Why regulators Should Stay away from Safety Culture and Stick to Rules Instead

This banger chapter comes from an equally slapping book ‘Trapping Safety into Rules’. The authors argue why “regulators should stay away from safety culture”.

Too much to cover, so just a few points.

They open with “Ever since the Chernobyl catastrophe, safety culture has been invoked as a crucial discriminator between good and bad ways of dealing with high risk”.

Since this time, there has been endless debates about the meaning and usefulness of SC for promoting safety. While the original definition coined by the International Nuclear Safety advisory group focused on the Safety First principle as core to SC, other definitions have broaden its meaning to include “shared norms and beliefs related to how safety issues are dealt with in an organization culture”.

Notably, they argue that “Social scientists have generally warned against treating safety culture as yet another management tool because by its very nature it cannot be easily captured or engineered”. This hasn’t stopped organisations, or regulators, from trying – with some regulators “requiring companies to show proof of having or working towards a good safety culture”.

In this chapter they argue that including SC into regulatory requirements “may have detrimental effects on the factual safety of high-risk organizations”, because using SC as a frame draws attention from addressing “more manifest safety issues”.

It’s said that the great draw of SC—apparently being a way to capture complex social underpinnings of organisations, is also its greatest weakness. That is, combining two difficult to define terms (safety & culture) into a new one has “spurred imagination, but has also provided an easy way out as a catch-all construct”. For instance, when things go wrong, the easy explanation is that the organisation, project or team lacked “the right kind of safety culture”.

Directly quoting the paper, this leads to questions like:

a)?????? What is the ‘right’ kind of safety culture?

b)????? Should the focus be on safety culture or on safety climate and how are these two concepts related?

c)?????? Is safety culture per se good, so that it is a matter of a company having or not having a safety culture, or are there good and bad safety cultures?

d)????? Can safety culture serve as a leading indicator to predict problems in safety performance, or is it possible only after the fact to diagnose safety culture as having contributed to whatever problem occurred?

e)????? Can safety culture be measured, managed and even prescribed and if any of this is possible what would be characteristics of (good) safety culture to aim for?

They argue that the time spent trying to answer these questions may be better spent trying to address “manifest problems in managing safety more directly”, including inadequate work organisation, bad technical design or unsupportive leadership styles.

Moreover, instead of trying to apply “guesswork to make any kind of judgement on an organization’s culture”, a focus should be placed on the organisation’s operational safety management. Likewise, regulators should concentrate on “prescribing, monitoring and enforcing operational safety management” and at the same time “abandon any attempt to include safety culture into regulations”.

In any case, they take a stab at answering the above questions:

b) the difference between culture and climate is pretty well-established: culture concerns shared norms and assumptions guiding behaviour, whereas climate is shared perceptions of organisational reality; hence, climate is often conceptualised as an expression of culture

c) safety culture is defined as the sum of all safety-related assumptions and norms shared by the majority of an organisation’s members; hence there can be ‘good’ or ‘bad’ cultures in the sense of shared norms and assumptions that are beneficial or detrimental to safety performance or goals [*** There’s also research doubting whether an organisation could really ever have a monolithic culture, and it’s more likely a collection of macro and micro/sub-cultures]

d) SC is really “only useful as a leading indicator helping to identify norms and assumptions that potentially hurt safety performance”, but when used for post hoc analysis tends to “obscure the picture because by focusing attention on very broad assessments of norms and values it distracts from manifest organizational and management problems”

e) SC “cannot be controlled or prescribed”, but is affected via safety and management activities, but “cannot be managed as such” [*** Hopkins appears a bit more optimistic on a leader’s ability to directly change or mould cultures/sub-cultures]

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Minimizing versus Coping with uncertainty

Next they cover some issues like personal vs process safety, which I’ve skipped, and then uncertainty.

Just a few points here.

They point to two paradigms on how uncertainty is managed in organisations:

1)????? Minimise uncertainty by high levels of standardisation, central planning, automation of work processes and high levels of specialisation with “few degrees of freedom for employees”

a.?????? This is said to be based largely on principles of scientific management and bureaucratic organisations

2)????? Per newer organisational theory, flexible adaption can counter increasing uncertainty due, by “empower[ing] all members of an organization to cope with uncertainty locally by providing them with plenty of opportunities for learning and cooperation, with options for action rather than fixed plans and standards, and with decision-support tools rather than algorithmic automation.

They talk about when stability and flexibility is advantageous. Stability is preferred in tightly coupled processes and where there’s a need for traceability of decisions, low fault-tolerance or low qualification levels of personnel.

Flexibility is more advantageous when dealing with high level of uncertainty caused by frequent external changes, high variance in work processes and high demands on innovation, and for avoiding over-routinisation and complacency in very processes.

Safety management tends to usually follow the first paradigm, by use of stability-inducing standardisation and formalisation. But there is a growing recognition for the importance of the need for higher flexibility. System design should support adequate balances between stability and flexibility. This balance has to recognise context and industry, e.g. “nuclear power plants require more stability and less flexibility than building sites”.

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Recommendations regarding the role of Safety Culture

Looking at regulatory regimes, they argue that the focus should be on prescribing, monitoring and enforcing the safety management systems, and not safety culture.

Further, “safety management systems should also not be defined in terms of safety culture because this creates a not very helpful tautology”.

Culture should be internally monitored and reflected upon in organisations, and especially as a source of resistance to change. Drawing on Schein’s conceptualisation, they note that while “Basic assumptions can only be made explicit and understood by the members of the organization itself”, actually unearthing and interpreting those assumptions may require an outsider.

Even if the external regulator takes part in unearthing the cultural elements of the organisation, and therefore their cultures “become more visible, this still precludes the “prescription of specific cultural changes [because they] still [remain] unfeasible”.

Further, they argue that for the regulator, it is an important task for them to help organisations in balancing stability and flexibility. They can reflect on the cultural norms encountered during regulatory activities regarding how those norms influence the assurance of safe operations. But, importantly, “rules set by the regulator need to be evaluated against stability and flexibility requirements in organizations”.

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Adequate rules for meeting stability and flexibility requirements in work processes

Here they say that the “overall objective of rules – and therefore a crucial task for regulators – should be to support an adequate balance between stability and flexibility in high-risk work processes”

The distinction of rules from Hale & Swuste may be useful here:

1)????? Goal rules: Define only the goal to be achieved, leaving open how that goal is accomplished

2)????? Process rules: Provide guidance for deciding the right course of action for achieving certain goals

3)????? Action rules: The strictest type, which prescribes detailed courses of action – “possibly without even mentioning the goal to be achieved”.

As rules of thumb on good rule making, types 1 & 2 should be favoured when flexibility is desired, whereas type 3 when stability of processes is required.

They say that regarding rules, “an important final check for any rule is to assess whether the assigned responsibility for uncertainty handling in the work processes matches the capability of the actor concerned”.

Conclusion

In concluding, they state:

·?????? “regulators should not aim for shaping safety culture, but rather for drawing up rules that help strike the appropriate balance between stability and flexibility in high-risk organizations”

·?????? “While culture by definition is not easily malleable, stability and flexibility of organizational processes can in fact be altered by regulation”

·?????? If a task requires more stability, then high alignment between rules, routines in principle and routines in practice is needed [** I skipped the section on what routines in principle and routines in practice means]

·?????? If flexibility is needed due to high levels of external and internal uncertainties, then “strict alignment between rules and routines can be a hindrance to safety and flexible routines and rules with more leeway may be necessary”

·?????? In developing rules, the key perspective should be whether “rules help coordinate work processes by initiating effective behavioural routines”, that is, do the rules actually have an impact on work

·?????? They argue that “external regulators tend to view rules as an instrument for defining legal accountability” and this is problematic when “the responsibility assigned to an actor by a particular rule does not match that actor’s capability for sufficiently controlling work processes to produce the requested outcome”.

Ref: Grote, G., & Weichbrodt, J. (2017). Why regulators should stay away from safety culture and stick to rules instead. In?Trapping Safety into Rules?(pp. 225-240). CRC Press.