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NEBOSH International Certificate
Distance Learning
IGC1 - Management of International Health & Safety
Phoenix Health & Safety
Ticking all the right boxes
T: 0845 500 8811
NEBOSH International Certificate
Distance Learning
Management of International Health & Safety
Phoenix Health & Safety
Ticking all the right boxes
E: info: phoenixhsc.co.uk W:
NEBOSH International Certificate
Management of International Health & Safety
W: www.phoenixhsc.co.uk
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 2 of 133
Contents
Page
Element 1 – Foundations in health & safety 3
Element 2 – Health & Safety Policy 19
Element 3 – Organising for Health & Safety 36
Element 4 – Promoting a Positive Health & Safety Culture 59
Element 5 – Risk Assessment 77
Element 6 – Principals of Control 90
Element 7 – Monitoring, Review & Audit 106
Element 8 - Incident and Accident Investigation, Recording and Reporting 118
Tutor Marked Assessment (TMA) 131
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Element 1 – Foundation in Health and Safety
Key Learning Outcomes
At the end of this element, you should be able to:
Outline the scope and nature of occupational health and safety
Explain briefly the moral, legal and financial reasons for promoting good standards of health and safety
Outline the role of national governments and international bodies in formulating framework for the regulation
of Health and Safety
Identify the nature and key sources of health and safety information
Outline the key elements of a health and safety management
Introduction
The Management of Health and Safety is a broad subject, and incorporates aspects from many other disciplines, such
as the Sciences, psychology and ergonomics. Based in legislation the requirements to manage health and safety places
a number of requirements on the employer and employees and failures in these duties can result in prosecution which
can lead to fines and imprisonment.
In this first Element, you will be introduced to the scope of Health and Safety and the three main reasons for effective
management which consist of Moral, Legal and Financial reasons. We will also outline the role of national governments
and international bodies in formulating framework for the regulation of Health and Safety. The Element will also give you
an understanding of the key sources of information of health and safety and outline the key elements of a health and
safety management system.
The Scope and Nature of Occupational Health and Safety
Multi Disciplinary Nature of Health and Safety
Health and Safety spans across all of the different industries and professions found in the Workplace. This means that
the subject itself is vast and complex. Safety legislation has to consider and make provisions for the variety of industries
in existence across the United Kingdom. In order to achieve this, Health and Safety has to include a multi disciplinary
approach and incorporate the knowledge from backgrounds such as Engineering, Chemistry, Physics, Biology and
Psychology to name a few.
Due to the many different aspects involved within Health and Safety there can be competing and conflicting demands.
For an organisation to be successful there needs to be a balance between earning and spending, between profit and
loss. Equally, Health and Safety standards will aim to ensure that suitable provision is made within each organisation to
ensure that in the pursuit of gain, the employer is not unreasonably exposing their workforce to situations that could put
them in danger and lead to loss of life or impact on health. With so many disciplines involved across a wide range of
industries it would be an overwhelming task to legislate for every eventuality. To balance this, Health and Safety
Legislation is generally non prescriptive, allowing for interpretation and implementation of best practice, suitable for the
nature of the organisation seeking to comply.
Barriers to good standards can be varied. Economically, some organisations choose to see Health and Safety as a cost,
a legal requirement that will provide no benefit to the organisation except for ensuring compliance. This is a very narrow
view of the discipline and it is one that we will discuss in more depth later in this element to dispel this myth. There are
other barriers that need to be noted, the general perception of safety in the workplace can be negative and can be
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viewed as more interested in stopping people working than keeping people safe. The fact that Health and Safety
legislation is not prescriptive can also cause confusion. A common criticism is that the legislation is not clear and that
the regulations lack a definitive rule to ensure compliance. As we have discussed briefly, this is simply not practical,
because not every organisation will be able to implement measures in a set way due to the complexities and differences
of organisations and other industry compliances that may also be required.
Health and Safety is not just concerned with objects and premises, predominantly the objective is to protect people. To
do this introduces a broader challenge, as it is an extremely difficult exercise to legislate for behaviour. Health and
Safety legislation however, does seek to incorporate human failure and draws on psychological studies to assist with this
task. This has lead to the development of Behavioural Safety as a discipline and the approach of engaging the
workforce to re educate negative cultures and improve the standards within the workplace.
Health, Safety, Welfare and Environmental protection
Due to the complexities of Health and Safety, there are four main areas where protection will need to be afforded. We
are obviously concerned with the Health of workers, and this can be affected by work through a multitude or reasons.
Health is concerned with the physiological and psychological well being of the workforce. It will need to consider both
short and long term illnesses and injuries, ill health caused through exposure to substances and any psychological
illnesses too.
Safety of the workforce involves the risks on a day to day basis that may lead to accidents occurring and how the
workplace can be best managed to prevent incidents that may affect the overall safety of the workforce, the individual
and the buildings, including plant and equipment that are present.
Welfare is also a consideration within Health and Safety management and legislation. Appropriate welfare facilities are
required for any workplace and this should include toilets, rest areas and washing facilities where appropriate.
Environmental protection is given consideration within Health and Safety. Although there have been acts introduced
which specifically focus on the Environment, there is a need to ensure that the environment within which workers will be
required to work is safe and without risk. This will include assessing buildings and premise, the effects of the
environment for outdoor workers and the effects that any operations may have on the environment.
Each of these four areas will need consideration when assessing risks and implementing safe systems of work. They
need to be an integral part of an organisations health and safety arrangements.
Occupational Accidents, Dangerous Occurrences, Near Misses, Work-Related Ill-Health and Commuting
Accidents
To manage health and safety effectively, an organisation must be aware of the nature of incidents that might occur within
the workplace. We will discuss these terms again in more depth during the rest of the course, but for an introduction,
you will need to be aware of the definitions of accidents, dangerous occurrences, near misses and work related ill health
and also be aware that the impact that these might have in relation to physiological and psychological effects.
Occupational Accidents:
“An unplanned and undesired event which results in harm to person or damage to property”
Dangerous Occurrences:
Dangerous Occurrences are events where had the inputs been different, could have resulted in a major incident.
This could be something like a small fire, which luckily was spotted but could have been a major fire if it had happened at
a different time of day for example.
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Near Misses:
“An unplanned and undesired event which, under slightly different circumstances, could have resulted in harm to person
or damage to property”
Work Related Ill-health:
In terms of Health and Safety, Ill Health refers to an illness which has been developed as a result of exposure to
something within the workplace. A topical example of Ill Health is Asbestosis, a disease which is contracted due to
inhalation of Asbestos fibres. It also covers issues such as Stress or Depression as a result of pressures at work.
Physiological effects are concerned with the body and how events in the workplace will affect the body and the types of
harm that could result, typical examples can range from serious damage such as broken bones, contracting of illnesses
such as cancer through to minor knocks and cuts.
There are also psychological effects that a worker may suffer such as stress and depression. Psychological effects are
concerned with how events in the workplace will affect the workers mental health and the types of harm that could result,
such as loss of confidence, mental breakdowns to give a few examples.
It is worth noting that physiological and psychological effects are not mutually exclusive and often occur together due to
the effects of an accident.
Commuting Accidents
Hazard and Risk
The concepts of Hazard and Risk will be explored in more detail in later elements, as they form a core aspect of the
management of health and safety.
It is important that these terms are understood and that you are clear on the difference.
A Hazard is anything with the potential to cause harm
A Risk is the likelihood that harm will occur and the severity of that harm.
The Moral, Legal and Financial Reasons for Maintaining and Promoting Health and
Safety
The Health and Safety “Problem”
The media puts much emphasis on the restrictions of Health and Safety, often using “The World Gone Mad” scenarios,
which have prevented events going ahead, or restricted the liberties of individuals and cited health and safety (mostly
incorrectly) as the cause.
The extent of the problem that is faced nationally is undermined by such reporting. Health and Safety still has a long
way to go, to take an example nation with the United Kingdom, despite the wealth of Legislation a lot is still going wrong,
which the following figures confirm:
Each year in the UK;
245 work related deaths
30,000 major injuries
130,000 over three day injuries
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38.5 million work days lost
25,000 people leave the workforce due to harm suffered at work
It is worth spending a few minutes looking at these figures and figures for the Country in which you are based, the ability
to recall some of the statistics will assist you in this course.
The need to provide a safe place of work, safe plant and equipment, safe systems of work, training and
supervision and competent employees.
The Health and Safety “Problem” clearly identifies that there are many things that an organisation can proactively
manage to help to mitigate the risks of serious injury or ill health. Within the ILO Guidelines on Occupational Safety and
Health Management Systems and within the Occupational Safety and Health Convention it is clearly identified that
Employers should provide the basics of:
A safe place of work
Safe plant and equipment
Safe Systems of Work
Training and Supervision
Competent Employees
Each Nation will make suitable provision for this within their National Legislative Framework; in the United Kingdom for
example these duties form Section 2 requirements of the Health and Safety at Work etc Act 1974.
We will discuss these arrangements in more detail in later sections, but it is important that you are familiar with the basic
requirements and how they are implemented within the Country in which you work/live.
The Business Case for Health and Safety
There are associated costs for the effective management of Health and Safety, and for every business before
investment is made, the Organisation will want to understand the benefits that the service will bring. The decisions on
how best to manage health and safety within an organisation will require some investment, which the organisation would
ideally like a return on. The benefits of health and safety can’t be measured in the standard way of using sales
forecasts, but there are significant cost benefits that you will need to be aware of and utilise in persuasion of the need for
investment to improve Health and Safety.
Health and Safety is deeply rooted within the means to prevent accident and injury and it is when such events take place
that the true costs of the failure to manage safety are most apparent.
When an accident occurs, there are two types of costs that are accrued; these are known as Direct and Indirect. Direct
costs are concerned with the immediate costs of the accident. These will include the damage to any equipment, the
cleanup of the accident and the loss of the worker if they have to take a leave of absence. Indirect costs are concerned
with the less obvious costs, such as replacement labour, loss of sales, and loss of confidence of the workforce which
may result in employees deciding to leave the company.
The following diagram illustrates that the Insured costs are just the tip of an iceberg and underneath are far more
substantial costs that can’t be insured- uninsured costs.
© Phoenix Health & Safety 2011
The uninsured costs are estimated at around ten times the amount of the actual incident. These consist mostly of
indirect costs. More examples include:
Product and material damage
Lost production time
Legal costs
Overtime & temporary labour
Investigation time/Administration
Supervisors time
Fines
Loss of expertise/experience
Loss of morale
Bad publicity
There a lots of reasons to have a good health and safety management system, they can be categories under three main
headings, Moral, Legal and Economic reasons.
Moral
Employers have a duty of reasonable care to those affected by the undertaking. It is also deemed as socially moral for
organisations to seek to reduce accidents, injuries and the pain and suffering of employees in th
gain. Morally it is not acceptable to put employees at risk or to expect them to risk life or limb in order for the organisation
to make money or to achieve its goals.
IGC1: Management of International
The uninsured costs are estimated at around ten times the amount of the actual incident. These consist mostly of
Investigation time/Administration
There a lots of reasons to have a good health and safety management system, they can be categories under three main
d Economic reasons.
Employers have a duty of reasonable care to those affected by the undertaking. It is also deemed as socially moral for
organisations to seek to reduce accidents, injuries and the pain and suffering of employees in th
Morally it is not acceptable to put employees at risk or to expect them to risk life or limb in order for the organisation
International Health & Safety
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The uninsured costs are estimated at around ten times the amount of the actual incident. These consist mostly of
There a lots of reasons to have a good health and safety management system, they can be categories under three main
Employers have a duty of reasonable care to those affected by the undertaking. It is also deemed as socially moral for
organisations to seek to reduce accidents, injuries and the pain and suffering of employees in the pursuit of financially
Morally it is not acceptable to put employees at risk or to expect them to risk life or limb in order for the organisation
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Legal
Legal reasons for having a good safety management system are that it will help to ensure compliance, which in turn will
make Enforcement Action, such as notices and prosecution, which could lead to fines and imprisonment, less likely to
occur.
Controlling the risks effectively within the workplace will also prevent serious injury which in turn will reduce the likelihood
of Claims seeking compensation for losses or injuries.
Economic
An effective health and safety management system will assist in avoiding costs of repairing/replacing damaged plant and
equipment and the need to hire additional equipment. It will also avoid costs such as additional labour.
Effective health and safety can improve production and product quality and boost motivation within the workforce. This
will lower the staff turnover rate and save on costs such as retraining and job advertising. In turn, a motivated workforce
and improved productivity will have a positive impact on the organisations image and reputation and will assist with the
development of goodwill and stronger relationships with other organisations.
Through the reduction of accidents and claims, Insurance issues will be less costly, such as achieving lower premiums
due to the organisation demonstrating that it is a low risk.
Internal resources will not be drained due to accident and incident investigations, attending court and facilitating
enforcement officer visits, which can be very time consuming if the organisation is constantly involved with incidents.
Directly associated with this is the avoidance of additional uninsured costs indirect , such as cleaning up area/ first-aid/
administration/ other staff days off due to stress.
Employer’s Liability Insurance:
Legally an Employer must have Employers Liability insurance. This insurance must be a minimum cover of Five Million
within the United Kingdom. The Certificate of Insurance must be on display within the workplace to fulfil the legal
requirements.
The role of national governments and international bodies in formulating a framework for
the regulation of health and safety
Employer’s responsibilities
The Guidelines provided by the ILO, Guidelines on Occupational Safety and Health Management Systems (ILO-OSH
2001) clearly identifies the Employer’s responsibilities in so far as producing management systems. Key international
bodies such as the ILO target ensuring that there is fair and equal representation for workers rights and works closely
with its members to achieve harmonised standards.
Based on the guidance from organisations such as the ILO, National Governments will set their own legislation to
encompass the key principles. For example, in the United Kingdom this has been achieved through Section 2 of the
Health and Safety at Work etc Act 1974.
Section 2 (1):
Every employer must ensure, so far as is reasonably practicable, the health, safety and welfare at
work of all his employees
Section 2 (2):
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More specifically, employers must provide:
a) Safe plant and systems of work
b) Safe use, handling, storage and transport of articles and substances
c) Any required information, instruction, training and supervision
d) A safe place of work, including safe access and egress
e) A safe work environment with adequate welfare facilities
Section 2 (3):
Employers with 5 or more employees must:
Prepare a written health & safety policy
Set down the organisation and arrangements for putting the policy into effect
Revise and update the policy as necessary
Bring the policy and arrangements to the notice of all employees
Section 2 (4-7):
Employers duties to consult with employees
Now more specific regulations on the subject
Section 3:
Every employer and self employed person must conduct their undertaking in such a way as to ensure,
so far as is reasonably practicable, that persons not in their employment who may be affected, are not
exposed to risks to their health & safety
Individual Countries will have their own provisions and it is important that you are aware of the scope of an Employers
responsibilities. In essence, particularly for those within the EU, directives are issued which outline the key elements
which a country must introduce into its legislation, but how it is then enforced is up to the individual country to decide.
Effectively this ensures that there are shared principles across Countries, but the referencing will differ.
Worker’s responsibilities and rights
It is essential that within the standards set out for Health and Safety that the issues of workers’ rights and responsibilities
are also sufficiently detailed. The ILO is keen to ensure that vulnerable groups are specifically considered, but this has
not removed the requirement to place duties on the individual. Drawing once again on the United Kingdom’s provisions
for this requirement, it is clear to see that with the scope of the Act, this has been given full consideration.
Section 7:
Employees Duties:
To take reasonable care of themselves and others who may be affected by their acts or
omissions at work
To co-operate with their employer to enable him to comply with the law
Section 8:
Duty on Every Person:
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No person may misuse or interfere with anything provided in the interest of health, safety or
welfare
Not limited to employees
There are also Regulations that are concerned with “Vulnerable workers” such as new and expectant mothers and
Young Workers.
The role of enforcement agencies and the consequences of non-compliance
In each individual Country the nature and role of enforcement agencies will essentially be similar. The reason for the
creation of the enforcement agencies is to ensure that any Health and Safety laws are complied with. To breach such
laws will result in criminal action. It is therefore essential that you understand how the laws are upheld in the Country in
which you live and/or work, as this will significantly differ between Countries.
To allow further elaboration on this topic, I will use the example of the United Kingdom, although specifically England
and Wales.
Health and Safety Executive:
Historically the Health and Safety Commission, who were involved with policy making and regulations and the Health
and Safety Executive who were involved with enforcement of the regulations, had key responsibilities as external
agencies for ensuring Health and Safety within UK. In April 2008, the HSC and the HSE merged, taking on the name of
the Health and Safety Executive, but incorporating both roles.
The role of the Health and Safety Executive is now twofold. They advise the Secretary of State in the creation and
amendment of Regulations and they also provide information and guidance for all Industries. The Health and Safety
Executive also provide Enforcement for directly regulated industries and we will learn more about inspectors and their
powers shortly.
Activities that are enforced by the Health and Safety Executive include:
Construction
Mine or quarry work
Fairgrounds
Agriculture
Broadcasting and filming
Railways
Local Authorities:
Local Authorities provide enforcement for industries that are not directly regulated by the Health and Safety Executive.
This is achieved through Local Authority Inspectors, who work to the same guidance and with the same authority as
Health and Safety Executive Inspectors.
Activities that are enforced by the Local Authorities include:
Retail
Office
Catering
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Laundrettes
Churches and Worship
Car parking facilities
Provision of Childcare
Fire Authorities:
Since the introduction of the Regulatory Reform Order, the role of the Fire Authorities now involves Enforcement for fire
related compliance. The Fire Inspectors have the same rights and authority as Health and Safety Executive Inspectors
and have the ability to issue Improvement and Prohibition notices for Fire related breaches.
The authority does not extend to enforcement of any other Health and Safety breaches or practices, except for Fire.
Environment Agency:
The Environment Agency is concerned with the impact that industry has on the environment. Certain industries will need
specific authority to operate, typical examples of this include timber treatment works and where premises are directly
located next to a river or main watercourse.
The Environment Agency has the right to prosecute organisations for failure to comply with Environmental legislation and
can trace back contaminated water to the source of the pollutant, but it is not just concerned with water. The agency will
also respond to noise and air pollution, to name just a few examples.
The Environment Agency also provides information and industry guidance on best practice.
Scottish Environment Agency:
The Scottish Environment Agency is the equivalent in Scotland and operates in the same remit, but due to legislative
and organisational differences, the operations between Scotland and England and Wales are separate.
Insurance Companies:
Insurance Companies, in the terms set out in their policy can set particular standards across industries which require
compliance for the insurance to remain valid. This has been particularly effective for the regular inspection required for
lifting equipment, where the equipment must be subject to regular inspection by an independent person, which is usually
from an Insurance company.
The Insurance Companies stipulate minimum standards that must be achieved for insurance purposes, which is a strong
incentive financially for organisations to comply.
The Powers of Inspectors
Inspectors are the main way in which compliance of organisations is tested and confirmed. Provisions for the powers of
inspectors are set out in the Health and Safety at Work etc Act 1974 which permits them to stop works where necessary,
issue notices and begin prosecution in cases of serious breaches. Inspectors also have the right to be involved in
accident investigations.
Regular visits by inspectors can be an invaluable resource for organisations, where the opportunity can be taken to
review aspects of the operation and ask for guidance on improvement techniques and further measures that could be
taken. Inspectors have a wealth of knowledge across many different industries and can offer great assistance.
We will now look in a little more detail with regard to their powers.
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Powers:
An Inspector may choose to visit a particular organisation for a number of reasons; routine inspections, following up of a
complaint, to conduct an accident investigation, following the receipt of an incident reported under the Reporting of
Incidents, Diseases and Dangerous Occurrences Regulations 1995. Due to the varied reasons for an Inspector to visit,
you may or may not receive advance warning of the visit. Inspectors do have the right to enter premises at a reasonable
time or where it is suspected there is a dangerous situation. In the event that an Inspector is refused entry, they do have
the power to gain entry with assistance from the Police.
The remit of Inspection, gives them the right to undertake examinations/inspections, to take
measurements/photographs/recordings for the purpose of investigation and to ask and take copies of relevant
documentation. It is also within their rights to request assistance or facilitation with the inspection from relevant people
with control or responsibility within the organisation. The inspector also has the right to take authorised people or
equipment/materials with them on the visit.
In the event of unsatisfactory findings, the inspector has the right to take or render harmless, samples of articles or
substances from the premises or atmosphere. They can also order premises or equipment to be left undisturbed for the
purpose of investigations and they can require a person to answer questions and sign a declaration of truth. Inspectors
have the power to issue notices and to initiate prosecution. We will discuss the matter of notices in more detail.
Notices:
There are two different types of notice that an Inspector can serve an Improvement Notice and a Prohibition notice.
These have to be served in accordance with the Health and Safety at Work etc Act 1974.
Improvement Notice:
Such a notice can be served when, in the inspector’s opinion, there is a breach of relevant statutory duty provisions (or
where there has been a breach which is likely to be continued or repeated). The notice will require the hazard to be
resolved over a given time period. Failure to comply with the notice may result in a prohibition notice or prosecution.
A typical example is a worn floor, which requires work to resolve the hazards.
Prohibition Notice:
This is the more serious of the notices and is issued when in the Inspector’s opinion there is, or is likely to be, a risk of
serious personal injury. The notice will prevent the use of the equipment or premise in question and failure to comply
with the notice is a criminal offence.
A typical example is an unsafe scaffold.
There is an appeal process for both of these notices, which will be heard at an Employment Tribunal. For the
Improvement notice, the notice will be suspended until the appeal is heard.
Prohibition notices continue to remain in force until an appeal has been heard. The appeal is also heard at an
Employment Tribunal and for both types of notice an appeal must be lodged within twenty one days of receiving the
notice.
An appeal is designed for the person in receipt of the notice to contest it. An appeal will usually be made on the grounds
of:
Incorrect interpretation of the regulations made by the Inspector
The inspector exceeded their powers
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The breach of the law admitted but the is claimed to be insignificant
The breach of the law is admitted but the guidance to rectify is not possible or practical.
International Standards and conventions
The sources for International Standards in relation to Health and Safety stem from organisations such as the
International Labour Organisation (ILO) and the International Standards Organisation (ISO).
Founded in 1919, the International Labour Organisation (ILO) is the global body responsible for drawing up and
overseeing international labour standards. It works with its member states to ensure that labour standards are respected
in both practice and principle. It is also the only tripartite United Nations Agency, working with governments, employers
and workers to shape policies and programmes.
Further guidance about what it is and what it does can be found on their website, the information is also available in a
number of different languages www.ilo.org.
There is also the International Standards Organisation, you may be familiar with ISO, such as ISO 14001
(Environmental), ISO 9001 (Quality). They are the world’s largest developer and publisher of international standards and
it is a non - governmental organisation that bridges between the public and private sectors. More information about ISO
can be found at www.iso.org.
Sources of Information on Health and Safety
There is a wealth of information on health and safety available for all organisations to assist in the effective management
of risks and to understand strengths and weaknesses of the management systems in place. The information comes
from both internal and external sources.
Internal Sources of Information
Internal sources of information are collated and compiled from within an organisation. The information is collected from
reactive methods, such as accident and ill health data. This enables an organisation to understand the incidents that
have caused injury, damage or loss and to assess the weaknesses of the current arrangements. Absence records can
also assist in understanding the scope of absence from work and the underlying causes.
There are also active monitoring records that can assist, such as completed Inspections and maintenance reports.
These can be used to assess how effectively arrangements are being carried out and indicate areas where more
investment or further processes might be required.
Audits can provide a wealth of structured information, which systematically go through the arrangements and identify
areas where compliance is strong and also where it requires further development. Audit scores can be used in setting
targets and objectives for the following year.
Investigation reports provide a key opportunity to understand failures and to identify areas where improvements are
required.
The use of internal information sources can be collated and used for comparison against other companies within the
same industry, this gives an organisation the opportunity to measure itself against competitors and to identify where
improvements can be made and to develop a stronger position within the market place.
External Sources of Information
External sources of information come from a range of providers. Legislation and ILO guidance and information provides
critical sources that can be used by an organisation to firstly ensure compliance and secondly outline areas for
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improvement and further development. Such sources of information can be of great assistance when problem solving
solutions for particular risks.
Manufacturer’s data is also invaluable; it will provide guidance on maintenance requirements, safe operations and the
vital statistics of any equipment or machinery being used within the workplace. British, European and International
Standards provide further information and compliance requirements and standardise safety requirements so that at the
purchasing stage an organisation can identify the required standard and purchase appropriately graded equipment.
Trade associations publish a wealth of information on all aspects of safety, whether it is in relation to working practices,
particular equipment or the human effects of the workplace. Trade associations make survey results known and have a
larger resource than many individual organisations for the commissioning of studies, so the reliability of the studies
increases due to the numbers involved.
IT sources and Encyclopaedias are a great resource for the health and safety professional and ensure that the
practitioner or the organisation is kept up to date with developments, recent events and topical discussions.
Sources of Information
Overall the types of information that an organisation may wish to consult when measuring performance, deciding upon
safe methods of working and assessing the efficacy of health and safety management include:
Risk assessments
Employees/ safety reps
Results of observing/ analysing tasks/ JSA/ identification of repetitive actions
Ill-health reports/ analysis of absenteeism records/ accident reports
Supervisors (e.g. number of complaints)
Published information (e.g. guidance from the enforcing authority)
Manufacturers’ information
Training records/ competencies
Employee records (e.g. details of age, disabilities etc )
Results of surveys/ questionnaires/ interviews/ production records machine faults
Specialists (e.g. ergonomists/ occupational health)
Other employers/ trade bodies
Social activities co-ordinator (e.g. Information on recent out of work activities (e.g. new squash/ tennis/ cricket
league)
In terms of sources of information that are provided by websites and publicity offices of national and international
agencies, it is important to be aware of:
International Labour Organisation (ILO)
Occupational Health and Safety Administration (for the USA)
European Agency for Safety and Health at Work (within the EU)
Health and Safety Executive (within the United Kingdom)
Worksafe (within Western Australia)
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The Key Elements of a Health and Safety Management System
To assist with achieving compliance and to effectively manage risks within an organisation, the creation and
use of a health and safety management system is a critical tool. A Health and Safety Management system
should include:
Setting a Policy
Organising
Planning and Implementing
Evaluation (Monitoring, review, measurement, investigation)
Auditing
Action for improvement (preventative and corrective action, continual improvement)
The ILO has produced a guidance document title “Guidelines on Occupational Safety and Health Management Systems
(ILO-OSH 2001) there is also the widely acknowledged framework of OHSAS 18000 Series.
Policy
To set clear aims and objectives/targets
To state intentions/define approach
To lay down criteria/principles for action and response
The policy is the starting point for the health and safety management system. It should clearly state the aims of the
organisation, with defined objectives and targets. This sets the standard for the organisation and clearly shows
commitment to managing safely.
Organising for Health and Safety
To allocate responsibilities for health and safety
To establish effective communication systems (hazards/risks)
To establish commitment at all levels
The organisation of health and safety should clearly allocate responsibilities for named people and clearly define
communication systems. Most organisations choose to allocate responsibilities for health and safety for every role, from
employees through to senior management. This gives ownership across all levels of a business and clearly
demonstrates a strong commitment to health and safety management.
Planning and Implementing
To assess the risks faced by employees, etc
To introduce controls/safe systems of work/documentation
The Planning and implementing stage includes introducing workplace controls such as safe systems of work and
procedures. These ideally should be in writing for clarity and ease of reference. These procedures can then be audited
to ensure efficacy. It is also at this stage that the risks faced by employees are assessed and measures put in place to
mitigate those risks.
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Evaluation (Monitoring, Review, Measurement, Investigation)
Monitoring and Measurement
To provide data on achievement/lack of achievement
By use of active (inspections, etc)/reactive (accidents, etc) monitoring systems
It is critical to measure performance to ensure that the Safety Management system is effective and is providing adequate
protection through the implemented measures. Measuring performance gives an organisation the opportunity to prove
achievements have been made and to also identify where weaknesses remain. Measuring performance can be reactive,
by looking at history, such as accidents and also active, where the use of inspections is used to identify weaknesses
prior to anything going wrong.
Review
To evaluate performance (trends, benchmarking, etc)
To review options for remedial action to improve performance to set new targets
A regular review will assist to evaluate performance; it can be used to identify trends and benchmarking for performance
comparisons. It also provides an opportunity to review remedial actions that can be used to improve performance, by
which new and more challenging targets can be set. This helps the organisation to plan for continuous improvement.
Audit
To provide an independent/structured examination of all parts of SMS
To assess compliance with health and safety management procedures
To identify where standards inadequate
The Audit stage aims to provide a structured examination of all aspects of the safety management system, and provide
and independent review of existing measures. The audit measures performance against the procedures and will assess
compliance. The findings of an audit will provide information on areas where standards have been found inadequate, so
the organisation can target these for further development and improvement.
Action for Improvement (preventative and corrective action; continual improvement
This final section is a direct output from the Audit process. On completion of audits, the findings will identify corrective
actions. These are often communicated in terms of non compliance or suggested actions.
It is an essential part of a Health and Safety Management System to seek continual improvement. This forms a key
concept in models such as the OHSAS 18000 series.
Preventative actions can become apparent outside of the Audit process, for example when Legislative changes take
place, as key finding from Accident/ Incident Investigations and from guidance issued by national or international
agencies, such as the ILO or Health and Safety Executive.
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Figure 2 – Main elements of the OSH management system
This diagram is from the ILO-OSH 2001 and illustrates the process of the recommended management system and the
relationship each stage has with the Auditing process.
The implementation of a Health and Safety Management system is a valuable tool for an organisation, but it does require
commitment throughout the organisation and the original buy in from the directors or bosses of the organisation for the
system to be successful. The process does involve time and commitment and there is some cost involved. There are
significant economical benefits to implementing a health and safety management system however and these include:
Increased productivity (less down-time, improved morale)
Reduced legal action costs (fewer fines, civil claims, etc)
Reduced accident costs (investigation, equipment damage, etc)
Lower sickness rate
Reduced insurance premiums
Better corporate image (increased sales/contracts, etc)
Improved product quality (fewer failures, etc)
Reduced employee turnover
Legal Requirements and Guidance
Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001) ISBN 0-580-37805-5
ILOLEX (ILO database of International Law) http://www.ilo.org/ilolex/index.htm
Occupational Health and Safety Assessment Series (OHSAS 18000): Occupational Health and Safety Management
Systems OHSAS 18001:1999 (ISBN-0-580-28298-8), OHSAS 18002:2000 (ISBN: 0-580-33123-7), BSI
Occupational Safety and Health Convention (C155), ILO
Occupational Safety and health Recommendation (R164) ILO
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Activity – Financial Reasons
An accident has occurred at the offices of a company called Example Stationery Ltd.
Mrs. Careless (a trained secretary, who has been with the company for 15 years) has tripped on a lifting carpet tile
and fallen down the stairs. It appears that her leg is broken, and an ambulance has been called and taken her to
hospital. There were several friends and co-workers who witnessed the accident and horrific injuries sustained. A
trained first aider attended the scene first and administered basic first aid until the ambulance arrived.
The area was immediately cordoned off, and management began an investigation with a couple of hours. The
investigation team was made up of the Operations Director, the Health & Safety Advisor and the Trade Union
Representative.
The following day, a Health & Safety Inspector arrived on-site and began his own investigation.
It is estimated that Mrs. Careless will be unable to return to work for at least 6 months.
List as many different financial costs as you can. Try to identify which ones the company would be able to insure
against. Write your answers in the space below:
You have now completed IGC1 Element One.
Spend some time attempting to answer the following questions. Pay attention to the wording of the questions and the
points available to give you an idea of how much information is required. To help you the action verbs have been
highlighted in bold.
Revision Questions
1. List EIGHT possible costs to an organisation when employees are absent due to work-related ill health. (8 marks)
2. The number of absences due to upper limb disorders in an organisation appears to be increasing. Outline the
possible sources of information that could be consulted when investigating this problem. (8 marks)
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Element 2 – Health & Safety Policy
Key Learning Outcomes
At the end of this element, you should be able to:
Explain the purpose and importance of setting policy for health and safety
Describe the key features and appropriate content of an effective health and safety policy.
Introduction
For an organisation to ensure that it manages the local requirements and associated regulations there needs to be a
method of communicating how the requirements are going to be met. This can be achieved by detailing it as part of a
Health and Safety Policy.
Based on the guidance from organisations such as the ILO, National Governments will set their own legislation and
guidance to achieve the occupational health and safety management framework. For example, in the United Kingdom
this has been achieved through the Health and Safety at Work etc Act 1974
As an example, the Health and Safety at Work etc Act 1974 requires; where an organisation has five or more employees
this Policy must be in writing and should contain three individual sections:
Statement of Intent
Organisational Responsibilities
Arrangements for Implementation
Within this Element we will discuss the importance of setting policy for health and safety, the key elements to be
included within the policy and how this can be measured and reviewed to ensure compliance.
The Importance of Setting Policy for Health & Safety
The Role of the Policy in Decision Making
Every organisation will need to decide how it is going to manage the requirements for health and safety. The overall aim
of the health and safety policy is to clearly define the parameters of the organisations’ undertaking and how it will
allocate roles and responsibilities to manage the areas of significant risk.
This is the opportunity for the organisation to display its commitment to safe working practices and should be driven from
Senior Management through to the general workforce.
Organisations may also be required to produce annual Corporate Responsibility reports for their Stakeholders and health
and safety performance will form a portion of the information required. The policy should reflect the areas of
performance and allow the organisation to benchmark against other organisations and target improvement.
The policy forms the commitment that an organisation will give to health and safety arrangements and it is through the
arrangements set out in the policy that the organisation will be measured and reviewed. Therefore, it is a very important
document not just for legal compliance but as a measure of performance.
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Key Elements of a Health & Safety Policy
As with any policy written by an organisation, the overall aim is to state what the organisation wants to
achieve, who the key people are and what processes are involved to ensure correct delivery - health and
safety policies are no different. Due to the varying needs of organisations, there is no one formal template for
a Health and Safety Policy. It has been deemed inappropriate for something so inflexible to be issued within
the legislation, but instead clear guidance has been set out for what is expected to be in a policy.
As we have discussed the key elements of a health and safety policy fall into three sections:
Statement of Intent
Organisational Responsibilities
Arrangements for Implementation
Or, in simpler terms:
WHAT we intend to achieve
WHO is responsible
HOW it will be done
We will go through each element in detail in the next section.
The Key Features and Content of a Health & Safety Policy
Statement of Intent
The Statement of Intent is usually kept to one page. It defines the general aims and objectives of the organisation and
demonstrates management commitment. To clearly demonstrate the importance of the overall policy, the Statement of
Intent is signed by the most Senior Person in the company, often the Managing Director (MD) or the Chief Executive
Officer (CEO). The signature is also accompanied by a date, which will set the review period. The review period is
usually annually, but a review may be required prior to this if there are significant changes.
Organisational Responsibilities
The second section of the policy should define how health and safety will be organised. This requires the organisation to
define health and safety roles and responsibilities for each category of person within the organisation. Often this is
supported by an organisation chart, which will indicate the flow of accountability, communication and feedback.
Often the Organisation section delegates responsibility according to position within the Organisation. Such positions
may be for example:
Directors/Senior Managers (who may be required to set general policy and objectives, ensure adequate
resources are available, ensure competent advice is in place etc.)
Middle Managers (who may be required to implement policy in their area of responsibility, carry out risk
assessments, devise safe systems of work, identify training needs etc.)
Supervisors (who may be required to check day to day compliance with the policy, investigate accidents etc.)
Competent Persons/Safety Advisors (who will have specific health and safety responsibilities/advising company
on accident prevention and compliance)
Occupational Health Persons (who will be responsible for health issues and health surveillance)
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Safety Representatives/Representatives of Employee Safety (who will be responsible for representing the
workforce in relation to Health and Safety consultation with management)
Employees (will have general health and safety responsibilities for themselves and others and to comply with
policy)
First Aiders/Appointed Persons (who will be trained to provide first aid to injured persons, or appointed to
summon assistance in the event of an emergency)
Fire Marshalls/Responsible persons (who will have specific duties to support evacuating buildings safely and
fire related duties)
In larger organisations, there should be a keen focus on line managers. This front line facing management role, is the
key area of interaction between management and the workforce and therefore it is of great importance. The line
manager will be viewed as the recognised face of management and their acts or omissions will generally define how the
workforce perceives how importantly the organisation views health and safety. It will often be the line manager who is
driving through the implementation of policies and measuring the effectiveness of them. A weakness at this level will be
of great disadvantage to both the organisation and to the workforce, and could lead to increased risk of loss and injury.
Imagine that you are working in an area that requires the use of Personal Protective Equipment, such as protective
footwear. If you are busy working and your line manager walks in without correct footwear, what impression does that
give? Would that make you feel that the organisation has a strong commitment to health and safety?
Health & Safety Arrangements
The Arrangements section provides the opportunity for an organisation to detail procedures for implementing the health
and safety policy. The arrangements should ensure that there is sufficient scope for the organisation to control hazards,
consult and communicate with the workforce and provide a means for monitoring compliance. Without the arrangements
section, there is no clarity on how the organisation will ensure that the objectives set out within the Statement of Intent
are being fulfilled and it will not inform the workforce about how health and safety will be managed.
The Arrangements section will of course be totally specific to the organisation, depending on what activities are being
conducted on a day to day basis, however there are some elements that would normally be included. The following
table details the issues that should be included as a minimum, and the kind of details that may be required to be
described:
Section Detail
Risk Assessment When they are carried out.
Forms/templates to be used.
Who is to carry them out, and their level of competence.
When they should be reviewed etc.
Health & Safety Training Identification of training needs.
Arrangements for induction training.
Frequency of refresher training.
Specific tasks that require additional training e.g. forklift trucks,
specific vehicle licences, operating machinery etc.
Storage of training records.
Consultation with Employees Methods for consulting with employees e.g. safety representatives,
direct consultation with individuals etc.
Terms of reference for health and safety committee etc.
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Section Detail
Monitoring Health & Safety Performance Arrangements for regular inspections of the workplace.
Arrangements for investigating accidents, incidents and ill-health.
Arrangements for regular audits of health and safety performance.
Who is to carry out the monitoring, their competence etc.
Managing Contractors How the competence of contractors is assessed.
Who is responsible for the initial assessment/appointment of
contractors, and their level of competence.
How the assessment of contractors is recorded and reviewed.
Management of contractors working on site etc.
Safe Systems of Work/Permits to Work Who is responsible for developing safe systems of work, and their
level of competence.
How the safe systems are documented and communicated to
relevant staff.
The jobs that require formal permit to work systems.
The training required in operation of the permit system etc.
Disciplinary Procedures for Non-Compliance Which breaches constitute a breach of discipline, and which ones
constitute gross misconduct.
Procedures for disciplinary hearings, formal warnings and dismissal
where appropriate.
Emergency Procedures The types of emergency that require procedures e.g. fire.
The actions to take in an emergency.
How often procedures will be tested.
Who is responsible for certain actions in the event of an emergency
e.g. roll call, fighting fires, calling for help etc.
First Aid The names and location of first aiders, and how they can be
contacted.
The location of first aid equipment e.g. kits, eye wash stations,
emergency showers etc.
Arrangements for ensuring first aid kits remain fully stocked etc.
Accident Reporting and Investigation The definition of an accident.
Who accidents should be reported to, and when.
Documents to be used to record accidents e.g. accident book,
report form etc.
Who should investigate accidents, and their level of competence.
Forms to be used to document the investigation etc.
Arrangements for Control of Specific Hazards
e.g. Hazardous Substances, Manual Handling,
Transport, Machinery etc.
Arrangements for specific risk assessments.
Arrangements for specific training.
Responsibility for implementing particular control measures etc.
It is important to note that these are just examples – an organisation’s policy and its contents should be specific to the
organisation. It should be written to meet their particular needs, objectives and targets.
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Policy Review
The health and safety policy should be monitored and reviewed on a regular basis; this ensures that the information
within it remains up-to-date and relevant. Though the passage of time is a very good reason to regularly review a policy
(most companies adopt an annual process) there may be other factors that require a review to be conducted.
Changes in key personnel may require a review of the policy, particularly if their role/responsibilities have been
documented in the Organisational Responsibilities section. The Statement of Intent will be signed by the most senior
person in the organisation, so if there is a change then this should also prompt a review.
There may also be changes to procedures, systems of work and possibly organisation structure. As these are all
detailed within the policy, when any element changes these must also be updated in the policy and the policy reissued.
Other reasons to prompt a review will include any accidents/incidents/ill Health, where the key findings indicate that a
change is required in the management of the significant risks. A company may for example decide to introduce health
surveillance, which will need to be included within the Arrangements section.
Enforcement action, by enforcement officers, may provide input to change or modify the organisations existing policy or
they may indicate that there are short falls within the arrangements of certain risks, in which case once the
improvements have been decided, they should be updated within the policy.
The organisation through the continual review of its arrangements may also identify weaknesses that require addressing
and the improvements may need to be detailed within the policy. This may be as a result of monitoring activities for
example inspections of the workplace, or management audits.
Other changes might be the organisation moving to a different premise which may require alterations within the policy or
where there have been changes in legislation, which require the organisation to alter how it manages risks.
Communication of the Health & Safety Policy
Simply producing a policy is not enough – it has to be communicated to employees and other interested parties. It is
pointless having a detailed policy if it is locked away in the Safety Advisor’s draw. The policy can be communicated to
employees by a variety of methods, and it is up to the organisation to decide on the method that best suits them. Some
examples of how the policy can be communicated are:
Issue a hard copy to each individual employee, and obtain a signature of receipt and understanding (easy in
smaller businesses, but may prove problematic in larger organisations)
Email a copy to all employees and add accept/reject buttons to the email, or request a read receipt (suitable
for organisations where everyone has access to email)
Training courses (it is good practice to include the policy in every health & safety training course)
Display the policy on notice boards or the intranet (for detailed policies, it may be more appropriate to just
display the one page Statement of Intent on a notice board or in reception)
Employee handbooks
Can you think of any more ways to communicate the policy?
As well as employees, there are a variety of other groups that may be interested in the contents of the health & safety
policy:
Visitors
Contractors
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Enforcing Authorities
Clients/Customers
Shareholders
Legal Requirements and Guidance
The Guidelines provided by the ILO, Guidelines on Occupational Safety and Health Management Systems (ILO-OSH
2001) clearly identifies the Employer’s responsibilities in so far as producing management systems.
For example, in the United Kingdom this has been achieved through the following legislation:
Health and Safety at Work Etc Act 1974
The Management of Health and Safety at Work Regulations 1999
Section 2(3) of the Health and Safety at Work Etc Act 1974 requires that every organisation with 5 or more employees
should have a documented health and safety policy.
It also requires that the policy must be brought to the attention of all employees and that it be reviewed and revised as
appropriate.
Regulation 5 of the Management of Health and Safety at Work Regulations builds on this and requires that every
employer makes arrangements for the nature of their activities which include effective planning, organisation, control,
monitoring and review of the preventive and protective measures. Although the regulations do not specifically say so,
these arrangements would normally be detailed in the health & safety policy.
Sample Health & Safety Policy
A sample of a UK health & safety policy for a small to medium business has been included on the following pages. It
should serve to illustrate the points we have made in this element.
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Health & Safety Policy
General Statement of Intent
The company believes that health & safety is a vital component of the business – a good health and safety record
goes hand in hand with high productivity and quality standards.
Employees are the most important asset to this company, and therefore their health, safety and welfare is a priority at
all times.
The company believes that prevention is not only better, but cheaper than cure. Profits and safety are not in
competition - on the contrary, good health & safety is good business.
From a legal perspective, the company is committed to ensuring that it complies with all relevant health and safety
legislation. Where it is reasonably practicable to do so, the company will strive to go beyond the requirements of
legislation.
The company is committed to ongoing monitoring and review processes, so that continual improvement in the
management of health and safety can be achieved.
Our general intentions are:-
To provide adequate control of the Health and Safety risks to employees and others arising
from our work activities;
To consult with our employees on matters affecting their Health & Safety;
To provide and maintain safe plant and equipment;
To ensure safe handling and use of substances;
To provide adequate information, instruction and training supervision for employees;
To prevent accidents and cases of work related ill health;
To maintain safe and healthy working conditions; and
To review and revise this policy at regular intervals.
Signed: John Smith
Job Title Managing Director
Date: 1st January 2009
Review Date: 1st January 2010
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Organisational Responsibilities
Overall and final responsibility for health and safety is that of:
John Smith
Day-to-day responsibility for ensuring this policy is put into practice is delegated to:
Joe Bloggs, Health & Safety Advisor
To ensure that health and safety standards are maintained and improved, the following people have responsibility in
the following areas:
Name Responsibility
Jane Doe Office
Mike Evans Warehouse
Organisation Chart
Directors Responsibilities
Ensure the Company has access to competent Health and Safety advice as required by the Management of Health
and Safety at Work Regulations 1999.
Ensure that there exists an effective policy for Health and Safety management, supplemented by additional
documents and safe systems of work relating to the required performance in each particular area and type of activity
and that this document is implemented throughout the business.
Ensure this policy is routinely reviewed on an annual basis to ensure the arrangements for health and safety remain
current and valid.
Ensure that necessary resources and information is made available for the policy to be effectively put into practice.
Ensure that Line Managers are inducted and trained to enable them to carry out their role effectively.
Ensure that Line Managers carry out their respective duties regarding health and safety within their areas of control.
Ensure that all accidents, incidents, diseases and/or dangerous occurrences are reported to the Enforcing Authority
where required.
Co-operate and assist, as necessary, with all enforcing authorities and any other external body concerned with
Health and Safety in the course of their duties.
Managing
Director
Operations
Director
Operations
Manager
Commercial
Director
Sales Manager
Human
Resources
Director
Health & Safety
Advisor
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Line Managers Responsibilities
Co-operate with Directors on health and safety matters
Ensure that the duties and responsibilities for safe working are properly assigned, accepted and understood by all
personnel working in or entering the workplace.
Budget for adequate workplace resources to fully implement the health and safety policy.
Ensure that the health, safety and welfare arrangements within their workplace are effectively implemented in
accordance with the specific procedures detailed in this policy.
Ensure that all recommendations from the risk assessments are implemented within the relevant timeframes.
Ensure that all accidents and near misses are reported and investigated to determine if further controls are
necessary to prevent a re-occurrence.
Ensure that Health and Safety training is provided to all new workplace employees as part of the company’s overall
training programme.
Ensure that all employees within the workplace have been briefed on and understand the Health and Safety Policy
along with any safe working systems/procedures relevant to their work.
Ensure employees have access to all necessary and relevant information appertaining to their health, safety and
well-being at work.
Ensure that necessary protective clothing and equipment is correctly used and maintained in good order by
employees under their control, and by any visitors and external contractors in the department.
Employees Duties
Co-operate with Line Managers and Directors on health and safety matters.
Not interfere with or misuse anything provided to safeguard their health and safety.
Take reasonable care of their own health and safety, and that of others.
Use equipment and substances correctly, in accordance with training and instructions received.
Use personal protective equipment correctly, in accordance with training and instructions received.
Report all health and safety concerns to their Line Manager or a Director.
Stop work and seek advice if they believe there is an imminent risk of injury to themselves or others.
Report any near miss or accident immediately.
Assist at all times in maintaining good housekeeping standards.
Non-compliance with health and safety rules and procedures can result in disciplinary action, which may include
immediate dismissal if appropriate.
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Arrangements for Implementation
All company policies and procedures in relation to health and safety are regarded as supplementary to this policy.
Risk Assessment
The company will carry out risk assessments of all activities that present a risk to employees or others. These risk
assessments will be carried out in line with the ILO, Guidelines on Occupational Safety and Health Management
Systems (ILO-OSH 2001), and the procedure for doing so is as follows:
1. Identify the significant hazards involved in our activity.
2. Decide who might be harmed and how.
3. Evaluate the level of risk and decide if existing precautions are sufficient, or if more needs to be done.
4. Record the significant findings of the assessment.
5. Review the assessment when things change, or there is reason to believe that it is no longer valid.
Risk assessments will be undertaken by:
Joe Bloggs
Approval for the required action to remove or control risks will be given by:
John Smith
Health & Safety Advice
The company has access to competent Health & Safety advice.
Health & Safety advice is available from:
Joe Bloggs
Qualifications in Health & Safety:
NEBOSH International General Certificate
Consultation with Employees
The company will consult with its employees.
Employee Representative(s) are:
Bill Jones
Sarah Thomson
Mark Wilkinson
Consultation with employees will be provided by:
Monthly team meetings with health & safety as a standing agenda item.
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Plant, Machinery and Work Equipment
The company will ensure that all plant and equipment is suitable and without risks to health and safety, in accordance
with legislation such as the Provision and Use of Work Equipment Regulations 1998, the Lifting Operations and Lifting
Equipment Regulations 1998 and the Electricity at Work Regulations 1989.
All employees are required to carry out a visual check of any equipment before it is used. In some cases, this check will
need to be documented. The company will advise when this is the case.
Responsibility for identifying all plant and equipment needing maintenance is that of:
Joe Bloggs
Responsibility for ensuring that all identified maintenance is implemented is that of:
Mike Evans
Any problems with plant or equipment should be reported to:
Mike Evans
Responsibility for checking that new plant and equipment meets health and safety standards before it is purchased is
that of:
Joe Bloggs
Portable electrical appliances are tested by/every:
W.E. Testem Electrical every 12 months
The fixed electrical installation is tested by/every:
W.E. Testem Electrical every 5 years
Hazardous Substances
The company will assess and control health risks from exposure to hazardous substances in accordance with the
Control of Substances Hazardous to Health Regulations (COSHH) 2002.
Chemical Safety Data Sheets are obtained by:
Joe Bloggs
Chemical Safety Data Sheets are stored at:
Chemical store in warehouse
COSHH assessments will be carried out by:
Approval for the required action to remove or control risks will be given by:
John Smith
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Manual Handling
In accordance with the Manual Handling Operations Regulations 1992, the company will eliminate the need for manual
handling where possible. Where elimination is not possible, the risks from manual handling will be assessed and
reduced, so far as is reasonably practicable.
Manual handling risk assessments will be carried out by:
Joe Bloggs
Approval for the required action to remove or control risks will be given by:
John Smith
Display Screen Equipment
The company will assess and control health risks from exposure to display screen equipment in accordance with the
Health and Safety (Display Screen Equipment) Regulations 1992.
Employees that are classed as habitual Display Screen Equipment users are entitled to free eye tests, and vision
correction appliances where these are only needed for work with display screen equipment.
Display screen equipment risk assessments will be carried out by:
Jane Doe
Approval for the required action to remove or control risks will be given by:
John Smith
Information, Instruction, Training and Supervision
The company will provide adequate information, instruction, training and supervision to employees in accordance with
the general duties on employers under Section 2 of the Health and Safety at Work etc. Act 1974 and various regulations.
All employees will be provided with information on the significant findings of any risk assessments relevant to their
particular activity/workplace. This will include information on the hazards and relevant control measures.
All information, instruction and training given to employees will be recorded on individual training records. In certain
instances, employees will be asked to sign to confirm receipt and/or understanding.
Induction training for all new employees is the responsibility of:
Joe Bloggs
Training will be identified, arranged and monitored by:
Line Managers as part of the training needs analysis process
Training records are kept at/by:
Personal files, managed by Jane Doe
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The Health and Safety Law poster is displayed at:
Kitchen
Supervision of young workers/trainees will be arranged/undertaken/monitored by:
Joe Bloggs
Responsibility for ensuring that our employees who work at locations under the control of other employers are given
relevant health and safety information is that of:
Joe Bloggs
Accidents, First Aid and Work Related Ill-Health
The company is committed to preventing accidents and cases of ill-health to employees and others who may be affected
by its work activities.
However, the company recognises that failures can occur and will investigate all accidents and ill-health to identify the
immediate and underlying causes so as to prevent recurrence.
All reportable incidents, as defined by the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995
will be reported to the enforcing authority within the relevant timeframes. The following types of work related
incident/accident need to be reported:
• Death
• Major Injuries e.g. broken bones, dislocations, amputations, loss of sight etc.
• Any accident resulting in more than 3 days lost from work
• Any non-employee being taken directly to hospital
• Certain types of disease e.g. dermatitis, asthma, upper limb disorders, TB etc.
• Certain types of dangerous occurrence, even when no-on is injured e.g. scaffold collapse, overturn of lifting
equipment, electrical fires/explosion etc.
The company will provide adequate first aid personnel and equipment, in accordance with the Health and Safety (First
Aid) Regulations 1981.
All accidents and work related ill-health should be immediately reported to:
Joe Bloggs
All accidents and work related ill-health are recorded in the accident book, which is kept by/at:
Joe Bloggs
All hazards/near misses should be reported to:
Responsibility for investigating accidents/ill-health/hazards/near misses is that of:
Joe Bloggs
PPE will be issued to employees by:
Joe Bloggs
Any problems (e.g. defects/loss etc.) with PPE should be reported to:
Joe Bloggs
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Managing Contractors
The company recognises that it owes a duty to contractors as well as employees, as stipulated by the Health and Safety
at Work etc. Act 1974 Section 3 and the Management of Health & Safety at Work Regulations 1999.
In the first instance, the company will ensure that only competent contractors are selected. From then on, the activities of
appointed contractors will be adequately managed.
Competence of contractors will be assessed by:
Joe Bloggs
Contractors working on site will be managed by:
Joe Bloggs
Any problems/hazards arising from the activities of contractors should be reported to:
Joe Bloggs
Information on site hazards/controls/safety rules will be provided to contractors by:
Joe Bloggs
Welfare Facilities
The company is committed to providing suitable and sufficient welfare facilities to employees, in accordance with the
Workplace (Health, Safety and Welfare) Regulations 1992.
Adequate numbers of toilets and washing facilities are provided for the number of staff required to use them. Toilet
paper, soap and means for drying hands will always be available.
Cleaning is carried out by/every
Toilets – Sparkle Cleaning every day
Rest areas – Sparkle Cleaning every day
Other areas – Sparkle Cleaning every week
Problems with cleanliness/hygiene standards should be reported to:
Jane Doe
Drinking water is available at:
Kitchen
Emergency Procedures – Fire and Evacuation
The company will have in place procedures to follow in the event of emergency. These will be communicated to all
employees and will be tested on a regular basis.
In the event of a fire, immediately sound the alarm.
Only attack the fire if trained to do so – do not put yourself at risk.
Dial 999 and ask for the fire brigade – give address and ensure it is heard.
Evacuate the building by the nearest exit.
Do not stop to collect personal belongings.
Do not re-enter the building until told it is safe to do so.
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 33 of 133
Responsibility for ensuring the fire risk assessment is undertaken and completed is that of:
Joe Bloggs
Approval for the required action to remove or control risks will be given by:
John Smith
Fire extinguishers are maintained and checked by/every:
Drenchem Fire every 12 months
Emergency evacuation will be tested every:
12 months
The fire alarm will be tested by/every:
Joe Bloggs, every week
Emergency lighting will be tested by/every:
Joe Bloggs, every month
Legal Requirements and Guidance
Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001) ISBN 0-580-37805-5
ILOLEX (ILO database of International Law) http://www.ilo.org/ilolex/index.htm
Occupational Health and Safety Assessment Series (OHSAS 18000): Occupational Health and Safety Management
Systems OHSAS 18001:1999 (ISBN-0-580-28298-8), OHSAS 18002:2000 (ISBN: 0-580-33123-7), BSI
Occupational Safety and Health Convention (C155), ILO
Occupational Safety and health Recommendation (R164) ILO
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 34 of 133
Activity – Health & Safety Policy
ABC Supplies Ltd. is a supplier of protective equipment, tools, cleaning products etc. to the construction industry. It
employs approx. 50 staff, and its premises consist of a warehouse, mezzanine floor, yard area and offices.
The warehouse holds 10 bays of storage racking. Pallets are removed from the racking by forklift truck and placed on
the floor. The goods are then placed by hand onto trolleys and pushed to the front of warehouse ready to be picked
up and delivered by the delivery vans. The delivery process is contracted out to a local firm.
The offices contain sales, admin and finance departments, as well as being home to the Directors.
Identify the issues that should be included in the arrangements sections of ABC Supplies Ltd’s Health & Safety Policy.
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 35 of 133
Revision Questions
You have now completed IGC1 Element Two.
Spend some time attempting to answer the following questions. Pay attention to the wording of the questions and the
points available to give you an idea of how much information is required. To help you the action verbs have been
highlighted in bold
1. a.) Outline the legal requirements whereby employers must prepare a written statement of the health and safety
policy (2 marks)
b.) Explain the purposes of EACH of the following sections of a health and safety policy document:
i. ‘statement of intent’ (2 marks)
ii. ‘organisation’ (2 marks)
iii. ‘arrangements’(2 marks)
c.) Outline the issues that are typically included in the arrangements section of a health and safety policy
document. (12 marks)
2. Outline the circumstances that may give rise to a need for a health and safety policy to be reviewed. (8 marks)
3. Identify SIX categories of persons who may be shown in the ‘organisation’ section of a health and safety policy
AND State their general or specific health and safety responsibilities. (6 marks)
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 36 of 133
Element 3 – Organising for Health and Safety
Key Learning Outcomes
At the end of this element, you should be able to:
Outline the legal and organisational health and safety roles and responsibilities of employers, managers,
supervisors, employees and other relevant parties.
Explain the importance and means of consulting with employees on health and safety issues and the means to
achieve effective consultation.
Introduction
Organising for Health and Safety will require careful thought and consideration. To fail to organise could lead to
significant failures within the management of health and safety.
The consequences for failing to organise for health and safety are serious, but within this
Element we will discuss the methodology for effective organising, so that the key legislative requirements can be
achieved and we will establish how an Organisation can structure its health and safety management to avoid such
problems.
Legal and Organisational Health and Safety Roles and Responsibilities
Every organisation will need to ensure that it clearly defines safety roles and responsibilities across the workforce. The
responsibilities will need to include provisions for anyone affected by the activities of the organisation; this will include
employees of all levels but will also include third parties such as Visitors, Contractors, Members of the Public and also
trespassers.
The legal and Organisational Roles and Responsibilities:
R164 Occupational Health and Safety recommendation suggests that each country does set out duties that the
Employer should be held accountable for. You will see that this reflects Section 2 duties of the Health and Safety at
Work etc Act 1974, and should also reflect the relevant legislation for the Country in which you are based.
IV. Action at the Level of the Undertaking
10. The obligations placed upon employers with a view to achieving the objective set forth in Article 16 of the Convention
might include, as appropriate for different branches of economic activity and different types of work, the following:
(a) To provide and maintain workplaces, machinery and equipment, and use work methods, which are as safe and
without risk to health as is reasonably practicable;
(b) To give necessary instructions and training, taking account of the functions and capacities of different categories of
workers;
(c) To provide adequate supervision of work, of work practices and of application and use of occupational safety and
health measures;
(d) To institute organisational arrangements regarding occupational safety and health and the working environment
adapted to the size of the undertaking and the nature of its activities;
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 37 of 133
(e) To provide, without any cost to the worker, adequate personal protective clothing and equipment which are
reasonably necessary when hazards cannot be otherwise prevented or controlled;
(f) To ensure that work organisation, particularly with respect to hours of work and rest breaks, does not adversely affect
occupational safety and health;
(g) To take all reasonably practicable measures with a view to eliminating excessive physical and mental fatigue;
(h) to undertake studies and research or otherwise keep abreast of the scientific and technical knowledge necessary to
comply with the foregoing clauses.
The legal responsibilities within the UK for Employers and Employees are set out in the Health and Safety at Work etc
Act 1974. A brief summary of the requirements of Employers, as outlined in the Health and Safety at Work Act 1974,
sections 2 include:
General duty to ensure the health, safety and welfare of employees
Provision and maintenance of plant and SSW
Safe use, handling, storage, and transport of substances and articles.
Provision of information, instruction, training and supervision.
Safe work place, access and egress.
Health and safety policy – organisation and arrangements.
Consult with safety representatives
To form a safety committee when correctly requested.
In terms of organisational requirements; every level of employee within the organisation should have defined health &
safety responsibilities, which reflect any applicable legislative requirements. The levels of employees include:
Directors
Senior Managers
Middle Managers
Supervisors
Health & Safety Practitioner
Employees
We will now discuss in detail, what the levels of responsibilities are likely to be for each of these roles.
Directors:
It is standard practice for a Director from the Board to be appointed overall responsibility for Health and Safety. This
requires the Director to formally accept the role and to show the collective Director responsibilities as well as their own
individual responsibility to provide Health and Safety leadership within the Organisation.
Directors must ensure that board decisions reflect their health and safety intentions and recognise their role in engaging
the active participation of workers in improving health and safety standards.
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 38 of 133
With this responsibility comes the requirement to ensure that they are involved and kept informed of relevant health and
safety issues and to carry out an annual review of performance. The appointed Director will usually be the signatory on
the Statement of Intent, so the responsibility to ensure that the Policy is kept up to date and reviewed at least annually
will also form part of their remit.
As a board representative the Director responsible for Health and Safety will need to ensure that any health and safety
failures are clearly communicated at Board level and that any investigation findings are also brought to this forum.
It is also at Director level that the decisions for auditing are made and sufficient means will need to be in place for the
effective management systems for monitoring and reporting on the organisations health and safety performance.
Any decision made at Board level must be made in consideration of any health and safety implications that these
decisions may have.
Safety Advisors:
Dependant on the Country in which you are based, the requirements for Safety Advisors will be detailed within National
Legislation. In the United Kingdom for example; The Management of Health and Safety at Work Regulations, regulation
7 requires an organisation to have arrangements for Competent Assistance. Where possible this assistance should be
provided by an internal resource, but where this in not possible it should be sourced externally, for example through the
use of Consultants.
Safety Advisors, as the title indicates have the responsibility is of an advisory capacity, with no direct responsibilities. A
health and safety advisor will need to be able to advise the organisation on a number of topics and should have the
relevant competence. The nature of advice will include:
Needs to be able to advise on:
Creating and developing H&S policies
The promotion of a positive H&S culture
H&S planning and target setting
Accident/incident investigation, reporting and analysis
Performance reviews and audits of the health & safety management system
For a Safety Advisor to perform their function, they will need to:
Have appropriate training and qualification (will differ depending on business)
Keep up to date information systems
Know how to interpret the law as it applies to the business
Be able to present their advice independently and effectively
Report accurate feedback to Senior Managers/Directors regularly
A number of other external support services may also be required by an Organisation to ensure that the Health
and Safety management process is robust. These will include:
Engineers
Occupational Hygienists
Occupational Health Professionals
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 39 of 133
Ergonomists
Physiotherapists etc
Senior Managers:
Senior Managers may be required to set general policy and objectives, but they must also ensure that there are
adequate resources available for the effective management of Health and Safety, which will include ensuring that there
are competent advice arrangements in place.
Middle Managers:
At this level of the Organisations structure, middle management is more concerned with implementing the structure as
defined by the Directors and Senior Management team. The responsibilities for middle management will be to carry out
risk assessments, devise safe systems of work and identify training needs. This level of management must implement
the policy requirements within their area of responsibility.
Supervisors:
The role of the Supervisor is a very important part of the Organisations overall arrangements for Health and Safety. It is
the Supervisor who is the day to day face of seniority for the workforce, so their acts or omissions will impact greatly on
the perception of how seriously health and safety is taken by the Organisation.
The responsibilities are more of day to day requirements, ensuring that the compliance with the policy is actively
enforced and supervising to ensure that those arrangements are being followed by the workforce and reporting upwards
to more senior management where issues have been identified. The Supervisor is also likely to be responsible for
investigating accidents, unless they warrant further support from senior managers.
Employees:
Employees should be given responsibility to report any short comings within the organisations health and safety
arrangements and report immediately any unsafe acts or conditions. Employees should be instructed that they have a
duty to work in accordance with the organisations health and safety arrangements and not endanger anyone that they
are working with or around by unsafe behaviour.
In general, responsibilities for employees set by the organisation will closely mirror those required of them by law (in the
UK this is sections 7 and 8 of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at
Work Regulations)
There are two other groups of people that will have responsibilities for Health and Safety, which may or may not apply to
every organisation.
Persons in control of premises will have some responsibility for those using the premises as a place of work and also to
those using any plant or substances that are provided. In the UK for example, these duties stem from Section 4 of the
Health and Safety at Work etc Act 1974 and apply to non domestic premises. The requirements concern the upkeep of
the building to ensure that reasonable measures are taken to ensure is safe and without risk to health.
The self employed also have responsibilities for their own health and safety and also of those who may be affected by
their acts or omissions. We will talk in depth about arrangements for Contractors later in this Element.
Duties of Suppliers, Manufacturers and Designers:
Many larger organisations are forcing improved health and safety standards through the supply chain, which impacts on
smaller organisations looking for business.
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 40 of 133
The requirements of the larger organisations involve asking their links within the supply chain to demonstrate that they
meet minimum standards for health and safety. For smaller organisations, failures to have sufficient health and safety
standards in place may result in lost business, as well as the obvious breaches in health and safety legislation.
Organisations operating within supply chains will request their suppliers to provide health and safety documentation,
details of breaches or prosecutions and ask questions about health and safety procedures, in a very similar approach to
the management of Contractors which we will discuss shortly.
Guidance required each individual Country to ensure that there is adequate provision for Suppliers, Manufacturers and
Designers. In the UK this has been achieved by Section 6 of the Health and Safety at Work etc Act which is specifically
aimed at the duties of Designers, Manufacturers, Importers and Suppliers. Much of the requirements have been
amended through the introduction of the Consumer Protection Act 1987, however the responsibilities are still applicable.
The main requirements concern Articles and substances for use at work in relation to the health and safety of such
products and the provision of information.
Articles are defined as any plant designed for use or operation within the workplace and Substances refers to any
substance be it natural or manmade that is intended for use within the workplace.
Designers, Manufacturers and Suppliers must ensure that any such articles or substances have firstly been designed
and constructed to be safe and without risk, as far as is reasonably practicable, which may include testing and
examination. There must also be sufficient information supplied to the end user to ensure that the nature of the
substance or article can be understood and that any conditions for safe use can be described.
Client and Contractor Duties:
A contractor is anyone an Organisation employs to do work who is not an employee, the typical types of Contractors
often employed by organisations include:
Construction/Maintenance/Repairs
Decorating
Electricians/Gas/Water
Fire extinguishers/alarms/emergency lighting
IT
Catering
Cleaning
The legal requirements for an Organisation to manage the use of contractors will depend upon the National Legislation
implemented within each country, for example in the UK this is covered in the main by three different pieces of
legislation.
Firstly, the Health and Safety at Work etc Act 1974 places specific duties within Section 3. In addition to this further
regulations have been implemented that extend these duties and place further emphasis on what is expected.
The Management of Health and Safety at Work regulations 1999, specifically covers Contractors working in Host
Employers.
Specifically for Construction work, the Construction (Design and Management) Regulations 2007 requires the control of
construction contractors.
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 41 of 133
In any client / contractor relationship, BOTH parties have duties under health and safety legislation. The client (the
organisation employing the Contractor) will have a duty to ensure that they employ competent and safe contractors. The
Contractor will have a duty to comply with health and safety arrangements and if they decide to sub-contract any of the
work, then all parties will have duties to ensure that competent fellow workers are provided.
The extent of each party’s responsibilities will depend upon the specific circumstances of the works being conducted.
To assist in defining the scope of responsibilities and the level of risks involved with the contracting out of works, some
industry examples have been provided. The examples focus on when contracting works go wrong and the
consequences of those events for the parties involved.
Example One:
Contractors provided a scaffold onto a fragile roof which was 10m off the ground. An operator walked onto the roof and
fell to his death through a fragile vent.
The client was found guilty and fined £27,000 plus costs for failing to provide adequate instruction and supervision. The
contractor was found guilty and fined £3000 plus costs for failing to implement straightforward controls and safeguards.
Example Two:
Contractors installed overhead projectors into asbestos ceilings at a local school in Caerphilly. No information regarding
the presence of asbestos was known by the school and therefore the presence of asbestos or any relevant information
could not be given to the contractors. As a result of this failing the contractors unknowingly exposed themselves to
asbestos whilst completing their set tasks.
Caerphilly County Council fined £8,000 plus costs.
Example Three:
Contractors were appointed to conduct roof works at a B&Q store. One of the Contractors workers was seen working on
the roof with no protection from fall risks. B&Q had previously been made aware of the requirements to control
contractors and had been given extensive advice regarding roof work, due to two previous accidents in the past.
B&Q were fined £4,500 plus £25,000 costs.
Example Four:
An accountancy firm had previously been given advice about unsafe working at height arrangements, but failed to make
improvements. Unsafe work was being carried out on a tower scaffold by contractors, which lead to the individual
partners of the firm being fined £1,250 plus £2000 costs each.
The examples illustrate the need for Contractors activities to be monitored and for the Organisation to assess the tasks
required and ensure that suitable information is given to the Contractors prior to works commencing.
To assist an Organisation to manage contractors there are 5 management steps that can be applied:
5 steps to managing contractors:
1. Planning
Define the job to be carried out
Identify the hazards involved in the job
Assess the risks from the hazards
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 42 of 133
2. Choosing a contractor
Spell out conditions contractor has to meet
Deciding factors may include:
Availability
Cost
Technical competence
Reliability
Health & Safety
“Pre-Qualification” can save time and effort in the future
How to decide on a contractor?
Build relationships to set up preferred contractors
Use your contacts in the business
Use informal networks
Interview different contractors
Ask questions and get evidence
Issues to explore:
Experience in this kind of job
References
Health & Safety Policy
Risk Assessments
Health & Safety Performance
Accident performance
Enforcement action
Membership of trade/professional bodies
Procedures for subcontractor selection
Training/competence of staff
Access to competent health & safety advice
Arrangements for supervision
Accident/incident reporting
Insurance – Employers and Public Liability
Some schemes have been established to prequalify contractors
The intention is that this saves clients time and money in selecting contractors
IGC1: Management of International Health & Safety
© Phoenix Health & Safety 2011 Page 43 of 133
Examples:
CHAS (Contractor H&S Assessment Scheme)
National Britannia Safe Contractor
3. Contractors working on site
Contractors should sign in and out so that it is always known who is on site
Contractors should be told about health & safety rules – smoking, emergency procedures etc.
Visitors/contractors cards/leaflets may be useful
Contractors should be given a named site contact
Contractors should sign out when they leave site
4. Keeping Check
Check should be carried out to see that contractors are doing the work in the way agreed
Contractors are responsible for supervising their own work and for ensuring that they work safely
However, they can’t just be left get on with it
They do not need to be watched all the time
The amount of checking should be based on the level of risk involved
It should be decided and agreed at the beginning of the job
Contractors should be encouraged to report accidents and incidents
5. Reviewing the work
Learn about the job and the contractor when the work is done
What needs to be done differently next time?
Any surprises or lessons learned should be recorded and used for next time
The record can be used when reviewing the list of preferred contractors
An example has been provided of a Contractors Assessment form. This is one method that an organisation may choose
to adopt to ensure that due care and considerations has been given to the selection of Contractors.
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Nebosh international certificate distance learning

  • 1. NEBOSH International Certificate Distance Learning IGC1 - Management of International Health & Safety Phoenix Health & Safety Ticking all the right boxes T: 0845 500 8811 NEBOSH International Certificate Distance Learning Management of International Health & Safety Phoenix Health & Safety Ticking all the right boxes E: info: phoenixhsc.co.uk W: NEBOSH International Certificate Management of International Health & Safety W: www.phoenixhsc.co.uk
  • 2. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 2 of 133 Contents Page Element 1 – Foundations in health & safety 3 Element 2 – Health & Safety Policy 19 Element 3 – Organising for Health & Safety 36 Element 4 – Promoting a Positive Health & Safety Culture 59 Element 5 – Risk Assessment 77 Element 6 – Principals of Control 90 Element 7 – Monitoring, Review & Audit 106 Element 8 - Incident and Accident Investigation, Recording and Reporting 118 Tutor Marked Assessment (TMA) 131
  • 3. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 3 of 133 Element 1 – Foundation in Health and Safety Key Learning Outcomes At the end of this element, you should be able to: Outline the scope and nature of occupational health and safety Explain briefly the moral, legal and financial reasons for promoting good standards of health and safety Outline the role of national governments and international bodies in formulating framework for the regulation of Health and Safety Identify the nature and key sources of health and safety information Outline the key elements of a health and safety management Introduction The Management of Health and Safety is a broad subject, and incorporates aspects from many other disciplines, such as the Sciences, psychology and ergonomics. Based in legislation the requirements to manage health and safety places a number of requirements on the employer and employees and failures in these duties can result in prosecution which can lead to fines and imprisonment. In this first Element, you will be introduced to the scope of Health and Safety and the three main reasons for effective management which consist of Moral, Legal and Financial reasons. We will also outline the role of national governments and international bodies in formulating framework for the regulation of Health and Safety. The Element will also give you an understanding of the key sources of information of health and safety and outline the key elements of a health and safety management system. The Scope and Nature of Occupational Health and Safety Multi Disciplinary Nature of Health and Safety Health and Safety spans across all of the different industries and professions found in the Workplace. This means that the subject itself is vast and complex. Safety legislation has to consider and make provisions for the variety of industries in existence across the United Kingdom. In order to achieve this, Health and Safety has to include a multi disciplinary approach and incorporate the knowledge from backgrounds such as Engineering, Chemistry, Physics, Biology and Psychology to name a few. Due to the many different aspects involved within Health and Safety there can be competing and conflicting demands. For an organisation to be successful there needs to be a balance between earning and spending, between profit and loss. Equally, Health and Safety standards will aim to ensure that suitable provision is made within each organisation to ensure that in the pursuit of gain, the employer is not unreasonably exposing their workforce to situations that could put them in danger and lead to loss of life or impact on health. With so many disciplines involved across a wide range of industries it would be an overwhelming task to legislate for every eventuality. To balance this, Health and Safety Legislation is generally non prescriptive, allowing for interpretation and implementation of best practice, suitable for the nature of the organisation seeking to comply. Barriers to good standards can be varied. Economically, some organisations choose to see Health and Safety as a cost, a legal requirement that will provide no benefit to the organisation except for ensuring compliance. This is a very narrow view of the discipline and it is one that we will discuss in more depth later in this element to dispel this myth. There are other barriers that need to be noted, the general perception of safety in the workplace can be negative and can be
  • 4. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 4 of 133 viewed as more interested in stopping people working than keeping people safe. The fact that Health and Safety legislation is not prescriptive can also cause confusion. A common criticism is that the legislation is not clear and that the regulations lack a definitive rule to ensure compliance. As we have discussed briefly, this is simply not practical, because not every organisation will be able to implement measures in a set way due to the complexities and differences of organisations and other industry compliances that may also be required. Health and Safety is not just concerned with objects and premises, predominantly the objective is to protect people. To do this introduces a broader challenge, as it is an extremely difficult exercise to legislate for behaviour. Health and Safety legislation however, does seek to incorporate human failure and draws on psychological studies to assist with this task. This has lead to the development of Behavioural Safety as a discipline and the approach of engaging the workforce to re educate negative cultures and improve the standards within the workplace. Health, Safety, Welfare and Environmental protection Due to the complexities of Health and Safety, there are four main areas where protection will need to be afforded. We are obviously concerned with the Health of workers, and this can be affected by work through a multitude or reasons. Health is concerned with the physiological and psychological well being of the workforce. It will need to consider both short and long term illnesses and injuries, ill health caused through exposure to substances and any psychological illnesses too. Safety of the workforce involves the risks on a day to day basis that may lead to accidents occurring and how the workplace can be best managed to prevent incidents that may affect the overall safety of the workforce, the individual and the buildings, including plant and equipment that are present. Welfare is also a consideration within Health and Safety management and legislation. Appropriate welfare facilities are required for any workplace and this should include toilets, rest areas and washing facilities where appropriate. Environmental protection is given consideration within Health and Safety. Although there have been acts introduced which specifically focus on the Environment, there is a need to ensure that the environment within which workers will be required to work is safe and without risk. This will include assessing buildings and premise, the effects of the environment for outdoor workers and the effects that any operations may have on the environment. Each of these four areas will need consideration when assessing risks and implementing safe systems of work. They need to be an integral part of an organisations health and safety arrangements. Occupational Accidents, Dangerous Occurrences, Near Misses, Work-Related Ill-Health and Commuting Accidents To manage health and safety effectively, an organisation must be aware of the nature of incidents that might occur within the workplace. We will discuss these terms again in more depth during the rest of the course, but for an introduction, you will need to be aware of the definitions of accidents, dangerous occurrences, near misses and work related ill health and also be aware that the impact that these might have in relation to physiological and psychological effects. Occupational Accidents: “An unplanned and undesired event which results in harm to person or damage to property” Dangerous Occurrences: Dangerous Occurrences are events where had the inputs been different, could have resulted in a major incident. This could be something like a small fire, which luckily was spotted but could have been a major fire if it had happened at a different time of day for example.
  • 5. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 5 of 133 Near Misses: “An unplanned and undesired event which, under slightly different circumstances, could have resulted in harm to person or damage to property” Work Related Ill-health: In terms of Health and Safety, Ill Health refers to an illness which has been developed as a result of exposure to something within the workplace. A topical example of Ill Health is Asbestosis, a disease which is contracted due to inhalation of Asbestos fibres. It also covers issues such as Stress or Depression as a result of pressures at work. Physiological effects are concerned with the body and how events in the workplace will affect the body and the types of harm that could result, typical examples can range from serious damage such as broken bones, contracting of illnesses such as cancer through to minor knocks and cuts. There are also psychological effects that a worker may suffer such as stress and depression. Psychological effects are concerned with how events in the workplace will affect the workers mental health and the types of harm that could result, such as loss of confidence, mental breakdowns to give a few examples. It is worth noting that physiological and psychological effects are not mutually exclusive and often occur together due to the effects of an accident. Commuting Accidents Hazard and Risk The concepts of Hazard and Risk will be explored in more detail in later elements, as they form a core aspect of the management of health and safety. It is important that these terms are understood and that you are clear on the difference. A Hazard is anything with the potential to cause harm A Risk is the likelihood that harm will occur and the severity of that harm. The Moral, Legal and Financial Reasons for Maintaining and Promoting Health and Safety The Health and Safety “Problem” The media puts much emphasis on the restrictions of Health and Safety, often using “The World Gone Mad” scenarios, which have prevented events going ahead, or restricted the liberties of individuals and cited health and safety (mostly incorrectly) as the cause. The extent of the problem that is faced nationally is undermined by such reporting. Health and Safety still has a long way to go, to take an example nation with the United Kingdom, despite the wealth of Legislation a lot is still going wrong, which the following figures confirm: Each year in the UK; 245 work related deaths 30,000 major injuries 130,000 over three day injuries
  • 6. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 6 of 133 38.5 million work days lost 25,000 people leave the workforce due to harm suffered at work It is worth spending a few minutes looking at these figures and figures for the Country in which you are based, the ability to recall some of the statistics will assist you in this course. The need to provide a safe place of work, safe plant and equipment, safe systems of work, training and supervision and competent employees. The Health and Safety “Problem” clearly identifies that there are many things that an organisation can proactively manage to help to mitigate the risks of serious injury or ill health. Within the ILO Guidelines on Occupational Safety and Health Management Systems and within the Occupational Safety and Health Convention it is clearly identified that Employers should provide the basics of: A safe place of work Safe plant and equipment Safe Systems of Work Training and Supervision Competent Employees Each Nation will make suitable provision for this within their National Legislative Framework; in the United Kingdom for example these duties form Section 2 requirements of the Health and Safety at Work etc Act 1974. We will discuss these arrangements in more detail in later sections, but it is important that you are familiar with the basic requirements and how they are implemented within the Country in which you work/live. The Business Case for Health and Safety There are associated costs for the effective management of Health and Safety, and for every business before investment is made, the Organisation will want to understand the benefits that the service will bring. The decisions on how best to manage health and safety within an organisation will require some investment, which the organisation would ideally like a return on. The benefits of health and safety can’t be measured in the standard way of using sales forecasts, but there are significant cost benefits that you will need to be aware of and utilise in persuasion of the need for investment to improve Health and Safety. Health and Safety is deeply rooted within the means to prevent accident and injury and it is when such events take place that the true costs of the failure to manage safety are most apparent. When an accident occurs, there are two types of costs that are accrued; these are known as Direct and Indirect. Direct costs are concerned with the immediate costs of the accident. These will include the damage to any equipment, the cleanup of the accident and the loss of the worker if they have to take a leave of absence. Indirect costs are concerned with the less obvious costs, such as replacement labour, loss of sales, and loss of confidence of the workforce which may result in employees deciding to leave the company. The following diagram illustrates that the Insured costs are just the tip of an iceberg and underneath are far more substantial costs that can’t be insured- uninsured costs.
  • 7. © Phoenix Health & Safety 2011 The uninsured costs are estimated at around ten times the amount of the actual incident. These consist mostly of indirect costs. More examples include: Product and material damage Lost production time Legal costs Overtime & temporary labour Investigation time/Administration Supervisors time Fines Loss of expertise/experience Loss of morale Bad publicity There a lots of reasons to have a good health and safety management system, they can be categories under three main headings, Moral, Legal and Economic reasons. Moral Employers have a duty of reasonable care to those affected by the undertaking. It is also deemed as socially moral for organisations to seek to reduce accidents, injuries and the pain and suffering of employees in th gain. Morally it is not acceptable to put employees at risk or to expect them to risk life or limb in order for the organisation to make money or to achieve its goals. IGC1: Management of International The uninsured costs are estimated at around ten times the amount of the actual incident. These consist mostly of Investigation time/Administration There a lots of reasons to have a good health and safety management system, they can be categories under three main d Economic reasons. Employers have a duty of reasonable care to those affected by the undertaking. It is also deemed as socially moral for organisations to seek to reduce accidents, injuries and the pain and suffering of employees in th Morally it is not acceptable to put employees at risk or to expect them to risk life or limb in order for the organisation International Health & Safety Page 7 of 133 The uninsured costs are estimated at around ten times the amount of the actual incident. These consist mostly of There a lots of reasons to have a good health and safety management system, they can be categories under three main Employers have a duty of reasonable care to those affected by the undertaking. It is also deemed as socially moral for organisations to seek to reduce accidents, injuries and the pain and suffering of employees in the pursuit of financially Morally it is not acceptable to put employees at risk or to expect them to risk life or limb in order for the organisation
  • 8. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 8 of 133 Legal Legal reasons for having a good safety management system are that it will help to ensure compliance, which in turn will make Enforcement Action, such as notices and prosecution, which could lead to fines and imprisonment, less likely to occur. Controlling the risks effectively within the workplace will also prevent serious injury which in turn will reduce the likelihood of Claims seeking compensation for losses or injuries. Economic An effective health and safety management system will assist in avoiding costs of repairing/replacing damaged plant and equipment and the need to hire additional equipment. It will also avoid costs such as additional labour. Effective health and safety can improve production and product quality and boost motivation within the workforce. This will lower the staff turnover rate and save on costs such as retraining and job advertising. In turn, a motivated workforce and improved productivity will have a positive impact on the organisations image and reputation and will assist with the development of goodwill and stronger relationships with other organisations. Through the reduction of accidents and claims, Insurance issues will be less costly, such as achieving lower premiums due to the organisation demonstrating that it is a low risk. Internal resources will not be drained due to accident and incident investigations, attending court and facilitating enforcement officer visits, which can be very time consuming if the organisation is constantly involved with incidents. Directly associated with this is the avoidance of additional uninsured costs indirect , such as cleaning up area/ first-aid/ administration/ other staff days off due to stress. Employer’s Liability Insurance: Legally an Employer must have Employers Liability insurance. This insurance must be a minimum cover of Five Million within the United Kingdom. The Certificate of Insurance must be on display within the workplace to fulfil the legal requirements. The role of national governments and international bodies in formulating a framework for the regulation of health and safety Employer’s responsibilities The Guidelines provided by the ILO, Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001) clearly identifies the Employer’s responsibilities in so far as producing management systems. Key international bodies such as the ILO target ensuring that there is fair and equal representation for workers rights and works closely with its members to achieve harmonised standards. Based on the guidance from organisations such as the ILO, National Governments will set their own legislation to encompass the key principles. For example, in the United Kingdom this has been achieved through Section 2 of the Health and Safety at Work etc Act 1974. Section 2 (1): Every employer must ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees Section 2 (2):
  • 9. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 9 of 133 More specifically, employers must provide: a) Safe plant and systems of work b) Safe use, handling, storage and transport of articles and substances c) Any required information, instruction, training and supervision d) A safe place of work, including safe access and egress e) A safe work environment with adequate welfare facilities Section 2 (3): Employers with 5 or more employees must: Prepare a written health & safety policy Set down the organisation and arrangements for putting the policy into effect Revise and update the policy as necessary Bring the policy and arrangements to the notice of all employees Section 2 (4-7): Employers duties to consult with employees Now more specific regulations on the subject Section 3: Every employer and self employed person must conduct their undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in their employment who may be affected, are not exposed to risks to their health & safety Individual Countries will have their own provisions and it is important that you are aware of the scope of an Employers responsibilities. In essence, particularly for those within the EU, directives are issued which outline the key elements which a country must introduce into its legislation, but how it is then enforced is up to the individual country to decide. Effectively this ensures that there are shared principles across Countries, but the referencing will differ. Worker’s responsibilities and rights It is essential that within the standards set out for Health and Safety that the issues of workers’ rights and responsibilities are also sufficiently detailed. The ILO is keen to ensure that vulnerable groups are specifically considered, but this has not removed the requirement to place duties on the individual. Drawing once again on the United Kingdom’s provisions for this requirement, it is clear to see that with the scope of the Act, this has been given full consideration. Section 7: Employees Duties: To take reasonable care of themselves and others who may be affected by their acts or omissions at work To co-operate with their employer to enable him to comply with the law Section 8: Duty on Every Person:
  • 10. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 10 of 133 No person may misuse or interfere with anything provided in the interest of health, safety or welfare Not limited to employees There are also Regulations that are concerned with “Vulnerable workers” such as new and expectant mothers and Young Workers. The role of enforcement agencies and the consequences of non-compliance In each individual Country the nature and role of enforcement agencies will essentially be similar. The reason for the creation of the enforcement agencies is to ensure that any Health and Safety laws are complied with. To breach such laws will result in criminal action. It is therefore essential that you understand how the laws are upheld in the Country in which you live and/or work, as this will significantly differ between Countries. To allow further elaboration on this topic, I will use the example of the United Kingdom, although specifically England and Wales. Health and Safety Executive: Historically the Health and Safety Commission, who were involved with policy making and regulations and the Health and Safety Executive who were involved with enforcement of the regulations, had key responsibilities as external agencies for ensuring Health and Safety within UK. In April 2008, the HSC and the HSE merged, taking on the name of the Health and Safety Executive, but incorporating both roles. The role of the Health and Safety Executive is now twofold. They advise the Secretary of State in the creation and amendment of Regulations and they also provide information and guidance for all Industries. The Health and Safety Executive also provide Enforcement for directly regulated industries and we will learn more about inspectors and their powers shortly. Activities that are enforced by the Health and Safety Executive include: Construction Mine or quarry work Fairgrounds Agriculture Broadcasting and filming Railways Local Authorities: Local Authorities provide enforcement for industries that are not directly regulated by the Health and Safety Executive. This is achieved through Local Authority Inspectors, who work to the same guidance and with the same authority as Health and Safety Executive Inspectors. Activities that are enforced by the Local Authorities include: Retail Office Catering
  • 11. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 11 of 133 Laundrettes Churches and Worship Car parking facilities Provision of Childcare Fire Authorities: Since the introduction of the Regulatory Reform Order, the role of the Fire Authorities now involves Enforcement for fire related compliance. The Fire Inspectors have the same rights and authority as Health and Safety Executive Inspectors and have the ability to issue Improvement and Prohibition notices for Fire related breaches. The authority does not extend to enforcement of any other Health and Safety breaches or practices, except for Fire. Environment Agency: The Environment Agency is concerned with the impact that industry has on the environment. Certain industries will need specific authority to operate, typical examples of this include timber treatment works and where premises are directly located next to a river or main watercourse. The Environment Agency has the right to prosecute organisations for failure to comply with Environmental legislation and can trace back contaminated water to the source of the pollutant, but it is not just concerned with water. The agency will also respond to noise and air pollution, to name just a few examples. The Environment Agency also provides information and industry guidance on best practice. Scottish Environment Agency: The Scottish Environment Agency is the equivalent in Scotland and operates in the same remit, but due to legislative and organisational differences, the operations between Scotland and England and Wales are separate. Insurance Companies: Insurance Companies, in the terms set out in their policy can set particular standards across industries which require compliance for the insurance to remain valid. This has been particularly effective for the regular inspection required for lifting equipment, where the equipment must be subject to regular inspection by an independent person, which is usually from an Insurance company. The Insurance Companies stipulate minimum standards that must be achieved for insurance purposes, which is a strong incentive financially for organisations to comply. The Powers of Inspectors Inspectors are the main way in which compliance of organisations is tested and confirmed. Provisions for the powers of inspectors are set out in the Health and Safety at Work etc Act 1974 which permits them to stop works where necessary, issue notices and begin prosecution in cases of serious breaches. Inspectors also have the right to be involved in accident investigations. Regular visits by inspectors can be an invaluable resource for organisations, where the opportunity can be taken to review aspects of the operation and ask for guidance on improvement techniques and further measures that could be taken. Inspectors have a wealth of knowledge across many different industries and can offer great assistance. We will now look in a little more detail with regard to their powers.
  • 12. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 12 of 133 Powers: An Inspector may choose to visit a particular organisation for a number of reasons; routine inspections, following up of a complaint, to conduct an accident investigation, following the receipt of an incident reported under the Reporting of Incidents, Diseases and Dangerous Occurrences Regulations 1995. Due to the varied reasons for an Inspector to visit, you may or may not receive advance warning of the visit. Inspectors do have the right to enter premises at a reasonable time or where it is suspected there is a dangerous situation. In the event that an Inspector is refused entry, they do have the power to gain entry with assistance from the Police. The remit of Inspection, gives them the right to undertake examinations/inspections, to take measurements/photographs/recordings for the purpose of investigation and to ask and take copies of relevant documentation. It is also within their rights to request assistance or facilitation with the inspection from relevant people with control or responsibility within the organisation. The inspector also has the right to take authorised people or equipment/materials with them on the visit. In the event of unsatisfactory findings, the inspector has the right to take or render harmless, samples of articles or substances from the premises or atmosphere. They can also order premises or equipment to be left undisturbed for the purpose of investigations and they can require a person to answer questions and sign a declaration of truth. Inspectors have the power to issue notices and to initiate prosecution. We will discuss the matter of notices in more detail. Notices: There are two different types of notice that an Inspector can serve an Improvement Notice and a Prohibition notice. These have to be served in accordance with the Health and Safety at Work etc Act 1974. Improvement Notice: Such a notice can be served when, in the inspector’s opinion, there is a breach of relevant statutory duty provisions (or where there has been a breach which is likely to be continued or repeated). The notice will require the hazard to be resolved over a given time period. Failure to comply with the notice may result in a prohibition notice or prosecution. A typical example is a worn floor, which requires work to resolve the hazards. Prohibition Notice: This is the more serious of the notices and is issued when in the Inspector’s opinion there is, or is likely to be, a risk of serious personal injury. The notice will prevent the use of the equipment or premise in question and failure to comply with the notice is a criminal offence. A typical example is an unsafe scaffold. There is an appeal process for both of these notices, which will be heard at an Employment Tribunal. For the Improvement notice, the notice will be suspended until the appeal is heard. Prohibition notices continue to remain in force until an appeal has been heard. The appeal is also heard at an Employment Tribunal and for both types of notice an appeal must be lodged within twenty one days of receiving the notice. An appeal is designed for the person in receipt of the notice to contest it. An appeal will usually be made on the grounds of: Incorrect interpretation of the regulations made by the Inspector The inspector exceeded their powers
  • 13. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 13 of 133 The breach of the law admitted but the is claimed to be insignificant The breach of the law is admitted but the guidance to rectify is not possible or practical. International Standards and conventions The sources for International Standards in relation to Health and Safety stem from organisations such as the International Labour Organisation (ILO) and the International Standards Organisation (ISO). Founded in 1919, the International Labour Organisation (ILO) is the global body responsible for drawing up and overseeing international labour standards. It works with its member states to ensure that labour standards are respected in both practice and principle. It is also the only tripartite United Nations Agency, working with governments, employers and workers to shape policies and programmes. Further guidance about what it is and what it does can be found on their website, the information is also available in a number of different languages www.ilo.org. There is also the International Standards Organisation, you may be familiar with ISO, such as ISO 14001 (Environmental), ISO 9001 (Quality). They are the world’s largest developer and publisher of international standards and it is a non - governmental organisation that bridges between the public and private sectors. More information about ISO can be found at www.iso.org. Sources of Information on Health and Safety There is a wealth of information on health and safety available for all organisations to assist in the effective management of risks and to understand strengths and weaknesses of the management systems in place. The information comes from both internal and external sources. Internal Sources of Information Internal sources of information are collated and compiled from within an organisation. The information is collected from reactive methods, such as accident and ill health data. This enables an organisation to understand the incidents that have caused injury, damage or loss and to assess the weaknesses of the current arrangements. Absence records can also assist in understanding the scope of absence from work and the underlying causes. There are also active monitoring records that can assist, such as completed Inspections and maintenance reports. These can be used to assess how effectively arrangements are being carried out and indicate areas where more investment or further processes might be required. Audits can provide a wealth of structured information, which systematically go through the arrangements and identify areas where compliance is strong and also where it requires further development. Audit scores can be used in setting targets and objectives for the following year. Investigation reports provide a key opportunity to understand failures and to identify areas where improvements are required. The use of internal information sources can be collated and used for comparison against other companies within the same industry, this gives an organisation the opportunity to measure itself against competitors and to identify where improvements can be made and to develop a stronger position within the market place. External Sources of Information External sources of information come from a range of providers. Legislation and ILO guidance and information provides critical sources that can be used by an organisation to firstly ensure compliance and secondly outline areas for
  • 14. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 14 of 133 improvement and further development. Such sources of information can be of great assistance when problem solving solutions for particular risks. Manufacturer’s data is also invaluable; it will provide guidance on maintenance requirements, safe operations and the vital statistics of any equipment or machinery being used within the workplace. British, European and International Standards provide further information and compliance requirements and standardise safety requirements so that at the purchasing stage an organisation can identify the required standard and purchase appropriately graded equipment. Trade associations publish a wealth of information on all aspects of safety, whether it is in relation to working practices, particular equipment or the human effects of the workplace. Trade associations make survey results known and have a larger resource than many individual organisations for the commissioning of studies, so the reliability of the studies increases due to the numbers involved. IT sources and Encyclopaedias are a great resource for the health and safety professional and ensure that the practitioner or the organisation is kept up to date with developments, recent events and topical discussions. Sources of Information Overall the types of information that an organisation may wish to consult when measuring performance, deciding upon safe methods of working and assessing the efficacy of health and safety management include: Risk assessments Employees/ safety reps Results of observing/ analysing tasks/ JSA/ identification of repetitive actions Ill-health reports/ analysis of absenteeism records/ accident reports Supervisors (e.g. number of complaints) Published information (e.g. guidance from the enforcing authority) Manufacturers’ information Training records/ competencies Employee records (e.g. details of age, disabilities etc ) Results of surveys/ questionnaires/ interviews/ production records machine faults Specialists (e.g. ergonomists/ occupational health) Other employers/ trade bodies Social activities co-ordinator (e.g. Information on recent out of work activities (e.g. new squash/ tennis/ cricket league) In terms of sources of information that are provided by websites and publicity offices of national and international agencies, it is important to be aware of: International Labour Organisation (ILO) Occupational Health and Safety Administration (for the USA) European Agency for Safety and Health at Work (within the EU) Health and Safety Executive (within the United Kingdom) Worksafe (within Western Australia)
  • 15. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 15 of 133 The Key Elements of a Health and Safety Management System To assist with achieving compliance and to effectively manage risks within an organisation, the creation and use of a health and safety management system is a critical tool. A Health and Safety Management system should include: Setting a Policy Organising Planning and Implementing Evaluation (Monitoring, review, measurement, investigation) Auditing Action for improvement (preventative and corrective action, continual improvement) The ILO has produced a guidance document title “Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001) there is also the widely acknowledged framework of OHSAS 18000 Series. Policy To set clear aims and objectives/targets To state intentions/define approach To lay down criteria/principles for action and response The policy is the starting point for the health and safety management system. It should clearly state the aims of the organisation, with defined objectives and targets. This sets the standard for the organisation and clearly shows commitment to managing safely. Organising for Health and Safety To allocate responsibilities for health and safety To establish effective communication systems (hazards/risks) To establish commitment at all levels The organisation of health and safety should clearly allocate responsibilities for named people and clearly define communication systems. Most organisations choose to allocate responsibilities for health and safety for every role, from employees through to senior management. This gives ownership across all levels of a business and clearly demonstrates a strong commitment to health and safety management. Planning and Implementing To assess the risks faced by employees, etc To introduce controls/safe systems of work/documentation The Planning and implementing stage includes introducing workplace controls such as safe systems of work and procedures. These ideally should be in writing for clarity and ease of reference. These procedures can then be audited to ensure efficacy. It is also at this stage that the risks faced by employees are assessed and measures put in place to mitigate those risks.
  • 16. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 16 of 133 Evaluation (Monitoring, Review, Measurement, Investigation) Monitoring and Measurement To provide data on achievement/lack of achievement By use of active (inspections, etc)/reactive (accidents, etc) monitoring systems It is critical to measure performance to ensure that the Safety Management system is effective and is providing adequate protection through the implemented measures. Measuring performance gives an organisation the opportunity to prove achievements have been made and to also identify where weaknesses remain. Measuring performance can be reactive, by looking at history, such as accidents and also active, where the use of inspections is used to identify weaknesses prior to anything going wrong. Review To evaluate performance (trends, benchmarking, etc) To review options for remedial action to improve performance to set new targets A regular review will assist to evaluate performance; it can be used to identify trends and benchmarking for performance comparisons. It also provides an opportunity to review remedial actions that can be used to improve performance, by which new and more challenging targets can be set. This helps the organisation to plan for continuous improvement. Audit To provide an independent/structured examination of all parts of SMS To assess compliance with health and safety management procedures To identify where standards inadequate The Audit stage aims to provide a structured examination of all aspects of the safety management system, and provide and independent review of existing measures. The audit measures performance against the procedures and will assess compliance. The findings of an audit will provide information on areas where standards have been found inadequate, so the organisation can target these for further development and improvement. Action for Improvement (preventative and corrective action; continual improvement This final section is a direct output from the Audit process. On completion of audits, the findings will identify corrective actions. These are often communicated in terms of non compliance or suggested actions. It is an essential part of a Health and Safety Management System to seek continual improvement. This forms a key concept in models such as the OHSAS 18000 series. Preventative actions can become apparent outside of the Audit process, for example when Legislative changes take place, as key finding from Accident/ Incident Investigations and from guidance issued by national or international agencies, such as the ILO or Health and Safety Executive.
  • 17. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 17 of 133 Figure 2 – Main elements of the OSH management system This diagram is from the ILO-OSH 2001 and illustrates the process of the recommended management system and the relationship each stage has with the Auditing process. The implementation of a Health and Safety Management system is a valuable tool for an organisation, but it does require commitment throughout the organisation and the original buy in from the directors or bosses of the organisation for the system to be successful. The process does involve time and commitment and there is some cost involved. There are significant economical benefits to implementing a health and safety management system however and these include: Increased productivity (less down-time, improved morale) Reduced legal action costs (fewer fines, civil claims, etc) Reduced accident costs (investigation, equipment damage, etc) Lower sickness rate Reduced insurance premiums Better corporate image (increased sales/contracts, etc) Improved product quality (fewer failures, etc) Reduced employee turnover Legal Requirements and Guidance Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001) ISBN 0-580-37805-5 ILOLEX (ILO database of International Law) http://www.ilo.org/ilolex/index.htm Occupational Health and Safety Assessment Series (OHSAS 18000): Occupational Health and Safety Management Systems OHSAS 18001:1999 (ISBN-0-580-28298-8), OHSAS 18002:2000 (ISBN: 0-580-33123-7), BSI Occupational Safety and Health Convention (C155), ILO Occupational Safety and health Recommendation (R164) ILO
  • 18. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 18 of 133 Activity – Financial Reasons An accident has occurred at the offices of a company called Example Stationery Ltd. Mrs. Careless (a trained secretary, who has been with the company for 15 years) has tripped on a lifting carpet tile and fallen down the stairs. It appears that her leg is broken, and an ambulance has been called and taken her to hospital. There were several friends and co-workers who witnessed the accident and horrific injuries sustained. A trained first aider attended the scene first and administered basic first aid until the ambulance arrived. The area was immediately cordoned off, and management began an investigation with a couple of hours. The investigation team was made up of the Operations Director, the Health & Safety Advisor and the Trade Union Representative. The following day, a Health & Safety Inspector arrived on-site and began his own investigation. It is estimated that Mrs. Careless will be unable to return to work for at least 6 months. List as many different financial costs as you can. Try to identify which ones the company would be able to insure against. Write your answers in the space below: You have now completed IGC1 Element One. Spend some time attempting to answer the following questions. Pay attention to the wording of the questions and the points available to give you an idea of how much information is required. To help you the action verbs have been highlighted in bold. Revision Questions 1. List EIGHT possible costs to an organisation when employees are absent due to work-related ill health. (8 marks) 2. The number of absences due to upper limb disorders in an organisation appears to be increasing. Outline the possible sources of information that could be consulted when investigating this problem. (8 marks)
  • 19. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 19 of 133 Element 2 – Health & Safety Policy Key Learning Outcomes At the end of this element, you should be able to: Explain the purpose and importance of setting policy for health and safety Describe the key features and appropriate content of an effective health and safety policy. Introduction For an organisation to ensure that it manages the local requirements and associated regulations there needs to be a method of communicating how the requirements are going to be met. This can be achieved by detailing it as part of a Health and Safety Policy. Based on the guidance from organisations such as the ILO, National Governments will set their own legislation and guidance to achieve the occupational health and safety management framework. For example, in the United Kingdom this has been achieved through the Health and Safety at Work etc Act 1974 As an example, the Health and Safety at Work etc Act 1974 requires; where an organisation has five or more employees this Policy must be in writing and should contain three individual sections: Statement of Intent Organisational Responsibilities Arrangements for Implementation Within this Element we will discuss the importance of setting policy for health and safety, the key elements to be included within the policy and how this can be measured and reviewed to ensure compliance. The Importance of Setting Policy for Health & Safety The Role of the Policy in Decision Making Every organisation will need to decide how it is going to manage the requirements for health and safety. The overall aim of the health and safety policy is to clearly define the parameters of the organisations’ undertaking and how it will allocate roles and responsibilities to manage the areas of significant risk. This is the opportunity for the organisation to display its commitment to safe working practices and should be driven from Senior Management through to the general workforce. Organisations may also be required to produce annual Corporate Responsibility reports for their Stakeholders and health and safety performance will form a portion of the information required. The policy should reflect the areas of performance and allow the organisation to benchmark against other organisations and target improvement. The policy forms the commitment that an organisation will give to health and safety arrangements and it is through the arrangements set out in the policy that the organisation will be measured and reviewed. Therefore, it is a very important document not just for legal compliance but as a measure of performance.
  • 20. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 20 of 133 Key Elements of a Health & Safety Policy As with any policy written by an organisation, the overall aim is to state what the organisation wants to achieve, who the key people are and what processes are involved to ensure correct delivery - health and safety policies are no different. Due to the varying needs of organisations, there is no one formal template for a Health and Safety Policy. It has been deemed inappropriate for something so inflexible to be issued within the legislation, but instead clear guidance has been set out for what is expected to be in a policy. As we have discussed the key elements of a health and safety policy fall into three sections: Statement of Intent Organisational Responsibilities Arrangements for Implementation Or, in simpler terms: WHAT we intend to achieve WHO is responsible HOW it will be done We will go through each element in detail in the next section. The Key Features and Content of a Health & Safety Policy Statement of Intent The Statement of Intent is usually kept to one page. It defines the general aims and objectives of the organisation and demonstrates management commitment. To clearly demonstrate the importance of the overall policy, the Statement of Intent is signed by the most Senior Person in the company, often the Managing Director (MD) or the Chief Executive Officer (CEO). The signature is also accompanied by a date, which will set the review period. The review period is usually annually, but a review may be required prior to this if there are significant changes. Organisational Responsibilities The second section of the policy should define how health and safety will be organised. This requires the organisation to define health and safety roles and responsibilities for each category of person within the organisation. Often this is supported by an organisation chart, which will indicate the flow of accountability, communication and feedback. Often the Organisation section delegates responsibility according to position within the Organisation. Such positions may be for example: Directors/Senior Managers (who may be required to set general policy and objectives, ensure adequate resources are available, ensure competent advice is in place etc.) Middle Managers (who may be required to implement policy in their area of responsibility, carry out risk assessments, devise safe systems of work, identify training needs etc.) Supervisors (who may be required to check day to day compliance with the policy, investigate accidents etc.) Competent Persons/Safety Advisors (who will have specific health and safety responsibilities/advising company on accident prevention and compliance) Occupational Health Persons (who will be responsible for health issues and health surveillance)
  • 21. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 21 of 133 Safety Representatives/Representatives of Employee Safety (who will be responsible for representing the workforce in relation to Health and Safety consultation with management) Employees (will have general health and safety responsibilities for themselves and others and to comply with policy) First Aiders/Appointed Persons (who will be trained to provide first aid to injured persons, or appointed to summon assistance in the event of an emergency) Fire Marshalls/Responsible persons (who will have specific duties to support evacuating buildings safely and fire related duties) In larger organisations, there should be a keen focus on line managers. This front line facing management role, is the key area of interaction between management and the workforce and therefore it is of great importance. The line manager will be viewed as the recognised face of management and their acts or omissions will generally define how the workforce perceives how importantly the organisation views health and safety. It will often be the line manager who is driving through the implementation of policies and measuring the effectiveness of them. A weakness at this level will be of great disadvantage to both the organisation and to the workforce, and could lead to increased risk of loss and injury. Imagine that you are working in an area that requires the use of Personal Protective Equipment, such as protective footwear. If you are busy working and your line manager walks in without correct footwear, what impression does that give? Would that make you feel that the organisation has a strong commitment to health and safety? Health & Safety Arrangements The Arrangements section provides the opportunity for an organisation to detail procedures for implementing the health and safety policy. The arrangements should ensure that there is sufficient scope for the organisation to control hazards, consult and communicate with the workforce and provide a means for monitoring compliance. Without the arrangements section, there is no clarity on how the organisation will ensure that the objectives set out within the Statement of Intent are being fulfilled and it will not inform the workforce about how health and safety will be managed. The Arrangements section will of course be totally specific to the organisation, depending on what activities are being conducted on a day to day basis, however there are some elements that would normally be included. The following table details the issues that should be included as a minimum, and the kind of details that may be required to be described: Section Detail Risk Assessment When they are carried out. Forms/templates to be used. Who is to carry them out, and their level of competence. When they should be reviewed etc. Health & Safety Training Identification of training needs. Arrangements for induction training. Frequency of refresher training. Specific tasks that require additional training e.g. forklift trucks, specific vehicle licences, operating machinery etc. Storage of training records. Consultation with Employees Methods for consulting with employees e.g. safety representatives, direct consultation with individuals etc. Terms of reference for health and safety committee etc.
  • 22. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 22 of 133 Section Detail Monitoring Health & Safety Performance Arrangements for regular inspections of the workplace. Arrangements for investigating accidents, incidents and ill-health. Arrangements for regular audits of health and safety performance. Who is to carry out the monitoring, their competence etc. Managing Contractors How the competence of contractors is assessed. Who is responsible for the initial assessment/appointment of contractors, and their level of competence. How the assessment of contractors is recorded and reviewed. Management of contractors working on site etc. Safe Systems of Work/Permits to Work Who is responsible for developing safe systems of work, and their level of competence. How the safe systems are documented and communicated to relevant staff. The jobs that require formal permit to work systems. The training required in operation of the permit system etc. Disciplinary Procedures for Non-Compliance Which breaches constitute a breach of discipline, and which ones constitute gross misconduct. Procedures for disciplinary hearings, formal warnings and dismissal where appropriate. Emergency Procedures The types of emergency that require procedures e.g. fire. The actions to take in an emergency. How often procedures will be tested. Who is responsible for certain actions in the event of an emergency e.g. roll call, fighting fires, calling for help etc. First Aid The names and location of first aiders, and how they can be contacted. The location of first aid equipment e.g. kits, eye wash stations, emergency showers etc. Arrangements for ensuring first aid kits remain fully stocked etc. Accident Reporting and Investigation The definition of an accident. Who accidents should be reported to, and when. Documents to be used to record accidents e.g. accident book, report form etc. Who should investigate accidents, and their level of competence. Forms to be used to document the investigation etc. Arrangements for Control of Specific Hazards e.g. Hazardous Substances, Manual Handling, Transport, Machinery etc. Arrangements for specific risk assessments. Arrangements for specific training. Responsibility for implementing particular control measures etc. It is important to note that these are just examples – an organisation’s policy and its contents should be specific to the organisation. It should be written to meet their particular needs, objectives and targets.
  • 23. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 23 of 133 Policy Review The health and safety policy should be monitored and reviewed on a regular basis; this ensures that the information within it remains up-to-date and relevant. Though the passage of time is a very good reason to regularly review a policy (most companies adopt an annual process) there may be other factors that require a review to be conducted. Changes in key personnel may require a review of the policy, particularly if their role/responsibilities have been documented in the Organisational Responsibilities section. The Statement of Intent will be signed by the most senior person in the organisation, so if there is a change then this should also prompt a review. There may also be changes to procedures, systems of work and possibly organisation structure. As these are all detailed within the policy, when any element changes these must also be updated in the policy and the policy reissued. Other reasons to prompt a review will include any accidents/incidents/ill Health, where the key findings indicate that a change is required in the management of the significant risks. A company may for example decide to introduce health surveillance, which will need to be included within the Arrangements section. Enforcement action, by enforcement officers, may provide input to change or modify the organisations existing policy or they may indicate that there are short falls within the arrangements of certain risks, in which case once the improvements have been decided, they should be updated within the policy. The organisation through the continual review of its arrangements may also identify weaknesses that require addressing and the improvements may need to be detailed within the policy. This may be as a result of monitoring activities for example inspections of the workplace, or management audits. Other changes might be the organisation moving to a different premise which may require alterations within the policy or where there have been changes in legislation, which require the organisation to alter how it manages risks. Communication of the Health & Safety Policy Simply producing a policy is not enough – it has to be communicated to employees and other interested parties. It is pointless having a detailed policy if it is locked away in the Safety Advisor’s draw. The policy can be communicated to employees by a variety of methods, and it is up to the organisation to decide on the method that best suits them. Some examples of how the policy can be communicated are: Issue a hard copy to each individual employee, and obtain a signature of receipt and understanding (easy in smaller businesses, but may prove problematic in larger organisations) Email a copy to all employees and add accept/reject buttons to the email, or request a read receipt (suitable for organisations where everyone has access to email) Training courses (it is good practice to include the policy in every health & safety training course) Display the policy on notice boards or the intranet (for detailed policies, it may be more appropriate to just display the one page Statement of Intent on a notice board or in reception) Employee handbooks Can you think of any more ways to communicate the policy? As well as employees, there are a variety of other groups that may be interested in the contents of the health & safety policy: Visitors Contractors
  • 24. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 24 of 133 Enforcing Authorities Clients/Customers Shareholders Legal Requirements and Guidance The Guidelines provided by the ILO, Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001) clearly identifies the Employer’s responsibilities in so far as producing management systems. For example, in the United Kingdom this has been achieved through the following legislation: Health and Safety at Work Etc Act 1974 The Management of Health and Safety at Work Regulations 1999 Section 2(3) of the Health and Safety at Work Etc Act 1974 requires that every organisation with 5 or more employees should have a documented health and safety policy. It also requires that the policy must be brought to the attention of all employees and that it be reviewed and revised as appropriate. Regulation 5 of the Management of Health and Safety at Work Regulations builds on this and requires that every employer makes arrangements for the nature of their activities which include effective planning, organisation, control, monitoring and review of the preventive and protective measures. Although the regulations do not specifically say so, these arrangements would normally be detailed in the health & safety policy. Sample Health & Safety Policy A sample of a UK health & safety policy for a small to medium business has been included on the following pages. It should serve to illustrate the points we have made in this element.
  • 25. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 25 of 133 Health & Safety Policy General Statement of Intent The company believes that health & safety is a vital component of the business – a good health and safety record goes hand in hand with high productivity and quality standards. Employees are the most important asset to this company, and therefore their health, safety and welfare is a priority at all times. The company believes that prevention is not only better, but cheaper than cure. Profits and safety are not in competition - on the contrary, good health & safety is good business. From a legal perspective, the company is committed to ensuring that it complies with all relevant health and safety legislation. Where it is reasonably practicable to do so, the company will strive to go beyond the requirements of legislation. The company is committed to ongoing monitoring and review processes, so that continual improvement in the management of health and safety can be achieved. Our general intentions are:- To provide adequate control of the Health and Safety risks to employees and others arising from our work activities; To consult with our employees on matters affecting their Health & Safety; To provide and maintain safe plant and equipment; To ensure safe handling and use of substances; To provide adequate information, instruction and training supervision for employees; To prevent accidents and cases of work related ill health; To maintain safe and healthy working conditions; and To review and revise this policy at regular intervals. Signed: John Smith Job Title Managing Director Date: 1st January 2009 Review Date: 1st January 2010
  • 26. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 26 of 133 Organisational Responsibilities Overall and final responsibility for health and safety is that of: John Smith Day-to-day responsibility for ensuring this policy is put into practice is delegated to: Joe Bloggs, Health & Safety Advisor To ensure that health and safety standards are maintained and improved, the following people have responsibility in the following areas: Name Responsibility Jane Doe Office Mike Evans Warehouse Organisation Chart Directors Responsibilities Ensure the Company has access to competent Health and Safety advice as required by the Management of Health and Safety at Work Regulations 1999. Ensure that there exists an effective policy for Health and Safety management, supplemented by additional documents and safe systems of work relating to the required performance in each particular area and type of activity and that this document is implemented throughout the business. Ensure this policy is routinely reviewed on an annual basis to ensure the arrangements for health and safety remain current and valid. Ensure that necessary resources and information is made available for the policy to be effectively put into practice. Ensure that Line Managers are inducted and trained to enable them to carry out their role effectively. Ensure that Line Managers carry out their respective duties regarding health and safety within their areas of control. Ensure that all accidents, incidents, diseases and/or dangerous occurrences are reported to the Enforcing Authority where required. Co-operate and assist, as necessary, with all enforcing authorities and any other external body concerned with Health and Safety in the course of their duties. Managing Director Operations Director Operations Manager Commercial Director Sales Manager Human Resources Director Health & Safety Advisor
  • 27. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 27 of 133 Line Managers Responsibilities Co-operate with Directors on health and safety matters Ensure that the duties and responsibilities for safe working are properly assigned, accepted and understood by all personnel working in or entering the workplace. Budget for adequate workplace resources to fully implement the health and safety policy. Ensure that the health, safety and welfare arrangements within their workplace are effectively implemented in accordance with the specific procedures detailed in this policy. Ensure that all recommendations from the risk assessments are implemented within the relevant timeframes. Ensure that all accidents and near misses are reported and investigated to determine if further controls are necessary to prevent a re-occurrence. Ensure that Health and Safety training is provided to all new workplace employees as part of the company’s overall training programme. Ensure that all employees within the workplace have been briefed on and understand the Health and Safety Policy along with any safe working systems/procedures relevant to their work. Ensure employees have access to all necessary and relevant information appertaining to their health, safety and well-being at work. Ensure that necessary protective clothing and equipment is correctly used and maintained in good order by employees under their control, and by any visitors and external contractors in the department. Employees Duties Co-operate with Line Managers and Directors on health and safety matters. Not interfere with or misuse anything provided to safeguard their health and safety. Take reasonable care of their own health and safety, and that of others. Use equipment and substances correctly, in accordance with training and instructions received. Use personal protective equipment correctly, in accordance with training and instructions received. Report all health and safety concerns to their Line Manager or a Director. Stop work and seek advice if they believe there is an imminent risk of injury to themselves or others. Report any near miss or accident immediately. Assist at all times in maintaining good housekeeping standards. Non-compliance with health and safety rules and procedures can result in disciplinary action, which may include immediate dismissal if appropriate.
  • 28. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 28 of 133 Arrangements for Implementation All company policies and procedures in relation to health and safety are regarded as supplementary to this policy. Risk Assessment The company will carry out risk assessments of all activities that present a risk to employees or others. These risk assessments will be carried out in line with the ILO, Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001), and the procedure for doing so is as follows: 1. Identify the significant hazards involved in our activity. 2. Decide who might be harmed and how. 3. Evaluate the level of risk and decide if existing precautions are sufficient, or if more needs to be done. 4. Record the significant findings of the assessment. 5. Review the assessment when things change, or there is reason to believe that it is no longer valid. Risk assessments will be undertaken by: Joe Bloggs Approval for the required action to remove or control risks will be given by: John Smith Health & Safety Advice The company has access to competent Health & Safety advice. Health & Safety advice is available from: Joe Bloggs Qualifications in Health & Safety: NEBOSH International General Certificate Consultation with Employees The company will consult with its employees. Employee Representative(s) are: Bill Jones Sarah Thomson Mark Wilkinson Consultation with employees will be provided by: Monthly team meetings with health & safety as a standing agenda item.
  • 29. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 29 of 133 Plant, Machinery and Work Equipment The company will ensure that all plant and equipment is suitable and without risks to health and safety, in accordance with legislation such as the Provision and Use of Work Equipment Regulations 1998, the Lifting Operations and Lifting Equipment Regulations 1998 and the Electricity at Work Regulations 1989. All employees are required to carry out a visual check of any equipment before it is used. In some cases, this check will need to be documented. The company will advise when this is the case. Responsibility for identifying all plant and equipment needing maintenance is that of: Joe Bloggs Responsibility for ensuring that all identified maintenance is implemented is that of: Mike Evans Any problems with plant or equipment should be reported to: Mike Evans Responsibility for checking that new plant and equipment meets health and safety standards before it is purchased is that of: Joe Bloggs Portable electrical appliances are tested by/every: W.E. Testem Electrical every 12 months The fixed electrical installation is tested by/every: W.E. Testem Electrical every 5 years Hazardous Substances The company will assess and control health risks from exposure to hazardous substances in accordance with the Control of Substances Hazardous to Health Regulations (COSHH) 2002. Chemical Safety Data Sheets are obtained by: Joe Bloggs Chemical Safety Data Sheets are stored at: Chemical store in warehouse COSHH assessments will be carried out by: Approval for the required action to remove or control risks will be given by: John Smith
  • 30. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 30 of 133 Manual Handling In accordance with the Manual Handling Operations Regulations 1992, the company will eliminate the need for manual handling where possible. Where elimination is not possible, the risks from manual handling will be assessed and reduced, so far as is reasonably practicable. Manual handling risk assessments will be carried out by: Joe Bloggs Approval for the required action to remove or control risks will be given by: John Smith Display Screen Equipment The company will assess and control health risks from exposure to display screen equipment in accordance with the Health and Safety (Display Screen Equipment) Regulations 1992. Employees that are classed as habitual Display Screen Equipment users are entitled to free eye tests, and vision correction appliances where these are only needed for work with display screen equipment. Display screen equipment risk assessments will be carried out by: Jane Doe Approval for the required action to remove or control risks will be given by: John Smith Information, Instruction, Training and Supervision The company will provide adequate information, instruction, training and supervision to employees in accordance with the general duties on employers under Section 2 of the Health and Safety at Work etc. Act 1974 and various regulations. All employees will be provided with information on the significant findings of any risk assessments relevant to their particular activity/workplace. This will include information on the hazards and relevant control measures. All information, instruction and training given to employees will be recorded on individual training records. In certain instances, employees will be asked to sign to confirm receipt and/or understanding. Induction training for all new employees is the responsibility of: Joe Bloggs Training will be identified, arranged and monitored by: Line Managers as part of the training needs analysis process Training records are kept at/by: Personal files, managed by Jane Doe
  • 31. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 31 of 133 The Health and Safety Law poster is displayed at: Kitchen Supervision of young workers/trainees will be arranged/undertaken/monitored by: Joe Bloggs Responsibility for ensuring that our employees who work at locations under the control of other employers are given relevant health and safety information is that of: Joe Bloggs Accidents, First Aid and Work Related Ill-Health The company is committed to preventing accidents and cases of ill-health to employees and others who may be affected by its work activities. However, the company recognises that failures can occur and will investigate all accidents and ill-health to identify the immediate and underlying causes so as to prevent recurrence. All reportable incidents, as defined by the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 will be reported to the enforcing authority within the relevant timeframes. The following types of work related incident/accident need to be reported: • Death • Major Injuries e.g. broken bones, dislocations, amputations, loss of sight etc. • Any accident resulting in more than 3 days lost from work • Any non-employee being taken directly to hospital • Certain types of disease e.g. dermatitis, asthma, upper limb disorders, TB etc. • Certain types of dangerous occurrence, even when no-on is injured e.g. scaffold collapse, overturn of lifting equipment, electrical fires/explosion etc. The company will provide adequate first aid personnel and equipment, in accordance with the Health and Safety (First Aid) Regulations 1981. All accidents and work related ill-health should be immediately reported to: Joe Bloggs All accidents and work related ill-health are recorded in the accident book, which is kept by/at: Joe Bloggs All hazards/near misses should be reported to: Responsibility for investigating accidents/ill-health/hazards/near misses is that of: Joe Bloggs PPE will be issued to employees by: Joe Bloggs Any problems (e.g. defects/loss etc.) with PPE should be reported to: Joe Bloggs
  • 32. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 32 of 133 Managing Contractors The company recognises that it owes a duty to contractors as well as employees, as stipulated by the Health and Safety at Work etc. Act 1974 Section 3 and the Management of Health & Safety at Work Regulations 1999. In the first instance, the company will ensure that only competent contractors are selected. From then on, the activities of appointed contractors will be adequately managed. Competence of contractors will be assessed by: Joe Bloggs Contractors working on site will be managed by: Joe Bloggs Any problems/hazards arising from the activities of contractors should be reported to: Joe Bloggs Information on site hazards/controls/safety rules will be provided to contractors by: Joe Bloggs Welfare Facilities The company is committed to providing suitable and sufficient welfare facilities to employees, in accordance with the Workplace (Health, Safety and Welfare) Regulations 1992. Adequate numbers of toilets and washing facilities are provided for the number of staff required to use them. Toilet paper, soap and means for drying hands will always be available. Cleaning is carried out by/every Toilets – Sparkle Cleaning every day Rest areas – Sparkle Cleaning every day Other areas – Sparkle Cleaning every week Problems with cleanliness/hygiene standards should be reported to: Jane Doe Drinking water is available at: Kitchen Emergency Procedures – Fire and Evacuation The company will have in place procedures to follow in the event of emergency. These will be communicated to all employees and will be tested on a regular basis. In the event of a fire, immediately sound the alarm. Only attack the fire if trained to do so – do not put yourself at risk. Dial 999 and ask for the fire brigade – give address and ensure it is heard. Evacuate the building by the nearest exit. Do not stop to collect personal belongings. Do not re-enter the building until told it is safe to do so.
  • 33. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 33 of 133 Responsibility for ensuring the fire risk assessment is undertaken and completed is that of: Joe Bloggs Approval for the required action to remove or control risks will be given by: John Smith Fire extinguishers are maintained and checked by/every: Drenchem Fire every 12 months Emergency evacuation will be tested every: 12 months The fire alarm will be tested by/every: Joe Bloggs, every week Emergency lighting will be tested by/every: Joe Bloggs, every month Legal Requirements and Guidance Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001) ISBN 0-580-37805-5 ILOLEX (ILO database of International Law) http://www.ilo.org/ilolex/index.htm Occupational Health and Safety Assessment Series (OHSAS 18000): Occupational Health and Safety Management Systems OHSAS 18001:1999 (ISBN-0-580-28298-8), OHSAS 18002:2000 (ISBN: 0-580-33123-7), BSI Occupational Safety and Health Convention (C155), ILO Occupational Safety and health Recommendation (R164) ILO
  • 34. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 34 of 133 Activity – Health & Safety Policy ABC Supplies Ltd. is a supplier of protective equipment, tools, cleaning products etc. to the construction industry. It employs approx. 50 staff, and its premises consist of a warehouse, mezzanine floor, yard area and offices. The warehouse holds 10 bays of storage racking. Pallets are removed from the racking by forklift truck and placed on the floor. The goods are then placed by hand onto trolleys and pushed to the front of warehouse ready to be picked up and delivered by the delivery vans. The delivery process is contracted out to a local firm. The offices contain sales, admin and finance departments, as well as being home to the Directors. Identify the issues that should be included in the arrangements sections of ABC Supplies Ltd’s Health & Safety Policy.
  • 35. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 35 of 133 Revision Questions You have now completed IGC1 Element Two. Spend some time attempting to answer the following questions. Pay attention to the wording of the questions and the points available to give you an idea of how much information is required. To help you the action verbs have been highlighted in bold 1. a.) Outline the legal requirements whereby employers must prepare a written statement of the health and safety policy (2 marks) b.) Explain the purposes of EACH of the following sections of a health and safety policy document: i. ‘statement of intent’ (2 marks) ii. ‘organisation’ (2 marks) iii. ‘arrangements’(2 marks) c.) Outline the issues that are typically included in the arrangements section of a health and safety policy document. (12 marks) 2. Outline the circumstances that may give rise to a need for a health and safety policy to be reviewed. (8 marks) 3. Identify SIX categories of persons who may be shown in the ‘organisation’ section of a health and safety policy AND State their general or specific health and safety responsibilities. (6 marks)
  • 36. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 36 of 133 Element 3 – Organising for Health and Safety Key Learning Outcomes At the end of this element, you should be able to: Outline the legal and organisational health and safety roles and responsibilities of employers, managers, supervisors, employees and other relevant parties. Explain the importance and means of consulting with employees on health and safety issues and the means to achieve effective consultation. Introduction Organising for Health and Safety will require careful thought and consideration. To fail to organise could lead to significant failures within the management of health and safety. The consequences for failing to organise for health and safety are serious, but within this Element we will discuss the methodology for effective organising, so that the key legislative requirements can be achieved and we will establish how an Organisation can structure its health and safety management to avoid such problems. Legal and Organisational Health and Safety Roles and Responsibilities Every organisation will need to ensure that it clearly defines safety roles and responsibilities across the workforce. The responsibilities will need to include provisions for anyone affected by the activities of the organisation; this will include employees of all levels but will also include third parties such as Visitors, Contractors, Members of the Public and also trespassers. The legal and Organisational Roles and Responsibilities: R164 Occupational Health and Safety recommendation suggests that each country does set out duties that the Employer should be held accountable for. You will see that this reflects Section 2 duties of the Health and Safety at Work etc Act 1974, and should also reflect the relevant legislation for the Country in which you are based. IV. Action at the Level of the Undertaking 10. The obligations placed upon employers with a view to achieving the objective set forth in Article 16 of the Convention might include, as appropriate for different branches of economic activity and different types of work, the following: (a) To provide and maintain workplaces, machinery and equipment, and use work methods, which are as safe and without risk to health as is reasonably practicable; (b) To give necessary instructions and training, taking account of the functions and capacities of different categories of workers; (c) To provide adequate supervision of work, of work practices and of application and use of occupational safety and health measures; (d) To institute organisational arrangements regarding occupational safety and health and the working environment adapted to the size of the undertaking and the nature of its activities;
  • 37. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 37 of 133 (e) To provide, without any cost to the worker, adequate personal protective clothing and equipment which are reasonably necessary when hazards cannot be otherwise prevented or controlled; (f) To ensure that work organisation, particularly with respect to hours of work and rest breaks, does not adversely affect occupational safety and health; (g) To take all reasonably practicable measures with a view to eliminating excessive physical and mental fatigue; (h) to undertake studies and research or otherwise keep abreast of the scientific and technical knowledge necessary to comply with the foregoing clauses. The legal responsibilities within the UK for Employers and Employees are set out in the Health and Safety at Work etc Act 1974. A brief summary of the requirements of Employers, as outlined in the Health and Safety at Work Act 1974, sections 2 include: General duty to ensure the health, safety and welfare of employees Provision and maintenance of plant and SSW Safe use, handling, storage, and transport of substances and articles. Provision of information, instruction, training and supervision. Safe work place, access and egress. Health and safety policy – organisation and arrangements. Consult with safety representatives To form a safety committee when correctly requested. In terms of organisational requirements; every level of employee within the organisation should have defined health & safety responsibilities, which reflect any applicable legislative requirements. The levels of employees include: Directors Senior Managers Middle Managers Supervisors Health & Safety Practitioner Employees We will now discuss in detail, what the levels of responsibilities are likely to be for each of these roles. Directors: It is standard practice for a Director from the Board to be appointed overall responsibility for Health and Safety. This requires the Director to formally accept the role and to show the collective Director responsibilities as well as their own individual responsibility to provide Health and Safety leadership within the Organisation. Directors must ensure that board decisions reflect their health and safety intentions and recognise their role in engaging the active participation of workers in improving health and safety standards.
  • 38. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 38 of 133 With this responsibility comes the requirement to ensure that they are involved and kept informed of relevant health and safety issues and to carry out an annual review of performance. The appointed Director will usually be the signatory on the Statement of Intent, so the responsibility to ensure that the Policy is kept up to date and reviewed at least annually will also form part of their remit. As a board representative the Director responsible for Health and Safety will need to ensure that any health and safety failures are clearly communicated at Board level and that any investigation findings are also brought to this forum. It is also at Director level that the decisions for auditing are made and sufficient means will need to be in place for the effective management systems for monitoring and reporting on the organisations health and safety performance. Any decision made at Board level must be made in consideration of any health and safety implications that these decisions may have. Safety Advisors: Dependant on the Country in which you are based, the requirements for Safety Advisors will be detailed within National Legislation. In the United Kingdom for example; The Management of Health and Safety at Work Regulations, regulation 7 requires an organisation to have arrangements for Competent Assistance. Where possible this assistance should be provided by an internal resource, but where this in not possible it should be sourced externally, for example through the use of Consultants. Safety Advisors, as the title indicates have the responsibility is of an advisory capacity, with no direct responsibilities. A health and safety advisor will need to be able to advise the organisation on a number of topics and should have the relevant competence. The nature of advice will include: Needs to be able to advise on: Creating and developing H&S policies The promotion of a positive H&S culture H&S planning and target setting Accident/incident investigation, reporting and analysis Performance reviews and audits of the health & safety management system For a Safety Advisor to perform their function, they will need to: Have appropriate training and qualification (will differ depending on business) Keep up to date information systems Know how to interpret the law as it applies to the business Be able to present their advice independently and effectively Report accurate feedback to Senior Managers/Directors regularly A number of other external support services may also be required by an Organisation to ensure that the Health and Safety management process is robust. These will include: Engineers Occupational Hygienists Occupational Health Professionals
  • 39. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 39 of 133 Ergonomists Physiotherapists etc Senior Managers: Senior Managers may be required to set general policy and objectives, but they must also ensure that there are adequate resources available for the effective management of Health and Safety, which will include ensuring that there are competent advice arrangements in place. Middle Managers: At this level of the Organisations structure, middle management is more concerned with implementing the structure as defined by the Directors and Senior Management team. The responsibilities for middle management will be to carry out risk assessments, devise safe systems of work and identify training needs. This level of management must implement the policy requirements within their area of responsibility. Supervisors: The role of the Supervisor is a very important part of the Organisations overall arrangements for Health and Safety. It is the Supervisor who is the day to day face of seniority for the workforce, so their acts or omissions will impact greatly on the perception of how seriously health and safety is taken by the Organisation. The responsibilities are more of day to day requirements, ensuring that the compliance with the policy is actively enforced and supervising to ensure that those arrangements are being followed by the workforce and reporting upwards to more senior management where issues have been identified. The Supervisor is also likely to be responsible for investigating accidents, unless they warrant further support from senior managers. Employees: Employees should be given responsibility to report any short comings within the organisations health and safety arrangements and report immediately any unsafe acts or conditions. Employees should be instructed that they have a duty to work in accordance with the organisations health and safety arrangements and not endanger anyone that they are working with or around by unsafe behaviour. In general, responsibilities for employees set by the organisation will closely mirror those required of them by law (in the UK this is sections 7 and 8 of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations) There are two other groups of people that will have responsibilities for Health and Safety, which may or may not apply to every organisation. Persons in control of premises will have some responsibility for those using the premises as a place of work and also to those using any plant or substances that are provided. In the UK for example, these duties stem from Section 4 of the Health and Safety at Work etc Act 1974 and apply to non domestic premises. The requirements concern the upkeep of the building to ensure that reasonable measures are taken to ensure is safe and without risk to health. The self employed also have responsibilities for their own health and safety and also of those who may be affected by their acts or omissions. We will talk in depth about arrangements for Contractors later in this Element. Duties of Suppliers, Manufacturers and Designers: Many larger organisations are forcing improved health and safety standards through the supply chain, which impacts on smaller organisations looking for business.
  • 40. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 40 of 133 The requirements of the larger organisations involve asking their links within the supply chain to demonstrate that they meet minimum standards for health and safety. For smaller organisations, failures to have sufficient health and safety standards in place may result in lost business, as well as the obvious breaches in health and safety legislation. Organisations operating within supply chains will request their suppliers to provide health and safety documentation, details of breaches or prosecutions and ask questions about health and safety procedures, in a very similar approach to the management of Contractors which we will discuss shortly. Guidance required each individual Country to ensure that there is adequate provision for Suppliers, Manufacturers and Designers. In the UK this has been achieved by Section 6 of the Health and Safety at Work etc Act which is specifically aimed at the duties of Designers, Manufacturers, Importers and Suppliers. Much of the requirements have been amended through the introduction of the Consumer Protection Act 1987, however the responsibilities are still applicable. The main requirements concern Articles and substances for use at work in relation to the health and safety of such products and the provision of information. Articles are defined as any plant designed for use or operation within the workplace and Substances refers to any substance be it natural or manmade that is intended for use within the workplace. Designers, Manufacturers and Suppliers must ensure that any such articles or substances have firstly been designed and constructed to be safe and without risk, as far as is reasonably practicable, which may include testing and examination. There must also be sufficient information supplied to the end user to ensure that the nature of the substance or article can be understood and that any conditions for safe use can be described. Client and Contractor Duties: A contractor is anyone an Organisation employs to do work who is not an employee, the typical types of Contractors often employed by organisations include: Construction/Maintenance/Repairs Decorating Electricians/Gas/Water Fire extinguishers/alarms/emergency lighting IT Catering Cleaning The legal requirements for an Organisation to manage the use of contractors will depend upon the National Legislation implemented within each country, for example in the UK this is covered in the main by three different pieces of legislation. Firstly, the Health and Safety at Work etc Act 1974 places specific duties within Section 3. In addition to this further regulations have been implemented that extend these duties and place further emphasis on what is expected. The Management of Health and Safety at Work regulations 1999, specifically covers Contractors working in Host Employers. Specifically for Construction work, the Construction (Design and Management) Regulations 2007 requires the control of construction contractors.
  • 41. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 41 of 133 In any client / contractor relationship, BOTH parties have duties under health and safety legislation. The client (the organisation employing the Contractor) will have a duty to ensure that they employ competent and safe contractors. The Contractor will have a duty to comply with health and safety arrangements and if they decide to sub-contract any of the work, then all parties will have duties to ensure that competent fellow workers are provided. The extent of each party’s responsibilities will depend upon the specific circumstances of the works being conducted. To assist in defining the scope of responsibilities and the level of risks involved with the contracting out of works, some industry examples have been provided. The examples focus on when contracting works go wrong and the consequences of those events for the parties involved. Example One: Contractors provided a scaffold onto a fragile roof which was 10m off the ground. An operator walked onto the roof and fell to his death through a fragile vent. The client was found guilty and fined £27,000 plus costs for failing to provide adequate instruction and supervision. The contractor was found guilty and fined £3000 plus costs for failing to implement straightforward controls and safeguards. Example Two: Contractors installed overhead projectors into asbestos ceilings at a local school in Caerphilly. No information regarding the presence of asbestos was known by the school and therefore the presence of asbestos or any relevant information could not be given to the contractors. As a result of this failing the contractors unknowingly exposed themselves to asbestos whilst completing their set tasks. Caerphilly County Council fined £8,000 plus costs. Example Three: Contractors were appointed to conduct roof works at a B&Q store. One of the Contractors workers was seen working on the roof with no protection from fall risks. B&Q had previously been made aware of the requirements to control contractors and had been given extensive advice regarding roof work, due to two previous accidents in the past. B&Q were fined £4,500 plus £25,000 costs. Example Four: An accountancy firm had previously been given advice about unsafe working at height arrangements, but failed to make improvements. Unsafe work was being carried out on a tower scaffold by contractors, which lead to the individual partners of the firm being fined £1,250 plus £2000 costs each. The examples illustrate the need for Contractors activities to be monitored and for the Organisation to assess the tasks required and ensure that suitable information is given to the Contractors prior to works commencing. To assist an Organisation to manage contractors there are 5 management steps that can be applied: 5 steps to managing contractors: 1. Planning Define the job to be carried out Identify the hazards involved in the job Assess the risks from the hazards
  • 42. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 42 of 133 2. Choosing a contractor Spell out conditions contractor has to meet Deciding factors may include: Availability Cost Technical competence Reliability Health & Safety “Pre-Qualification” can save time and effort in the future How to decide on a contractor? Build relationships to set up preferred contractors Use your contacts in the business Use informal networks Interview different contractors Ask questions and get evidence Issues to explore: Experience in this kind of job References Health & Safety Policy Risk Assessments Health & Safety Performance Accident performance Enforcement action Membership of trade/professional bodies Procedures for subcontractor selection Training/competence of staff Access to competent health & safety advice Arrangements for supervision Accident/incident reporting Insurance – Employers and Public Liability Some schemes have been established to prequalify contractors The intention is that this saves clients time and money in selecting contractors
  • 43. IGC1: Management of International Health & Safety © Phoenix Health & Safety 2011 Page 43 of 133 Examples: CHAS (Contractor H&S Assessment Scheme) National Britannia Safe Contractor 3. Contractors working on site Contractors should sign in and out so that it is always known who is on site Contractors should be told about health & safety rules – smoking, emergency procedures etc. Visitors/contractors cards/leaflets may be useful Contractors should be given a named site contact Contractors should sign out when they leave site 4. Keeping Check Check should be carried out to see that contractors are doing the work in the way agreed Contractors are responsible for supervising their own work and for ensuring that they work safely However, they can’t just be left get on with it They do not need to be watched all the time The amount of checking should be based on the level of risk involved It should be decided and agreed at the beginning of the job Contractors should be encouraged to report accidents and incidents 5. Reviewing the work Learn about the job and the contractor when the work is done What needs to be done differently next time? Any surprises or lessons learned should be recorded and used for next time The record can be used when reviewing the list of preferred contractors An example has been provided of a Contractors Assessment form. This is one method that an organisation may choose to adopt to ensure that due care and considerations has been given to the selection of Contractors.