When does the language of “zero harm” become unlawful?

I am not a fan of the language of “zero“, either as an aspiration or as a stated goal. It has never sat well with me, and seems so disconnected from day to day reality in both society and a workplace that people cannot help but become disconnected from, or dismissive of, the message behind the term. My view has always been that the language of zero actually often undermines the objectives it is trying to achieve (see this case for example).

If you are interested in this topic (and if you are involved in safety you should be) there are far more passionate, learned and articulate critics of the language of zero than me – See for example, anything by Dr. Robert Long.

However, recently I have been asked to do quite a bit of work around psychological harm in the context of occupational safety and health. In particular, how the legal risk management of psychological harm in the context of safety and health might differ from the Human Resources (HR)/employee relations context.

WHS legislation around Australia expressly includes “psychological” health within its remit and the Western Australian Department of Mines and Petroleum has acknowledged that they regard “health” as including “psychological” health, even though it is not expressly described in the State’s mining legislation.

What has emerged, at least to my mind, is the extent to which our policy, procedure and policing approach to safety and health, far from alleviating psychological harm in the workplace, might be contributing to it.

Safety management might be part of the problem.

In an ongoing Western Australian inquiry into the possible impact of fly in/fly out work on “mental health” the Australian Medical Association identified that the way health and safety is managed can contribute to a “distinct sense of entrapment” (page 43):

The AMA also expressed its concerns about this issue, noting that “[o]nerous rules, safety procedures and focus on achievement of production levels have been shown to create a distinct sense of entrapment in FIFO workers.”

The inquiry drew, in some measure, on an earlier report, the Lifeline WA FIFO/DIDO Mental Health Research Report 2013 which also appeared to note the adverse impact of safety and health management on psychological well-being. For example “[a]dhering to on-site safety rules” was identified as a workplace stress (page 77). Interestingly, the Lifeline report noted a sense of “intimidation” brought on by the number of rules and regulations associated with work on a mine, and :

This sense of intimidation was further mirrored in the outcomes of mining safety regulations which in theory were designed to care for workers but in practice led to inflexible regulation over genuine safety concerns (page 81).

Examples from the Lifeline report include:

… a participant recalled a situation in which a worker handling heavy loads required an adhesive bandage but was unable to ask someone to get them for him because he had to fill out an accident report first (which he was unable to do mid-job); hence he had to carry on working without attending to his cuts. Alternatively, another example of the application of safety rules in an inflexible manner was illustrated when a group of workers were reprimanded for not wearing safety glasses on a 40 degree day even though they could not see from them due to excessive sweating. Hence, safety rules themselves were accepted as a necessary part of work but their implementation in an inflexible uniform manner created stress as workers felt their impact hindered their ability to conduct basic work tasks safely and/or without attracting rebuke. Hence, site rules and regulations could translate into arbitrary and punitive forms of punishment, which undermined participants’ ability to fulfil jobs to their satisfaction and left them feeling insecure with their positions (page 81).

It seems, then, that we need to think beyond our own perceptions of what might contribute to workplace stress and understand the impact that our efforts to manage health and safety might actually be having. Again, as the Lifeline research noted:

… although past research has shown that site conditions and cultures, such as isolation and excessive drinking are problematic, this research shows that the regimented nature of working and living on-site also takes a toll on mental health and wellbeing. From the responses of many participants, it was apparent that following site safety rules (either under pressure of internal monitoring or in the perceived absence of adequate safety precautions by co-workers and supervisors) was a significant stressor. Participants felt unable to apply self-perceived common-sense judgments and also reported feeling vulnerable to intensive scrutinising, intimidation and threats of job loss (page 82) [my emphasis added].

The common criticisms of the language of “zero” seem to me to go directly to the factors that have been identified in this research as contributing to psychological harm in the workplace. The pressure to comply with rules, fear about reporting incidents, the inability to exercise individual judgement on how to manage risk and the inflexible application of process are all side-effects of the language of “zero“.

Up until this point the debate around “zero harm” and its utility (or otherwise) as the headline for safety management has been relatively benign. Apart from the advocacy of people like Dr Robert Long “zero harm” seems to have been perceived as a relatively neutral strategy, insofar as people believe that it “does no harm“, and “what’s the alternative?”.

It seems, in fact, that much harm may be perpetuated in the name of “zero“, and at some point the behaviours that it drives will be found to be unlawful.

It is also going to be interesting to see how health and safety regulators, often the champions of “zero harm” oversee its potential impacts on psychological harm in the workplace. Indeed, it would be very useful to see what risk assessments, research or other measures were taken by regulators prior to introducing “zero harm” style campaigns or messages to understand the potential effects of their interventions, or any subsequent research to understand the potential harm they may have done.


10 thoughts on “When does the language of “zero harm” become unlawful?

  1. Interesting article. Whilst we don’t ever want someone to be harmed at work, either physically or mentally, I totally agree that having a system that is too prescriptive and regimented can be self-defeating. For me the most critical part is to enable employees to perform risk assessments and use their common sense and the tools and training which have been provided to them. The danger with following a system blindly is that if the system is wrong, or doesn’t take into account different situations, then harm can occur. Its a bit like totally following your car’s sat nav even if the road signs say “flooded road” – you are likely to get wet

  2. These experts write about how ZERO HARM is not obtainable and how workers don’t believe in it, but they promote excellence and perfection and reaching maturity and becoming world class or even becoming a HRO. If you want to talk about STRESS and why workplaces become toxic, then striving/forcing people to meet unrealistic targets and budgets and timeframes is more detrimental in my view and needs much more attention that the topic of ZERO HARM.

    My thinking places reaching anything above/below a mean level (regression to the mean) is seeking perfection (something Dr Long calls a mental health disorder), and is not dissimilar to the Zero Harm topic where by some experts constantly say that using this Zero language primes negativity, primes absolutes, primes cynicism and double speak, primes distrust and authoritarianism. I say that so does seeking the other end of the spectrum of seeking HRO status as this the binary position of absolute also (I think it is convenient that these experts have never thought of this).

    You cannot reach ZERO as much as you cannot reach Maturity…so both as bad as each other.

    Some articles replying to Long points on Zero Harm and No Blame.





    Home page http://risksafetycritique.blogspot.com.au/

    1. This is a good reply post and the comments about what is reasonable is on the ball and well said in my view. This is why I find it funny how people cannot agree with what is documented (from learning’s…mostly bad) in codes and standards etc, that have been written to give practical advice.

      How many people when writing a SWMS or a procedure or designing a new device refer to such key documents. They then (after killing someone) go…we didn’t know…well if you had of read what is practicable then you would not be worried about losing your business to incompetence!!! these leaders need to pay for their incompetence as far as I am concerned.

      Sometime practicable cannot be done, but it will have to be a good reason why practicality was not practiced.

      In fact Rob, can you do a specific post on this subject as is what I call simple safety?


  3. Zero harm is quite easy to achieve, on the road, at work, anywhere. Just choose a small enough exposure space (either physically, no of people, duration, etc). Almost all small businesses will achieve zero harm tomorrow. On the other hand if you choose a large exposure space (e.g. car driving over a population of millions over a period of a year) then it won’t work (not at the moment anyway). But if your town wants to have “fatality free minute” then you’ve a good chance that your excellent promotion will be show that it was well received, everyone got the message, you won their hearts and minds, and showed what everyone can do if we just work together.

  4. There is a number of interesting statements in this AMA report. One has to ask if this really represents an actual evidence that OHSMS cause psychological damage.

    I think it is important to clearly distinguish between extreme cases of misuse associated with safety rules, extreme policing and inflexible practices on one side, and a framework for safe work execution which is established by most organisations as part of wide collective learning. Examples from the lifeline report are extreme cases and are certainly not a dominant approach in management of health and safety in mining. Yes, there are some very narrow minded and police like approaches, but they are in minority. AMA report quoted here (in my view) puts forward predominantly one sided view on things. Examples I see in this article are certainly very extreme, but let’s talk about stress for a minute. Some presence of stress is a normal part of life. What if the risk to employees eyesight was greater than inconvenience and discomfort of wearing glasses in degree day? How do we know if this was not the case? At what point do we open the decision making process to everyone and make all rules optional?
    Where does this work well? What part of industry and society which highly depends on human performance works successfully deregulated and completely open to individual risk perception?

    Imagine military operations conducted in this manner or an operation of nuclear power station? Do we make stopping on red light optional and open to individual interpretation of risks and common sense? And what is exactly a common sense, in real terms? Chinese proverb states that only thing which is common about common sense is that is not so common. My life experience aligns with this ancient view. Adherence to rules may not make sense but it does save lives. Mind you there are lots of questionable rules which need to be scrutinised and re-examined, that is for sure. Human fallibility is an issue as much as a virtue. Best accumulated, collective and agreed knowledge needs to be incorporated into a system of work which needs to cater for most people, not for the most knowledgeable, highly intelligent, very risk aware or most educated and experienced. Academics lose sight of this sometimes. We need to continue to recognise our weak points and cater for them, by applying all scientific approaches available. Greater, group benefit and collective agreement on risk needs to prevail.

    Do rules need to be flexible on mine sites? Yes to some extent. The options are there. Every mine site I ever worked on, gave people an ability to stop the work, recognise issues with agreed work methodology and initiate a change via various forms of risk assessment, including the procedures and systems. I have seen changes in procedures and systems occur hundreds of times. All legislations advocate for this via consultative arrangements, yet we call them ‘zero champions’ .Production pressures are a real culprit, of that I have no doubt. Much more needs to be understood developed to cater for this misbalance between production and protection.

    Feeling intimidated on a mine site due to safety rules is like saying that we feel intimidated whilst driving on public roads. Strict rules and liability applies. Is this a workplace stress and entrapment or a real life and ‘normal’ stress we all have to accept in society?
    Are those real workplace issues or something else? Let’s hear other views, but firstly, put yourself in a situation of a senior organisational decision maker or a registered manager on a mine site of 1000 people with all associated liabilities and expectations and see what this looks like from that point of view.
    Language of zero has little to do with failures to implement safe systems of work, display appropriate leadership, work practices and set organisational priorities. Language of zero however has a lot to do with poorly understood meaning of various ‘zero’ rhetoric’s and moral and ethical dilemmas faced by senior decision makers. Understanding what goes on in the heads or those people, seeing the world from their perspective and understanding those issues and dilemmas are the key. It is not surprising that so many people attribute the entire negative observable effects to zero language. It is like blaming a poorly executed advertising for poor sales. Cosmetic at best. Linking it to wide organisational practices as a driver, precursor or a root cause of organisational behaviour is looking for a simplistic explanation, from one restricted point of view only.
    Philosophical approaches and real life are often very different. Unless one experiences all angles (experience at coal face, management and academic levels) tendency to attribute blame to known and familiar will surpass ability to be objective.

    1. Hi Goran

      You know my thoughts. I think you put this post into some good context and I think the point you raise about “all angles” is important. This falls in line with my thoughts on a “collective of safety” concept also, as much as how collective organisation/enterprise risk management should be practiced. You point on workplaces and social rules (road rules) is much the same in my view, that being rules, laws and safety in design are those things that have been borne from our mistakes…if we could imagine and manage uncertainty then not many events would occur that need such controls. As I have said many times, you cannot have a bunch of humans running around doing what they chose to do based on their perception….we already see this every night on the news and this is only a small portion of what would occur if we were not control…while being loose and living in grey sounds great, it can only be practiced in a world full of one…that be you only!

      You also further express in some degree what John said in saying Zero is based on context also. I have said this also saying that there are many tasks we do that have an end result of zero harm…but if you take it the extreme fundamentalist viewpoint like some people do, they will say that a few thousand cells died in you hand while using a hammer, so harm was caused.

      Maybe the purpose of the term Zero is about ‘what we do to try and achieve it’ we all know we are just not going to get a million dollars in the hand, but we all (most) strive for this goal every day. We all (most) want a simple life and free from stress etc, but we all (most) know that happiness is almost an impossible goal to reach, but we try each day anyway.

      One must keep in mind the philosophy of ZERO HARM as presents by Qld Gov…

      (Its aim is to foster a cultural change in the way workplaces think about workplace health and safety so that a zero harm approach is second nature.

      They use the word approach

      Its time to focus energy into solving what we can improve.

  5. Agreed Mark.
    I for one cannot understand why people confuse zero harm with zero tolerance or zero incidents rhetoric’s. They are significantly difficult concepts.
    I am also puzzled why (in this particular context) anyone would view zero harm as an aim towards infinite state, instead what it truly is – a temporary state free of personal injuries. The more often this gets achieved, the better. It is hard to argue with this simple logic. I think this is the point where views fall apart.
    Zero harm only needs to be taken as a moral aspiration, nothing more than that. This is what it means to those who set it on organisational level. As Hopkins so rightfully points out in his work, practices, as true form of organisational culture are another matter altogether, often influenced by other, more complex factors.

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