Manufacturers can have procedures, risk assessments and training records in place and still find that the way a job is being carried out has changed, explains Josh McNicholas from Evalu-8…
A recent HSE prosecution is a good example. The company was fined £800,000 after a worker suffered burns while disposing of waste pyrotechnic material.
HSE found there was no suitable risk assessment or safe system of work for the method being used, suitable PPE had not been provided, and the activity was taking place in an unlicensed part of the building.
One part of the investigation stood out.
The business already had an established method for disposing of the material, but that was not the method being used when the incident happened. HSE found that another, unapproved method had been used informally on a number of occasions over several years.
For a compliance manager, that is the part I would be looking at.
Does the procedure on file still match the way people are doing the job?
When a workaround becomes normal
Workarounds can start for fairly ordinary reasons.
A piece of equipment is unavailable. A particular area is occupied. Production is busy. Someone finds another way of completing a task and nothing goes wrong.
So they use the same method again.
Other people see it being done that way and start doing the same. Someone joining the team may even learn the workaround from a colleague before they ever see the written procedure.
Eventually, the business can end up with two versions of the same job: the approved version and the version people actually use.
The unofficial method may never have been assessed. It could introduce different hazards, require different PPE or involve equipment being used in circumstances it was not designed for.
Once people have done something the same way for long enough, it can stop feeling like a deviation.
“We’ve always done it like this”
If someone has completed the same task hundreds of times without an injury, it is easy to understand why they might see little reason to change it.
But previous experience does not prove that the risks are properly controlled.
A risk assessment can still look perfectly reasonable on paper even though the work taking place on the factory floor has changed.
The problem is not always the document itself. Sometimes the document simply no longer describes the job.
Look at the work, not just the paperwork
Audits and inspections need to look at what people are actually doing, not only whether the right documents exist.
Is the equipment listed in the assessment being used?
Is the work being carried out in the correct area?
Are the stated controls practical during a normal shift?
Has machinery, staffing or the production process changed since the assessment was completed?
The people doing the job will usually know where the process causes problems.
Experienced employees often know which parts of a task are awkward, which controls are difficult to use and where people have found their own ways of getting the job done.
That does not automatically mean someone has ignored a procedure.
A repeated workaround may point to a process that needs updating. In other cases, it may uncover an unsafe method that needs to stop.
You need to spot that difference before it becomes an incident.
Do not wait for an accident
A serious incident should not be the first indication that people are working differently from the approved method.
Near misses, equipment damage, inspection findings, employee concerns and repeated deviations can all show that something has changed.
If the same problem keeps appearing, look at why it is happening.
The equipment or production process may have changed since the assessment was written, or a control may no longer work well in practice. People may also have started showing colleagues a different way of doing the job, so the process changes over time without anyone formally updating it.
That is often where the gap between the procedure and the real job starts to show.
Keeping track of what changes
Keeping risk assessments, inspections, actions and employee acknowledgements together makes follow-up easier.
Evalu-8 EHS Software allows businesses to keep those records in one system, so issues identified on site can be recorded, assigned and tracked.
But none of that replaces seeing how the job is actually being done.
One of the most useful things a manager can ask is:
“Show me how you actually do this job.”
Then compare it with the approved procedure.
If the two are different, find out why.
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