Our discussion today centers around a 2017 Journal of the Australian Petroleum Production & Exploration Association (APPEA) paper, Golden safety rules: are they keeping us safe? by Samantha J. Fraser and Daryl Colgan. Although the paper was published in a trade journal and not an academic one, the research is solid, even though they could have made it semi-structured and somewhat open-ended to find out even more from the interviewees.
We will discuss the pros and cons of “Golden Safety Rules” and a punitive safety culture vs. a critical risk management approach, and analyze the limitations of the methods used in this research.
The paper’s abstract introduction reads:
Golden safety rules (GSR) have been in existence for decades across multiple industry sectors – championed by oil and gas – and there is a belief that they have been effective in keeping workers safe. As safety programs advance in the oil and gas sector, can we be sure that GSR have a continued role? ERM surveyed companies across mining, power, rail, construction, manufacturing, chemicals and oil and gas, to examine the latest thinking about GSR challenges and successes. As we embarked on the survey, the level of interest was palpable; from power to mining it was apparent that companies were in the process of reviewing and overhauling their use of GSR. The paper will present key insights from the survey around the questions we postulated. Are GSR associated with a punitive safety culture, and have they outlived their usefulness as company safety cultures mature? Is the role of GSR being displaced as critical control management reaches new pinnacles? Do we comply with our GSR, and how do we know? Do our GSR continue to address the major hazards that our personnel are most at risk from? How do we apply our GSR with contractors, and to what extent do our contractors benefit from that? The paper concludes with some observations of how developments outside of the oil and gas sector provide meaningful considerations for the content and application of GSR for oil and gas companies.
- There isn’t a lot of good research out there on Golden Rules
- Most of the research is statistics on accidents or incidents
- Most Golden Rules are conceived without frontline or worker input
- Golden Rules are viewed as either guidelines for actions, or a resource for actions
- Some scenarios where workers should not/could not follow absolute rules– David’s example of the seatbelt story in the AU outback
- If rules cannot be followed, the work should be redesigned
- Discussion of the paper from the APPEA Trade Journal
- Answering seven questions:
- Are life-saving rules associated with punitive safety cultures?
- Have life-saving rules outlived their usefulness?
- Has the role of life-saving rules been replaced by more mature risk management programs?
- Do we actually comply with life-saving rules?
- How do we know there is compliance with life-saving rules?
- Do life-saving rules continue to address major hazards?
- How do we apply life-saving rules to our contractors?
- There were 15 companies involved in the research and a one hour interview with a management team member for each company
- Our conclusions for each of the questions asked
- Key takeaways –
- If we’ve got rules that define key roles, they may continue to be relevant
- There are a lot of factors that influence the effectiveness of the rules program
- It’s difficult, if not impossible, to divorce a life-saving rule program from the development of a punitive safety culture
- Critical control management needs to be developed in partnership with your workforce
- So the answer to this episode’s question is – this paper cannot answer it
- Send us your suggestions for future episodes, we are actively looking!
“People tend to think of rules as constraining. They’re like laws that you stick within that you don’t step outside of.” Dr. Drew
“Often the type of things that are published in trade associations are much closer to the real-world concerns of people at work, and a lot of people working for consultancies are very academically-minded.” – Dr. Drew
“One way to get a name in safety is to be good at safety, another way to get a name in safety is to tell everyone how good you are at safety.” Dr. Drew
“They’re not just talking to people who love Golden Rules [in this paper]. We’ve got some companies that never even wanted them, some companies that tried them and don’t like them, some companies that love them. So that’s a fantastic sample when it comes to, ‘do we have a diverse range of opinions.’” – Dr. Drew
“In many organizations that have done life-saving rules, they saw this critical risk management framework as an evolution, an improvement, in what they’re doing.” Dr. David
“I think that’s the danger of trying to make things too simple is it becomes either too generic or too vague, or just not applicable to so many circumstances.” Dr. Drew
Link to the Golden Safety Rules Paper by Fraser and Colgan