Occupational Safety and Health

Occupational Health and Safety in Catering Industry in Hong Kong

Occupational Safety and Health

The incidence rate of workplace accidents in the catering industry in Hong Kong is higher than that of other sectors, even those associated with inherently high risk to workers. Despite corrective action within the catering industry, the accident rate remains stubbornly high. This research identifies causal factors in occupational accidents in catering companies and delineates effective strategies that can be emulated by catering businesses in Hong Kong in efforts to reduce their accident rates and worker injuries.

Hong Kong is known for its international cuisine and, characteristically, a high number of restaurants -- many offering catering services -- exist in the city. Yet, the polished environments of the dining areas of world-class restaurants contrast greatly with the restaurant kitchen and backroom workspaces. The catering industry in Hong Kong attains extraordinarily high rates of accidents and has, according to the 2010 occupational safety and health statistic bulletin of the Labour Department of Hong Kong Special Administrative Region (HKSAR) of the People's Republic of China, has the highest rate of occupational accidents, even exceeding the accident rate found in construction, manufacturing, mining and quarrying, transport and servicing, and utilities. Changes in safety measures to reduce the number of occupational accidents in the workplace have been attempted by numerous catering companies in Hong Kong (Kuen, 2005). A considerable amount of resources have been directed at the safety measures (Kuen, 2005). Nevertheless, the corrective measures have not made a substantive impact on safety for workers in the catering industry in Hong Kong (Kuen, 2005). Moreover, the global economic recovery, which includes revitalizing increases in tourism, suggests a growing catering industry. Indeed, with approximately 10,000 eating establishments that account for roughly 170,000 jobs, it is important that this mainstay service industry have a robust operational health capable of sustaining high rates of employment (Kuen, 2005).

Most of the studies on accident rates in catering companies have focused on the causes and the costs of unsafe workplaces. Researchers have examined the problem of unsafe workplaces from the perspective of injuries to personnel, indirect company costs, direct company costs, company reputation, job retention, employee morale, and other human costs (Kuen, 2005). Direct costs that have been addressed in the literature include workers' compensation expenses born by companies, sick leave taken by injured workers, occupier's liability premium, and legal representation costs (Kuen, 2005). Indirect costs are at times difficult to ascertain since they may be difficult to quantify or estimate (Kuen, 2005). A wide array of worker-related statistics is available on the websites of government agencies, including the Census Statistics Department and the Labour Department. Data is available on occupational diseases, the number of work-related injuries and deaths, the number of work-related accidents, and the types of work-related accidents. The thrust of information collection in government and academia has to been aggregate data. There is a conspicuous dearth of prescriptive information about how to mitigate the situations that lead to high worker accident rates. Businesses have long relied on case studies to provide models for transformative practices. This research is based on the notion that catering companies located in Hong Kong can effectively benefit from the review of case studies that illustrate and delineate effective safety programs.

The continued capacity of the restaurant business in Hong Kong as a substantive source of jobs is dependent on the ability of the industry to correct its unsafe operations. This research is intended to illuminate strategies that can be utilized by Hong Kong catering businesses to manifest these safety goals through important transformations. This study is designed to identify causal factors in the occupational accidents occurring in the workplaces of catering companies, and to identify approaches and methods used in companies located overseas where catering companies have lowered their accident rates.

Chapter 2 - Literature Review

This chapter presents a review of the literature on occupational safety and health in the catering industry, and compares the causality and incidences of work-related accidents in the Hong Kong catering business with those in the food and beverage industry overseas. Several issues relating to differences in the data sets, reporting formats, and substantive differences in resource availability and enforcement of regulations across the cases are also discussed.

Occupational safety and health data from Hong Kong. A partnership program of the Occupational Health and Safety Counsel (OSHC), the Green Cross Group offers research outcomes, benchmark studies, and training programs in the area of safety and health management ("OSHC," 2012). The OSHC is a statutory body for promoting workplace health and safety and to safeguard and sustain the Hong Kong workforce ("OSHC," 2012). OSHC facilitates networking for the purpose of benchmarking the safety and health performance of different organizations with the best performers in their industries ("OSHC," 2012). A primary purpose of the benchmarking initiative is the identification of variables that are associated with best practices in order to create models and make recommendations for peak performance in safety and health management ("OSHC," 2012). OSHC provides a lending library and creates local networking events and meetings of participating organizations to create common interest groups by organization or functional process ("OSHC," 2012). Moreover, through the OSHC, safety training is made available to organizations in order to explore the application of benchmarking and quality improvement initiatives ("OSHC," 2012). This effort is strengthened by conducting local and international study missions, workshops, and symposia with the idea that the shared experiences will lead to deeper insights into best practices implementation ("OSHC," 2012).

Green Cross research has established that the workplace injuries that occur in the catering business in Hong Kong tend to be less severe on the whole than injuries that occur in the construction industry ("OSHC," 2012). However, on an absolute basis, the number of injuries in the catering business exceeds the number of injuries in the construction industry ("OSHC," 2012). In 2004, Green Cross conducted an investigation through surveys research on the number and root causes of industrial accidents ("OSHC," 2012). Of the 5,827 accidents that occurred in the catering business accounted for roughly half of the total industrial accidents. Interestingly, the number of accidents occurring in the construction trade from 1999 to 2003 fell steadily from approximately 14,000 accidents to about 4,000 accidents, or roughly one third of the 1999 rate ("OSHC," 2012). In contrast, the number of accidents occurring in the catering industry was approximately 12,500 in 1999 and fell to 5,827 in 2003, or roughly just under one half of the 1999 rate ("OSHC," 2012). Moreover, the number of accidents that have occurred in the catering industry from was consistently higher than the number of accidents in the construction industry, and the difference between the two industries was substantial for the years 2001, 2002, and 2003 ("OSHC," 2012). In summary, each of the major industries that are associated with high occupational rates has experienced a substantive drop in those rates, but the catering industry continues to have the highest rates ("OSHC," 2012).

The Labour Department has established a comprehensive database about work-related issues, including the accidents that occur in the catering industry ("OSHC," 2012). Approximately two-thirds of the worker injuries that occur in catering occupations are caused by the use of hand tools, contact with hot substances or hot surfaces, and some type of fall, including slipping and tripping ("OSHC," 2012). Following these most common sources of injuries, are accidents from striking some fixed or stationary object, lifting and carrying injuries, and contact with some moving object including moving machinery or objects being machines ("OSHC," 2012). Catering workers also sustain injury by being trapped between objects and from falling objects. In addition, some workers are exposed to or contact a harmful substance or are hurt by animals in the course of their catering work ("OSHC," 2012).

The order in which these accidents are listed here roughly corresponds with the accident incidence rate by type in the catering industry from year-to-year. Specifically, Labour Department statistics show the overall number of accidents in 2001 was 10,149 and that the accident rate per 1,000 employees was 54.7% ("OSHC," 2012). Of the 49,649 cases of employee compensation reported in 2002, 21% or 10,484 were from the catering industry ("OSHC," 2012). Moreover, in 2003, 47,376 injury cases resulted in employees taking sick leave for three days or more, with 10,358 or 22% of that number from the catering industry ("OSHC," 2012). Injured employees and their families received approximately $61 million in compensation, a figure that represents 7.7% of the total amount of compensation ($804 million) paid in 2003 for employee related accidents ("OSHC," 2012). Approximately 160,000 workdays were lost as a result of workplace injuries in 2003, the total cost of which was more $1.2 million ("OSHC," 2012). From a brief review of these figures, it is apparent that financial costs and profitability strongly motive attention to workplace safety at the corporate level ("OSHC," 2012). Moreover, it is important to note that although workplace accident rates have gone down over the decade or so, certain types of accidents are more likely than others in particular industries ("OSHC," 2012). In the catering industry, those high-risk situations are readily apparent from historical data and from any time-series data obtained by taking "snapshots" of the industry over time.

In 2001, the OSHC conducted a survey regarding the conditions of kitchen workers in Chinese restaurants (Kuen, 2005). A total of 471 kitchen workers, including chefs, cooks, assistant cooks, grill cooks, dim sum cooks, and material preparation cooks, from 159 different Chinese restaurants participated in the survey (Kuen, 2005). Of the kitchen workers surveyed, 80% were injured on the job and more than 60% took sick leave due to accidents at work (Kuen, 2005). The work-related injuries included cuts, burns, musculoskeletal problems, and stab wound from shrimp or fish (Kuen, 2005). Health problems of kitchen workers were predominantly gastrointestinal disorders and headaches (Kuen, 2005).

The Occupational Safety and Health Council (OSHC) conducted a similar survey, also in 2001, with a total of 388 participants who were exclusively floor staff -- those not working directly in the kitchen areas -- in 69 Chinese restaurants (Kuen, 2005). The floor staff included receptionists, waiters and waitresses, head waiters and head waitresses, food servers, dim-sum servers, stewards, managers, supervisors, and even a few workers performing menial services such as clearing tables (Kuen, 2005). OSHC was particularly interested in how the hectic environments of the Chinese restaurants might be impacting the stress levels of the floor workers (Kuen, 2005). So, in addition to physical problems caused by work-related injuries, OSHC was inquiring about mental health problems or sufficiently high stress levels that could leave floor staff vulnerable to workplace injury (Kuen, 2005).

Occupational health and safety data in the United States. The North American Industry Classification System (NAICS) code 445 represents Food and Beverage Stores of the Retail Trade Sector (44-45). The following definition applies:

"Industries in the Food and Beverage Stores subsector usually retail food and beverage merchandise from fixed point-of-sale locations. Establishments in this subsector have special equipment (e.g., freezers, refrigerated display cases, refrigerators) for displaying food and beverage goods. They have staff trained in the processing of food products to guarantee the proper storage and sanitary conditions required by regulatory authority." (NAICS, 2012).

In the United States, the Bureau of Labor Statistics annually compiles, analyzes and reports the number and frequency of work-related fatal injuries and nonfatal injuries and illnesses ("Bureau of Labor Statistics," 2012). The Bureau of Labor Statistics also provides detailed data about the characteristics of injured or killed workers and about the circumstances surrounding workplace injuries and illnesses ("Bureau of Labor Statistics," 2012). The Census of Fatal Occupational Injuries (CFOI) and the Survey of Occupational Injuries and Illnesses (SOII) provide the data for the reports generated by the Bureau of Labor Statistics ("Bureau of Labor Statistics," 2012). The Bureau administers the CFOI, and in conjunction with the 50 States, the District of Columbia, and New York City, compiles data on all work-related fatal injuries occurring in the United States ("Bureau of Labor Statistics," 2012). The CFOI uses diverse sources to identify, verify, and profile fatal work injuries in order to create complete and detailed data sets. Source documents come from many source and are cross-referenced to gather key information about each workplace fatality ("Bureau of Labor Statistics," 2012). Data sourced include Federal and State agency administrative records, workers' compensation reports, death certificates, and news accounts ("Bureau of Labor Statistics," 2012),

The 2011 Bureau of Labor Statistics of the Department of Labor shows nonfatal occupational injuries and illnesses of food and beverage stores, as follows: (a) Number of people employed = $2,859.7 (in thousands); (b) 4.7 incidents per 100 full-time workers; and, (c) 2.7 cases per 100 lost work time, were put on restricted work time, or were transferred to other jobs due to the nature of their injuries ("Bureau of Labor Statistics," 2012). The significance of data reports such as those from the Bureau of Labor Statistics and its international corollary is that the food and beverage industry growth rate is expected to continue in its current upward trend ("Bureau of Labor Statistics," 2012). This, of course, means that a corresponding increase in employment of food and beverage workers will be seen as well. In Hong Kong, much of the growth will be seen in the catering businesses many of which are associated with retail restaurants and other food establishments. The economic environment suggests that continued growth in the food and beverage industry, which includes catering businesses, will continue to be a focus of attention for those industries and governmental agencies with responsibly for the health and safety of the women and men who make their living in the industry (Martinez, 2011). In 2008 alone, an approximate total of 6,299,930 food and beverage serving workers (servers) were employed in the United States; should the current growth rate continue, this number will increase by roughly 10% by the year 2018 (Martinez, 2011). A variety of positions are subsumed within the category of food and beverage servers. For the food an beverage industry in the United States during the year 2008, the breakdown by job position was approximately as follows: 2,371, 750 waiters and waitresses, 2,708,840 combined serving and food preparation workers, 527,530 counter attendants, 503,420 bartenders, and 188,390 non-restaurant food servers (Martinez, 2011).

Jobs of all types in the food and beverage industry, perhaps with the exception of managerial and administrative positions, attract young workers, many of whom are still teenagers or in their twenties, who have no previous work experience and no actual job experience in the industry (Martinez, 2011). The nature of food and beverage industry jobs across the globe exposes workers to substantive hazards that are not shared by other categories of workers. Only very recently has national data on nonfatal injuries and illnesses been calculated on the basis of the total number of hour worked rather than just on the number of days worked ("Bureau of Labor Statistics," 2012). A more accurate representation of the inherent job-related risk is provided when the number of hours is considered in the analysis ("Bureau of Labor Statistics," 2012).

Food and beverage industry employees often work long shifts, typically spanning lunch and dinner service, and are frequently on their feet (Martinez, 2011). These two variables alone can contribute to fatigue and a corresponding mental impairment and physical slowness that set the workers up to have accidents (Martinez, 2011). Add to that a mix of duties that include carrying heavy trays and containers of hot food, breakable dishes and glassware, sharp utensils, and slippery floor surfaces (Martinez, 2011). Given this volatile mix, it is not surprising that over the six years from 2003 to 2008, the number of fatalities for food and beverage workers reached 141 (Martinez, 2011). In addition, in 2008 alone, there were 26,870 nonfatal injuries and illnesses -- all of which caused days lost from work -- to employees who worked as food and beverage servers in the private sector (Martinez, 2011). This number was down 29% from the 37,860 nonfatal injuries to food and beverage servers that were reported in 2003 (Martinez, 2011). In order to gain perspective, it is useful to know that for all other occupations combined in 2008, there were 1,078,140 nonfatal injuries and illnesses -- a figure that has decreased 18% from the 1,315,920 incidences that were recorded in 2003 (Martinez, 2011). The correspondence is particularly noteworthy for nonfatal occupational injuries and illnesses that required time off from work for food and beverage servers. In 2008, roughly 70.6 such cases occurred for every 10,000 fulltime food and beverage workers, while the corresponding figure was 113.3 for full-time workers from all other occupations combined (Martinez, 2011).

When examining the figures related to workplace injuries, it is important to distinguish between injuries that result from accidents and injuries that result from workplace violence (Martinez, 2011). Importantly, most fatal injuries to food and beverage workers are the result of homicides that are associated with the occurrence of crimes, intention to commit crimes, and interpersonal disputes that occur in the workplace (Martinez, 2011). In comparison, most nonfatal injuries and illnesses in food and beverage workers are the result of some accident that took place during their regular performance of their job duties (Martinez, 2011). Accidental events typically associated with nonfatal injuries and illnesses in food and beverage workers include contact with dangerous equipment or substances, slipping or falling, and overexertion resulting in strains or collapse (Martinez, 2011).

There is considerable merit in disaggregation analysis that enables researchers to examine relationships between various aspects of injuries, such as the parts of the body injured, the source or sources of the injury, the nature of the accidental event or exposure (Martinez, 2011). In the case of injuries to food and beverage workers, this is a particularly important measure since raw numbers do not provide a complete picture of how accidents and injuries happen. Research has shown that the interactions among the variables are often important and that food and beverage workers incur injuries as a result of accidents that are unique to the workplace hazards (Martinez, 2011). The pace of work in the food and beverage industry is typically very fast. Using 2008 as a unit of analysis, the most prevalent types of injury for food and beverage workers were: (a) Sprains and strains, and (b) cuts and lacerations (Martinez, 2011). Unpacking the variables associated with these two types of nonfatal injuries can help inform policies and practices associated with increasing workplace safety. In 2008, 1,910 food and beverage servers experienced injuries that resulted in sprains or strains as a result of overexertion, where the trunk was the injured body part and the source was containers (Martinez, 2011). Of this total, 1,440 injuries were the result of overexertion in lifting (Martinez, 2011). This type of event in which a food and beverage worker tries to lift a heavy container and strains some part of the trunk region of their body is a typical nonfatal injury for workers in this industry (Martinez, 2011). Another typical injury type common to food and beverage workers occurs when they accidently cut themselves while using or handling sharp or dangerous utensils such as knives or slicers (Martinez, 2011). In the example year 2008, 1,090 workers incurred cuts or lacerations where the finger or fingernail was the body part injured when using knives where the handheld object they were slicing or cutting slipped or the cutting implement slipped (Martinez, 2011). Cuts to fingers and fingernails by knives are common injury to food and beverage workers, but are less common among other occupations (Martinez, 2011).

Research purpose. On objective of this research is to identify effective strategies for addressing the high incidence rate of workplace accidents in the catering industry. Substantive differences can be found the policies and practices of for occupational safety and health from country to country. For the sake of comparison, it is useful to ensure that the accident rates in the industries under examination are expressed in equivalent units. The Labour Department of Hong Kong Special Administrative Region (HKSAR) of the People's Republic of China reports accidents in occurrences per 1000 workers. In the United States, for instance, workplace accidents are reported per 100 workers. Moreover, the industry reporting definitions used by governmental departments in nations differ as well. In Hong Kong, the unit of analysis is the catering industry. In the United States, for example, the unit of analysis is the food and beverage industry. It is important to note that these distinctions can impact the figures reported sufficiently to make comparisons challenging. That said, the different rates are so substantial that segmenting the food and beverage designation, say, to create a discrete catering business segment would enhance the distinction rather than diminish it.

Occupational health and safety data in the United Kingdom. The IOSH is the chartered agency for health and safety professionals ("IOSH," 2012). Members number approximately 40,000 across 85 countries, making IOSH the world's largest professional health and safety organization ("IOSH," 2012). The goals of the IOSH include standards setting, support and development activities for members, the provision of resources, training, guidance, and events relevant to the member industries and lobbying on issues that impact millions of workers ("IOSH," 2012). IOSH is a registered charity with international NGO status ("IOSH," 2012).

Beginning in September 2012, an annual survey is being conducted in the UK that will take a close look at accidents in the food and drink industry ("IOSH," 2012). Key organizations who are passionate about worker safety, and who have close relationships with their members, will provide input into the survey ("IOSH," 2012). Businesses will also be asked to respond to the survey anonymously in order to provide a more honest reflection of health and safety circumstances in the food and drink industry ("IOSH," 2012). With a year-over-year reporting, the survey is expected to reveal detailed and comprehensive data on the performance of health and safety management in the food and beverage industry ("IOSH," 2012). The first set of data is in and it shows the following: 45 companies employing nearly 70,000 persons -- which is about 14% of the total food and beverage workforce -- reported two deaths, 137 major injuries from accidents, and 808 injuries that required over-three days of lost work ("IOSH," 2012).

The project is a joint project of the Institution of Occupational Safety and Health (IOSH), Food and Drink Group, Food and Drink Federation, and Dairy UK. A primary objective is to develop an annual health and safety benchmarking survey ("IOSH," 2012). According to the IOSH Food and Drink Group,

"The true picture of work-related injuries and ill-health across UK industry is hard to capture because reporting can be quite inaccurate. We only have very limited information on accidents in food and drink. We wanted to develop a reporting survey that gives us a fuller picture over the years, including a clearer view of ill-health -- of which there are thousands of incidents costing millions of pounds annually." ("IOSH," 2012)

The problem of collecting accurate data that can be meaningfully aggregated is common to each of the countries represented in this study. Moreover, even when data is collected from businesses, there is a strong disincentive for the companies to misrepresent the data to official agencies. A strong recommendation from the research is to require companies to report information anonymously when surveys will aggregate data and the purpose of the data collection is not to follow-up for purposes of remediation or fines.

Chapter 3 - Methodology

This research is a descriptive qualitative study that is grounded in phenomenology (Glasser & Strauss, 1967). A phenomenological philosophy is founded on the belief that textual resources provide a source of knowledge for research (Glasser & Strauss, 1967; Lincoln & Guba, 1985). The researcher will employ archival document review as a secondary source of qualitative data. To that end, this researcher will provide an "explicit account of how and why the different methods and data complement each other" (Denscombe, 2007). Specifically, the study adopts qualitative approaches including review of documents and journal articles. The cases reviewed provide a closer look at how improvements in occupational accident rates are accomplished in different locations with contrasting developmental trajectories. A discussion of the research approach, research design, data collection and data analysis procedures follows.

Qualitative research using grounded theory. Grounded theory is based on the assumption that patterns and themes that emerge from an exploration and analysis of the extant data. Since the research is qualitative, it will not engage in formal hypothesis testing (Glasser & Strauss, 1967). A qualitative researcher does not look for particular themes so much as anticipate that themes will emerge (Glasser & Strauss, 1967). A researcher using a grounded theory approach lets the data "speak" through an iterative process of constant comparison of the data (Dye, et al., 2000). Through these qualitative research techniques, patterns emerge from the data. At this point, the researcher applies his or her expert knowledge of the topic and -- with an open mind -- analyzes the patterns that have emerged while watching for any apparent coalescing of themes (Glasser & Strauss, 1967; Lincoln & Guba, 1985). The components of grounded theory are as follows: Collection of raw data, data reduction and analysis, data reconstruction and synthesis, process notes, expressions of intention and disposition, instrument development (Lincoln & Guba, 1967).

Document review and textual analysis. Textual analysis of documents involves the exploration of the nexus between the researcher's frame of reference and the producers of the document text. According to Scott (1990),

"The aim of this dialogue is to move within the 'hermeneutic circle' in which we comprehend a text by understanding that frame of reference from which it was produced, and appreciate that frame of reference by understanding the text. The researcher's frame of reference becomes the spring board from which the circle is entered, and so the circle reaches back to encompass the dialogue between the researcher and the text."

(Scott, 2002, p. 110)

Further, the validity of documents was verified using four criteria suggested by Platt (1981) and Scott (1990) for evaluation of the research utility of documents. These fundamentally self-explanatory criteria are: Authenticity, credibility, representativeness, and meaning. Similar criteria apply to the evaluation of the internet websites and webpages used in the qualitative research methodology of this study. Since anyone can post information to the Internet, issues of credibility and authenticity are paramount. Not only must the researcher subject sources found on the Internet to his or her own personal and professional quality audit -- that is his or her personal judgment that the sources exhibit trustworthiness -- but determinations must be made on the basis of the "authoritativeness, trustworthiness, up-to-date status, and popularity of the site" (Denscombe, 2007, p. 243). Note that a detailed discussion of the nature and trustworthiness of document review as a viable research process is discussed in the section on research limitations.

Model cases for improvement of occupational accident rates. Theoretically, researchers assert that employers and the government can avoid the high cost of workplace injuries by increasing worker knowledge about safety in the workplace, and enhancing implementation of occupational health and safety programs

Europe. The International Labour Office in Geneva Switzerland established a program for dealing with major workplace hazards ("International Labour Office," 1991). The model program consists of the following elements: (a) Establishment of a Group of Experts, (b) on-site emergency planning, (c) off-site emergency planning, (d)siting and land-use planning, (e) training of government inspectors, (f) preparation of check-lists, (g) inspection of installations by government inspectors, (h) inspection of installations by specialists, and (i) actions following the evaluation of safety reports ("International Labour Office," 1991). The elements in this program are common to governmental agencies like OSHA and OHSC. However, the element that is most innovative and relevant to the food and beverage industry is the Group of Experts. This element involves an ad hoc group of experts from each of the major areas of the industry that have relevance to issues of health and safety ("International Labour Office," 1991).

Canada and the United States. Although the practices of Starbucks safety practices and policies are not limited to North America, they are well-established there. The approach is all-inclusive and includes exacting training of all staff. Once each and every shift, a different employee does an on-site survey of the store, following an established checklist and noting any problems on a report form that is immediately submitted to the store manager. This insures that the report is always up-to-date, that immediate action can be taken by management and staff collectively, and that a running compilation of the problems and the resolutions is recorded as a resource for future training and the development of safety standards.

Australia. The National Research Centre for Occupational Health and Safety Regulation (NCOHSR) in Australia is focused on the development of excellence in health and safety practices and regulation (Wood, et al., 2010). The Centre conducts deep empirical and policy-focused research in occupational health and safety regulation (Wood, et al., 2010). The primary audience of the Centre's research is government agencies charged with reform initiatives in work health and safety legislation, inspection procedures and practices, and policy regulation (Wood, et al., 2010). The Centre's fundamental goal is to ensure the efficacy of regulation directed at improving health and safety outcome in Australian workplaces (Wood, et al., 2010). Currently, the Centre receives funding from WorkCover New South Wales, WorkSafe Victoria, and Workplace Health and Safety of Queensland (Wood, et al., 2010). The Centre's work with these agencies is directed at the monitoring and production of periodic white papers on occupational health and safety regulation and research, and the support of a series of working paper publications (Wood, et al., 2010). The Australian Research Council and Safe Work Australia also work with the Centre to conduct research on regulatory compliance in health and safety regulation (Wood, et al., 2010).

Australia employs responsive regulation practices that are based on the belief that regulators should function in a manner that is responsive to the culture, context, and conduct of the people they seek to regulate when determining the level of intervention needed (Wood, et al., 2010). The tagline for this approach is "soft words before hard words, and carrots before sticks" (Wood, et al., 2010). Moreover, the approach is grounded in practicality, context appropriate, and an appreciation of diversity (Wood, et al., 2010).

The model that resulted from the responsive regulations beliefs was developed by Braithwaite and Ayres in their book Responsive Regulation: Transcending the Deregulation Debate (Wood, et al., 2010). However, the development of responsive regulation continues to be a collective effort of numerous scholars and institutions (Wood, et al., 2010). The fundamental principles of responsive regulation are illustrated in the form of a one-dimensional pyramid that is widely recognized as the regulatory pyramid (Wood, et al., 2010). The base layer of the pyramid is labeled advisory and persuasive measures (Wood, et al., 2010). The next layer up is labeled mild administrative sanctions (Wood, et al., 2010). The top layers represent more punitive sanctions that are believed to be sufficiently undesirable or aversive to "halt the behaviors of the most determined offenders" (Wood, et al., 2010). The premise of the responsive regulation approach is that activity should primarily be at levels represented at the bottom of the pyramid and escalate only if and when less intrusive measures have been ineffective, and that de-escalation should always remain a top-of-mind option (Wood, et al., 2010). Importantly, the "presumptive preference" for acting at the bottom of the pyramid is countered by the "credible enforcement peak," which in essence means that follow-up enforcement must take place if the model is to be effective (Wood, et al., 2010).

An interesting addition to the OSHC website presents information about the Catering Industry Safety Award Scheme (2012/2013), in which a list of winners of the Word Search Puzzles Competition is presented ("OSHC," 2012). The competition occurred in late October of 2012, so it is entirely timely ("OSHC," 2012). While this is a charming activity that doubtless draws the attention of a limited number of workers to occupational safety, an overall large-scale impact is doubtful. Moreover, there is not indication that the effectiveness of this campaign is being measured in any meaningful way.

Chapter 4 - Data Analysis and Findings

A constant comparison method will be used to code and analyze the data in order to identify emerging themes (Dye, et al., 2000). Extant data and documents will be analyzed through textual analysis and will employ a constant comparison method Glaser and Strauss (cited in Lincoln and Guba, 1985, p. 339) describe the constant comparison method as a four-stage procedure. The four stages are as follows: (1) comparing data that is applicable to each category, as the categories emerge; (2) integrating the categories and their properties to reduce the data set and data noise; (3) further delimiting the theory based on reduced data set; and (4) writing the theory. The constant comparison method allows the social phenomenon to be at once recorded, categorized, and compared across several categories (Goetz & LeCompte, 1981). Relationships among the data were identified, and since coding is integral to the data collection and data analysis, themes were being continually built. "As events are constantly compared with previous events, new topological dimension, as well as new relationships, may be discovered" Goetz and LeCompte (1981, p. 58).