Health and Safetyby Pete Fisher
Managing health and safety
Leadership and commitment are crucial to the success of health and safety management; implementation must therefore be cascaded and enforced from senior management down.
The Health and Safety Policy
In all companies employing five or more staff, there must be a written Health and Safety Policy, outlining the way relevant health and safety legislation will be complied with, and detailing individual responsibilities and procedures to be adopted. The Company Health and Safety Policy is a unique document that details who does what, and when and how they should do it.
The document should be a ‘living policy’, continuously reviewed and updated as circumstances change. It is usually structured in three sections.
1. Policy statement
Apart from being a legal requirement, the most effective demonstration of commitment to health and safety is a Policy Statement, signed and dated by the Managing Director or Chief Executive Officer of the company.
This does not need to be a lengthy document, but it is a statement that the company will strive to meet legislative requirements and supply equipment, training and other facilities with the intention of ensuring, so far as is reasonably practicable, the health, safety and welfare of its employees and others.
This section should provide concise details of health and safety objectives, performance standards and responsibilities.
The health and safety responsibilities of management, supervisors and individuals at all levels should be set out in a precise summary that follows the general language of the company and can be easily understood.
The way in which the company consults with its employees, together with the structure of any related committees, should also be outlined in this section.
In order that health and safety can be effective throughout an organisation, there needs to be clearly defined responsibilities, communication and cooperation between individuals and groups, especially if work involves other companies or contractors.
The size of this section and the amount of detail in it will vary from company to company, but the main headings will cover
- Systems used to monitor performance and Key Performance Indicators
- Staff training
- Specific procedures for
- Risk assessment
- Accident reporting and investigation
- Health and safety pre-qualification of contractors
- Management of contractors
- Use of hazardous substances
- Any other procedures specific to the company
- Auditing and review of the policy.
Health and safety responsibilities
Within HASAW, general health and safety responsibilities are placed on employers to, so far as is reasonably practicable, provide
- Safe plant and systems of work
- Safe handling, storage, maintenance and transport of articles and substances
- Information, instruction, training and supervision
- A safe place of work, with safe access and egress
- A safe working environment and adequate welfare facilities.
There are additional responsibilities that extend to the safety of other persons as a result of work activities or where the employer acts as a landlord.
Employees also have a legal duty to
- Take reasonable care of themselves and others who may be affected by their acts or omissions
- Co-operate with their employer to enable him to comply with his legal duties.
In addition, it is an offence for anyone to interfere with or misuse anything provided in the interests of health and safety.
As well as the general duties above, anyone who has responsibility for someone at work in any guise (director, manager, supervisor, foreman, instructor and so on) also has an element of responsibility for that person’s health and safety. The extent of this responsibility should be detailed in the Company Health and Safety Policy and it is vital that this is known by all concerned.
Although health and safety duties can be delegated down, health and safety responsibilities cannot.
An employer must identify all the circumstances that could put employees at risk while at work and circumstances that may expose anyone else to risk as a result of anything done in his business. He must then determine the level of resource needed to manage those risks effectively.
Without an assessment of the possible risk relating from exposure to or the release of a hazard during work, health and safety cannot be effectively and proactively managed. An objective assessment, based on the experience and knowledge of a competent assessor, is in most cases adequate to identify an appropriate course of action; where there is any doubt, qualified advice or measurement must be sought.
Risk assessment is an essential, proactive management tool, used to identify hazards and implement risk controls prior to work activities being undertaken. Risk assessments are instinctively undertaken before carrying out most day-to-day activities; however, there is a legal requirement for assessments relating to work activities to be documented and made known to all relevant parties.
Someone is competent when they have sufficient training or experience or knowledge and other qualities in relation to the task.
This is something that could cause harm – for example, electricity, bright light or trailing cables.
This is the likelihood of that harm occurring.
This takes account of the nature of the risk and the likelihood of its happening, together with the frequency of the event and the severity of the possible outcome.
Hazard and risk evaluation
The first step with risk assessment is to identify the hazards associated with the task being assessed. This will involve walking around the work area, observing the task and talking to those involved – this aspect of an assessment cannot be done remotely from a desk. Where machinery, tools and electricity are involved, the hazards may be obvious, but you should also consider others, such as handling, noise, lighting and trips.
For each hazard, consider who may be harmed; in most cases this will not be limited to the operator. Think about other staff in the area, as well as cleaners, contractors, visitors and the public. If children are likely to come into contact with the work, additional controls may be required. Also take into account any special requirements particular workers may have as a result of any disability or medical condition.
Once the hazards are noted, the level of risk attributed to them should be evaluated. This must take account of the severity of the possible outcome (finger cut as opposed to a broken limb or worse) and the exposure (one person once a month or a number of people each day). The most common method of assessing risk is against a matrix of likelihood and severity which then equates to High, Medium or Low risk or possibly a numerical value (see also Risk Management). If used, these charts will be found in the Company Health and Safety Policy. An example of a filled-in chart is given below.
|Harm||Never heard of in our industry||Heard of in our industry||Has occurred in our company||Occurs several times a year in our industry||Occurs several times a year in our company|
All risks, regardless of the level, must be managed and where possible reduced. Ideally, the hazard should be eliminated, but this may not be possible and controls must therefore be implemented. Concentrate on significant hazards first; combating low risks may not be viable or can be programmed in for when time and budget allow.
The level and complexity of risk controls will be dependent on the severity of the likely outcome. In other words, if it is likely that someone could be killed, much tighter controls will be required than if the most severe outcome is a minor injury. The recommended hierarchy of controls is as follows:
- Hazard elimination – use an alternative method or design
- Substitution – replace the machine or chemical with a less hazardous one
- Barriers – remove the hazard from the worker or keep the worker away from the hazard; barriers may also need to be interlocked to the machinery so that moving parts stop if the barrier is broken
- Operating procedures – implement a safe system of work (see below) or restrictions on exposure, where noise or extreme temperatures are involved, for example
- Warning systems/signs – visual and/or audible warnings of the hazard
- Personal Protective Equipment (PPE) – make PPE available (such as eye, hearing or respiratory protection or high visibility clothing) and enforce its use. Users must be given instruction on when and how to use the equipment. PPE is a last resort as it depends upon human response, which is not infallible!
It is likely that some risk assessments will identify circumstances in which health surveillance is appropriate. In certain circumstance – when working with lead, for example – this is mandatory.
In these circumstances, the company should make arrangements with a competent occupational health practitioner, who will advise on an appropriate programme of checks.
MHSW requires that all risk assessments are documented and made available to the relevant persons. They should also be reviewed periodically (usually annually) or when circumstances change – for example, when new equipment is introduced or there is a change in processes – and this information is passed on to the operatives.
Whether or not required by legislation, it is best practice to record other information, such as routine checks/tests, maintenance data, modifications, inspections and disposal records. In this way, managers will be able to identify whether any gaps or trends are developing and also be able to prove due diligence during any audit or investigation.
Safe systems of work
Where a risk assessment has identified that elements of risk still exist after controls have been applied, a documented safe system of work will be required. This is a formal procedure that identifies safe methods of working, thereby ensuring that the remaining risks are minimised.
For example, cleaning or repairing a fault situation on a mixing machine will necessitate removing guards and barriers designed to contain the hazards. A more formal analysis of the work is therefore required and the task must be broken down into stages, with particular precautions specified at relevant points.
All stages of the task must be looked at and the system must be written down, to ensure that the same procedure is followed each time. A manager should undertake the initial drafting of the Safe System of Work, together with the workers involved. The system must take account of
- What is used – plant, substances, tools, testing equipment and so on
- Sources of energy – electricity, retained potential energy and so on
- Where the task is carried out – at height, in a confined space and so on
- How the task is undertaken – potential failures in work methods, frequency of task, training needs, supervision and so on.
Once implemented, the safe system should be monitored and modified if an alternative, safer method is developed.
Monitoring/audit and review
In every other aspect of business, companies measure performance to establish where they are in comparison to targets, KPIs and the competition. When new equipment or technology comes on line, processes are reviewed to identify how those factors have affected business plans and finances.
Managing health and safety is no different!
An efficient manager needs to be proactive and regularly check day-to-day operations against risk assessments and procedures, to ensure set standards are being achieved and risk controls remain effective.
There are two types of monitoring:
- Proactive – used to measure the achievement of objectives and standards before something goes wrong, resulting in injury or damage to property; this usually involves inspection, checks and measurements
- Reactive – used to collect data and information for analysis after a failure in controls and performance; the information should be used to implement changes that subsequently improve performance or prevent a recurrence of the failure.
Proactive monitoring can involve local initiatives, such as ad hoc management walk rounds, health and safety discussions or presentations at team meetings, staff suggestions and feedback, as well as the planned actions contained within the Health and Safety Policy and business plans.
An established Health and Safety Policy or management system will require formal audit, usually on an annual basis, to provide feedback and recommendations for improvement to senior management. This audit can either be done internally, if the skills exist within the company structure, or through the use of external consultants.
Health and safety training and supervision
General legal duties are placed on employers in HASAW, MHSW and other regulations to provide adequate training and supervision. Staff must be given appropriate information covering the company’s procedures (in particular, emergency procedures) and methods of reporting; this is usually carried out during the induction training of new staff.
Other, more specific, training on the operation of equipment, safe systems of work, risk controls and so on should be identified by risk assessment and given to relevant staff. Training records should be maintained to identify trained staff, indicate when refresher training is required, and for auditing purposes.
Health and safety planning
In all fully committed companies and organisations, health and safety is recognised as being of equal importance to other business objectives; as such, it is fully incorporated into day-to-day working practices and contracts with third parties.
Health and safety should form an integral part of business planning and management processes, including annual budgets. In this way, the health and safety culture and awareness can continuously improve as the business evolves. A fully functional Health and Safety Policy and/or management system will operate as an enabler to business development.