The grandfather of Safety Management Systems is not what it once was

Many people will at least be aware of the safety management system affectionately known as HSG65 (the document series and number, in fact). It arrived more than 20 years ago. Even though it’s technically a UK thing, instantly conjuring up images of a tranquil, green and pleasant land, haymaking in the fields of England, bothys in Scotland, Doctor Who in Wales and skipping along the giant’s causeway in Northern Ireland, it is difficult to deny its global importance. HSG65 stuck as the unofficial title because it was considerably less dull and far more memorable than the actual title. It also puts one in mind of how you might be addressed if you were jailed for not having implemented it – names are for tomb stones and numbers are for prison.

Whilst the UK government is struggling to think of something worthwhile to do, other than dodging bailing out the Euro zone, HSG65 is being revised (or ‘refreshed’ as they like to put it). The draft is currently out for consultation, the purpose of which is, like all consultations, to share the blame.

When I first read HSG65, I found that I forgot each page the instant I turned it over. I thought there was something wrong with me (well, there is) but it was all that woolly management speak that sounded great but didn’t stick. But I guess it felt it had to, because it was trying to speak to managers, using their language. Well, now it’s moved on and recognised that the attention span of most has reduced considerably – I mean, we have to be constantly fiddling with our mobiles, texting, waiting for that important email, tweeting and updating facebook and linkedIn with anything that passes through our mind.

The revised draft version is in three main parts (there is a fourth part, but this is simply a list of references and links). There’s an overview, then evidence criteria to look for (to evaluate whether you’ve a management system that’s up to it) and finally, more detail for the committed who are actually trying to implement or improve things. The original stretched to over 100 pages long, being revised and reprinted many times. This draft is about a third of that.

Part 1, the overview, is very short and succinct. And that’s good, because there is no need for it to be any longer. The style and language are more accessible than before. There’s also a distinct emphasis on the familiar general management repetitive cycle of plan-do-check-act (PDCA), commonly referenced in all the ISO management system standards (and then promptly ignored in them). Indeed, as it stands, HSE plan to ditch the original POPMAR model framework (Policy-Organising-Planning-Measuring-Audit-Review) or at least subjugate it beneath the PDCA mantra. They make it very clear that you don’t need a formally recognised management system, but you do need a consistent system rather than fire-fighting with single interventions to fix things.

HSE also strongly emphasise that safety culture (attitudes and behaviours) is absolutely central to whether safety is actually managed effectively. This is because it is people that have to develop, implement and maintain all the nice little policies and procedures, identify and control risks and all the rest. Without this proper balance and perspective, paperwork (i.e. the documentation of the system) can become an end in itself and this is a recipe for disaster.

Part 1 then goes onto explore elements of a safety management system around the PDCA framework. That is, what you’d be doing and what you would have in place at any one time. That gets rid of those silly arguments about whether something is a ‘planning’ or ‘implementing’ activity when the truth is that many activities are a bit of both – you don’t wait till you’ve planned absolutely everything in fine detail in your business before you do anything.

Part 2, the evidence criteria, is also quite short. It is nicely set out in tables to show you what management elements look like when they are done well and, importantly, what they look like when they are done badly or not at all. This takes you through issues of leadership and management, competence, and worker involvement. It also distinguishes between some different sizes and types of organisations, recognising that things may be far less formal in small businesses.

In the leadership area, for example, it indicates what you’d be looking for in a leader (you know, a top manager). Many of these are expressed as questions to ask yourself (assuming you are a leader) or use to beat up on a leader (if you aren’t doing that already). Granted some questions are very high level and are more involved but the juxtaposition of good and bad examples helps to clarify. I like the one about visibility – which should be easy to verify for most humans. The classic flouting your own site safety rules is also in there as a negative indicator. A leader who aspires to be truly bad (I can understand the attraction), should find a wealth of ideas to upon which to model himself.

I like the fact that it rails against that “silo mentality”. It doesn’t serve to separate out health and safety as some kind of add on to business management. It treats it as something that should be integrated. For example, it takes the presence of ISO 9001 (formally a quality management system) as likely evidence of having a good business system in place (or at least potentially); I know that isn’t always true, but having at least some good business management system in place could just mean that it needs to be tweaked to make sure safety is fully encompassed. All businesses that are managed effectively, working to a common business goal, by definition, have to have integrated processes.

Part 3 is by far the longest section and aimed at implementers and improvers, greatly expanding on part 2. The idea is that you find out where you’re not doing so well from part 2 and look to part 3 for ideas on what to do about it. There is always the option of doing nothing and sharing a cell with HSG65.

A theme of the old HSG65 POPMAR model was the 4C concept (control, co-operation, communication, competence). This was considered central to developing a health and safety culture. Part 3 of the draft asks the question as to whether the 4C model is still relevant. I actually don’t find it all that helpful, not only because it was difficult to remember what each C actually stood for (I can think of lots of words beginning with C that might not be relevant at this time) but also because categorising things in this way can fool you into thinking they are distinct, independent concepts, when they are not. For example, communication is involved in all the other three and control also relies on others co-operating (or at least complying). Thus, things you might do for one C will impact on the others. They interact. I think the replacement by themes of leadership, competence and worker involvement says all the important bits (albeit, there still is overlap). Nonetheless, part 3, still cannot relinquish the 4C’s framework upon which to hang material together, but I personally think it awkward and unnecessary, especially considering it discusses worker involvement and competence in just about each one of the C’s.

Part 3 is framed as an action list, identifying the likely roles for the actions too. This is, on the whole direct and helpful, but occasionally dives into diffuse, woolly, management things “somebody, somewhere, should do something” that leaves you confused and indifferent. For example “demonstrate commitment to the process” is probably not worth saying on its own. But having said that, there’s a lot of practically helpful stuff such as: Make a statement of intention and sign it; if the risks are complex, think about hiring an expert to advise you or train up one of your own people. Obvious to most I know, but worth saying.

So, does it work? Good things come in threes – clover leaves, blind mice, pigs, wise men, McDonalds meal deals – so the 3-part approach is bang on. This lends itself to not having to wade through mountains of irrelevant C (just think of a suitable four letter word here) to discover “I still haven’t found what I’m looking for..” (apologies to U2). You get an overview, a set of criteria to help you decide and some practical pointers on how to fill any gaps. All in less than 40 pages (it is bound to get bigger after the consultation).