Systematic work environment management, SWEM, in Sweden experiences from the implementation in small companies

Systematic work environment management, SWEM, in Sweden experiences from the implementation in small companies Paper presented at STAS 2001, 8. Scweiz. Tagung fur Arbeitssicherheit, Casino, Luzern, 11. September 2001 Ann-Beth Antonsson, Swedish Environmental Research Institute, Box 210 60, 100 31 Stockholm, Sweden, tel:+46-8-598 563 47, fax:+46-8-598 563 90, e-mail:ann-beth.antonsson@ivl.se

The regulation The Swedish regulation on systematic work environment management, SWEM, is a regulation similar to the EU-directive 89/391 which requires a policy, risk analysis, information, division of work tasks regarding the work environment, registration of work related accidents etc. The Swedish regulation however, is more far-reaching than the EU-directive. SWEM contains the following basic requirements: The employer shall make provisions for integration of a systematic way of dealing with the work environment in day-to-day business. SWEM includes all physical, psychological and social aspects that affect the work environment. Employees and safety rep s must be given the opportunity to take part in SWEM. Additionally, the following requirements have to be fulfilled: a work environment policy routines for how to work with SWEM, work tasks regarding SWEM should be divided among employees, workers must have knowledge of risks and control measures in their working environment, follow-up on work-related accidents, diseases and near-accidents, risk analysis has to be conducted and control measures undertaken, an action plan should be made if the control measures cannot be immediately realised, use of occupational health services when needed, and a yearly follow-up of SWEM. History The first step towards the SWEM regulation was taken with the revision of the Swedish Work Environment Act in 1992. A new paragraph was introduced, stating that the employer has to systematically plan and manage the activities in the company in such a way that the demands in work environment regulations and the Work Environment Act are fulfilled. Based on this paragraph the regulation on internal control came into force on January 1 1993. After one or two years, it became apparent that the regulation had little effect in small companies, i.e. those with less than 50 employees. A revision was started with the aim to make the regulation easier to understand for small companies. The main focus was the language. After a few more years, it was decided that the regulation should once again be revised and the purpose was the same to facilitate implementation in small companies. This last revision came into force on July the first this year (2001). This time the revision was a bit more extensive. The name of the regulation has been changed from Internal Control, which is a term that has required explanation to all those who have not heard it before, to Systematic Work Environment Management, which (at least in Swedish) is much easier to understand. Additionally, the regulation has been reorganised and the requirements have been better specified. During this presentation, I will only use the abbreviation SWEM, regardless of whether I refer to

the Internal control, which was the name until July first 2001, or the work required by the new regulation. I will give you some examples of clarifications in the new regulation. The first and second versions of the regulation stated that if needed some parts of the internal control should be documented. In the new regulation, the requirements are clearer. E.g. the policy, division of work tasks and yearly follow-up of the SWEM have to be documented only in companies with 10 employees or more. In this way, the new regulation alleviates the demands on companies with less than 10 employees and increases the demands on those with 10 employees or more. The sharper definition of the requirements is intended to make interpretation easier for companies. Earlier there was a requirement that The employer has to investigate the causes of ill health, accidents and serious near-accidents. This was often interpreted as a requirement for routines on what to do if an accident should happen, even in companies with no experience of accidents. This is clarified to When an employee is subject to ill health or an accident at work or when a near-accident takes place at work The present situation After all these years of effort to implement the regulation and revisions of it, in order to make it easier to implement, how far has this taken us in Sweden? The easiest answer is to present the latest figures on the implementation of SWEM in Swedish companies. These figures are based on figures from The Work Environment Inspectorate and their inspection of 5,891 companies during 2000. The status classification has to be explained. Status 4 is a well functioning SWEM where results, in terms of a good work environment, can be seen. Status 3 is a SWEM that fulfils the requirements in the regulation, that is a complete SWEM, but without the visible effects in the work environment. This classification may seem a bit peculiar, but is presently also being revised. Status 1 is no SWEM and 2 is a semifunctioning SWEM. We suspect that at least some of the companies classified as 3, do not have a complete SWEM. As an example, I have visited a company that cited the work environment inspector who said that he classified them as 3, but if they added the yearly follow-up in their SWEM, they would be classified as 4. Obviously, the SWEM was not complete and should not have been classified as 3, but rather as 2.

Present situation Status of SWEM in companies, 2000 0-49 empl 50-499 empl >500 empl 4 1 5 12 3 22 37 67 4 = SWEM implemented and giving effect 3 = SWEM implemented New regulation Campaign to revitalise SWEM Copyright Ann-Beth Antonsson As the figures show, and as can be expected, large companies are better at following the regulation. According to these figures, 23 % of small companies are obeying the regulation. I believe this is an overestimate, and I will get back to why later on. Regardless of whether it is an overestimate or not, we can see that even though there are many companies not fulfilling the regulation, there are maybe as many as 20% that have a complete SWEM as required by the regulation. This is a considerable fraction, especially taking into account that many people do not believe that small companies are able to work systematically with their work environment. The last revision of the regulation and an on-going campaign to revitalise public opinion of the working environment and SWEM, are both aimed at increasing the implementation of SWEM in small companies. What have we learnt about SWEM in small companies? I would like to share with you some Swedish experiences from the implementation of SWEM. In 1995 and 1996, I managed a project where we interviewed small companies about their experiences with SWEM. From a sample of 30 small companies with less than 50 employees, some of which were chosen randomly, we could see that 22 knew about SWEM. Out of these 22, 14 found SWEM too bureaucratic and considered the demands for documentation to be too extensive, 3 said SWEM was suitable for large companies, not small ones and 2 disliked authorities and the demands they make. 3 companies (14%) were positive about SWEM. Even if 22 companies knew about SWEM, only 12 had tried to implement SWEM and according to our judgement, not one of them had a complete SWEM. 3 companies had a fairly good SWEM. Some companies had a fairly good documentation of routines etc, but had not implemented them in day-to-day business. The companies who knew about SWEM but chose not work with it, argued it was too bureaucratic.

12 companies had started to work with SWEM. Managers had cooperated with the safety rep in only 3 companies. In none of the companies, had other employees been involved in the SWEM. Other studies have shown that worker participation is of great importance in succeeding with SWEM in small companies. The employer in a small company is usually so busy; it is obvious that he or she needs some help to make all details of SWEM work in day-to-day-business. Maybe the low degree of worker participation reflects the fact that SWEM has been perceived as a pure management tool, with no need to involve the employees. Another interesting finding was that of the 12 companies with some degree of SWEM, 9 also had ongoing work with quality management. Only one company with a quality management system had no SWEM. It is also interesting that 7 of the small companies claimed they did not work systematically with anything at all of course, they did not work systematically with SWEM either. During the spring year 2001, we continued to interview small companies about their SWEM. This time we focused on companies with a good SWEM, that is, status 3 and 4 according to the Work Environment Inspectorate. I will show you some figures from our interviews with these companies. We have contacted 58 small workplaces that were expected to have a good SWEM. We were not able to get in touch with 13 of the 58 companies and thus we know nothing about them. We have interviewed 45 companies, which in the statistics were classified as small workplaces, not as small companies. Very often, however, these statistics are presented as figures representing small companies. 18 of the 45 companies (40 %) were not small companies, but small workplaces, attached to large companies, organisations or authorities. We judged that 18 small companies of the remaining 27 (67%) had a good good SWEM. For the last 9 companies (20%), we judged that their SWEM did not fulfil the requirements of the regulation at all. 6 of these had a good SWEM when they were visited by the work environment inspector, but it had deteriorated. These randomly made interviews; show that the statistics on SWEM status probably overestimate the status in small companies. Firstly, due to the use of statistics concerning small workplaces attached to large companies etc. instead of using the company statistics. Secondly, a good SWEM does not last forever. As earlier studies have shown, routines regarding the working environment are sensitive to disturbance in day-to-day life in the company. Economic problems, staff problems and new premises are all factors with the potential to rapidly impair a good SWEM. We do not know how easy it is to revitalise such a damaged SWEM. What can we learn from companies with good SWEM? Small companies with a good SWEM are interesting as good examples to show to other small companies. They can illustrate the benefits of a good SWEM. Especially interesting is that they may also give us ideas on how to implement and work with SWEM in order to make it work in other companies. To learn from good examples of

SWEM in small companies, we have made extensive interviews in twelve small companies. We have interviewed management, saftey rep s and employees. We have seen that some of the characteristics of small companies with a good SWEM are that firstly, all of them are used to, or have started working systematically with, other management systems or with other formal routines. Secondly, most of these companies have managers with previous experience as employees in the same or a similar company and thirdly, many of the companies had a good safety culture, which preceded the implementation of SWEM. Another unexpected finding was that three of the twelve companies had own experiences of fatal accidents. This has probably contributed a lot to their motivation to work with SWEM. This fact also illustrates that their work was quite hazardous. Unfortunately, these characteristics are all very company-specific. Factors such as the use of other management systems and a managers former experience are usually impossible to affect from an external occupational health and safety expert. Thus, the analysis might not help a lot when implementing SWEM in other small companies. Other Swedish experiences There are other experiences from the implementation of SWEM in small companies, which I believe are of great importance, as they illustrate both problems and possibilities with the implementation of SWEM. We have seen that there is a clear trend towards the production of written documentation, for example, binders with the documentation required by the regulation. Usually these binders are produced by some kind of health and safety consultant, for example from the occupational health service. We have also seen that these expert-produced binders are of little help in companies SWEM. What has been especially astonishing to me, is that when SWEM was introduced, everyone talked about how important it was that the companies worked with the implementation themselves and that consultant-produced SWEM systems were less likely to succeed in day-to-day work. However, it seems obvious that this message has not reached the small companies a considerable fraction of small companies with SWEM have hired consultants to do the job for them. One explanation of the consultant-produced SWEM-binders may be that they are produced by safety engineers. As they are skilled technicians, they look upon SWEM as a problem that they are engaged to solve and therefore provide companies with a solution. In many cases a binder. Today, when I work with small companies and SWEM, I would rather look upon SWEM as a change process instead of a technical problem. Another experience from the implementation of SWEM is that many skilled specialists have implemented it in companies. The specialists know a lot about work environment and want to make use of their knowledge. Therefore, they tend to work with SWEM on too advanced a level, even when they make efforts to adapt the SWEM to the little company. As the companies cannot manage too advanced SWEM, they leave the work to experts instead of being active themselves.

Conclusions We are now working with a project where we are developing methods for the implementation of SWEM in small companies. I would like to share with you the basis of our work. First of all, we look upon SWEM as a change process which has to take place in the companies. Of course SWEM is also about solving problems in the work environment, but SWEM is mainly about developing a way of working systematically and proactively regarding the work environment of companies. What is SWEM about? Improving work environment? Solving problems? YES, but 1. Increase awareness of work environment 2. Change attitudes 3. Increase knowledge 4. Change behaviour A CHANGE PROCESS Copyright Ann-Beth Antonsson The simple steps of a change process are: 1. to increase the awareness of the work environment at the workplace. When people are aware, they are also motivated to continue to the second step 2. attitudes to the working environment may be changed and there is a perceived need to improve the work environment at the workplace 3. to learn more about the work environment at the workplace, the risks and safe routines and preventive measures, when there is knowledge 4. when there is knowledge and a desire to change, the change can be realized. These steps may seem simple but are in practice quite difficult to accomplish. It is often easy when problems in the work environment are obvious and all agree they have to be removed. When the problems are remote, something that has never happened but may happen at least if something goes wrong, the problems are often not given priority. As SWEM is proactive, at least parts of the problems that it should take care of are these remote problems. In order to increase the implementation of SWEM in small companies, we are going to:

Use personal contact to increase awareness of, and attitudes to, the work environment. We are going to collaborate with the social partners, occupational health services and regional safety representatives, which cover most small companies and already have personal contacts within many small companies. Use personal contact in combination with good tools that can be used by the company to improve the knowledge about their working environment and start the change processes that have to take place. We know that the implementation of SWEM is a process that takes time. Of course we don t tell that to the companies. That would scare them away! We will focus on the actual work environment in the companies, not on bureaucratic routines, and try to establish some kind of simple and regular activities. Everything that the companies are expected to do, should be adapted to their means of working and integrated, if possible, in existing routines. We will not start to talk about work environment in the companies, as we know quite a large fraction are repelled by just those words. Instead, we would like to start talking about the company, their needs and present situation, and try to fit work environment within that context. As our Swedish definition of work environment includes work organisation and competence, this is not very hard to do. Even if we start by approaching the company manager, our aim is that employees in the companies will be involved in SWEM. Work material was developed for small companies, based on one of my projects, which I have described earlier today. I believe it will be an option for the companies to work with that or similar material. The work material is very simple and contains the following parts: Survey the working environment once a year with a checklist or similar tool A yearly meeting with staff focusing on about ten questions reflecting demands in the SWEM Part of day-to-day work, for example as a part of regular staff meetings Register work-related accidents, diseases and near accidents I believe these methods will increase the implementation of SWEM in our group of small companies. As we have decided only to use realistic methods and not put a lot of work into supporting and persuading the companies, I would be surprised if we succeed in more than one third of the companies. SWEM is a difficult concept to implement and it is not realistic to expect that 100 % of small companies obey the regulation. This leads to the last part of my presentation. I would like you to reflect upon the following questions. If a compulsory SWEM is introduced, do you think it is good if it covers all small companies, even those where the owner is the only person that works in the company and even those small companies where the risks can be ignored (if there are such companies)?

I would say that if you want SWEM to cover all those companies, it is of utmost importance that the SWEM is well adapted to these target groups. If you want to exclude some companies, then you have to consider what the criteria should be for requiring companies to have SWEM. If your alternative is a voluntary system rather than a compulsory one, how can such a system be adapted to small companies? Voluntary systems are usually more rigid than compulsory ones, requiring, for example, more documentation. Such requirements are often barriers towards their use in many small companies. One could also question if vast documentation improves the outcome of the systems. Voluntary systems require some kind of inspection or certification. For small companies, the cost for certification may be too high. What are the incentives for small companies to have a certificate? With all the difficulties in implementing SWEM I have pointed out, and all the questions I have asked you to think about, I would like to end this presentation hoping that, if you are confused, I hope, I have at least succeeded in making you confused at a higher level!!! References Lena Birgersdotter, Lisa Schmidt, Ann-Beth Antonsson. Fungerande systematiskt arbetsmiljöarbete i små företag.erfarenheter från 45 små arbetsställen. IVL-rapport B 1475, 2002. Ann-Beth Antonsson, Malin Nilsson, Ola Hansén. Internkontroll i små företag. Verklighet och visioner. IVL-rapport B 1291, 1998 Both reports are available in Swedish with an English summary on www.ivl.se