HSE Overkill

I was recently on a crew where they had a HSE policy which placed emphasis on the top 5 risks for the current project. While I was there the HSE people from their head office decided, in their infinite wisdom, to change the policy to the top 10 risks. This made for a long winded discussion on what items should be in the top 10 and then what order to put them in. It also made it very difficult for anybody to keep track of what the top items are.

In matters of HSE, like most other matters, I believe that it is always better to keep to the KISS principle. Whenever you make too many complex rules you run the risk of people simply deciding that it is all too difficult and not bothering with the complexity anymore. The problem with this is that they then tend to ignore all of the rules, even those that they had willingly followed before things were made more complex.

I would like to know exactly what was in the minds of the people who made the change and exactly how they thought that it would improve the crew’s performance, especially in the light of the crew I was on having gone three years without a reportable incident. Perhaps they were aiming the more complex ideas at the other crews that didn’t have as good a safety record. How could they expect that a crew struggling to keep up with a simpler regime to embrace a more complex one and do better?

That is the problem with HSE rules. Nobody is allowed to question just how effective they are. I believe that every addition or change to HSE policies should face tough scrutiny. The person devising the new rule should be able to answer the following questions.

  1. Does it fix a real problem?
  2. Is it the best way to fix the problem?
  3. Is it simple to follow at all crew levels?
  4. Is it equally applicable in all circumstances?
  5. Is it cost-effective?

I see everybody on seismic crews wearing safety boots all the time and I question their effectiveness. Since slips, trips and falls generally figure fairly high in the risk matrix on crews is use of heavy boots with soles designed more for a workshop than rough terrain sensible or necessary? Drillers normally need such things as they are often handling fairly heavy objects which the safety boot may be able to deflect. Layout and pickup crews on the other hand are at little risk of a cable falling on their feet and causing more than minor discomfort, far less injury. Bulldozers and vibroseis operators don’t have much hope if a track passes over their steel toes or a pad comes down on them.

I often see labour-intensive crews in third world countries where the crew is provided with the cheapest safety boots available. These boots generally only last a couple of months. Could the extra cost of steel toed boots be better utilised buying decent boots without the added toecap?

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