Questioning the Risk Management approach for mentally healthy work
In November 2023 the NZ health and safety regulator, WorkSafe, released its draft mentally healthy work guide for consultation. Through this it has put spotlight on mental health at work. The guide is centered around following the four step risk management process outlined in HSWA 2015.
This raises a number of questions. For example; Can mentally healthy work can be achieved through a predominantly risk management approach? Can culture be controlled? Is leadership a function of management?
Governance is an important issue
Governance for mentally healthy work is fundamentally different from most if not all safety issues. Critical safety issues occur in frontline operations and incident/events occur on the shop floor. So the governance role is clearly identified and is indirectly involved via a root cause chain. But with psychological demands the organisational directors and executive leadership team can be directly experiencing issues themselves or they can be a risk factor.
There a whole new set of complexities that need to be considered. A senior leadership team or other governing body can be a source of risk. Directors and officers can be indirectly involved and can also be directly involved in a risk. They can be potentially governing themselves as workers. Directors are officers who have a legislated requirement to hold their direct reports 'to account' for managing the risks but they can also be the direct cause of those risks due to the nature of their leadership or management. The complexity of the issue is not mentioned or addressed in the guide or a suitable governance mechanism to address this issue.
I would argue that the ‘governance gap’ is a symptom of a larger issue. I think that the guide is trying to address a systemic and holistic issue with a reductionist approach. It appears to be built on the idea that the holistic outcome of mentally healthy work can be achieved through managing the risk of psychological demands, using the four step risk management process.
A holistic issue can’t be controlled within a simplistic risk management process
The WorkSafe Mentally Healthy Work guide includes the outcome in the title but then states that it provides “good practice guidelines for managing psychosocial risks at work”
Throughout the draft WorkSafe guide there is interchanged used of outcome terms (mentally healthy work and wellbeing) with risk terms like 'psychological demands'. Section one introduces wellbeing and Te Whare Tapa Wha is an important description of this outcome. But it then introduces psychological demands as the risk to address and describes the four-step risk management process as the core business process to folloiw (refer section 3). It explains how to identify the different individual hazards of psychological demands then individually assessing them, controlling and monitoring and updating those controls as needed.
By mixing these terms and ideas, it implies that managing the risks of Psychosocial demands is the same as achieving the outcomes of mentally healthy work and/or wellbeing. And that all that is needed is the four step risk management process.
So I would argue that a mentally healthy work guide needs to include a holistic outcome driven approach and a risk oriented risk management process. But not to mix them up.
My fundamental issues are that:
mental health and wellbeing are positive and holistic outcomes i.e. they aspirational goals that people, communities or organisations want to work towards. Psychosocial demands, on the other hand, are risks that a community or organisation might want to avoid.
business processes used for achieving holistic outcomes are fundamentally different from the four step risk management process. The four step process is avoidance based, rather than outcome driven. Its also logical and linear and based on reductionist thinking - breaking problems into parts to solve them. This approach isn’t suited to complex issues. Outcome driven strategic planning is different to be able to deal with the inherent complexity of a holistic issue.
Why is it a problem?
Risk management is complimentary but also fundamentally different to creating a strategic plan to achieve an outcome. An issue with trying to push all your activity within a risk management process is that it’s focussed on what can go wrong, rather than an outcome what we want to achieve. So it can stifle creativity and can miss some of the inherent strengths that people and communities bring.
Another issue is the time consuming nature of risk management. These might include: violence and agression, trauma, bullying and descrimination, sexual harassment or change. Following a good risk management approach you would likely determine that these different psychosocial risks affect different worker populations in different ways. So you need to separate each risk out individually and develop a control plan for each risk.
But like mental health and wellbeing in general, there are some general determinants of mentally healthy work. A good physical environment, effective tools, positive relationships, good education and good leadership. These things are both enablers of positive outcomes and act to manage risk. But one problem with thinking about them as controls is that they are so general that they overlap all risks. This can lead to ‘safety clutter’ where different work groups are having multiple conversations trying to solve the same issue.
In the WorkSafe draft guideline the primary framework is the four step risk management and there is very limited acknowledgement of wider management and leadership system functions or holistic issues. So issues like ‘governance’ are missed even though they are important and many things are identified as controls even though they cant actually be implemented and monitored like a control should be.
Mentally healthy work is a part of mental health in general.
One way to consider this question is by asking, can mental health in general be managed through a predominantly Risk based approach?
The WorkSafe approach is in contrast to the 2018 Government Inquiry into Mental Health and Addiction outlined a vision that is primarily outcome based, and supported by risk management rather than the other way around. It identifies that “The new system should have a vision of mental health and wellbeing for all at its heart: where a good level of mental wellbeing is attainable for everyone, outcomes are equitable across the whole of society, and people who experience mental illness and distress have the resilience, tools and support they need to regain their wellbeing.” and also identifying that “We believe that many dimensions of the aspirations of Māori and Pacific peoples, especially the call for a holistic approach, point the way for all New Zealanders”
My concern is that the risk management process does not provide an effective mechanism for aspirational and holistic approaches because it is fundamentally deficit based and reductionist. The process requires you to start with what you don't want (the hazards) rather than your ideal outcome (an aspiration). Then involves breaking them down in to parts (each hazard) and developing control plans for them (reductionist).
WorkSafe even acknowledge the problem with a reductionist approach in the guide itself, highlighting how the different ‘controls’ are co-dependant and can have paradoxical outcomes. Personally I don’t think it is enough ot just acknowledge it. I think the risk management process is too linear and simplistic to deal with the complexities of these issues. So instead I suggest that to achieve the outcome of mentally healthy work or wellbeing, organisations need to combine critical risk management with outcomes driven strategic management. Outcomes driven management is a standard approach to management and leadership. It is fundamentally positive in that it starts with an aspirational purpose or vision then establishing a strategic plan built on strategic priorities. This type of plan can be holistic in that you can bundle priorities up to the overarching outcome. It can also be person and community centred.
Management vs Leadership and Culture
There is a well used phrase that you manage processes, but you lead people. Many successful business leaders and research studies have highlighted how leadership and management are complementary. This recent Linked article by Mike Bennetts is one example in popular media.
But in the WorkSafe guide ‘developing and supporting effective leadership’ is identified as a control (Section 7.2 Choosing the most effective control measures). This implies that leadership is just a function of management - rather than complimentary but different.
In the same section ‘building a positive culture’ is also listed as a control. Culture is a broad and holistic idea that is influenced by all aspects of an organisation. I, for one, dont understand how ‘building a positive culture’ can be implemented in a risk specific way separately from all the other controls and organisational priorities.
Managing the risk of psychological demands is inherently logical and leaves very little room for interpretation. But an outcome driven goal for mentally healthy work is aspirational in nature and will be aligned to the values and culture of the organisation.
A leader can implement a control but they must embrace a culture within their own way of being. You manage a risk, but you lead people.
The Health and Safety at Work Acts set a requirement for organisations to primarily focus efforts on managing risks. The legislation sets a risk management agenda.
But there is an ongoing push and pull between risk based management of safety issues and culture based approaches to improving safety. The drive towards ‘critical risk management’ has largely come from the industrial safety world rather than mental health and wellbeing literature. Solutions for industrial safety management don’t always translate effectively into people management.
Control of social situations can have unintended consequences. One small example is how controls against free speech have been used internationally to manage for hate speech, where groups can be identified as extremist to have their communications and activities controlled. Well, in a recent news article it was highlighted how Russia is seeking an extremist label for the LGBT movement https://www.bbc.com/news/world-europe-67454386
So I don’t think the gold standard and most preferred solution for addressing destructive emotions is to aim to eliminate them or to control or minimize relationships. That is an option, and an important one, but it should be the last option not the preferred one or the only one. Not the gold standard. Building trust, actually requires some risk taking and accepting of risk. So instead, I believe that social issues need to be addressed with more socially intelligent solutions.
The Curious Case of Prisons
I am writing this article as an independent person and it does not represent the position of my employment or my current employer. That said, I work for Ara Poutama Aotearoa, the NZ department of corrections and am familiar with international custodial literature. So One way I will illustrate my argument is with the example of these secure institutions internationally.
Prisons and other secure facilities are functions of our society. They are employed to play a role in the justice system, but in doing this they are required to implement the most social controls of any organization or institution.
Prisons often take great steps to manage risks of aggression, violence, manipulation, stand-overs (bullying and harassment) and other social issues. Internationally, they do this commonly through control. By eliminating or minimizing social interaction and relationships.
Upon entering prison people are risk assessed. They are physically separated and secured within locked units and cells. There are many layers of surveillance. Peoples interactions and communications are heavily monitored and controlled. With all these controls in place prisons should be some of the most socially safe places in the world. But they’re not. In fact they often have some of the highest rates of violence, bullying and misconduct of any social institution.
Ugilvik (2020) highlights that the architecture of prisons, their regimes, rules and regulations, and the ever-present dividing line between prisoners and officers all contribute to creating a low-trust environment in most prisons. This situation profoundly shapes the relationship between individual prisoners and members of staff. But Uglivik (2020) also acknowledges the impact or those individual relationships themselves, acknowledging that the experience of being trusted by staff can act as a powerful catalyst for desistance and his research clearly shows that relationships between prisoners and prison staff can play a significant, even life-changing, role in assisting desistance processes. (45)
Further more research shows that the prisons that tend to be more open can actually achieve better outcomes. Here are some examples:
Uruguay - Punta de Rieles is one latin American example of an aspirational ‘model’ prison from Uruguay. Punta de Rieles is a progressive "open" prison just outside the Uruguayan capital, Montevideo. " which offers opportunities you don't find anywhere else." It’s recognised internally for changing peoples lives for the better.
Grendon is a unique prison in England that operates as a ‘therapeutic community’. Inmates volunteer to go there, they have control over the day-to-day running of their lives, and they can be voted out at any time by their peers. Grendon is internationally regarded for its approach and achievements and reports significantly better outcomes for prisoners as well as staff.
An new approach at the Macquarie ‘rapid build’ Correctional Centre included innovations in both the structure of the centre and its inmate management practices. Research indicated strong positive outcomes in prisoner behaviors & reoffending outcomes and staff-prisoner relationships. How did they do it? Staff and prisoners discussed a range of factors affecting their experience in the centres, with many innovations of the Rapid Build model noted as having particularly positive impacts. As one example, the facility had dormitory-style accommodation with increased contact between inmates which led to an overall increased feelings of community. This is an example where control was actually carefully reduced to enable better relationships.
Dominican Republic CCRs - Over 10 years the Dominican Republic have tested and grown a New Prison Model ‘Centers for Correction and Rehabilitation (CCRs) so that they now include 18 sites, which is half of the countries facilities. Amongst other things they provide medio libre and other innovations: medio libre is an innovative programmes which is a semi-open regime with strict eligibility criteria in which people are granted day release for work or study outside the facility or weekend or holiday release to connect with their families
Scandinavian exceptionalism- The performance of the whole Scandinavian regions penal system is often highlighted in the literature as exceptionally positive. Pratt has identified that ‘Scandinavian Exceptionalism’ in these countries includes the humane prison conditions, highlighting that in this region, conditions of daily life approximate to life outside as far as possible, rather than being allowed to degrade and debase all within. In these countries simply going to prison itself is recognised as the punishment for crime. (39)
A consistent finding through is the holistic nature of the prison models:
Local relationship dynamics have been identified as being important by Leibling et al “There are different kinds of staff cultures that exist including somewhat paradoxical situations whereby those prisons rated most positively by prisoners were those in which staff were least positive about their own working lives and most negative in their views of prisoners.” Furthermore prison staff cultures are not static, and they are shaped by local factors, such as the nature of the local employment sector, and the particular history and ethos of a prison.
The characteristics and needs of a local culture will influence the specific features and how they interact within an organisations operating model.
In a study about safety within the health sector Liberati et al has also highlighted how that the interactions between the different features of an work function appears to be as important as the features themselves, concluding that features do not appear to act in isolation, each with independent effects; instead, every feature seems to interact with the next in a synergistic way, so what is seen at the level of the unit is the product of those interactions. No individual feature appears dispensable, and none on its own is sufficient. However, when all are present, they are likely to create a self-reinforcing cycle that promotes safety at a system level.
Bennett and Shuker acknowledge that it can be difficult to unpick or isolate specific elements of an integrated social system such as a DTC and that their model is not intended to be definitive. They highlight how their identified features cannot stand alone and that they have to be embedded within, or part of a general effort to create and sustain, a positive social climate and culture.
Finally, the 2022 evaluation of the NSW Rapid Build prison unit project, based on a purposefully established operational model, also highlighted the importance of the interaction between the individual features in enabling a positive Prison Social Climate. Their research confirmed how innovative features were seen to operate as an interconnected system rather than as independent components.
For a framework to be suited to any local context the range of local influences need to be taken into account. The interactions between the different operational features are as important as the choice of features themselves, and the suitability will be affected by a range of influences that are present within the local prison network context.
For these reasons, the risk management process is unsuitable alone. It needs to be proceeded with a holistic process where mentally healthy work or an equivalent outcome is agreed as a strategic goal, and then the priorities and standards are designed holistically so that the interactions between features can be easily considered. Then only risk specific controls need to be addressed within a risk specific planning and management process.
Staff health and wellbeing is a strategic issue that needs a strategic solution.
Staff health and wellbeing is a complex strategic issue that needs to be addressed in a strategic way rather than being ring fenced into a reductionist risk-focussed control program. Mentally healthy work priorities need to be embedded broadly into the organisations overall holistically managed strategic direction and planning program and additional critical risk controls and monitoring need to be incorporated into the organisational risk management program.
For organizations - strategic planning that starts with an outcome based approach.
By taking an outcome driven approach you can address the big picture issues holistically and more creatively. This provides a practical development process to identify connections and commonalities and solve multiple problems creatively with single solutions.
The Risk management process doesn’t allow for this as it requires you to separate risks out, break then down and work on them independently. If you start with a risk management approach you immediately get caught up in the detail of an individual risk, where as if you start from an outcome oriented approach you address all issues together at once and only go into detail once the complex problems are already addressed
Align mentally healthy work to the organisations strategic vision and plan
Identify positive priorities that are part of the organization's overall strategic goals and that address the foundational determinants of mental health and wellbeing holistically
Priorities can be addressed using Design Thinking and Systems thinking R&D approaches which are suited to solving complex problems.
THEN, identify the most critical psychosocial risks and develop a risk specific targeted control plan for each of them to address gaps in the holistic priority driven plan
In summary
With WorkSafe NZ putting a spotlight on mentally healthy work and psychological demands. This paper has raised and explored the question of whether mentally healthy work can be achieved through a predominantly risk management approach.
Personally I believe it needs to include outcomes and risk based approaches. Or if it is all about risk, then I think controls need to be limited to what can actually be controlled. If you try to adopt culture as a 'control' then you will end up with a culture of control.
For the WorkSafe guide, i’ll offer two alternative recommendations:
WorkSafe could change the title to 'Psychosocial Demands - for managing psychosocial risks at work', and remove the references to mentally healthy work and wellbeing,
Or
Update the guide with a new section between Section 3 and Section 4 to outline an 'outcome orientated framework and process that complement the risk management process. This way, all the holistic person-centred issues can be addressed in the outcome centred process and taken out of the risk management process.
