HSG48 and HSG65, UK wide
Safety Culture and Behavioural Safety
Two sites can run the same procedures, the same training and the same equipment and produce completely different results. The difference is what people do when nobody is watching and what happens when they raise a problem. AL23 Safety builds and tests safety culture programmes that change both, for clients UK wide.
What is safety culture?
The shared assumptions that decide what happens when the procedure is inconvenient
Safety culture is the set of shared values, attitudes and behaviours that decide how risk is treated in your organisation. It shows in small decisions. Whether a supervisor stops a job running late. Whether an operative reports a near miss knowing it will trigger questions. Whether a manager who cuts a corner is quietly rewarded for hitting the date.
It is worth saying what safety culture is not. It is not posters. It is not a slogan, a lanyard or a signed pledge card. It is not a score in a survey. Those things describe or promote a culture. They do not create one. Culture follows what an organisation actually does with time, money and consequences.
Where the guidance comes from
Two HSE publications carry most of the weight. HSG48, Reducing error and influencing behaviour, sets out the human factors model. It treats behaviour as the product of three interacting things, the job, the individual and the organisation. Most human error is a symptom of how work has been designed rather than a character flaw.
HSG65, Managing for health and safety, provides the framework it sits in. Plan, Do, Check, Act. Culture work belongs in each phase rather than as a project running beside them. Both are guidance. Neither is law, nor does either carry the special status of an Approved Code of Practice.
The honest caveat, up front
Culture programmes fail most often when used instead of fixing something physical. If the extraction is inadequate, the access equipment is wrong or the shift pattern makes fatigue inevitable, no amount of engagement will hold. Behaviour follows conditions. We will tell you when the honest answer is capital spend rather than a campaign.
Who needs one
Where behaviour, not knowledge, is the limiting factor
- Your incident rate has plateaued despite good procedures, training records and current risk assessments
- Investigations keep concluding with human error or failure to follow the procedure as the cause
- Near miss reporting is low or has fallen, which usually means confidence has fallen rather than risk
- You are preparing for ISO 45001 certification and clause 5.4 on consultation and participation of workers is exposed
- Two sites in the same business perform very differently on the same systems
- A serious incident has damaged trust and you need something more credible than a stand down
- Leadership visibility has been raised as a finding by an auditor, a client or an insurer
The regulations that apply
Your legal framework, in plain terms
There is no safety culture regulation. The duties sit in the Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999. What culture work does is make those duties achievable, since a system nobody uses is not a system.
HSWA 1974 section 2(2)(c)
Information, instruction, training and supervision so far as is reasonably practicable. Supervision is the part most often thin. It is also where behaviour is actually shaped.
HSWA 1974 section 7
Every employee must take reasonable care for their own safety and that of others affected by their acts or omissions. Individual duties are real, though they never displace the employer duty.
HSWA 1974 section 37
Where an offence is committed with the consent or connivance of a director or manager or is attributable to their neglect, that individual is also guilty. On indictment the maximum is an unlimited fine and up to two years imprisonment.
MHSWR 1999 regulation 5
Arrangements for planning, organisation, control, monitoring and review. Culture determines whether the monitoring stage produces truth or reassurance.
INDG417, Leading health and safety at work
Joint guidance from the Institute of Directors and HSE, built around a plan, deliver, monitor and review agenda for boards, with strong and active leadership, worker involvement and review as its core principles. It is guidance rather than law. It is also the document most auditors reach for when testing board engagement.
What the service covers
From a climate survey to a just culture
- A safety climate survey run confidentially, with results reported by area rather than by individual
- Follow-up focus groups, since a survey tells you where the problem is and only conversation tells you what it is
- A leadership visibility review, covering how often directors and senior managers are on the floor and what they do when they get there
- A review of your reporting culture, including near miss and good catch volumes, the time from report to feedback and the proportion that lead to a visible change
- Design or repair of a behavioural observation programme, with observer selection, training, coaching conversations and anonymised data
- A just culture framework separating human error, at risk behaviour and reckless behaviour, with a decision guide managers can actually apply
- Consultation arrangements meeting ISO 45001 clause 5.4, the clause most commonly failed at stage 2 audit
- Alignment of investigation practice so findings reach systems and conditions, supported by our incident investigation work
- Leading and lagging indicator design, letting improvement be evidenced rather than felt
- An honest conditions check, listing the physical and organisational fixes that must happen before behaviour change is fair to ask for
Our process
Fix the conditions before the behaviour
- 01
Baseline
Climate survey, incident and near miss data, investigation quality, training records and a walk round. We look for the gap between what is written and what is done.
- 02
Listen properly
Focus groups and one to one conversations at every level, including nights and weekends where you run them. The night shift usually knows most and is asked least.
- 03
Fix the conditions first
We separate findings needing engineering, resourcing or scheduling from those genuinely about behaviour. The first list is dealt with first.
- 04
Build the programme
Leadership routines, observation and feedback, reporting improvements and the just culture framework, each with named owners and a defined cadence.
- 05
Measure and re-survey
Leading indicators monthly, a repeat climate survey at twelve to eighteen months. Anything shorter measures enthusiasm rather than change.
What you get
Reports and routines reported as found
- A safety climate report by site and area, with free text themes summarised honestly rather than sanitised
- A prioritised conditions list separating capital, resourcing and scheduling actions from behavioural ones
- A leadership routine specification setting out what directors, managers and supervisors do, how often and with what record
- A just culture decision guide with a short manager briefing to go with it
- An observation programme pack with observer guidance, conversation prompts and a data structure avoiding named individuals
- A measurement set of leading and lagging indicators with a board reporting template
What we need from you
Real access and honesty about funding
- Genuine access to people, including operatives, agency workers and contractors, without a manager sitting in
- Three years of incident, near miss and investigation records, including the ones that were closed as human error
- Visible commitment from the top, since a programme the directors delegate entirely is read correctly by everyone
- Honesty about what will not be funded, sparing us a programme built on a control that never arrives
Why AL23 Safety
We will not sell a campaign over a fix
Accountable
If your culture problem is actually a maintenance problem, we say so. We will not sell a behaviour programme to cover a broken guard.
Evidence over enthusiasm
Surveys, focus groups and indicators, reported as found. A climate score that only ever improves is measuring the wrong thing.
Grounded in the operation
Our consultants spend the day where the work happens rather than in the meeting room, which makes findings recognisable to the workforce.
UK wide
We run culture and behavioural safety programmes for single sites and multi-site groups across the UK from our Manchester base.
Where to start
A conversation about what your data is already telling you
Send us your incident and near miss figures for the last three years. That usually tells us more in ten minutes than a proposal will.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usThey are worth doing for one purpose, which is finding where to look. A survey measures perception at a point in time. It cannot tell you why. It is vulnerable to a low response rate and to fear of identification. Used alone it produces a number and no change. Used as the front end of focus groups and an action plan it is genuinely useful.
It can be. That is the fair criticism. An observation programme counting unsafe acts while the conditions causing them stay untouched shifts responsibility onto the people with least control. We record why a behaviour happened rather than only that it happened, feed conditions findings into the maintenance route and keep observation data anonymous. Where conditions are not being fixed, we recommend you stop the observations.
Speed of feedback matters more than any incentive. People report when they see something change and when they trust the report will not be used against them. That means a visible response within days, a just culture position stated by the directors and applied consistently and no league tables punishing the site that reports most. Rising volume is usually a sign of trust rather than deterioration.
It means the response to an unwanted event depends on the behaviour rather than the outcome. Honest error attracts a system fix. At risk behaviour, where someone did not appreciate the risk being taken, attracts coaching. Reckless disregard of a known and substantial risk attracts discipline. The value is consistency. Where the same act is punished after an injury and ignored without one, people learn to stay quiet.
With a mix, never one number. Lagging indicators such as injury and ill health rates matter. Nationally they show why the work counts, with 1.9 million workers reporting work-related ill health in 2024/25 and 40.1 million working days lost. Leading indicators tell you sooner. Near miss reports per hundred workers, time from report to feedback, actions closed on time and leadership tour completion.
Cost is driven by headcount, sites and whether the programme is built and handed over or run with you. Reporting behaviour and leadership routines can shift within one to two quarters. A measurable move in climate scores usually takes twelve to eighteen months. Anyone promising faster is selling a campaign rather than a change. Our published pay as you go rates are £95 per hour or £695 per day plus VAT, with longer programmes sitting inside a retainer from £550 per month at Advanced level. Where the work must land inside a certified framework, our ISO 45001 consultancy and health and safety management systems pages cover that.
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