Legal Obligations for Worker Engagement
It is a legal requirement in most jurisdictions to actively involve workers in health and safety. While employers have some flexibility in determining how to fulfil this duty, legislation and regulations often suggest appointing formally trained Safety Representatives and forming Safety Committees as primary methods.
This approach, though understandable, raises concerns about its effectiveness. Based on my experience with numerous employers, Safety Representatives often start with enthusiasm but soon become uncertain about their roles, leading to minimal action. Similarly, Safety Committees tend to struggle; without active engagement from the safety team or management, these committees rarely make a meaningful impact on overall safety and risk management. In most cases, only a few members actively participate, while others remain silent and fail to communicate safety issues back to their colleagues. Even recruiting committee members often requires considerable effort, as many are reluctant to join.
What is the Problem?
I am suggesting that the problem is not if workers must be involved, but what should they be involved in. The current approach is all too often attempting to involve the workers in the safety bureaucracy: increasing near miss reporting, reviewing incident investigations, training completion rates, inspections and audits, and even purely management activities like compliance and legal requirements as well as policy updates. Almost as an afterthought, the last point on the agenda is often worker concerns and suggestions.
I am not convinced this is what the regulations meant, even though the regulator often does not even think this through and settlers for the traditional approach.
The Need for a New Approach
This raises the question: do we need to change our approach? While compliance with legal requirements is non-negotiable, it is worth reconsidering whether these forums genuinely achieve the intent of the legislation and regulations. The critical question is how best to utilise frontline workers’ experience and wisdom to ensure safe work practices.
The short answer is, by involving them in performing work safely. Not in more paperwork, or policies or safety activities. No, in simply allowing them to do their work safely.
In my book, Safety 2.1: The Safety Envelope, I argue that management often over-prescribes behavioural controls when determining risk control measures. Instead, I propose that organisations should focus on ‘hard’ controls—measures that do not rely on human actions, such as engineering solutions. These controls should reduce safety risks to a tolerable level (as low as reasonably practicable), after which frontline workers can manage the remaining risks within what I call the ‘risk envelope.’ Thereafter, the workers should be empowered to independently decide how to operate safely within this predefined boundary.
This level of involvement allows frontline workers to discuss and determine amongst themselves the safest way to perform their tasks, and whatever they decide is what they implement. Management—and the safety team—must step aside, granting them the autonomy to decide.
Preparing Workers to Manage the Risk Envelope
This approach does not mean leaving workers unsupported in deciding how to perform their work safely within the safety envelope. Organisations should prepare workers to manage these risks by:
- Providing a safe work environment and the necessary tools to perform tasks effectively.
- Training workers to ensure they have the knowledge and skills required for safe work practices.
- Fostering a safety culture where adherence to safe practices is the norm.
- Maintaining a work environment that supports mental well-being and minimises stressors.
A Shift in Safety Decision-Making
Let me repeat this approach in safety terminology: the organisation does not dictate all ‘standard operating procedures’ or ‘safe work methods.’ Instead, after minimising risks primarily with engineering controls to a predetermined tolerable level, it empowers workers to determine the safest ways to complete their tasks. This decision-making can occur formally, such as through a safety committee run by – and for – the workers, or informally during interactions like toolbox meetings or spontaneous discussions at the start of a task.
These decisions are often undocumented, and adherence enforcement happens within the group rather than being imposed by management. This concept aligns with principles of group dynamics, where teams naturally establish and enforce their own internal rules. By providing the necessary space and trust, organisations can rely on frontline workers to manage their safety behaviour within the safety envelope.
While this approach may seem counter-intuitive or challenging, trusting frontline workers can lead to genuine involvement in safety decisions—far beyond the limited impact of traditional committee meetings. This shift not only engages workers more effectively but also fosters a culture of ownership and accountability in safety practices. I explore this process extensively in my book, Safety 2.1: The Safety Envelope.