Are they are as popular – and efficient – as some believe?
Hazard assessments abound in the field of health and safety and the idea of a hazard assessment has been around for a long time. There are many different kinds of hazard assessments, but an article I read recently rekindled some thoughts about the field level hazard assessment (FLHA/FLRA), also known as the "STOP" card or the "take five cards."
Names change, but the premise is the same. By having employees conduct their own hazard assessment, we can somehow make the workplace safer. I was surprised to learn that this safety card process has been around for a long time and may even be traced back to the 1930s. Remember the 1930s when airships were quite popular?
Workers love them, right? Well, it depends on who is asking. The individual safety card assessment is like a lot of things and safety. It sounded like a good idea and was implemented with absolutely no research or demonstrated benefit.
When we get past the fascination with new things, we realize that the emphasis placed on these cards by management doesn't necessarily mean they're a good idea or work. What brings a short-term improvement in safety is the emphasis placed on safety by management. This is the well-known Hawthorne or Observer effect. Things tend to improve when under scrutiny.
Any sort of initiative can improve performance in an area for a short time simply by placing a focus on, in this case - safety.
The article I read was about a small study on the "take five" pre-task risk assessments. Most of the observations here I was familiar with. Arguments for such cards are that they provide psychological encouragement for workers to be engaged in safety. That seems very simplistic and, frankly, condescending.
Other purposes of these cards are to help with the planning of the work. That may be, but a good supervisor would do that anyway. There's talk of increasing "heedfulness" or attentiveness. I suppose that might work if workers were not attentive, but I don't find very many that aren't attentive.
These safety cards also help with hazard identification and engage workers in identifying hazards. I suppose that's all right, but it's also appropriate to mention that it is the employer's job to identify and control hazards, and the employer must involve workers in that process.
My favourite, by far, is that using such cards demonstrates due diligence. It's hard not to roll your eyes when you hear the phrase "due diligence" because it is so often misused and spoken by people that don't really have a clear idea of what it means. I've written before about how I have shown clients some of these same cards and explained to them how they demonstrate the company is not duly diligent.
These cards tend to be poorly filled out (and understandably so). They tend to demonstrate that employees are inadequately trained in assessing and controlling the hazards in the workplace (not their direct responsibility). The value of such hazard assessments is questionable.
Additionally, supervisors usually sign these cards off even when they have controls like "be careful," or "be aware." Some are more sophisticated and say things like "Use situation awareness," or "dynamic risk assessment." That really demonstrates that the company isn't appropriately assessing hazards and mitigating them in the workplace.
However, despite findings that these cards don't really do any of the things they say, surely there ought to be some benefits or successes? Creating bureaucracy? Filling banker boxes? Or the most basic of reasons – meeting a client requirement? Perhaps they are meant to (unintentionally) deprive small woodland creatures of their habitat? It depends on your definition.
I see incident reports that indicate that the cause of the incident was the worker "failed to identify the hazard." The investigator knows this because they look at the worker's hazard assessment card. Eureka! The root cause is found? Not even close. While it may be true the worker did not identify the hazard, that responsibility rests with the employer. You could argue it is a shared responsibility, and maybe that is true, but the employer is ultimately responsible, but we rarely see a cause of "employer failed to identify the hazard." Maybe because they do not fill out handy cards that can be examined for fault in the light of hindsight, inexperienced investigators, and a zealous belief in the "truth" that it must be someone's fault.
I know some of you are thinking that sounds unfair. Why is everything put onto the employer? Well, the simple truth is it is part of the trade-off we see in health and safety legislation. The employer is empowered to control the workplace and make the rules, such as dictating the personal protective equipment the workers are supposed to wear and requiring adherence to procedures. In return, the employer is entirely accountable for everything that happens in the workplace. That's why every health and safety act starts with the employer's responsibilities.
However, having these cards helps employers and those convinced of their investigative brilliance to blame the worker for failing to identify the hazards and take appropriate precautions, thereby promoting the illusion that the employer is providing a safe workplace.
There is no proof these cards improve workplace safety despite the many workplaces using them. It is a blizzard of paper and stunning in its bureaucratic triumph.
Companies proudly proclaim they have filled out thousands, hundreds of thousands, even millions of these cards. They would make for some interesting reading. Therein lies the rub. Virtually no one reads them. An activity without robust training, standards, or feedback can never be effective.
Why do it at all? Well, not doing it is taking the risk of being different – and possibly safer. Doing it puts everyone firmly in the herd. It also appears that the employer is supporting safety and making the workplace safer. Looking like you are doing things is a lot easier than actually doing something effective.
Are these cards for workers? I think not.