Service line 04

Who owns the risk when the safety team isn't in the room?

For EHS leaders whose framework has grown for 15 years and been pruned once.

4

Line 4 of 5

The problem, in your words

"We've got a procedure for that." 200 documents, some of which contradict each other, and a permit system that 3 sites run by the book while the rest run the way that works.

Underneath it, the thing I hear most from senior EHS leaders when they describe their own situation: safety is being done to the business, rather than owned by it.

Three layers, not two

Most process work compares how things are with how they should be. In health and safety there's a third layer, and it's the one everybody skips.

You already hold a legally required statement of what should happen, by whom, by when and to what extent. Your Arrangements (HSWA s.2(3); MHSWR reg 5). It isn't an input to the mapping; it's a layer in its own right, and in my experience it's frequently the thing that's wrong.

So we map 3: work as prescribed, work as done, work as redesigned. And we grade 2 gaps that most methods collapse into one:

  • Prescription gap: reality has drifted from the arrangement. Workarounds, corner-cutting, the version that works.

  • Design gap: the arrangement itself is the problem. Ambiguous, impossible, contradictory, or diligently defending the wrong risk.

The distinction matters because the fixes are opposite. And because of what it exposes: your three lines of defence can be immaculate, every control working exactly as designed, and still be faithfully defending something broken. We name those findings explicitly.

A workaround is evidence about your process

When discovery finds someone routinely skipping a step, that's a finding about the design, not about the person. Discovery runs no-blame and the findings are framed structurally, not out of politeness but because it's the only condition under which anyone tells you how the work runs.

What the work looks like

A multi-month programme on a fixed 6-stage method, across a prioritised portfolio of your processes. Or one process, end to end, if you'd rather see it work before you commit.

  • Mandate, scope and process inventory. Effort proportionate to the process (nobody should spend a programme's budget mapping a kettle); what's excluded is excluded by decision and written down.

  • The prescribed layer: what your documents say should happen.

  • Discovery: interviews, observation where we can, and your own records as evidence of how the work runs. Coverage is stated. If we spoke to a fifth of your operators, the report says so.

  • The maps and the gap analysis: both layers side by side, every gap typed, quantified and flagged for exposure.

  • The redesign, co-designed with your people. Every change traces to a named finding.

  • Recommendation and handover.

Better is better than best. A simpler process your organisation will run beats an optimal one it won't.

What you keep

A findings and recommendations report with the maps in it; the maps themselves, editable in a free tool and built so you can keep them alive without us; a process register workbook; and, where the redesign changes an arrangement, the redrafted arrangement text, ready to go into your policy.

Boundaries

Exposure flags are professional risk-exposure judgements, there to prioritise what you fix first. They are not legal advice and they are never a prediction about how any enforcement or prosecution would go.

Implementation support is real work and we're happy to do it. It sits outside this scope and gets scoped separately, so the price of the programme is the price of the programme.

Pricing

Fixed fees, phased across the programme, agreed before work starts; scoped to your portfolio in a conversation rather than a rate card.