How to get the pulse of safety in your business (with James Pomeroy, Director of Global Health & Safety)

Global Health and Safety Leader, James Pomeroy, has a storied career in safety. In this interview, we cover how EHS has gotten way too proceduralized and some techniques you can use to drive innovation and continuous improvement on your team. James also shares the one technique that he would advise you to try out to get the pulse of safety in your business.

You can listen to this interview on the Safety Leaders Now podcast.

Hi there, James. Thanks for joining me. Could you tell me a little bit about your current role and if you could also give us a little bit of an expansion on what the company does, the size of the organization, things like that.

Yeah, certainly. So thanks for inviting me. It’s great to kind of share experiences. So I work for Arup, which is a global engineering and consulting practice. They’re involved in a number of very large kind of projects around the world involving tumbling bridge construction, and addressing some of the real challenges that we face today around sustainability. It’s a multidisciplinary practice. Very large in North America, in Europe, Australasia, and equally in Asia as well. Some of the real areas we get involved in are big capital investment projects, roads, rail, big building construction, and advising clients on how to best optimize their real estate and investment decisions.

So super opportunity. I’ve been with the firm for about 10 weeks. I’m relatively new and still finding my way in the organization, but it’s fantastic to be part of an organization that’s doing some really incredible things around the world.

Awesome. What’s the scale of the organization? What’s the head count look like these days?

It’s growing quite significantly. So we tend to kind of double every 10 years and headcount—it’s just touching on 18,000 globally and a real range of individuals that we hire—from ecologist or environmental through to a lot of civil engineering, tunneling, acoustic specialists. Basically, if you want it, the practice has got that kind of discipline. We’ve even got economists that do modeling for what kind of capital and revenue programs. So just a massive kind of intellect and knowledge to come together to try and solve some of these problems.

Okay. Well, I don’t know if I personally can fully understand what an economist would do in that context, but it sounds, pretty neat.

It’s kind of—so if you’re going to build something and you’ve got revenue projections for it—you want a degree of certainty around it. If you’re going to put a road infrastructure in place and you want to actually, it’s going to be a private venture, then you want to know actually, and equally, if you’re going to make an investment. There may be a lot of kind of capital investments that you need economic advice. So alongside looking at: Is it built right? Is it built safely? Is it built sustainably? Are we making best use of economic investments also?

Okay. Gotcha. Well, that’s super neat. And I know, if you don’t mind me mentioning it, I know you’d spent five years at Lloyds previous to that. So what’s that transition looked like for you coming from that (obviously it’s sort of a grand old lady in the safety space) and now working for Arup? How do you evaluate that transition? How much overlap is there between those two businesses?

Yeah, it’s a really insightful question. There is a degree of overlap. I mean, both of them are not owned by shareholders in the sense that they are not privately…they’re not owned by market investment. So Arup is an employee owned business, which has got a unique kind of character and culture to it. Lloyd’s is an organization known by a foundation charity. So both of those bring a certain kind of vibe to the organization.

You’re not driven by quarterly earnings requests from investors. It enables you to do things within the organization and it attracts a certain type of individual. In Lloyd’s, it was very much focused on being owned by a charity. People came for that kind of purpose and they worked for a higher mission, should we say. You move into Arup—it’s a highly intellectual space. A lot of very…specialists, we take in over 800 graduates per year and we really look for the best in their particular field. So you get a level of dialogue and you get people questioning things at first principles that you wouldn’t necessarily do. But I think it’s always a challenge when you move between organizations. I’m eight weeks in, so I’m still kind of finding my feet between the two.

Okay. Well, that helps set the stage here a little bit. But again, part of what we’re trying to do here with this show and with the dialogue—what we’re trying to pull the thread on here is diving a little bit more into the tactical components of being a safety practitioner. So I think what would be really helpful for me is just understanding how you’re evaluating things and also just the organization at Arup right now. Can you just give me a little bit of an insight?

You have this huge multidisciplinary business, that’s going to…you’re going to have these intellectual components. You also have all this civil engineering and things like that happening in the field. What does that translate to as far as the org structure within the safety organization? How are people reporting to you and how does that work its way out to the front lines of the business? What are those layers and how are they structured?

I think the first thing to say about the professional consulting practice is that I’m not the safety expert. We have safety experts in their fields, whether that’s structural tunneling or any of the areas where we employ. We’ve got several hundred fire engineers who really know their stuff.

So I think the first thing is recognizing that you’re in a consulting advisory kind of role where you’re drawing on their knowledge, but recognizing that they are the individuals with the key expertise. I think the other thing, whenever you go into an organization, they’ve each got different structures. When I was with Lloyd’s, I was hired in to run a corporate function and there was then six areas underneath. Very quickly, we went for a transition where we try to merge them together to create one team.

Moving into Arab, you move into a team that you have a corporate team and then you have five regions. So it’s kind of similar to what I moved into with Lloyd’s. And understanding that kind of structure.

• Are you controlling through the team?
• Are you trying to actually influence policy or are you trying to influence others through regional or business streams?

I think understanding that structure is always summit. You want to get in very early on. If someone approaches you about a role—understand, “Well, what is the role?” Because corporate roles…I think safety people get really attracted to corporate roles. I’ve had people rotate through teams and it’s a kind of career aspiration to go from operating in a facility to perhaps go up to a division and then maybe go up to a corporation. But a corporate safety role is not always what it’s geared up to be.

Firstly, you end up doing…you’re far removed from the shop floor. So your ability to walk the floor to go out to sites—you’re not doing it that often. And if you are a practitioner that really wants to do that sort of thing, then that may not be the role for you. The second thing is it involves a lot of kind of stakeholder management. I won’t say so much politics, but engaging with people, listening to people, that’s not for everybody. Some people really like to be able to go out and see and do things and don’t like that sense of having to interact with individuals. But, then you do a lot of management reporting probably more than most people would want to do. So I guess what I take from that is just understand:

Think clearly about what your career pathway is. Don’t always think that a vertical move up to corporate is necessarily for everybody. It isn’t.

So would you sort of categorize your role overseeing these various sort of regional groups more as a strategic role where you’re just trying to point things in the right direction based on what you’re hearing from those groups?

It’s kind of listening to them. It’s kind of coming up with plans that work from a group perspective. A corporate role is the intermediary between the group board and then the entities sitting underneath. In practice, what that means is you need to give the leadership a sense of direction in terms of where we’re going with safety, what are we getting, giving them a lot of information about reporting. But equally, you’re trying to then learn from the regions themselves—what their kind of pressures are, coming up with ideas that would work for what can be very diverse organizations.

I introduced talking about, we’ve got fire engineers and civil engineers and economists and all of this vast range. You can imagine the different views on safety. A fire engineer has a very practical understanding of safety as does someone involved in tunneling. But probably someone in an advisory consulting, economic capacity, it’s not something they necessarily touch and feel. So you need to come up with an approach that deals with all of them and equally addresses the cultural differences.

We’ve got five regions. Those regions each have a cultural dimension to them and where things like safety, culture, and procedures and process mean different things to them. So you’re kind of in the middle between what the executives want (which is a general sense of uniformity and comfort to know that we’re getting the right information and, dare I say, a degree of consistency) and then what the regions want (which is a degree of autonomy and something that works for them within their markets or their geographies).

Okay, well, I’m very keen to pull the thread on that executive component because I think that’s the thing that I often hear safety professionals are quite interested in—that ability to communicate with and influence those executive groups.

But before we dive into that, I’d like to just take a pause and…you’ve mentioned here a lot about listening to those regional groups and letting them influence you to a certain degree to make sure that you’re moving things in the right direction. I guess I’d be curious…obviously you’re relatively new to this role, but when you arrive, when your kind of parachute lands here, what does that listening look like for you? You mentioned you have these five geographic regions. Can you give me some examples of specifically how you’re doing that listening to give you an understanding of where those regions are right now?

It’s kind of open questions about what people’s kind of issues are, what their reflections are, building up a sense of trust so that they feel confident to share with you some of the concerns, issues, and equally what their ideas are and openly asking for people’s ideas. Some people come forth with them quite quickly, and others need that kind of permission to listen. I think the other piece to it is if you can talk about career pathways and how their kind of career could fit into further development. For many people in a region or a business entity, safety can be a bit of a one-way road. The longer you’re in that it becomes a bit of an area that you get parked and it gets very difficult to move back into operations or into other areas.

So the ability to move within an organization and potentially to create specialisms…but I think back to your question, it’s asking kind of open questions around:

• What people’s issues are
• What they think
• How they diagnose the problem
• Where they see opportunities of where the safety program’s going

And equally trying to be quite clear about what is it that they would like and what they would not like. Asking them what they don’t want to see. Very quickly though…they say, “What I don’t want to see a big kind of corporate one size fits all approach. I don’t want to see it where you tell me…” But if you give me some sense of direction where you tell me that we’re going to be moving, we’re going to be going in this particular area. As long as I’ve got a degree of discretion around that, then I think that’s particularly key. Then there’s these sources of data—looking at data, looking at what people are doing.

We’ve got a variety of five regions all doing slightly different things. We’ve got some trying new ideas in safety—going out, doing kind of learning team events and listening—trying to look for what’s going right. We’ve got others doing very traditional kind of focus on safety, which is probably more reflective of a traditional kind of risk assessments, procedures, and process. Each of them are at different stages in terms of their thinking. They’re trying to understand what they’re trying to do. We have different versions and interpretations of what is safety within our…that reflects kind of regional differences and maturity. Trying to get underneath the skin of why that is, I think is important.

In this specific example of you coming into this organization, when you worked, when you were unpacking all of that, you’re going region to region and coming to this realization that we’ve got some regions that are a little bit more traditional approach and some are trying to blaze a new path. Who are the people that you were involving in those conversations? Is this exclusively dotted line to the safety professionals in those regions? Are you involving operational management? How is that funnel that you’re using to pull that information in?

So it’s from starting from the board, having discussions with the board members and the boards are interesting because they’ve all got different views. Some actually very traditional, some really looking at kind of, “No, we need to improve.” Others actually seem to be doing okay. Then, working down to the operations. So there’s some corporate operations officers in the organization, CLOs, there’s a series of safety teams, and then looking for specialists in particular disciplines. We’ve got, as we said, specialists in fields, in fire engineering and others. It’s quite wide. HR is always a good source to listen to.

Then speaking to some of the commercial teams. Commercial teams are interesting because they give a sense of actually what customers are asking for. It makes it a lot easier if you’ve got an external voice and a pull on that, too.

We certainly have in many of our markets, customers that particularly in the last two years since the pandemic, are really talking a lot more about safety and the idea that the health of the employees is the health of the business. Now, that’s kind of interesting to hear that from clients.

I wonder, is that something that you saw or I’m curious, that seems like something you probably would have also been hearing about in your experience at Lloyd’s. You know my background is in the maritime space, so I’m quite familiar with the model. I know in that world, safety performance has massive commercial impacts. So I think that it’s, maybe that’s just an evolution that all industries are going through. But, as you know, everyone becomes more cognizant of the fact that safety performance and overall risk management has direct commercial impacts. How would you compare where you are now in this engineering space to that maritime space in the past?

Yeah, it’s interesting. I think safety has been on the agenda in many sectors for decades. And you talk about maritime—I think safety has…I think what’s changed over the past two years is health. You know, there’s organizations… particularly organizations where human capital (it’s a phrase I’m not 100% comfortable with because it becomes, you know, we are a commodity, but if we just run with it) there are organizations where people are the value of the organization.

We’ve kind of always known it, but to actually know that 14% of your employees are absent because of COVID or so many people are not together because they’re worried about stress, mental health, and got issues that they’re concerned with—that really does bring it home, that employee health is actually the health of the business. It adds a new dimension to the idea of safety.

It’s not solely about waiting for an accident to happen and this whole idea that where if you think safety is expensive, think about an accident—but actually reframes it to say actually how people feel and their perception of wellness and wellbeing actually adds another dimension to how we think about safety. I think that’s really been dialled up in the last couple of years. So I think to your question, organizations like Arup and those that actually…the body of knowledge that they have as an organization is what they’re selling, then absolutely, fundamentally, safety and health are key to that because that’s what you’re promoting.

When you’re talking to those commercial interests in these regional groups, are they asking, “Is this a qualitative metric or is this quantitative? Is that commercial division of the business telling you, “James, we need to be seeing these specific numbers,” or is it a little bit softer than that?

No, it’s a subjective discussion. I think many organizations have had an awakening about employee health. They’ve been doing a lot for many decades, but I think it’s really got a lot more attention recently. Some high profile leadership teams have really suffered because of the hours that they’ve put in and just the demands.

So I think it’s a narrative rather than necessarily a number that they’re after. It’s a discussion, but I also think there’s other things at play here. Safety is a really interesting point.

So it’s not solely about what’s coming out of the pandemic. There are other kinds of themes that mean that the spotlight that safety has had over the past couple of years…I think many safety practitioners are going to find that it’s just going to continue for the next two or three years.

Okay. Well, that’s super interesting. I think that the health piece is something that I’m keen to dive into because obviously this is something that is a geography agnostic, industry agnostic right now. It’s a challenge that everybody’s dealing with. Is there anything in particular (and this could be health-related or it could be otherwise), but I’m just curious to pull out again, those very tangible examples.

You’re 10 weeks into this role. You’ve done all this consultation with your various constituent groups. Is there anything you’ve been particularly surprised by that you think other people listening might be worth exploring, whether it be weak points or strong points in the organization that were surprising to you coming from a very different context?

I think if any practitioner goes into an organization that has a kind of federated model, Arup is an organic business. It’s not one that goes out in big M&A activity. It’s grown by allowing people to actually be entrepreneurial in the business.

Now, the challenge with that is how do you get some form of uniformity or harmonization? So if you’re going in as a safety advisor, safety leader into an organization that is not particularly big on top-down rules, but wants some benefit in having governance—how do you get that kind of sweet spot between encouraging some form of uniformity, but not telling people what to do? Models that I’ve used before and I would like to use at Arup are concepts like freedom within a framework, where you have a common framework, but you allow people to have different approaches and different models to how they train, to how they have procedures. But, it’s all within an envelope.

I think it’s a very topical discussion that we are dealing with. We’re going through continuing high rates of growth. We attract people who are creative by nature. So, if you give them a solution, they are likely to turn around and say, “Well, I can do better than that, Joe.” and come up with another version of it. So how’d you put some parameters to actually say, “Yeah, we all need to kind of think about safety and risk in this way. This is our approach to dealing with work at height or to driving.” You’ve got some leeway in there because you’re in Canada and you’ve got some winter issues to deal with and all of the compliance issues, but we do need to have a degree of consistency about how we measure that, how we approach that, so that when people travel around the world, they know that that is our approach.

What we want to avoid doing is having one size fits all, because it won’t work in a practice that’s this multidisciplinary and geographic. So I think this concept of freedom within a framework—how do we apply that into safety, I think is really key. I think the second piece is about health. That’s a really strong debate. I think, like many organizations, we’ve done a lot, but we need to do more in providing flexibility to employees—probably the biggest thing is about where they work and how they work. I think that is a real kind of challenge. The ability to switch off for some employees was them working at home. It’s a constant challenge. So I’d say wellness and wellbeing is a second area.

The third thing that I would say as a reflection is the need to rethink how we approach some areas around risk. Arup’s a designer, so we have the greatest opportunity of prevention through design. So, how do we get better at designing and eliminating risk rather than wrapping people in PPE and providing them with training? How do we move up that hierarchy? That for us is a big kind of challenge.

Yeah. The anticipation pieces. That’s always tricky. I want to take a step back here because you’ve hit on a particularly…a topic that I’m quite enthusiastic about personally, where you’re talking about this freedom within a framework idea. So I think that’s something that I…you know for me, coming from an operational background, the reason that I chose to enter the safety field was essentially trying to address that problem. I was very invigorated around this idea that we keep trying to solve the dynamic problem of risk with static tools and static policies that simply don’t…it’s nonsensical. My belief is there’s a certain degree of intellectual dishonesty in the solving of the problem.

So with that, if you’re trying to institute that sort of methodology of freedom within a framework, is there any particular mechanism that you would be quickly trying to move away from, especially if you’re joining a new organization or you’re trying to change the strategy in your organization to move away from this very top-down static approach, to being a little bit more empowering to the workforce? Is there anything that you would have your eye out for to say, “These are the types of things we need to avoid.”

I think the first thing is have a look at whether you’re using rules or principles. So, “thou shalt, thou must” is a single directive dictate coming from upon high. Whereas if you have a principle that defines a design output, for example, “This is what we’re trying to achieve for work at height. How you get there is up to you.”

This is our principles around driving, or whatever it may be, that provides a degree of discretion. So I think the verbiage and the words you use are really important. Then, also thinking about how you articulate that. So what I really like doing is being very clear about what are the parameters of which we will use and I try and keep things like a light process from group, just to one page. I like the idea of SOAP, which is kind of “summary on a page”. So having principles that are really key, that can be said in a page using very chunky, very simple kind of language.

I think the second thing is articulating what you want people to do. So, what do I mean by that? Within the regions (I can only speak to the work I did at Lloyd’s because we’re still in that formative stage with Arup)…but if we say we’ve got freedom within a framework, so I say, “Alright, we’ve got 12 principles or 18 principles and they cover the key risk areas alongside reporting.” Being equally clear what you want people to do outside of that—and that means innovation. That means trialing things. That means clearly saying to people, “What I’d like you to do is go and pick three pieces of technology and try them. What I’d like you to do is to run a competition in your area or run something different, which gets people engaged.” Now that’s important because what we miss in safety is innovation.

So what if I take the traditional model that I sit in Europe, or if I sit in the US as the corporate Safety Director, and I say, “This is the way we’re going to do it.” What we’re getting is one person’s idea that gets dumped down from upon high. But if we take a freedom within a framework model that actually says, “Right, here’s the set of principles. Here’s the envelope that provides the board of directors a degree of comfort, that we’ve got a degree of control, and the safety team have a degree of uniformity.”

But equally what I’m doing is it making it really clear, right? “Every year I want you to try some technology. I want you to run competitions. I want you to have committees. I want you to come up with five ideas that you can share with people.” That’s the innovation piece. That’s the bit that everyone’s trialing something different. Everybody’s innovating. Then we come together and share some of that and be comfortable to say, “It didn’t work because it didn’t work.” You know, we’re going to try five things and four of them will fail. But at least if they’re trialing in a safe space locally, then we’re not trialing one great idea as a global organization. And we can scale it up—if it looks like a particular program, intervention, or technology works in a geography, we could then try it in another geography and do it organically, rather than I pick the technology and say, “This is this particular type of protective equipment or gas alarm is what we want. Push it down.” And they say, “It doesn’t work for us.”

Do you think that’s something we should be measuring that to create space for innovation, not only through what we say, but also through what we measure? Should you have a metric that you’re judging your regions on? Did you test for technologies this year or do you think that’s too much?

I’ve put it in people’s appraisals before, but that’s probably as close as I get to kind of metrics on it. I think if you make very clear what you want and signal that in performance reviews and say, (in the past past roles, every year I’ve always put things like innovation) “You need to come up with…trial three things. I’m not saying they need to be successful, but just draw on them. I need you to run some competitions.” We do things like client safety days. So we didn’t…we weren’t sure in Lloyd’s (and we won’t do the same in Arup) that clients would be interested in actually engaging with us on safety, beyond the kind of the safety meetings you have on site and the prep meetings. So I thought we’d give it a go.

So we said, “Right, we’re going to arrange client safety days, where we bring clients into…we hire a hotel, bring them in.” It worked really well and the beauty of that is it was their event. They organized it. They had done everything and they were sitting at the back, writing down the notes of everything the clients are sharing with them about different ideas. And it’s this idea that they own that, that’s a 100% their responsibility, and they’ve created relationships locally through clients. The business development team love it because it’s added value that the clients see.

Now, all I did was say, “I want you to have a client engagement event.” And three of them went away and did a whole client safety event. From that, that spiralled, and every region was then doing that. From that we learned and we deepened partnerships. That’s all I’ve done is just set one line on an appraisal and they’ve done the rest.

I think that’s an awesome tactical takeaway for listeners to dive into those things and making sure that whether it’s a department level objective, or simply on an appraisal—creating that space for people to be driven, to be challenging what’s going on, or could be pushing things in a progressive direction. I think it makes a lot of sense.

If you’ve got a corporate…if you’ve got a global team, they’re the safety lab. They’re the individuals that can try things and they can try things safely before we decide that we’re going to move away from a particular method or we’re going to try a new process, because the temptation is in organizations that you move herd-like and everything has to happen as once. You get to find out what works and what doesn’t. Certain interventions work in certain things. It’s not just the technology.

So, in some of the Asia markets I’ve worked in…I’m not a great fan of telling people. That’s not…I may or may not be in the right profession, but I don’t really like doing that. I think that should be the last resort, but I had to reflect early on that actually the Asian teams did like that. They did like a greater sense of direction than the European or my North American colleagues wanted, where they wanted more autonomy and freedom. That was my lesson to reflect that actually for them, it was a sense of uncertainty when the group leader wasn’t giving them direction. So I think you need a bit of…you need to temper that a bit. I’m quite happy with some teams, just to give them a single line. So that’s what we want to do and for others, they just need a bit more structure.

I think you’ve just got to try things and give people the space to innovate and to grow. As long as we’ve got control of the critical risks, as long as we’re managing those things that result in the worst outcomes, then the rest of it should be things that people can try.

Do you think that those critical risks are the circumstances where perhaps you need to be a little bit more authoritarian here, even if it’s not what you’re most comfortable with? I mean, when talking about rules or principles, do you think that critical risk environments are where you need to have rules or do you think in those notice moments it’s not the time?

I think the freedom within a framework concept is that the framework consists of critical risks. So that should be the things that you absolutely need to get right because we’ve got enough data from safety over 40, 50 years to know that things like lockout tag out and fatigue when driving—there is a best way of managing that. It’s not acceptable from a compliance, regulatory, or governance point of view to have it loose. So you need…that’s the bit, but that doesn’t mean that you need 55 page manuals. You can define what needs to happen for a lockout tagout, confined space, work at height, chemical safety program. You can get those basics down to be really clear and crisp. And it’s better for users because for employees, the simpler we make things, the less we put in procedures and we make it more, much more concise—it’s easier for them to remember.

But I think, to your point, absolutely. From a governance point of view, from a responsibility point of view, if you’re going to do anything in safety, you absolutely need to focus on the safety and the fatality and injury prevention pieces that are absolutely critical. The bits around the edges, the bits that have less risk potential, that’s the bit you can innovate in.

When you said that earlier about rules or principles, I think broadly, I agree, but I thought in a work permit, there’s not a lot of room for interpretation on a hot work permit. In these moments, when you might start a fire, the rule is you create a document like this so that we know that that particular high-risk activity is going to be controlled at least within some basic parameters. So I think that…

There’s quite a lot of discussion in safety about things like life safety rules and golden rules. I’m an advocate of stuff like that because I think you provide clarity to people. I think it’s simply not fair to turn around to someone at a high risk situation, performing a fatality to not have clarity workers want that level. But as long as they’re imposed with a degree of understanding where you don’t set them up to fail and say, “You need to follow this rigidly.” Absolutely, regardless of any circumstance, as long as you trust them to make judgements. Yeah, absolutely.

But I think the freedom within a framework concept is the idea that in the heart of fatality and injury prevention…but you’re using human performance techniques to understand where it is they’re having problems or challenges around this, where it is that compliance is a problem, and hopefully creating the culture that people can speak up.

You’ve broached another topic here that I’m quite passionate about which is, again, this idea of…for me, I would classify one of the sort of fundamental missions of QHSE/HSEQ (whatever you want to call the department) is decision guidance. It’s that you’re guiding people to not hurt themselves or have health issues or lead to environmental incidents. The reason we care about the stats and the reason that we measure things is to make us better informed to guide those decisions.

With that in mind, I’m very much aligned with your, dare I say, libertarian approach to safety.

Hah. You’ll get me fired out of this profession for that.

No, but what I’m curious about, where you’re saying, “we need to be (let’s say) suspicious of rules or challenging them,” and saying, “Wherever possible, we should be guiding. We should be providing principles that are empowering the people in the field.” Do you think that there’s any space for…how do you create a correction mechanism within a company to be checking in on the rules we have created and making sure that we haven’t created too many layers to the onion? Is that something that you need to proceduralize to say, “hey, we try to minimize the rules we create,” but do you think that there’s also a space to be recursively reviewing the rules that you do have, and seeing if they’ve become redundant or excessive or things like that? Do you think that there’s space for that? Do you think that companies ever fall down that hole of adding small rules to the point that they become a big spiderweb?

Yeah. One of my proudest moments in Lloyd’s Register was when I was able to look at our safety management system that had grown with all the guidance and all the systems and everything to 650 pages. 650! I was just absolutely overjoyed to order in three dumpsters and take the whole thing down to about 40 pages. There’s an example of just where over procedure lies.

Now, part of it is because people who go into safety are generally risk conservative, right? If they liked risks, they would be a marketing. But because they’re generally quite conservative and they attract a certain personality…and that’s not a dig, it’s generally—you can see it in quite a lot of psychology. If you are attracted to a compliance risk advisory role, you tend to be more conservative in your views.

There’s a tendency to over proceduralize and you put just so much into it and you think, “I need to tell five other things and five other things.” And then you end up with a 15 page procedure. So yeah, absolutely. You can easily lose sight of it. So, let’s take a very quick example.

I came across a procedure once for driving a vehicle. Now, the first thing is, do you really need a procedure for driving a vehicle? It’s a question in itself, but let’s just say you do because it’s one of the biggest fatality risks that organizations have. So, we could play a simple game. We could say, “Alright, what do you think, but you can only have five things? What do you think the five things you need to get right?” And then we can look at the data and actually, it’s make sure that you drive at a sensible speed, keep your distance, don’t use distracted devices, and then you start to run out...oh yeah—wear your seatbelt. When we start to run out of things, how did we end up with three to four page procedures? Pretty much every procedure for a vehicle starts with walk around the car and inspect it, but nobody does that.

So we write in stuff that’s complete nonsense. We proceduralize too much when what we should be saying is that there are five things you need to do. The fifth thing, of course, is take a break. Regularly take a break to make sure that you’re not fatigued. Beyond that, we’re saying too much. But if we can trust employees and say, “We’re just going to tell you these five things. We’ll focus on those five things.” There’s a chance they’ll remember them. There’s a chance that conformity will be higher and we can listen to them about where some of the challenges are that we provide. But I think we proceduralize too much and there’s a second point to this, which is we lose focus on who we’re writing it for.

What do I mean by that? So there’s quite often, you can see when a safety team has lost sense of who it is that they’re in the game for because they write procedures. When you actually ask them, “Why did you write some of this stuff? And they say, “Well, the auditor.” I don’t really care about the auditors. It’s not my bother. You know, the auditor comes around once every year, maybe once every quarter. The fact that we’re writing procedures for employees and we’re writing them too long, using a language that’s got paralegal compliance sentences in it—we’ve lost sense of who the audience is. That often does happen when you end up with procedures that are written not for the workers, but to satisfy an auditor a regulator. So we need to check in on who we’re writing this stuff for and if we do, we’ll probably end up writing less, writing more concisely, maybe even using visual information rather than text.

Yeah. I think definitely a part of that…maybe I would pause it. Certainly part of this is or generates from the psychology of safety professionals and perhaps an overall cautiousness and a desire to make sure that everything is buttoned up as neatly as possible. But I would say that also part of it (and you just alluded to this now) is a technology problem where we focus so much on making small iterations to the way we used to solve the problems and just…I would say that procedures, having a written procedure in a word document on some company’s SharePoint folder is just a very questionable way to manage risk fundamentally.

And what tends to happen is you end up in a cycle of complexity. So, I’ll just kind of break that down a bit. An accident happens. I interview you and I said, “Why didn’t you follow the procedure?” “Well, I didn’t quite understand.” or “The procedure didn’t do this.” Right. Okay. I’ll go away and I’ll write another half a line or another paragraph, or (hopefully not) another page into the procedure. Then I say, “Right, you didn’t remember it last time. Please remember this.” And now it’s three pages long. Guess what, the same thing happens again because I haven’t really listened to you. I haven’t understood the context of why that incident happened and I’ve actually made it more likely an accident is going to happen again.

Procedures are such a dated idea of how to deal with things. We’ve got a generation coming through now who don’t engage with that “too long, didn’t read” stuff—we need to go back and actually, can we go back to more visual ways, more animated ways, more kind of instant ways of communicating with people that speak to a generation that doesn’t do a four page procedure?

This is a thread I’d absolutely want to pull, but I think I want to go back to the comment you made earlier around people, especially health and safety professionals, driving their behaviours based on audit results. I might take a clip of that and send that out to every (you know, given your pedigree) Lloyd’s Register vessel out there in the world because for me, coming from a maritime background, what I can say (and this is something that, again, I’ve seen happen over and over again) is (and I hope anyone listening takes this away) people will take a comment from an auditor and the only way that their management system allows them to resolve it (you know, it’s not a nonconformity, not necessarily an observation) is, “Well, we better add this to the procedure.”

Instead of having that fortitude to say, “We have a procedure that is strong enough, and we appreciate your feedback, but we’ve thought through this.” I think that there is a huge amount of reactiveness there that leads to this. Not all auditors are perfect, all due respect, classifications society or otherwise. I think, with the example you gave around people not reading procedures in that leading to incidents, and then revising the procedure as a result of that—I’ve seen that morph into an auditor wanting to see, “Well, can you show me that each individual on this site has read this procedure?” Then companies are then devoting resources to ensure people have read convoluted procedures, but there’s no correction mechanism to make sure, “Is this procedure sensible? Is it concise? Is it clear?”

It’s just again…I talk to people about this all the time that we cannot…the only solution to the problem is not exclusively to add another layer to the onion. Perhaps we need don’t need it.

What happens with procedures? What we don’t realize is that they are like the snake that kind of winds around our leg. They develop a sense of control in themselves and they become the temple that we worship at. So rather than actually saying, “How are we going to improve work and how are we going to make it safer for the worker and how do we understand the challenges and constraints that they have?” We end up wrapping it into procedures and thinking we’ve done something by actually making the procedure longer.

We need to take a kind of leaf out of the book of aviation who have actually looked hard at their procedures and write procedures for people to understand. They’re not perfect, but they’re certainly leading the way. Then equally to look at other roles—some of the most complex demanding roles that are out there actually don’t use procedures. They use other methods and they trust individuals on judgment. They put people through simulators. They use more kind of tacit based knowledge. But we have got into a situation where we think that the only solution is proceduralizing—writing things in rules, putting them into paperwork. Whereas actually, we would be as good to do the job with the worker for a period of time, understand the kind of challenges they’ve got, and then that may force us to think differently about it.

I want to add some perspective to this—I think it’s easy for you and for me to sit here on this call and say, “Who needs rules? Let’s empower people. You know, we proceduralize too much.” But if I’m a Safety Practitioner or a Director of Safety at a company and an auditor has come in and given us a finding (whether they agree with the finding or not), how would you recommend they react to that? How would you recommend that they triage those results so that that auditor is not hijacking their business? How should they be thinking about these problems to make sure that they’re not adding complexity just in a reactionary way?

Well, I think it starts with being comfortable challenging what the basis of the problem is because what tends to happen with auditors is they come in and it becomes a bit of a one trick pony that the procedure needs to be added in large, refined…rather than actually saying, “What do you actually see is the problem here?” and trying to get agreement on the nature of the problems. I think it starts with challenge.

I then think this concept of simplification or decluttering (whatever we call it), this idea that actually you start from a principle—that more words on a paper does not make safety. So if we are forced by a regulator or an audit body to actually to either proceduralize things (because we should only be proceduralizing things that are really important)—that’s another issue here is we proceduralize too much because a lot of it can be left to judgment or we can design it into the process. Procedures should really be used for things that are particularly important, where there’s real consequences to it.

So if we have to proceduralize, then we need to get to a point of only really defining or writing the things that are of significance. Keep it simple, keep it concise, write it in the language that people can understand, but only do that if you have to. Can we not try and actually use video tutorial, instructions, other forms of communication rather than pen and paper?

I want to double tap on this a little bit because, again, I think it’s this sort of idea of (oh, my dog wants to get involved here).

It’s an interesting topic. I can imagine your dog. I don’t know what kind of procedures there are for dogs, but they can get animated as well.

Indeed, indeed, clearly too many because he’s quite upset.

I think the expression “measure what counts or you will count what you measure” comes to mind here specifically because I think as much as we may aspire to this (and a lot of people that I speak to as safety practitioners would very much agree with everything we’ve discussed here, that we need to reduce complexity, increase engagement), the wall that people often come up against is, “That’s great to say.” But at the same time, it’s very easy for us to measure the fact that we got three comments and two observations and one non-conformity. It’s difficult to measure (let’s say) the efficacy of our documentation, or to incentivize that and equally measure it to something that’s so easy for us to quantify. So do you think in the same way that you spoke earlier around adding an innovation metric to a performance appraisal, do you think that there’s something that companies should be measuring or should be adding to the way that they evaluate their business that keeps them from getting too distracted by these external factors?

Yeah. I think there’s something in your question that probably wants breaking down a bit and that’s kind of about the measurement thing. What often is used in measurement is that people go on and on and on about this idea that what gets measured gets managed. Personally, I think we need to break that one down because it’s a quote that’s often misquoted. So people often say, “you know what gets measured gets managed.” But actually, the fullness of the quote, if people Google it actually brings another dimension. What gets measured gets managed, even when it’s dangerous and corrupts the organization, right? So people take truncated version of this famous quote and they say, “Only things that are measured.”

So the first thing we need to say is, “Only things that are measured are of value and only things that are measured actually get done.” Well, that’s clearly not true because I got up today, I didn’t measure what I did, but I had a really productive day. I’ll hopefully go for a run later. I won’t be measuring that. That should hopefully be enjoyable. So much of what we do in life is achieved and is done without measurement. So I think…I’m not saying, again, it’s like sometimes people interpret what I say as some kind of antidote to this.

I’m just saying we should use things like procedures, rules, and measurements appropriately because they get far overused.

Whether you’re on a vessel, in a factory, in an office—we’re all subject to probably more measurement than we need to be and what we should be doing is not measuring the process, but measuring the outcome if we’re going to do anything. If we measure outcomes, then we’re more likely to give people autonomy in their roles and allow them to innovate a bit more, which will be good for their wellbeing and mental health.

You’ve hit on exactly the point I was trying to make which is that…I think the industry has really latched onto these easy measurements of inputs and we haven’t sufficiently kind of reset that baseline to measuring our success by the outputs of those things. So a very easy example that I used in a conversation I had recently (it wasn’t even my example), someone I was talking to talked about workplace observations and they said, “Yeah, every company has some workplace observation program. They measure those, they’ll compare sites based on the amount of observations they submit.” But, they’d said, “We did not institute this workplace observation program to collect observations. We instituted this program so that those observations could lead to positive impacts on our business, whether that be safety improvements or quality improvements, or overall improvements to the organization.”

If we’re not measuring that, if we’re not creating some sort of metric that says, “Did we receive 600 observations, but only responded to three of them?” Well, then we’re going to fixate on inflating a number that’s meaningless to the business instead of really measuring the efficacy of that program. I think there’s a huge opportunity for a dialogue around that saying, “What’s the next evolution of these metrics, if we recognize that there’s a problem around measurement in the industry?” To me, in a commercial environment, we can’t say we can have no measurements—it’s more saying, when we go into that board meeting, what are the new numbers that we’re going to share with the rest of the organization that’ll allow them to measure our progress, but to measure it in a way that’s meaningful and less destructive?

I think that if we drawback from procedures and metrics, what the common theme is here is safety management, right? If we just forget “safety” from it and just use the word “management”—what has happened over the past 20 years is we’ve adopted these kinds of ISO standards and we’ve said (whether it’s a maritime safety system or typical kind of procedures that you see in an organization)…what we need to remind ourselves is that these are full of representations.

By “representation” I mean there’s work over here that’s the reality of work and then over here is the management and in the middle, they use representation. So we’re using procedures to represent how the work should be done. We’re using metrics to say how the work is actually performing and whether it’s on time. We’re using audits to say what the level of conformity is. The problem with all of these representations of safety is they’re not what’s actually happening.

They rate an interpretation and they become the God and the temple, which start to drive up behaviour metrics—metrics start to become obsessive. We start to say the procedure’s absolutely how the work should be done and when we’re off on an audit—suddenly we think the world’s turned upside down because we’ve got an audit finding. In reality, where the best thing that we can actually do is go and do a management tour and go and do the job. Not observe people doing…no go and do the job. Actually go and put your coveralls on and go and try it for 30 minutes. Try it for a day if you can because it’s the art of doing, not so much a management tour, but management actually going and trying and doing the job for a bit—they would get a much better sense of the challenges of the role as opposed to measuring through representation.

I think important caveat to that, not only doing the job, but also following the various procedures around risk controls that are associated with the job and getting a sense for the fact that what seemed like an innocuous, clerical change in the office has led to thousands of productive hours being wasted on something that’s completely meaningless.

Yeah. Well, what we’ve ended up with…and you talked about worker observation. I don’t really like being observed. I don’t really like being measured. I kind of like the freedom and autonomy. It’s kind of why I chose to join Arup, but I don’t think anybody likes that sort of thing. I know what we want is to be given a degree of autonomy, but yes, we need boundaries and yes, we need critical risk controls. But, they need to be pragmatic. They need to work for us. The best thing I want from a management is compassion and understanding that actually understands these are the challenges of doing the job.

Not trying to say, “No, the procedure must absolutely be followed.” If the procedure can’t be followed, then listen to why I think it can’t because the reality is, the workers actually know a lot more about doing the job than management do.

Do you think that we do enough to solicit that feedback from the workforce?

No, because I think we’re managing through representations. We’ve got this intermediary between the work and management and it’s a management system and it’s become this temple. It’s become this idea that procedures and metrics and audits and behavioural observations are what we’re doing. The fundamental thing that we need to do is actually go and listen and learn from the front line. Go and find out what it’s actually like. Many of the managers have come up through that route. So go back and spend some time. Best thing I would advise any manager, any supervisor to do is dedicate some time to going and doing the work. Not touring, not observing, not talking—listening and doing it. It doesn’t need to be time-consuming.

Just to be cheeky, James, have you put on coveralls since you joined Arup?

Mhm.

There you go. I had to ask. I had to make sure that none of your new team is listening to this and saying, “He’s never done that.”

No, and more than that, when I was with Lloyd’s, the best part was going spending time with some of our surveyors in the yards. It was an absolute privilege just to sit and listen to them. It’s a kind of dated concept now, but the back to the floor initiative is really important.

It’s not going to sell hundreds of safety books on the new method—just going back and actually trying it is a pretty basic idea, but I think it’s pretty important. The same applies when there’s an accident. How many times do you look at a representation of an accident by writing, by reading an accident report, rather than someone saying, “Let’s just go and do the work. Let’s just go and try it for 20 minutes.” So everybody go down from the accident investigation team and try, not observe, just go try and look what happened and see.

I would tend to say that if we measured how many times a supervisor or a manager engaged with the frontline instead of measuring how many million person hours have we had without an incident, I think that would incentivize a lot more positive behaviours than, well, then the inverse. I guess I’ll just leave it at that.

Yeah, I think if we are going to measure things, then measuring how much we’re learning, measuring how much (and I don’t mean how many hours because we end up with another pointless metric which is we’ve all done 200 hours training)…I mean actually how much time have we spent listening and learning? How much time have we spent trying doing the job? And then what is usefully coming through from that, I think is really key.

For sure. So I want to take a quick (I’m sure everyone’s heard enough about us railing on procedures here)…I want to maybe just take a little bit of a step back. You’re in this role, the organization’s growing. Is that growth trend translating into your team? Is that team growing as well? I guess the reason that I ask is, I’m curious for you—you’re somebody with strong opinions, who’s been successful, and you have this tenured sort of pedigree within the safety world. What are you looking for? Whether you’re hiring currently or not, what do you think are those key things for somebody coming into a safety role? How do they need to be looking at things? Do you, do you look for an operations background? Do you look for a certain personality? Do you think there’s anything…?

Yeah, I can, I can talk to three roles I’m hiring for at the moment because they kind of speak to that.

The first role I’m looking for is a Digital Lead. I want to actually digitalize all of our processes because we have quite a degree of variation within Arup, reflecting our regions. So have them all being digitally available, mobile:

• so they are accessible
• so that we can enable people to actually access material
• to get the right information
• to share their experiences, their incidents
• to practice what they’re seeing
• enable managers and everybody to actually see performance data, but to see it visually to enable it to be mobile accessible

So that would be the first thing. Hiring in someone who can…who is digitally competent, gets excited about the idea of digitalization, and probably sees safety digitalization as a pathway, probably to do other roles within digitalization. So for them, their career trajectory wouldn’t be within safety, but it may be that this is a project that they come in and do and then they hand over to someone.

Another role I’m looking for is safety by design. So we talk endlessly in safety communities about the hierarchy of control, but ask yourself the question, “How much chatter, when you go onto LinkedIn or into safety forums, is at the bottom of the hierarchy, about what particular type of training behavioural observation or protective equipment is good?” as opposed to, “I saw a fantastic design the other day that eliminated risk.” We get hardly any conversation at the top of the hierarchy, but we know it’s the most effective, so I want someone to come in as a Safety Design Advisor to really spearhead and to champion that whole piece. Not conversations about behaviour, but how we took risk and eliminated it through prevention through design concepts because that is a fantastic area for us as an organization to promote talk about.

And the third area is about learning. So I’m after someone who can come in and do organizational learning within Arup from a safety perspective—change all of our training because we have quite a traditional method of training. Use much more video tutorial. Try VR to see what we can do in that space. Perhaps try adaptive learning.

We’ve got a very high intellect within Arup. There’s a lot of very clever people. So if I, even if I put it in an e-learning package, the idea of still having to click through it…so the idea of doing an adaptive learning that responds to people’s knowledge and then cut short the course if they clearly know it or provides them the opportunity to feed into it. So trying different methods of learning…and some of this I think will be key for that role.

So three roles. Super interesting, and that I think gives a kind of a flavor to what we’re hiring for and actually where we want to go.

And is there any…you know, again, you’ve been in management roles for awhile. I know for me, there are certainly certain things I’m looking for from candidates, regardless of what the responsibilities are—having strong conviction around what they’re doing, things like that. Is there anything you would like to proactively get out there because I’ll just tell you right now, you’re going to get inundated from software sellers because of what you’ve said and also probably from candidates. Is there anything you would want them to know before they reach out to you as far as the types of candidates that are successful, not only in your organization, but also working with you?

I think innovation and ideas. I’m someone who, yeah, I’ve got opinions, but equally, those opinions are formed by what other people have shared with me and have told me in the past. So I think people’s ideas, strong characters with ideas and thoughts, and deep expertise. I interviewed someone the other day for one of the roles and I was blown away by their knowledge and they were not in a core safety role. They were doing something else, but they had just levels of professionalism and understanding about their particular brief. They had a passion about it. We need passion because safety gets a bit of a bad rap. So actually having a degree of energy and enthusiasm to it, I think is key.

Yeah, I do think.. on safety getting a bad rap…I think that’s the case, but I think one of the things that that’s so exciting for me and part of the reason that we started this show was that I do feel as though there is sort of a growing chorus of people who are earnestly and effectively looking to change the things—and I think this goes back to what you said about design. I think that’s very exciting for me to hear because most of what we spoke about around procedures and around all these other things— those are design flaws. That is a…you have chosen the wrong solution to a problem and that’s a design issue. So I think that’s what I’m excited for as I look forward and I continue to have conversations with people like yourself who are leading large organizations who are not sort of shackled to the ways that we’ve done these things in the past and are looking to earnestly improve them.

You know, it’s my feeling that there is a change in the wind.

I think you’re right. I think we don’t spend enough time sharing ideas of how we’ve eliminated or reduced risk. We spend a lot of time talking about which particular behavioural program is the best or how to write a procedure more effectively, but this is all kind of bottom feeding stuff at the bottom of the hierarchy.

It’s important, of course. I would hate anybody to kind of listen to this and actually think that I’m saying we do away with all procedures. I’m not. I’m just saying they need to be proportionate and used appropriately and written for the user rather than written for the auditor. But equally, we need to spend a lot more time thinking about how we take risk out the business—thinking about how we can reduce the level of unnecessary burden that we place on workers. That is primarily through how we shape the work, how we design the work, and the tools and equipment that we give them

You’ve given me a lot of ideas here. I feel like if companies instituted a…do some sort of frontline survey—what are the procedures we need and what are the procedures that we don’t need—that would probably lead to some interesting insights.

Yeah, I think so or ask the board to go out and actually do the job. Just follow the procedure.

Just follow the procedure and understand that we’re paying people to do this at what cost argument of saying, “All of these things are good ideas.” But do you believe that somebody spending 30 minutes a day filling out some piece of paper that we put in a banker’s box and save for seven years, just in case—that’s not helping our business learn. That’s not helping us understand risk tomorrow. That’s a sort of myopic static activity.

I once went into an organization and I thought I’d have to kind of create an impression at the first board meeting. It was really causing me stressful nights for a long time thinking, “How am I going to make an impression?” So I got out one of the procedures and it was a three-page procedure for driving. Yeah. Someone had actually written a three page procedure. I calculated by how many vehicles and how many trips, how much all this nonsense that was written in the procedure that was adding no value would actually take.

It equated to two and a half whole time equivalents for a year of doing just literally -> Every time you get into a car, check your mirror, do this and all this, and then you need to walk around the car and someone actually wrote in the procedure that you need to check all the tires before you set off. So, you know, we’ve got salespeople constantly on the road who would have to do this 18-20 times a day, and it’s not value adding. It’s been written by someone who’s got no comprehension of actually what the impact is and whether it’s actually beneficial from a safety perspective.

And it was great because you told the board that and you gave them the numbers and they were staggered by it. But we started the conversation with, “Could you just write down on a piece of paper (you’ve only got six things) what are those six things that you would tell a driver to do to get to the destination?” So, of course, they all came up with the same six things, but they didn’t come up with, “walk around the vehicle” and “kick the tires” and “do the cockpit check” because they know that nobody does that.

But again, it’s the “at what cost” argument. I think it’s exactly what we were talking about earlier, is that all of this is, it’s not meaningless, but it’s disingenuous if we’re not measuring the outcomes. If we don’t say, “Hey, walk around the car.” but we’re not finding some way to measure, is walking around the car leading to any sort of reduction in incident? If not, can we relieve that burden on the workforce and help focus on what matters? I think that a focus a little bit more on, again, not just measuring what we could be doing, but measuring, are we being effective and are we actually moving the needle? I think it’s a transition towards a world where it’s not about arbitrary measurement. It’s not about turning safety into a function of monthly reports, but it’s a matter of saying if we’re truly going to be effective and taken seriously within the organization, my belief is that there is an opportunity to do that. It’s just that the devil’s in the details.

Yeah. Correct.

Okay. Well, I’m just looking at the clock here and I think we’re…we haven’t spoken about COVID at all, but…

I’ve spoken about COVID for two years. I don’t need to speak any more about that. I’m done. I’m so over it.

Fair enough. Aren’t we all? So I guess with that, is there anything else you want to put out there before we wrap things up?

No, I think, as I’ve summarized a couple of times, I’m not saying that what we’re doing is wrong. I’m saying we just need to refine it and we need…I think that message about understanding who the audience is and listen, engage, and communicate with them in a way that is meaningful and helpful to them, I think is particularly important. I think you talked about some of the challenges with auditors and we talked about metrics and procedures, all of which are helpful and useful if you use proportionately, but it’s back to what we were talking about earlier about right tool for the right job at the right time.

Absolutely. Okay. I guess with that, James, I will thank you for coming on. I’m really excited to get this out here. I think a lot of people are going to be…I would say find this to be a refreshing conversation (at least I hope). Thank you so much for coming.

Thank you for inviting me, Joe.

Alright. Thank you so much.