A Bureaucratic Approach to Safety is Weakening the British Army’s Training

In recent years, a number of fatal accidents involving UK service personnel have been reported, each a tragedy in its own right. At the same time, since the withdrawal from Afghanistan, the armed forces have become a significantly safer environment than the wider civilian world; service personnel are 56% less likely to die each year than their civilian peers. While statistics are no comfort to a grieving family, this provides some perspective for the evaluation of Defence’s approach to safety.

Two years ago, a brave syndicate of young officers published an article on the extreme shortage of collective military training in the British Army. While levels have significantly improved in spite of severe resourcing issues, this article will argue that the present rules-driven, top-down approach to safety is holding training back – and may be less safe than a more balanced approach. Safety bureaucracy is also arguably hampering innovation and the development of resilience against the unexpected dangers inevitable in war.

The armed forces are subject to the same health and safety legislation as business, except where the Secretary of State explicitly waives it, but Defence cannot be prosecuted except – in extremis – for corporate manslaughter under the Corporate Manslaughter and Corporate Homicide Act 2007, something which may be tested for the first time shortly.

Defence’s approach to safety is grounded in Lord Justice Haddon-Cave’s report on the Nimrod accident in 2006, in which 14 RAF aircrew died in a fireball. His report is recognised as a landmark document. He unearthed a range of institutional and individual shortcomings, and showed moral courage in, for example, dismissing the findings and comments of his fellow judge, the coroner on the case.

Haddon-Cave’s proposals were rooted in four principles:

• ‘… strong leadership from the very top, demanding and demonstrating by example active and constant commitment to safety and Airworthiness as overriding priorities’.
• Thorough independence throughout the regulatory regime, in particular in the setting of safety and airworthiness policy, regulation, auditing and enforcement.
• Much greater focus on People in the delivery of high standards of Safety and Airworthiness (and not just on Process and Paper).
• Regulatory structures, processes and rules must be as simple and straightforward as possible so that everyone can understand them.

These were prescribed for all three services, but this short article focuses on the Army.

For supervision of airworthiness, the Military Aviation Authority (MAA) – paralleling the civilian Civil Aviation Authority, has been set up in line with Haddon-Cave’s recommendations and Defence has also established a separate Defence Safety Authority (DSA), including its Defence Accident Investigation Branch. Both the MAA and DSA have grown in numbers, while the size of the armed forces has declined. Safety in the Army is administered by the Defence Land Safety Regulator, also part of the DSA. Each commanding officer is accountable as Duty Holder for their unit, but SO2 Equipment Support – in brigade headquarters – rules which vehicles are safe to use. Meanwhile the risk for each vehicle type is held by a designated senior officer.

It is it is hard to see how Haddon-Cave’s third principle – shifting the focus more towards people rather than processes and paper – has been followed. For example, SO2 Equipment Support regularly vetoes use of vehicles, overriding commanding officers, yet the assessments as to whether inspections are up to date are based on a software system (JAMES) without any direct oversight of the checks it records. As most vehicles no longer ‘belong’ to units and are instead held centrally in the Training Uplift Fleet, their state while not in use is no longer the responsibility of the commanding officer. Many vehicles are old, without a single owner and in poor shape, so a unit taking them over (and often finding there are too few of them available) may face a choice between keeping the checks it logs fairly superficial or risking being simply unable to exercise.

In 2021, a soldier was crushed to death while sitting on the turret ring of a Scimitar when the driver struck a tree with his gun barrel. More recently, a young officer was crushed under the tracks of a Warrior when it reversed over him. A people-based approach to ‘lessons learned’ from these tragedies would surely emphasise the importance of ensuring that people are trained on individual vehicles properly and that their commanders – the people who know them best – appraise when they are ready to take on the much greater challenges of operating these vehicles in the excitement and stress of collective training.

Instead, both accident reports tabulate long lists of process shortcomings (some of which are actually admitted to be wholly irrelevant) and a large number of recommendations which, while sometimes making individual sense, could collectively only lead to less training, especially when resources are so limited. One extreme example was a recommendation to introduce a new formal qualification for being a competent Warrior passenger as a condition for participating.

The latest Defence Land Safety and Environmental Regulations, at 130 pages long and with many connecting links to other long documents, are somewhat shorter than their predecessor and contain a clear intent from the (then) Chief of the General Staff, but units face a constant stream of highly prescriptive safety notices by email. While a case can no doubt be made for each, together they risk robbing individual soldiers of their one opportunity to ‘use the kit’ in a year and/or reducing a unit’s ability to field critical mass for training. Besides apparently contradicting Haddon-Cave’s third principle of rebalancing from processes to people, it is hard not to believe that this level of micromanagement of commanders is damaging unit training. The combination of more rules and less training over the past decade – in the view of many practitioners – has led to a loss of confidence among those operating the vehicles, which can only make them less competent and less safe. It seems that the guideline of a ‘Safe System of Work’ has driven out the wider concept of mission command based on commanders’ judgement.

Furthermore, Haddon-Cave’s second principle – of independence – may have been taken further than he intended. Either way, current practice conflicts with more recent thinking. Haddon-Cave quotes two main theorists, but arguably the pre-eminent one today has published most of his work since the judge’s report. Professor Sidney Dekker has held posts in US, Australian and Dutch universities. Besides his broad study of safety across many industries and knowledge of psychology, he is an experienced part-time airline pilot and has extensively researched the small category of accidents where crews survived under the most challenging conditions. The lessons from these are arguably disproportionately important for war, where coping with surprise is a critical factor in military capability.

Dekker’s comment on the independence of regulators and their inspectors (Haddon-Cave’s third principle) is:

‘The tension between having to be an insider and an outsider at the same time is difficult to resolve. The conflictual adversarial model of safety regulation has in many cases not proved productive. It leads to window dressing and posturing … during inspections … real practice is easily driven underground.’

He recommends organisations:

‘…need to monitor the gap between procedure and practice and try to understand why it exists (instead of just trying to close it by simply telling people to comply)… what goes … unnoticed is that informal work systems compensate for the organisation’s inability to provide the basic resources needed for task performance.’

Perhaps the most striking illustration of the potential gap Dekker highlights between practitioner and regulator is provided by a fatal accident in a Jackal armoured reconnaissance vehicle. This involved two senior non-commissioned officers, an instructor and a trainee, both with many years of Regular Army experience but serving in a yeomanry unit, who made repeated attempts to mount a steep bank until the vehicle rolled, killing the trainee. Instead of focusing on the lack of testing for tilt safety on conversion from the original Urgent Operational Requirement to wider use (and ‘up-armouring’) and simple principles on training the trainers, these issues are buried among some 170 contributory causes. The report on the accident promulgates pages of recommendations, including setting up yet another safety agency to deal with feedback on minor accidents (at arm’s length from the DSA, thus conveniently shielding the latter from responsibility for processing such material).

There is much emphasis on shifting culture in the report, but a failure to acknowledge as Haddon-Cave does that transforming culture requires a rebalancing from processes to people and greater simplicity. Nowhere, of course, does any report suggest that the DSA itself – and its expanding library of rules – may be risking losing the respect, and hence the compliance, of operators, thus actually undermining a culture of ownership of safety. The old principle that an excessively long safety brief is unlikely to inculcate better safety habits seems apt here. In fact, through calling for a shift from process to people and for simplicity, Haddon-Cave foreshadowed the work of people like Dekker who call for a bottom-up-driven safety culture, in which those on the ground genuinely own safety and regulators are seen as partners rather than enforcers.

There is a fundamental difference between civilian work and military training – the former is carried out as an organisation’s primary purpose, while the latter is preparation for the vastly greater dangers of war, trying to simulate the actual scenarios of conflict. Military training requires an approach that prepares people to assess and take risks when tired, cold and frightened – circumstances where accidents are inevitably more likely. This difference is reflected in the Secretary of State’s discretionary powers and in the considerable restrictions on the powers of the (civilian) Health and Safety Executive (HSE), but it is seldom acknowledged in the public space.

Two further factors worsen the picture, both of which are exemplified by the Ukraine conflict. First, innovation has proved critical there – from the use of drones to operating weapons from irregular platforms. Yet, a system in which nothing can be tried on exercise that has not been extensively trialled for safety prevents challenging commanders to deal with the unexpected – something critical for resilience in war. Second, while the issues above are severe for a professional army, they make training for reserves – with their much more limited time available – doubly hard, and the current mindset rules out altogether the mass integration of civilian volunteers which has also been critical in Ukraine.

Indeed, at a time when the US (the world’s most litigious country) has part-time aviators flying F22s, the UK Army Reserve is likely to have to give up on Jackal and go back to Land Rover variants because the Jackal safety regime has too many hoops for part-timers to jump through. It will be interesting to discover what lessons have been learned from the UK’s role in training Ukrainian recruits. This has been delivered much faster than training the British Army’s own soldiers. Equally, feedback on UK training from Ukrainians after their subsequent deployment at the sharp end must be studied.

Faced with questions from lawyers, the media and Parliament after fatalities, senior officers and their political masters are under strong pressure to ensure paper trails to cover backs in enquiries, coroners’ courts and civil action, even at the expense of delivering demanding, realistic training – and indeed the best approach to safety. Curiously, despite the Secretary of State’s discretion and the reduced powers of the HSE, the latter has no policy to distinguish military activity in the way it does for the police. The government may also wish to question whether the 2007 Corporate Manslaughter Act is really appropriate for troops training for war.

Defence should consider setting a different course, with a lighter rulebook and greater delegated discretion. Legislation would help underpin this, but ministers and military leaders must engage in the public space with Parliament, the media, coroners and others (as Haddon-Cave did) to make it clear that preparing for war must involve accepting a degree of risk. If training is not demanding and realistic (including a significant element of experimentation and surprise), casualties will be much higher in war and capability will be lower – even for professional soldiers – while training follow-on formations may become impractical.

The present imbalance between safety and realism has been struck in peacetime, in the expectation that the downstream risks inherent in sending formations to war under-trained for its stresses and complexity would be unlikely ever to arise. That expectation has been falsified by Russia’s aggression; a new balance must be found.

The views expressed in this Commentary are the author’s, and do not represent those of RUSI or any other institution.

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