Com­pli­ance and safety

Com­pli­ance en­force­ment costs are mul­ti­plied in re­turn, but does it trans­late into safety?

Owner Driver - - Safety Accelerator - Daniel Elkins

THOU­SANDS OF HEAVY ve­hi­cles in­ter­cepted, mil­lions of dol­lars ex­pended on stop­ping and in­spect­ing them, tens of mil­lions in rev­enue col­lected, and po­ten­tially bil­lions in rev­enue lost to our econ­omy. All with no real un­der­stand­ing as to the ben­e­fit it de­liv­ered to pre­vent­ing road trauma in the heavy ve­hi­cle in­dus­try. Some­thing must change in re­gards to this en­force­ment mind­set.

Given the stag­ger­ing amount spent on com­pli­ance ef­forts by reg­u­la­tors—the train­ing pro­grams, hot­lines, and other sys­tems de­signed to pre­vent and de­tect breaches, is in­dus­try not en­ti­tled to see a di­rect ben­e­fit and know the out­comes it is achiev­ing?

For highly reg­u­lated in­dus­tries – like trans­port – the real costs are in the hun­dreds of mil­lions, and ul­ti­mately con­sumers pay for these costs in higher prices. The re­al­ity is, as­sess­ments of the cost of on-road com­pli­ance ac­tiv­ity to the trans­port in­dus­try deeply un­der­es­ti­mate the true costs to the com­mu­nity, be­cause train­ing and other com­pli­ance ac­tiv­i­ties con­sume thou­sands of valu­able em­ployee hours ev­ery year.

Many in the trans­port in­dus­try are in­creas­ingly frus­trated about the grow­ing and im­mense com­pli­ance costs with­out see­ing the ben­e­fits. Yet en­force­ment agen­cies con­tinue to con­duct ex­ten­sive on-road com­pli­ance ac­tiv­ity be­cause they think it in­flu­ences re­duc­ing road trauma. These types of dra­co­nian op­er­a­tions have be­come a box-tick­ing ex­er­cise to pla­cate a gullible pop­u­lace that this in­or­di­nate ex­pense is de­liv­er­ing road safety out­comes.

The lit­eral tragedy is there is no ev­i­dence be­ing pro­duced it is ef­fec­tive, and it all can be avoided. There are an in­cred­i­ble num­ber of is­sues and chal­lenges sur­round­ing en­force­ment agency per­cep­tions of on-road com­pli­ance. Re­search is re­quired to as­cer­tain how well on-road com­pli­ance ac­tiv­ity is work­ing and ex­plain the ben­e­fits to re­duc­ing road trauma. En­force­ment agen­cies must be able to demon­strate they have the right mea­sures and to ad­vise in­dus­try what works and what doesn’t.

What is the an­swer? It is in bet­ter mea­sure­ment of these on-road ac­tiv­i­ties. En­force­ment agen­cies can’t con­duct com­pli­ance ac­tiv­i­ties with­out hav­ing ef­fec­tive per­for­mance-mea­sure­ment tools. Cre­at­ing bet­ter mea­sure­ment can re­sult in ap­pro­pri­ate re­source al­lo­ca­tion and tar­geted en­force­ment lead­ing to more ef­fec­tive out­comes and re­duc­ing road trauma.

BET­TER COM­PLI­ANCE MEA­SURES

En­force­ment agen­cies and the heavy ve­hi­cle in­dus­try must get bet­ter at iden­ti­fy­ing the right mea­sures within their busi­ness if they are to im­prove safety. Com­pli­ance pro­grams can be viewed as an in­surance pol­icy not only for avoid­ing breaches, which im­proves the bot­tom line, but en­sures driv­ers re­turn home.

Any com­pli­ance pro­gram must have sub­stance and not be a se­ries of tick­boxes – flick-and-tick check­lists are sim­ply no longer ac­cept­able. Ev­ery ef­fort should be put into en­sur­ing it is sim­ply not a pa­per pro­gram.

At present, en­force­ment agen­cies have pa­per pro­grams sim­ply re­port­ing the num­ber of in­ter­cept and the breaches iden­ti­fied but not link­ing this back to in­juries pre­vented and lives saved.

Pro­duc­ing mas­sive binders of poli­cies and pro­ce­dures that list reams of con­trols is also not ad­e­quate. Ev­i­dence is re­quired that those poli­cies, pro­ce­dures and con­trols have been mea­sured and track the num­ber of breaches. Im­por­tantly, that means col­lat­ing the out­comes and how those breaches were ad­dressed and the ac­tions you took to en­sure they weren’t re­peated. This is not sim­ply about rep­ri­mand­ing of­fend­ers over and over again for the same of­fences – it’s about pre­vent­ing them from oc­cur­ring.

OUT­BOUND JOUR­NEY RISK

Record­ing the num­ber of rep­ri­mands is­sued and those re-trained or pros­e­cuted is not an ef­fec­tive mea­sure of per­for­mance. This is not a mea­sure of the com­pli­ance ef­fort but an out­come of dis­cov­er­ing a breach. How did you im­prove the risk-man­age­ment pro­cesses to stop it hap­pen­ing in the first in­stance or, in­deed, again?

Don’t se­lec­tively pick and re­port data to pro­vide sup­port­ing ev­i­dence that your com­pli­ance pro­gram is ef­fec­tive – num­bers of breaches doesn’t mea­sure ef­fec­tive­ness.

For ex­am­ple, of what in­ter­est is the num­ber of fa­tigue breaches de­tected? It in­di­cates the propen­sity for of­fend­ing no doubt but this is hardly an in­di­ca­tion of the like­li­hood of a fa­tigue in­ci­dent oc­cur­ring. Clearly the more breaches recorded would in­di­cate an in­creased like­li­hood of an in­ci­dent oc­cur­ring but at what level of fa­tigue, when, at what stage of the jour­ney or shift?

Na­tional Trans­port In­surance data in­di­cates that 68.9 per cent of out­bound heavy ve­hi­cle jour­neys rep­re­sent the high­est fa­tiguere­lated in­ci­dents. This points to poor driver prepa­ra­tion and in­suf­fi­cient man­age­ment prac­tices to as­sess pre-trip pre­pared­ness, not the driv­ing task it­self. It’s about un­der­stand­ing which type of fa­tigue (mi­nor, ma­jor, se­vere or crit­i­cal) is more likely to re­sult in an in­ci­dent. This may re­quire ask­ing driv­ers to record all near-miss in­ci­dents and cor­re­lat­ing this back to driver work di­ary records, pro­vid­ing in­for­ma­tion to de­ter­mine date, time and lo­ca­tion within the shift.

It can be chal­leng­ing de­ter­min­ing how to trans­form a pa­per pro­gram into a com­pli­ance pro­gram of sub­stance.

The fo­cus should be on as­sess­ing the ef­fec­tive­ness of the com­pli­ance pro­gram. For ex­am­ple, ad­dress­ing a breach by a driver is im­por­tant but was the man­ager also held ac­count­able for the breach?

You must recog­nise and ad­dress data that in­di­cates a fail­ure in meet­ing your safety ob­jec­tives.

Train­ing is seen as one of the most ef­fec­tive mea­sures of a safety man­age­ment sys­tem. All com­pa­nies mea­sure com­ple­tion rates and even the to­tal num­ber of hours spent on train­ing per em­ployee, as­sum­ing it is ef­fec­tive if most em­ploy­ees fin­ish it.

Us­ing com­ple­tion rates as a mea­sure does not re­flect the qual­ity of the train­ing nor how much em­ploy­ees put it into prac­tice.

Just be­cause it has been con­ducted does not mean it is ef­fec­tive. This ap­plies equally to en­force­ment agen­cies which re­port on the num­ber of in­for­ma­tion ses­sions and at­ten­dees and laud it as a demon­stra­tion of the ad­e­quacy of their pro­gram.

To as­sess your pro­gram and de­ter­mine if your com­pli­ance pro­gram is us­ing the right mea­sures, there are sev­eral things to be aware of in de­sign­ing it.

IN­COM­PLETE MEA­SURES

When de­cid­ing on good met­rics, you must con­sider whether they are com­plete and record the whole com­pli­ance story.

Record­ing the num­bers of breaches and sanc­tions and who was re­trained is a good point to start. How­ever, a more com­plete met­ric would be to record how many breaches did not re­sult in dis­ci­plinary ac­tion.

It is com­mon to rou­tinely record high­risk breaches and let lower risk breaches go unat­tended or re­main un­recorded.

LINK TO SAFETY OUT­COMES

The pri­mary pur­pose of any com­pli­ance pro­gram is to en­sure you un­der­stand that your safety ob­jec­tives are be­ing met.

Are we pre­vent­ing near misses and in­jury ef­fec­tively and if so how? What data (met­rics) do we col­lect that val­i­date the safety pro­gram’s ef­fec­tive­ness?

If you are un­able to link your com­pli­ance pro­gram to safety out­comes, you are record­ing and mea­sur­ing the wrong things.

PRO­GRAM EF­FEC­TIVE­NESS

How can you as­sess if train­ing, poli­cies and pro­ce­dures have been ef­fec­tively im­ple­mented? A com­pany that does not re­port all breaches and all sanc­tions has a cul­ture that con­dones par­tic­u­lar risky be­hav­iours. These be­hav­iours trans­late to the way peo­ple work ev­ery day. De­spite that an em­ployee has ac­knowl­edged they at­tended train­ing or have read (and un­der­stood) poli­cies and pro­ce­dures, it is not ev­i­dence they are im­ple­ment­ing them.

How you deal with mi­nor breaches is im­por­tant but of more im­por­tance is that you have recorded them and taken ac­tion. It’s about ac­tion, not tick­ing boxes.

“Dra­co­nian op­er­a­tions have be­come a box-tick­ing ex­er­cise to pla­cate a gullible pop­u­lace.”

DANIEL ELKINS has a wealth of ex­pe­ri­ence in the safety and as­sur­ance (com­pli­ance and en­force­ment) space, is a safety ac­cel­er­a­tor and one of Aus­tralia’s fore­most pro­gres­sive safety thinkers.

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