Missing the Target
“There is an understanding that not all risks are equal in terms of the potential for causing significant injury, illness, or fatality and that a focus on those risks which, although occur less frequently, could cause the greatest harm to workers (“critical risks”) provides for a safer work environment for everyone.”
Government Health & Safety Lead (NZ)
One of the things to come out of the recent legislative consultation (in New Zealand) on the Health and Safety at Work Act is the focus on what have become known as Critical Risks.
The Government Minister leading the charge has stated that the New Zealand regulator, WorkSafe, should focus on these critical risks and seek out ‘over compliance’ (how you can over comply with “so far as reasonably practicable” is a discussion for later.)
I’ve got a few issues with the term critical risk.
Firstly, it lacks a legal definition; each organisation decides what they are, so everyone is talking a slightly different language.
Secondly, selecting which risks are critical is prone to the same level of bias and gaming as your standard risk assessment matrix.
Thirdly, critical risk programs have a strong focus on designing verifications to ensure ‘Officers’ that all is well, rather than improving work design through risk mitigation.
And lastly, and to me most importantly, it distracts from the risks faced by many of the vulnerable workers we are supposed to be protecting.
Critical risks in the context of health and safety management are usually some variation of ‘things that happen as part of work that will kill or have a serious, negative life-changing effect on someone”
Or what I would call low probability, high consequence events or more simply, shit that could kill you.
Seems perfectly reasonable, eh? Nothing wrong with that as an approach.
The issue is that using this as the foundation for your approach to health and safety management can result in misdirecting the limited resources of risk managers, including those in occupational safety.
Let me explain.
In recent history, I was somewhat taken to task for criticising International Men’s Day. I should clarify that it was the idea that a Men's Awareness Day is necessary that I was criticising, not that men, as part of the human race, shouldn’t have a safe, empathetic society in which to live.
Men live a life of advantage. Some men more than others, without question, but as a general statement based on how the majority of societies operate and men’s position within those societies, it is a fair one. This was reinforced for me recently while reading Minority Rule by Ash Sarkar. The descriptions given to the author by transgender men and women of their experiences pre and post their decision to live as their true gender. From descriptions of their lived experiences, it becomes clear that how people interact with those they perceive to be male is very different from how women are treated. There is an example in the book of a transgender male research scientist, who was told at a conference after a presentation of a long-term research project, that they were much more insightful than their ‘sister’.
One of the arguments that is raised in opposition to the idea that men live in a society designed by them for them, specifically related to the context of workplace health and safety, is that men are more likely to be killed or seriously injured at work. Therefore, it is implied that they are not afforded the same level of protection as other workers in a workplace or, at a minimum, that they work in higher-risk environments which require more organisational focus.
It is a statistical fact that more men die at work, but is it also reasonable to suggest that, due to ‘boy jobs’, to quote former British Prime Minister Theresa May, carrying a greater level of immediate and correlative risk?
The majority of high-risk occupations have traditionally had male-dominated workforces. Farming, forestry, mining, construction and trades are, while not exclusively male (thankfully) anymore, remain severely underrepresented when it comes to women. The only example of high-risk work, at least in New Zealand, where women are in the majority, that comes to mind is the emergency ambulance service (although only for those in frontline roles; management roles are still predominantly held by men). There is always an exception, eh?
“But why does this matter? Isn’t critical risk management about saving lives, all lives?”
That may be the intent behind the concept, however the reality is that women in the workplace may not be being killed at the same rate as men, but the evidence shows that they are employed in roles that cause high levels of pain and suffering; it’s just that it is both under-researched and even if it is often ignored when the issue is highlighted.
Karen Messing’s excellent book, Bent Out of Shape. Shame, solidarity and womens bodies at work, provides insights into the fact that while ‘boy jobs’ have for many years been the focus in terms of reducing physical risks we have now reached the point that, work traditionally done by women, such as cleaning, caring and intricate production line work in manufacturing are now associted with greater occupational safety risks, than those carried out by men. The perception that men undertake riskier work doesn’t match the reality of many workplaces. It is true, though, that ‘boy jobs’ are more visible and therefore gain more attention.
Work done traditionally by women and increasingly in the modern workforce, minority groups, cause significant harm to those workers; however, it doesn’t grab public attention, or have the visibility of male occupations, so it creates few noticeable ripples.
I’m not saying that the fact that critical risk management predominantly addresses risks present in male-dominated environments is the only reason the approach has been successfully promoted and accepted as the ‘right’ approach. Still, it is not a massive leap to consider it a factor. It is also reasonable, I think, to suggest that men have a louder voice, greater opportunities to use it and are more likely to be heard by other men, including those in power, than many other societal groups. The use of new tools like A.I. are only making the issue worse due to the inherent bias in these models.
Few headlines have been written about the long-term effects of poorly designed work. It is hard enough to make an impact on the news cycle if one person dies in a workplace. Mass casualty events are needed before society notices and demands change. This leaves the type of long-term illness and injury suffered by those in low-paid work, the majority of whom are women and minority groups, largely ignored.
During Covid, Karen Messing’s book highlights that 76% of workers classed as essential and 73% of healthcare workers who became infected with the virus were women.
In manufacturing environments, it is often the case that those maintaining the equipment (typically ‘skilled’ men) are more likely to be exposed to what are usually classed as critical risks. Those performing technical, repetitive manufacturing work are carrying out tasks at ever-increasing speeds to meet the relentless pursuit of efficiency, often in work environments designed for an average person who doesn’t exist and suits no one.
Heavy industry and other traditionally male work environments have rightly improved conditions in an effort to reduce the physical impact of work on its staff. This drive for improvement has been much slower to materialise in environments where, it is assumed, often wrongly, that the impact of the role on a worker’s health and safety is minimal.
These roles (stupidly and incorrectly labelled as ‘semi-skilled, low or unskilled) are undertaken, often by those on low wages with few other options and limited influence over the design of the work. The work might not kill them in the same way workplace statistics highlight, but low risk, it is not.
All organisations need to prioritise. There will always be a need to prioritise resources. Difficult decisions need to be made based on the type of work an organisation does, but focusing on critical risks isn’t prioritising. It’s exposing vulnerable workers to long-term adverse physical and mental health effects, and can lead to overlooking occupational safety risks that affect vast numbers of workers.
Who is doing the work is essential knowledge when assessing risk. Physical capability, size, age, language, influence, and background (among many other factors) influence the risks present and how they are managed. Assigning an arbitrary title, such as labelling something a critical risk, reduces the ability to learn and develop context-appropriate, safe, and healthy work practices.
Humans are terrible at long-term thinking. We easily ‘get’ the idea of critical risk, especially when it relates to an immediate, relatable outcome, but we struggle with assessing long-term impacts. If you don’t believe me, try having a conversation in an open forum about climate change.
The majority of the harm caused by work is long-term in nature. Some of that harm isn’t immediately predictable, so if we are always focused on critical risks, these will slip past us until it is too late (silicosis, anyone?)
If creating better workplaces is the aim, then prioritising your occupational safety resources in such a way that builds better work for all, not just the roles that have been decreed to include risks that meet your definition of critical.
Lots of you are going to read this and tell me, “but Mick, you are wrong, we haven’t ignored our long-term risks in our critical risk program, and we would never approach risk management with a gender (or other) bias” and I honestly believe you think you haven’t, I really do.
I know this, because I never thought I would either…. (or I might be wrong, it wouldn’t be the first time and won’t be the last)
I wait with anticipation to be assigned the ‘woke’ tag, as if it were an insult.