#BeTherippleblogs - A Call to Include Mental Health Injuries as 'Reportable Incidents' Under RIDDOR Regulations

13/9/2021

Image: https://www.hse.gov.uk/statistics/causdis/stress.pdf

We are delighted to share a blog piece written by Nigel Bowker. The piece is entitled, 'Mental Health and Safety'.

Nigel is a Chemical engineer with 43 years experience of process design in oil & gas developments and operations including pipelines, HS&E & contractor management. An independent consultant since 2008, Nigel is also an instructor for the IChemE in a variety of safety-related subjects.

You can find Nigel on LinkedIn: Here

Over to Nigel:

A Call to Include Mental Health Injuries as 'Reportable Incidents' Under RIDDOR Regulations

Image: https://www.hse.gov.uk/statistics/causdis/stress.pdf

Whereas workplace physical injuries have been in decline over a long period, mental injury statistics are showing no improvement. The thesis of this article is that we should adopt those same techniques that have helped to deliver improvements in physical safety to improving the workplace mentally.

Introduction

The brain is a remarkable organ, capable of almost unimaginable things. It consists of more than 100 billion nerves communicating through trillions of connections called synapses. It can be damaged by the actions of others just as surely as the body can be injured physically.

The damage mechanism is understood to be as follows:

The hippocampus is located near the centre of the brain. It stores memories and regulates the production of a hormone called cortisol. The body releases cortisol during times of physical and mental stress. If excessive amounts of cortisol are sent to the brain due to a stressful event or a chemical imbalance in the body, this can lead to problems. In a healthy brain, neurons are produced throughout the adult life in a part of the hippocampus called the dentate gyrus. Long term exposure to increased cortisol levels can slow the production of new neurons and cause the neurons in the hippocampus to shrink. This puts you at increased risk of many health problems, including anxiety, depression, digestive problems, headaches, heart disease, sleep problems, weight gain and memory and concentration impairment.

Post traumatic stress disorder (PTSD) is caused through a similar process.

Some people are under the impression that their bad behaviour doesn’t cause any actual damage to others and is therefore OK. They are wrong. It damages the brain. Everyone should be more aware of that. Such events are “mental injuries”.

The Impact

What could the result of brain damage such as this be? There is no straight answer to this, any more than there would be if you ask me “what damage would I do to my car if I crashed it?”. There are a range of possible outcomes, including:

•            Nothing;
•            Short term mental damage;
•            Long term mental damage;
•            Lost time associated with short or long term mental damage
•            Suicide.

To help us see how well as a nation we are doing, there is detailed UK data for work-related stress, depression or anxiety, defined as a harmful reaction people have to undue pressures and demands placed on them at work. The latest data (rate per 100,000 workers) is detailed below:

Image: https://www.hse.gov.uk/statistics/causdis/stress.pdf

As the text on the chart says: “The rate of self-reported work-related stress, depression or anxiety was broadly flat but has shown signs of increasing in recent years.”

This is a chart of estimated days lost (in millions):

Image: https://www.hse.gov.uk/statistics/causdis/stress.pdf

This is flat over the last 20 years, at best. These figures will be significantly worse than shown since many events are simply not reported.

What’s being done?

Given that things aren’t improving in the UK and many other countries, what is the way of addressing it? “Mental health” is the normal answer and indeed organisations are keen to proclaim their support for mental health and have implemented programmes. The content of these programmes, of course, differs widely. The UK Health and Safety Executive has developed a set of Management Standards which address:

Demands – issues such as workload, work patterns and the work environment;
Control – how much say the person has in the way they do their work;
Support – this includes the encouragement, sponsorship and resources provided by the organisation, line management and colleagues;

Relationships – this includes promoting positive working to avoid conflict and dealing with unacceptable behaviour;
Role – whether people understand their role within the organisation and whether the organisation ensures that they do not have conflicting roles;
Change – how organisational change (large or small) is managed and communicated in the organisation.

It will however take time for the fruits of what is being done to show through. A complementary approach which may accelerate the pace of change is offered within this article.

Is there a “model” world?

For the safety practitioners amongst us, one naturally turns to the world of safety and the tremendous progress that has been made in that arena.

This is a chart of fatal injuries to workers in Great Britain :

Note that this is absolute numbers of fatalities and the frequency will be falling even faster, given the growth in the workforce.

The following commentary was provided in the report:

“This reduction is in part due to changes in the industry composition over the period (for example a shift away from mining, manufacturing and other heavy industry to lower risk service industries). A comparison of fatal injury numbers between 1974 (when the Health and Safety at Work Act was introduced) and 2018/19, adjusting to allow for the difference in industry coverage of the reporting requirements between these years, suggests that fatal injury numbers to employees have fallen by around 84% over this period.”

So, even without correction, this is a pretty spectacular achievement. The comparison between this and mental events is stark.

A historical analogy comes to mind. Many who live in Scotland will be familiar with the Forth Estuary and may pass to and fro on a regular basis. There are three bridges within sight of each across the Forth at Queensferry.

The Forth (rail) Bridge was built by the Victorians. It was thought at the time that 57 lives had been lost building it. Recent research suggests this was more like 73. Although no one thought this was excellent performance at the time, the project wasn’t stopped. In the 1960s, the Forth Road Bridge was built at the cost of seven lives. More recently a third bridge – the Queensferry Crossing - has been built with only a single fatality. This is indicative of how society’s expectations and industry performance have risen over the years with respect to personal safety.

Models for safety

Over time, the concept of safety has developed two key areas. The first is personal safety or occupational safety. This is what most people think of when they hear the word “safety”. It is focussed very much on protecting individuals or small groups from hazardous events. It includes matters such as:

Work control and permits;
Slips, trips and falls;
Dropped or falling objects;
Electrocution;
Falls from heights;
Vehicle accidents.

Typically one to three people might be at risk in a particular incident, although a major vehicle accident, for example, could cause significantly more fatalities. The risks can be much the same irrespective of the industry or locality. You can be the victim of a dropped object whether you work on a building site or a nuclear power station.

The other key category of safety is process or technical safety. This is where the materials used or the engineering can lead to a hazardous event. It includes matters such as:

Release of hazardous substances leading to asphyxiation, poisoning or fire and explosion;
Catastrophic technical failure.

The risks are therefore very dependent on the application. If there is no toxic inventory, you can’t be poisoned.

For an example of the difference between these two types of safety, consider the aviation industry. When designing and manufacturing a new plane, you have the possibility of causing a major accident due to the plane disintegrating or crashing. This requires technical safety expertise. On the other hand, when assembling it you have to ensure the workforce don’t get injured. This requires personal or occupational safety expertise. And you must never assume that you have “got” either type of safety.

To take the aircraft analogy further, design and manufacturing isn’t enough. The manufacturer and the airline need to have a concern for the aircraft in service. The manufacturer needs to advise on any issues which it becomes aware of. The airline needs to have a focus on the ongoing technical integrity of the plane and the personal safety of the passengers, crew and maintenance personnel.

Hence, it has become commonplace to talk about lenses. We can look at safety through the lens of personal/ occupational safety or through the lens of process/ technical safety. In some models, this is supplemented by a concern for mental health. So the model can be represented like this:

Mental health, however, generally fails to deliver on the full mental safety agenda, as outlined previously. This isn’t in any way to scorn mental health agendas, but it is suggested here that what is being done is not enough and needs to be amplified and elevated in status. To put it another way, the mental health agendas are necessary but not sufficient.

Proposal

In order to promote mental safety to the same level as personal safety and process safety, a “Shamrock Model” is proposed, where mental, process safety and personal safety are prioritised in equal measure, with common goals, commitment and processes:

How would you go about doing this?

A great way of implementing mental health and safety is to develop a series of commitments. You should create your own list but here’s a typical one:

1.         We will treat mental safety as equal in importance with personal safety and process safety.

2.         We will develop and enforce standards of conduct for protecting mental safety.

3.         We will train our management and workforce in mental safety.

4.         We will include mental safety targets in company and personal objectives.

5.         We will assess employees in their delivery of mental safety.

6.         We will not differentiate between staff members, contractors and visitors regarding mental safety. Everyone deserves to go home undamaged mentally.

7.         We will have a system of reporting mental injuries.

8.         We will investigate mental injuries with the same rigour as physical injuries.

9.         We will never engage in arbitrary “trade offs” against mental safety.

10.      We will ensure that the victims of mental injury receive the same degree of medical care as the victims of physical injuries.

11.      There will be no retribution against those who report mental injuries.

12.      We will impose similar requirements on our contractors.

In Summary

There has been tremendous progress in both personal and process safety over the last 40 years as illustrated within this article. Mental health and safety is now firmly on the agenda and clearly being prioritised by many organisations. But is that enough and will change happen sufficiently fast to prevent further damage? In summary, this article proposes that we move towards the “Shamrock Model” illustrated herein, showing that mental safety is equal with personal safety and process safety and using that as a springboard for closing the gap between mental safety performance and “physical” safety performance.

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