The Myth of the SWMS Manifesto

I’d like a dollar for every mail I get telling stories about what is considered necessary in a Safe Work Method Statement (SWMS). It seems that Safety is far more attentive to safety mythology (something that is made symbolically true, that isn’t) than what is actually in the Act and Regulation. I get emails from so many people who get bullied by safety people who insist some kind of global rule about what should go in a SWMS. It’s amazing how these documents have been made into a monster manifesto under the rule, ‘if in doubt, put more in’. In reality, the Regulation doesn’t expect much of a SWMS, just 6 things:

1. To identify high risk work
2. State hazards related to high risk work
3. Risks associated with those hazards
4. Describe measures for mitigation/control
5. How those measures (methods) will be implemented, monitored and reviewed
6. Make such readily accessible and understandable for the people who ‘use’ SWMS

Of course, there is money to be made out of fear (https://vimeo.com/166935963 ), ignorance and SWMS scams. You can purchase endless SWMS templates online and just change the logos which of course means a risk assessment was not done. The Court will quickly tear to shreds any ‘tick and flick’ process that assumes that the purpose of a SWMS is the production of a SWMS. This attitude is what underpins the absurd notion that being Papersafe (https://www.waylandlegal.com.au/paper-safe ) makes one safe. As Greg Smith (https://www.waylandlegal.com.au/ ) states:

… at some point health and safety management has lost its way. Rather than being concerned about protecting workers and others from the hazards associated with business, health and safety management has devolved into a self-perpetuating industry which seems to have driven a wedge between management and the workforce.

Regulators even give out SWMS templates:

for the right reasons but somehow these still grow in to monsters. This is how mythology works. There are also guides about what should be included in SWMS  but it doesn’t matter, safety mythology soon takes over and the ‘volume is best’ rule becomes the norm.

With all of this, including the examples given by regulators, there is an assumption about the format of how SWMS must be done as if a visual analysis/method is NOT acceptable. This is more mythology. If you give a problem to an engineer, they will give you a spreadsheet. There is nothing in the Act or Regulation that prohibits a visual method of risk analysis (https://safetyrisk.net/visual-thinking-and-risk/ ). The same applies to how incident investigations ought to be undertaken. More mythology.

The problem is not really with the SWMS idea itself but rather the mythology the safety industry has created about them. This is what comprises the SWMS Manifesto, and it’s a myth. When a myth becomes a symbol of something else (eg. fear of prosecution) it takes on the most absurd political power (https://vimeo.com/165397953 ). This is what has made SWMS a manifesto but is not a representation of reality.

Unless a SWMS is an accurate record of actual work it is pretty meaningless. We saw in the recent case with Multiplex and R&R Cranes that all the paperwork was in place but it wasn’t a representation of actual thinking about risk. You can imagine the excessive paperwork associated with a Tier 1 construction company. Most Tier 1 construction companies have turned safety mythology into an art form. You don’t count the pages in their systems, you weigh them. I was recently talking with a person in a Tier 1 safety organisation that espoused ‘safety differently’ that had more paperwork than ever!

So, let’s go back to item number 6 in the requirement of a SWMS. A SWMS has to be useable, accessible, and ‘understandable’ for the people who ‘use’ the SWMS.

By useability let’s not get confused about a structure of comprehension (https://safetyrisk.net/paperwork-and-usability-in-tackling-risk/ ). Useability is NOT about format but utility, particularly with low literacy levels (up to 50%) in industries in high risk work. We need to understand how workers really make decisions (https://vimeo.com/471823469 ) not what some engineer thinks about judgment and decision making. An engineer would be the last person I would get to design a risk assessment process that understood the nature of learning (https://safetyrisk.net/visual-thinking-and-risk/ ).

In reality, most workers assume a SWMS is necessary but NOT as a tool to help them think about a risk/task. SWMS are mostly viewed in Building and Construction as an embuggerance that gets in the way of doing work. They are most often text and tables-based documents that get signed but not read. With such high rates of illiteracy in Building and Construction, you can be sure they are NOT a tool for critical thinking or actually tackling the risk on site.

Over the short evolution of this industry we now have ended up with a political manifesto based on pure mythology that generates volumes of paperwork (https://vimeo.com/162034157 ) that actually doesn’t keep people safe. We end up with excessive paperwork because a certain group of people ‘imagine’ the necessity of a document as a substitute for a process. This is what develops when behaviourist assumptions and mechanistic assumptions about decision making are made the manifesto for an industry that is locked OUT of Transdisciplinarity. When we lock out aural, visual and kinaesthetic learning in the way we approach risk, we lock out 50% of the workforce and their ability to ‘use, access and understanding’, the very things the Act and Regulation require of a SWMS.

One way to remedy this problem is to embrace a broad Transdisciplinary approach to risk (https://safetyrisk.net/transdisciplinary-safety/ ) that considers non-engineering, non-behaviourist approaches to human judgment and decision making.