Safety is considered paramount in the offshore wind industry; however, individuals break the rules that were created and are implemented to protect them. The present study has four objectives: to find how the work environment affects the implementation of the Wind Turbine Safety Rules, to find deficiencies on the application of the Wind Safety Rules (WTSR), to study relations between technician’s backgrounds and how they perceive the rules. Furthermore to probe to which extent the difference between customer staff, manufacturer staff and contractors may affect their attitude towards the rules.

To achieve this, sixty-one individuals from three different organisations, that are trained on or working under the WTSR were sent an online survey; of which thirty-five individuals completed the survey. The results indicate that work environment does severally affect the implementation of the rules and can be a catalyst for rule violation. Several shortcomings of the implementation of the WTSR identified, and that can be related to management responsibilities. There are some differences between manufacturer and customer staff views regarding safety. The analysis of relations between technician’s backgrounds, roles, education or skillset demonstrated that even though technicians believe that the WTSR exist to protect them, they also believe they are used to protected companies from prosecution.

The same analysis indicates that the role does not influence the way technicians see the rules but affects the way others exert pressure on them, with Authorising Engineers (AE) followed by Authorised Technicians (AT) as feeling most pressured to break the rules. This study lays the foundation for further studies on this topic and provides recommendations to mitigate rule violations in the offshore wind industry.

Extracto

Wind Turbine Safety Rules: A study on rule violation in the offshore wind industry in the UK

Acknowledgements

Abstract

List of tables and figures

Introduction

Literature Review

Research Methodology

Findings, Discussion and Analysis

Conclusions

Reference List

Bibliography

Annexes

Acknowledgements

I would first like to thank my supervisor Mr. Jim Schofield for his guidance and support formulating the research methodology and providing feedback on my drafts.

I would like to acknowledge all the participants in this study, those who authorised it, as well as those that contributed with their time and input.

Lastly, I would like to thank my partner for many hours of herculean strength taking care of our baby son and myself, while pushing me to finish this dissertation.

Abstract

Safety is considered paramount in the offshore wind industry; however, individuals break the rules that were created and are implemented to protect them. The present study has four objectives: to find how the work environment affects the implementation of the Wind Turbine Safety Rules, to find deficiencies on the application of the Wind Safety Rules (WTSR), to study relations between technician’s backgrounds and how they perceive the rules and to probe to which extent the difference between customer staff, manufacturer staff and contractors may affect their attitude towards the rules. To achieve this, sixty-one individuals from three different organisations, that are trained on or working under the WTSR were sent an online survey; of which thirty-five individuals completed the survey. The results indicate that work environment does severally affect the implementation of the rules and can be a catalyst for rule violation. Several shortcomings of the implementation of the WTSR identified, and that can be related to management responsibilities. There are some differences between manufacturer and customer staff views regarding safety. The analysis of relations between technician’s backgrounds, roles, education or skillset demonstrated that even though technicians believe that the WTSR exist to protect them, they also believe they are used to protected companies from prosecution. The same analysis indicates that the role does not influence the way technicians see the rules but affects the way others exert pressure on them, with Authorising Engineers (AE) followed by Authorised Technicians (AT) as feeling most pressured to break the rules. This study lays the foundation for further studies on this topic and provides recommendations to mitigate rule violations in the offshore wind industry.

List of tables and figures

Table 1 - Participants age

Table 2 - Professional background

Table 3 - Role

Table 4 - Role Statistics

Table 5 - Crosstabulation: Role & WTSR

Table 6 - Crosstabulation: Role & WTSR

Table 7 - Crosstabulation: Employer & WTSR

Table 8 - Crosstabulation: Employer & WTSR

Table 9 - Crosstabulation: Education & WTSR

Table 10 - Crosstabulation: Education & WTSR

Table 11 - Crosstabulation: Education & Safety

Table 12 - Crosstabulation: Employer & Safety

Table 13 - Crosstabulation: Role & Safety

Table 14 - Crosstabulation: Role & Reasons

Table 15 - Crosstabulation: Employer & Reasons

Table 16 - Crosstabulation: Education & Reasons

Table 17 - Crosstabulation: Education, Employer, Role and Skillset

Table 18 - Crosstabulation: Role & Skillset

Table 19 - Crosstabulation: Role & Rule improvement

Table 20 - Crosstabulation: Role & Safety through experience

Figure 1 - Questionnaire respondents

Figure 2 - Age distribution

Figure 3 - Sex

Figure 4 - Employer

Figure 5 - Level of education

Figure 6 - Skillset distribution

Introduction

This study is the culmination of the bachelor’s degree in Engineering Management at the University of Lincoln. The subject choice is motivated by the inexistence of scientific study related to the Wind Turbine Safety Rules.

The Wind Turbine Safety Rules (WTSR) were first approved in 2013, but its first steps were given back in 2006. They are a product of combined effort and expertise from wind turbine manufacturers as well as wind farm operators, developers and owners. It established an all-purpose set of safety rules covering all aspects of safety from the system. The system, in this case, is a Wind Turbine Generator (WTG) and the rules cover only inherent dangers of the WTG, such as electrical hazards, chemical hazards, stored energy, etc. as opposed to environmental dangers.

In order to establish the rules on a company there is a WTSR structure that has on top an Authorising Officer (AO), often described on the WTSR (RenewableUK, 2015) book as an appropriate officer, its responsibilities are broad, but the main is auditing the application of the rules, personally assess, test and authorise Authorising Engineers (AE) and Authorised Technicians (AT), arbitrate any questioning of the rules and unilaterally revoke any authorisation from AE’s or AT’s. The AE’s are the level below the AO, while the AO is a highly administrative role the AE is the highest technical role under the WTSR.

The AE is responsible for the writing, reviewing and approving Authorised Written Procedures, meaning that all safety measures that can be foreseen to be necessary during any tasks are decided by the AE (RenewableUK, 2015).

The AT is a technician that is authorised after being assessed and tested, to independently lead its own team, carry out work under the possession of an Authorised Written Procedure (RenewableUK, 2015). Under such document, the AT is not allowed to deviate from its strict instructions under any condition, unless under exceptional circumstances and direct order from an AE in a procedure called General Provision 3 - Special Instructions, generally referred to as GP3 on the WTSR (RenewableUK, 2015). These teams led by AT’s are normally composed of Competent Technicians (CT) or contractors that are not nominated or authorised under the rules. A CT sits at the bottom of the responsibility pyramid on the WTSR (RenewableUK, 2015). Under the rules, a CT will only lead a work party in very limited tasks with strict restrictions on work that can be performed under a Routine Operational Procedure (ROP). This ROP is also written, reviewed and approved by an AE (RenewableUK, 2015).

The world has changed a lot since 2006, especially with regards to the wind turbine industry, according to WindEurope (2019), several known brands are now investing heavily in this industry: BMW, General Motors, Nissan, Honda, BP, Shell, Lego, IKEA, Facebook, Google, Amazon.

This industry in the United Kingdom has seen exponential growth since the first offshore wind farm was installed in the Liverpool bay in 2004, from 900Mw to 20680Mw (RenewableUK, 2019).

This research aims at four fundamental points:

- Identify how the work environment affects the implementation of the rules
- Identify the shortcomings of the implementation of the rules
- Study the relationship between the technician’s backgrounds and how they perceive the rules
- Study to which extent the difference in culture or training between customer staff, manufacturer staff and contractors affect their attitude towards the rules

To achieve this a site in the United Kingdom (UK) was studied, with participation from all intervenient entities: manufactures, owners and contractors, location and identities cannot be shared due to confidentiality agreements.

As no previous study of the Wind Turbine Safety Rules has been done, this study compares the results of the information gathered with the results obtained in other domains of the rule-breaking literature. Such comparison is made mainly with the offshore oil and gas industry due to the similarities between both industries, they both are at remote sea locations, they both are heavily technical trades, and they both use Permit to Work (PTW) systems.

An Authorised Written Procedure (AWP) is by definition a PTW since it’s an official written scheme for works considered hazardous (Iliffe et al., 1999). This system has limitations, specifically human factors (Iliffe et al., 1999). Even though people have a habit of following rules (Cialdini and Goldstein, 2004), people will sometimes break the rules.

The reasons for rule breaking and safety have been widely studied in several fields such as offshore oil and gas (Chan, 2011; Mathisen and Bergh, 2016; Mearns et al., 2001), railway industry (Stiles et al., 2018), civil engineering (Wu et al., 2016) and nuclear power stations (Martínez-Córcoles et al., 2011). In the offshore wind industry, this study had not been done before. Therefore, a study using an online survey on a dedicated Qualtrics cloud base server was specifically created and sent to the pre-aligned participants.

The online survey was the most suitable platform to gather information in a short amount of time from many participants with very different schedules. Its significant advantage was that it was possible to incorporate Saunders et al. (2012) research onion process and Sue and Ritter (2012) online survey construction techniques to tailor the structure and questions to maximise the information gathered while minimising the time it took to complete the survey. The objective of this study is to establish the first reflexions on a topic unexplored before, by studying an offshore wind farm and their staff, with more focus on their offshore staff.

Literature Review

This literature review aims to report the many concepts that are contained within the research on safety rule application in the wind industry. It will review the WTSR concept, the WTSR evolution, and its main benefits.

The WTSR (RenewableUK, 2015) are composed of several documents namely Authorised Written Procedures (AWP’s), Method Statements (MS) and Risk Assessments (RA). The AWP’s are a legal requirement and a document that describes a step by step procedure to establish safety from the system, the system being any electro-mechanical plant or apparatus to be worked on or at.

Most health and safety entities such as the Institution of Occupational Safety and Health (IOSH) refer to a process called hierarchy of control pyramid (IOSH, 2017) when trying to achieve safety from the system. The WTSR cross the three levels of the pyramid, from Isolate level, the Engineer controls level and the level of the Administrative controls.

The Isolate level promotes the separation of the hazard and the people at risk from injury. The Engineer controls can be exemplified by the addition of safeguard mechanisms. Instructions for both levels are found on the AWP’s and MS for any job under the WTSR. The Administrative controls are effectively; in this case, the rules themselves because they alter the way people work (NIOSH, 2015). Administrative controls are widely used and recommended as they tend to be inexpensive and they are the easiest and fastest way to counter poor safety habits and procedures (Balasubramanian and Louvar, 2002).

There are no previous studies on the wind industry regarding the topic of rule violation, specifically the WTSR; therefore, it is necessary to establish a parallel with studies from other topics and from other industries, to be able to build a framework in which conclusions can be drawn.

The obvious parallel is the Offshore Oil and Gas industry. Such industry appears to have been a safety driver since the Piper Alpha incident in the North Sea killed 167 people, and Lord Cullen (1990) wrote his conclusions and recommendations regarding it. From those recommendations, number 32 to 38 were adopted across all major Distribution Network Operators (DNO) as part of their electro-mechanical safety rules. Thus, the WTSR (RenewableUK, 2015) also reflect those recommendations in its genesis.

These recommendations outlined the omissions, ambiguity and lack of structure the rules had; however, recommendations 33 and 35 also brought a responsibility onus to those in charge of work parties and those taking part in the work to be competent in their tasks.

Even though these recommendations were implemented in the wind industry, there are still shortcomings not only on the rules but mostly on its implementation, seemingly leading to catastrophic accidents. According to Conca (2013) in the wind industry, there are 1000 deaths per 15 trillion kilowatt hours.

In addition, the CIWF accident report from 2018 compiled information on recorded accidents in the industry since before 2000 up to 31st December 2018, it shows there have been 2372 accidents, 139 of those were fatal accidents, with 186 fatalities (CIWF, 2018). It could be argued that the report and its sources are not accurate since reports appear not to be filled depending on the nature of the accident, the country where it occurred and the ethics of the company responsible for the report, meaning that many accidents may not be reported at all. This difficulty in finding information lead Asian et al. (2017) to do a data mining study, their conclusions are supportive of the idea that accidents on WTG’s during maintenance are mostly resultant of human error.

In January 2018 two technicians died in Scotland while stranded by the weather, Unions were quick to ask for Health and Safety Executive (HSE) to act (Bark, 2018), but in reality, the safety provisions and guidelines were established by Health and Safety act (1974) and the WTSR (RenewableUK, 2015) thus, there was clearly a shortcoming on the implementation of the rules by the company in charge of the work.

Humans are predisposed to follow the rules (Cialdini and Goldstein, 2004), so any deviation of this pattern comes with cognitive struggle to the rule offenders (Pfister et al., 2016). One of the authors studying the rule-breaking phenomenon was Chan (2011) that set out to establish the top ten causes for accidents in the oil and gas industry; even though fatigue was cause number one, number two is more relevant for this research, and it was violation of safety procedures. Rule-breaking can be defined as a deliberate violation of a company procedure, rule or ban (Morrison, 2006).

The study will attempt to understand the reasons for this rule-breaking, if the reasons lie with a work environment that pressures for production, the perception that rules are not in place to protect people but to protect the businesses from lawsuits, or simply the belief that their knowledge and experience outweighs the need for the application of the rules.

Mearns et al. (2001) studied human behaviour and attitude as indicators of safety in the UK offshore Oil and Gas industry. Their objective was to ascertain if the way the offshore workers feel, act on and see safety are reliable gauges to unsafe behaviour and the reasons lying behind it.

Mearns et al. (2001) findings further reinforced the results from the previous studies such as Hofmann and Stetzer (1996), Lawton (1998) and Lawton and Parker (1998). The study reiterates previous conclusions that unsafe behaviour and pressure for production are the root cause of rule breaking in that specific context and that consequently lead to accidents. However, Morrison’s (2006) research contradicts some of the previous studies and indicates that rule-breaking was a form of improving service, improving efficiency or a form of helping colleagues; consequently, it is necessary to determine which view do the technicians have. This is therefore significant to cross reference the wind industry and identify if like the oil and gas industry the work environment is directly or indirectly influencing and even maybe conditioning the implementation of the safety rules. Sulea et al. (2012) established a clear relationship between work engagement and damaging work behaviours, such as rule breaking.

Mathisen and Bergh (2016), theorised that errors and rule violations in offshore oil rigs were mostly due to phycological factors, such as emotional exhaustion or lack of engagement. However, in their study they did not separate internal and external employees; this might be relevant since in offshore wind there appear to be significant differences between responsibilities and expectations of internal and external parties. Given the broad spectre of none wind native companies investing in wind such as BMW, General Motors, Nissan, Honda, BP, Shell, Lego, IKEA, Facebook, Google and Amazon (WindEurope, 2019) its plausible that the culture of each company will influence the way their employees behave and thus because of this background influence the way they perceive the rules.

Furthermore, both Chan (2011) and Mathisen and Bergh (2016), defend emotional exhaustion and physical exhaustion as a potential catalyst for rule violations.

Tyler and Badler (2005) established a clear difference between following the rules and accepting the rules. Furthermore, their study concluded that rule breaking occurs more frequently when rules are enforced via orders and imposed regulations than when rules are intrinsically accepted and coincident with the employee’s motivations.

This phenomenon was observed during this research since it was possible to see this difference between rule following and rule acceptance.

A completely different approach was taken when studying honesty and rule violation by Rindermann et al. (2018), that associated rule-following to a higher cognitive ability, implying that smart people tend to be honest, but individuals are influenced by an organisation level of honesty. When studying rules and rule-breaking Ting (2018) criticised the previous studies for being rigid and not accounting for people dynamics, and that early decisions may bring different outcomes in the future. This can be understood as an attempt to contextualise rule breaking, but for this research, it is also an indication of the potential differences of rule following and rule acceptance of the customer staff, the manufacturer staff and the third parties such as subcontractors.

Breaking the rules occurs in many different environments and scenarios, Huemer (2018) studied the traffic violations done by cyclists, some of the most vulnerable users of the road network in Germany. She concluded that this behaviour is related to a sense of impunity. Other authors such as Scott-Parker et al. (2009) had also postulated a similar philosophy that rule violation is directly related to the sense of impunity, and that rules are broken after the perpetrators have weighted the reward versus the punishment.

Regardless of the situation, an essential factor to be considered is presented by Kimura and Takeda (2014) is that individuals can be oblivious that they have in fact broke the rules if they do it unknowingly. In that situation, the neurological signals that should be triggered are not, and consequently, there is no moral dissonance, no internal fight between right and wrong. Therefore, this behaviour is mentally logged as previous experience and weakens the moral standard in the time that is faced with similar rule violations.

Iliffe et al. (1999) added an important insight into the PTW systems like the WTSR, by concluding that the paper-based systems were inefficient and recommending in 1999 the implementation of digital systems to improve the performance of the process.

In summary, it is necessary to consider for the study the factors that may cause people to break the rules such as work environment, pressure for production, emotional exhaustion and sense of impunity.

Research Methodology

The Methodology used in this research is an analytical study based on mix-method of quantitative and qualitative research (Creswell and Clark, 2004), surveying staff that have directly been in contact with the rules, either by being trained on them or having to work under them. Quantitative design characteristically defines factors such as sample size, data collection procedures, types of data to be collected, data processing, selection and recruitment techniques and analysis strategies (Sue and Ritter, 2012) . To study people’s feelings towards safety rules it is also necessary to use a qualitative design, especially because no statistical inference is to be made (Walliman and Baiche, 2000). To conduct this research, the design was planned using Saunders et al. (2012) research onion process.

The research objectives are:

- To understand the staff’s views on the work environment impact of the implementation of the rules;
- To explain the staff’s views with regards to rule implementation failures;
- To explore relations between role, employer, skillset, education and their safety views;
- To understand the difference regarding safety views between customer technicians and manufacturer technicians.

Research philosophy:

Starting with the outer layer, a pragmatistic approach was selected since its prerogative is that the most important are the research questions and objectives (Simpson B., 2009). Moreover, with the focus being to answer the questions a single method such as qualitative or quantitative is not enough, it is used therefore a mixture of both in this research. This approach is also supported by Creswell (2018) that defends the research methods deserve little focus since the target is to understand the problems, and thus any resource available should be used.

Research approach:

On Saunders et al. (2012) research onion process, the second layer is the approach. It can be inductive, by collecting data, processing it and developing a theory or deductive in which the existing literature is used to identify fitting theories (Saunders et al., 2012).

Given that there is no existing literature on this specific subject it defaults to an inductive approach, finding the specific information and processing it to create a generalised hypothesis.

Research strategy and time horizons:

The third and fourth layers of Saunders et al. (2012) process, are the research strategy and the time horizons. The strategy is intertwined with the time horizon since this is an academic research work and there are time constraints. A longitudinal study would require a lot more time (Sahay, 2016) and higher levels of authorisation from all the businesses involved. Thus, the use of the mix-method and a cross-sectional study is preferable, based on the focus in the answers as suggested by Creswell (2018).

Research method:

The mix-method allows the use of qualitative information as well as quantitative. Sandelowski (2003) defines the mix-method as a combination of purposeful and probability sampling, open and closed answers collection, descriptive and multivariable analyses in which everything can be used together.

The qualitative method provides unique information from the participants, by providing their unique perspectives, mindset and insights harnessed from experience (Creswell, 2018; DiCicco-Bloom and Crabtree, 2006). Consequently, a qualitative method will be used to gain a comprehensive picture from the participants based on their experience of the rules and how they are implemented on site and to what degree they are followed. Usually, qualitative research has description and exploration as objectives, while quantitative research aims to describe and explain (Johnson and Christensen, 2008).

It is suggested that quantitative research is suitable when it is necessary to measure relations between variables (Robson, 2002); and, it does not affect the research findings since all responses from the participants are treated and processed into numbers for statistical analysis (Cooper and Schindler, 2016). The exclusion of relevant human experience and the fact that it does not control all variables is also a weakness in the quantitative method (Cooper and Schindler, 2016).

By combining both methods, a better understanding of the study can be done since they complement each other’s weaknesses (Tashakkori and Teddlie, 2008).

Target population:

Parahoo (2014), defines a population as the total number of individuals, items or organisations that are selected to be studied as a sample. For this research, participants include manufacturer and customer staff both onshore and offshore, as well as third parties such as subcontractors. However, it is limited to the three site populations, and this constrain makes this survey a non-probability sample. As an investigative research with reach limited to the site, it not fully encompasses the companies involved, this will also reflect in the findings since it is not possible to calculate margins of error.

Sample size and strategy:

Using Saunders et al. (2012) non-probability selection technique, it was possible to identify the sampling technique. Starting with the apparent fact that it is not possible to collect data from the entire population due to the size of the companies involved and that there is no suitable sampling frame available. Therefore, the focus is on the research questions and objectives and consequently the result is a purposive sampling. This is also supported by Saunders et al. (2012) as it is suggested that for populations under fifty is advisable to collect much data as possible. In this case, the population is small and so all individuals that met the criteria before mentioned – trained on or working under the WTSR – were invited to participate.

The next step is to select the correct focus, in this case, due to the size of the sample a critical case sampling is identifiable using Patton’s (2002) inferences, as it is possible that the rule-breaking issues are replicated on other sites.

The questionnaire:

The survey provides primary data, directly from the people affected by the rules, while the literature (books, journals, course materials and internet sources) provide secondary data and comparison elements to infer results. This primary and secondary data can then also be triangulated with the observations from the oil and gas industry to draw a new picture of the reality in the wind industry.

It is particularly important to capture on the survey answers from key players, namely:

- Authorising Engineers (AE) – Responsible for the formal approval of Approved Written Procedures, Method Statements and Risk Assessments, consequently establishing the precise guidelines to achieve safety from the system under all foreseeable situations. It is also responsible for deciding on the course of action for special procedures that may arise under unforeseeable situations, even if it means to deviate from the rules.
- Authorised Technicians (AT) – Responsible for the work, the work party members and general safety at the point of work, while working under an AWP;
- Competent Technicians (CT) – Responsible for work under the supervision of an AT and responsible for the work, the work party members and general safety at the point of work, if working under the routine operating procedure;
- Supervisors – Overall responsibility of day to day operation and maintenance activities in the wind farm. Decides on the documentation (AWP, MS, RA) to be issued to each team daily.
- Other office staff:

- Managers - since some of them have additional HSE responsibility, subsequently they are ultimately the legally responsible person for any inadequacy in the rule and its application on their sites;
- Operational Controllers (OC) – Responsible for handling the process of transfer of control of the wind turbines between the control centre and technicians in the field, which includes document control of the AWP to be used at specific locations.
- Marine Controllers (MC) – Managing the maritime activities in and around the park with particular attention to turbines where work is being conducted.
- Health and Safety Executives – Responsible for general management of the HSE on site.
- Technical Service Administrators, Site Administrators, Warehouse Coordinators – all of which work daily under different sections of the rules and deal with WTSR requirements

It is also worth noting that there is a minimal amount of AE’s in the industry, less than five per cent of the offshore staff. Most roles are in a similar situation as AE’s with regards to numbers, with the exception of CT’s and AT’s (clear majority of the offshore staff). However, the AE role carries the highest responsibility under the rules (RenewablesUK, 2015) and thus the most significant scrutiny from manufacturers and customers.

The literary review of this research was conducted using published articles, scientific books, training course books, online magazines, online journals, reputable websites and statistics from the energy sector.

This survey focuses in the United Kingdom due to its maturity in the offshore wind industry but mostly because it’s the birthplace of the WTSR and therefore where these are further developed, implemented and monitored. This research is limited in the sample size of sixty-one questionnaires sent that does not represent the industry but represents a site and might help to shed light into the behind the scenes subtleties of the Wind Turbine Safety Rules, its form, its use and its implementation.

The survey is anonymous, confidential and voluntary, not only to protect the involved but also to encourage honest responses as suggested by Warner et al. (2011). Anonymity was also a request of the companies participating. However, Lelkes et al. (2012) discourage this approach as it removes some degree of accountability and thoughtfulness of the survey, thus becoming another limitation on this study.

It is also limited by the time available to develop it since most people surveyed work on shift rotations on remote locations and have limited time availability to participate.

This inquiry allowed the collection of data to take further steps towards a theory regarding the rule-breaking dynamics in offshore wind. What is likely to make people break the rules, values, external factors, dissociation from the rules or other.

It is done using the Qualtrics platform firstly because it ensures the safety of personal information on the Qualtrics server secondly because it has tools that allow for different formats of questions to minimise the respondent’s tendency to answer without reading.

The questionnaire structure follows Sue and Ritter (2012) procedure, initially determining what information will be sought, preliminary research, the type of questionnaire, the form of response, evaluation of sampling options, the wording of each question to maintain clarity and impartiality, the flow of the questions and the layout and presentation. Followed by distribution and response monitoring with reminders; and finally, with the data download, processing and analysis. Alternatively, face to face interviews were considered but the possible better response rate would have compromised the anonymity from the respondents and would have been more time consuming (Sue and Ritter, 2012). An online survey for this study was more efficient, with faster reach and easier data treatment using the Qualtrics tools (Sue and Ritter, 2012).

The survey after initial consent to participate in the study flows in four parts:

- Demographics

- Qualitative and Quantitative questions establishing primary demographic distribution such as age, sex, employer, job level, level of education and skill suit;

- How do you see the WTSR?

- Quantitative (Likert Scale) questions to gather information on behaviours, the impact of the rules on workflow and workload, rule implementation, management role on rule implementation and following, the purpose of the rules, self-assessment on rule following, company safety culture, responsibilities;

- Generic Perception of the rules

- Qualitative and Quantitative data gathered using open answer questions focusing on extracting the views on the different topics without leading the respondents.

- Last question

- Qualitative data, this last question required a more significant amount of characters – forty- in ordered to be valid. This condition was used to force the respondents to elaborate on their views.

No incentives were given to the survey participants as there would be no guarantee of participation or quality in the responses as supported by Cook et al. (2000).

To assess the validity, readability and consistency of the study, a pilot inquiry was conducted on two individuals external to the population of the study with an understanding of the WTSR. Also relevant to its validity is the structure of the questions used to obtain quantitative data, since the data’s value will depend on how close the questions relate to the object of the research (Collis and Hussey, 2014).

Between Qualtrics self-assessment function and the testers, the survey was estimated to have a duration of ten minutes, and thus in line with the recommendations of Crawford et al. (2001) and Shannon et al. (2002) that advocate for shorter questionnaires to maximise response levels.

Sixty-one participants were selected from the three organisations and emailed the survey. The invited participants included high-profile management and middle management to gather their point of view since they have a critical role on the implementation of the rules by establishing organisational culture (Deal and Kennedy, 2000) and consequently a safety culture.

Due to the role of some respondents it is necessary to do some ethical considerations, namely the anonymity and confidentiality of all the respondents, the companies they work for and their places of work. Even though the some of those answers could be relevant for this study, they could prove very damaging to the respondents and their organisations image.

Findings, Discussion and Analysis

Starting with a pool of sixty-one invited individuals to whom the survey (Annex 1) was sent, thirty-five completed the survey, eighteen started but did not finish, and eight did not respond. It is implicit that all of those who started the study consented to participate in Q1.1 of the survey.