Embedding safety culture

Building a Safer Future, Independent Review of Building Regulations and Fire Safety: Interim Report recognised a failing safety culture within construction. This guidance aims to address how safety culture can be embedded in the industry.

Author: David Thomas, Safety Health and Wellbeing Panel

True and lasting change will require a universal shift in culture …
Dame Judith Hackitt^[1]

As well as addressing technical competence, there is a pressing need to see the leadership that is required within the construction industry … to drive the shift in culture. Professional bodies need to demonstrate and deliver this leadership …
Dame Judith Hackitt^[2]

1.0 Introduction

‘Building a Safer Future: Interim Report’^[1] identified that the system of building regulations and fire safety was not fit for purpose and that a ‘culture change’ was required to support the delivery of buildings that are safe. A system failure, identified in the interim report, had allowed “… a culture of indifference to perpetuate …”.

‘Building a Safer Future: Final Report’^[2] includes the term ‘cultural change’ on twenty occasions. It is noted that “The HSE [Health and Safety Executive] has worked hard with industry to embed the new requirements of the CDM Regulations and to drive culture change. This is the approach that now needs to occur in respect of building safety too …”.

Whilst a new regulatory regime has now been established, there is little advice on what culture change might ‘look like’ or ‘feel like’ at the workface, although a case study in the Final Report^[3] includes mention of collaboration, training, leadership, communication, clarity of message, effective feedback, openness and trust, coaching and industry workshops.

So, what can be learnt from the world of occupational safety and health?

2.0 What ‘is’ safety culture?

The term ‘safety culture’ made its appearance first^[4] in the International Atomic Energy Agency’s initial report following the Chernobyl disaster (1986). Since then, inquiries into major accidents such as the King’s Cross fire (1988), Piper Alpha (1990) and the Herald of Free Enterprise (1987) have found faults in the organisational structures and safety management systems, throwing the importance of safety culture into the spotlight.

The HSE has a definition of safety culture: The safety culture of an organisation is the product of individual and group values, attitudes, perceptions, competencies, and patterns of behaviour that determine the commitment to, and the style and proficiency of, an organisation’s health and safety management^[5]

So, the term ‘safety culture’ (sometimes termed 'safety climate') is used to refer to the:

Behavioural aspects, viz. what people ‘do’
Situational aspects of the company, viz. what the organisation ‘has’
Psychological characteristics of employees, viz. how people ‘feel’

Following the Ladbroke Grove Inquiry^[6], priority areas were recognised by Lord Cullen, leading to the identification of five indicators of positive safety culture:

Leadership
Two-way communication
Involvement of staff
The existence of a learning culture
The existence of a ‘just’ culture, focusing on the prevailing attitude of ‘blame’

Taking each indicator in turn:

2.1. Leadership

- Senior management should give safety a high status within the organisation’s business objectives, demonstrated by providing sufficient:

Health and safety budget
Opportunities for safety communication
Health and safety training
Support to personnel
And resources, including health and safety specialists

- They should visibly and repeatedly demonstrate their commitment to safety throughout all areas of the organisation, creating a shared vision of the importance of safety, eg by verbal and written communication.

- Organisations should have effective systems in place for the management and co-ordination of safety, led by a safety management team.

2.2. Two-way communication

- A positive safety culture requires effective ‘all round’ communication on safety matters, meaning:

Top-down - key to providing successful health and safety leadership
Safety reporting - a feedback mechanism concerning any actions taken
Horizontal communication - the transfer of information between individuals, departments and teams

2.3. Involvement of staff

- Active employee participation, through the involvement and participation of staff, is a positive step towards preventing and controlling hazards.

- ‘Ownership’ of safety issues is increased through the provision of effective training and the opportunity for staff to have specific responsibility for areas of safety.

- It should be easy for staff at all levels to report concerns about decisions that are likely to affect them, particularly during organisational change. Peer pressure in design practice can drive ‘culture’.

2.4. The existence of a learning culture

- A learning culture enables organisations to identify, learn and change unsafe conditions. They should recognise and plan for growth and career progression.

- Employees, through increased involvement in the company, can contribute ideas for improvement, particularly through:

The analysis of incidents
The sharing of information - with any actions taken being disseminated

2.5. The existence of a ‘just’ culture

- Some companies have a ‘blame’ culture at the expense of correcting defective system(s).

- Fault and responsibility is allocated to the individual making the error, rather than to the system, organisation or management process.

- Organisations should move from a ‘blame’ culture to a ‘just’ culture (or one of accountability) with management demonstrating care and concern towards employees.

- Employees should feel that they are able to report issues or concerns without fear that they will be blamed or disciplined. The nature of the construction industry, with its lack of security of employment and high rate of self-employment, leads to certain behaviours as people believe that they are likely to be dismissed if they raise an issue.

These five indicators are all reflective of a positive safety culture.

3.0 What might safety culture ‘feel like’?

A useful concept^[7] is the Bradley CurveTM. This was developed in 1995 by a DuPont employee, Berlin Bradley. It identifies four stages of safety culture maturity: Reactive, Dependent, Independent and Interdependent (see Figure 1). The aim is to move from Reactive to Interdependent safety performance.

Figure 1: Bradley curve (credit: ecoonline.com)

Taking each stage, in turn:
1. Reactive stage

People don’t take responsibility.
They believe that safety is more a matter of luck than management, and that “accidents will happen.” And over time, they do.

2. Dependent stage

People see safety as a matter of following rules that someone else makes.
Accident rates decrease and management believes that safety could be managed “if only people would follow the rules.”

3. Independent stage

People take responsibility - ‘safety is personal’.
They believe they can make a difference with their own actions. Accidents reduce further.

4. Interdependent stage

Teams of employees feel ownership for safety and take responsibility for themselves and others.
People do not accept low standards and risk-taking. They actively converse with others to understand their point of view.
They believe true improvement can only be achieved as a group, and that zero injuries is an attainable goal.

4.0 What might safety culture ‘look like’?

A useful tool is the Risk Management Maturity Model (RM3). This was published by the Office for Road and Rail (ORR)^[8]and developed in collaboration with the rail industry. It identifies:

Five themes for excellence in health and safety management systems
Twenty-six criteria for key elements of a health and safety risk management system
Five levels of maturity

The model^[9]:

Defines what excellent health and safety management ‘looks like’
Adopts the Plan, Do, Check, Act framework set out in the HSG65^[10] (see Figure 2)
Incorporates the key features of good practice in Health and Safety Management Systems (SMSs)^[11]
Draws in knowledge from incident reviews^[12] from both the safety[^13] and commercial risk areas

Whilst some of the requirements mention ‘rail’ they are considered to be broadly generic.

Figure 2: Plan, Do. Check, Act Framework (credit: Risk Management Maturity Model (RM3), Office of Rail and Road)

The tool is designed to:

Help manage health and safety risks;
Identify areas for continuous improvement, and
Provide a benchmark for year-on-year comparison

4.1 Themes

There are five RM3 themes (see Figure 3):

Health and safety policy, leadership and board governance - SP
Organising for control and communication - OC
Securing co-operation, competence and development of employees at all levels – OP
Planning and implementing risk controls through coordinated management arrangements – PI and RCS
Monitoring, audit and review – MRA

Figure 3: Themes and criteria (credit: Risk Management Maturity Model (RM3), Office of Rail and Road)

4.2 Criteria

Each theme is divided into several criteria. There are 26 criteria in all covering the key elements of a health and safety risk management system (see Table A.1).

4.3 Maturity scale

RM3 uses a five-point maturity scale to provide an assessment against the criteria (see Figure 4).

Figure 4: Maturity scale Figure 5: Assessing evidence

(credit: Risk Management Maturity Model (RM3), Office of Rail and Road)

4.4 Criteria and evidence

When making judgement, assessors should consider consistency of evidence, quantity of evidence, quality of evidence, and currency of the information (see Figure 5).

4.5 Maturity descriptors

Each of the 26 criteria has several maturity descriptors against which evidence can be judged. For example, for ‘Excellence’ in Leadership:
Maturity descriptors for ‘Excellence’ in Leadership - SP1
Culture: Leaders recognise they have an obligation to foster the kind of organisational climate where people find it easy to speak up and share when they have made mistakes rather than covering up errors.

Leaders at all levels of the organisation demonstrate shared values which strive towards continuous improvement
Leaders search within and outside the organisation for opportunities to improve risk control in their area of the organisation, to ensure it is as effective and efficient as possible
Leaders always consider how they influence others, recognising that good leadership is compelling, not coercive
They pro-actively promote a positive culture and encourage H&S improvements in all areas of organisation
Leaders recognise that better H&S results are achieved through exercising power with, rather than control over, employees
Leaders encourage people and enable them to join forces and to participate as responsible individuals in a collaborative institutional enterprise
Non-technical management skills development is recognised as world-class
Leadership demonstrates and reinforces the values and culture of the organisation and ensure these lead to engagement and empowerment across all levels

More generally, descriptions of excellence have been set for each of the five main areas of an effective safety management system (see Table A.2^[14].

5.0 Application in civil and/or structural engineering

What might this all mean for civil and/or structural engineering designers?

5.1 General

These designers often work in different project teams and whilst individual companies may be building a safety culture each project team should be doing likewise. This requires good two-way communication and sharing between team members to create a learning environment; hopefully within a supportive framework.

Design and management should address the ‘soft hazards’ given in Table A.3 based on ‘Essential consideration of ‘soft hazards’ on civil and building engineers projects: a checklist for all those engaged in structural or fire engineering design’ (CROSS, 2022^[15]).

Figure 1 in BS 5975^[16] illustrates the complex web of relationships that can exist on building projects, and stresses the need for clear co-operation and teamwork. Some permanent works designers can need reminding, as stated in BS 5975, Clause 8.3.1, that they, “should address the buildability of the permanent works and identify, and make provision for, any temporary works and temporary conditions required by their design and their assumed method of construction.”

Designers should establish robust processes for checking all designson projects of all sizes. Calculations should have both the correct input related to the project assumptions and the output, especially when carried out by computer, should be checked by an appropriately competent individual.

Interdisciplinary understanding is important as well as trusting members of the design team from other disciplines.

5.2 Adapting RM3

It is considered that RM3:

Usefully defines what excellent health and safety management ‘looks like’
Whilst developed in collaboration with the rail industry, it is considered sufficiently generic to be used by civil and/ or structural engineering designers
If used, it should be amended to include the consideration of ‘soft hazards’ (see Table A.3)
Could usefully be supplemented to cover temporary works and the key recommendations set out in BS 5975: 2019 (see Table A.1, Notes)

6.0 Closing remarks

The aim of this article is to encourage civil and/ or structural engineers to be more confident in their views on ‘safety culture: what it is considered to be, what it ‘looks like’ and what it might ‘feel like’. Other safety maturity models are available. Whatever you think of this one, or indeed others, have a ‘safety conversation’ with your work colleagues. Without this, nothing will change.

References

Building a Safer Future, Independent Review of Building Regulations and Fire Safety: Interim Report, December 2017 [p3, Overview]
Building a Safer Future, Independent Review of Building Regulations and Fire Safety: Final Report, May 2018 [2.13]
Ibid, Para. 10.15
HSE Research Report 367, A review of safety culture and safety climate literature for the development of the safety culture inspection toolkit
Advisory Committee on the Safety of Nuclear Installations (ACSNI: HSC, 1993) 3 Lord Cullen in the Ladbroke Grove Inquiry Report Part 2 (HSC)
Lord Cullen in the Ladbroke Grove Inquiry Report Part 2 (HSC)
Bradley Curve
Risk Management Maturity Model (RM3), Helping the rail industry to achieve health and safety excellence
ORR notes that RM3 is, “… not an audit or compliance tool but a model to structure discussions about evidence and where to go next, either internally in organisations or between inspectors and the organisations we regulate …”.
HSG65, Successful health and safety management (HSE, 2013)
The model provides a consistent way of evaluating the management arrangements required by the Management of Health and Safety at Work Regulations 1999 (MHSWR)
Examples include Baker Report into the Texas City explosion; Haddon-Cave Nimrod Review; Walker Report into Governance within the UK Finance sector; UK Government report into the collapse of Carillion; Aircraft Accident Report 1/2017 Hawker Hunter T7 G/BXFI on 22 August 2015; Emerging findings from the Grenfell inquiry and RAIB investigation reports
The revised RM3 2019 criteria have been validated against BS ISO 45001:2018, Occupational health and safety management systems
RM3, Page 9
Essential consideration of 'soft hazards' on civil and building engineering projects, John Carpenter, CEng, FICE (CROSS, 2022)
BS 5975: 2019, Code of practice for temporary works procedures and the permissible stress design of falsework (under revision) (BSI, 2019)

Bibliography
HSE: Safety culture on the Olympic Park, RR942 (2012)
HSE: Preventing catastrophic events in construction, RR834 (2011)

Appendices

Table A.1: Key elements of a health and safety risk management system
Health and safety policy, leadership and board governance – SP ^{See NOTE 1}
SP1 Leadership SP2 Health and safety policy SP3 Board governance SP4 Written safety management system
Organising for control and communication – OC ^{See NOTE 2}
OC1 Allocation of responsibilities OC2 Management and supervisory accountability OC3 Organisational structure OC4 Internal communication arrangements OC5 System safety and interface arrangements OC6 Organisational culture OC7 Record keeping, document control and knowledge management
Securing co-operation, competence and development of employees at all levels – OP ^{See NOTE 3}
OP1 Worker involvement and internal co-operation OP2 Competence management system
Planning and implementing risk controls through coordinated management arrangements - PI and RCS ^{See NOTE 4}
PI1 Risk assessment and management PI2 Objective / target setting PI3 Workload planning RCS1 Safe systems of work, including safety critical work RCS2 Management of assets RCS3 Change management, operational, process, organisational and engineering RCS4 Control of contractors and suppliers RCS5 Emergency Planning
Monitoring, audit and review – MRA ^{See NOTE 5}
MRA1 Proactive monitoring arrangements MRA2 Audit MRA3 Incident investigation MRA4 Management review MRA5 Corrective action
NOTES: For those designers involved in ‘temporary works’ the following, from BS 5975: 2019, should also be considered: Policy; Temporary works procedure; Designated Individual (DI) Job descriptions; Appointment letters – Temporary works coordinator (TWC) and Temporary works supervisor (TWS) Incident reporting (including CROSS); Education and training; Refreshers; Learning and sharing; Competence assessment(s) Identify temporary works (TW Register); Design brief; Design checking (Design check category), Design certificate, Design check certificate; Implementation plan (Implementation risk); Risk assessment and method statement(s) (RAMS); Hold points (Permits to work); Inspection and test plans (ITPs) – Inspection and Checking; Referral to Permanent works designer (PWD) and/or Temporary works designer (TWD); Sub-contractor selection Leading and lagging indicators; Learning and sharing

Table A.2: Descriptions of excellence or each of the main areas of an effective safety management system
Health and safety policy, leadership and board governance
The organisation’s policies are visionary, based on solid evidence of what the organisation can achieve, and promote a consistent approach to health and safety at all levels of the organisation Leaders of the organisation set and communicate clear direction that reinforces a consistent approach to health and safety and shapes the day-to-day activities, as well as striving to continuously improve risk control Leaders at all levels of the organisation act in a consistent way that reinforces the values, ethics and culture, needed to meet their organisation’s objectives The leadership style throughout the organisation is transformational, as opposed to transactional
Organising for control and communication
The organisation is structured to help put its policies into practice, as efficiently as possible There is a clear understanding of how each person’s role affects the organisation’s ability to achieve specific goals and the overall objectives The organisation provides the framework for using people, plant and processes successfully Communications up, down and across the organisation are highly effective Communications from management should be appropriate for the target audience. The right message should be received at the right time, by the right people, and through the appropriate channels
Securing co-operation, competence and development of employees at all levels
Competences (knowledge, skills, experience and abilities) needed to work effectively, efficiently and safely, are understood by the organisation, with the right number of people, in the right place, at the right time, with the right competence Recruitment, selection, training and continued development focus on meeting the organisation’s objectives Employees are actively involved in developing processes and making the business successful and safe Employee representatives and trade unions are recognised as an essential means of employee involvement
Planning and implementation of risk controls through coordinated management arrangements
Organisations systematically implement procedures to make sure that the plant, people and processes are fully used, continually improving effectiveness, efficiency and safety to achieve the organisation’s objectives
Monitoring, reviewing and auditing to provide effective governance, management and supervision
Monitoring is an important part of the organisation’s management arrangements at all levels Performance measures and audit programmes are used to continually encourage everyone to achieve the organisation’s objectives and reduce risk to the business Variations from expected outcomes, are reviewed to understand where the organisation is failing and what corrective action is necessary, to restore and improve performance The organisation actively seeks opportunities to identify best practice from both within the organisation and from others across the rail industry
NOTE: Whilst some of the requirements mention ‘rail’ they are considered to be broadly generic

Table A.3: ‘Soft’ hazards
A ‘soft hazard’ is defined as a hazard which originates from the design, but whilst leading to a risk to others, does not lead to a work task on site. They are, in essence, design-related management issues. Several issues are identified as they are known recurring hazards that are often not well considered. On any project there may be others, and this possibility should always be considered.
Competency of the team
Based on the brief, both the individual and the team need to be competent Keep under review
Adequate resource
Provide sufficient resources (including time) taking account of fees and other commitments Consider unplanned change and the briefing of new staff
Thorough consideration of the ‘brief’
Ensure that there is an adequate design brief, reviewed by a competent person Identify clearly the scope of design, limitations, incomplete design, further information required, etc
Incomplete design/design by others
Identify incomplete design elements to key personnel Ensure that essential information is passed on, eg design codes, design data, interfaces, assumed construction sequence
Documenting assumptions
Assumptions should be identified and documented clearly - across all stages of the contract Document any monitoring and supervision required, assumed construction sequences (including temporary works), structural movement limits, etc
Interfaces: where risk thrives
Remove or reduce the number of interfaces whether physical or procedural. Identify gaps Ensure that interfaces are considered when considering constructability. Identify responsibilities
Change control
Ensure that any change follows an agreed approval and recording procedure and is appropriately approved Changes should be communicated to relevant parties and the process allow for the raising of queries
Value engineering
Establish and implement a value engineering policy that promotes improved constructability, whilst maintaining functionality, safety and quality Have a process in place for raising and resolving concerns Construction sequence and temporary works Ensure that an acceptable construction sequence is identified by the relevant designer(s) Temporary loads, eg loadings likely to exceed those allowed for in the completed structure; temporary conditions (eg intermediate instability) and temporary works should be identified
Standard of Building Regulation submissions
Building Regulation submissions should be clear, comprehensive and easily understood
Checking
Design should be subject to an appropriate level of check and approval Where identified, under an independent peer review
Disproportionate collapse considerations
As required, consider disproportionate collapse Ensure that any provisions are identified clearly
Gateways
As required, ensure that any gateways are adopted, whether statutory or not Time for tendering, mobilising and constructing Within the limits of your control, ensure that there is adequate time available to tender Concerns as a result of inadequate time should be documented and communicated
Design competency of sub-contractors
Ensure that design work to be completed by others (eg design and build, steelwork connections, structural fixings, etc) is identified clearly and undertaken by competent sub-contracted designers Sub-contracted designs should identify key safety issues and identify any monitoring and supervisory arrangements necessary
Site supervision
Take reasonable steps to ensure that any design is subject to appropriate site monitoring and/ or supervision Identify and communicate whether additional measures are required for specific elements of work, eg sub-contacted work, during the construction phase, etc
Information for H&S File and Safety Cases
Contribute to the preparation of a Safety Case, whether required by statute (eg Building Safety Act) or identified as a risk management measure Take steps to ensure that appropriate information is provided for the CDM Health and Safety File
Maintenance and planned repair assumptions
Identify anticipated maintenance and repair, arising from the design Ensure any assumed access assumptions are set out in the maintenance access strategy (along with any significant residual risks) are made known to the client
De-commissioning
Take reasonable steps to ensure that issues relating to any design likely to be unexpected or difficult to control during de-commissioning is highlighted clearly Highlight clearly any assumed method of dealing with de-commissioning hazards, eg pre- and post-tensioned structures, interim stability issues, reliance on adjacent structures, structures that need to be de-commissioned in reverse order of construction
NOTE: The introduction to the SCOSS Checklist^[15] provides the following opinion: “… It is reasonable to suggest that designers should adopt the following advice [given above], unless good reason not to, and this is recorded …”.