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As a recent theoretical exercise, I asked ChatBot GTP to write a health and safety management plan for the Canterbury Safety Charter. This seemed a perfectly reasonable request, as a lot of information about the Charter can be found online, in addition to a lot of information about the requirements of a health and safety management plan in New Zealand. Mr ChatBot duly responded, and a document was produced in a matter of seconds which complied fully with HSWA 2015. I could also ask it to give me a whole lot of templates to complete my paperwork requirements, though I suspect it might struggle to fill them in for specific circumstances.
Is this the future of health and safety compliance, and can AI replace a lot of menial repetitive administration tasks we currently do? Where does administration stop and creative problem solving, and change management kick in?
A recent post on LinkedIn also caught my attention from Dr Paul Reyneke, who described himself as a semi-retired Health and Safety Professional. The article had over 80 likes and 18 comments all basically agreeing with his sentiments, so he seems to have struck a chord with a lot of people in the industry.
His main points were.
- The declining “obsession with ‘Zero Harm’, except for NZTA.’
- That Safety 2 is not much different from safety 1. “We involve frontline people more and more in designing and implementing ‘safety culture’, as if their closeness to the frontline makes them experts in how you define and change culture. It is as if we concede H&S is not a science and there is no ‘expertise’ involved.’
- There is an increase in the bureaucratization of safety. “An ongoing obsession with procedures and rulemaking and increasing number of JSAs, SWMS, TAs, Bowties and SSSPs etc.. We talk the Hierarchy of Control talk, but the emphasis is still on administrative controls.”
- “The role ‘clients’ and ‘principals’ play as de facto regulators, in particular in contracting. They are often not the experts in the contractor’s technical field but require the contractor to provide high levels of detail in the contractors’ risk assessments and controls as part of the contractor’s ‘pre-qualification’. It is not uncommon for a Site-Specific Safety Plan (SSSP) to be 80 to 100 pages long.”
I think I agree most with his sentiments on the bureaucratization of health and safety and the amount of documentation required for both pre-qualification and safety plans. I am not so sure about less expertise of health and safety culture within frontline workers, but I do recognise that there is a natural tension between the theoretical “scientific” aspects of health and safety and the pragmatic things that are done on the ground.
Are we allocating too much time and resource on the paperwork, and less than we should on the areas that have the most impact? The answer may involve simplification of health and safety documentation and having organisations spend more time at the apex of the hierarchy of controls, rather than at the administrative and PPE level. Can we utilise technology to undertake more of the repetitive documentation processes and leave humans to create the culture of health and safety.
The critical thing to realise is that the existence of my ChatBot documentation in no way made the organisation a safer place to work. You can have all the plans and policies in place, but are they working as you intend?
Perhaps the first step in the process is verification. How much time do we spend on verifying our systems, and is it more or less than the time spent on creating, documenting, and administering them? The act of verification provides a natural feedback loop where changes can be made based on actual observation. It enables communication and engagement with frontline workers, and the opportunity to comment on what works and what doesn’t.
A small number of steps working very effectively will always beat a large number not working at all….
Paul Duggan, General Manager
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