The battle between Hazards and Risks
This article was written by Dr. Francois Joubert and & Elsabé Steyn.
This post discusses the following question: "Which Health and Safety risks should belong on the project risk register for the execution phase (construction phase) of the project?"
The "project" part is important and this post will not address any "business" or "operational" safety risks. The argument that "project safety risks" may become "business safety risks", however, remains valid, but is also not the purpose of this discussion.
After I started writing this post, I asked LinkedIn the same question. The outcome of this was fascinating in that it ran from "all of them" to the "context specific ones". The most interesting aspect came from discussion regarding the difference between risks and hazards. ISO31000:2018 states that "risk is the effect of uncertainty on objectives" and the ISO Guide 73 defines the term hazard as "a source of potential harm". In my mind, the consequences of hazards include blood. Therefore, the question should actually be "Which context specific hazards, should also appear on the project risk register?".
It should be important to note, that in the South African context (and your country most probably has similar legislation), the identification and management of construction risks and hazards are the responsibility of management as per Section 8, Duties of Employers. The following aspect are included in the Construction Regulations under the Occupational Health and Safety Act (1993):
Regulation 8(5): A contractor must, after consultation with the client and having considered the size of the project, the degree of danger likely to be encountered or the accumulation of hazards or risks on the site, appoint a full-time or part-time construction health and safety officer in writing to assist in the control of all health and safety related aspects on the site: Provided that, where the question arises as to whether a construction health and safety officer is necessary, the decision of an inspector is decisive.
Regulation 9 (1): A contractor must, before the commencement of any construction work and during such construction work, have risk assessments performed by a competent person appointed in writing, which risk assessments form part of the health and safety plan to be applied on the site.
Taking the above into consideration, the following caveats apply:
It is not a "list of risks" which one can use as a checklist, but about the principles which one can use to determine which risks are included on the project risk register.
Ensure that the Health & Safety risks in your project risk register are aligned to the country laws in which you operate.
This discussion also excludes any discussions related to technical design risks, HAZOP studies and so forth, as these will be covered in a separate post.
To answer the above question, the following arguments were encountered:
The "Maturity" argument.
The "Fatal Ones" argument
The "Qualitative/Quantitative" argument
The "Unusual and Context Specific" argument.
1. The maturity argument
Zaid Omer (https://www.linkedin.com/in/zaid-omer-03662ba/) brought up this argument, and linked it to the ability or requirement to do quantitative risk assessments. He said that "It depends entirely on the level of maturity of risk management in general. At a certain level of risk maturity, using risk registers to manage risks are intended for monitoring and reporting tool. In the case of contracting conditions, it is necessary as evidence to enable draw down from contingency budgets." I believe that this argument is entirely valid, as it touches on the context in which the risks are identified and managed. I therefore put this risk first, as it influences all the subsequent phases.
Immature Health & Safety Management systems tend to have the following characteristics:
Contractors are immature in that they (i) are new and use consultants to create paper-based health & safety management systems. These contractors tend to be unable to conduct risk assessments and are not successful in implemented treatment plans.
Contractors which cannot comply to basic Health & Safety compliance requirements, such as safety files, management plans and decent risk assessments.
Inexperienced Health & Safety officers on site.
Health & Safety incidents are treated with paper, and not with training and changes in behavior.
2. The "Fatal Ones"
The first person I discussed my original question with, is my colleague Elsabé Steyn (https://www.linkedin.com/in/elsabe-steyn-b96b6090/). She is an experienced Health & Safty Agent and her first words were "The fatal ones. As they affect cost and schedule objectives". This comment is in line with a discussion I have with Julie Pagan (https://www.linkedin.com/in/julie-pagan-75054461/). Julie said that she uses fatal risks as the starting point and then considers what that means in the context of the project.
This list of "fatal risks" may be determined during a risk workshop (very effective if the team members consist of individuals that have experience in similar previous projects) or may be derived from published research regarding actual construction project injuries and fatalities. This list of risks will include hazards such as "working at heights", but not “excessive noise from a grinder or other construction plant or equipment", as the latter would not be fatal.
Using this technique to identify Health & Safety Risks, falls into the "we are doing something about the known-knowns". I sometimes feel that risk workshops and project managers spend too much time pondering the "unknown unknowns" and the "known unknowns" and forget to focus on what they already know and can manage. In practical terms, if there is research which indicates that traffic accidents are the number one contributor to deaths on construction projects, this risk should be addressed. I have seen this risk realising, especially when working on railway projects, where travel distances are long and employees speed to get home before nightfall/the weekend.
Fatal risks are in many cases the combination of risk causes and events (or chains of events), such as what happened at Injaka Bridge (https://projectpro.co.za/injaka-bridge-collapse/). The chain of events leading to the bridge collapse was only determined after an extensive investigation and is unlikely to have been identified in a risk workshop prior to the start of project execution. When working with a list of "fatal risks" one also ventures onto the shortcomings of a checklist, as identified by ISO3010. These include "tick the box" behavior and ignoring the "unknown unknowns". The other issue with this method is that an inexperienced project team might not identify all the possible fatal risk events.
Knowing about such incidents like the Injaka Bridge collapse, on the other hand, enhances our knowledge regarding potential "fatal risks" and how they can realize.
3. The Qualitative/Quantitative argument
John said that when doing quantitative risk assessments, he normally has a generic major and a minor safety incident on all his project risk registers, which is then used in modelling short and long safety incidents. He also includes any context specific safety risks unique to a project that could have a significant mitigation cost or time impact. Alberto had a similar argument regarding taking the potential consequences of these risks into consideration when deciding which ones to include in the risk register.
The argument talks about the role of the risk manager. If the risk manager concerns himself with being able to construct a reasonably accurate quantitative risk and schedule model, the focus may be less on the management of day-to-day safety risks. This also fits into the "Maturity" argument, as in my experience, immature risk management systems are rarely concerned with the intricacies of conducting a cost and schedule Monte Carlo simulation.
4. The "Unusual and context specific ones"
This is best described in terms of an example. One of the first projects I worked on, was the dismantling of an old shiploader (https://en.wikipedia.org/wiki/Shiploader). When the shiploader was installed, it was levelled by using radio-active isotopes which were built into the structure. According to the project risk workshop participants, these were not removed from the structure. As the presence of radioactive isotopes are unusual, we included a risk related to the safe removal of these isotopes during the dismantling process. In this case, we also included "working from heights" in the project risk register, as extensive rigging, lifting and dismantling work was going to take place, and was important in the context of the project objectives.
I am also working on a tunnelling project. Unless you are a mining engineer, or working in mines, or for an international tunnelling company, these type of projects are relatively rare, which means that the project teams might not be that familiar with the very specific risks related to geology, water seepage, blasting as a construction method, and so forth. For this project, we decided to include the "tunnelling specific" safety risks on the project risk register as well, as it generates awareness about these risks, and should they realize, it is likely that they could fall into the "Fatal Ones" category. The resulting "duplication of risks" is a small effort in comparison to managing the consequences of a project fatality. These risks are also helpful to prepare team members to the hazards which may be encountered during a site visit.
Whenever I get asked a difficult question during a risk workshop, and I need time to think, I always answer "That is a very interesting, context specific question". The "answer" to the question "Which context specific hazards, should also appear on the project risk register?" is therefore, also context specific, as it depends on which approach is followed to "get to the answer".
Scenario 1: Immature Contractor Health & Safety Management System: All the context specific hazards should go onto the project risk register. Risks and treatment plans associated with the immature Health & Safety Management System should also appear on the project risk register.
Scenario 2: Mature Contractor Health & Safety Management System: This is a function of whether qualitative or quantitative risk assessments are required, and we propose the following when a Qualitative Approach is used:
A risk covering the hazards which may have fatal consequences.
Other context specific hazards which may have material / significant cost and schedule implications or that require unique controls / interventions that if not managed properly can result in cost or schedule impact
Other “unusual” hazards which the project team is not familiar with.
For a Quantitative Approach, the following is proposed:
A risk talking about an incident with major cost and schedule implications. This risk is quantified in the schedule and cost estimate.
A risk talking about an incident with minor cost and schedule implications. This risk is quantified in the schedule and cost estimate.
Other context specific safety risks and hazards which may have material / significant cost and schedule implications. This risk may or may not be quantified in the schedule and cost estimate, to avoid double dipping with the quantified risks in the above block.
From the above article, the issue of risks being context specific was again a thread which ran through the article. It is therefore, very difficult to prescribe rules which may be applicable to each and every project context. It should however be noted, that the above arguments have been derived from the practical experience of project risk specialists, which have worked on a large range of construction projects. As a concluding remark, the following. If you are unsure regarding which health & safety risks to include on the risk register, please invite your Health & Safety specialist / team member to your project risk workshop.
If you believe that you have similar or additional experience, feel free to comment and share your experience.
Copyright 2020 Dr. Francois Joubert & Elsabé Steyn
Copyright 2020 Dr. Francois Joubert