Disguised compliance: The need for management intervention

Disguised compliance: The need for management intervention

Senior management should never assume that the safe working methods they put in place are followed on site.

Earlier this week we overheard a site worker recanting an incident at a social event. The person concerned was a skilled tiler who had been brought in to carry out some high-spec work on a new-build estate project. He arrived on site with a tiler-cutter that did not have the required dust-extracting bag fitted to meet the safe-working policy being operated on that site.

The site foreman wanted the tiling completed by the end of the shift, but also knew the management's H&S manager was inconveniently touring the site that day too. Rather than resolve the problem by supplying a compliant tile-cutter, he suggested he would stand watch and turn up the radio to cover the sound of the tile-cutter in operation and warn if the H&S manager was coming their way, so they could hide the offending equipment.

As surely as night follows day, this kind of event happens far more often on site than senior management would wish ... or more to the point ... can accept.

Even if the H&S manager had caught wind of what was going on and issued a report to management, there is a fair chance the firm's lower operational management would have done exactly the same as the offending site manager. They may well feel obliged to issue a mild rebuke, but they will probably be thinking his only real mistake was being careless enough to get caught in the first place.

Taken in isolation, the breach of policy in using a non-compliant tile-cutter may seem insignificant. The event passed off without incident and the worker concerned admitted he always wore a face mask, so the absence of a dust collecting bag did not represent a serious increase in health risk on this occasion.

Unfortunately, an isolated departure from a safe-working policy that results in no adverse consequences, makes it even easier to justify the next breach.

The situation can quickly escalate to a position where the whole H&S safety culture on a site becomes an illusion of compliance, disguising the reality that unsafe practices occur all the time with the connivance of the site management who should be enforcing the safe working policies put in place.

This kind of problem is a senior management's worst nightmare. Disguised compliance is the breeding ground for creating the conditions in which hundreds of workers are seriously injured each year and aroud 50 people lose their lives. 


How to avoid disguised compliance


1. Clear communication of expected standards from the top down:

Productivity and compliance are not necessarily mutually exclusive but observing safe working methods comes with a cost and time overhead.

Senior management must convey an unequivocal message to lower management that they accept the cost of implementing their health and safety policies and expect everyone on site to observe the safe working methods they introduce ... without exception.

If the lower management are confident that their senior management will support them when they take decisions that adversely effect productivity in the name of health and safety, then one of the most significant barriers to compliance is removed.


2. Breaking the mould by educating and retraining from the top down ... not the other way around:

We are often called in by directors concerned to see an improvement in their organisation's health and safety compliance, only to discover their middle and lower management tiers are filled with people who continue to treat site health and safety with contempt.

The problem is many of these managers spent their formative years working on sites where everyone engaged in unsafe working practices, and health and safety was satisfied if somebody remembered to put up the HSE poster on the site office wall.

One must start at the top and work your way down until all the management levels are retrained to take health and safety compliance seriously. Then you stand a chance of implementing a coherent and sustainable health and safety culture across the board.


3. Adopt a no-tolerance approach to disguised compliance:

The old ways are always hard to change, and not everyone can adjust to meeting the higher health and safety standards that must be observed on even the smallest of construction sites today.

If an otherwise competent site manager is not prepared to play his or her part in enforcing strict observance of the health and safety policies issued by head office ... then they become a liability and they must be removed.

As site managers are the first, and often only, line of health and safety enforcement on many small construction sites ... senior management would be well advised to take every step ensure these people really do enforce and tow the company policy line.