Regulation, principle 2 of managing for safe behavior
Tension in Management Philosophy
A management philosophy addresses questions such as who or which level in the organization takes responsibility for a particular process. The integrated management model advocates for delegating responsibility through the chain of command to the lowest possible level in the organization. This means a safety policy that is primarily bottom-up aligned with employee behavior. At the same time, society is increasingly holding executives (personally) liable, especially for the effects of their policies on the environment. Safety and the environment are critical elements of the ‘license to operate,’ requiring attention and responsibility from the top. Therefore, management must organize certain elements of the safety policy top-down.
No Blueprint
There is no blueprint for how liability and responsibility relate to each other. Each management team must answer the question of where each element of the safety policy will be placed. The higher the responsibility lies in the organization, the more uniform that part of the policy will be. The lower the responsibility lies in the organization, the more customization can be provided to align the policy with work processes. Determining this mix of uniformity and diversity is a matter for a management conference.
Head Office Guidelines
There are global differences in how the management philosophy is implemented. International companies with a parent company, especially in Australia and the United States, prefer to position responsibility high in the organization. They formulate guidelines that everyone in the organization must adhere to, regardless of local conditions. For example, an incident at one location can lead to a rule for the entire organization. Thus, each location is provided with mandatory solutions for non-existent problems. This leads to alienation from the safety policy and a pro forma introduction. While liability at the top is covered, this comes at the expense of the credibility of local safety departments and their policies.
Audits
Covering liability also involves regular audits. This audit focuses more on the paper implementation of regulations than on the impact of the rules on process management. A QESH department takes at least a week to gather all the paperwork for an audit and another week to give auditors the opportunity to audit. Although many questions are asked, the essential ones are often forgotten:
- Does each individual rule contribute to making the organization safer?
- Does the package of rules align with the organization’s management philosophy?
- Is there also an audit of the auditing process, meaning, do the auditors focus on the right things, and does auditing in this way add value?
Back to the essence, why did we have rules in the first place?
Is the rule the best way to regulate behavior?”
