A linked committee structure would be great for a larger organisation - a rep from each committee would also attend the committee / management meeting at the next level, acting as the two-way interface between both. Goodman Fielder used to use this model to ensure there was a clear, unbroken line of communication throughout the organisation, making it easy to escalate an issue or cascade information, as appropriate.

If you REALLY understand the underlying principles of safety, you will have nothing to resist from first considering the nature of the organisation and its needs, listening to the concerns and needs of workers, and finding solutions that bring it all together.

Genuine leaders are happy to listen because they understand already what is essential and where they need to end up, and they are not so limited in their perspectives as to think there would be only one way of getting there. Leaders also understand the importance of engaging and consulting without a pre-set agenda, because people are usually quick to pick up on inauthentic dialogue. Although it may be tempting to just push forward with a pre-set agenda, it will ultimately cost you more time and loss of trust, among other things.

- exactly!! Those people not only think they 'know everything' because they have the certificate that says so; they also have had a linear / binary experience that drives a linear / binary approach, always pushing their own ideas onto others, even at times behaving in ways that can only be described as self-righteous bullying, and very much driven by the need to be 'right' at all costs. They are very disruptive on so many levels - destroying relationships and trust because they don't listen and don't even seem to have much depth of genuine understanding.

It's highly ironic that HASANZ / NZISM has chosen to put so much weight on formal qualifications as the key criteria for membership. Most training is based on very old and outdates methodologies that are quite out of step with the needs of modern workplaces, 'designed' to push an 'approved' doctrine of 'safety management' rather than leadership, overly focused on 'WHAT' without adequately addressing (or God forbid QUESTIONING whether such perspectives are still relevant or actually meet requirements to take 'all practicable steps' or to genuinely manage risks 'as far as reasonably practical'. Then there's the factor that most training in NZ these days lacks genuine rigour of assessment and verification of genuine competency - i.e.,meaningful verification of more than just a trainee's ability to parrot words and their associated definitions or select the right options from multiple choice answers. What about the ability to critically analyze data and apply concepts? What about the ability to design a system or tool? Even more obscure and more difficult to measure, but possibly most important of all, what about the ability to grasp the intent behind a requirement in such a way that they can explain it in different ways to different groups of people or adapt to suit different organisations in ways that support overall business activities and needs rather than creating a 'silo' system that doesn't align with the rest of the organisation? Most assessments are either designed primarily to enable trainees to achieve a 'pass' mark so training providers can get their money (a significant flaw in the way NZ's NZQA qualifications framework operates).

In an ideal world, training would be based on sound, proven instructional design practices, starting with an appropriate Learning Needs Analysis that sets out a coherent and meaningful set of competency objectives from which training would be designed, delivered and assessed. Furthermore, for individuals to be genuinely competent and for NZ businesses to be appropriately supported by safety practitioners as professionals, competency frameworks must include meaningful criteria for competency using a recognised instructional design framework such as Bloom's Taxonomy of Learning, and much more thought and consideration must be given to the real work of safety professionals.

Competency frameworks must recognise that professionalism and effectiveness in workplace health and safety require a much broader range of skills than simply depth of specific technical knowledge (most of which can be readily obtained using resources generally available on the internet), or what is essentially a kind of indoctrination on 'approved' safety ideas. Professionals in every discipline need leadership skills, management skills, communication, the ability to build relationships and coach others to learn and develop (and to get oneself out of the way of other people's learning and development!). Without these, safety will continue to chase its tail and blame everyone else for not following when they never provided meaningful leadership in the first place!

Well said, Tania - as always!

It's interesting to see such a comment coming from WorkSafe NZ just as HASANZ is aiming to bring more formal structure and professionalism into workplace safety....

As with most things in life, generalisations rarely represent the entire category. Like you, when I am working with a client, I aim to enable them as much as possible to be self-sufficient (like the analogy of giving a man a fish vs teaching them to fish), and I am definitely not receiving exorbitant fees for doing so - and I have the bank statements to show it!

One of my great frustrations at the moment is that the HASANZ framework is so rigid and relied overly much on holding specific pieces of paper, with little consideration for people like me who have not only been out there actually doing the work and undertaking self-directed learning on an ongoing basis, especially as a specific requirement arises. I also regularly collaborate with and consult with others to check my understanding and delve more deeply into the 'wrinkles'. I have not had time or money to pursue a Post-Graduate Diploma in H&S or a degree, and to be honest, I don't feel I would get much value for the investment of my scarce resources, other than another piece of paper from the HASANZ organisation, which seems to have been set up as a gatekeeper to opportunities and authority in this field. I did achieve NEBOSH IGC with Distinction when an employer made it possible, but this is not considered to be enough evidence of my capabilities.

Meanwhile, at the same time while HASANZ and NZISM would consider my credentials and experience insufficient to receive their endorsement, I know of several individuals, some of which I have personally worked alongside, who have a PGD H&S and are still very incompetent and unprofessional, yet because they have the requisite piece of paper, they have been recognised as Graduate Members eligible for HASANZ membership. To me, this seems to shoot the very framework in the foot. Yet another example of how a generalisation can fail.

Clearly, there is still much work to be done.

A rigid requirement to sign minutes looks very much like an attempt by the company to cover their own butts, and employees can see that a mile away. This does not contribute to building trust - in fact quite the opposite, and it's likely to be an ongoing downward spiral unless managers start acting more like LEADERS and change the dynamics. Trust is the foundation for everything else, and leaders have to start the ball rolling. Building trust takes time and it has to be earned - you can't demand it, and you can't force it.

It sounds like time for managers to step back and do some deep soul-searching.

Here's a somewhat related story - some common themes:
https://www.stuff.co.nz/business/118463532/worker-fired-for-declining-a-face-scan-awarded-23200

Here's an interesting story where an employer introduced a facial recognition programme under the guise of 'health and safety', without appropriate engagement or consultation, and with the underlying agenda to crack down on cheating on time sheets. The employer fired a worker who refused the facial recognition scan when the employer could / would not answer questions about how it was used, how it actually linked with safety on site, and what was going to be done with the data.

https://www.stuff.co.nz/business/118463532/worker-fired-for-declining-a-face-scan-awarded-23200

I can well imagine that there are probably many submissions that are based more on opinions, emotions and personal perspectives than those based on objective facts to support a position. That must be very tedious to try to wade through.

Since 2000, I have usually worked with a small, committed group of people to go through the proposed legislation, prepare comments and make submissions. We have made quite an effort to leverage our collective knowledge, skills and experience in order to make meaningful submissions. It's quite disappointing to have these disregarded by regulatory agencies and personnel who cannot be bothered to read and consider with similar commitment.

All the same, I aim to do whatever I can to ensure I am appropriately informed and understand the issues. I can't control what they do with my submission, but I also live by the maxim that 'Silence implies consent." We really don't have justification to complain if we have not spoken up. I remember when the Health and Safety Reform Bill Discussion Document was issued, and members of NZISM met to hear from a legal expert what the issues were. The lawyer asked the group (probably about 40 people) who had actually read all or part of that voluminous document, and only 4 of us raised our hands! Yet this legal framework was going to be a key influence on the direction, activities and expectations of our profession!

I know people are busy with their jobs, but we all have the same amount of time every day; it's all about what you value enough to prioritize it. When we were reviewing the MBIE Discussion Documents, the people in our group were all very busy with their jobs during the day, so I invited them to come to my house one evening per week, working through one chapter each week for five weeks. We sat at my dining room table and worked solidly for about 1 1/2 hours, then we would have a cup of tea and some of my baking as we wrapped things up. At the end of our process, we had each made an individual submission as well as a group submission, which we copied to Responsible Care NZ as well. My key point here is that we were all committed enough to make it happen.

In addition, the collaborative approach adds immense value because the group discussions and contributions from a greater variety of individual perspectives and experience mean that each person finishes up understanding existing and proposed frameworks far more comprehensively - including what they ARE and what they ARE NOT, which equips us to manage and lead much more effectively.

In addition, the collaborative group approach has also given us the opportunity to share the load so it is easier to get through it. When changes to the Hazardous Substances Regulations were proposed more recently, one of the group members invited us to join her at her workplace for discussions. We agreed to divide up the regulations amongst members, with different people taking responsibility for the various parts of the regulations. At that time, I was least directly involved in handling hazardous substances, so I offered to take minutes of all our discussions, thus involving myself more deeply with the dialogue. The minutes were then available to each member of the group so they could develop their own individual submissions as well as having the notes for future reference in their own business.

Meanwhile, I live in hope that we won't have to keep running into metaphorical brick walls with ineffective / inappropriate regulatory frameworks, and that one day someone is going to listen a little more carefully to suggestions, rather than just waiting until the political pressure that develops from a disaster spurs them into action!

I was pleasantly surprised to see WorkSafe / MBIE taking the initiative and using a world café type approach last year, where they presented the context, then operated 3 short sessions with small groups around tables, each table with a specific theme to explore. Each table was attended by a representative of WorkSafe or MBIE, who collated comments, summed them up and presented them back at the end of the interactive session, then was charged with taking those comments back to the office to include in their considerations. It was a big step in the right direction in terms of achieving meaningful feedback, getting people involved, and supporting people to understand more of the regulatory requirements.

Thanks, Andrew - you confirmed everything I had suspected! So maybe these issues such as not actually reading documents and submissions are not confined to just the US GOP.....

Well said, and definitely if our minds and ears are closed from the start, our opportunity to learn and improve will be limited.

With such a significant event and under worldwide media scrutiny, I can well imagine that there will be a lot of people aiming to deflect any possibilities of being blamed, but defensiveness right now would be such a barrier to really understanding and learning how best to minimize the impact, and potentially for tour operators to be able to resume tours more safely.

"In the fullness of time I believe we'll get some direction as to where we will go as operators and individuals, but right now, our thoughts are in other places." - Tim Barrow, Volcanic Air Safari director and chief pilot

https://www.stuff.co.nz/national/118111491/multiple-casualties-multiple-victims-man-who-flew-last-survivor-off-whakaariwhite-island-speaks?rm=a

"If you don't take a risk you don't get anywhere." - pilot Mark Law on making recovery flights

Recovery plan under way as volcanic ash threatens to entomb bodies on Whakaari/White Island
https://www.stuff.co.nz/national/118138376/recovery-plan-underway-as-volcanic-ash-threatens-to-entomb-bodies-on-whakaariwhite-island?rm=m

Yes - your comment really highlights the most important point: users need to conduct their own risk assessment and determine what is appropriate.

I can well imagine with all the heavy-handed threats of prosecution if an injury incident occurs, it's common for people preparing SDSs and those managing the SDSs at the user end to default to 'err on the side of caution' and just assume the highest level of controls for constituent materials.

One of the things that is most ironic about HSWA's approach to holding people and businesses more personally accountable for safety is that their use of fear tactics often takes them further off track and discourages them from doing their own thinking, which is ultimately counter-productive to genuine and effective workplace safety management.

Some more relevant stories about this event (keeping in mind that everyone is now likely to either be in the camp of '20/20 hindsight' or throwing up their hands in exasperation over a force of nature they could not be expected to control).......

https://www.nzherald.co.nz/index.cfm?objectid=12292857&ref=twitter

https://www.nzherald.co.nz/index.cfm?objectid=12293369&ref=twitter

https://www.stuff.co.nz/business/118098320/whakaari-white-island-three-helicopter-companies-all-unregistered-for-adventure-activities

Exactly. And I would suggest that SDSs produced in such a way would actually not meet the legal requirements and could potentially be a breach of the regulations because they don't accurately represent the hazards of the actual substance.

I recall when I used to deliver training about the HSNO that there was among the penalties a provision for fines that could apply if a substance was labelled or otherwise identified as hazardous when it was not, and the example we used to discuss is when a substance was transported with labeling and signage that indicated it was more hazardous that it actually was. Is that your understanding as well?

The difficulty with SDSs is that there is currently very little meaningful policing of the quality of information. When I worked with chemicals in the past, many were sourced from China, and those often were accompanied by the barest skeleton of information, rarely anything close to the ISO standard format, and often little more than the technical data sheet, which is more like a product specification, without safety information for handling, storage, use and disposal.

It would be interesting to find out how much review and vetting is done by organisations that provide hazardous substances information for emergencies - e.g., Chemwatch. Even so, these service providers are often not used by smaller companies who may be in a position of 'you don't know what you don't know'.

Or Elf decides to manage a hazard by substitution, so they engage a contractor to do the work instead of their own employee.

- yes! And nearly as bad are those SDSs that warn of all sorts of possible risks that don't relate to the product at all - especially when they are based on the hazardous properties of the pure ingredient that might be present in only very diluted form or as a possible trace contaminant!

That probably happens either when people don't really understand the hazards information, or forget the intent of that section of information, and / or just can't be bothered to think it through and figure out what is needed.

FYI - Rebuttal from Amazon via EHS Today:
https://www.ehstoday.com/safety/amazon-responds-criticism-high-injury-rates?NL=OH-05&Issue=OH-05_20191205_OH-05_634&sfvc4enews=42&cl=article_1&utm_rid=CPG03000008027398&utm_campaign=38854&utm_medium=email&elq2=c78ffd2fa17848d0aabef10168e40dc0&oly_enc_id=4569F5190945A3Y

This is another topic in which it is vitally important to connect all the dots and don't just criticize a worker for appearing to be overweight, with the assumption they must be very unfit (I have met some people who look overweight but are incredibly athletic!!).

1. Consumer demand is a key driver of many products and services, many of which we complain are unethical - for example, many people speak out about the dangers of genetic modification, yet growers are like any other business and want to achieve more profitable crops, while the general population typically aims to keep its expenditures as low as possible. It's kind of like a 'game' where everyone is seeking the opportunity to have some kind of break-out advantage. The needs of these two groups are essentially diametrically opposed, resulting in some experimentation with methods that will allow both to get what they want, and without taking the full set of consequences into account because we don't yet have enough information to really quantify the health risks and other potential consequences.

2. The cost of compliance is an interesting matter. I have often heard the comment that NZ is among the most highly regulated countries in the world. I will resist the urge (for now at least!) to delve into some of the values and perspectives underlying the urge to make rules for so many parts of life, and just have a look at the issue of cost.

Rigid compliance requirements are often imposed as a knee-jerk reaction, typically with a relatively superficial aim (a bit like assigning a root cause without having done appropriate root cause analysis), often accompanied by a raft of ambiguities and omissions that further muddy the waters. Without sound foundations, compliance is often implemented based on inefficient and bureaucratic assumptions that ultimately add costs that no one really knows how to justify, other than "because WorkSafe said so". So the 'good' guys do their best to comply, and the 'bad' guys either look for every loophole or wait for someone to come along and catch them, happily counting the dough they have saved by holding out.

HSNO itself is a very interesting example of how a regulatory framework comes into existence - it took the ICI fire to get the public to sit up and take notice, and then politicians needed to be seen to be taking prompt action. The history of HSNO included a crazy patchwork quilt of regulatory frameworks, with separate regulatory agencies that didn't work with each other and each had its own inspectors - I used to work with a chemical company as HSEQ & Regulatory Manager, coordinated Dangerous Goods Licenses, Poisons Licenses, Building Warrant of Fitness, Air Discharge Consent, etc. When HSNO became law, substances registered with the Ministry of Health were turned over to ERMA, who had been expecting only a few thousand substances to be registered, but there were so many flaws in the systems that there were HUNDREDS of thousands of substances to wade through, requiring resources they had not anticipated! The board of ERMA included a number of people with very little practical knowledge of chemicals or chemical production, so they imposed their own 'zero-risk' approaches and created very rigid and impractical frameworks, with most of their advisors brand-new university graduates with no real-world experience - when they didn't know much and were not sure of the facts, they rigidly applied limits and there was no room for discussion unless a company wanted to take on an expensive and time-consuming appeal. I experienced it all first hand!! They became too focused on perceived differences between the substances themselves and lost track of the overarching intention to regulate the hazardous PROPERTIES of those substances - classic case of not seeing the forest for the trees!

I am please to note that much later in the piece, with those worry-worts gone from the board, regulators finally realized the sense in implementing what we tried to suggest right at the beginning and implemented generic approvals for groups of substances, which is much more sensible on all fronts and also supports innovation and improvement, which goes some way as an incentive to make those substances safer.

3. It seems very hypocritical for NZ government to impose more and more regulatory requirements on New Zealand businesses, while at the same time holding the back door open and encouraging businesses to move their manufacturing to China. We all KNOW that China does not operate by the same standards for workplace safety, environmental protection and sustainability. Eve those companies that audit and produce reports that verify 'compliance', it is very well known that most Chinese businesses will agree to whatever is asked of them, sign any required documents, and then just go on and do what they like. There may be some of those businesses that do comply, however I can imagine that most, exactly like their NZ counterparts, are more concerned about the bottom line and not missing opportunities, so they just cut corners where they can as they try to survive and hope to thrive.

NZ businesses that set up those business operations in China still have obligations to ensure worker safety and environmental protection. Just because we can't see it with our own eyes here in NZ doesn't mean it isn't happening, and it doesn't mean it doesn't affect us.

Not only do we all share one planet Earth; we now operate in a global economy. Asian countries have stopped accepting waste from western countries, and we can probably expect them to push back on unsafe work activities, too. So we really should be starting to think about new paradigms.

I agree with Michelle about re-thinking the role each of us plays in all of this. My partner and I have been actively simplifying and streamlining how we live, growing as much of our own food as we can, making more environmentally-friendly and sustainable choices about what we buy and consume, including the ethics of producers, the materials used, the waste produced, packaging, safety, durability, etc. and scaling down as much as we can. I can't solve the whole system, but I can make better informed and more conscientious decisions within my own sphere of influence, and if each person did just that, we could really make a difference.

Unfortunately yet another example of NZ regulators setting up a razzle-dazzle compliance framework that is not supported with appropriate means of following up to ensure compliance.....any compliance framework is only as robust as its enforcement.

I recall some years ago listening to a speaker from NZTA at an NZISM meeting, who observed that much of NZ's legislation seems to assume that simply putting a law or regulation in place was automatically going to result in the desired behaviours - rarely have meaningful considerations been given to enforcement actions and resources. It's exactly the same as posting a hazard sign or notice in a workplace and thinking you have the hazard under control!

Anything purporting to represent Values will ultimately fail if imposed from the top down - workers will always look for examples where your own behaviours and actions don't match your rhetoric, which will result in losing credibility and trust.

"Agreements" generally work better than "Rules" because workers generally place very high priority on having a say in matters affecting their work (and there is a famous leadership study that verified this - I just don't know the specific details).

Smart organisations facilitate dialogue and discussion (this is what the regulations on employee engagement and participation aim to achieve, too), listen and respond to employees in meaningful ways. No one wants to come to work and be treated as if you were a clueless child being ordered around by an authoritarian parent!