Removing barriers to lung health and compliance issues

Dr Tristan Casey: So, I'm conscious that I'm standing between you and lunch today, but what I wanted to do is tell you a little bit of a story, a story about where compliance comes from, and then leverage that and think about, "Well, what's an alternative way of looking at compliance that might give you some ideas about how to punch sort of the safety plateau and get some additional benefits from your safety performance?" Okay. So I'm from the Safety Science Innovation Lab, and this is the stuff that we specialize in, is coming up with ideas to improve safety in industry, so hopefully you can take away a couple of things today. This is a fancy graph and it's from Google's Ngram and what it shows is the increase in the percentage of words that have compliance in them. So books, publications, stories, anything that Google can index, it shows that compliance is basically on the rise.

And we see that over the past sort of 30, 40 years, compliance has become more of a prominent thing in our vernacular. We're talking about it more. We're writing about it more. It's becoming a more established part of how we do business. Other publications show that the percentage of the Australian market that concentrates on compliance related jobs is also increasing. So this graph is from Deloitte and shows that roughly over the past 20 years or so, we've seen a jump from around five and a half percent up to nine, 10 percent of jobs have some sort of compliance role attached to them. So even in the job market, we're seeing a rise in compliance activity. Again from Deloitte, this is showing the cost of compliance. So this report sort of highlights the fact that we're spending more on compliance and funnily enough, over half of that amount is actually spent on self-imposed compliance.

So things that aren't necessarily required by legislation, but nevertheless, we're still doing it. So we're still doing these things that are maybe not adding as much value as we might've hoped, so 250 billion is the combined cost of compliance in Australia. So why have I got a picture of a plateau? Well, many of you probably heard that phrase, "The safety plateau," this idea that we've had a lot of gains in terms of maybe engineering based approaches to safety, then we've moved into the safety management systems era. Then we move into culture, safety culture being another sort of era of safety science, and what we're seeing then is a bit of bouncing around. We got our safety performance down to a good level, but what we see is this sort of bouncing around, this sort of sweet spot, we can't penetrate that layer any further and we're getting frustrated.

We're not getting to the sort of Nirvana of complete compliance or complete removal of safety incidents and organizations. So today, here's, I guess, an idea that maybe we need to change how we look at compliance, how we look at this idea of following rules, following processes and adopt a more nuanced, more intricate view of what compliance actually is. So I see this presentation as being a nice little summary of what we've heard today so far, and I'll be the first to admit I'm not an expert in Asbestos, but I'm certainly an expert in behavior and cultural change so hopefully you can walk away today with a few little snippets of things that could help you as you go about improving compliance in your organizations.

So what does it mean to comply? Well, if you look at the dictionary, there's a few kind of standard meanings. In fact, actual fact of complying with the wish or command the state of fact according to meeting rules or standards. And an interesting one is this sort of idea of acquiescence, that we're sort of unwillingly going along with the impositions of someone else. You know, maybe a leader, maybe an authority in our organizations. This sort of... I guess, if you asked a worker what compliance was about, they would probably resonate most strongly with this idea of acquiescence. We sort of do it because we have to. We do it because it's legislated or we'll get in trouble if we don't do that compliance. So that's really the dominant way, I guess, if we ask the workers what they thought of compliance,

So compliance is all about power. It's about an authority, someone in charge, maybe imposing a right way of doing things or a standard way of doing things on other people. Some of the, I guess, assumptions or philosophies underpinning the traditional approach to compliance, people are a liability, they, there are error prone, they make mistakes and so we need to control them. We need to make sure that they're following things as prescribed, that someone else might know a better way of doing things. That we've got perhaps codes of practice and experts that have spent years and decades looking at this stuff. And that there really is one ideal way of doing things. So we write that up in a procedure and then we try and enforce compliance against that one ideal way.

So some of this of course is true. There's certainly a great value of having experts, of having procedures, of having standardized way, but is there an alternative? Is there an additional way that we should be strategizing our compliance to break through that plateau and achieve even better performance? So where does compliance come from? Well, if we go back to the Industrial Revolution, sort of the turn of the 1900s, we see Frederick Taylor come out. That's the name that's widely cited, this idea of scientific management. So before the 1900s, the dominant explanation for why accidents happen was really down to maybe divinity that someone's just had a bad stroke of luck, or they've been a bad person potentially, and there's a punishment that needs to be applied from someone outside. So there is a real lack of determinism when we come to humanity's role in preventing accidents. Fast forward a little bit to the Industrial Revolution and the Scientific Revolution, The Enlightenment, we started to think about humanity's role as much more prominent in our environment, so we can do more to prevent accidents from occurring.

Now, good old Fred, he really liked rules and procedures and standardizing things. And they found a lot of benefit in those manufacturing environments through decomposing tasks into little steps, optimizing each one of those steps, putting them all together, and then enforcing the compliance against that one sort of prescribed way of doing things. It's not to say that's all bad. It certainly helped us from a productivity perspective, as well as from a safety perspective. The safety one kind of approach, this idea of procedures and rule following and standardization has resulted in massive gains, but arguably there're some limitations with that as we move further along, and I'll go to that in a moment. So we can think about the tayloristic approach as being what's called a model one view of compliance. So model one has a few characteristics, we're either compliant or noncompliant. There's really no grey area.

There's no different types of compliance or levels of compliance. It's an either or situation. It's really treated as a situational thing. If this situation occurs, then do this. So it's sort of like a prescription for people to follow. Safety results from more procedures and closer following of the procedures, that's sort of the implicit assumption. And sometimes giving people discretion, giving them autonomy, is a way of eroding safety, so it's a bad thing. We don't want people to sort of go around or deviate from those procedures. So that's model one, sort of the traditional way of looking at things. Problems with model one, some limitations of this traditional compliance approach. Well, we can put rules in place simply to satisfy a regulator or a certifier or an auditor, and not really make a difference when it comes to operational safety. We can become burdened with bureaucracy, too many rules, too many processes, too inefficient.

If we follow all the rules, maybe we'll never get anything done. And we've seen some examples of that in the aviation industry with pilot strikes and they follow all the rules and that creates massive delays. Once we have a lot of rules, innovation becomes harder and assumes that stability is achieved through more constriction. So more rules, more limits on behaviour, not through flexibility, not through adaptation, not through improvisation, so that's sort of one of the limitations of model one. Why is it no longer enough? Why do we need to look at something alternative? Well, there's a lot of things that are changing with the nature of work and the way that we do things. So there's more uncertainty, there's more competitive pressure, there's more interdependencies when it comes to different teams working together. Say in a construction project, you've got a lot of different stakeholders all working collaboratively.

Interactions, so unexpected ways that people can interact and sort of work on top of each other or influence each other's work processes. And importantly, our systems are becoming so safe that the LTI, the focus on the negatives that really is a hallmark of model one, what people are doing wrong, is dropping to such a point that we're not getting much information back. Our incident rates are dropping statistically. We can't do much with that data. We're not getting the learnings that we need.

So model two, what's the answer? What's some ideas that we could start to float around to see, well, what next? What do we do to cope with all these different issues, these challenges? Well, this is a model that is developed by a colleague at QUT, and it sort of starts to take a more nuanced view on what compliance actually is. Of course, we have violations and we can even further decompose a violation into maybe something that was purposeful versus non purposeful. We have surface compliance, so just going through the motions, applying the procedure because we have to. We're not really thinking too deeply about it. We have deep compliance, so this is probably a nirvana for safety performance. We want people to start thinking very deeply about, how do they use that procedure in that setting? How do they make the most of that resource they've got to protect themselves and others?

And the interesting part is adaptive compliance. How do we create the capability in our people to be flexible, to be autonomous, to notice when the rules don't make sense or don't apply or don't fit the situation, or there's no rule at all, and yet still be successful when they are achieving their safety, their productivity, their quality goals? So four different takes on what compliance could look like. So what conditions, what do we need in our organizations to kind of make compliance get the bang for buck when it comes to compliance? And there's a psychological theory called self determination theory. This really gets to the heart of, how do we get people to want to comply rather than have to comply? Now there's three little ingredients that we need. There's autonomy, belonging, and competence. If we supply those little psychological ingredients to people, they're more likely to adopt those goals, adopt those procedures, adopt those rules and follow them because they want to.

So autonomy, it's about involving people in development of those procedures, giving them a voice to help feel like they're contributing to the rules that they're being asked to follow. The belonging part, they feel part of a team. They feel part of the safety department. They feel part of being able to voice concerns about when procedures don't work and they're listened to. And competence, not only are they given opportunities to be educated and upskilled in the procedures and the training, but also their competence is recognized. So maybe for an expert, the procedure becomes a resource, whereas for a new person, it becomes more of a prescription. This is exactly what you need to do step by step, whereas an expert, this is the general goal. Stay safe, handle Asbestos in a certain way, but we'll allow you to figure out the best way to accomplish that task.

So other things that we can do to foster compliance is separate out the way that we talk about our work goals. So on the one hand, we can talk about work goals in a high risk setting as being about prevention focus, highlighting the dangers, highlighting the risks, talking about what could go wrong. That sets a certain psychological mindset. Or when we want innovation, creativity, flexibility, adaptation, we talk more about, how can you contribute? How can you be empowered to make a decision about the procedure? How can you share some feedback on how to innovate and make a new procedure that's even better? So it's about how we frame up our goals and how we interact as leaders with our people. Some additional kind of recommendations or ideas, we want to use what's called full range safety leadership. So what this means is we don't have sort of a personality type as a leader where we just do one type or one style, but rather we utilize the transactional type behaviours, the carrot and the stick when we need to, but also more transformational, empowering, and even what we call servant leadership.

So empowering people to have a voice at the table, providing them with equipment and resources, and really coming down to their level and working with workers to understand, "Well, how do we make sure that that compliance is achieved? What else do you need to make that procedure relevant and useful to you in your job?" We need a safety climate, but not just the typical prevention climate that focuses on compliance and rule following, but also about involvement in practices. So how do we empower people through participation, through consultation, through contributions to making those rules better as well? There's two different types of safety climate. Building that job expertise and confidence, so allowing people to learn how to use the procedures, buddying them up with mentors, allowing them to interact and observe how those procedures are implemented. And another factor is perceptions of procedure usefulness, so when it comes down to designing them, are we utilizing the attitudes, the perceptions, of our people when putting those procedures together?

So a little bit of a model to guide compliance. So what this is... Again, taking all these ideas, wrapping them up and presenting some ideas about, "Well, how do we tackle compliance in different types of situations?" So when it comes to high risk Asbestos work, we utilize our traditional methods, compliance and scripts, sort of like a safe work method statements are very proceduralized, standardized, traditional ways of managing things. We still do that. That has a time in place. But rather than implementing that as a blanket across all different types of work, we're a little bit more flexible, and we think, "Well, okay. When things have gone wrong, when we've made a mistake, the focus should be on learning." So compliance is more about adapting, improving, making incremental adjustments to the procedure. So that again, it fits the situation more effectively next time people encounter it. When we're doing our low risk, sort of business as usual tasks, things that don't really carry a high risk, maybe compliance becomes more about goals.

Say, "I want you to demolish this particular structure. We know there's very minimal risk of Asbestos. We've tested everything. We just give you a general goal and the resource of the procedure if you need it, but not the prescription." Don't do every task exactly the same way, but give them the principles they need, the goals, the guidance to make that clear and allow them to flourish and be technically excellent at what they do. And the last situation when there's opportunities to pursue, maybe we've won a new tender. Maybe we've won a new job where we know there's going to be a Asbestos there, let's get a group of workers together, engage with them and actually do compliance as innovation. How do we adapt or adjust our existing systems and procedures and processes to fit this new context and really engage with people meaningfully to make them part of the solution?

So what can be done? A little bit of a practical takeaway. When trying to achieve decompliance, we create the emotional connection. We create the sense that this is a risk. This affects me. This affects potentially my family, my partner, the personal life outside of work, and really highlight what could go wrong. What are the potential consequences and how severe can they be? So, our approach becomes one of prevention and highlighting risk in the workplace. We want to achieve adaptive compliance. We encourage reflection. As leaders,, we maybe get a post-project review together. We get a learning team together. We ask people to share their experiences good and bad, what works, what didn't, and sort of that psychological safety that allows people to speak up and be honest. When we want to achieve innovation, what we do is encourage people, emphasize how they can contribute to our vision, our goals, our company's success.

We want you to contribute directly to making us the best construction company there is, and that includes working safely and effectively with this Asbestos. When we want to achieve flexible compliance, so this idea of the routine business as usual, we highlight general goals. We say, "Hey, there's no swims that apply here. There's no real specific procedure that applies here. We want you to figure out the best way to do the job. You've done it 10, 20, 30 times before. It's routine. Show off your skills. Be effective, be efficient and be safe," and also highlight the boundaries and non-negotiables. What sort of the freedom within a framework we can give people to say, "This is okay. This is not." The line that joins the dots between is up to you to figure out how to tackle that job most effectively.

Applying to safety behaviour, as I've said throughout, drawing on workers is a big approach of mine, so that consultation that's part of the other legislation and good practice when it comes to safety management. If we come up with innovative solutions using workers, we might negate the need for those ineffective or less effective procedural PPE controls. We might eliminate that has it all together. When we do need to go for those administrative PPE approaches, we engage workers to actually get them to be part of the solution. So giving them options to try, allowing them to have ownership, allowing them to have autonomy to choose the right gear that fits them, and actually makes the job easier, not harder. And lastly, trust is not to be underestimated. When we build trust in our organizations, people are going to tell us when they don't comply and why.

How many times have you kind of gone and observed a work process and people have covered up things, or maybe not been honest with you around what they're doing and what they're not doing. When you have trust, when you move away from blame and punishment and more towards learning and restoration, you start to get some wonderful results.

So key takeaways, model one focused on reducing negative outcomes of failures, monitoring, and enforcement. We need that for some situations, of course. Model two, creating positive capacity for success. So it's more of the safety to, safety differently, new view of things. There're some situations where that can be really effective as well. The key difference between the two is how we treat noncompliance. Model one, we need to remove the deviation, get back to where we need to be, perhaps through punishment, perhaps through reward. Model two, more about engaging workers, getting them to be part of the solution. And in reality, we need both forms to make safety even better. That's me. Thank you very much.

Speaker 2:

Some questions for a Tristan. You might've got off lightly. I'll start with just one quick one. This is about buy-in, this is about encouraging people, and I think you used the term in one of the slides to belong, to be part, to have a key path in an organization, whether it be compliance or performance or whatever it might be about buy-in, about encouraging people to have that buy-in. Tristan?

Dr Tristan Casey:

Yeah. So I guess the buy-in factor comes down to what we call workers imagined versus workers done. So when we create a procedure or a system, that's how we imagine the work will be undertaken. But the reality is, is the workers done, that how workers actually apply those things, and that can be quite different in a lot of situations. So the buy-in factor is about acknowledging to workers, "Hey, we get that you don't follow these things a hundred percent of the time, all the time, and we want to understand why. We want to understand that gap and help us as leaders to do a better job to improve our systems."

Speaker 2:

Surely in the past, there has been a hesitancy about leadership and losing control as such. That perception that, "If they don't do it the way it's supposed to be in the manual, or we've done it this way forever," that you are losing control. Is that a key factor? Whereas, this is now a more collaborative approach in that you're encouraging others to offer feedback, whether you accept it or not, whether it becomes part of a procedure in practice is then up to... To decide by you or the committee or whoever it might be.

Dr Tristan Casey:

I think it just really comes down to challenging our notions of what control is. So safety is definitely a control problem. When we have a loss of control, risks occur, hazards are triggered, bad things happen, but control can be achieved in different ways. Control can be topped down, prescriptive, enforcement based, or we can still achieve control through flexibility because when people vary, when they compensate for shortcomings, when they improvise and are technically brilliant at their jobs, that's still a form of control. We're maintaining the stability of our system through flexibility. It's a bit of a paradox, but it does ring true for a lot of high risk industries. That's how they get those benefits is through enabling workers to improvise where they need to and come back to that security of this is what the procedure and the system says.

Speaker 2:

And just going back, just quickly just to finalize our session here. Just quickly that LEAD program that WHSQ had on was about empowering leaders, not just to lead and do as I do, but to set an example to open doors, to have an open door policy, to allow people, their workers as an asset, to give them feedback, to give input, all that sort of stuff, to be more open.

Dr Tristan Casey:

Yeah. Yeah. So the LEAD program was developed with Curtin University and UQ and it continues to be adopted across industry. So TS Australia manufacturing company recently won the NSCA award for their work with the lead model, and the electrical safety office is using it as well. So I encourage you to jump on the website, WHSQ and you can grab some deep some details about how to improve safety leadership in your business.

Speaker 2:

Beautiful.

Dr Tristan Casey:

Thanks.

Speaker 2:

Thank you. Round of applause for Tristan.