Review – Safemode White Paper – Towards a Safety Learning Culture for the Shipping Industry

I was sent this paper from a seafarer that requested a review and I thought perhaps readers might be interested in it:


The paper commences with this (p.6):

‘Within the framework of the EU-funded SAFEMODE project, a series of confidential, in-depth interviews of seafarers and investigators was carried out to ascertain the current status of Safety Culture in the shipping industry, and to recommend possible avenues for improvement.’

So, one has to assume that this paper is some kind of representation of the seafaring industry, given its funding base and support from many organisations.

If this is the best research the shipping industry can muster on safety then, it is in a sorry state. As such, the paper also represents a common way in which Safety approaches knowledge from its own echo chamber. So much in this paper is assumed as ‘fact’ and is little more than the repetition of safety ‘code’. Safety code is often identified by the use of certain language and semiotics that give comfort to people in the safety industry but has little meaning or purpose, other than identity to the comfort of its own sound/noise.

This is what is common to all cults. Identity and belonging is confirmed by code known to the group so that in-groupness and out-groupness can be known. In safety this is done by the repetition of myths associated with Heinrich’s pyramid, James Reason’s Swiss-Cheese, Icebergs and key words that Safety loves to hear. This helps create an exclusivity that confirms the indoctrination of the sector.

As such, this paper serves as a good example of Safety propaganda and indoctrination and, has nothing to do with critical thinking, research or professional, academic or evidence-based practice.

So, let’s progress through the paper and deconstruct what is presented.


The title of the first chapter confirms an exclusivity of a cult. Since when was the tide against safety? The question presupposes some kind of binary opposition, why? Since when were people against safety? Such silly framing of a problem creates a mythical adversarial position. It also affirms that Safety has some sense of projected insecurity about itself. The myth is that no-one cares about safety except Safety. Only Safety knows about safety! This is exactly how cults create comfort and certainty through their own language.

This opening to the paper and such framing, demonstrates that what follows is most likely going to be a typical Safety diatribe of assertions, assumptions, rhetoric, safety ‘code’ and ‘safety speak’. It reminds me of how religious groups speak about the ‘saved’ and the ‘unwashed’. Here we see that Safety has already created a myth about itself and this is confirmed by the language and semiotics throughout the text.

We see this immediately by the use of the language ‘safety culture’ without any qualification, definition or footnote, and this is problematic. It is highly debated that there is such a thing as ‘safety culture’ and such should be at least acknowledged. I have no doubt that there is a culture and sub-cultures anchored to the shipping industry and seafaring but none of this is discussed, defined or acknowledged.

The paper is framed by this: ‘Better safety is business common sense’. This is simply business mythology and there is no such thing as ‘common sense’. If sensemaking is held in common, why does it have to be requested and stated? If better safety is ‘common sense’ why does such a paper need to be written?

Sensemaking about safety is NOT held in common because the paper opens with the statement that the tide has been against it. This kind of immature and amateurish language demonstrates low level thinking and unprofessional framing as an opening to so called ‘research’ in safety. The use of the metaphors ‘toward’ and ‘against’ are common to the cultic formation of security and projected superiority when a group is juxtaposed against an ‘other’ ie. all those who don’t care about safety.

The first two paragraphs of the report are wasted in generalisation, projection and assertion.

Similarly, if safety is good business, why is it that Business doesn’t drive safety? So, Business has to be informed by Safety that safety make good business sense? This is an example of the contradictions threaded in to the introduction that simply don’t make sense. In this way, Safety (as an Archetype) is pitted against Business (as an Archetype) and so the paper sets up a conflict between forces that apparently don’t understand each other indeed, are adversaries in opposition to each other.

In this way Safety says to Business, ‘you don’t even know yourself as we do’, ‘if only you knew what Safety knows, you would be better’!

So, the paper starts with an economic argument not a human argument for safety?

For the purposes of this review, we will progress through the report page by page.


At the opening of the report four terms are used and none are footnoted, defined or qualified, these are:

  • Safety Culture
  • Safety Learning Culture.
  • Learning Culture
  • Just Culture

This is how safety builds safety ‘code’ so only the initiated understand what is discussed. This kind of obscurity is common to all cultic code for any in-group. So, at the outset, one is expected to know what these four concepts are. Even so, as the paper progresses we find that things like ‘safety learning culture’ means ‘safety management systems’ (SMS). This is how all cultic code works.

The paper is constructed from 19 video interviews (of 90 minutes length) led by: ‘three Human Factors and Safety Culture experts’. And in the same paragraph we get this: ‘All interviews were thus held in good faith, with interviewees giving honest and frank answers to the questions asked.’ Such an assertion and judgement is naïve in the extreme. This assertion is founded on the Safety myth of objectivity and in complete ignorance of power distribution and ethical practice. In no place is there any statement of ethics, methodology or method in the paper wither by footnote, appendix or discussion. Then this:

‘to ensure an objective and unbiased assessment, while also ensuring interviewee confidentiality.’

The whole report so far is so heavily loaded in safety speak-mythology and this is simply a nonsense statement. There is no such thing as ‘objective and unbiased assessment’ especially when anchored to Human factors and Safety Culture Experts (whatever they are). Only Safety could assert such mythology regarding the complexities of research ethics and subjectivity.

Please note: mythology refers to concepts made true or real through semiotics, linguistics, rhetoric and ritual. For example, linear causality is neither real or true but asserted as so by Safety confirmed by the swiss-cheese symbol and metaphor.

Safety bias is declared on the next paragraph:

‘The interviews, led by three Human Factors and Safety Culture Experts’

And this:

‘All interviews were thus held in good faith, with interviewees giving honest and frank answers to the questions asked’.

In what way was the bias and subjectivity of these ‘experts’ filtered? This is all mythology and stated as if there are no power dynamics or pressures on seafarers to confess or give testimony of what is expected! There is no footnote on language or cultural issues or power imbalance??? Even the language of these experts would have been alienating for the average seafarer.

And in the last paragraph (p.9.) we learn the agenda of the paper (bias) is: ‘near miss reporting, reporting, investigation, ‘human element’, SMS, safety at sea, ‘safety learning’ and ‘just culture’.

And apparently a ‘magic wand question’? (Whatever that is) as a metaphor demonstrating that this paper is about an impossible wish. Why is such unprofessional language used in the text?

p10 & 11.

So, we are three pages into this safety propaganda piece and we are presented with ‘An Interview Approach’ (Figure 1. An Interview Approach)

Figure 1. An Interview Approach

More framing of an agenda focused on reporting, near miss, ‘the human element” (whatever that is), safety, Safety Management Systems, Just Culture (never explained or defined) and Safety Learning. I wonder if ‘Safety Learning’ is different from learning? This serves as an example of how cults code language. IN safety there is not just learning but ‘safety learning’.

All of this language is not discussed, defined or explained as if by declaration all of what is projected is true. Similarly, all of the mythology of James Reason is embedded in page 11 as if such things as ‘Just Culture, ‘Reporting Culture’ and ‘Culture of Care’ exist. This is so typical of how Safety presents and undertakes non-research. Truth is made by assumption and assertion based upon safety myths using the discourse of mythical gurus of safety such as James Reason.

A typical example is this:

‘Safety Culture is the over-arching concept that embodies Just Culture, Reporting Culture, Learning Culture, and the relatively new Culture of Care arising in the shipping industry. Safety Culture is essentially the priority given to safety, and is hence the motivation for safety at all levels in an organisation, encapsulating ‘the way we do things safely around here,’ even when no one is looking’.

This collection of safety code culminates in the repetition of the old favourite of safety that culture is about ‘doing’. Accepting this definition of culture is common to the safety industry but has little to do with culture and helps anchor Safety to Behaviourism: ‘what we do around here’. It also demonstrates the way in which Safety defines itself by common propositions accepted as safety code.

This serves as an example of how Safety conducts research. An assertion is made and such an assertion must then be accepted as factually true because it has been asserted by someone in the cult of safety. In this way we observe the assertion that a ‘culture of care’ exists because it has been stated as being so??? And somehow this is ‘new’? Caring for seafarers is ‘new’? If I assert that Santa Claus is real, does it make it so? Of course, Santa is a myth confirmed by all the semiotics of Christmas that declare Santa as true/real.

If there were such a thing as a ‘culture of care’ where and how is this demonstrated? By what method is a so called ‘culture of care’ known? Most of the discussion in this paper demonstrates that there is no such thing in seafaring.

We already note by page 11 that the best practices in ‘Safety Learning’ (whatever that is) are already known. Such is the nature of how Safety declares Propaganda as truth.

By Chapter 2, one knows that this is a safety paper about asserting safety myths and safety code, not a paper about learning or culture. The agenda is clear and so much safety mythology, language and semiotics are accepted and proclaimed as fact/normal. There is no open enquiry in this paper. Safety has a task, a framing bias and objective to declare to an audience who adores the sound of its own safety noise within its own echo chamber.

This is a safety paper about safety with little interest in learning, research or culture. So many assumptions are made about so many things. It is simply an unprofessional safety diatribe wrapped in safety language, projecting safety myths and rhetoric to the believing cult.

No critical concepts are explained, defined or footnoted. Much is plagiarised from typical Reason or Hollnagel discourse. Reason and Hollnagel serve as Archetypes of normalised discourse, linguistics and code accepted by this paper. The paper includes commonly accepted mythology and numerous common safety semiotics accepted without question.

Please note: an Archetype is something with a force and energy to itself. Such is common in language for example we commonly speak of ‘the Market’ or ‘the Economy’ as Archetypes. In this review, Safety as an archetype is Capitalised.

p12 & 13

Chapter Two commences by following the outline of ‘The Interview Approach’ (pictured earlier). This is the undeclared method of the paper but just as there is no recognition of bias towards Reason or Hollnagel, there is no discussion of methodology or an ethic of research. And this is how Safety typically conducts itself. Without definition of an ethic or methodology and in naïve immature mythology about objectivity, it simply asserts what it knows and declares it to be true all framed against the adversaries of Safety. But the tide is turning, apparently. This is the kind of language Safety uses to elevate itself and is personified as a righteous quest.

So, the chapter starts with nonsense speak like this:

‘Investigators made it clear they are not there to apportion blame, though they do need to verify compliance with procedures.’

This is how Safety qualifies nonsense concepts so: ‘we don’t blame but we need to verify compliance with procedures’. This is the same nonsense one gets in Safety Differently discourse eg. ‘people are not problems to control but resources to harness’. It is the same thing! Are people in safety so lacking in critical thinking that they cannot see that harnessing people like an animal is worse than controlling people as a problem? In the same way there won’t be blame but we need to validate compliance! By what method will this be done? If one thinks of the extensive education of Rogerian counsellors, where is similar education for Safety, to ensure no blame?

This is all common code to the ‘safety differently’ discourse. Nothing changes in methodology except to undertake the same methods of safety ‘differently’.

This is the kind of nonsense projected by Safety II discourse; that the bogey-man of negativity must be avoided and blame is wrong yet compliance is necessary!

Similarly, the same nonsense is framed around cause and ‘contributory factors’. Just think of the skills required (that Safety doesn’t have) to investigate causes and contributory factors without any sense of blame! Yet, the language of blame is threaded throughout the discourse of this paper.

The next paragraph is just more unquestioned safety mythology and rhetoric:

‘They contrasted their focus on the creation of a narrative of what happened and the rationale behind the sequence of events, with the judiciary perspective, which focuses on direct causality, and also has a sense that justice must be served.’

So, let’s have ‘direct causality’ and ‘justice served’ but no blame! This is all just more Safety rhetoric and myth. And all this will be undertaken with no skills in ethics, moral philosophy, semiotics, linguistics or social psychology!

On page 13 we discover that seafarers are ‘wary’ of investigations and investigators and this stands in contrast to previous nonsense statements about ‘objectivity’ and reliability in testimony in interviews for this paper. Especially in light of the fact that:

‘Some seafarers said they had seen people fired or ‘let go’ following an incident or accident, or transferred back to their home country before the investigators arrived.’

We also learn that the paper accepts the ‘5 whys’ approach to investigations which has a focus on blaming not open questioning. Similarly, it focuses on objects not subjects in a similar way to the nonsense ‘bow-tie’ method. Even when this paper discusses ‘the human element’ and human ‘factors’ it refers to objects, systems and process.

On page 14 we have openly declared myth and rhetoric about ‘defining causes not responsibility’. What nonsense language! Who can undertake such nonsense separation in thinking and questioning method. This is just more SafetyII mythology that plays games with language to an audience that cannot deconstruct what is being said.

This page is littered with so much ‘safety speak’ for example, ‘human factors’ never means anything human but rather humans as a ‘factor’ in a system.

The report then just progresses through the ‘Interview Approach’ with more unquestioned rhetoric, safety mythology and ‘safety speak’.

On page 18 we have reference to a ‘Tower of Babel effect’ which is interpreted as ‘an abundance of rich stories’. This is NOT the meaning of the term and demonstrates the amateurish nature of the research. The Tower of Babel effect is about the creation of confusion ( This language demonstrates just how Safety works. It figures out what conclusion it wants and then creates a myth to fit the desired outcome. Most often Safety declares what is, by what isn’t. This is how mythology is constructed.

This section is about something called the ‘human element’ but we never learn what that is. This section also includes unquestioned assumptions about Shell and a Marine Guidance Note (MCA) about the ‘deadly dozen’. These are listed in a semiotic of text (p18) at Figure 2. The Deadly Dozen:

Figure 2. The Deadly Dozen

This is not explained nor defined but serves as a semiotic to endorse more safety myths. This is what the paper does, it asserts what is true or real by presentation but there is no explanation or evidence to support any of its safety code. Notions such as ‘alerting’, ‘complacency’ and ‘distraction’ are nonsense and meaningless language that Safety thinks explain some thing. None of this language has any psychological meaning. If you were to ask anyone in safety to explain what these are, they couldn’t tell you. These are just safety code for ‘I know why people commit error or make mistakes’ and you don’t.

The ‘deadly dozen’ is typical of safety rhetoric about ‘cardinal rules’, ‘life-saving rules’ etc. but are mostly meaningless rhetoric and serve as language of belonging to the safety echo chamber.

Once a myth has been made true such as the ‘Deadly Dozen’ it becomes accepted ‘fact’ and unquestioned.


We find out that ‘Safety Learning’ is the Safety Management System (SMS) and has nothing to do with learning. The idea that SMS has anything to do with learning is simply nonsense. Most SMS are about anti-learning, repetition, paper-systems and safety rituals. Yet, this is how Safety confirms its mythical truth, most often declaring something by what it isn’t. Truth is confirmed by unquestioned cultic repetition so that all is accepted as true, confirmed by indoctrination, semiotic and ritual.


This is just more repetition of Reason and Hollnagel rhetoric on Just Culture but there is nothing in this section on Justice or Culture. More rhetoric on non-punishment, more non-critical thinking about the ideology of positivity which consumes Safety II discourse.

The paper for some purpose, holds up the aviation industry as some kind of benchmark on safety and seems besotted and fixated on common safety myths repeated in that industry. All of this rhetoric on ‘just culture’ is just more regurgitation of safety propaganda and involves no critical thinking or deconstruction of safety myths. What is meant by ‘justice’? We don’t know? What is understood as Culture? We don’t know. Apparently behaviours.


By the time one gets to page 27 all of the myths of safety have been constantly repeated ad infinitum without any definition or explanation, all accepted as both real and true. We are then provided with a semiotic of ‘The Safety Learning Cycle’ (Figure 3. The Safety Learning Cycle).

Figure 3. The Safety Learning Cycle

What can we say about this semiotic? It has nothing to do with learning. Capturing data is NOT learning. Data analysis is NOT learning. Monitoring operations is NOT learning. Observation of SMS is NOT learning and the work of risk assessment and system design has nothing to do with learning. However, what the semiotic does is confirm the myths of the paper as semiotically real. This is how all myth is endorsed.

This whole section is focused on systems NOT persons. Without an understanding of persons, movement, disposition, change and reorientation, there is no learning.

The circular semiotic confirms a cycle even though learning is not cyclic. In this way, the semiotic is used to anchor to a myth but none of this is connected to persons or the organic way humans learn.

p28 & 29

The semiotic on this page is NOT focused on learning. Each one of these ‘levels’ of learning are focused on systems.

Next, we have Ten Safety Learning Approaches on top of the Six Safety Learning Levels, coupled to the ‘Safety Learning Cycle’. Confused yet? You should be. These rhetorical mechanisms are designed as safety code for the initiated to accept without question.

This section also introduces the classic iceberg and swiss-cheese semiotics. Safety adores this stuff. If you spatter enough of common safety semiotics in a safety report, the safety audience is convinced they are reading something professional and academic, which this is not.


Here we get to ‘Investigating Differently’ that is not different and has nothing to do with learning or culture. It starts with data entry, recording information for court, causation mythology, the deadly dozen, safety myths about error, productivity and a ‘taxonomy’ of meaningless language that safety accepts as meaningful. How is something ‘different’ when the same language, systems, methods and discourse is used as traditional safety?

p34 & 35.

This section is all about a database, the love child of safety. None of this has anything to do with learning or culture but is presented to promote a database by SAFEMODE called ‘SHIELD’. The collection of data and information has nothing to do with learning. But Safety names data as learning and makes it so, more mythology.


Here we can add now to out numeric 6 levels, deadly tens, learning tens and iceberg ‘the ten most wanted’. How Safety enjoys all this counting and numbering of lists that have nothing to do with the ethical engagement of persons about risk. These rhetorical devices give the impression of addressing something systematically as if Safety has some understanding of what to do about culture and risk.

We soon progress into ‘deep dives’ that is code for hyper-causation fault-finding and prevention-barrier mythology.

p.40 & 41.

This is classic safety stuff. Mythology endorsed by semiotic (See Figure 3. Maritime Swiss Cheese).

Figure 3. Maritime Swiss Cheese

Of course, this is all myth. Incidents and events are rarely linear just as tackling risk is never systematic but rather organic. However, by placing commonly accepted safety mythology in place, those in the safety industry are comforted that their indoctrination is true.

None of this is real or meaningful but just semiotically endorses the mythology of Reason. It serves as a great example of how Safety accepts and endorses its own myths within its own echo chamber. It has no connection to the realities of culture, learning or how risk works.


As we near the end of this paper we get served more circles, cycles, numbered lists and semiotics that serve to endorse and validate the mythology of the report. None of this is true or real but just sits in place to substantiate semiotically, the accepted assumptions of the paper that in no place receive any critical attention.

The semiotics serve to endorse the assumptions that were evident at the beginning of the report and the outcomes are typical safety approaches to systems safety. There is even further endorsed by a semiotic pyramid (you have to include a Holy Heinrich) and a 5 step sequence of where to go next.

And what is under the pyramid semiotic? A ‘Safety Learning Culture Arrival Checklist’! Of course. The checklist lists all the typical traditional favourites of Safety that it could easily list without any interviews or any white paper.

How good to bring a pyramid together with a checklist, all wonderful safety code for an industry that loves to read its own myths spoken back to it and see its common semiotic myths in clear vision.

The report ends with six case studies that help endorse traditional safety approaches through the rhetoric of Hollnagel language and Reason mythology.

So, here are some of my conclusions about this paper:

  • None of this paper has any connection to learning (never defined in the paper) nor culture (poorly defined in the paper).
  • There is no open enquiry in this paper.
  • There is no Transdisciplinary approach to knowing or learning.
  • There is no mature approach to culture or understanding of culture.
  • No safety terms used are explained, defined or discussed.
  • A typical systems approach to safety is endorsed couched in ‘safety differently’ rhetoric.
  • It has many meaningless lists and checklists that have no relationship to an ethical approach to persons in tackling risk.
  • The paper offers nothing that improves or helps the shipping sector move or learn or tackle the realities of its culture.
  • The paper offers nothing to help with safety, learning or culture. And so, this ensures that nothing in safety in shipping will change.
  • Yet, at the same time the white paper has all the semiotics and myths to make safety people feel comfortable that something of intelligence has been presented.

This is how Safety ensures that it endorses all that it knows, maintains its comfort code and confirms it certainties and doesn’t research what matters.


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