7 Establishing: Leadership commitment, policies, procedures and planning

Organisations that blame-the-victim will not prioritise safety management (see Chapter 4); they only consider the active failures (human error) within their businesses and will not genuinely adopt systems-based approaches to address latent conditions.  As James Reason would explain it through his safety culture theory, a learning culture will not exist within these businesses; as Patrick Hudson would explain it, they are likely pathological or, at best, reactive (see Figure 6.2).  In contrast, this chapter takes the perspective of a business that has adopted a blame-the-system philosophy and is now seeking to establish a safety management system.

Learning Objectives

As outlined in ISO 45001:2018, this chapter introduces:

  • Leadership commitment as an enabler of safety management.
  • The role of policy and procedures in establishing safety management in an organisation.
  • The vital importance of planning before establishing a safety management system.

Leadership Commitment

In ISO 45001:2018, leader commitment to safety is fundamental to achieving safety management system success because it ensures the resourcing required to enact the system and establish the safety culture (Standards Australia & Standards New Zealand, 2018).  However, even when taking a blame-the-victim approach, organisational levels of commitment to safety do vary.  As a WHS professional, it is vitally important to determine the extent to which your organisation’s leadership team values, and is committed to, safety otherwise you may face “tensions and burdens due to…general management not embracing ethical values, and safety being regarded as a value while facing financial and economic constraints (Lindout & Reniers, 2021, p. 8518).  If your leaders are not committed to safety, your ability to enact safety and develop a safety culture, is limited (Hudson, 2007).

So how can you determine an organisation’s level of commitment to safety?  Patrick Hudson’s Safety Culture Ladder (see Figure 6.2) is one tool (Hudson, 2007).  Discussions with staff are likely to reveal if a blame-the-victim or blame-the-system approach prevails within the business.  Reviewing an organisation’s safety record would likely position the organisation on one rung of the ladder (pathological, reactive, calculative, proactive and generative) and would highlight any pathological recidivism (repeat offending).

So how do organisations make decisions regarding their commitment to safety?  Again, analysing Hudson’s Safety Culture Ladder it appears that pathological and generative organisations make moral choices, whereas reactive, calculative and proactive organisations adopt a risk-centric, cost-benefit analysis, approach.  Examining the moral versus business risk approach is therefore useful.

A moral commitment to safety

Morality may be defined as “’what is right?’ …respect for autonomy, non-maleficence, beneficence and justice” (Lindout & Reniers, 2021, p. 8515).  The decision by senior leaders to commit to safety is a moral judgement, the “evaluation of actions with respect to moral norms and values established in society” (Thoma et. al. 1991 cited in Li et al., 2017, p. 122).  In making their choice, some senior leaders will take a relativistic stance; they will make their judgement based on the situation or individuals involved.  In contrast, those who “value moral principles of harm/care and fairness/reciprocity more highly…are more likely to experience distress toward harm and outrage toward injustice” (Li et al., 2017, p. 135) and would support safety as a moral impetus.

HR managers engaged in safety management likely have little influence over a senior leader’s moral commitment to safety.  Depending on your moral stance, the value placed on safety may be an important consideration in selecting your place of work.  This said, moral decision-making is not the only driver for the implementation of WHS management, often the impetus is business risk avoidance enabling a business case to be made for safety.

A business-risk derived commitment to safety

Not to be confused with safety-specific risk, business risk may be defined as the “exposure a company or organization has to factors that could lower its profits or lead it to fail(Kenton, 2022, para. 1).  Kenton (2022) suggests that business risk is comprised of four principal risks: strategic, compliance, operational or reputational.  Safety management, at least in its early stages within many organisations, is likely prioritised according to the risk poor safety management presents in the each of these four domains.  However, WHS management also presents good business opportunities, as effective safety practices should mitigate:

  • compliance risk: averting prosecution for negligence.
  • operational risk: with continuous safety improvement enhancing productivity through design efficiencies (better ergonomics), better control of maintenance regimes etc.
  • reputational risk: averting WHS incidents.

Up until this point, we have viewed WHS management as a people-centric HR business function.  This is because the origins of safety management are derived from the Industrial Revolution concurrent with employment relations (labour rights) and unions (see Chapters 1–3).  However, the subsequent evolution of WHS management theory (see Chapters 4–6) has led to a systems-based philosophy which, increasingly, aligns WHS with environmental and quality risk management approaches (Kauppila et al., 2015).  This risk-centric response recognises that businesses need a social licence to operate, an “ongoing acceptance of a company or industry’s standard business practices and operating procedures by its employees, stakeholders, and the general public” (Kenton, 2023, para. 1).  WHS is being drawn into an alternate philosophical frame grounded in sustainability and the triple bottom line, there is now an expectation that business should be reporting on “their social and environmental impact—in addition to their financial performance—rather than solely focusing on generating profit, or the standard ‘bottom line'” (Miller, 2020, para. 5).  WHS management, and its performance outcomes, through this lens are then perceived as a social good sustaining an organisation’s social licence to operate, rather than a worker entitlement.

Box 7.1: John Berry, Social licence to operate

In this video John Berry, an expert in sustainable investing, discusses the implications of the concept of a social licence to operate on contemporary business.


Source: Leckie, T. & Sheridan, L. (producers) (2023). Business for Good: John Berry.
Molloy, J. (video and audio), Pearce, J. (coordinator), Hortle, L. (assistant), Media Production Unit, the Otago Business School. University of Otago, New Zealand.  YouTube

Sustainability reporting is one approach taken by organisations to foster their social licence to operate.  Sustainability reporting requires businesses to provide “an overview of the economic, environmental, social and cultural impacts, caused by an entity’s activities” (External Reporting Board, 2023).  Compiling these reports, usually undertaken for compliance and reputational reasons, can be exceedingly complex.  One strategy to simplify their operationalisation is to have the key performance indicators (KPIs) aligned and managed across business functions within management systems.

Similar to safety management systems (Chapter 6), there are standards are used to manage the business risks associated with the natural environment (ISO 14001) or product quality (ISO 9001) (International Organization for Standardization, n.d.).  Again, these standards are likely to be operationalised via environmental or quality systems before they are audited and certified to independently demonstrate an organisation’s fulfilment of the social licence to operate.  One organisation adopting the combined systems approach to safety management is Unilever (see Box 7.2).

Box 7.2: Unilever, a systems-based approach to managing business risk


The Unilever company logo is a large U comprises of lots of different shapes. The word Unilever is written in cursive font in the same colour blue underneath the large U shape.

Figure 7.1: Unilever’s brand logo
Source: Unilever on Flickr.com, CC BY-NC-ND 2.0


Unilever is a large multinational organisation operating in more than 190 countries (Unilever, n.d.-a).  Given their cross-border operations, they use a standards-based approach to ensure compliance in all jurisdictions where they operate (Unilever, n.d.-b).  Ideally, they would be adopting practices from their most demanding legislative jurisdictions and applying these across the entire business.

The sustainability performance data collected by Unilever is categorised into environmental and occupational [work] safety (emissions, waste, water, and occupational safety incidents), planet (climate action, waste, water, and environmental fines), society (safety at work, nutrition, community investment), and people (recruitment, workforce composition, gender diversity, learning and development, and retention). All these KPIs are verified through independent auditing and certification. Management of quality is implied across their business indicators with references to being a good employer (Unilever, .n.d-c) and their focus on producing high quality consumer products (Unilever, n.d.-d).

Further reading:

Unilever (n.d.-b) Sustainability reporting standards. Available at: https://www.unilever.com/planet-and-society/sustainability-reporting-centre/reporting-standards/ (accessed 12/10/2023).

Seeing safety through the business risk lens—rather than solely through the HR lens—explains why safety management is showcased on the international stage via initiatives such as the United Nations Sustainable Development Goals where safety is implicit in Goal 3: Good Health and Well-being and Goal 8: Decent Work and Economic Growth (United Nations Department of Economic and Social Affairs, n.d.).  As explained by the Institution of Occupational Safety and Health (UK):

Workplace health and safety is all about sensibly managing risks to protect your workers and your business.  Good health and safety management is characterised by strong leadership involving your managers, workers, suppliers, contractors and customers.  In a global context, health and safety is also an essential part of the movement towards sustainable development. (2021, para. 1)

Box 7.3: Air New Zealand, Sustainability Reporting

In its sustainability reporting, Air New Zealand is attempting to communicate all its KPIs in one table that encapsulates environmental, safety and quality risk management at the local level (New Zealanders) through to a global level (UN Sustainable development Goals).


A table from the Air New Zealand sustainability framework with different colored boxes and text explaining the company’s priorities, focus areas, and targets. The framework has a subtitle “Empowering care of our people, community, and planet” in English and Māori. The framework is divided into three sections: “Our priorities”, “Our focus areas”, and “Our targets”.

Figure 7.2: Extract, Air New Zealand 2023 Sustainability Report
Source: Air New Zealand (2023, p. 11).

In this holistic sustainability framework, the first column ‘Caring for New Zealanders’ positions caring for workers as the top priority.  This care is to be achieved, in part, through organisational and staff alignment with the key values of diversity and equity.  There is no specific mention of WHS, but it does infer that Air New Zealand is promoting a just culture which, in turn, can foster a positive safety culture according to James Reason’s Safety Culture theory (Reason, 1998).

The KPI for care towards New Zealanders (employees) is a staff engagement score (output indicator) that is benchmarked against a global measure (Glint’s Global Top Engagement Index with 750+ organisations surveyed) together with input indicators including employee uptake of their Employee Assistance Programme.  The latter metric demonstrates proactive mental health support for workers to address issues, including those outside of work, and is then paired with bullying / harassment prevention programmes (likely input indicators, i.e. number of training attendees) to reduce work-based issues.  Beyond employees, the organisation’s care extends to customers and New Zealand communities, each with their own respective metrics (see Figure 7.2).

Air New Zealand’s local-level care for New Zealanders is then linked to United Nations Sustainable Development Goals to demonstrate a contribution towards global collective efforts: Goal 3: Good Health and Wellbeing, Goal 4: Quality Education, Goal 5: Gender Equality, Goal 8: Decent Work and Economic Growth plus Goal 10: Reduced Inequalities.  These goals are all WHS related directly (Goal 3 and Goal 8), or indirectly (Goal 4, Goal 5, and Goal 10) as they support positive workplace environments.

The second column “Climate Action” reflects Air New Zealand’s environmental performance commitments.  The focus is clearly on the de-carbonisation of their business activities together with offsetting them, via forestry inputs, as a form of climate impact mitigation.  First, they outline how they will create scientifically developed measures to evaluate any carbon reduction followed by a net zero 2050 target and a 10% uptake of sustainable aviation fuel by 2030.  Likewise, the third column is environment-centric “Driving towards a circular economy” and focuses on the potential good that can be achieved through procurement supply chains, from an environmental and social perspective.  The final column “Sustainable Tourism” seeks to balance the environmental impacts of tourism, including their impacts in providing air travel, with the socio-economic benefits that tourism can offer. Air New Zealand links these aspirations to United Nations Sustainable Development Goal 7: Affordable and Clean Energy, Goal 9: Industry, Innovation and Infrastructure, Goal 12: Responsible Consumption and Production, Goal 13: Climate Action and Goal 15: Life on Earth.  Goal 8: Decent Work and Economic Growth is also mentioned, and is likely associated with Sustainable Tourism’s potential positive socio-economic outcomes.

Overall, the Air New Zealand Sustainability Framework identifies both global and local sustainability priorities.  As an organisation that operates across national and regional boundaries, this dual perspective is fundamental to its social license to operate; domestically it will be critiqued for its positive or negative impacts on local communities, and, internationally, its environmental performance will be evaluated relative to other global airlines.

Further reading:

Air New Zealand (2023) 2023 Sustainability Report. Available at: https://p-airnz.com/cms/assets/PDFs/2023-Air-New-Zealand-Sustainability-Report-Final.pdf (accessed 14/10/2023).

While some organisational leaders adopt a relativistic moral stance towards safety and decide “who cares as long as we’re not getting caught” (Hudson, 2007, p. 704; see Figure 6.2), the strategic, compliance, operation and reputational business risks can make a compelling business case for safety management.  Surely even those who take a relativistic stance would see the potential benefits that effective safety management might generate (see pro-safety management arguments as presented in Box 7.4).

Box 7.4:  Creating a business case for safety

The Institution of Occupational Safety and Health (UK) motivates PCBUs to undertake safety management by explaining that safety is important to their business because:

  1. It is morally right to ensure your workers return home safe and healthy at the end of every working day.

  2. By protecting your workers, you reduce absences, ensuring that your workplace is more efficient and productive.

  3. Research shows that workers are more productive in workplaces that are committed to health and safety.

  4. Reducing down-time caused by illness and accidents means less disruption – and saves your business money.

  5. In some countries, health and safety legislation is criminal law and you are legally obliged to comply with it. Legal breaches can result in prosecution, fines and even imprisonment of senior executives.

  6. To attract investors and partnerships you may need to demonstrate your commitment to sustainability and corporate social responsibility, which will include how you protect your workers.

  7. Increasingly, customers want to buy products and services that are produced ethically – so you also need to think about the work practices throughout your supply chain and deal only with ethical suppliers that protect their workforce.

  8. More and more, job hunters—particularly Millennials and Generation Z—seek roles with employers who share their values, so without strong corporate responsibility and sustainability practices you may struggle to attract or retain the best employees.

  9. A good health and safety record is a source of competitive advantage: it builds trust in your reputation and brand, while poor health and safety performance will directly affect profitability and can result in loss of trade or even closure of the business.

  10. Good health and safety at work secures long-term benefits for you, your business and the wider community. (2021, para. 2)

Point 1 adopts a moral stance whereas points 2–10 justify safety management using business risk as the motivator.

However, we should be cautious in judging an organisation as reactive if they adopt a business-risk based approach to safety management, as it be a methodological approach to safety that co-exists with a strong moral commitment to safety.  Dubbink & Van Liedekerke (2020) suggest we should not to misconceive an organisation’s sense of duty as purely being relativistic, in this case as solely being compliance driven.  Fundamentally, what is important here is that you understand that safety management cannot happen without leadership commitment, but also that you consider your moral stance towards safety because this will define how you enact safety management.

Policies and procedures

Once senior leadership commitment is secured, it is time to establish the policies and procedures that will outline the organisation’s interpretation and boundaries for safety management.  These will then establish the behavioural parameters that will underpin the organisation’s safety culture.  Policies may be defined as “rules and guidelines that define and limit action, and indicate the relevant procedures to follow” (Heery & Noon, 2017, para. 1); policy takes a top-down approach. In contrast, procedures are “step-by-step sequences of actions that should be taken to attain particular objectives” (Heery & Noon, 2017, para. 1), and should take a bottom-up approach, as they will only be adopted if are actionable in practice.

While safety concepts may be integrated into broad business policy documents, procedures should be very specific to the safety activity, for example outlining the responsibilities and expected actions of staff during an emergency response.  Policy should set the tone of the organisation’s expectations around safety, while the procedures are how, in practice, to get it done.

Note: At this stage, the procedures being discussed are focused on how to operationalise the safety system, not to be confused with standard (safe) operating procedures that can only emerge via worker consultation when undertaking hazard control (see Chapter 11).



Once policy is in place, formally establishing the organisation’s intention to enact safety management, the planning (P in the Plan-Do-Check-Act) stage of the systems-based safety management cycle begins; often this requires recruitment of staff into key safety-specific roles.  These organisational safety pioneers must have knowledge and experience in the comprehensive end-to-end planning of safety management systems; to evoke success these practitioners begin with the end in mind—the requirements of management reporting that enables continuous safety improvement—and work backwards identifying what is reasonably practicable to achieve.  These staff principally design and manage the system: compliance with the standards, determine the measurable KPIs to adopt, set up internal and external audit cycles to facilitate safety certification, and also continue to engage with senior leadership to ensure the ongoing commitment to safety management and its improvement within their organisation.

Importantly, these safety professionals recognise that it is easy to worry and immediately seek to identify hazards and manage their risks, however, they know that a lack of a coordinated approach quickly turns this into an overwhelming task.  Moreover, they understand that taking this approach could damage the emerging safety culture of the business; by not figuring out how to involve staff in determining what is reasonably practicable and communicating this, workers may become disillusioned when their safety expectations are not met.

Planning comprises designing literally every component of the system, from determining who is responsible for which parts of the organisation’s policy and procedures, through to the specific tools and techniques that workers are to adopt to reduce the possibility of active failures (human errors) combining with latent conditions.  Planning identifies everything required to reduce worker exposure to occupational health and safety (incident-centric) hazards.  While coordinated by systems safety staff, specialist roles may also be established to enable this, such as hiring in occupational health specialists or hazard and risk assessment experts.

Once the plan for how to operationalise the safety management system has been established, the organisation must begin by reviewing the legislative requirements applicable to their jurisdiction; the next chapter focuses on achieving the compliance competency necessary before establishing a safety management system.



Share This Book