SafeContractor - the final instalment

Firstly, apologies for recent lack of blogging. My father died unexpectedly a couple of weeks ago. I am now back in action, and with plenty to blog about.

We finally said goodbye to SafeContractor in August. They were still trying to get us to use an overly wordy, repetitive and therefore ineffective Health and Safety Policy document. Plus a whole load of other issues, very similar to those we first came up against when this whole fuss started. The H&S policy was just the first thing on their list, and when we failed to persuade them that ours was much better (being clear, concise, not repetitive, and still covering all the key points) I decided enough was enough and we simply wouldn't ever convince them that their materials are (in our opinion) less safe than our own.

Here, if you are interested, is their super-long Health & Safety Policy sample. And here is our version (in draft form - the one we actually issue to staff is much prettier).

Despite being far, far longer, I really don't think there is anything substantive in theirs which is not in ours. Or at least, nothing sufficiently important to warrant the inevitable loss of clarity that would result from extending the length of the document.

Plus their sample is horribly let down by what I can only assume is a drafting error in the very first two clauses (which are almost identical).

Here is the letter I wrote to SafeContractor informing them of our decision to withdraw from their accreditation programme (copied into the HSE):

John Kinge
National Britannia Group Ltd
Britannia House
Caerphilly Business Park
Caerphilly
CF83 3GG


Dear John,

Thank you for your e-mail of 1st August.

We do very much appreciate the work that you and your colleagues have put into reviewing our SafeContractor accreditation. It is a credit to your organisation that you have paid so much attention to our very detailed concerns.

Nevertheless, we cannot escape the fact that we have very different views on managing health and safety. We think that long, repetitious documents with redundant information are dangerous as they are not read properly, the really important information gets lost amongst less important information, and they give the reader the impression (whether justified or not) of being part of a bureaucratic box-ticking exercise.

In our discussions you have indicated that you agree with these principles (of keeping documents concise, readable, relevant etc.). But, in practice, you give far less weight to these principles than we do, to the extent that those principles are completely overshadowed by the competing principle of including as much information as possible, even if it is of minimal importance, or repetitive.

I think that the first two clauses of your sample H&S Policy template are very telling:

“1.1 The Company acknowledges and accepts its legal responsibilities for securing the health, safety and welfare of all its employees, of subcontractors working on its behalf and all others affected by their activities.”

“1.2 The Company recognises and accepts the general duties imposed upon the company as an employer under the Health and Safety at Work Act and subsequent health and safety regulations appertaining to it’s [sic] operation.”

Clause 1.2 says nothing substantive that clause 1.1 does not say. While you might see this redundancy as a trivial drafting error, I think that the fact that such obvious repetition has found its way into the very first section of your sample template says a lot about the (lack of) importance given to producing a concise, readable, effective document. Clearly no-one has read through this document, thinking “Can we make this shorter and clearer? Can we make the key messages more prominent?” etc. No document (whether relating to health and safety or not) would be produced by our organisation without that sort of attention to detail. To you, attention to detail seems to mean “have we covered everything?” To us, attention to detail means “is this document as effective as possible?”

I should emphasise again that we are not rejecting your approach because we want to reduce paperwork, or that we see paperwork per se as burdensome. We are rejecting it because we think it is less safe. We firmly believe that our health and safety documents help foster a safer working environment than we would have if we followed your approach. We therefore no longer wish to seek renewal of our SafeContractor accreditation.

We will continue to work independently to further improve our materials and processes, including taking into account Jim Neilson’s and Steve Pointer’s comments about more formally documenting the process we have gone through to produce the employee-facing material that we use.

Thank you again for the time and effort you have put into this.


Yours sincerely,




Bruce Greig
Managing Director

Less is more in (traffic) safety

Pleased to see that London's experiment with reducing street clutter in High Street Kensington has improved safety, consistent with our own "less is more" philosophy of managing safety.

Two years ago part of Ken High St was revamped, with pedestrian guard rails removed, many traffic signs removed, etc. Accidents involving pedestrians have dropped by a whopping 40-odd% since the changes.

(Reported in today's Evening Standard, but can't find it on their site. Similar, but apparently older, stats are reported here, though.)

Meeting with National Britannia / Safecontractor

So I went up to Caerphilly to meet with representatives of National Britannia (including their divisional managing director, James Ostler) to discuss the curfuffle I have created over our SafeContractor renewal.

I was actually quite impressed: National Britannia have put a lot of thought into what I have said, and took my concerns very seriously. Broadly speaking, this was the outcome of the meeting:

1. NatBrit agree that overloading people with information is counter-productive

2. Our risk assessments are very good, and do a good job of communicating information to our handymen

3. They would prefer to see more paperwork documenting the work we have done to produce those risk assessments (i.e. why we have chosen those risks not others; our process for identifying new risks, etc.)

This is also what the HSE hinted at: that the paperwork we issue to handymen is excellent, but we should have more 'back-office' paperwork to back it up.

NatBrit are going to re-audit our application and issue a revised list of additional things they'd like to see. I doubt if producing this extra paperwork will make our business any more safe, but it probably won't make it less safe (assuming, that is, that they don't ask us to issue more bumf to our handymen, just have it filed away for occasional review in the office) Once I know what new paperwork they would like to see, I will decide whether it is commercially worth the extra time and effort needed to produce it.

One question I did pose, which to their credit they did consider very carefully (and, I suspect, discussed further after I left) was this: "would you ever reject a risk assessment because it was too long-winded?". If one really does believe that over-loading people with excessive information is counter-productive, then it follows that you must reject some risk assessments for being too long. A 2,500 word document about, say, using a Stanley knife is unlikely to be an effective document and should be rejected. NatBrit didn't think they had yet rejected anything for ticking too many boxes, but maybe they will start doing that now?

Safecontractor renewal latest

James Ostler, Divisional Managing Director of National Britannia has invited me to come to their office in Caerphilly to discuss my concerns about our SafeContractor renewal.

So I am up at the crack of dawn tomorrow to travel to Caerphilly in deepest Wales (well, 30mins from Newport, deep enough) to meet him.

Should be interesting.

Safecontractor renewal latest

Well, still haven't heard anything from National Britannia, except for repeated boilerplate letters saying "we are still awaiting additional information from you." Nothing from James Ostler (senior bod at SafeContractor), even though both our SafeContractor auditor and our contact at Workplace Health Connect said they would ask him to call me.

So I have written to him directly, copy here.

HSE responds on SafeContractor

Jim Neilson of the Health & Safety Executive has responded with a thoughtful and detailed letter regarding our disagreement with National Britannia and our SafeContractor renewal. (see earlier posts)

He broadly agrees with our position, saying that "health and safety should be about practical actions that make a difference, and not paperwork for its own sake."

He advises me that a colleague will raise this issue with National Britannia, and draw their attention to what the HSE considers to be sensible risk management. And they will write to me again advising me of the outcome of those discussions within a month.

Which I think is very good of them, top marks to HSE, zero marks so far to National Britannia.

I note in passing that if you Google "safecontractor renewal", you get my blog at #1 spot, with SafeContractor's own site some way down the search results. And even just Googling "safecontractor" has me at #5 or thereabouts.

Lord McKenzie responds on Health & Safety (sort of)

Lord McKenzie's office has responded to my letter about SafeContractor (see this post here, and also more background here and here), saying:

"Lord McKenzie read your letter and attachments with interest. He was pleased that your experience of working with colleagues on the Workplace Health Connect programme was successful, and wishes you success in the future."

Hmmm. Well, with the greatest of respect to His Lordship, he may well have read my letter (copy here), but clearly didn't get past the third paragraph.

A colleague has suggested that the best way to contact a Minister is via our MP, that way (apparently) you are assured of a more detailed response.

More on Health & Safety

Finally spoke in detail to the auditor at National Britannia who is responsible for our Safecontractor renewal.

Had a predictable discussion about how, yes, they need to see thousands of words of guff, and no, our safe, concise, effective new materials just won't do. We spoke in some detail about using sharp tools, as an example. We have a single generic risk assessment about using sharp blades. Copy here. Basically reminds you to secure the workpiece (less chance of slipping), keep yourself out of harm's way (so if you slip you don't cut your hand off), wear gloves (so if you do slip, and somehow slip blade onto hand, injury reduced somewhat).

But that's just not enough for NatBrit. They want to see a separate risk assessment for every job where you might be using a sharp blade, plus a method statement to describe the steps to take to perform that task. So one risk assessment plus one method statement for cutting a carpet tile; one for opening a package; one for cutting into plasterboard, etc. And then (although I think he was just getting carried away here, and he can't have really thought this through) they also want risk assessments for permutations of tasks (e.g. cutting into plasterboard while also up a stepladder). Not sure how good our man is at arithmetic, but if you had risk assessments for every job and every combination of jobs, you really would have a book full of worthless guff.

So, I have written to Jim Neilson, who is the man at HSE responsible for the Workplace Health Connect programme (through which we produced our new materials); copying in Geoffrey Podger (HSE Chief Exec) and Lord McKenzie of Luton (Minister responsible for the HSE).

Copy of my letter is here.

National Britannia SafeContractor vs HSE Workplace Health Connect

As mentioned in previous post we are having some trouble renewing our National Britannia SafeContractor accreditation after revamping our Health & Safety procedures under guidance from the Health & Safety Executive (under their oddly-named "Workplace Health Connect" programme).

We think our new H&S stuff is great: concise and effective. National Britannia basically want us to reinstate all the pages and pages of guff we used to have, which no-one ever read, but which tick all of NatBrit's boxes. But managing safety should be about reducing risk, not ticking boxes.

Here is an example: click here to see the sort of waffle NatBrit would like us to say about working at height. Over 1,000 words of guff.

Now click here to see our version. 150 words of clarity.

Which is more likely to get our handymen to be careful with ladders?

(Ironically, the HSE themselves contract NatBrit to manage their H&S advice line. I've told NatBrit and Workplace Health Connect about this whole palava, hopefully they'll fight it out amongst themselves and our concise, clear, safe documentation will win the day.)

Elf n' Safety

I mentioned elf n' safety in my previous post (about how we re-jigged our H&S paperwork with the assistance of the HSE through their "Workplace Health Connect" programme).

The upshot of the re-drafting was that we turned our 100+ page A4 H&S manual into an 11 page filofax insert to issue to all our handymen.

Why did we previously have such a huge H&S manual? Because we had written a risk assessment and "method statement" for pretty much every conceivable situation. We thought we had to do that, but I had for a long time thought that such thoroughness was counterproductive: if you give an employee a 100 page document to read, he probably won't read it, or if he does he is unlikely to remember much about it.

And if you issue to people a document about which they are generally dismissive (which they would be if it told them how to safely change a lightbulb), you risk making them generally dismissive about all safety issues, which is bad.

In reality (we think) there are a small handful of potentially dangerous situations that our handymen are exposed to. And our new H&S material focusses purely on those situations, with a simple one-page risk assessment about each one, plus real-life examples of where our own handymen have incurred injuries doing those tasks.

A graphic description of Patrick's hand after he sliced it with a Stanley knife is a lot more effective than burying a warning about sharp implements somewhere amongst hundreds of pages of waffle about elf n' safety.

Every additional bit of information you add to a document inevitably reduces the impact of existing bits of information. So if you add a risk assessment about a lightbulb, you reduce the impact of the (more important) risk assessment about working at the top of a ladder. And if you add dozens and dozens of risk assessments about relatively trivial risks, the really important stuff is completely drowned out by the noise.

Why am I blogging about this?

Because, this week, our National Britannia Safecontractor accreditation renewal was delayed because their assessors didn't like our new (shorter, focussed, safer) risk assessments. They gave us an example of what they think a risk assessment should say (several hundred words, small print, lots of superfluous and redundant wording); and I think they think we should have more than the half-a-dozen or so that we have.

It will be interesting to see how this pans out: there is no way that I am going to revert back to our previous H&S manual. But of course National Britannia will want to cover their backs: as far as they are concerned the more paperwork we show them the better, I would imagine. So will they listen to what I (and HSE) say? Will I persuade them that our new H&S manual is a million times more effective (=safer) than the reams of waffle they would probably rather we produced?