Managing safety

To be successful, health and safety management is best included in all normal business procedures, just as one would approach issues such as quality control or financial accounting. It is also important there is high level commitment towards securing good health and safety standards. As with quality issues, there should be the recognition for continued monitoring and improvement as an ongoing management responsibility.

The Health and Safety at Work Act 1974 requires businesses to produce health and safety policy documents. These documents can provide the basis for setting out clearly the management policies of the company and provide the means for recording health and safety management arrangements.

The key elements of successful health and safety management are:

• clear policy

• organising

• planning

• implementation, including staff consultation and training

• measuring performance

• auditing and review

Policy

The aim of sound health and safety policy is to apply the logic and rigour of business planning to the identification and control of risks.

To set relevant and workable policy, it is important to analyse work practices, systematically identify risks and establish objectives and performance standards – this is achieved by carrying out risk assessments.

The following areas of business are influenced by effective health and safety policies:

• corporate strategy

• finance

• human resources

• marketing, product design and product liability

• manufacture and operating policy

• information management and systems

Organising

To secure the implementation and continued development of health and safety policy, it is essential to have a clearly defined structure to manage the implementation of procedures. Responsibilities of individuals involved in health and safety at all levels of the organisation must be established, as must the relationships between these people.

The aims of the organisation should be to:

• establish and maintain management control within the organisation

• promote co-operation between individuals, safety representatives and groups so that health and safety becomes a collaborative effort

• ensure communication of relevant information throughout the organisation

• secure the competence of employees

Planning and implementation

To be successful in health and safety management, it is necessary to draw up plans and set performance standards, with the overall aim of eliminating and controlling risks.

These will define what standards of health and safety the organisation is aiming to achieve, how they will be accomplished, and the timescale for achievement.

The planning and implementation process will result in operating and maintaining systems that will:

• identify objectives and targets for their achievement within a specified period

• set performance standards for management actions

• set performance standards for the control of risks to employees and others affected by work activities (for example, customers and visitors)

• establish priorities for provision and maintenance of control measures

• ensure adequate supporting documents for all performance standards

Training helps develop a health and safety culture in an organisation and is important at all levels within a company.

In devising control measures, employers and the self-employed must consider the hierarchy of risk management:

1 If possible, completely eliminate the hazard so that risks can be avoided altogether.

2 If not possible, tackle the hazard source.

3 Failing this, priority should be given to measures to control the risk that will protect all workers.

4 As a final resort only, measures must be undertaken to control the risk by means of personal protection.

Measuring performance

In order to check that the health and safety standards are actually being achieved in practice, it is necessary to measure performance against the pre-determined plans and standards.

Any areas where the planned standards are not being fulfilled should be identified for remedial action.

The types of systems that can be used to monitor health and safety performance include:

• active monitoring systems

• reactive monitoring systems

• reporting and response systems

• investigation systems

Active monitoring systems

Measure health and safety performance on a routine basis, eg spot checks by a supervisor.

Reactive monitoring systems

Identify where health and safety standards are not being met by monitoring for failures in the systems – such as accidents, cases of ill health, damage to property, etc.

This requires the setting up of reporting systems for notifying accidents, analysis of health surveillance data etc within the organisation.

Reporting and response systems

Ensure that monitoring information is evaluated by people competent to identify situations that create an immediate risk to health or safety, as well as longer term trends. They must have sufficient authority to ensure that appropriate remedial action is taken.

Investigation systems

Effective investigation ensures:

• priority is given to incidents that indicate the greatest risk

• identification of both the immediate and the underlying causes of events

• information reaches management with sufficient authority to start remedial action, including changes to policy and the structure of the organisation

• adequate analysis of all collected data to identify common features or trends and initiate improvements at an organisational level

Audit and review

This is the final step in the health and safety management cycle. Together, performance auditing and review constitute the ‘feedback loop’ needed to enable the organisation to maintain and develop its ability to manage risks to the fullest possible extent.

Auditing and review ensures that any inadequate performance is identified and appropriate remedial action is put into effect.

Auditing methods

Regular auditing of health and safety systems can identify whether they have deteriorated or become obsolete. Auditing needs to be comprehensive and examine over time all the components of the health and safety management systems in an organisation. Various methods of auditing can be used, but these can be broadly divided into two approaches:

• ‘Vertical slice’ auditing – examining one specific aspect of health and safety, eg emergency arrangements or fire safety, to see if it meets all the management requirements.

• ‘Horizontal slice’ auditing – examining one particular element of the health and safety management system in detail, eg an in-depth examination of the process of defining health and safety policy or planning.

Health surveillance

The purpose of health surveillance is to monitor the health of employees so that any adverse effects that results from activities in the workplace can be detected as early as possible.

It is necessary to draw up plans and set performance standards, with the overall aim of eliminating and controlling risks.

If risk assessments indicate that health surveillance is required, this should continue throughout the worker’s employment, unless risks are short term. Individual health records must be kept.

The health surveillance technique(s) used will depend on the condition(s) to be detected. It is important that the appropriate surveillance methods are adopted. To ensure this, it may be necessary to seek medical advice. It may also be appropriate to introduce more than one surveillance technique.

What is health surveillance?

Health surveillance is any means by which adverse health effects of work activities can be monitored among the workforce. Procedures can include:

• inspection of easily recognisable conditions by a responsible person, eg visual skin inspections for dermatitis by a supervisor

• enquiries about symptoms, inspection and examination by a qualified person such an occupational health nurse, eg questionnaires concerning relevant symptoms such as wheezing, tightness of the chest etc, which could indicate occupational asthma

• medical surveillance, which may include clinical examination and measurements of physiological or psychological effects by an appropriately qualified practitioner, eg X-ray examination of lungs

• biological effect monitoring – the measurement and assessment of early biological effects, eg lung function testing

• biological monitoring – measurement and assessment of potentially harmful agents or their metabolites in body tissues, fluids, eg blood or urine samples

When is health surveillance required?

Health surveillance will be required when specific health and safety regulations apply and where assessment shows the following criteria to apply:

• there is an identifiable disease or adverse health condition related to the work concerned

• valid techniques are available to detect indications of the disease or condition

• there is a reasonable likelihood that the disease or condition may occur under the particular conditions of work

• surveillance is likely to further the protection of the health of the employees to be covered

Help in complying

Appointment of competent persons to assist in health and safety management should be included as part of the health and safety arrangements and be recorded by employers of five or more workers.

These ‘competent persons’ must be employees by preference. External expert consultants may be appointed, although only in an advisory capacity. Sole traders or members of partnerships may appoint themselves or other partners – as long as they are competent.

Employers should be aware that they cannot delegate their legal responsibilities owed to their employees and others. Although they are required to appoint competent persons to assist them in health and safety management, and can delegate responsibility for managing aspects of health and safety within their business, the responsibility remains with the employer.

Emergency procedures and dangerous situations Employers have to set up procedures to deal with serious danger situations, emergencies and evacuations. They must nominate enough competent people to implement evacuation procedures.

Since December 1999, employers have been required to make contact with providers of external emergency services – the regulations making explicit reference to first aid, emergency healthcare, and the potential providers of any rescue service.

Health and Safety Executive guidance says these arrangements need:

• be no more than publicising emergency contacts among employees in low-hazard working environments

• to involve staff who understand the hazards present in high risk or complex workplaces, so that proper advice is given to the emergency services when contact is made.

Information for employees

This covers information explicitly required by legislation (for example, the Health and Safety Executive’s display poster: ‘Health and safety law: what you should know’) and specific information relevant to health and safety risks in your workplace.

Risk assessments will help to identify what information is necessary.

Information can be provided in whatever form is most suitable for your circumstances. For example, it can be provided:

• in the form of posters or notices displayed in the workplace

• as written information supplied to employees

• as video or audio tapes

• verbally

The most important thing is that it should be understood and remembered by the employees concerned. It is very important to recognise that some of employees may have little or no understanding of English, may not be able to read English or may be visually or orally impaired.

Special arrangements should be made to overcome these problems. This could include provision of translations, use of interpreters, or substitution of symbols or diagrams for written information.

The requirement for provision of information applies to all employees, including trainees and those on fixed-duration contracts.

Elected representatives must be given adequate training, time off and facilities to enable them to carry out their functions.

For young persons under school leaving age on work experience, basic health and safety information must also be made available to their parents before they take up work. This information must include details of the risk assessment of the work the child will be involved in.

Training

Employers must ensure that, when they allocate work to employees, the demands of the work do not exceed the individual capabilities of their employees. This will include physical and mental abilities and the level of training and experience. Risk assessments should determine the appropriate level of training for different tasks. All health and safety training should take place in work time.

Training helps develop a health and safety culture in an organisation and is important at all levels within a company, including top management. It should be relevant to the health and safety requirements of the work performed and should be reinforced regularly.

The type of training will vary according to the health and safety issues to be covered Often, the best form of training will be on the job, allowing the trainee to learn good practice in situ. But this may not always be practicable and it may be necessary to supplement this type of training with at least some classroom activities. Particular consideration should be given to the needs of young workers.

Training should always be delivered by a person who is competent to do so. For on the job training, this may well be just an experienced worker or supervisor.

For other issues, input from a health and safety officer or manager may be required. Outside trainers may also be used and some specialist areas may necessitate their help, particularly training for specific skills, eg training a fork-lift truck driver.

Types of training that should be addressed include:

• induction training

• job-specific training

• training to respond to changes in the work environment

• refresher training

Induction training

Training needs are likely to be greatest when a new employee joins a company.

All new employees should receive basic induction training on health and safety, including procedures for first-aid, fire and evacuation. Special attention should be given to the needs of young workers, including those on work experience.

Job-specific training

Risk assessments should identify where work tasks require specific training. This should address defined safe systems of work, and any specific areas of risk or aspects requiring special skills, eg manual handling, machinery operation, fork-lift truck driving.

Changes in working environment

Further training should be considered when:

• employees transfer or take on new responsibilities

• there is a change in the equipment or systems of work in use

Refresher training

It will be necessary to repeat training periodically to avoid complacency and a decline in skills. Competency will fall if skills are not used regularly (eg emergency procedures). Special attention should be given to employees who occasionally deputise for others – because their skills may only rarely be used, they are likely to require more frequent refresher training.

Where skills are used regularly, it may not be necessary to repeat whole training programmes and it may be more relevant to concentrate on key areas where staff are likely to develop bad practices through habit or complacency.

Information from routine health and safety checks, accident and near miss investigations and personal performance monitoring can help to establish suitable periods for re-training and the key areas where attention is required.

Consultation with employees

Where employees are represented by recognised trade unions, they have a statutory right to appoint their own safety representatives. These safety representatives will act as a focal point of communication between employers and employees.

They have specific functions and rights, and employers have legal obligations towards them in allowing time to carry out their functions. They must also provide relevant information on health and safety issues within the workplace. Employers must set up a health and safety committee, if requested by safety representatives.

Where there are employees who are not represented by trade unions, employers still have a duty to consult with them on health and safety issues, specifically:

• any measures that may substantially affect their health and safety

• arrangements for appointing or nominating competent persons

• health and safety information required by law to be provided to employees

• planning and organisation of health and safety training required by law

• health and safety consequences of the introduction of new technologies into the workplace

This consultation must take place in good time to allow employees to express their views and for these to be taken into account before any decisions are made in relation to these issues. Adequate information must be made available to employees for them to participate fully and effectively in the consultation process.