Health and Safety

It is becoming normal to bash the "Health and Safety" for wrecking one thing after another. The latest example is the Tate Modern work "Shibboleth 2007", which apparently is causing chaos and destruction by means of being a hole in the floor.

But it is only natural that we are more risk-averse than our predecessors: we can afford higher levels of security, so why shouldn't we have them? Health is a good thing, and safety is a good thing, so what's wrong with a "health and safety" culture.

Nothing, fundamentally. It becomes problematic is when it gets unrealistic. It gets unrealistic by becoming too formal, too rules-based.

In any organisation, there are two problems. One is that the people working in the organisation do not entirely share the organisation's purposes and priorities, and they can direct the resources of the organisation to their own purposes instead. The other is that rules and procedures cannot cover every contingency; the right decision can only be made by the right person having power to make it.

These two problems can each only be solved at the expense of making the other worse. I've written about the issues before: Deskilling and Overskilling, Microsoft Bugs, School Uniforms and thought crimes, In each case I am complaining about replacing intelligent decision-making with inadequate procedures, however, I would be the last to deny that an absence of any rules governing job performance would cause problems of its own.

We have to balance rules against discretion, but we tend to have too many rules and too little discretion. What drives this is accountability. In a particular case, we might get better outcomes by allowing more discretion, but if something does go wrong, which it can either way, it is more convincing to say "I followed the procedures, but they turned out to be bad" than to say "I made what seemed to me the best decision, but it turned out to be wrong".

The dilemma will always be with us, but I think we could get a more effective balance simply by insisting, when it comes to blame, that obviously stupid procedures are no excuse for anything. If you're trying to write down a procedure, and it clearly is not going to succesfully deal with a large number of cases, give up and say the operative in question must make the best determination they can. We will get more agency problems, more corruption, but less blind stupidity, and I think in balance we will be slightly better off.

Two digressions:

Boris Johnson took some stick for his Telegraph article blaming rule-based health & safety culture for the shooting of Charles de Menezes, but I found it quite persuasive, although slightly speculative. The rule "don't let unarmed surveillance officers arrest a possibly-armed terrorist suspect" was not a stupid one, but avoiding that "listed" risk at one point in time led to being forced to take much bigger risks later, involving probably just as much risk to the officers, as well as the unnecessary death of an innocent man.

It is not just risk where a rule-based system leads to irrational choice between small "listed" costs and larger "unlisted" costs. Part of the process of reducing waste in the civil service (and in private businesses, for that matter) is to set different budgets for different activities. That appears to have led, in one case, to deciding not to provide a specific R&C data dump for the NAO, (which would have resulted in a charge to the budget from EDS), but instead to copy an existing dump, which contained far more information than the NAO asked for. The cost incurred as a result was rather more than a few grand for a couple of days' work by a contract programmer.

Those digressions aside, I don't really have answers, except to tweak the balance in the case of health and safety by declaring that a stupid procedure is no excuse for a stupid action.