Thursday, 23 February 2012

Who's afraid of the big, bad risk register?

I'm getting towards the age now where I can start saying that things have changed since my day. Well, let me tell you, risk registers have most definitely changed since my day. In fact, they've changed since last week as far as I can see. And their transformation has been rapid, profound, and unexpected.

A risk register used to be a run of the mill project management tool. You'd identify the risks to your project, describe them, and then assign attributes to the risk - for instance, how likely is it to occur? What would be the impact if it did occur? Who's going to take ownership of the risk? What mitigating actions is the risk owner (and others) going to take to (ideally) eliminate the risk, or reduce its likelihood and/or impact?

Sensible type stuff, right? Nothing too scary. Of course in practice the quality of a risk register can vary significantly. Some of that variance is down to what sort of project it is and what sort of project manager is in charge of it. Some of it is just down to human nature - countless projects will kick off with the best intentions, initiate the full range of approved project management tools, review the risk register once and then rarely, if ever, look at it or update it again (they'll also often be poorly formatted without the requisite level of Microsoft Excel love and pastel shading, but that might say more about me than about risk registers...).

Now that's what I understand a risk register to be. Imagine my escalating surprise over the last few days as it has morphed into a necromantical nightmare, which cannot be released for fear of melting the feeble brains of us poor plebs.

Bit of background and context - on Monday 30 January 2012 early day motion 2659 was tabled in Parliament. The motion stated:

That this House expects the Government to respect the ruling by the Information Commissioner and to publish the risk register associated with the Health and Social Care Bill reforms in advance of Report Stage in the House of Lords in order to ensure that it informs that debate.

In November 2011, the Information Commissioner had ruled that "the public interest in maintaining the exemption (the exemption being 'formulation of government policy') does not outweigh the public interest in disclosure". The Commissioner therefore required that the Department of Health release the risk register that related to the Health and Social Care Bill.

The original request made for the release of the risk register was in November 2010 - the wheels, they do turn slowly!

The subsequent debate following the early day motion happened yesterday, Wednesday 22 February 2012. In my humble opinion, and with all due respect to the honourable members, none of the major parties covered themselves in glory during this debate.

We have this gem from Julian Smith MP - "Why is the right hon. Gentleman (Andy Burnham MP) such a scaremongering buffoon?"

The Deputy Speaker even felt compelled to interject - "this is easily and by some margin the worst-tempered debate that I have chaired".

The transcript of the debate is very long, but do pick out your own highlights if you get the chance. For me, it basically boiled down to quite a lot of going off the topic of the debate, so that opposing sides could make their points about why the Health and Social Care Bill is a good or a bad thing. And also quite a lot of Labour accusing the Government of hiding something that should be released, and the Government accusing Labour of hypocrisy.

Here's Andrew Lansley MP - "Frankly this is a broken bat debate...because the shadow Secretary of State (Andy Burnham MP) is trying to suggest that this Government should do something that he as a Minister and then as Secretary of State steadfastly refused to do".

Frankly Andrew, I don't care. It's totally irrelevant what previous governments have or haven't done. The fact is that the request for a specific risk register has been made now, and the request has been upheld and endorsed by the Information Commissioner. And besides, why not take this opportunity to be better than previous governments? You remember, the whole most open and transparent government in history thing.

Chris Skidmore MP threatened to inject some much needed sanity into proceedings - "Members have talked today about the risk register in apocalyptic terms, as though it were a document that should remain within the confines of MI5 or MI6". Sadly he then went on to say - "The risk register that would be released is that from the time of the White Paper, before the changes were made and before the listening exercise... If the document was released, it would be out of date, inaccurate and would scaremonger among the population".

In a superb heads I win, tails you lose manoeuvre, Mr Skidmore concluded - "The Government do not have to publish the updated registers on the basis of the Information Commissioner's verdict, which was on the autumn 2010 register... The Opposition are asking for an out-of-date document. We might as well give up and go home".

Oh would you? Please. Politicians giving up and going home... what's the worse that could happen? Maybe I should start a risk register...

So Mr Skidmore, who seemed visibly delighted with his reasoning, is simultaneously saying that the risk register isn't scary but its release would scaremonger the population, and that the Government shouldn't release an out of date risk register, but won't release the most recent version. Got that? Good.

Mr Skidmore, on fire by this point, had more to offer - "We are debating whether we should release a register that is no longer relevant and that was written in autumn 2010, at the time of the request on 29 November. The topic is completely irrelevant, as the debate has moved on. We have wasted six hours of parliamentary time today discussing an out-of-date risk register".

Chris (good name, by the way) - I've got a really good idea. Why not just release the risk register and not waste any more time? Oh, and just to point out, it's taken this long from the original request because the Department of Health and the Government have fought its release every step of the way.

Ok, that's more than enough from the debate itself. As I say, the transcript goes on and on and on, so feel free to read it for yourselves.

The final quotes in this post must go to Simon Burns MP (or #SimonBurns4SOS to give him his full title - follow Andy Cowper on Twitter, @HPIAndyCowper, for more). Here's a blog by Mr Burns posted just before yesterday's debate began.

Mr Burns says that risk registers are where civil servants "contemplate the most extreme circumstances of any major government project. They think the unthinkable to ensure that the unthinkable never happens... The consequence of this is a paper trail which details some of the most outlandish and extreme possibilities that civil servants have contemplated".

I'm sorry, what? No seriously, what? That's not a description of a risk register, that's a description of a think the unthinkable register - which incidentally doesn't exist as a thing, and is a trite contradiction anyway. Or it could be a description of an outlandish and extreme register - which again doesn't exist as a thing, and would be somewhat pointless to introduce as a new project management tool.

This is pure fantasy. It's trying to persuade us that senior civil servants sat down and detailed the most extreme and unlikely things possible to do with the Health and Social Care Bill. Right, so guys, risk number one... anyone? Here's one, aliens come down and snatch Andrew Lansley's body... ok, good, now we're cooking with gas... but hang on, is that a risk or an opportunity? Hmmm, good point. Ok, well there's that Mayan prophecy about the year 2012. Oh yeah! And there's that film that backs it up. Stick it down!

Civil servants haven't thought the unthinkable on the risk register (just to note once again, that is a truly rubbish, oxymoronic phrase). Nor have they detailed the most outlandish and extreme things possible. All they've done is document what they see as the risks associated with the Health and Social Bill. Nothing more, nothing less.

Now, to end, here's a quick Q&A:

Q: Will releasing the autumn 2010 risk register associated with the Health and Social Care Bill scare the general population?

A: No, although it would be good if the media didn't try to sensationalise anything that was within it. Risk registers are what they say on the tin - they register risks that might occur, and it is a positive and responsible thing to try to document those risks.

Q. Would releasing the autumn 2010 risk register associated with the Health and Social Care Bill now be pointless?

A. No. Things may have moved on, but it should provide an accurate picture of what were the perceived risks at that time. Again, we might need the media to be responsible and recognise that.

Q. Should the Government release the autumn 2010 risk register associated with the Health and Social Care Bill?

A. Yes. They have been instructed to do so by the Information Commissioner. If they wish to also release an up-to-date register to show how things have changed and moved on, no-one is going to stop them.

Q. Should politicians pack up and all go home?

A. ...

You see, it's quite a bit about trust and faith for me. My trust and faith on things to do with the Health and Social Care Bill has long since been used up (mmmm, brains). So the Government might think that they're being smart fighting tooth and nail not to release the risk register, but actually, all it makes me think is wow, its contents must be really, really bad or it must be a really, really shoddy piece of work (or both) for them to kick up such a fuss.

Now you tell me, does that help nurture an informed and productive debate about the major changes to the NHS that are on the horizon?


Wordle: Who's afraid of the big, bad risk register?

P.S. I've stayed pretty focused throughout this post for a change, so here's the wandering off that you've been waiting for... and it is worth waiting for.

Here's Gareth Johnson MP during yesterday's debate - "The BMA (British Medical Association) opposed the very creation of the national health service, so we should take no lessons from such organisations".

Nice one, Gazza. Do you happen to remember who else opposed the creation of the NHS? Yes, that's right. The Conservative Party. We should take no lessons from such an organisation.

P.P.S. I can't believe I forgot to say what the outcome of yesterday's vote was! 246 MPs voted in favour of releasing the risk register, but 299 voted against. So by a majority of 53, the risk register stays safely under lock and key, and every day life can continue. You can rest easy... for now at least.


  1. I don't know enough of the historical detail to judge what the full picture is, but the BMA says on their website that it's a myth that they opposed the principle of the NHS when it was founded. They say that they only opposed doctors being 'salaried officers':

  2. Forgot to add:

    If that's a fair representation of what happened (and as I said, I don't know enough of the detail to judge but I have no reason not to believe the BMA), it means that we should trust the Conservatives even less on the NHS, because while the BMA have remained consistent in their support for the NHS, the Conservatives have flip-flopped from opposition to now claiming to support it (but of course in reality trying to undermine it and dismantle it).

  3. I was near doubled over with laughter at the repeated claim from the Government side of the debate that make the risk register public would somehow affect the contents of future risk registers. It seems that just because the contents would be available to the public, civil servants would feel the need to censor themselves when identifying risks so we can figure out how to mitigate them.

    As a civil servant who has written a number of risk registers in the past I can safely say I wouldn't care in the slightest if a member of the public read what I wrote. What those Government MPs were actually saying was "If we have to publish this then we're going to have to put pressure on civil servants to produce documents that fit our political ambitions."

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