being useful for implementation. I don't know if we want to run through these or have a quick chat about the categories that they fall into.
Drew: I definitely think we should talk about some because some of them are really revealing about golden rules. The ones that are most interesting are when the companies that are keeping the rules and love them and the companies that are abandoning the rules say exactly the same thing about the rules, they just reached different conclusions. Because I think that gives a very fair impression that this is universally true.
I thought the first one that was worth drawing out was the idea of a particular view of just culture and consequences. The companies that like golden rules—these are companies in favor of golden rules—say that for success, it's really important to set strict boundaries around the rules and to have clear consequences if people break them. In fact, if there are no consequences for breaking the rules, that undermines the rules. It stops them having the value that they have.
Typically, this is associated with a model of just culture that is very deterministic. It's the one that says that a just culture is one which has clear expectations, consistent, and predictable consequences if you don't meet those expectations.
The companies that are abandoning the rules say exactly the same thing. They say we're moving away from rules because we think that we've moved beyond that sort of culture of strict compliance, that we want to have systems of assessing accidents that have a less deterministic rule framework, that have more nuance around it, and have more sensitivity.
I'm not using the exact words they use here. I'm inserting my own interpretation over what they said, but more of sensitivity to operations, sensitivity to what's actually going on with the workers.
The important thing there is they both agree that the golden rules are very closely aligned to that very strict consequence deterministic punitive management of safety. Even the ones who love it think that that is a good thing.
David: That's a really interesting conclusion that the companies that think they're really positive and the companies that think they're really quite negative are actually talking about the exact same thing. Did you want to pull out any others that spoke to you about these success factors?
Drew: The second one that stood out to me was about this idea of a culture of care. That stood out to me just because I thought it was an interesting thing. I would be very surprised if it was one of the questions that they asked. It does seem to spontaneously have come out of the data.
That is that along with being very punitive, all of the companies that love golden rules also think it's really important to show their workers that they're doing this for the good of the workers and to explain the importance of safety and the importance of these rules for preserving safety.
This could be me misinterpreting, but it seems like a preemptive response to the criticism or response to the backlash, as in they have to justify to themselves and to their workers why they are being so punitive, because they recognize that punitive at face value seems harsh, seems unfair. They need to moderate that by saying to themselves and to their workers, yeah, this is strict, yeah, the consequences are harsh. But we're doing it because it is necessary, because it is justified by the safety we achieved through doing it. We're being harsh out of care.
David: I guess it's like the tough love thing. I've heard those conversations inside organizations and I'm sure our listeners would have as well, which is that we've literally dismissed that person because we care so much. We just couldn't live with ourselves if we let them stay around in the company and they hurt themselves.
I guess that's the way that you tell yourself that you're doing a really useful thing for that person and for safety if you hold them accountable for what's happened. Some organizations have immediate sanction rules if someone's even involved in a near miss incident, not associated with the safety rule where they've got a 48-hour or a 72-hour stand down until the person has been retrained for any incident that occurs in their work.
I've even had those organizations tell me that, no, no, the workers want to be stood down and the workers want to be retrained. My comment there is, yeah, they probably tell you that because of how strong that procedure is inside the company and how little psychological safety. They have to tell you what they really think.
Drew: I don't know how true this is. I think this is one of the ones where we can't quite take the participants on face value. The people who support golden rules say that it is important that we apply them consistently. We don't just apply them when there's been an accident. We investigate all breaches of the rule and we require reporting of all breaches of the rule.
They seem to honestly believe whether it's true or not that that does, in fact, happen. These companies, at least, think that they have a very good understanding of when the rule is broken when it's not, that all breaches get reported to them, and that they act consistently based on the breach, not based on the consequence.
David: I think from your tone there, I don't think you would believe that.
Drew: I believe that they believe it. I have no faith at all that that is true. The fair way of putting it is this research is incapable of uncovering whether it's true or not because they wouldn't know. The safety managers would not know if there are lots of breaches that are occurring.
We can't say that those breaches are occurring. We can't say that they are occurring. What we can say is that their faith they would definitely know is misplaced. They would not know whether or not it's true. They shouldn't be that confident.
David: These data points and why I introduced that survey of 500 frontline workers across 33 mine sites at the start of this episode because if 1/3 of those people say that they break rules regularly and that their frontline leader knows that they're doing it, then if you're in an organization and you have 11 life-saving rule breaches in a year, then those things just don't add up. I guess that tells you a lot about your organization's climate and culture, if you like, as much as the rule breaches and the consequences around them themselves.
Drew: There's another one here. This is less about the people who are applying the rules and more of the people who are moving away that I think is worth having a slightly longer conversation about. I read in this paper that the people who are abandoning the rules are doing it because they think they're moving onto something more mature. The strong hint I got that was explicit in a couple of places was the more mature thing they were doing or at least the thing they thought was more mature was moving away from golden rules and towards critical controls.
The difference being that a golden rule is typically a statement that is very personal about an individual's behavior and in the positive and universal, whereas a critical control is typically a statement about a control around a particular hazard and about the presence of that control. It might be personal or it might be technical. But it's not generic, it's based around when we are doing work involving this specific hazard. Did you get that same impression that that is the movement that people are talking about? What do you think about that?
David: I guess in the resources sector like we mentioned, IAOGP produced their life-saving rule international guidance in 2013. The ICMM (the International Council of Mining and Minerals) produced their critical risk management work by Jim Joy in 2015. There are lots of guidance like that on the internet. I guess these were these competing frameworks.
Many organizations that had done life-saving rules saw this critical risk management framework as an evolution or improvement in what they're doing. I've been involved in a number of organizations helping with this transition from life-saving rules to a critical risk management program.
I guess at a high level, the organizations are moving away from these punitive culture and saying, as opposed to managers disciplining workers for behaving in a certain way, what we want to do is partner with our frontline workforce in (I guess) ensuring that controls are present when working with a particular hazard or exposed to a hazard.
I guess it's that approach. I guess like anything, though, that intention can be corrupted by the prevailing climate within the organization, whether you call it a critical risk control or whether you call it a life-saving rule. I guess it was going to boil down to the climate which you dropped that into.
Drew: Yes. One of the things they didn't look at all in this paper, which I thought was a really curious omission, is nowhere in this paper did they collect sets of what the rules actually were. We've got lots of discussion about the use of rules, but not any examination of specific sets of rules. In fact, no comparison of when those rules actually met the intent of what people were claiming.
For example, a number of participants said that it was really important that the rules be phrased as ‘I will,’ rather than ‘I will not’ or ‘we will not.’ We know in this study, did we actually get to check with the rules that actually do follow that positive framework?
I think this is one of those situations, where, in order to distill a simple set of rules, you've got to either be very generic so that your rules apply everywhere or you've got to be very vague so your rule doesn't stops being a rule and it starts being something like, we will use the appropriate form of protection for the work we're doing.
All the rules are just not applicable. I've been on sites, for example, during the induction, where they've gone through a slide talking about the 10 rules. Then the presenters said, oh, for this work site, rules seven and nine, those are the two that matter. None of the rest actually apply to this site. They're golden rules, but most of the work doesn't even have relevance for that set of rules.
I think that's the danger of trying to make things too simple. It becomes either too generic, or too vague, or just not applicable to so many circumstances.
David: With that will and will not, this is some of the nuance with rules. Some of the will not are potentially particularly useful, like I will not walk or work under a suspended load in and around crane operations and things like that. Design your work, so you've got to understand if the work can still get done, if that's the case.
I've seen some great work process innovations just through the sheer need to comply with that rule, changing industry standards around certain work activities and things like that, looking at engineered design stands and a whole range of things to try to solve for that rule. I guess that's where it is really enabling things. Actually, now this rule is creating permanent change to a work process that's physically more safe.
The other side of the rule is where we see a rule that says, I will not enter a confined space without a permit. That's just having a life-saving rule to do you some paperwork. It says nothing about what the control actually has to be. I guess I'm like you. It would have been good to see rules because not all rules are created equal. I think this is why this is a very gray area of debate and discussion within organizations and within the safety community.
Drew: The suspended load is a great example because it's a rule that for many contexts, you would struggle to find a possibility of an exception. But for many contexts, you would struggle to find even an application. If you're on a work site that's got no suspended loads, that is absolutely a redundant rule.
David: Yeah, and you're talking about localization there. That's where critical risk management tries to go to. What are the critical risks on this site? What are the controls, and what are the critical controls? The whole debate around that and if I could find some decent research, we could probably do a really good episode. Maybe we'll try and do that before we hit 100. We'll try to find some sort of critical risk paper so that we can extend this conversation.
Many organizations are doing their critical risk controls as life-saving rules by another name. Maybe not the quite punitive culture, but like you said, it's the same set of critical controls and critical risks at every single worksite around the world. It's the exact same form that needs to be checked off. It's the exact same reporting that shows that 99.99% of the time all of those critical controls are green and in place for all of the work.
I think many organizations may not be getting any more value out of their critical risk work than they were getting out of having a set of life-saving rules that no one followed and no one reported anything about.
Drew: That is definitely something that is worth following up because I think some of the implementations of critical controls are explicitly intended to move away from this. It's an interesting question to the extent to which they have. Just before we move on to takeaways, I think we can draw some conclusions against the questions that this paper asked of itself.
The question of are golden rules associated with punitive safety cultures? I think they pretty solidly managed to answer that question in the affirmative. If even the people who love them say, yeah, it's punitive, then we can pretty much say yes, at least.
Possibly even more importantly, they all thought that that was inevitable, that that's an essential part of it. There's this strong feeling that we can't get away from them being punitive without getting away from the golden rules altogether.
David: We call them rules. The fact is they're rules. They create compliance, punitive type responses and cultures.
Drew: Yup. The second thing we can say fairly clearly is that they're associated with a philosophy of safety that's very much around top down tough love. Management understands not necessarily what's best in every case, but certainly understands enough to lay down some inviolable rules that apply in every case and is enforcing them on the workers for the workers' own good. That's the philosophy of applying them.
It would be very difficult to integrate golden rules with a much more worker-focused frontline expertise style approach to safety. Those would be quite inconsistent. That's a fairly universal message.
Finally is the idea that organizations that are moving away from golden rules aren't necessarily doing it towards a Safety-II or Safety Differently approach. Often what they're doing is moving towards a much more context-specific, hazard-specific, as like what operations are we doing on this site type approach that may have much of the same philosophy.
It just gets away from the generic towards the particular. It's more sensitive to the local workers and the local context, or at least that's the goal of moving away from local rules. Abandoning local rules doesn't have to come from a Safety-II or Safety Differently space. It can just come from a more individualized, less generic safety application space.
David: This next question is about, do we actually comply with our rules and how do we know? I think the respondents probably answered yes to that, but I think your comments from earlier would say, yeah, I'm not so convinced.
Drew: I just don't think we can answer that from this paper. You can't ask the person who's implementing the system whether the system works or not. Of course, they think it does or they wouldn't be doing it. Of course, they think it doesn't or they wouldn't be abandoning it. We need different types of work to measure what effect it has.
David: Yeah, and then this question about, maybe it's similar, do the life-saving rules continue to address our major hazards? I guess that's something that we can't get much insight on from this [...].
Drew: We've got to, at least, see what the rules are to make that sort of judgment.
David: That last content about life-saving rules to our contractors was really interesting. Again, this goes a bit like parent-child tough love because the people said, well, we don't apply our life-saving rules to joint venture companies that we don't have any control over, but we do apply our life-saving rules to all of our contractors because we control them. It was kind of like this down the line, tough love with rules, but no expectation that joint venture investments would need to follow them.
Drew: We just suggest that their partners in the joint ventures are successfully pushing back as well, which is kind of interesting.
David: Yeah. Maybe there's a whole nother podcast about business models and safety. Do you want to do some takeaways?
Drew: You've written the takeaways, so I think you'd better go first.
David: I dropped a couple in here. I guess one of the takeaways from the paper is that if we've got life-saving rules that define some really key behavioral controls, then they may continue to have relevance in creating margins for safety.
I guess this was part of maybe broader than just this research about our work on rules and procedures in safety, where, when we look at all the other conflicts in the workplace, if you've got a rule that says a driver can't drive for more than 10 hours a day, it really does allow them to cold stop after 10 hours no matter what pressure they're getting from their organization. Things that can be done and should be done, and are supported by the organization to be done, can't be really useful in creating some margins and boundaries around work.
Drew: As you mentioned before, even creating innovations in work to avoid breaking the rule.
David: Yeah. I think there are some places for this, whether you call it [...]. I hesitate to even use the word rules, but should we have clear expectations about how work happens?
The second one here is that there are actually a lot of factors that influence the effectiveness of a life-saving rules program. Fifteen factors are highlighted in this paper or maybe even. I suspect that it's actually those factors around the program, which probably have more influence on the effectiveness of the program itself than the actual content of the rules.
Drew: It's possible this didn't come through from our discussion. But all of these factors are mostly associated with different aspects of the safety management system. We've got factors around how accidents are investigated, factors around safety promotion, factors around management commitment. All of these are other safety activities that all need to be aligned with the philosophy of the life-saving rules for the life saving rules themselves to work.
In that sense, they might be almost like a centerpiece that guides the structure and the implementation of other safety programs, rather than something that just exists in isolation and could never be evaluated in isolation. You couldn't just say, let's take 10 companies, give 5 of them golden rules, 5 not, and see if it makes a safety difference.
David: And there are so many more. Apparently the effectiveness, none of them talk about co-designing and seeing if the workers actually agree with the rules. None of those factors say find out whether the rules actually match the reality of work and whether they can be followed. A lot of things that also go to this is the effectiveness of anything you're trying to do in this space in your organization.
The third practical takeaway is interestingly what you said. Coming up with here was, it's difficult, if not impossible, to divorce a life-saving rule program from the development of a punitive safety culture.
Drew: If there was anything that reading this paper and talking about it changed my mind about, it's about the extent to which that might be inevitable. I think I almost started the podcast saying that I'd be willing to accept life-saving rules coming from a different philosophy.
Actually, even as we've talked through and I've been reminded of the bits in the paper, I'm thinking that they actually build a fairly convincing case that the two are so linked that you'd basically need to wait a generation before reintroducing them. Otherwise, people are going to remember how linked they are to a punitive safety culture.
David: And I think they mentioned in the paper that even if your organization is doing this differently to the rest of industry, people who come into your organization with experiences of rules in other organizations and punitive cultures around that, that the leak into your organization will be unable to be prevented.
The fourth takeaway here I've got is about critical control management. It may provide a useful approach to partnering with the workforce in the presence of risk controls as opposed to what I said about managers disciplining workers and contractors for their behavior.
Creating some locally relevant, effective controls for the hazards in partnership with your workforce, and then mechanisms to have them in place could be a useful approach. But again, like we said, it still has to be done very, very well to not suffer from all of the same things as your life-saving rules program.
Drew: I think if you were in an organization that had life-saving rules and you were looking to move away from them, then looking at something like a shift to site specific or operation specific, critical control, and management, might be a lot more easy to do within the current frameworks in philosophy than trying something like a Safety-II challenge to the golden rules. Let's throw them out, ritually burn them, and trust our workers. You might find that move towards critical control as politically much easier and is much more of an incremental step.
David: That's been my experience. Do you want to have any more takeaways?
Drew: Nope, that's it.
David: The question we asked this week was, do the benefits of life-saving rules outweigh the negative or potential or negative consequences? Thoughts?
Drew: You've got written down in our notes, probably not. I'm actually thinking that this paper doesn't really answer that question. What it does is it says that the life-saving rules are intrinsically tied to this punitive culture. If you're like me and I'm pretty sure, like you, David, thinking that a punitive culture is not positive for safety, then I think you just have to follow down that path and say, yeah, probably not.
David: I think even though you cautioned on the use of quantification of such a small sample, I guess the answer to this question of, do the benefits outweigh the negative consequences, half the people think yes and half the people think no. I guess if you're walking down the safety street and you asked two safety people, one of them is going to say yes and one of them is going to say no to whether the benefits of life-saving rules outweigh the negative consequences. I guess it's up to our listeners to decide for themselves.
Drew: Yeah, but I think the decision is, which group do you want to stand with given the other things that the people who say yes stand by as well?
David: Yes. All right. If anyone wants Drew's email address, please let me know. That's it for this week. We hope you found this episode thought-provoking and ultimately useful in shaping the safety of work in your own organization. Send any of your comments directly to Drew, questions/ideas for future episodes to feedback@safetyofwork.com.