Safety Science 141 (2021) 105352

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Safety Science
journal homepage: www.elsevier.com/locate/safety

A regulatory perspective on safety in design practices in New Zealand

Brian H.W. Guo a, *, Rory Weston b, Paul Jianphinitnan a, 1, Wanjun Liu a, 1, Eric Scheepbouwer a,
Daniel van der Walt a, Yang Miang Goh c
a
Department of Civil & Natural Resources Engineering, University of Canterbury, 69 Creyke Road, Christchurch 8140, New Zealand
b
WSP New Zealand, Level 1 Morrison Square, 77 Selwyn Place, Nelson 7010, New Zealand
c
Safety and Resilience Research Unit (SaRRU), Dept. of Building, School of Design and Environment, National Univ. of Singapore, 4 Architecture Dr., Singapore 117566,
Singapore

A R T I C L E I N F O A B S T R A C T

Keywords: Previous research regarding safety in design (SiD) primarily focused on legal aspects of integrating health and
Safety in design safety into the design, identifying causal links between flawed designs and accidents, safe design tools and
Design for safety methods, and multi-stakeholder collaboration. Despite these advancements in SiD, there is a lack of studies
Prevention through design
investigating how new SiD regulations changed SiD knowledge, attitude, and practices. To fill the research gap,
Safe design
Regulation
this paper aims to (1) examine current SiD knowledge, attitude, and practices after the introduction of the New
Zealand Health and Safety at Work Act 2015 (HSWA), (2) examine stakeholders’ perceptions about the effects of
the HSWA on SiD, and (3) identify challenges of SiD implementation. This study adopted mixed methods con­
sisting of a survey and semi-structured interviews. Results indicated an urgent need for developing SiD capability
at the company and industry level, although the industry had a positive attitude toward SiD. Several challenges
in SiD implementation were identified, including (1) additional cost and time, (2) unclear scope of SiD, (3)
opaque SiD process, (4) lack of collaboration/support, and (5) lack of good practice. Both survey and interview
participants raised several significant concerns over the new SiD regulations, HSWA 2015. These include (1)
HSWA being vague and more details needed to promote the implementation, (2) lack of good practice examples
and case studies, (3) lack of non-compliance examples, and (4) compliance burden on small businesses. This
paper contributes to the body of knowledge of safe design regarding industry professionals’ perceptions of SiD
knowledge, attitude, practices, implementation challenges, and new SiD regulations. In addition, the regulatory
perspective on SiD offered insights into regulation and policy formulation.

1. Introduction become a statutory requirement for designers to eliminate or minimize

In 2017, the construction industry in New Zealand (NZ) had the
second-highest number of work-related injury claims, accounting for
15.4% of all claims (Stats NZ, 2018). Internationally, NZ construction
safety performance is also poor. Compared to eight other Organization
for Economic Cooperation and Development (OECD) member countries,
NZ rated the worst, having a construction occupational fatal injury rate
of 15.3 per 100,000 person-years (Lilley et al., 2013). To improve
workplace health and safety, NZ underwent its most significant reforms
for 20 years and issued the Health and Safety at Work Act 2015 (HSWA).
The new workplace health and safety law came into effect on 4 April
2016. Since the introduction of the HSWA, Safety in Design (SiD) has
health and safety risks for down-stream stakeholders (e.g., construction
workers, maintenance workers, and end-users). Designers, as upstream
stakeholders, have a legal duty to ensure that, so far as is reasonably
practicable, any designs of plant, substances and structures are without
risks to the health and safety of people who construct, maintain, clean,
repair and eventually demolish the structure (NZIOA, 2015). The addi­
tional legal responsibility of designers can be seen as a result of the
established connection between design and construction accidents
(Poghosyan et al., 2018).
Safety in Design (SiD) is the process of integrating hazard identifi­
cation and risk management of a project’s lifecycle early in the design
phase. Globally, the concept of Safety in Design (SiD) takes various

* Corresponding author.
E-mail addresses: brian.guo@canterbury.ac.nz (B.H.W. Guo), Rory.Weston@wsp.com (R. Weston), sji48@uclive.ac.nz (P. Jianphinitnan), wli69@uclive.ac.nz
(W. Liu), eric.scheepbouwer@canterbury.ac.nz (E. Scheepbouwer), daniel.vanderwalt@canterbury.ac.nz (D. van der Walt), bdggym@nus.edu.sg (Y.M. Goh).
1
Formerly.

https://doi.org/10.1016/j.ssci.2021.105352
Received 15 November 2020; Received in revised form 26 February 2021; Accepted 18 May 2021
Available online 27 May 2021
0925-7535/© 2021 Elsevier Ltd. All rights reserved.
B.H.W. Guo et al.
names. For example, it is called Prevention through Design (PtD) in
North America, Design for Safety (DfS) in Singapore, Safe Design in
Australia, and Construction (Design and Management) (CDM) in the UK
(these terms are used interchangeably in this paper). These terms share
the core principle that designers should either ‘design out’ or minimize
health and safety risks through safe designs. As an upstream stakeholder,
designers can play a vital role in identifying, assessing, and managing
safety hazards early in the design process. As the lifecycle of a project
progresses, the ability to improve safety decreases and the cost to
address safety issues increases (Soh et al., 2020). Thus, designers are in a
strong position to make construction and operation safe.
Previous research efforts focused on: legal aspects of integrating
health and safety into the design (Gambatese, 1998; Hinze and Wiegand,
1992), identifying causal links between flawed designs and accidents
(Behm, 2005; Driscoll et al., 2008; Gambatese et al., 2008; Gibb et al.,
2004; Seo and Choi, 2008; Toole and Gambatese, 2008), safe design
tools and methods (Cooke et al., 2008; Dewlaney and Hallowell, 2012;
Gambatese et al., 1997; Goh and Guo, 2018; Guo and Goh, 2017), de­
signers’ hazard recognition ability (Hallowell et al., 2016), the effects of
decision-making processes on SiD initiatives (Lingard et al., 2012),
multi-stakeholder collaboration (Toh et al., 2016), and BIM-based DfS
tool (Hossain et al., 2018). Despite these advancements in SiD, a liter­
ature review conducted by Poghosyan et al. (2018) indicated that only a
small amount of research investigating legislation issues regarding SiD
implementation. In the SiD literature, very few studies investigated the
implementation of SiD-related regulations (Martínez-Aires et al., 2016).
While regulations form a significant driving force for SiD implementa­
tion (Aires et al., 2010; Poghosyan et al., 2018), there is a lack of studies
investigating how industry professionals perceived the new SiD regu­
lation and how the new SiD regulation changed SiD knowledge, attitude,
and practices from a regulatory perspective. The enactment of the HSWA
provided an opportunity to examine the effects of the new legislation on
SiD and identify implementation challenges.
To fill the research gap, this paper aims to (1) examine current SiD
knowledge, attitude, and practices after the introduction of the HSWA,
(2) examine stakeholders’ perceptions about the effects of the HSWA on
SiD, and (3) identify challenges of SiD implementation.
2. Literature review
2.1. Pioneering national safe design initiatives
The European Union (EU) developed the European Framework
Directive (89/391/EEC), which was applicable in all EU Member States.
The revolutionary Framework Directive established significant pro­
visions regarding safety and health standards, the legal responsibility of
employers, risk assessment methods and processes. Among the 19 in­
dividual Directives within the scope of the Framework Directive,
Directive 92/57/EEC establishes provision on the implementation of
minimum safety and health requirements at temporary and mobile
worksites. Regarding SiD, Directive 92/57/EEC requires that “The
project supervisor, or where appropriate the client, shall take account of the
general principles of prevention concerning safety and health referred to in
Directive 89/391/EEC during the various stages of designing and preparing
the project.” (Legislation UK). A study by Aires et al. (2010) suggested
that although member states adopted the Directive 92/57/EEC in a
different way, the effects of the Directive 92/57/EEC on accident
reduction were mostly positive.
In the early 1990s, design causal factors of occupational injuries and
illnesses were not adequately addressed in the US. As a result, the US
National Safety Council established the Institute for Safety through
Design in 1995 (Manuele, 2008). The term “Safety through Design” was
initially adopted. According to Manuele (2008), early strategies were
adopted to improve conceptual knowledge by promoting education and
increase awareness by establishing liaison channels. Around 2008, the
National Institute for Occupational Safety and Health (NIOSH) started a
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Safety Science 141 (2021) 105352
nationwide PtD program. The program focuses on four key areas to
promote PtD: research, education, practice, and policy. NIOSH also
made efforts to collaborate with the US Green Building Council to
explore the nexus between safe and sustainable design practices.
In Australia, early safe design initiatives commenced in the late
1980s (Creaser, 2008). In 1998/1999, the National Occupational Health
and Safety Commission (NOHSC) started a longer-term program, Safe
Design Project. Early research conducted by NOHSC identified de­
ficiencies in the knowledge of safe design (Cowley et al., 2000) and
causal effects of design on accidents and fatalities (Driscoll et al., 2008).
Safe design is one of the priorities established by the National Occupa­
tional Health and Safety Strategy 2002–2012. The importance of safe
design was re-emphasized in the Australian Work Health and Safety
Strategy 2012–2022 (Safe Work Australia, 2012).
2.2. Influence of SiD on construction safety performance
There have been many studies conducted to investigate the influence
of SiD on construction safety performance. Evidence has gradually
accumulated that safe design contributes to better site safety perfor­
mance. An early study conducted by Gibb et al. (2004) suggested that
there was a strong association between construction accidents and
permanent design of buildings. The authors reviewed 100 accident cases
and identified 47% were linked with unsafe designs. Behm (2005)
claimed that SiD is a viable method to reduce construction injuries and
accidents. The study analyzed the fatalities investigated and recorded by
the National Institute for Occupational Safetyand Health (NIOSH) Fa­
tality Assessment Control and Evaluation (FACE) program. Chi-square
tests of independence were applied to test if there was a relationship
between safe design and fatality. The results indicated that 42% of 224
fatality cases reviewed could be linked to unsafe designs. A later study
by Gambatese et al. (2008) demonstrated that these previous results and
expert panel opinions were in agreement for 71% of the cases reviewed.
The study reinforced the evidence of design’s impact on site safety.
Similarly, Seo and Choi (2008) identified that there were 203 design
elements of underground linked to accidents and injuries. Driscoll et al.
(2008) assessed the contribution of design to work-related fatal injuries
in Australia. They found that 37% of the 210 identified fatalities had
unsafe design issues. Lingard (2013) pointed out that only one of the
analyzed fatalities was associated with the design of the permanent
structure, while the majority were related to the “design of plant or
electrical equipment being used at the time” or “design of the process of
work”.
Despite the evidence, Hale et al. (2007) argued that no standard
definition of “design error” existed. Hence, those studies of identifying
design attributes from accident analysis based on expert opinion were
subject to large interpretation variations. Researchers (Hardison and
Hallowell, 2019; Tymvios et al., 2020) called for more objective
evidence.
2.3. Implementation challenges and barriers
Several studies were conducted to investigate the status of SiD in
terms of knowledge, attitude, practices, and implementation challenges,
such as Toft et al. (2003) in Australia, Toh et al. (2016) in Singapore,
Abueisheh et al. (2020) in Palestine, and Tymvios and Gambatese
(2016) in the US. What is common among these studies’ results is that
the industry’s attitude toward SiD was generally positive, but the SiD
practices level was still low. Gambatese et al. (2005) investigated the
feasibility and practicality of SiD as an intervention to improve site
safety. The study concluded that SiD is a viable intervention for
improving site safety performance, but there was a strong need for
improving designers’ knowledge of and mindset towards safety. The
Construction (Design and Management) Regulations 2015 required that
clients appoint competent individuals and/or organizations when
implementing SiD. Poghosyan et al. (2020) developed a web-based
B.H.W. Guo et al.
system to measure an organization’s design for safety capability using
18 attributes. Similarly, Adaku et al. (2021) developed a theoretical
framework to define and measure an organization’s capability of SiD.
These theoretical advancements are useful for both firms and govern­
ment agencies to measure and monitor SiD performance.
In addition, legal liability concerns were frequently raised in SiD
literature over the past three decades (Coble and Blatter, 1999; Gam­
batese, 1998; Gambatese et al., 2005; Toole and Erger, 2019). Designers’
lack of knowledge of safety presents significant challenges (Hardison
and Hallowell, 2019; Toole, 2005; Tymvios and Gambatese, 2016). This
issue exists on both the individual and organizational level. Research
effort was made to help measure the organizational capability of safe
design. For example, Poghosyan et al. (2020) developed a web-based
safe design capability maturity model. The five-level maturity indica­
tor is useful for an organization to self-assess, develop, and improve safe
design capability. Adaku et al. (2021) proposed a theoretical framework
to measure a design firm’s organizational capability of SiD.
2.4. SiD methods and tools
Seo and Choi (2008) presented a safety impact assessment method
applying a risk-based approach for underground construction projects.
The method can be used to identify the relationships between risk events
and design factors. The Australian Council of Building Design Pro­
fessionals and the Royal Australian Institute of Architects developed the
Construction Hazard Assessment Implication Review (CHAIR) tool to
facilitate SiD (Workcover, 2001). The tool aims to assist designers,
constructors, clients, and other key stakeholders to collaborate to
eliminate or reduce construction, maintenance, repair, and demolition
safety risks associated with design. The process consists of three main
phases. Phase I is performed at the conceptual design, Phase II focuses on
construction and demolition issues during the detailed design, and Phase
III is concerned with maintenance and repair issues.
Research was conducted to identify challenges in implementing SiD
internationally. For example, Lingard (2013) pointed out that the level
of construction safety knowledge possessed by designers may be limited.
Toh et al. (2016) and Goh and Chua (2016) suggested that there is a
positive attitude towards SiD, but lack of knowledge is a concerning
issue. Early research efforts were made to develop decision support
systems to facilitate SiD. For example, Gambatese et al. (1997) collected
400 design suggestions from multiple sources (e.g., Safety design man­
uals and checklists, interviews with experts, journal articles, etc.). The
authors claimed that all types of construction site hazards could be
addressed by the design suggestions. The authors further developed a
workable software package, Design for Construction Safety ToolBox,
that can identify hazards and present design suggestions to manage the
hazards. Cooke et al. (2008) developed a web-based rule-based
reasoning tool (ToolSHeDTM) to provide decision support for SiD.
ToolSHeDTM can assess the risk of fall from height and offer practical
design suggestions. It represents a significant effort to give the designers
easy and inexpensive access to expert safety knowledge.
3. Methods
3.1. Data collection
Mixed methods were adopted in this study to collect both quantita­
tive and qualitative data by conducting a survey and semi-structured
interviews. Mixed methods were applied because they offer several ad­
vantages. For example, qualitative findings can be collected from in­
terviews to explain quantitative results by a survey. This can enhance
the validity and reliability of the study (Tashakkori et al., 1998). As the
third research paradigm, mixed methods lead to great depth and breadth
in overall results and enable the researchers to make more accurate
inferences with increased credibility (Jogulu and Pansiri, 2011).
3
Safety Science 141 (2021) 105352
3.1.1. Survey
Survey questions were developed based on the literature review
findings and a review of various NZ SiD guidelines. The survey was
created using the software package Qualtrics (Qualtrics, 2019). A pilot
survey was carried out to ensure that the survey questions were clear
and comprehensible by practitioners and that the results obtained would
be useful in concluding the data. The link to the survey was distributed
in three primary ways. Initially, the link was sent to local government
agencies (e.g, local city councils) and private companies in the New
Zealand AEC industry. WorkSafe New Zealand was also contacted, who
were able to distribute the survey. Lastly, Engineering New Zealand
(ENZ) assisted in distributing the survey to members in their weekly
email.
The survey consisted of four sections. The first section aimed to
assess participants’ knowledge of various SiD concepts and the HSWA.
The second section asked participants about their attitude towards SiD,
and whether they believe SiD is effective and/or necessary. The third
section sought to determine the current practice of SiD within the AEC
industry, including the effect of the HSWA. Each of these sections con­
sisted of a variety of questions, either utilizing a Likert Scale, multi-
choice or open questions. The questions of the first third sections are
listed in Table 1. The final section asked the discipline and experience of
the participants.
In total, 231 responses to the survey were recorded. To be deemed as
useable data, two separate criteria were used to filter the responses.
Firstly, any responses in which at least 95% of questions were answered
was considered useable as suggested by Seo, (2005). Secondly, any re­
sponses which left either the general information empty or had a
discipline considered unlikely to be involved in the AEC industry were
removed. Because of the screening process, 176 responses were deemed
to be useable. Note that 12 responses from several other disciplines were
removed from group comparisons. The professional discipline and
experience of the respondents are displayed in Table 2 and Fig. 1,
respectively.
3.1.2. Interview
To complement the survey data, this study conducted fifteen semi-
structured interviews. The discipline and experience of interviewees
are shown in Table 3.
Interviewees were recruited from a link at the end of the survey.
Interviewee selection was based on the following criteria: (1) a mini­
mum of five years in the AEC industry, (2) knowledge of SiD within the
NZ AEC industry. All interviewees were asked a selection of core ques­
tions which supplement the KAP questions within the survey. These
included: the most significant challenges they face in implementing SiD;
the effect of the HSWA on their work, and their perception of the KAP of
different stakeholders. Additional questions were also asked based on
the discipline of the interviewee and the nature of the responses pro­
vided. All the interviews were recorded and transcribed.
3.2. Data analysis
Descriptive analysis of the survey data was first conducted to mea­
sure respondents’ knowledge, attitude, and practices of SiD. In the
analysis of the survey, the Likert scale questions were converted to nu­
merical values, where “1′′ corresponded to ‘strongly disagree’ to “5”
which corresponded to ‘strongly agree’ or equivalent with the value “3”
corresponding to the neutral value, in which participants neither agree
nor disagree.
A one-way analysis of variance (ANOVA) test (Miller, 1997) was then
performed using SPSS (Field, 2013) to identify if there is any statistically
significant difference between groups regarding SiD knowledge, atti­
tude, and practice. Three main assumptions were tested and met: outlier,
homogeneity of variances, and normality. The results of the inspection
of a box-plot for values greater than 1.5 box-lengths from the edge of the
box suggested that there were no outliers in the data. In addition,
B.H.W. Guo et al. Safety Science 141 (2021) 105352

Table 1 Table 2
Survey questions and statements. Professional disciplines of respondents.
Section Questions/Statements Discipline Number of respondents

SiD knoweldge 1: When did you initially hear of the concept of SiD? Engineer 90
2: Where did you initially hear of SiD? Architect 25
3: How would you describe your knowledge of SiD Project manager 24
and the Health and Safety at Work Act 2015 (HSWA Health and safety (H&S) professional 25
2015)? Other 12
4: Since the introduction of the HSWA 2015, your
knowledge of SiD has increased.
5: You know how to address safety risks associated
with construction and operation in the project
design.
6: Do you believe there is a lack of knowledge within
the New Zealand AEC industry on SiD?
7. The HSWA 2015 clearly defines the roles and
responsibilities of each party during the life cycle of a
project.
8. Have you attended a SiD course or seminar?
9. Please rank your familiarity of controls for the
following hazards?
Falls from height; structural or equipment collapse;
moving plant/objects; collapse of formwork; caught
between objects
SiD attitude 10. Do you think that the implementation of SiD is
very important?
11. Do you feel the HSWA 2015 has been effective in
creating greater awareness of SiD?
If you disagreed with the previous question. What
materials would you like to see in making SiD more
effective? Fig. 1. Experience of respondents.
12. What would you consider the main benefits of
SiD?
13. The implementation of SiD leads to a significant Table 3
reduction in accidents and illnesses throughout the
List of Interviewees.
building life cycle.
14. What do you consider the main negatives of SiD? Interviewee Discipline Years of experience
15. If you were given a choice, would you include
I1 Civil Engineer 28
SiD in your work?
I2 Civil Engineer 5.5
16. What do you think the main factors contributing
I3 Mechanical Engineer 39
to the effectiveness of SiD are?
I4 Health and Safety (H&S) Professional 28
SiD practices, 17. How often do you participate in SiD risk
I5 Electrical Engineer 10+
implementation assessments?
I6 H&S Professional 14
challenges 18. Undertaking SiD risk assessments is an
I7 Maintenance 25
inconvenience.
I8 H&S Professional 14
19. Who do you believe has the greatest influence on
I9 Civil Engineer 15.5
the SiD during its lifecycle?
I10 Civil Engineer 30
20. Optional: How would you say the knowledge of
I11 Project Manager 25
SiD obligations and attitude towards SiD varies
I12 Civil Engineer 5
between stakeholders?
I13 Architect 10
21. Has the HSWA 2015 had any impact on your
I14 Architect 5
engineering design work?
I15 Architect 5
22. How much impact do the following factors have
on the SiD process?
Project budget; Procurement method; length of project;
public vs. private client; number of stakeholders 4. Results of the survey
23. What are the main challenges faced by a designer
when they perform their Safety in Design duties? 4.1. SiD knowledge
24. Since the introduction of the HSWA 2015, have
you noticed an increased collaboration between all
parties involved in the project life cycle regarding
The concept of SiD is relatively new to some respondents, with 19.3%
the safety and buildability of a design? of all being first aware of it after the implementation of HSWA in April
25. Currently individual companies develop their
own SiD guidelines. Do you think having a national
Table 4
guideline would be beneficial?
26. Does a lack of a national guideline lead to
First knowledge and knowledge sources of SiD.
confusion about SiD obligations between When and where did respondents initially hear of SiD Proportion
stakeholders?
When After April 2016 (implementation of HSWA) 19.3%
2013–2016 34.7%
2010–2013 13.6%
Levene’s Test for homogeneity of variances indicated that the popula­
2007–2010 11.4%
tion variances in each group were equal. A Sharpiro–Wilk’s test (p BEFORE 2007 20.5%
greater than 0.05) was conducted to test normality. Results revealed that Where Tertiary education 17.0%
the dependent variables are normally distributed in each group. The Through your work or company 71.6%
interview data collected were transcribed and analyzed using NVivo 12 Publication/Seminars 4.0%
Media 2.3%
(Edhlund and McDougall, 2019). Other 4.5%
Never heard of it before 0.6%

4
B.H.W. Guo et al. Safety Science 141 (2021) 105352

2016, as shown in Table 4. Only 0.6% of respondents had never heard of Table 6
SiD before the survey. The majority of respondents learned SiD through Factors contributing to the effectiveness of Safety in Design.
their work or company, which is followed by tertiary education (17.0%). Factors Architects Engineers Project H&S
This implies that more SiD-related curriculums can be designed and managers professionals
implemented in tertiary education. The designer’s mindset 1st 1st 1st 1st
Regarding Question 5 (You know how to address safety risks asso­ towards safety
ciated with construction and operation in the project design), Health The availability of SiD 2nd 3rd 1st 2nd
and safety professionals had the highest self-rated score, 4.1 (with “1′′ tools and guidelines
Engagement of 3rd 2nd 2nd 3rd
representing very low and “5” representing very high). Engineers and knowledgeable and
architects had a similar self-rated score, with 3.7 and 3.8, respectively. experienced designers
Project manager showed the lowest score. This may be caused by the fact in safe design
that project managers are generally less involved in building design. modification
The emphasis of SiD by 4th 4th 2nd 4th
Respondents were also asked to rate their knowledge of how to address
the authority
safety risks associated with construction and operation in design. The
perceptions by discipline are consistent with self-rated knowledge of
SiD.
Table 7
Although respondents were generally confident that they have good
Other factors identified from comments.
knowledge of SiD, over 70% of respondents believed that there was a
lack of knowledge of SiD within the New Zealand AEC industry. Other factors Comments by respondents

Client buy-in • Buy-in from clients.

4.2. SiD attitude
Respondents were asked to rate the importance of SiD, with ‘1′ being
very unimportant and ‘5′ being very important. The average rating was
4.76, which indicated that the majority of respondents hold a view that
SiD is very important. Table 5 shows the distribution of the attitudes of
different disciplines towards the effectiveness of SiD in accident pre­
vention. In general, most respondents agreed on the effectiveness of SiD
in accident prevention. Over 83% of H&S professionals agreed (with
53.85% strongly agree) that the implementation of SiD leads to a sig­
nificant reduction in accidents and illnesses throughout the building life
cycle. Interestingly, ‘architects’ had the highest proportion of being
natural to the effectiveness of SiD (28%), and there were two cases in the
‘engineer’ group that disagreed on the effectiveness of SiD.
Respondents were also asked to choose the main factors that
contribute to the effectiveness of SiD. Table 6 presents the differences in
the ranking of factors by discipline. All groups deemed that designers’
mindset towards safety is the most driving factor contributing to SiD.
Respondents also believed in the importance of the availability of SiD
tools and guidelines and peer support.
In the survey, respondents were given the opportunity to list other
factors and comments contributing to the effectiveness of SiD. Five main
factors were identified from the comments by respondents, including (1)
client buy-in, (2) multi-stakeholder collaboration, (3) SiD culture, (4)
SiD knowledge and experience, and (5) knowledge of legal duties (see
Table 7).
4.3. SiD practice
Participants were asked to report the frequency of SiD participation
in practice. As shown in Table 8, note that, on average, about 16% of all
respondents never, or rarely, had been involved in SiD practices before.
Only 47.9% often, or very often, participated in SiD risk assessment.
When asked if undertaking SiD risk assessment is an inconvenience,
• Communication with the client.
• Client buy-in and preparedness to pay for the additional
inputs.
Multi-stakeholder • Client and contractor participation.
collaboration • Bringing all parties together with a Safety in Design
focus, rather than each discipline, or project phase, acting
alone.
• Having the right people involved - designers, clients,
constructors, operators, maintainers.
• SiD workshop to include experience from all fields of
expertise (operators, designers, owners).
SiD culture • Positive safety culture by all persons involved in
projection management and operational or asset
management.
• A culture that actively encourages SiD and H&S on a
daily basis.
SiD knowledge and • Experience across all project phases (design and
experience construction) allows an individual or company to reinject
that knowledge into future designs.
• Experience in areas other than design. One cannot
design plant, equipment, and systems, that are safe to
install, operate, and maintain unless one has installed,
operated, and maintained plant and equipment. The great
majority of modern consultants have never been in such
roles, and have little concept of the realities.
• Mind-set of construction and design industry as a whole.
Knowledge of legal • The knowledge that failure to comply will cause legal or
duties compliance action.
• Lack of case law demonstrating the Person Conducting a
Business or Undertaking (PCBU) liability in design.
Note: PCBU is a broad concept used throughout the HSWA 2015 to describe all
types of modern working arrangements which are commonly referred to as
businesses.
more than 20% of all respondents agreed, with about 55% choosing
either “somewhat disagree” or “strongly disagree”, and 24.31% adopt­
ing a neutral attitude. Survey participants were asked to choose the
stakeholder who has the most significant influence on SiD. 43% of all
respondents believed that owners/clients have the most significant

Table 5
Perceptions of the effectiveness to reduce accident.
Discipline Mean (M) Standard deviation (SD) The implementation of Safety in Design leads to a significant reduction in accidents and illnesses throughout the
building life cycle.

Strongly agree Somewhat agree Neither agree nor disagree Somewhat disagree Strongly disagree

Engineer 4.0 0.73 22.50% 65.00% 10.00% 1.25% 1.25%

Architect 4.0 0.74 28.00% 44.00% 28.00% 0.00% 0.00%
Project manager 4.0 0.76 41.67% 37.50% 20.83% 0.00% 0.00%
H&S professional 4.0 0.73 53.85% 30.77% 15.38% 0.00% 0.00%
Total 4.0 0.74 36.51% 44.32% 18.55% 0.31% 0.31%

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B.H.W. Guo et al. Safety Science 141 (2021) 105352

Table 8 impact on their engineering design work. About 62.8% of all re­
SiD participation frequency by discipline. spondents believed that the HSWA had successfully promoted collabo­
Discipline How often do you participate in Safety-in-Design risk ration among project stakeholders regarding safety and constructability
assessments? of building design, while 25% were unsure about the impact. Note that
Very often Often Occasionally Rarely Never there were about 12% did not see any increased collaboration among
project stakeholders since the introduction of the HSWA.
Engineer 11.11% 46.91% 33.33% 7.41% 1.23%
Architect 15.38% 30.77% 30.77% 15.38% 7.69%
Project manager 5.00% 20.00% 45.00% 20.00% 10.00% 4.5. Downside and challenges of SiD
H&S professional 12.50% 25.00% 50.00% 12.50% 0.00%
Total Mean 11.00% 30.67% 39.78% 13.82% 4.73% Table 10 lists the principal negative aspects of current SiD practices
that respondents perceived and raised in the survey. These negative
aspects include (1) additional cost and time, (2) unclear scope of SiD, (3)
impact on SiD, which was followed by consultants with 36.8%. Only
opaque SiD process, (4) lack of collaboration/support, and (5) lack of
7.64% deemed that contractors are the driving group.
good practice. Although it is true that SiD does cause additional upfront
cost, some respondents appreciated the fact that it can save money over
4.4. Perceptions of the HSWA 2015 the lifetime. In addition, respondents expressed their worries over the
scope and “box-ticking” exercise in SiD practices.
Overall, about 60% of all respondents agreed that their SiD knowl­ Survey participants were asked to select the main challenges faced by
edge has increased since the introduction of the HSWA. However, there designers when they perform SiD duties. Results revealed that “stake­
were still about 40% holding the opposite view. This may be because of holders lack of understanding of their roles in SiD” was the most
the fact that SiD was not a new practice and the guidelines provided by frequent challenge selected by engineers, project managers, and H&S
the government were limited. professionals (see Table 11). The cost was the challenge that appeared
Regarding the impact of the HSWA on SiD awareness, over 72% of all most frequently in architects’ responses.
respondents believed that the HSWA has been effective in creating
greater awareness of SiD. However, about 13.8% either somewhat or
strongly disagreed with the statement. In the survey, respondents who
disagreed were asked: “What materials would you like to see in making
SiD more effective?” Table 9 lists the main material categories and Table 10
specific comments made by respondents. Negative aspects of current SiD practices.
Participants were asked if the HSWA had any influence on their Negative aspects Specific comments by respondents
engineering design work and collaboration among project stakeholders.
Additional cost and • Many clients (specifically public sectors, e.g. Councils)
Results suggest that 12.78% stated that the HSWA had a significant time expect SiD to not cost any extra than before the Act was
impact on their engineering design work, and 47.37% chose “some introduced, however, to meet obligations it does cost more
impact”. More than 38% hold a view that the HSWA had little or no in time however is not always accepted by these clients in
proposals.
• In my experience, it generally saves money over the
Table 9 lifetime but does front-load the implementation time.
SiD materials requested by respondents. • Delays to the design process, often on a tight timeline.
• If it is misunderstood, it wastes a lot of time
Material category Specific comments by respondents
unnecessarily.
Good SiD • Case law, good practice examples which include why they Unclear scope of SiD • I don’t think the scope of “Safety in Design” is clearly
practices took the specific approach and how the process was done (not identified and the leads to misconceptions about what is
just the outputs). “Safety in Design”.
• Not necessarily documents, but campaigning by WorkSafe, e. • The difference in opinions as to whether something is
g. roadshows around the country aimed at engineering/ truly a safety risk that can be solved by design.
architectural/project management institutes to engage those • Challenges in obtaining approval or acceptance of
who have the biggest opportunity to eliminate risks through residual risks that were uneconomical to resolve during
planning and design. Hearing from people who have the design phase.
implemented real-time solutions. Campaigning of “what good Opaque SiD process • People often don’t know how to do it effectively. There
looks like”. isn’t a great understanding of the process.
SiD processes and • Formatted design process that is implemented. All PCBU’s • People take it too far and create ridiculous scenarios that
tools requiring this as part of the process of tendering. add little benefit to the process.
• Guidance on Safety in Design risk assessment. • It has become its own process and because of time can
• More standardized tools to use to meet obligations outlined in often be a checklist process rather than an embedded
HSAW Act. The Act itself does not explicitly require Safety in process of design.
Design, only that due diligence is completed by all involved in • Can potentially become a “box-ticking” exercise.
the design process and is correctly documented. For many • Sometimes overzealous approach can create more issues
small companies, SiD is completed but not necessarily than solutions - practical knowledge is gained through
recorded, and the introduction of the Act resulted in a lot of experience.
time for these smaller companies to develop SiD templates. • Poorly implemented safety in design processes can lead
Larger international companies tended to have these resources to a false sense of security, especially when it is considered
already. It would be good for WorkSafe or likes to have a tool to as a specific action to take instead of just being part of
use at minimum as a base to meet these new obligations. being a good designer considering risk throughout the
• Needs to be a cultural shift in the way the design process is entire design process.
approached; safety should always be considered first in any • It is not implemented consistently enough across all
design process. clients, engineers and contractors, most likely due to a lack
SiD legal duties • Expansion and highlight of “upstream” responsibility of of understanding and training.
PCBU’s in particular the utility industry where they often Lack of collaboration/ • Designers are not always best placed to determine safety
consume their own designs with use of subcontractors. The support improvements and need contractor/maintenance support.
gaps are often attempted to be filled using ‘standards’ for Lack of good practice • Much of it is already happening but not recognized as
contractors to follow. such, although there are glaring omissions, there needs to
• The prosecution, penalties for non-compliance, and law be a body of Knowledge of “Good Practice” made freely
enforcement. available for everyone’s benefit.

6
B.H.W. Guo et al. Safety Science 141 (2021) 105352

Table 11 Interviewees who have working experience in the UK compared

SiD challenges perceived by discipline. current SiD regulations in NZ to the Construction (Design and Man­
Challenges Architects Engineers Project H&S agement) (CDM) Regulations 2015 implemented in the UK. As Inter­
managers professionals viewee 11 pointed out:
Stakeholders’ lack of 2nd 1st 1st 1st
“The legislation (i.e., CDM) is very clear at the start and it was a lot of
understanding of their
roles in Safety in
pressure on all the consultants and the client to adopt the CDM process
Design and it becomes difficult to deal with the project without doing CDM. I
Lack of design guides/ 2nd 2nd 3rd 3rd think it’s the way to get everyone on-board with it. I think one of the
examples of safe concerns that I have on SiD legislation in NZ; it’s been softened quite a
design
lot.”
Cost consideration from 1st 3rd 2nd 2nd
the client and/or
This was complemented by the view of Interviewee 3 that:
company
No mechanism to check 4th 4th 4th 4th
“I was working in the UK at the time when the CDM regulations came in
for consistency in
Safety in Design
when they introduced the construction, design and maintenance regula­
tions. When they came out, they also came out with a very good guidance
booklet and what it actually means, and what people actually need to
4.6. One-Way ANOVA analysis do.”

ANOVA tests were then conducted to investigate whether there are
statistically significant differences in SiD knowledge, attitude, and
practice between the four groups (i.e., engineer, architect, project
manager, and H&S professional). Table 12 presents the results of one-
way ANOVA tests, which show that project managers’ self-rated SiD
knowledge was significantly lower than H&S professional at the 0.1
level. Engineers’ perception about whether HSWA increased their SiD
knowledge was significantly different from H&S professionals at the
0.05 level. In addition, Engineers’ perception about whether there is a
lack of SiD knowledge in the NZ AEC industry was significantly different
to both H&S professionals and project managers. Regarding the fre­
quency of SiD practice, engineers were statistically significantly higher
than project managers.
ANOVA tests were also conducted on Questions 7, 9, 10, 11,13,15,
18, and 19 and no statistically significant differences were found among
different stakeholders.
5. Results of the interviews
Four themes were identified from the theoretical coding of the
interview data, including (1) SiD regulations, (2) mindset, attitude, and
awareness, (3) SiD knowledge, and (4) SiD process.
5.1. SiD regulations
Overall, most interviewees agreed with the positive changes led by
the HSWA. When asked if the new Act (i.e., HSWA) has made changes in
SiD, Interviewee 10 stated that:
“I’d say so; it’s upped the game.”
Some interviewees raised the issue that the requirements by the
HSWA are vague. As the Interviewee 12 pointed out:
“But it’s the processes the HSWA asks for. It’s all vague. Like what does it
mean necessarily by ‘place documentation’? Do you need calculations?
Do you need a registration? Do you need a letter? What exactly do you
need? It needs more standardization, but ultimately that comes down to
cost consideration.”
5.2. Mindset, attitude, and awareness
In order to facilitate effective SiD implementation, interviewees
pointed out a need for a mindset shift in SiD. They highlighted the
importance of taking ownership of SiD. SiD is not new to most designers.
The difference lies in the fact that health and safety were only (volun­
tarily) considered in design previously, and now it has become a legal
requirement and process. Interviewees mentioned that although the
HSWA has been implemented for years, there is still a “not my problem”
attitude. Interestingly, a few interviewees criticized architect’s attitudes
towards SiD in general. For example, Interviewee 3 stated that:
“The area where I do find problems is architects. They don’t want to mess
up the beauty of the design. Architects are not as keen. They don’t want to
see anything (referring to mechanical stuff). This stuff isn’t difficult. They
are far too worried about aesthetics and lesser levels on safety and
functionality.”
This was echoed by Interviewee 12 and 6, who both mentioned that
from an architect’s perspective, aesthetics appeal is more important than
SiD. In some situation, the demands are conflicting.

Table 12
One-Way ANOVA Tests.
Questions Discipline (I) Discipline (J) Mean Standard Significance 95% confidence
Difference (I- error interval
J)
Lower Upper
bound bound

Q3: How would you describe your knowledge of Safety in Design Project H&S -0.708* 0.261 0.056 -1.35 -0.06
and the Health and Safety at Work Act 2015? manager Professional
Q4: Since the introduction of the Health and Safety at Work Act Engineer H&S 0.561* 0.215 0.073 0.03 1.09
2015, your knowledge of Safety in Design has increased. Professional
Q6: Do you believe there is a lack of knowledge within the New Engineer Project -0.664** 0.219 0.023 -1.27 -0.06
Zealand AEC industry on Safety in Design? manager
Engineer H&S -0.581* 0.219 0.065 -1.12 -0.04
Professional
Q17: How often do you participate in Safety-in-Design risk Engineer Project 0.693** 0.238 0.034 0.03 1.35
assessments? manager

Note: * the mean difference is significant at the 0.1 level. ** the mean difference is significant at the 0.05 level.

7
B.H.W. Guo et al.
5.3. SiD knowledge
In general, it was interviewees’ perception that the current knowl­
edge level of SiD in NZ is average, which is consistent with the survey
results.
Although SiD is not new, interviewees highlighted a strong need for
SiD case studies and examples. As Interviewee 9 argued:
“It would be beneficial to have some kind of case studies or examples, of
how design can impact safety issues, that is something I think is lacking.
Need something to open the door, let people know how they can have an
impact and why they are doing it. I think that would be really useful.”
The effectiveness of SiD largely depends on practitioners’ knowledge
of risk assessment. However, this is a significant issue, considering some
designers do not have any construction and facility maintenance expe­
rience. As Interviewee 3 pointed out:
“To have an understanding of the risks you have to have built stuff, you
have to have operated machinery; you have to have maintained it. If you
haven’t done that, you can’t understand it. If you haven’t done that,
that’s when you fall down. That’s where most of them are falling down.”
5.4. SiD process
Interviewees raised several significant issues regarding SiD process,
including lack of standardization, inconsistencies, reliance on a checklist
approach, and lack of an implementation framework. These issues
identified from interviews are consistent with those found from the
survey (see Table 11). The problem of lack of standardization and con­
sistencies in SiD practices is associated with the vague requirements
made by the HSWA. As Interviewee 1 pointed out:
“They (SiD processes) are still not consistent. There needs to be more
industry training and workshops on real case studies. This would be
beneficial to help people understand the importance of SiD.”
Interviewees also expressed the concern that organizations may
apply a checklist approach blindly and advocated for a framework that
can better facilitate SiD efficiency and effectiveness. When asked if each
company should use the same checklist, Interviewee 5 answered:
“I don’t think a checklist is a way to go, but I think a framework.
Checklists can be quite binary. A framework focuses on more what your
risk appetite looks like and what aspects of the design could breach this
level of appetite, then what are you going to do in terms of the level of
control. So it’s more of (a) framework, you can’t get a one size fits all
solution, but at least a framework can provide guidance.”
Another concern is that new SiD legal requirements resulted in
additional time and costs for stakeholders. Although interviewees
agreed that SiD saves money in the lifetime, it indeed causes significant
upfront costs. Interviewee 11 stated that the biggest barrier to the
implementation of SiD is cost:
“(The biggest barrier is) the cost, if it’s more expensive it’s frowned upon,
we have to find the cheaper way to do it and sometimes hard to achieve.”
Clients may not realize these upfront costs caused, and this would put
consultants who bid for projects into an uncompetitive situation. As
Interviewee 12 pointed out:
“Consultants want the best price. But adding SiD, clients may see it as
something you don’t need to worry about, just put it into your Health and
Safety stuff. It is extra work; you have to do a risk register and run extra
workshops with 4 or 5 high-level consultants, $2000 for an hour. A lot of
money.”
Public clients are more willing and capable to pay the compliance
8
Safety Science 141 (2021) 105352
cost, but this is a significant challenge for small businesses. Interviewee
7 argued that:
“… the cost of the compliance was difficult, so the big companies did
alright while the smaller company get squeezed. Then what happens to the
smaller company is they are trying to make it cheaper to provide advice, so
what they get is saving money in the short term, but not making compli­
ance to H&S. But now we have been told something by someone saying
“No, that’s how it is”. There is a lot of assumption and proof floating up
there from huge variety because people now realize we can make money of
this we don’t even have to know what we are talking about.”
Due to the lack of standardizes processes and tools, developing their
own methods, tools, and templates is another level of challenge for small
businesses.
6. Discussion
6.1. Comparison with previous research
This study investigated stakeholders’ perceptions of the knowledge,
attitude, practices, and challenges of SiD in New Zealand. Table 13
compares the results of this study with those of previous research on SiD.
Overall, the results are mostly consistent concerning the knowledge,
attitude, and practices of SiD. In specific, a consensus existed that there
was a lack of SiD knowledge within the AEC industry and it has been a
significant barrier to SiD adoption and implementation. In general,
knowledge of SiD can be divided into two main dimensions: (1)
knowledge of compliance (or implementation) processes and (2)
knowledge of safe design.
Most of the previous research focused on the second dimension: the
scientific knowledge of safe design. Hardison and Hallowell (2019), in a
review of construction hazard prevention through design, called for
more scientific exploration to objectively test the hypothesis: design
changes do not cause reductions in injuries and fatalities. The authors
argued that previous studies of SiD tend to focus on perceptions and
conceptual aspects of SiD and SiD is still a theory to be tested, rather
than a fact. This perspective has significant implications for SiD imple­
mentation. For example, the survey results indicated that there was still
a considerable proportion of participants that were sceptical of the
effectiveness of SiD to reduce accidents (refer to Table 5). From Vroom’s
expectancy theory of motivation (Vroom, 1964), such scepticism would
decrease people’s expectancy that safe designs can effectively reduce
accidents and injuries. Both survey participants and interviewees called
for more SiD examples and cases. Without a robust scientific knowledge
basis of safe design, SiD would quickly turn into paper exercise, which
only aims to meet compliance requirements (Goh and Goh, 2016). To
date, there is a lack of scientific measurement of SiD effectiveness, which
makes evaluation and enforcement difficult.
It seems that there was a consistent picture of people’s attitude to­
wards SiD at the global level. This study indicated that both survey and
interview participants hold a positive view on the importance of SiD,
which reinforced the studies (Abueisheh et al., 2020; Gambatese et al.,
2005; Gambatese et al., 2008; Toft et al., 2003; Toh et al., 2016) that
investigated SiD attitude. Despite the positive attitude towards SiD, the
level of industry engagement in SiD was still very low. Abueisheh et al.
(2020) and Toh et al. (2016) depicted a similar picture in Palestine and
Singapore, respectively.
Globally, the low level of industry engagement can be attributed to
several common barriers, including time and cost constraints, legal is­
sues, lack of collaboration, and lack of knowledge and capability.
6.2. A hybrid regulatory approach to SiD?
Both survey and interview participants raised several significant
concerns over the new SiD regulations, HSWA 2015. These include (1)
B.H.W. Guo et al.
Table 13
A comparison with previous research.
Aspects of SiD Previous research
Awareness, UK
knowledge and Designers lack exposure to
understanding onsite activities and
operations (Larsen and
Whyte, 2013)
US
Four (21%) of the 19
designers interviewed were
judged to be knowledgeable
of the concept (Gambatese
et al., 2005)
Knowledge of design for
construction worker safety
is very minimal (Tymvios
and Gambatese, 2016)
Singapore
DfS knowledge needs to be
improved (Toh et al., 2016)
Palestine
70% of 25 survey
respondents were aware of
the concept of design for
safety (Abueisheh et al.,
2020).
Attitude, interest, US
and willingness Among the 19 designers
interviewed, 7 respondents
(37%) were willing to
implement SiD, while 47%
gave a neutral response,
16% expressed negative
interest concept (Gambatese
et al., 2005).
Experts agreed that SiD is a
viable method to improve
site safety (Gambatese et al.,
2008).
Architects were the least
receptive to the idea (Toole
et al., 2017).
Australia
Members of the Australasian
Association for Engineering
Education had a positive
attitude toward SiD (Toft
et al., 2003)
Singapore
Stakeholders had a positive
attitude towards the concept
of design for safety (Goh and
Chua, 2016; Toh et al.,
2016).
Palestine
82% of 25 survey
respondents considered the
importance of design for
safety to be “very high” or
“high” (Abueisheh et al.,
2020).
Practice and US
implementation 47% of the 19 designers
interviewed addressed
construction safety in their
design on an informal basis;
42% made modifications to
a design to eliminate safety
risks (Gambatese et al.,
2005).
Safety Science 141 (2021) 105352
Table 13 (continued )
Aspects of SiD Previous research This study (New Zealand)
This study (New Zealand)
Only 0.6% of respondents Only 19.3% of engineers
had never heard of SiD and 5.4% of architects
before the survey. responded that their firm
practiced some form of safe
Survey respondents’ self- design in their designs (
rated knowledge of SiD was Tymvios and Gambatese,
high. 2016).
Both survey and interview UK
participants believed that (Morrow et al., 2016)
there is a lack of SiD identified three types of
knowledge in the AEC designers regarding the
industry. implementation of safe
design:
The doer: make conscious
efforts to dealing with
health and safety issues in
their designs;
The receiver: want to
implement safe design but
struggle to do so;
The giver: are not concerned
with health and safety issues
in their designs.
Palestine
Engagement in safe design
Both survey and interview practices was very low. Only
participants hold a very one out of the 15 practices
positive view on the can be regarded as being
importance of SiD. implemented at least
“Often” by the participants (
Over 80% of the survey Abueisheh et al., 2020).
respondents believed that
SiD leads to accident Singapore
reduction. The level of design for safety
practice was low (Toh et al.,
2016).
most civil & structural
engineers were not
practicing DfS and few had
attended design for safety
training (Goh and Chua,
2016)
Challenges and US (Gambatese et al., 2005) • Additional cost and time;
barriers to and (Tymvios and • Unclear scope of SiD;
implementation Gambatese, 2016) • Opaque SiD process;
Increased liability; • Lack of collaboration/
Designer have limited or no support;
construction experience; • Lack of good practice.
Time constraints;
Designers have no control
over who gets the bid;
Economic and contractual
obstacles.
UK (Larsen and Whyte,
2013)
Designers were driven by
aesthetics, not health and
safety
Singapore (Goh and Chua,
2016)
Client’s cost consideration;
Lack of early involvement of
the contractor;
Only 47.9% of the survey Lack of mechanism to check
participants often, or very for consistency in design for
often, participated in SiD safety
risk assessment.
HSWA being vague and more details needed to promote the imple­
mentation, (2) lack of good practice examples and case studies, (3) lack
of non-compliance examples, and (4) compliance burden on small
businesses.
To set up a proper regulatory perspective to interpret these concerns,
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B.H.W. Guo et al. Safety Science 141 (2021) 105352

a brief comparison between SiD related regulations in NZ, Australia,
Singapore, and the UK was made (see Table 14). Note that the com­
parison is by no means comprehensive, and the primary intention is to
provide a meaningful international regulatory context to interpret both
survey and interview participants’ perceptions of the new regulation,
HSWA 2015.
The OHS legislative systems of the four countries are based on the UK
Robens model (Robens, 1972). Robens report marked a significant shift
of regulatory practice from prescriptive to performance-based concepts.
The Robens model is underpinned by three main principles:
1. Define general duties and overall objectives that are to be achieved,
2. Approved codes of practice, standards, and guidelines of guidance to
support duty holders,
3. A more effective self-regulating system that allows duty holders to
choose means to comply with general duties.
Performance-based regulations have widely been recognized as a
superior approach over prescriptive regulations, as they are more
adaptable and accommodate innovations. However, performance-based
regulations depend on the ability of regulators to “specify, measure, and
monitor performance, but reliable and appropriate information about per­
formance may sometimes be difficult to obtain” (Coglianese et al., 2003).
The main advantage of performance-based regulations is that regulated
entities are provided with the freedom to choose any (cost-effective and
innovative) means to meet the required outcomes. From this perspec­
tive, the inconsistencies in SiD practices raised in the survey and in­
terviews are somewhat understandable since companies are permitted
the freedom to meet the mandated outcomes in anyways. However,
performance-based regulations are not a perfect approach without lim­
itations. Coglianese et al. (2003) argued that regulators need to consider
the conditions in which the regulations are applied. Performance-based
regulations are often loosely specified, which can introduce not only
flexibility but also vagueness and imprecision. Large firms may enjoy the
flexibility, as they are more capable of searching and determining the
means to comply. In contrast, small businesses may prefer prescriptive
standards, codes of practices, and guidelines. According to the Robens
philosophy, a high-level Act provides only general duty requirements
and performance standards. One of the primary purposes of Robens
philosophy is to provide flexibility. It may come at the cost of being
vague, however. For example, both survey participants and interviewees
criticized the HSWA for being vague regarding SiD legal duties and
processes. To reduce the vagueness, a hybrid approach was often
adopted to combine performance standards with either code of practice
or guidelines. In effect, these code of practices and guidelines developed
by government and industry bodies take the form of prescriptive stan­
dards. As shown in Table 14, under the umbrella of the Work Health and
Safety Act, only the UK and Singapore have SiD-related regulations. In
particular, the Singapore Workplace Safety and Health (Design for
Safety) Regulations 2015 was explicitly designed for SiD, where legal
duties of regulated entities are expressly specified. For example, the
Regulations even require that the developer must convene design-for-
safety review meetings and ensure that each meeting is attended by
all the relevant designers and contractors appointed. As such, the reg­
ulations are far more prescriptive. Similar specified duties are imposed
on regulated entities in the UK Construction (Design and Management)
Regulations 2015. On the other hand, such a level of clarity is generally
missing in the New Zealand Work Health and Safety Act 2015 and the
Health and Safety by Design – an Introduction (Good practice guide­
lines). One could argue that flexibility is deliberately reserved, being
consistent with the Robens philosophy. However, flexibility may be seen
as a burden for small businesses. Small businesses need more support,
and a high amount of guidance is beneficial (Anderson, 2007; Guo et al.,
2018; Wright et al., 2005). They may prefer to be advised what specific
duties are and what to do, rather than incur costs to develop SiD pro­
cesses and tools needed. This concern was well manifested in both the
survey and interview results.
Again, a common argument for performance-based regulations is
that they accommodate innovations. Nevertheless, prescribing SiD
process requirements does not necessarily stifle innovations. For
example, mandating SiD review meetings does not hinder creating safer
designs. The real test lies in duty holders’ SiD knowledge and
commitment.
In addition, the role of upstream Person Conducting a Business or
Undertaking (PCBU) (i.e., designer) is highlighted in the HSWA, while
the Singapore Workplace Safety and Health (Design for Safety) Regu­
lations emphasized the leadership of developers in leading and facili­
tating SiD processes (e.g., documentation, meeting, cooperation, and

Table 14
A brief comparison of SiD regulations.
Country New Zealand Australia Singapore UK

WSH Act Work Health and Safety Act 2015 Work Health and Safety Act Workplace Safety and Health Health and Safety at Work Act 1974
2011 (WSH) Act 2011
SiD-related Regulations / / Workplace Safety and Health Construction (Design and
(Design for Safety) Regulations Management) Regulations 2015
2015
Regulation type Performance-based Performance-based Performance-based Performance-based
National SiD related / Safe Work Australia Code of / /
code of practice Practice Safe Design of Structures
(2012)
National SiD related • Health and Safety by Design – • Safe Work Australia Handbook • Guidelines on Design for Safety in • Managing health and safety in
guidelines an Introduction (Good practice Principles of Good Work Design Buildings and Structures (2011) construction – Guidance on
guidelines) (2015) • Workplace Safety and Health Regulations
• Safe Work Australia Guide Guidelines—Design for Safety • Need building work done? – A
for Safe Design of Plant (2014) short guide for client on the CDM
Regulations 2015
Industry All workplaces All workplaces Construction projects Construction projects
Scope Design of plant, a substance, or Design of plant, a substance, or Design of a structure Design of a structure
structure structure
Duty holders PCBU PCBU • Developer • Client
Officer Officer • Designer • Designer
Workers Workers • Contractor • Principal designer
Other persons at workplaces (e.g., Other persons at workplaces (e. • Contractor
visitors) g., visitors) • Principal contractor
Methods for transferring Design Safety Report, • Safety report DfS register Health and safety file
safety-related Work health and safety file • Work health and safety file
information

10
B.H.W. Guo et al.
communication). Both the Workplace Safety and Health (Design for
Safety) Regulations and CDM Regulations 2015 require developers/cli­
ents to allocate sufficient time and resources for SiD. However, such
requirements are missing in the HSWA. As a result, it is not surprising
that survey participants believed that there is a lack of client buy-in, and
their awareness of SiD can be improved. Note that client buy-in would
directly affect procurement strategies and processes (Guo et al., 2015).
Without sufficient time and resources from the client, it would be
challenging for designers and downstream stakeholders to lead and
facilitate SiD processes. In response to Worksafe New Zealand regarding
the document “Work-related Health Strategy – Health and Safety by
design”, the Institution of Professional Engineers New Zealand (now
Engineering New Zealand) highlighted the importance of collaboration
among all relevant stakeholders and leadership of client (The Institution
of Professional Engineers New Zealand, 2016). However, the duties and
roles of clients are mostly missing in the Health and Safety by Design –
an Introduction (Good practice guidelines) (Worksafe New Zealand,
2018). It would make a significant difference whether or not client place
demands on designers and contractors to meet specific SiD standards.
7. Conclusions
This paper investigated the current status of SiD in New Zealand
regarding knowledge, attitude, and practices after introducing the
HSWA. This study revealed that the introduction of the HSWA contrib­
uted to the increase in SiD knowledge and awareness. 62.8% of all
survey respondents believed that the HSWA had successfully promoted
collaboration among project stakeholders regarding the safety and
constructability of building design. However, both survey and interview
participants believed that SiD knowledge in the industry needed
improvement. A large proportion of survey respondents showed a pos­
itive attitude towards SiD regarding its importance and effectiveness.
However, there were still some who questioned the link between SiD
and accident prevention. Several challenges in SiD implementation were
identified, including (1) additional cost and time, (2) unclear scope of
SiD, (3) opaque SiD process, (4) lack of collaboration/support, and (5)
lack of good practice. The interview results suggested that SiD may be a
barrier for architects to pursue architect aesthetics.
Comparisons of SiD regulations were made among four countries (i.
e., New Zealand, Australia, Singapore, and the UK) that implement the
performance-based legislative system. Although the SiD regulations
implemented in the four countries are all performance-based, they are
characterized by various degrees of flexibility. A high level of regulatory
flexibility is more likely to facilitate innovation in health and safety
management techniques. However, standardization of SiD processes is
equally important are the early stages of SiD adoption. More detailed
guidance from government agencies will be able to reduce the compli­
ance cost for small businesses.
The contribution of this paper is twofold. First, this paper adds to the
body of knowledge of safe design regarding industry professionals’
perceptions of SiD knowledge, attitude, practices, implementation
challenges, and new SiD regulations. This paper revealed both common
and unique situations in the New Zealand context by contributing a
piece of the global picture of safe design. The common situations (e.g.,
positive attitude towards SiD, lack of knowledge, and time and cost
constraints) proved that there is an urgent need for developing SiD
capability at the company and industry level. Innovative tools and
techniques that are based on an established knowledge base may ease
the time and cost constraints. Note that the effects of the new regulation
HSWA on the awareness, knowledge, attitude, and practice of SiD were
identified and examined based on qualitative data in this study. Future
research should be conducted to test theories using statistical analysis
techniques.
Second, the regulatory perspective on SiD offered insights into
regulation and policy formulation. Effective performance-based regu­
lations should be applied based on a thorough understanding of the
11
Safety Science 141 (2021) 105352
nature of the problem (Coglianese et al., 2003). With respect to SiD, the
current major challenge is the low level of SiD knowledge and organi­
zational capability. The results of this study suggested that industry
stakeholders expected more detailed case studies and good practices
from the government agencies. This calls for a hybrid approach that
combines higher-level performance-based regulations with lower-level
rigid standards and guidelines. More flexibility can be provided once
the organizational capability of SiD is significantly improved at the in­
dustry level.
Declaration of Competing Interest
The authors declare that they have no known competing financial
interests or personal relationships that could have appeared to influence
the work reported in this paper.
Acknowledgements
The authors would like to thank the anonymous reviewers for their
constructive comments. Appreciation also goes to all respondents for
their participation in this study.
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