Safety framing and compliance in relation to standards: Experience from the Australian gas pipeline industry

Safety Science 94 (2017) 52–60

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Safety framing and compliance in relation to standards: Experience from the Australian gas pipeline industry Sarah Maslen ⇑, Hedda Ransan-Cooper University of Canberra, Australia

a r t i c l e

i n f o

Article history: Received 27 July 2016 Received in revised form 13 October 2016 Accepted 15 December 2016

Keywords: Compliance Expertise Framing Major accident risk Sociology Standards

a b s t r a c t Safety is conceptualized in different ways across hazardous industries, but it is often expressed in terms of compliance. Compliance is about rules in various forms, including standards. Standards are core reference points that guide the design, construction and management of hazardous infrastructure such as high pressure gas pipelines. While standards are critical, we argue that neither their application nor their relationship to safety should be taken for granted. In this article, we investigate the ways in which safety as compliance in relation to standards manifests, the ways it is contested, its strategic use and implications for major accident risk management. Building on the framing literature, this article reveals where these frames reside and their interactions. We use qualitative methods to examine the framings of safety present in accounts of Australian pipeline industry members. We argue that the frames (compliance as expert judgment and compliance as process) are contested, which leads to the creation of a hybrid or compromise frame – one which integrates the underlying concerns of both frames. Best case, a dialogue between people using both frames results in a hybrid frame involving expert use of standards, with consideration of industry context. Worst case, standards are thoughtlessly applied, or are used as a way to displace organizational responsibility for safety that may be in conflict with business pressures. Ó 2016 Elsevier Ltd. All rights reserved.

1. Introduction It is about half way through the interview. The engineer has been sharing his professional background and the nature of his work with one of the authors who is interviewing him about his understanding of safety and development of engineering expertise. We get to a more critical question about potential conflict between a sound engineering decision and cost and schedule pressures. He responds: ‘Safety always goes first’. This is a common statement, and one that we could take from virtually any of our interviews with hazardous industry professionals. In this case, the engineer supported his claim with an example of making a decision that had the potential to incur additional costs, but was necessary in order to comply with the relevant standards. The engineer explains, ‘We just had to make the call. You can’t not do it, knowing that you are not complying with standards’. In this interview, as in many others, safety is being discussed in terms of compliance with standards. In this case, this was the end of the story. There was no push back from other key actors involved in the decision.

⇑ Corresponding author at: University of Canberra, University Drive, Bruce ACT 2617, Australia. E-mail address: [email protected] (S. Maslen). http://dx.doi.org/10.1016/j.ssci.2016.12.011 0925-7535/Ó 2016 Elsevier Ltd. All rights reserved.

If we only examined examples such as this one, we might conclude that major accident risk management in hazardous industries operates in a world without conflict. However, our article reveals that safety management, and indeed the nature of the risks faced by hazardous industries, are not uniformly conceptualized. For example, in the Australian gas pipeline context, some industry members see the potential for catastrophic failure as a non-risk. A senior pipeline engineer commented: The reality is there are not many risks, and the reason is that pipelines are very forgiving. They are tested to demonstrate that they are very strong . . . Pipelines take a long time for things to go wrong. When they do go wrong we throw them away. While there has not been loss of life due to a high pressure gas pipeline failure in Australia, catastrophic events like the failure at San Bruno, California draw into question the validity of confidence about integrity management in these systems (Hayes and Hopkins, 2014). At the same time, there is an alternative view among engineers working in this industry of the potential for disaster, captured by another pipeline engineer: ‘I keep saying it is not a matter of if, it is when’. In light of contestation over the nature of risks coupled with the unacceptable consequences of failure, safety researchers have argued for the use of ‘good’ rules as a safety management strategy

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(for a review, see Hale and Borys, 2013a, 2013b). Risk levels fall across a continuum, but decisions to take one course of action over another are more definite and so rules provide necessary guidance for decision makers (Hopkins, 2011). However, the use of rules is not straightforward because actors can interpret and respond to these rules in different ways, which undermines claims that safety is ensured simply via compliance. One way we can examine the complexities is via the lens of framing. In essence, frames are an abstraction; a linguistic and mental short cut for making sense of complex situations (Goffman, 1974). Based on interviews in the Australian gas pipeline industry, we critically interrogate conceptualizations of safety and safety management via compliance with standards. In this case study, compliance with standards is not framed uniformly. In the first frame we address, safety as compliance is seen as a matter of expert judgment. In this frame, safety is managed and debated in the language of standards, but standards are understood as requiring expert understanding to apply them safely. The second framing of safety as compliance sees compliance with standards as providing a straightforward set of requirements that ensure safety. Digging deeper into standard application is generally thought to be unnecessary given the strong safety record of the industry. In this article we refer to the two frames as compliance as expert judgment and compliance as process. To examine these framings of safety as compliance, we first start with an engagement of the framing literature in the context of safety and risk research. We establish a conceptual framework, which draws attention to different scales of analysis, the ways in which frames are enacted and issues with power and frame contestation. We then introduce our empirical research, including an overview of the data and a discussion of methods in the context of the conceptual framework. On these foundations in Section 4 we present and analyze the two framings of safety as compliance observed in the research, which are shown to reside at different scales (individual and organizational). Our analysis highlights the potential for conflict between framings of safety as compliance, and in Section 5 we explore the dynamics of this frame contestation by looking at relations between a design consultancy and their clients. We argue that in the Australian gas pipeline industry there are at least two frames (compliance as expert judgment and compliance as process) which are more or less present in different organizations and personal biographies. The two frames are also contested, which can lead to the creation of a hybrid or compromise frame – one which integrates the underlying concerns of both frames. Participants in this research did not often appear aware of this frame contestation, but we suggest that conscious engagement with the underlying assumptions behind frames and their implications is vital to safe outcomes.

2. Framing in safety and risk research Increasingly, frames (and framing) are being used to understand the social construction of risk in a variety of different institutional settings and at different scales. This reflects a broader ‘turn to framing’ seen across many disciplines in the social sciences (Dewulf, 2013; Hertog and McLeod, 2001; Metze, 2014; RansanCooper et al., 2015). In a general sense, frames organize central ideas of a complex issue, which endow certain dimensions with greater apparent relevance than others. However, the diversity of ways that framing has been used in the social sciences has led to significant conceptual confusion and calls for greater integration and synthesis (Cornelissen and Werner, 2014; D’Angelo and Kuypers, 2010). A detailed review of the conceptual intricacies is beyond the scope of this article (for reviews see Cornelissen and Werner, 2014; D’Angelo and Kuypers, 2010). Nonetheless, our brief review finds a similar lack of conceptual cohesion in the use of

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framing within safety and risk research, as we will outline below. Taken as a whole, the key problem is a lack of cross-scale analysis; a tendency for framing to be analyzed only at one scale. A consequence of this is that analysis tends to be limited to static descriptions of frames, rather than analysis of how frames are created in social interaction and how they influence social life. At one extreme, studies of risk and framing focus analysis at the micro scale. For instance, there is a stream of psychology research (Jefferies-Sewell et al., 2015; von der Heyde et al., 2015a, 2015b) that investigates how individuals respond to the presentation of risk communication. Researchers in this tradition are less interested in where frames reside or how they are used in practice, but rather focus their analysis on what type of language cues particular responses to risk. Another approach to understanding risk behavior at the individual scale situates inquiry within institutional settings. Morrow et al. (2015) used framing to explore why health and safety in the UK continues to remain unaddressed in the design phase of construction, despite the introduction of legislation mandating this. Their findings revealed that design engineers framed health and safety as outside their professional responsibility leading to a tendency to neglect health and safety issues. Sanne (2008) similarly focuses on professional framing of risk and its implications for practice in an ethnography with railway workers. He argues that risk taking, far from being a deviant behavior, can make sense within particular framings of risk. This conclusion obviates claims that railway workers need further training and engagement in improved reporting systems. In this case, railway workers took risks they perceived to be manageable within the context of an occupational responsibility frame. While the pressure of corporate and occupational discourses (in terms of ‘service to the nation’) is explored in Sanne’s work, there is less insight into how corporate/management action reinforces this discourse. The rich detail on how the framing plays out in specific situations could be complemented by exploring how this frame gets developed, and where and how it might be contested. Other studies have focused on frame dynamics at institutional and industry scales. This approach to frame analysis explores what sustains particular frames and what provokes shifts in frames. Behr et al. (2015) apply frame theory to several case studies of critical incident inquiries in hospitals. Interestingly, in all case studies, there was a shift in the framing of risk throughout the inquiry process from viewing risk as an individual’s lack of professionalism to a managerial frame which put the onus on management, and, eventually, to a governance frame which focused the story on the laws and regulations governing hospital risk management. Conflict between the different frames throughout the inquiry process was the trigger for these frame changes. This study is an example of how tracing the construction of frames across time necessarily entails an engagement with cross scale analysis. Metze (2014) took a similar approach in a macro analysis of risk framings of hydraulic fracking in the public arena in the Netherlands through an interpretive analysis of peaks of media activity. Her study revealed significant shifts in frames in the public arena with implications for what actors were involved in managing the issue as well as, eventually, putting the broader issue of Dutch dependency on gas on the agenda. Missing from such an analysis is the subtleties and mechanics of how the frame shifts come about. Media articles can only ever be a limited proxy of what people involved in the issue are actually saying and doing, a methodological limitation for frame analysis discussed in more detail in Section 3. 2.1. Framing safety: Conceptual pathways forward All these studies reflect a significant diversity in how framing has been used to explore safety and risk. In many of these studies, the singular focus at one scale of analysis limits the potential of the

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analysis to reveal how frame dynamics influence daily decisions. In their extensive review of framing in management and organization studies, Cornelissen and Werner (2014) argue that issues of clarity plague framing as different areas have developed the concept separately with little integration across the micro, meso and macro scales of analysis. As part of overcoming the fragmentation we have discussed, Cornelissen and Werner (2014) present a synthesized definition. Inspired by linguist Fillmore (1975, 1982 in Cornelissen and Werner, 2014), they define frames as ‘structured semantic representations that are invoked by words and made salient in a context of speech’. For individuals, previous experience and cultural knowledge primes how words are connected (as frames) which then sets up certain expectations of themselves and others. A key feature of this definition is that frames (and their articulation: ‘framing’) are embedded in institutional contexts and, as such, cannot be understood at an individual scale or within a manufactured lab setting. This definition focuses our analysis on the sources of influence of frames in context, and the openings and opportunities presented by personal biography or details on the institutional frame to sustain or change different framings. Frames are grounded in experience (Goffman, 1974; Reay et al., 2013). The implementation of practices depends not only on the frames used by actors, but also on individuals enacting and habitually performing such practices in line with the frame-based logic. In other words, tracing frames requires a focus on how actors engage in activity, and the ways in which they talk about their experiences. Other dramaturgical concepts such as ‘props’ can be useful to understand how various objects, imbued with symbolic meaning, can be used by actors to promote a frame (Goffman, 1959). A focus on how frames are constructed has similarly been emphasized in other fields of inquiry (for example in social movements, see Snow et al., 2014). Previous framing research directs our attention to issues of power (Carragee and Roefs, 2004). One straightforward approach to attending to power is to trace inequalities of resource distribution (cultural, intellectual, political and financial) available to different actors for promoting or consolidating particular frames. Cornelissen and Werner (2014) further suggest attending more systematically to the differences in political motivations and interests between individuals, groups and organizations in an institutional field (Fligstein and McAdam, 2011; Rao and Kenney, 2008). One consequence of this latter approach is to deepen our understanding of when and how the use of ‘compromise frames’ (Fligstein and McAdam, 2011), ‘frame bridging’ (Snow et al., 2014), or the construction of hybrid or ‘integrated frames’ (Rao and Kenney, 2008) occurs and explain how some frames linger or become dominant. Cornelissen and Werner (2014) are in line with many other researchers who argue that frame analysis needs to move beyond naming frames and explore framing as dynamic meaning construction within and across groups. A key methodological step to achieve this is to ‘move closer to the action at a micro level, and to study the ongoing and interpretive processes of framing and meaning construction across actors and across time’ (Cornelissen and Werner, 2014). Our analysis of how safety is framed within hazardous industries is guided by a sensitivity to how different scales are implicated, as well as a concern in uncovering the interests and motivations behind the enactment of different frame dynamics. As such, we investigate the practices, personal biographies, contexts and discourses that lead to and sustain particular framings of safety as compliance. Moreover, we examine the implications of these framings for the practices of managing pipeline risk specifically. Finally, we explore the conflict situations, openings, and opportunities to stimulate change in frames (whether personal, small group, or organizational) and how this is resolved (through the creation of a compromise or hybrid frame, or shift in frame

entirely). This analysis includes sensitivity to who has the power to define the safety frame and in what sort of situations.

3. Methods The conceptual considerations discussed above underpin our selection of a qualitative, interpretive methodology (see also Reese, 2010). Our focus is on how frames are constructed through language, reasoning, metaphor or abstraction, and how these contribute to understandings of safety and risk within the context of the Australian gas pipeline industry. Interview data is our primary source for analysis. We recognise that observation of actors doing their work would provide an important source for triangulating our understanding of frame dynamics. However, this data source is unavailable to us due to the scope of the original study from which our data comes. As such, building a strong rapport with interview participants was particularly important in order to gain an understanding of how safety frames play out in everyday decision-making across different contexts. While we did not observe the everyday work practices of the engineers we interviewed, we did build a relationship with participants over many months by attending industry seminars, conferences and social events. In these encounters outside of the interview we also gained a strong understanding of different framings of risk across the industry, as engineers would comment on the different viewpoints articulated in these industry forums. The data is drawn from 34 interviews that explored how safety is understood and managed in practice by pipeline engineers within their work group, organizational and industry contexts. The two primary questions for this research were: How do junior engineers joining the Australian gas pipeline industry understand safety, and where does this understanding of safety come from? In addition to junior engineers, the research included senior organizational and industry members as a way to examine the role of other actors in enacting safety and development of engineering expertise. As such, the research captured many accounts of how safety is understood, and the ways in which safety is managed in practice. Participants were drawn from across the work functions of pipeline design (n = 15), operations and maintenance (n = 15), and construction (n = 4) (see Fig. 1). They included new professionals to the industry (n = 23), and their managers/senior technical experts (n = 11). The work functions covered in this research reflect the two organizational contexts in which the data in this article is largely drawn. We focus on these two organizational contexts as a way to specifically examine the use of and conflict between frames at both micro and meso levels. The first organization (Company A) was an engineering design company, servicing primarily gas industry clients. Company A was small enough that formal structures were limited and personal relationships between staff were important. Technical expertise was highly esteemed and there was a strong value throughout the company of standards and checking. The company deliberately sought to link daily work in the design office to the potential for major accidents through sharing stories and supporting visits to assets. The second organization (Company B) was a large pipeline operating company. They had a typical matrix structure and tended to defer to formal structures and systems. Generally, Company B was more focused on occupational safety than on major accident prevention. We employed qualitative semi-structured interviews as a primary research method for their capacity to provide rich, investigative data. Semi-structured interviews focus on the participant’s knowledge of a certain area, in order to use both questions and narrative stimuli ‘to collect biographical data with regard to a certain problem’ (Flick, 2002). Interview questions act as a guide, or

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Company

Parcipant category

No. of parcipants

Design (Company A)

Junior engineers

10

Managers and senior technical experts

5

Subtotal

15

Operaons and maintenance (Company B)

Junior engineers

9

Managers and senior technical experts

6

Subtotal Construcon

55

15 Junior engineers

TOTAL

4 34

Fig. 1. Overview of research participants.

else a fall back if the conversation flounders or moves off topic, with the participant’s experiences otherwise driving the discussion. In line with the principles of this method, interviews focused on participants’ professional role, including their learning experiences and understanding of safety. Participants were encouraged to share illustrative examples. Similarly, the interviewers asked about specific examples – such as a participant’s knowledge and use of relevant standards – to prompt reflection. All interviews were recorded and later transcribed with the consent of the participants. Interviews were initially thematically coded, using orienting concepts such as safety knowledge, learning methods and organizational factors (Layder, 1998). This data was later reanalyzed to critically examine conceptualizations of safety as compliance using the lens of frames. In conducting the frame analysis on this data, we thematically coded for keywords including safety, standard/s and compliance. As already discussed, we are interested in how actors draw on frames to guide decision-making that relates to safety and risk management in their day-to-day work. As such, our interpretive analysis paid particular attention to frames and use of framing devices such as props when conflicts arose around safety decisions. Approval for this work was obtained from The Australian National University Human Research Ethics Committee. 4. Framing safety as compliance: Practices and implications We started this article with the reflections of a design engineer who, in explaining the place of safety in the context of cost and schedule pressures, referred to the imperative of compliance with relevant industry standards. Standards are core frameworks that guide the design, construction and management of complex technical systems from pipelines to offshore oilrigs. They distill knowledge about how to do things safely and, in this sense, good standards are critical. Indeed, members of the Australian gas pipeline industry have argued that their standard (AS2885) is a primary reason for the strong pipeline safety record in Australia, compared with the international experience (Tuft and Cunha, 2013). While standards are key, we should not take their use or their relationship to safety for granted. Rather, we can investigate the ways in which safety as standard compliance manifests, the ways in which it is contested, its strategic use and its implications for major accident risk management. While framing safety in terms of compliance suggests that safety and the means through which it is achieved is straightforward, our research participants draw on the framing of safety as compliance using starkly different language. There is ambiguity over the absolute requirements of standards and thus the require-

ments for safety in areas where seemingly it is just a matter of ‘following the standard’. One way in which we can view the manifestations of this framing is in discussions over ‘absolute’ requirements in the standard, versus the ‘spirit’ of the standard which implies a deeper commitment to safe judgments formed on the basis of expertise. For the purposes of this article, we describe the two compliance frames as:  Frame 1 ‘Compliance as a matter of expert judgment’. Safety here is framed in terms of compliance with standards, but it is recognized that standards (particularly risk-based standards like AS2885) need to be applied in the context of expert judgment. This implies that compliance with standards alone is not enough. Rather, this is compliance in relation to the intent of the professional group, not compliance to the letter of the standard.  Frame 2 ‘Compliance as a straightforward matter of process’. As we will explore, this frame sees compliance as ensuring safety in and of itself. There is less managerial deference to expertise in this context. Decisions that exceed the standard are seen as irresponsible from a business perspective. We now turn to an examination of the practices, personal biographies, contexts and discourses that lead to and sustain these two framings of compliance and their implications for safety management. 4.1. Frame 1: Compliance as a matter of expert judgment The first framing of safety as compliance in relation to standards views safety as achieved via compliance, but also sees compliance as necessarily informed by the expertise necessary to interpret and apply the standard. From this perspective, the standard is not a ‘cook book’ (Hayes, 2015b). With any standard there are grey areas. As one engineer we spoke with put it: ‘There is a spirit of the standard which is kind of implied in some places’. Within this frame, compliance is subject to professional interpretation. Professional interpretations are not formed independently or in isolation. Rather, groups of professionals and organizations come to interpret standards in a particular way. An engineer who views safety from this frame explains: As far as I can tell with the standards, they have their general way of doing it here at this company. It is not written down, you do it this way you do it that way, but they tend to be passed down through the ranks down to me. It may be grey in the standard, but it becomes very clear to me how it is done here [in my organization].

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Within this frame, expert judgment means making decisions based not only on collective experience, but also on a dialogic process with others (for more on building knowledge in social groups, see Knorr-Centina, 1999; Maslen, 2017; Wenger, 1998). When engineers cannot find the expertise within their own organization, they do not hesitate to seek expertise from elsewhere within the profession. The language within this framing is inherently social with constant references to the need for communicating with others in order to come to an agreed version of ‘compliance’ with standards. Significantly, the compliance as expert judgment framing of safety is dominant in the design consultancy introduced in Section 3 (Company A), and less so in the operating company (Company B). In other words, we can see this framing of compliance as being embedded in organizational cultures. In the case of the consultancy, their core service is provision of expertise. Standards in use in the Australian pipeline industry such as AS2885 are riskbased. From the perspective of engineers in this consultancy, this reinforces the critical role of expertise in arriving at a safe outcome. One engineer commented: ‘At some point you need to say ‘‘you’re professionals, understand what is going on and make a judgment, use a risk-based assessment and go from there”’. Another engineer in this company stated: ‘It gives the consultants and engineers a bit more of a purpose, because you have to engage your mind a bit more in interpreting the standard, and have that bit of background. You can’t apply it as a cookie cutter approach’. Their value-add is this expertise, and so from this perspective it is unsurprising that this is the dominant frame in their organization. Within the design consultancy, steps have been taken to ensure the continued use of this frame through mentoring junior engineers in the company. These efforts have been very successful. In order to foster this framing of safety, there is a strong focus on working collaboratively with more senior colleagues with expertise and a value of this expertise as a vital ingredient for safety management. As such, within the organization there is an ‘open door’ policy, with senior engineers working within a remit of being ‘clearly available’ to provide guidance to other members of the team. In keeping with this, the organization is structured around disciplinary work groups with clear, day-to-day mentoring arrangements with discipline engineers paired and seated to promote learning to specifically benefit individuals (Maslen, 2014, 2015). Success here is not only measured in terms of growing the consultancy or technical excellence, but also perpetuating what core members of this organization see as critical practices for public safety. Reflective of this, a principle engineer in the organization asked less experienced colleagues ‘Who have you killed today?’ as a shorthand way of reminding them of the potential consequences of their decisions (Hayes and Maslen, 2015). However, as we will discuss in more detail in Section 5, actors within different organizations using an alternative framing of compliance are challenging this frame. This presents challenges to the survival of this frame, and there is evidence that the expert judgment frame does not always win out. The expert judgment frame is not only located in organizations. It is also situated in individual engineer’s personal biographies, including an individual’s sense of what it means to practice professionally. This framing relies on individual expertise built over many years and in many organizational and industry contexts. Even within a broader organizational context where ‘framing as process’ dominates, particular experiences can shift the frame for individuals. A typical prompt for a frame shift would be an experience of a near miss. In one case, a junior engineer from Company A was on site as the ‘eyes and ears’ of the pipeline owner for an installation of a high-pressure gas pipeline. This site visit was undertaken solo. While on site, the construction contractor gradually asked the engineer to take on extra roles, and eager to perform

well and not delay work, the junior engineer read the procedures, took advice from the construction contractor, and agreed. During the installation, the excavation method used resulted in contact with the live pipeline. While there was the potential for a major accident, the pipeline was not damaged in this contact (for a more complete account, see Maslen, 2015). Reflecting on how this incident occurred, the junior pipeline engineer involved explained that there was contestation over what was ‘compliant’, revealing how different people respond to an actual situation while drawing on different frames: ‘It was in writing that you shouldn’t do that, but it was relayed to me that it was sort of accepted . . . if you did at slightly different, not exactly the same.’ After this event, the engineer involved had a different perspective on the notion of safety as compliance, realizing that the standard itself may be ambiguous because the decisions to produce a safe outcome are context specific. The engineer thus shifted his frame to one in which the language of expertise and professional judgment became the reference point. This experience is, on one level, highly personal. He says: ‘For me it is only a positive. Nothing bad happened out of it and I am much more aware of what can happen, and how easily it can happen’. This framing of safety as compliance through expert judgment resides, in part, in personal biographies grounded in experience. The evolution of the junior engineer’s personal framing of safety as compliance is also influenced by the safety lens of the organization (Company A). When the engineer returned to the office, senior technical experts and managers spent significant time working through the events that led up to the near miss, with a strong focus on learning what implications this has for safety management rather than blame. They concluded that an important lesson was building and drawing on the expertise of mentors within the company. Reflective of this, the organization changed their policy of sending junior staff members to site alone. It is critical for safety, from their perspective, that staff has the power to stop work if something does not seem right. To have the confidence to be able to do this, such judgments need to be supported by staff with a shared framing of compliance. This is to educate junior staff members about what ‘compliance as a matter of expert judgment’ means, but also to guard against undue pressure from workers from other organizational contexts who might be working from a different compliance frame. While people using the expert frame are sometimes accused of ‘gold plating’ decisions, the frame’s emphasis on expertise in making engineering judgments for safe outcomes is strongly supported by the organizational safety literature. Research shows that some organizations are able to operate for long periods while maintaining an accident-free record, despite operating in an environment that poses pressures to maintain high levels of production and/or service provision. Weick and Sutcliffe’s High Reliability Organizations (HRO) theory draws together traits of such high-performing organizations. They claim that high functioning, or high reliability, organizations have the ability to detect and respond to system variations due to their state of mindfulness about their operations (Weick and Sutcliffe, 2001; Weick et al., 1999). This mindfulness is fostered by qualities including a deference to expertise in allowing responsibility for decisions to be driven by knowledge rather than position in the organizational hierarchy (Weick et al., 1999). This emphasis on expertise and professionalism for safe outcomes is present elsewhere in the safety literature (Hayes, 2013; Maslen and Hayes, 2014; Roe and Schulman, 2008). 4.2. Frame 2: Compliance as a straightforward matter of process Following processes in line with the letter of the standards is central to the alternative framing of compliance. This compliance frame is dominant in the large pipeline operating company intro-

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duced in Section 3 (Company B), though the use of the frame is not universal within the organization. The process frame has a stronger connection to business imperatives, in particular pressures of time and cost. Where in the case of compliance as a matter of expert judgment there is a sense of chronic unease (Fruhen et al., 2014; Reason, 1997) over the potential for failure, within this framing of safety there is a greater sense of confidence that the processes embedded in the standard will ensure safe outcomes. This confidence is fed by a narrative that an absence of a major failure in the past is suggestive (in fact, almost predictive) of strong safety outcomes in the future. The compliance as process frame tends to result in little discernment over exactly what is being complied with – it is more about showing compliance, rather than a deeper question of the appropriateness of compliance. Actors drawing on the compliance as process frame acknowledge that there is inherent uncertainty found within the standards. However, what differs compared to the previous frame is their response to uncertainty. Instead of seeking to identify the most reliable interpretation in a given context based on collective expertise of a given community of engineers, here business pressures tend to be more dominant. An engineer and manager in this organization explains the scope for variation in compliance and the financial drivers that influence judgments: [The standard] isn’t prescriptive. It doesn’t say ‘you shall do this’, it says ‘you shall make it safe’. So it is great for 20/20 hindsight, it works really well until something goes wrong, and then you apparently didn’t follow the code . . . So that’s why it’s important to understand why we are doing what we are doing. If we haven’t had an accident in the past then we must be doing the right thing, but then it is a matter of whether we can pare it back to reduce costs, and whether if we did that would be right on the borderline. Compliance does not imply specific design requirements, but instead an understanding of safety that can be tailored and possibly pared back in response to financial imperatives. A common critique of the compliance as expert judgment frame discussed above is that engineers operating in this frame make things ‘too safe’ if they exceed the basic safety requirements prescribed in the standard. Such an over-extension can only be understood in the context of a framing of compliance as a straightforward matter of following process. Balance is a prevailing metaphor in the compliance as process frame. Safety is important but, at the same time, there is an imperative to keep safety measures and their costs in check. An engineer and senior manager at another operating company reflected on this balancing act: On the record or off the record, we’re not here because we’re good folk. We’re here to hit the financials. Someone said safety is good business. Well, it is. Imagine the costs recovering from San Bruno – huge costs! This balancing act is a source of unease for actors using this frame, as is reflected in the questioning over whether enough is being done to prevent disaster, while managing assets in a fiscally sound way. While not prescribed in the standard, one practice within the pipeline industry around this is cost-benefit analysis. Controls for a disaster scenario can be reasoned away through the use of such tools where the risk is identified as low and the cost is identified as high, even where the consequences of a failure would be unacceptable (Hopkins, 2015). Senior management may not even be made aware of the potential for disaster in such cases, as was witnessed in the case of the Gulf of Mexico blowout which killed 11 people. Here, the risk of blowout was assessed to be ‘low’ and therefore in keeping with organizational policy the judgment

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to take this risk without putting in place further controls was taken by the drilling rig foreman (Hopkins, 2012). Such examples draw into sharp focus the potential for catastrophic consequences, where safety is framed in terms of minimum required actions given probability, consequence and, ultimately, the cost of attending to a potential failure. Struggles with balance become particularly important where the standard is ambiguous or non-prescriptive. Junior engineers in the large operating company (Company B) raised challenges they had encountered in this respect. These engineers were conscious that standards are subject to interpretation. However, rather than seeing this as straightforward, they raised concerns about safety outcomes, particularly where the community of practice interpreting the standard did not include industry leaders who wrote the standard. One engineer stated: ‘Sometimes people have different interpretations of what the intent was of the people writing the standard . . . I’ve disagreed before and I was cut short pretty quickly. I really had to argue to get a word in’. Disagreement over interpretation and the potential for this to lead to unsafe practices prompted junior engineers in this organization to seek externally facilitated training sessions on relevant standards, because they were not confident in the prevailing interpretations of other more senior staff from their organization. This desire to access training outside the organization also points attention to the sources of different framings of safety and tensions that can arise at different scales (here, between individuals and their organization). ‘Box-ticking’ is a metaphor often invoked by the junior engineers to critique the framing of compliance as simply a matter of following process. Box-ticking, they argue, cannot result in good safety outcomes because the technical details matter. A junior engineer from this organization expressed: People will say, ‘why are you reading it, just sign it!’ And I have started saying ‘no if I am putting my name to it I’m going to read it . . . if you have got a problem with it, go to the state manager and complain about me’. I don’t care if I lose my job over it, but you’ve got young engineers coming through who . . . don’t have the confidence to . . . say ‘no’. As this example demonstrates, individuals in the workspace have a tendency to behave differently according to different frames they draw on in their everyday work practices. Those seeking to challenge this frame come face-to-face with management and at least perceive themselves to risk job loss by not sharing the approach to compliance taken throughout the company. Safety concerns are dismissed where there is otherwise group consensus, the potential consequences of which were demonstrated at BP Texas City (Hopkins, 2010). This is compounded where there is a difference in experience level. For instance, a junior engineer involved in a safety management study for the construction of a pipeline was concerned that the pipeline was already in the ground. The successful construction was taken as evidence that safety requirements had been achieved. The engineer explained: ‘It was just ticking a box to say it was done . . . You are sitting there and you think ‘‘surely it is not just me that thinks that this is wrong”. I was raising things, and others were saying ‘‘don’t worry, it has already being put in”.’ As a new team member, such concessions stand out as abnormal, rather than ‘the way things are done around here’ (Schein, 1992). However, this engineer felt powerless to effect change as a junior member of the team, a lone voice in the room and an outsider. The framing of compliance as process is founded on a narrative that the successful safety record of the past is enough of an indication that prevailing practice can ensure future safety. Such a logic is out of step with research on major accident risk management which has found that, on the contrary, absence of failure in the past is not an absence of risk (Hayes and Hopkins, 2014). Instead, orga-

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nizations operate hazardous technologies without major incidents due to the defenses in place including technical controls as well as organizational factors such as budgets, safety priorities and management styles (Reason, 1997), and the ‘mindfulness’ of organizations, including deference to expertise (Weick et al., 1999). Safe outcomes are compromised within the framing of compliance as process not because safety is unimportant (actors operating within this frame would vehemently argue that safety is core to their decisions), but because it is subtly sidelined in favor of process. Cost and time pressures implicitly drive the process frame. The language in the frame does not reference business pressures explicitly, and so actors using the compliance as process frame believe and act as if they are able to ensure safe outcomes through complying with the standards, while ignoring the real impetus behind their decisions (though there are cases where this focus on process equates to non-compliance). Nonetheless, we have provided numerous examples to demonstrate that decision making using this frame was less than rigorous and that, as a consequence, safety could be undermined.

5. Frames in conflict: Interactions between a design consultancy and their clients In the previous section, we gave evidence of framings of compliance in which it was clear that compliance could be interpreted differently across individual and organizational contexts. We extend this analysis by examining the ways in which frames are used and contested in interactions between the design consultancy and their clients. In the context of major accident risk management, conflict over safety interpretation is problematic because safety decisions are often compromised or ‘tested’ by other business pressures such as cost and schedule. This idea is captured in the ubiquitous iron triangle of project management (Hayes, 2015a). Contestation raises the potential that safety requirements will be reasoned away. The discussion of compliance as process showed the ways in which framings of safety can be contested. In this case our analysis revealed that it was the organizational framing that tended to dominate. Yet conflict between frames of compliance happen between organizations as well. The different understandings of safety and risk management between the two frames are at the heart of the conflict. In this section we engage with whether this conflict results in compromise or a hybrid frame, or a shift in frame entirely. We also examine who has the power to define the safety frame and in what sort of situations. The design consultancy (Company A) generally operates following the compliance as expert judgment frame. Some clients share this frame, but others operate in the alternative frame. Critically, though, despite this focus on compliance via expert judgments, the application of this frame does not always specify a particular design outcome. An engineer from the design consultancy explained how he works with clients from different companies. Some clients have more technical involvement, others less so. Some have their own standards, others do not. Some want a more sophisticated design, others want more ‘bare bones’ plant that requires more operator involvement. There is scope for variation within a design, which is responsive to client definitions of what it means to be compliant, economic and safe. This variation signals that there are different and perhaps competing objectives in the design, construction and operation of a facility. Can this variation result in conflict? This engineer said that while the design itself differs: ‘I like to think that the quality of the work that we do is the same for any client’. His confidence is tempered in cases where there is an awareness that in addition to some designs having fewer safety measures, designs may not necessarily be constructed

as they were designed. For instance, another engineer in this consultancy explained that due to cost considerations, some materials may be selected over others: ‘Technically it is not non-compliant with standards, but we look at it and go ‘‘okay”.’ This example highlights conflict, but also suggests that the consultancy has limited influence over many of the decisions. While the consultancy engineers were conscious of the limits of their influence, they still made an effort to assert the expert judgment frame in conversations with clients so that safety was given due consideration. An engineer gives an example of where the client wanted to do something that was non-compliant. In this case, the relevant standard was used to ensure the right outcome for safety. The client was ignorant of the correct technical details and, as such, the role of the consultancy was to ‘educate’ their client. The engineer commented: ‘sometimes we deal with guys who don’t necessarily have the technical experience or knowledge of the standards, and they might be looking at things from the wrong point of view.’ The clients who seem most under cost pressure appear to be the ones that most need this kind of push back from the consultants who constantly reference Australian standards such as AS2885. This reflection demonstrates the different frames that are in operation between individuals in the two organizational contexts. Within the design consultancy, the focus is on expertise, and so their conflict with the other point of view (or frame) is expressed as needing to educate a client who lacks this understanding. From the perspective of the client, we can imagine that they might claim they need to educate the design consultancy about the requirements of their business. 5.1. Frame conflict and the creation of hybrid frames The tensions that arise between the design consultancy and their clients are the foundations of a hybrid frame, where the final design is formed in conversation with standards interpreted through the engineering expertise of consultants and the requirements, priorities and interests of a business or sector. This is an iterative process, in which the consultancy develop a design in line with business requirements. There is back and forth between the actors using their respective frames and the outcome is not necessarily the starting point of either of the parties. They each take on variations except where there is a critical breach of the core principles underlying their frame. For the case of the design consultancy (Company A), this is where, in their expert opinion, a decision has the potential to compromise safety and this view is supported by requirements in the standard. We can see the creation of a hybrid frame through closer examination of the following communication between two actors. A senior engineer in the consultancy gives an example of using the standard as a prop to present a persuasive (and polite) argument based on the frame of compliance as expert judgment. This example refers to a decision with the potential to affect worker safety. While this example does not have implications for major accident risk management, it showcases the tactics employed to promote a frame that is being undermined, where there is a critical breach: It is mandatory in the Australian standard to have handrails on their platforms. And they [the client] are saying they don’t want it. We did actually put it on our design and they’ll have to speak to the contractor to not install it if they don’t want [it] . . . They say they’ve done a risk assessment internally . . . I guess we weren’t involved with that risk assessment, and it is mandatory in the standard to put them on . . . We spoke to [consultancy principle] to find out how forceful we should be with the client. We sent them the pages [from the standard] and told them what it was and why we thought they needed it.

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The reliance on the standard as a prop in these contexts is an attempt to communicate a particular frame of safety as compliance, with clients who use a different frame to understand compliance. We are particularly alerted to the issue of power imbalance in cases where the requirements in the standard are clear, and yet there is caution around how forceful to be and the need to be polite for client relations. Again, commercial interests influence frame dynamics. Their capacity to be forceful about safety issues is compromised due to the imperative of client relations. Consultants need to maintain a client base, but they are also concerned about a professional and safe outcome. The conflict described above does not necessarily result in an outcome where the frame of the consultancy is completely overridden. Rather, it can result in compromise or a hybrid frame. To work towards the best outcome that can be achieved in cases of conflict, the consultancy engineers emphasized the importance of relationship management, as well as a paper trail to protect themselves from litigation where their advice is not taken. As one engineer in this company explains: You have got to do the written part because that is what you fall back on if there is a dispute, [but it is also about] fostering relationships, being able to call people up, and doing the courtesy . . . you have got to have the talk about it and just say ‘please, do this part right’. That this engineer mentions the need for a paper trail alerts us to the level of concern about safety and the potential variation in outcomes that can occur, despite both framings of safety using the language of compliance. If the quality of the work was really the same for every client, then such professional liability concerns would not arise. Yet, this account also directs our attention to the willingness to compromise, providing aspects of the design essential to safety, from their expert perspective, are satisfied. This compromise or hybrid frame can emerge even in cases where a decision may be uncompliant. Despite this, the consulting engineers rely on polite education, calling clients to support decisions as a friend might and focusing not on compliance but the aspects of a design that are absolutely critical for safety. While there is the potential for tensions between the two compliance frames to be resolved in a way that does not fundamentally undermine safe outcomes, there is a power imbalance between the frame proponents. Throughout this discussion of frame dynamics we have seen the subtle ways that commercial interests undermine practices of considered decision-making. In educating clients about the standards, consultants are playing the role of a pseudo regulatory authority. At the same time, they are reliant on these very clients for their commercial survival. A safe outcome can depend on the client having enough deference to expertise, at least on critical design points. This deference to expertise is absolutely essential, as analysis of high reliability organizations has shown. We would suggest that the reliance on relationship management for safe outcomes is precarious, and an area worthy of further attention.

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these frames – the compliance as process frame – can undermine safety management and in ways that actors are not necessarily aware of. This is to the extent that while this framing of safety uses the language of compliance it could also result in non-compliance. As such, we hope that in revealing these two frames, the tensions between them and implications for safety management will be useful to practitioners in the industry. Our findings affirm the multi-scale nature of frame dynamics. We have argued throughout this article that personal biography and organizational context influence the creation and perpetuation of particular frames. As such, in organizational contexts in which one frame dominates, this framing may not be shared by all employees with their own experiences and interpretations. It is important to emphasize that there is a power imbalance in terms of the resources that can be harnessed to promote the frames. Given this, the frame assumed by organizations (and particularly operating companies) tends to dominate. Cost and schedule pressures play an important role here, as safety related decisions are always occurring within a real world business context. Nonetheless the expert judgment frame has the cultural capital behind it of a cohort of engineers who have in-depth knowledge of technical questions. The differences in types of resources that each frame is endowed with help explain why the tensions between them remain ongoing with neither frame ‘winning’ in every scenario. A significant finding from exploring compliance frame dynamics is that whether or not one uses a compliance as expert judgment or compliance as process frame is not a matter of expertise or industry experience. Indeed, many junior engineers are committed to the expert judgment frame, even to the point of risking their position in the company. Likewise, a number of senior engineers discussed compliance in terms of a compliance as process. It follows that improving major accident risk management in the context of the Australian gas pipeline industry is not a simple matter of providing education for novice members in order for them to be ‘trained up’ to the expert judgment frame. There are a number of issues to consider for future research. Further cross-scale analysis would enhance our understanding of compliance frame dynamics. In particular, examining the development of the standard as well as other industry level articulations of compliance would provide yet another valuable perspective on frame dynamics. Our research has also uncovered other framings of safety, separate from understandings of safety as ensured through compliance. Analysis of these competing framings of safety and their interactions with compliance frames is an area of research we intend to further explore. Acknowledgments Thank you to the research participants who gave up their time for interviews and made many thoughtful comments about their professional lives and activities. This work was funded, in part, by the Energy Pipelines CRC, supported through the Australian Government’s Cooperative Research Centres Program. The cash and in-kind support from the APIA RSC is gratefully acknowledged.

6. Conclusion Despite its relative newness within the safety and risk literature, framing is a useful conceptual approach for exploring manifestations of safety as compliance in the Australian gas pipeline industry. Our analysis reveals two, often competing, frames of safety as compliance. Neither frame challenges the foundational importance of compliance. Likewise, participants using both frames would rate safety as a core guiding principle to their decision-making. This is a positive for an industry that is significantly self-regulated. Nonetheless we have argued that one of

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