Practical proposals for improving the Department of Labour’s approach to high hazard industries
The Department's approach to high-hazard activities is not broken or fundamentally deficient. There are, however, some immediate improvements that could be made within the current regulatory framework that would go a long way to improving the focus, effectiveness and efficiency of the Department's efforts.
While there are no specific regulations or statutes relating to high hazard industries, regulations under the Health and Safety in Employment Act impose specific requirements on two industries considered to be high hazard in nature -mining and petroleum exploration and extraction.
New Zealand's health and safety inspectorate is small - about 140 inspectors covering approximately 470,000 enterprises in New Zealand and all of the places these enterprises undertake work. Consequently the amount of resource within this inspectorate focused on high hazard industries is small. Even taking New Zealand's diminutive size and the small size of its high-hazard industries into account, the Department's level of resource committed to the regulation of high hazards is small. It is important to note this as any significant increase in any high hazard resourcing potentially comes at the expense of other areas of focus.
Even with the best will in the world, securing additional capacity in these industries is challenging for a number of reasons. Because of the small size of the local industries, accessing people who are suitably independent is challenging. Because the global market for these specialists is reasonably competitive, the Department needs to match market price to secure their services. Expertise in these industries is globally quite small and in New Zealand it is very small.
This paper not only focuses on boosting the level of resources deployed in high hazards. It also tries to encourage thinking about how the Department can maximise its effectiveness with the limited resources it has at its disposal. This means trying to be more effective at marshalling all of the information, persuasion and connections the Department has to promote the best outcomes.
The paper also recommends a limited reorganisation of current resources so they are more nationally focused and managed. This is aimed at promoting a more strategic approach to the work and being able to efficiently deploy limited resources across the country. It also lifts the profile of the Department's high hazards work and enables more effective peer to peer relationships with other regulators and other jurisdictions.