Reframe risk from probablistic outcomes, to recognised working contexts & accepted control schemes

Working at Height Good Practice Advocacy

Ask the GPG to reframe its language around risk as a probabilistic outcome and focus on proactively managing risks to maintain distance from consequences, without relying on calculation. Reasonably practicable is about the weight of actions taken prior to harm, after all, and we are required to manage risk as far as reasonably practicable.

When talking about consequences, the term “likely” refers to a reasonably inferred worst case. For example, falling from 10m is likely to result in death or serious injury.

When talking about risk, we are talking about the “likelihood” of that “likely” consequence happening, which is probabilistic.

The problem is that likely and likelihood are abstract and represent an outcome, not how we got there. It does nothing to inform us about how to control the risks. And working-at-height risks are complex.

There are also many variables and harms that are not worst-case, which should not be excluded. Real incidents usually involve alignment across a series of openings.

Reasonably Practicable is about closing as many openings as reasonable. Focusing on proactive management, rather than avoiding maximal consequences, aligns better with how harm manifests in the real world and with the legislative requirement to demonstrate reasonable care.

Control schemes are about managing our distance from that outcome, and we all agree that the further from a serious outcome, the better.

So, why not use the guidance to focus on the proactive management of the risks, regardless of the potential outcome? People have serious falls and walk away; others have trivial falls and are seriously injured, so the outcome is unreliable anyway.

But doing nothing and avoiding a bad outcome is not good safety. Guidance should reflect good safety by doing two very important things.

1. Remove the need for imagination by presenting the generalised risks and controls explicitly. Ideally across the lifecycle of the controls within specific contexts
2. Remove probabilistic language by describing what good safety looks like for each context as it would look to any observer on the non-event side of an incident.

Hindsight always offers clarity, but by then, it's already too late for someone. Without this proactive clarity, the guidance fails its primary function: to guide decisions.

If you agree, let me be your voice and sign the petition to show support so I can advocate on your behalf.