CIRAS can often nudge a company into re-thinking its approach to a long-standing issue that hasn’t yet found a resolution. This article explores the origins of nudge theory, its applications to health and safety reporting, and the role of confidential reporting within it.
The whole concept of nudging behaviour has become very popular in the last few years. The concept really took off with a ground-breaking book called ‘Nudge’ by Thaler and Sunstein in 2008. The approach has been adopted on both sides of the Atlantic, with various industries taking an interest in how it can help influence people’s behaviour.
Nudging isn’t about telling people what to do - it’s about prompting desirable behaviour. Health and safety professionals who advise senior management teams on how to create safer working environments have begun to embrace the concept of nudge in some of their activities, but there is certainly greater scope for utilising confidential reporting in this connection. In certain circumstances, a nudge from a confidential report has the clear potential to prevent an accident.
In theory, most railway staff know instinctively that safety reporting can help prevent accidents and any related fatalities or injuries. And positive reporting behaviours can easily be embedded in competency frameworks as representative of a mature safety culture. But despite knowing that reporting is the right thing to do, people may often fail to report safety issues which are of ongoing, or long-standing concern.
In challenging operating environments, it may be simpler to avoid the effort involved in reporting altogether. What is an even more worrying state of affairs, though, is that in our experience some workplaces actively discourage reporting.
Improving internal reporting systems
To somebody in a safety critical role, if they perceive making a report internally will make little difference they may decide it will be nothing more than a wasted effort. Or the fear of reporting in the first place may stop a report dead in its tracks. Clearly this is a situation we all want to avoid - reports that are not allowed to surface will never be acted upon either.
So the big question is, ‘How do we nudge people at all levels – from cleaner to managing director - into reporting safety concerns as much as possible?’ The good news is that nudging staff into reporting does not necessarily require much capital investment. Often, all that is needed is a subtle re-design of forms, signs, processes, or the physical environment. By considering all the environmental influences and the fear factor involved in real-world reporting, the approach can help:
• nudge people into reporting by making it as ‘painless’ as possible
• display clear information on what, when and how to report
• provide subtle cues and messaging about the related safety benefits
Nudge-based solutions for reporting can be intuitive, but simple and effective at the same time. The beauty of this approach is that there is less of a need to moralise about people’s apparently apathetic reporting behaviour. We can always say in hindsight something should have been reported before an incident happened, but that tends to focus the attention on particular individuals who were in a position to report in the first place. It’s a shared responsibility – clearly there are many ways management can encourage and reduce the psychological barriers to reporting. For example, memorable poster campaigns and reminding staff that their peers are already reporting safety issues - big or small - can nudge others into doing the same.
Managers can positively influence their staff to report as much as possible. But the nudge principle can obviously work in both directions and they are not mutually exclusive.
The confidential reporting nudge
In the other direction, confidential reporting can nudge managers in a facilitative way. Health and safety managers are prompted by CIRAS reports to evaluate their existing safety management systems and respond accordingly.
In the last twelve months, there have been some good examples of CIRAS nudging management behaviour when a report has highlighted an issue:
• Several practices perceived as unsafe at a major contractor were highlighted. Communication was improved and further training and briefing were provided.
• Contradictory signage on a part of the West Coast mainline was rectified following a full investigation. Other geographically adjacent areas were also checked for similar issues.
• A non-compliant coach lifting procedure at a train operating company’s depot was addressed. The practice immediately ceased and correct process was implemented. Improved briefing was also introduced.
• Shunting procedures in a large depot were reviewed by a train operating company and improved briefing provided.
• Station dispatch arrangements were reviewed comprehensively by a train operating company with a specially arranged site test. Improvements have been identified.
These are just a few real life examples of where confidential reporting has made a big difference with a small nudge. We also compile statistics on the actions companies take in relation to our reports. Between May 2011 and November 2013, all our returned evaluation forms from companies receiving confidential reports were analysed. Each respondent is asked about the actions they have taken in relation to the confidential report they receive. Over this period, an impressive 911 actions were taken by companies in relation our reports and a breakdown of these is shown below.
‘Active monitoring’ - the specific attention paid to a particular safety issue - accounted for 24 per cent of cases. This was followed by the category ‘Planned action’ (18 per cent), which is the explicit intention to carry out a safety-related action in the future. Though one could argue these categories are perhaps a little difficult to pinpoint, many of the other categories represent fairly substantial, measurable actions. ‘Investigation’ (15 per cent) and ‘Briefing’ (12 per cent) may of course have quite a considerable impact on safety related behaviour, for example.
In 4 per cent of cases an audit was undertaken after a confidential report. In 3 per cent of cases, safety equipment was provided. Infrastructure faults were attended to in 2 per cent of cases and the figure is the same for the provision of training.
Breakdown of outcomes from CIRAS reports
The role of confidential reporting in nudging management behaviour
The overwhelming majority of reports to CIRAS have been reported through company reporting channels before reaching CIRAS. Yet 70% of these reports will still prompt, or nudge, a form of positive action from the company concerned. So in most cases, the company has already been made aware internally of the particular issue. However, for whatever reason – under appreciation of the risks involved, local politics, or general inertia – the issue has remained unresolved. There is something about receiving a confidential report which frequently makes the difference.
As a facilitator, CIRAS can never act coercively or enforce actions like a regulator could. Nevertheless, a lack of regulatory power may be CIRAS’s trump card. Nudging managers into re-thinking their standard responses is likely to be more effective without the shadow cast by a regulator. For managers keen on learning from reporting, it is about proactively reviewing the current safety management system and spotting potential weaknesses before a safety incident takes place.