Making Companies Safe - what works? (CCA ... - Unite the Union

odies, pressure groups and/or the media. They are also more likely to be large organisations
since large firms have greater access to resources and professional advice. 95
If Wright’s model is correct, then firms that display the characteristics outlined above might
be trusted to self-regulate and will be likely candidates for ‘earned autonomy’ status.
Although firms in these sectors will not necessarily have adopted a highly specified SMS, it is
nevertheless the case that systematic management of particular hazards and processes is
mandated through regulations that apply to the offshore oil, nuclear, chemicals and rail
industries. Individual organisations in each of these sectors must produce a safety case, which
should include details of the management systems that operators have in place to prevent and
mitigate major accidents, and to manage and control risks to the health and safety of staff
and the public. In addition, in regulating these firms HSE already rely heavily on auditing their
management systems and interviewing personnel based on that system. 96 These sectors
therefore provide a good ‘testing ground’ for the assumptions outlined above.
However, evidence from a number of major disasters and from regulatory experience with the
high hazard sectors in the UK fails to support either the proposition that organisational
behaviour can be reliably predicted or the proposition that high risk, high profile firms are
capable of achieving levels of internal self-regulation that would justify withdrawal of
regulatory oversight and intervention. First, Wright’s predictive model is not supported by
evidence that emerged during the Cullen inquiry into the Ladbroke Grove rail crash, which
revealed that Railtrack’s management were aware of the high and increasing number of
signals passed at danger (SPADs) in the Paddington area, but failed to take decisive action. 97
Similarly, and as previously discussed, senior managers at P&O were aware of the risk of
ferries sailing with their bow doors open, but failed to take any action to address this risk even
though an obvious and relatively inexpensive solution had been brought to their attention.
Both these companies were high-profile firms, operating in sectors where safety failures posed
a potential risk to the public. Supply and demand for ferry services is relatively elastic, and
whilst demand was relatively inelastic in the case of Railtrack, there was nevertheless the
potential for substantive regulatory intervention. In addition the rail industry had had recent
experience of major disasters, a factor that, according to Wright, should be associated with
higher levels of motivation. 98 Both these disasters, and the management failures that lay
behind them, demonstrate that management behaviour cannot necessarily be predicted and
that management cannot always be relied upon to act either rationally, or in a way that
prioritises safety in the face of competing priorities and pressures. 99
Nor does the empirical evidence necessarily support the contention that the levels of intrinsic
motivation in organisations in certain sectors are sufficiently high to warrant the withdrawal
of routine regulatory oversight and inspection. For instance, Wright et al. (2004) conclude, on
the basis of their review of the international research, that it is extremely doubtful whether
self-regulation occurs:
“without the proactive direction, support and real prospect of enforcement by the
regulator even amongst major hazard organisations that recognise the business
consequences of major accidents.” 100
According to Wright’s (1998) generic model, firms in the chemical manufacture, construction
and nuclear power industries would be expected to have the highest levels of intrinsic
motivation to proactively manage health and safety. 101 However, Wright et al. (2004) point to
the impact of the Nuclear Installations Inspectorate’s reports on BNFL, UKAEA, and British
Energy, “each of which led to major programmes of change”, and argue that this
demonstrates the necessity and effectiveness of regulatory intervention even in highly mature,
major hazard sectors. 102
In fact, an HSE safety audit of Dounreay concluded that many of the problems identified in
the audit were rooted in the fact that the industry had been self-regulating for almost 36
years. 103 This evidence from the UK’s nuclear power industry suggests that adequate standards
of safety may not be achieved in the absence of regulatory oversight and intervention. So
whilst there may be plausible reasons for assuming that some organisations will be more
highly motivated than others, this does not necessarily mean that those organisations are
capable of effective self-regulation. 93