Sylvester the lion is back in the hands of SANParks again after having been on the loose for a couple of days. With imminent danger to residents of the greater Karoo area lifted, SANParks will now have to review its OHS policies and procedures. There are certainly some serious improvements to be made.

Risk assessmets and Health and Safety Inspections could have preveted this situation
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It was the second time in just under a year that the three year old lion managed to escape the Karoo National Park outside Beaufort West. Last year Sylvester went missing for almost three week, causing a frantic search involving trackers and helicopters, that costed SANPark's nearly R 800 000. Adding to this, SANParks also had to compensate several farmers for the 28 sheep, 1 cow and a Kudu Sylvester had killed. As the unease about a lion on the loose was growing again during March of this year, SANParks announced that the lion would be euthanized as soon as it was to be recaptured. According to a spokesperson of SANParks, Sylvester was identified as a problem and that putting it down was the only option left. SANPark felt its decision was supported by the National Council of SPCAs (NSPCA) Wildlife Protection Unit. They believed that, as the animal now knew how to escape and where to find easy prey, the lion had become a danger to human beings as well. Killing it would be the best option in the interest of all, so they said. Unfortunately for SANParks, South Africa and others thought differently. The announcement caused a huge outcry from citizens and animal lovers across the country and abroad, leaving the organisation with no other option than retracting its statement.

Kneejerk reaction

SANParks approach of dealing with this failure in terms of keeping the lion within its premises is testimony for the kneejerk reaction companies tend to make once it becomes clear that they have failed to comply with their mandate. Instead of following the internationally accepted approach of reviewing their situation, considering their steps and implementing their actions before these will be submitted for constant evaluation, SANParks thought that killing the animal would prevent the escape of (dangerous) animals from it ever happening again. In health and safety things simply don't work that way. Even though the direct risk is removed, it still will not change the severity of the impact when a similar incident occurs. With SANParks mandate being to manage a system of parks which represents the indigenous fauna, flora, landscapes and associated cultural heritage of the country they rather should focus on dealing with the situation indefinitely than limiting their scope.

Cats are playful and it is common knowledge that lions are dangerous. God forbid to think what schools would be like if killing unruly children would have been considered the norm! Rather than jumping the gun (in this case, literally) SANParks should thoroughly investigate the incident. It will have to do so by questioning its own management, staff and materials as well as the environment in which Sylvester was kept. For each of these elements, SANParks will have to ask itself questions like 'who was involved or responsible?', 'what where they doing or thinking?', 'where were they when the lion escaped?', 'when exactly did the lion escape?', 'why did it escape' and 'how was it possible that it escaped. Only by answering these questions, SANParks will be able to come to the root cause of the incident which will produce a foundation from which it can rebuild its case.

Adhering to well-defined but basic principles

With the root cause established SANParks can go back to the (legal) drawing board to consider appropriate action. The national parks authority activities are governed by various acts, including the Environment Conservation Act, 1989 (Act No. 73 of 1989), the National Environmental management; Protected Areas Act (Act 57 of 2003) and the South African Occupational Health and Safety Act (Act 85 of 1993). In the interest of this article, I will focus on the latter. As we all know, abiding to the OSH Act is challenging but necessary. To SANParks it is not any different. That is why SANParks has to respect sections 8 and 9 of the Act which points out that they have to provide a (working) environment that is safe and without risk to the health of employees and others. Euthanizing Sylvester would have made no difference as it would not have improved the situation of preventing animals from escaping again. SANParks should rather assess and identify the risks that can result in financial loss, escaping animals, do damage to its reputation, harming employees, visitors, clients or other people and so on.

They should do so through a framework of principles, practices and criteria for implementing best practices in managing risk. This process is never ending as today's world is vibrant and an ever changing environment. As the rule of thumb states that by adhering to basic health and safety awareness and good governance, 98% of all incidents can be prevented in any type of organisation, assessing risk correctly can go a long way.

Health and Safety officials continuously study and assess the risk profile of their organisation. This can either be done through a baseline risk assessment to find out how they stand with regards to health and safety risks; an issue-based risk assessment that is done when there is a change in 'the workplace' or by conducting a continuous risk assessment by means of audits, inspections, tasks observations etc. The recent incident warrants that SANParks conducts all three forms of risk assessments for various elements of its operations. As part of either form of risk assessment the health and safety specialists actively visits 'the workplace', talks to all parties involved to understand who believes they are at risk and how risk is perceived, read up on incidents reported elsewhere in the industry and study any documentation available within the organisation in which the health and safety of the organisation is considered or discussed. This also includes, but is not limited to, incident reports and newspaper clippings of previous (similar) incidents. With Sylvester having escaped before, SANParks will surely have documentation and information in abundance that can be studied again in the latest incident investigation.

Wrong approach to the four T's

Proper risk assessments will always have to be conducted in pairs to allow the combined observations, knowledge and expertise of the individual assessors leading to robust debate and solutions that have thoroughly been considered. Once the risk has been identified, health and safety officials have four options for controlling the risk. They are commonly known as the Four Ts; tolerate, terminate, transfer or treat. It goes without saying that 'tolerating' the situation is impossible and unacceptable but neither is 'termination'. No health and safety official nor any conservationist is ever taught to translate 'termination' as a license to kill. In terms of occupational health and safety, 'termination' means; ending the exposure to risk.

Conservationist John Varty points out that no fence will ever stop any animal that has set its sights beyond property boundaries. But he also has some advice that can be considered to mitigate or reduce the possible risk. This includes removing any alpha lion from the same area as well as introducing two females to keep Sylvester focused. Only if such action still proves to be unfruitful, SANParks can consider transferring the risk by transferring the lion to an area that is better suited to the lion, or where it poses less danger. Given the outcry of the public caused by the poorly made statement, it is likely that SANParks feels forced to consider 'treating' the situation. It will be expected to do whatever it reasonably can do to reduce the risk of it happening again or make the consequences less seriously. With the thousands of kilometers fencing it and millions of animals for which SANParks is responsible, implementing a solution goes much further than just replacing the soil to prevent Sylvester from digging underneath a fence again.

In fact I would advise SANParks to take a much more holistic approach. If the Bird triangle is anything to go by, this serious incident is only the tip of the iceberg. Bird's triangle considers 'incidents' as serious injuries. He already claimed in 1969 that for each serious injury reported, 10 minor incidents, 30 incidents or property damages and 600 misses or warnings had already taken place. Bird had studied thousands of accidents to come to this conclusion. As the escape of a lethal animal out of a sanctuary can be considered as 'serious' one can only wonder how many minor incidents, property damages or near misses have been reported over the past few months.

SANParks will, without a doubt, be insured to compensate the owners of the animals that were killed last year. And even though R 800 000 is a lot of money to spend, it is still a fraction of the money the organisation makes by enabling tourists and visitors to see animals in their natural environment. In fact SANParks concerns, nor the concerns of any organisation that has experienced an incident, shouldn't be about the money it has to pay or the improvements it has to make. The cost resulting from its ‘kneejerk reaction’ can easily surpass this amount. As one protestor quickly pointed out,
killing the cub is not in line with its mandate and would conflict with SANParks own slogan that reads; 'Conserving nature since 1926'. Forgetting the basic in terms of instilling good health and safety practices in an organisation' day-to-day operation can cause serious damage. Making uninformed statements regarding this failure can, however, be more lethal than a lion being on the loose.


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Posted date: 12th Apr 2016
Latest News - Health & Safety Services - Risk Assessment - OHS Risk Assessment
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