Pass Me Another SWMS Leo, The Last One Was Too Short

by Dr Rob Long on September 27, 2013

in Robert Long,Work Method Statements,Zero Harm

Pass Me Another SWMS Leo, The Last One Was Too Short

Republished Guest Post by Dr Rob Long – Author of “For the Love of Zero” and one of our most popular regular contributors. See his other articles HERE

Isn’t it marvellous, SAI Global recently advertised new editable SWMSs (Safe Work Method Statement) for download. See the SWMS download media release here


Safe Work Method StatementsNow you don’t have to really assess risk, understand the job or know how to be safe, it’s the ultimate in cut and paste. So when the inspector comes, all the columns will be ruled right, the right words will be in the right place and then you can just go ahead and ‘get the job done’, marvelous. A godsend for ‘tick and flick’.


This of course is not the only source of templates, there are plenty of companies out there who will do all the paperwork for you, for a tidy price. And why do people want templates? Because the time they tried to do a risk assessment on their own, they were marked like a primary school child and corrected for spelling mistakes or sequence. I have some SWMS attempted by subcontractors that were taken recently on to a tier 1 construction site and it is embarrassing what was handed back. It wasn’t embarrassing for the subcontractor, the tier 1 company marked these SWMS like a primary school assignment, in red pen. What a bizarre place the safety industry has ended up when a tool, intended to be a thinking tool, has been made an idol by the religion of rules.

This is where we end up when we make the tool for thinking, the product and an ‘end’ in itself. Rather than understand the meaning of the tool, the purpose of the tool or the dynamic of the tool, it’s now come to this that the tool has become the new idol, let’s worship the tool. The fact that high profile agencies encourage and reward this practice is astounding. It is the ultimate in ‘tick and flick’. Enculturated ‘tick and flick’ is one of the most dangerous practices in the workplace. What is more dangerous than appearing to understand risk and how to manage it, when in reality no assessment of risk has been done. Not only this but, ‘tick and flick’ culture encourages people to dismiss the value of thinking tools and encourage fraudulence as good. And of what value is such a SWMS in court, nothing. The moment the court finds out that the SWMS is meaningless, the company will be judged on the reality of culture not the fake paperwork and cosmetics of safety.

I have been on construction, mining and energy sites this last month and each time I come on site I have been asked to sign on to a one page document an induction of sorts to get me on the job. At the top of the page were quoted the numbers for the SWMS relevant to the job, one was at a high-risk facility. When I asked about the relevant SWMS I was brought out a folder with hundreds of pages and shown the corresponding documents. I was told just to sign the paperwork otherwise the job couldn’t get done and I couldn’t get on site. When I actually asked a few questions about risks on the job it was clear there had been no such conversation. On one high-risk facility I asked if I could bring my phone on the job and was told no. I then asked them if that instruction was in the SWMS, and it wasn’t. However, the SWMS did tell you how to get out of your car and walk to the gate. How absurd has this all become.

With such dominance of ‘tick and flick’ in industry and delusions about the validity of paper in court, we should probably use new language about SWMS. We now need to talk about ‘real’ SWMS, ‘tick and flick’ SWMS or cosmetic SWMS. If you want a cosmetic SWMS, it’s now easy to buy one.

  • Wynand


    I agree with you totally. I am not part of the “Safety team”, my job is to make research as safe as practically possible. One of my pet peeves is the high emphasis safety system auditors place on checking the right boxes. I challenge my team (scientists) often with the question “what value does this add”, and too many times the answer is “nothing – we do it because we have to”. This takes them away from their real job, and create animosity towards safety. I believe it is George’s saying “people support what they create”, so in my opinion the challenge is to get people to create a safer environment, then they will support it. Scientists often challenge “bull”, and some of these challenges have led me to believe “Zero Harm” ideology is incorrect. They asked questions I could not answer until I read the debunking blogs about “Zero Harm”. One of my favourite sayings is “If safety is not about quality, you are not doing it right”. I firmly believe safety is a consequence of quality work.

  • audrey silver

    Hello. I am relatively new to the writings and writers here – but a big fan of challenging debates about safety.

    Although from the UK, we too have the ‘tick & flick’ approach all too often. One can buy (online- paypal accepted) ready-made ‘risk assessments’ and accompanying ‘method statements’ for a range of classic tasks, mainly in construction. This tells me that the construction industry (especially) is tickbox-bound. The client demands paperwork, the contractors supply it. Tick.

    My main comment is really around ‘the checklist manifesto’ – as observed by others, an excellent read. However, the book makes clear that this is not any old checklist approach. The devising of a relevant, focussed and purposeful checklist is a true craft, (as the story tells) and also should really be limited to high-risk safety critical situations, so as not to induce checklist fatigue or dilution.

    I don’t have an answer. I have been perusing safety practitioner job adverts recently. The employers want regulatory compliance, systems, standards (OHSAS18001). They want a person who will ‘ensure’ that no rules are broken. They often add in environmental (OK) and quality management (eh?) with all of those standards for compliance too falling to this super safety hero. They must also be good at training, influencing and in many cases, behavioural safety (whatever they mean by that). Oh – AND have experience in whatever industry the employer is in – however straightforward.

    We – the safety practitioners – have allowed, even encouraged, this kind of mentality. Because so many are checklisters, and view legislation, compliance, systems and “being the expert” as our main value. Very few have, or develop, skills in marketing, change management, psychology, human factors or any other ‘soft’ skills, and employers don’t see these abilities as being relevant either. Same old, same old.

    Rant over . ..

  • Sorry for coming in a bit late on this one sorry.

    As usual, thought provoking stuff from Dr Rob. It is extremely frustrating that plans (eg SWMS) are rejected on form as opposed to content and engagement.

    Ready made outcomes (eg. off the shelf SWMS) are highly dangerous as they are very rarely embedded properly.

    Checklists are helpful to add structure and ensure prompting of the key issues that should be considered.

    There is a balance to be struck between an unstructured “free for all”, and a zealous focus on form over content & engagement.

    To me, leading people through a structured process which still requires them to think and engage is probably the best way to go, however use of “cut and paste” content needs to be managed very carefully.

    None of the prolific SWMS/TRA “apps” that I have seen have quite hit the money here yet. They are heading in the right direction, but unfortunately don’t contain the IP or the IT smarts to result in thoroughness, consistency or engagement.

  • @Sandon Windy? Moi? Whoever would have thought?

    Ah, well, better give you another small breath of air from me…

    I am not sure if your comment is about my support of checklists (if so, please do acquire and read ‘The Checklist Manifesto’ – it states the case wonderfully… and I DO agree the users of checklists must focus… I sometimes work in an 11,000 volt switch-yard where the checklist appears hilarious in its simple statement of steps – eg SPOTTER who is reading the checklist out loud: ‘PICK UP RED KEY’ – to which the OPERATOR responds, once the key is taken up ‘RED KEY IN HAND’ -, but everyone who enters the site at critical changeover times is aware of our ‘sterile cockpit’ mode – where not extraneous chatter is to occur, and all focus is to be on the critical operation. Properly used checklists help us work in dangerous situations safely, so we can return to work in that same dangerous situation the next day, and the next and so on. And I include decent pre-work risk analyses in this as well. Yes, we depend on the very variable psyche of the user… and since ‘attraction plus attraction = distraction’, it becomes so easy to make an oversight when multiple things are happening. Dr.Rob is more the specialist in this murkier area of human foibles, and captures the fact humans are the best and the worst in any system, but checklists, with their possible human failings, are now necessary in our uses of massive amounts of energy. In fact, there is a line early in The Checklist Manifesto, arising from an airplane crash ‘The aircraft has grown too big for one man to fly’ and goes on to emphasise the usefulness of checklists.)

    Now, if your comment re windyness is about my support of the ‘human error’ concept, let’s hope George has enlightened folk as to what I have stated to him and others clearly in the past: our ‘human’ might be a legislator – an MP who participates blindly in the passage of a piece of rubbish legislation; the ‘human’ might be a shareholder in a company who does not give a stuff about safety if the return on the stock exchange is high enough – ‘don’t let safety stand in the way of a quick buck’; the ‘human’ might be a board with similar reasons to the shareholder, making unrealistic policies on maintenance budget or moving operations to an offshore market where WHS has no meaning; the ‘human’ might be the CEO who has inadvertently delegated a task to an incompetent subordinate… and so and so forth all the way down to our little ‘human’ on the shop floor who blithely undertakes a task for which s/he has not been trained. Of course, you can ask George to provide you an example of a non-ecologically caused damaging occurrence that did not involve ‘human error’.)

    Anyway, Sandon, there’s some more wind for your sails to power along and ensure the health, safety and welfare of all those you interact with… and – to keep things ‘windy’ – I’ll close with my old maxim (arising from my salvage diving days of old): ‘Safety: the ability to take my next breath in the most beautiful and comfortable way possible…’

    Enjoy this life!


  • Sandon Rothman

    Luke, totally agree and get your last 2 paragraphs. George, you have stated similar points in your last paragraph/post and agree.
    All, good debating and interesting reading….except for Doug’s windy comments!

  • Unfortunately, checklist thinking is a process of non-thinking. Even as an aid a checklist tends to desensitise humans to thinking and tends to drive humans into automaticity.

  • George Robotham

    Probably at least a year ago I went into considerable detail explaining to Doug why he was on the wrong track with this human error thing. for a copy if you are interested

    • Blimey, George, I thought we at least agreed to disagree on this.

      I recall I asked you to give me even ONE example of an occurrence (apart from a ‘natural environmental issue’ that did NOT – in hindsight – have a human error in it somewhere that, if it were corrected, would have prevented the occurrence…

      Oh, well… Enjoy this life (it is so bloody fragile after all),


  • Dr Rob

    Thank you for this article. How do you manage risk if you haven’t assessed the possibility of it’s existence. It will be a case Russian Roulette. Safety Management is proactive not reactive.
    What about due diligence, consultations, etc.

    It’s mind blowing


  • Hi Rob,

    This is a healthy discussion and frankly one that needs more attention devoted to it, and I’d like to add my perspective as the Managing Director of SafetyCulture Australia.

    The end goal here is to have a safe work place. Generic SWMS were developed to bring the costs down associated with safety and compliance.

    Let’s rewind the clock back ten years, and look at the options facing sub-contractors and small business operators for safety and compliance before generic SWMS:

    Option 1: Spend many hours writing a system from scratch after a day on the tools. This resulted in many employers not having the time to write the required documentation and they would “run the gauntlet” and not implement any compliance documentation for their workers.


    Option 2: Pay a consultant an hourly fee to develop documents specific to the work they are doing.

    Traditionally, small employers couldn’t afford this, and since they never wrote any of it, they usually weren’t familiar with the content at all, and it ended up sitting on shelves collecting dust.

    So the generic SWMS entered the market and provided a lower cost model for employers to implement. SafetyCulture clients are advised to conduct risks assessments, consult with their workers and customise the SWMS to suit their worksite at the time of purchase.

    Fortunately, most do take the time to customise their SWMS, but we still see some people submitting documentation without even entering the name of their worksite or company.

    The idea that a generic SWMS somehow replaces the need to consult with workers, conduct risk assessments, identify control measures and tailor them to suit their work, is not realistic. Generic SWMS are simply a framework, and should be used as one. Anyone who purchases a generic SWMS should be advised of that at the time of purchase.

    A certain percentage of people will always take short cuts and not comply. We have even seen one case where a client purchased a SWMS three days after the death of a worker and then submitted it to the regulator with a forged signature of the deceased worker. We can only help people up to a point.

    Many of our clients are actually safety professionals, who enjoy having a constantly updated library that they can offer to their clients to compliment their consultancy services.

    We also provide on-site implementation and consultation services for those clients that require it. Our aim is to help clients develop a culture of awareness and not rely on third parties that may not be on site at all times.

    I agree with George’s comments that a simple, clear approach is the way to go. Images and diagrams definitely help also, but are expensive to create or license. This is something that the industry could use a lot more.

    Keeping documents concise is also a challenge as more regulations are introduced each year and any edge case that isn’t catered for becomes an area of weakness in the documents effectiveness. Five years ago, our documents averaged 5-8 pages, now they are heading towards 20, which is too much to implement effectively on today’s worksites.

    I personally asked Julia Collins, head of the Harmonisation roll out at SafeWork Australia if a standard SWMS format could be implemented to simplify the process for workers. She said there wasn’t anything being developed at the time.

    Are SWMS still going to be the compliance indicator of choice 10 years from now? I doubt it, and I hope not. This type of top down compliance method is a government driven effort to force employers to operate safely at a time when very few systems were being utilised. It has served its purpose, but over the years ahead I expect it to be replaced with more powerful compliance aids.

    As training systems become cheaper and more accessible, employers will move from a compliance model based on getting a signature, to a model where workers actually develop and refine the systems themselves. This is a worker driven model and it is far more powerful than any current signature based model.

    In February 2012, we released an iPad/iPhone application called iAuditor – as a pilot to answer the question – If we gave workers the ability to create and collaborate their safety initiatives through a public cloud environment, would they do it?

    It is now just over 12 months on, and workers have demonstrated that they are prepared to get involved to create and share safer systems of work. iAuditor has now been used to conduct 3 million safety inspections, and has been adopted by workers globally as a way to develop their own checklists and risk assessments.

    They have shared 11,000 different types of checklists that they created and most of it has been driven by the workers themselves, often without management approval, who are then shown what the workers have created. All of a sudden some of the oldest challenges in workplace safety such as adoption and training have just been overcome. This is far better than a top down model where workers are the last to know about what has been developed.

    In summary, I encourage the discussion around the implementation of SWMS, and we need to remember they are only a tool, as a checklist is only a tool. An excellent book on checklists is The Checklist Manifesto, which goes into a great deal of detail about the psychology behind checklists and the valuable lessons pilots and surgeons have gained from refining on the job checklists in order to work safer.

    SWMS are only effective if they are used correctly, just like any other tool on a worksite. Whether the SWMS is created in-house or developed by a third party, employers still need to conduct risk assessments, consult with workers, employ control measures and review them regularly.

    Luke Anear
    Managing Director
    SafetyCulture Australia

    • @Dr. Rob
      Ahhh, wellll… firstly, Geroge R knows my feelings on the little subject of ‘operator error’… I hold the vast – probably over 97% – majority of damaging occurrences are due to ‘human error’… but before the union blacklists me, note by ‘human’ I include humans of all levels in the organisation(s) (don’t forget, the error may have eventuated up or downstream from your own entity). An outrageous statement? Investigate occurrences and there will be an ‘aha’ moment where some form of human intervention would have either prevented the occurrence, or greatly mitigated the outcomes. Fer gord’s sake, we have even improved our mitigations with extraordinary environmental surprises (e.g. tsunami early-warning indicators)…

      For all this, I know we are all on the path to greatly improve the outcomes for safety for all humans, and regret I am unable to contribute more to these open forums.

      I was pleased to read Luke’s contribution re SWMS, and must add my weight to his recommendation re ‘The Checklist Manifesto’. Interestingly, based as it is on an operating theatre surgeon’s perspective, I think the author’s (Atul Gwande’s) closing observations are handy to note. After enormous energy is put into the creation of life-saving operating and post-operating checklists, he prepares a questionairre for surgeons who have been asked to use the checklists. One question basically asks ‘Would you use the checklist?’, to which there is a mediocre reply. A later question asks something like ‘If you were needing surgery yourself, would you like the operating team to use the checklist?’ to which the vast majority of respondents say ‘YES’…

      We move forward…

      Enjoy your next breath!


  • Chris

    Good luck with your next comment Doug. you need it.

  • Perhaps the underlying story isn’t ‘Zero Harm’ at all. Perhaps it is about zero guilt.

  • George Robotham

    I have come across a number of safety people who work for Zero Harm companies tell me they have their own thoughts on how effective it is, but they shut their mouths in the quest to keep their job

  • Thanks Doug, so how do we set S M Achievable R T goals with a concept that is non-achievable for humans? Why do we narrow down achievement to minutes and days? Why not be bold and set a ZH target for 30 years? Then what do humans do when they fail? In fact, what do humans do, when they are constantly forced into failure by perfectionist and absolutist goals? So, if success is defined as hitting the target, who or what is a fault when we don’t hit the target? Do we dig back into our humanity and come up with some feeble rhetoric as ‘human error’? So, if I live with risk (uncertainty) daily and play poker, then I must know about luck? How does the ZH mindset cope with luck, because everything about ZH is based on control? With a goal and mantra of ZH, what do organisations and people do with matters that are out of their control? Does ZH help them focus on fallibility or control, or does it make the industry just better at counting? Just some questions for thought. My thought is, in the quest to be super human in ZH the controls of paperwork become god-like hence, the need to worship them at all costs. In the end ZH tends to drive a religious experience for most, perhaps not you, but my observation in most who hold to the ideology, it is immovable.

  • My point is that the whole ideology of zero harm is about much more than just some concept of aiming and targets. It is a philosophy of how one views people and culture, risk and language. The ideology of ZH breaks every fundamental rule of goal setting and primes populations to greater risk. Some investigation on the psychology of goal setting maybe helpful here. Your story of the bird and target is perfect, in your story you can see a bird in ZH ideology the goal is infinity, it is a non-human target. What is more interesting, even thinking this binary way about risk and humans drives a limiting way of thinking, it simply makes people more focused on counting and hiding. The safety industry at the moment is so calculative because of this mindset. Anyway, not the place here to have this discussion but we don’t have to agree either. the debate is healthy.

    • @Dr. Rob Ha ha ha…

      I think George was asking me what MY point was re a comment I made that appears to have been lost re the danger not being ‘ideology’ per se, but ‘BLIND ideology’ (eg talking parrot, rote application)… and to a great degree, your expansion provided it, Dr. Rob. This all requires depth of understanding as you state… and humans are always the best and the worst in any system, and I can say first-hand I sure have both aspects – and everything in-between (as David Broadbent also touches on in his regular blog stuff) – available to me in my day-to-day living… I just hope I apply the ‘best’ in critical situations, and “zero injury, illness, damage” is its outcome – i.e. I hit the bulls-eye… Dang! And then I have to hit it AGAIN, next time a critical situation comes along. [BTW I play low-stakes Texas Holdem poker regularly, and often reflect on ‘risk’ and I play percentages of likelihood, and how that affects how much money I put on-the-line based on that risk (with its potential ‘outcome’). And from time-to-time, even holding aces in the pocket, blind luck does its thing, and I lose. However, I am aware of my improvement in on-the-spot risk-awareness over time, and – as the saying goes – whatever we practice we get good at… In the grand scheme of things, our discussions cannot help but raise conscious awareness of what is involved in assisting folk to be more focussed on true-and-fair workplace H&S risk management (I was going to type ‘ensuring’ but in the spirit of your argument, ‘assisting’ is more appropriate!]

      Kind regards and enjoy the next breath!

  • George Robotham

    And your point is?

  • Doug, zero harm is an ideology.

  • HI Dr. Rob and cohort.

    Dang! I have been too busy to engage in arguing some of the negative stuff about ‘zero injury’ and ‘cut-n-paste’ you folk are pushing, but I find you have tilted me over the edge!!! Some quick thoughts to balance some of your ‘over the edge’ stuff…

    Re. ‘zero injury’… With all the background you have, surely you would know a ‘bulls-eye’ has a centre. For us, ‘zero injury’ is a great ‘centre’ to have… whether we get there or not is certainly open to debate along the lines you espouse, but do not blur the centre to aim for. (An ancient INdian tale tells of 3 brothers who are schooled in archery, and each is told to shoot at a bird in a tree. Each is asked by the master archer to say what they see. The first describes the whole scene in front of him and to the sides… The second describes the tree and the branch and the bird. The third says: “I see only the eye of the bird… my target…”)

    Re. ‘cut-n-paste’… You denigrate cut-n-paste? Ha! Fie to thee! (Though I have been guilty of the same…)

    When I was a ‘white knight’ in safety and strode forth to save the workers (and I now delight that in the harmonised states, ‘Worker’ now includes ALL folk who are involved in the inputs, processes and outputs of our workplace, so management at all levels is included!) – anyway, I strode forth and upon discovering a number of cut-paste stuff – even (probably like George) discovering some of my own wording lifted from generic training sessions… I took umbrage and pressured workplaces to create their own specific stuff… To cut to the chase, over the years, I now don’t care HOW the system eventuated – they may have copied word-for-word from a generic code-of-practice or someone’s off-the-shelf safety manual – so long as it is reasonable and is truly APPLIED… Delightfully, we are on the same page with this side of things: any system must be diligently applied, followed by a review and analysis and action based upon that analysis*. If it is discovered there is no need for the system – or part thereof – get rid of it…

    *An aside re this ‘analysis’.. darkly, some of my own cohort and I have a laugh every time some major damaging occurrence happens in the world: “Ahhh, another book for Professor Andrew Hopkins’ is our catch-phrase… and another ‘lessons learned’ type of publication will follow… Fer gordsake! It is not the ‘lessons learned’ we need, but the APPLICATION of those ‘lessons learned’… Ah, welllll… gotta get off me soapbox… enjoy this life!


  • George Robotham

    Rob has explained the problems with safe working procedure implementation quite well, often it is a long, complex, bull shit exercise
    Train people in Job Safety Analysis, apply Job Safety Analysis, involve the people who will use the procedures in their development, keep the bloody things simple and succinct, use pictures, diagrams, flow charts etc and you will have a better result

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