INQUIRY INTO WORKPLACE SAFETY – SUBMISSION
I am offering this submission to the Standing Committee on Law and Justice
to express my opinion on matters relating to workplace safety. I hope that
others may benefit from my experience ,gained in a working life of over
thirty years as an industrial chemist in defence manufacturing.
For many years I have been aware that industrial incidents occur mainly as
a result of management system failures, and in particular the failure to
integrate risk management strategies.
The introduction of ISO9000 type management system standards offer
management system models aimed at managing the four main areas of
industrial risk (quality, safety ,environment and security) related to
work processes. The difficulty lies in the fact that there are tradeoffs
between the four areas. For example a simple process of electroplating
high tensile screws with cadmium involves quality problems – some
processes cause hydrogen embrittlement, safety problems – cadmium plating
must be used to stop corrosion, it is toxic ,the baths contain cyanide,
both cadmium and cyanide present environmental problems, cyanide presents
a security problem.
Substitution of any component of the process causes development of new
problems. This combination is common in industry where hazardous
substances are in use and must be extreme where radioactive substances are
used. The management system must cope with this type of problem in a way
which is acceptable to its customers and society.
The ISO 9000 approach is for organisations to express their management
policy in the form of a documented management system, and subject this
system to continuous improvement through audit and team based problem
solving activities. There are Australian Standards which relate to the
four main areas of industrial risk , organisations which are certified to
these standards are committed to ongoing risk management and improvement.
In my experience the implementation of ISO9000 management systems meets
with opposition from middle managers , who understand that ‘if you do not
state your policy on any subject, you can never be wrong’, and wish to
manage on an ad hoc ,directive basis. It is my contention that most
managers in industry do not have formal training in risk management, do
not know how to counsel staff ,train staff, have only a rudimentary
knowledge of industrial law ,and have poor problem solving skills.
A major improvement could be effected by introduction of requirements for
management training and competency testing of supervisors and team
coordinators. I suggest that direction of employees by incompetent
supervisors is completely unacceptable. The fact is that under a directive
management system employees can be directed to perform tasks which place
them at risk, with little redress.
This brings me to the matter of industrial democracy. ISO9000 type
management systems encourage continuous improvement of processes and
systems, this is difficult to achieve under a directive management system.
I suggest that most certified organisations will embrace a participative
management system, and will become the more competitive for it.
Employee involvement is of paramount importance for workplace safety,
quality of product ,protection of the environment, and security. I suggest
that a major improvement would be implementation of tax incentives for
employees to undertake salary sacrifice for the purposes of purchasing
shares in their organisation. A simple expedient of discounting shares on
the basis of productivity improvements would provide the incentive for
employees to improve the efficiency of their organisation.
The key to integration of risk management systems lies in the work
practice documentation(procedures, codes of practice, process
specifications).The ‘process control’ element of ISO9001 requires
performance of work under controlled conditions ,including documentation
of work practices where lack of such documentation could adversely affect
quality (safety, environment, security). This implies that where there is
a reasonable expectation that an incident could occur due to a lack of
administrative control that the process should be documented. The very act
of documenting the process means that the process is visible to all and
can be evaluated easily by any competent person.
The processes involved in manufacture of most product are decided during
the design process. In industry it is quite common to design without
proper configuration management. This means that there is no basis for
systematic risk assessment. The modification of processes should be
performed during development of prototype product and continued by the
manufacturing team only under controlled conditions. By this I mean that
design engineers should be trained in process application and have a basic
understanding of toxicology so that ‘safe’ and ‘nonpolluting’ products are
used in their designs.
Workplace teams should evaluate processes and determine whether the safety
risks involved are acceptable to them. The need to consult with competent
persons where hazardous substances are involved should be the subject of
The principle I have discussed may be simply put:
SAY WHAT YOU DO
DO WHAT YOU SAY
BE ABLE TO PROVE IT
BUT IF YOU CANT DO IT SAFELY,DON’T DO IT AT ALL
Alan G. Cotterell
26th June 1997
"Alan Cotterell" <email@example.com>
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