The deadline of 1 July 2026 for the Governance Code for Safety in Construction (ViA) is fast approaching. For many organisations, this means a mandatory transition to at least Level 3 of the SCL. Putting theory into practice – and specifically filling in the mandatory 'behavioural objectives' in the web tool – often causes some trepidation. Can safety culture really be captured in hard targets? SCL trainers and knowledge partners Frank Thoonen and Wilfried Vermeiren cross swords, but share one firm conclusion: "You can set out a procedure, but a safe culture is something you have to live."
For SCL Light and SCL Light for small organisations, it is compulsory to submit an annual report via the web tool to set one to three behavioural objectives. According to the certification scheme, these must be ‘SMART’ (Specific, Measurable, Acceptable, Realistic, Time-bound). In practice, this often leads to frustration.
Frank Thoonen, of THOON Organisational Consultancy, doesn’t mince his words: “I sometimes react a bit negatively to auditors who rigidly stick to SMART objectives”. He sees small businesses struggling with theory, when it’s all about practice. “Suppose a managing director notices that half the staff aren’t wearing safety shoes. He discusses the issue with them; the men are allowed to choose a more comfortable pair themselves, and six months later everyone is wearing them. What does it matter ”Was that objective formulated on paper as 100% SMART? If so, that company has taken a huge step forward.”.
Wilfried Vermeiren of the consultancy firm Samurai at Work understands the aversion to tick boxes, but warns business owners not to let safety get bogged down in abstract terms. “To me, working safely is a matter of interpretation; it’s not a fact.” He emphasises that behaviour must always be objectively observable. “If you see someone acting in a certain way and you describe that behaviour, then you and I should observe exactly the same thing. Only then are you being objective and can you steer behaviour accordingly.”.
Although the approaches of both experts therefore differ slightly, they ultimately reach a joint conclusion: a SMART formulation is merely a tool and a method for structuring the discussion, but by no means an end in itself. What really matters in practice is that management and staff work together to find solutions that have an immediate and demonstrable impact on the shop floor. If the drive to achieve a theoretically perfect, clearly defined objective takes precedence over the actual if it stands in the way of improving safety, the whole process completely misses the mark
Pitfalls: “I’m going to bully people less”
A common mistake made by SMEs is that they set targets that are too ambitious or unclear. “We come across targets such as ‘everyone calls each other out on unsafe behaviour’ all the time,” says Wilfried. “But good luck with that; it’s simply not going to happen in a small organisation that’s just starting out. That’s Step 4 or 5 behaviour.” Goals such as “I’m going to bully less” also fall by the wayside, because they’re subjective.
His golden tip for putting behaviour down on paper? “Describe it in the present tense. Don’t say ‘I will’ or ‘I want to’, because that isn’t powerful enough”. He also recommends avoiding the word ‘don’t’: “The human brain doesn’t understand negatives. So don’t say ‘you mustn’t walk under a load’, but state the desired behaviour.” What’s more, keep it simple: a maximum of three to five clear rules to focus on.
The Web Tool (SAQ): Not a survey, but a mirror
Before setting targets, you must complete the questionnaire within the SCL Webtool (SAQ) for SCL Light and SCL Light for small organisations. This is the baseline assessment, but never simply complete it from the boardroom. “It’s not a survey where you should just ’tick boxes’ or provide socially desirable answers”. Wilfried advises management teams to bring staff together in small groups and discuss the questions with them before rolling out the survey, so that everyone understands it and an accurate picture emerges.
Frank then emphasises the true value of these results: “The internal auditor can use the tool to discover that the manager scores very highly on a particular topic, whilst the employee says they haven’t even reached Level 2 yet”. It is precisely in that blind spot (the perception gap) that your first behavioural objective lies hidden.
The CEO in the Audi
A successful transition to Level 3 stands or falls on authentic leadership. According to Wilfried, simply signing a policy statement is not enough: “Providing resources and training is all well and good, but what are you personally doing? How do your staff on the shop floor perceive that you prioritise safety?”.
Frank gives a painfully familiar real-life example. “The CEO may feel he’s being very sociable. But he needs to realise that when he steps out of a posh Audi onto the building site in his three-piece suit, panic can sometimes already set in amongst the workers.” He argues that senior management should literally “break the ice”. “Go and have a coffee in that site hut for a change. Ask what it’s like to be standing in the mud and clay. If you come across as genuine, people are quite willing to work hard for you and behave safely; they won’t put on a show just to climb the SCL ladder.”.
Take action before 1 July 2026 Are you feeling a bit daunted by the ViA deadline or the SCL Light (for small organisations)? Don’t get bogged down in theory – have a look at it roadmap or contact one of the independent SCL Knowledge Partners to provide you with seamless support.