Why a longer risk assessment is not necessarily a better one.

The purpose of a risk assessment is easy to forget. It is not to catalogue every conceivable pathway to harm or prove how seriously an organisation takes safety. It is to identify credible scenarios in which someone could be harmed—and determine reasonably practicable ways to prevent that harm.

Yet risk assessments often begin in catalogue mode. Every hazard that can be imagined is listed. Every familiar control is added. The document grows, and its length starts to look like evidence of diligence.

Superficially, this appears to satisfy the requirement to assess risk. But when exhaustiveness becomes the objective, it can come at the expense of identifying the controls that really matter.

When assurance becomes theatre

Large organisations are just as susceptible to this problem as small ones.

A mining or construction organisation with a carefully cultivated safety identity may feel pressure to require contractors to address every known risk associated with a proposed program of work. Nobody wants to be accused of doing things half-heartedly or failing to match stated values with practice.

The underlying assumption becomes: if the process is rigorous, it should be difficult to analyse and difficult to implement. That assumption is wrong.

Contractors and workers do not have unlimited attention to devote to proving diligence while also delivering an actual project. When the documentary burden becomes excessive, the work is often outsourced to consultants or assembled from boilerplate copied from previous assessments.

The organisation receives the substantial compliance document it asked for. The management system has its evidence. But the controls at the workface may also have been copied from previous jobs, accepted without challenge and signed without serious engagement.

Reusing controls is not inherently wrong. Many effective controls should be repeated wherever the same risk exists. The problem arises when generic material crowds out the specific conditions of the job—leaving hazards unnoticed and workers improvising on the day.

A SWMS should direct attention to what can kill

Safe Work Method Statements are intended to help prevent this outcome.

In Western Australia, a SWMS must be prepared before high-risk construction work begins. It must identify the high-risk work, the associated hazards and risks, the controls to be implemented, and how those controls will be implemented, monitored and reviewed. Its primary purpose is to help PCBUs, supervisors and workers implement and monitor the controls needed to perform that work safely.

That means concentrating attention on credible, serious events:

• an excavation collapsing onto a worker;
• a person being crushed while operating an elevating work platform, with nobody available to warn or rescue them;
• a worker falling through an open penetration in a dark corner of an unfinished floor;
• mobile plant striking a person working nearby; or
• energy being released during maintenance or isolation work.

These are the scenarios workers and supervisors should be reading, discussing and mentally rehearsing before work begins.

If the first controls in a SWMS concern sunburn, mosquito bites and other routine site expectations, however, attention can be exhausted before anyone reaches the hazards capable of causing fatal or catastrophic injury.

The twenty-page SWMS then goes around the table for signatures, enters a plastic sleeve and remains in a site-office binder. It may not receive close attention again unless something goes wrong and it is retrieved during an investigation.

The organisation may feel protected because every possible instruction has been recorded. In reality, it has trained people not to distinguish important information from background noise.

Not every control belongs in every document

There is nothing wrong with documenting routine controls such as safety glasses, sunscreen, hydration, barricading or injury reporting. The question is whether every one of those controls needs to be repeated in every SWMS.

A SWMS is not simply a record that safety was mentioned. It describes how high-risk construction work is to be carried out safely. The work must then be performed in accordance with it.

What workers and supervisors sign should therefore be meaningful.

If workers are repeatedly told in every SWMS to wear safety glasses, report injuries, use sunscreen and install signage, the document begins to function as a general code of conduct rather than a safe method for completing a particular job. Repetition also creates an unintended problem: when a routine instruction is absent from one document, its absence can begin to look like permission.

Some expectations are better established clearly and consistently through induction, site rules, training, supervision and task-specific procedures. The SWMS can then focus on the high-risk activity, its sequence, the credible events and the controls that must be in place before the work proceeds.

Repetition creates fatigue

Consider an angle grinder.

A worker may be required to use safety glasses and a face shield, ensure the guard and handle are fitted, check the equipment is electrically safe, manage leads correctly, remove nearby flammables and control sparks.

These are legitimate requirements.

But if the same complete list is reproduced in every SWMS for every job in which a grinder might be used, workers quickly learn that the document is written to protect the organisation rather than guide the work. They skim it, sign it and move on.

Routine expectations should be communicated clearly, reinforced consistently and addressed when they are not followed. Workers should not need to rediscover the basic rules of the workplace in every task document.

Then, when a SWMS is placed in front of them, it can answer a more important question: How could I be killed or seriously injured while doing this job—and what must be in place to stop that happening?

Shorter does not mean superficial

The argument is not that risk assessments should always be short.

Complex work may require substantial analysis. Different work groups, interfaces, changing conditions and multiple critical controls can justify considerable detail. A concise but generic assessment is no better than a long generic one.

The point is that length is not a measure of quality.

A useful risk assessment:

• describes the work as it will actually be performed;
• identifies credible events rather than broad hazard labels;
• gives appropriate prominence to fatal and catastrophic risks;
• specifies controls that are practical and capable of verification;
• makes clear what must happen if a critical control is absent or ineffective;
• is understood by the people who will perform and supervise the work; and
• is reviewed when the work or its conditions change.

Good risk assessment is an exercise in disciplined attention. It removes noise so that the people exposed to risk can see what matters.

A longer document may sometimes be necessary. But if its length makes the serious risks harder to find, the assessment has become less useful—not more rigorous.