People are an essential part of implementing a health and safety policy. To ensure implementation is efficient and effective it is important that roles and responsibilities are defined, covering everyone from the managing director to people on the shop-floor. The groups of people likely to be covered by such an organisation include:
As well as individual roles and responsibilities, it is important that reporting lines are clear, employees are empowered and competent to make an effective contribution, and that there are adequate communication systems in place. There should be effective consultation on health and safety and ultimately the aim is to motivate people to work safely.
It must be recognised that some external groups of people can influence or be influenced by the health and safety of an organisation. In this context it may be necessary to make arrangements with groups such as unions, regulators, emergency services, insurance companies, neighbours and organisations in the supply chain (i.e. suppliers and customers).
Organising for health and safety is often described as involving the ‘4 Cs’. They are:
1. Control;
2. Co-operation;
3. Communication;
4. Competence.
Control is about getting everyone to work together to achieve good health and safety performance. It starts at the top of an organisation, by nominating someone to have overall accountability. Responsibilities are then allocated to line managers. Specialists are appointed to advise the line.
Safety only happens when people accept it as part of the job. To achieve control
Co-operation is achieved by allowing and encouraging everyone to participate in health and safety. This generates ownership and understanding. Also, it ensures knowledge and experience is built into solutions.
Participation can be achieved through safety representatives and committees. However, everyone can be involved to some degree by inputting into and getting involved in decision making and problem solving.
Communication is much more than sending out messages and assuming people receive them. Successful communication means that ‘receivers’ understand messages in the same as was meant by the ‘sender.’
The effectiveness of communication will depend on how a message is formed, presented and transmitted. Face-to-face communication is usually most effective because people have the chance to interact, asking questions and seeking clarification. Direct communication can be achieved through:
Whilst written communication is often less reliable than face-to-face, it is still important. Readability, legibility and availability will influence its effectiveness. Options for written communication include:
A lot of communication takes place informally (for example one-to-one ‘chats’ or sending of emails) and it is quite common for these to have a greater influence (even if wrong) than messages from the boss (which are correct but may not be presented in a way employees respond to so well).
Competence is the ability of an individual or group to fulfil a role properly and safely. It takes much more than training for someone to become competent, with experience having a significant influence.
The first stage in achieving competence is to clearly define the competence requirements. Having done this it is possible to:
An organisation may decide that it is better to engage another organisation to provide competent people. This is usually the case where an activity is considered to be outside of the organisation’s core business (e.g. catering, administrative, security) or where specialist skills or knowledge are required. However, care is required when ‘contracting out’ activities and all organisations involved have to understand that they share responsibility for safety and have to co-operate in managing risks.
The culture of an organisation makes the greatest contribution to its health and safety performance. Unfortunately culture is not an easy concept to understand, measure or manage. A good health and safety management system can go some way to setting the scene for developing a good culture, but is only part of the picture.
The safety culture of an organisation is the product of individual and group values, attitudes, perceptions, competencies and patterns of behaviour that determine the commitment to, and the style and proficiency of, an organisation’s health and safety management.
Also (quoting from the Advisory Committee on the Safety of Nuclear Installations)
“Organisations with a positive safety culture are characterised by communications founded on mutual trust, by shared perceptions of the importance of safety and by confidence in the efficacy of preventative measures.”
Safety culture is not a difficult idea, but it is usually described in terms of concepts such as ‘trust’, ‘values’ and ‘attitudes’. It can be difficult to describe what these mean, but you can judge whether an organisation has a good safety culture from what its employees actually do rather than what they say.
The symptoms of a poor health and safety cultural include:
These conditions can be difficult to detect because a poor culture not only contributes to their occurrence, it also means that people may be inclined to hide or cover-up violations and unsafe practices.
Reference – ‘Inspectors human factors toolkit – Common topic 4: Safety culture’ available free at http://www.hse.gov.uk/humanfactors/topics/common4.pdf
The following can suggest an organisation has a positive health and safety culture:
It is not possible to improve culture directly. Instead, it is necessary to work at improving factors that can have a positive influence on culture. For example:
Reference – ‘Involving your workforce in health and safety: Good practice for all workplaces’ available free at http://www.hse.gov.uk/pubns/priced/hsg263.pdf
It takes a long time to develop a good culture (most estimates suggest five to ten years) but it can be lost very easily. Erosion will occur more quickly than growth, and single events can have a catastrophic impact. Examples of where it can go wrong include:
Cultures continually evolve and continuous attention is required to ensure changes are positive and not negative. High staff turnover, initiative overload and inconsistent decision making can make it very difficult to maintain a positive health and safety culture.
According to HSE Human factors refer to environmental, organisational and job factors, and human and individual characteristics, which influence behaviour at work in a way which can affect health and safety.
Reference – ‘Introduction to human factors’ available free at https://www.hse.gov.uk/humanfactors/introduction.htm
It can be broken down into the following three aspects:
In other words, human factors is concerned with what people are being asked to do (the task and its characteristics), who is doing it (the individual and their competence) and where they are working (the organisation and its attributes), all of which are influenced by the wider societal concern, both local and national.
Under UK law employers must consultant with employees on health and safety matters. Consultation is not just giving information, but also listening to and taking account of what employees say before making decisions. Employers must allow enough time and provide means by which comments can be made.
Reference – L146 ‘Consulting workers on health and safety. Safety Representatives and Safety Committees Regulations 1977 (as amended) and Health and Safety (Consultation with Employees) Regulations 1996 (as amended)’ available free at http://www.hse.gov.uk/pubns/priced/l146.pdf
Employers must provide enough information to their employees or their representatives to allow them to take a full and effective part in consultation. There are exceptions that mean information that would harm national security or the business for some reason other than health and safety can be withheld, or if it relates to an individual who has not given permission for that information to be distributed.
Employers must consult on any decision involving work equipment, processes or organisation that could affect the health and safety of employees.
There are many more topics that could be consulted on but it is recognised that it is impractical to consult fully on every aspect of a business. However, employees should as a minimum be consulted on the following:
Reference –‘Consulting employees on health and safety’ available free at http://www.hse.gov.uk/pubns/indg232.pdf
There are specific regulations regarding consultation in organisations where trade unions are recognised. The Safety Representatives and Safety Committees Regulations (SRSCR) 1977 require that, if safety representatives have been appointed then the employer must consult them on matters affecting the group or groups of employees they represent (which may include non-members of the union).
There are also regulations for organisations where trade unions are not recognised. The Health and Safety (Consultation with Employees) Regulations (HSCER) 1996 require employers to consult employees either directly or through elected representatives.
Safety representatives have a key role in representing employees in discussions with the employer on health, safety or welfare issues and in discussions with enforcing authorities. They can act as a focal point for consultation and can get involved in all aspects of health and safety including making inspections, investigations and following up employee complaints. They have a right to paid time-off to carry out their role and receive training; and have to be provided with suitable facilities.
An employer must set up a safety committee if two or more union safety representatives ask for one. Whether trade unions are recognised or not, health and safety committees can be an excellent method of communication, up, down and across the organisation. They provide an effective method of consultation and have the benefit of demonstrating commitment and providing a forum where consultation can take place whilst notes and records are made. For a committee to be effective it is important to:
Safety advisors are not responsible for the safety of an organisation as that cannot be delegated by management. Rather, their role is to provide advice to management and employees or their representatives regarding health and safety performance, improvement and compliance.
A health and safety advisor needs to be authoritative and independent. To be effective they need to have status and competence. To fulfil their role they need to:
Health and safety advisers are likely to be involved in liaising with outside bodies.
The Health and Safety Information (Amendment) Regulations 2009 require employers to display a poster or distribute a leaflet telling employees what they need to know about health and safety. These are available from HSE and are divided into the following three sections:
Reference – ‘Health and safety law – What you should know’ available free at http://www.hse.gov.uk/pubns/law.pdf
Risk assessment is the underlying principle in all aspects of health and safety. In its simplest form (which is adequate for most situations) it is a careful examination of what could cause harm to people and an evaluation of whether enough precautions have been taken or more should be done. Risk assessment is an important step in protecting workers and businesses, as well as complying with the law.
The HSE has a whole section of their website devoted to risk management. Its address is http://www.hse.gov.uk/risk
The two main terms used are hazard and risk
The HSE suggest there are five steps to risk assessment.
Step 1: Identify the hazards;
Step 2: Decide who might be harmed and how;
Step 3: Evaluate the risks and decide on precautions (including what more can be done to reduce risks on top of what is already in place);
Step 4: Record your findings and implement them;
Step 5: Review your assessment and update if necessary.
When carrying out risk assessment, the main groups of people to be considered include:
Special attention is required for vulnerable people who may be at a greater risk than the general population and so may require additional precautions. These groups include:
Risk assessment is best carried out by a team of people, who ideally have different backgrounds and experiences. This makes it more likely that all issues are considered and that the assessment is objective and realistic. It is important to recognise that it is natural for people to become complacent to the risks they experience on a regular basis to the point where they can fail to see hazards that are present. For this reason it is useful to involve people who are not overly familiar with the situations being assessed, possibly coming from another department or brought in from a separate organisation.
Risk assessment should not be a desk-based paperwork exercise. Wherever possible the activity being assessed should be observed and the people carrying out the activity asked for their opinions. Assessment team members need to have competence in carrying out risk assessment as well as a wide ranging knowledge of potential hazards and practical controls.
Risk assessments need to reflect reality so it is important that they are reviewed whenever changes occur to the way tasks are performed, equipment and materials used (including type and quantity), and the people likely to be harmed. Also, whenever new information becomes available that may affect the assessment, including as a result of an incident, following an audit or when a process is shown to not be working as expected. New legislation may change the requirements or emphasis on risk assessment, with the general trend being for it to be more risk-based and less prescriptive.
The HSAW act 1974 places a general duty on employers to ensure the health, safety and welfare at work of all employees so far as is reasonably practicable. Also, there is a legal duty under MHSW regulations 1999 to carry out risk assessment and, if five or more people are employed, it is necessary to record all significant findings.
The requirement of UK legislation is to develop risk assessments that are suitable and sufficient. To satisfy this it is necessary to demonstrate that:
A risk assessment is of no value if the results are not acted upon, with the ultimate objective being to reduce risk.
The first question to ask must always be ‘can the hazard be removed?’ If the answer is no, there is a hierarchy of control measures to consider. With this hierarchy it is important always start at the top, as these are the most effective controls. The options are:
Other options are available to reduce risks further, once the above controls have been implemented. They include use of Personal Protective Equipment (PPE), providing information to people who may be harmed and making arrangements to deal with emergencies (e.g. safety showers, first aid, fire fighting). These are not considered as effective controls because they do not prevent people being exposed to hazards, but they still have a role in reducing the likelihood of harm if primary control of a hazard is lost.
Although below hazard elimination and physical barriers in the hierarchy of risk control, the way tasks are performed is an important part of managing risks. Often there will be many different ways of doing the same activity, but some will be safer than others. This is why it is important to define safe systems of work.
A safe system of work is a method of working that is designed to eliminate, if possible, or otherwise reduce risks to health and safety. It should consider:
Safe systems of work should consider the need to change methods during an activity (i.e. in response to related and unrelated events) and constraints of work (i.e. when the activity should stop). A clear definition of what success will look like will help everyone understand what is required.
A true definition of the word procedure is a method of performing a task. However, in a work setting, especially where health and safety is concerned, reference to procedures is usually related to a method that is written down and available on paper or possibly on a computer screen.
Unfortunately reading and following procedures is not something people usually like doing. This is especially the case for experienced people who may have performed a task many times before. Although there are some things that can be done to enforce the use of procedures, the reality is that this can be a long and fruitless battle. Instead it is important to think carefully about the role of procedures in risk management. Where they are considered necessary, making sure they are fit for purpose makes it is more likely they will be used. In particular procedures need to:
It is most critical that procedures describe practical and realistic methods for performing tasks that are also safe. There are too many ‘safe’ procedures that cannot be followed or are too longer winded to get the job done. Involving end users in the development of procedures is a very good way of making sure procedures are useful and used.
There is a balance to strike with the number of procedures provided. Having too many will make it more difficult to find the one needed and tends to discredit the whole system, which may be perceived as being overly bureaucratic. Therefore, procedures should only be provided where there is a risk and where the procedure is able to make a positive contribution.
There are many cultural factors that affect whether procedures are used (or not). A positive culture means that everyone understands that using procedures for critical tasks is normal and expected. This avoids a macho culture where procedures are only considered necessary for trainees and other people who do not know what they are doing.
Reference –‘Core topic 4: Reliability and usability of procedures’ available free at https://www.hse.gov.uk/humanfactors/topics/core4.pdf
It is vital that organisations make arrangements to deal with foreseeable emergencies and that everyone knows what to do if an emergency occurs. Procedures are an important part of these arrangements. The types of event that should be covered include fire, explosion, toxic release, someone being injured, bomb threat and security incidents.
Emergency procedures should explain how to:
Emergency procedures need to be particularly clear and concise; and readily available. People should be trained in them so they immediately know what to do. However, managing an emergency is a demanding and stressful activity and hence prone to error. Anyone with a significant role should refer to procedures during emergencies, no matter how well trained they are.
People with disabilities require special attention when developing emergency procedures. A ‘Personal Emergency Escape Plan’ (PEEP) may be required for an individual if they may not hear and/or see a warning or may be unable to evacuate promptly without assistance.
Permit to work systems are fairly common, especially in hazardous industries. They are formal written systems used to manage risks by controlling certain types of work. They perform a number of key functions including:
Permit-to-work systems are normally considered most appropriate for non-production work, especially maintenance and construction at operational site. This covers a vast array of work, and in some cases different types of permit are used. The types of work typically covered by a permit to work system include hot work, confined space entry, electrical work, use of radioactive material or explosives, excavations, pressure testing and opening up systems where there is the potential to release hazardous substances (because it cannot be proved that they are isolated and/or hazard free).
Reference – ‘Guidance on permit-to-work systems’ available free at http://www.hse.gov.uk/pubns/priced/hsg250.pdf
PPE is equipment that is intended to be worn or used to protect people against one or more health and safety risks. It includes safety helmets, gloves, eye protection, high-visibility clothing, safety footwear, safety harnesses, hearing and respiratory protection equipment, and clothing protecting against extremes of weather.
PPE is at the bottom of the hierarchy of risk control measures. This is because it only reduces the likelihood of harm rather than preventing exposure to a hazard. It is not 100% reliable and so all other risk control measures must be considered first to reduce exposure to hazards. PPE can then be considered to provide additional protection, or protect against accidental exposure.
The correct type of PPE needs to be selected according to the hazard, task and characteristics of the person. The following issues need to be considered.
Eyes
Head
Breathing
Protecting the body
Hands and arms
Feet and legs
Hearing
Personal Protective Equipment at Work Regulations 1992 (as amended) apply to all PPE, except hearing protection and respiratory protective equipment, which are covered by other legislation. They require:
Reference – ‘A short guide to the Personal Protective Equipment at Work Regulations 1992’ available free at http://www.hse.gov.uk/pubns/indg174.pdf. Further information is available in L25 available free at http://www.hse.gov.uk/pubns/priced/l25.pdf
There is a convention for the colours of safety signs. It is
RED – Prohibition, danger or alarm;
YELLOW or AMBER – Warnings;
BLUE – Mandatory instructions;
GREEN – Emergency information, escape etc.
Whilst signs are important, their effect is limited, and after someone has seen the same sign a few times they are unlikely to notice it. Also, too many signs can be confusing and dilute the message. Therefore, whilst a useful addition, signs are not good risk control measures.
Reference – L64 ‘The Health and Safety (Safety Signs and Signals) Regulations 1996. Guidance on Regulations’ available free at http://www.hse.gov.uk/pubns/priced/l64.pdf
Having competent people is a key element of any safe system of work. Competency is the ability to perform an activity safely and to a specified standard by having the necessary skills, knowledge, understanding and attitude. This can apply to individuals and groups of people.
Reference – HSE have a page dedicated to competence on their website at http://www.hse.gov.uk/competence/index.htm
Training is one factor in someone becoming competent. However, training on its own does not make someone competent as that usually requires experience, other forms of education and having the right attitude.
Training comes in many different forms including people attending training courses and learning ‘on the job.’ Unfortunately a lot of training is ineffective because the objectives (i.e. what is needed to do the job safely) are not clearly defined and because the retention of training is not tested afterwards. Therefore, it is important that competency requirements are fully understood, training needs are evaluated (i.e. identifying which of the competency requirements an individual does not have), selecting the correct method of training and assessing competence after training.
People new to a job or work location are particularly vulnerable to having accidents because they may not know what hazards are present or the systems in place to control risks. Induction training can be a useful way of getting key messages over and making sure people start out with the right knowledge and attitude.
Induction training should cover the following:
A tour of relevant parts of the premises, pointing out hazards, safe routes, emergency call points and muster locations can be particularly useful.
Reference – An example induction for small construction companies is available free at http://www.hse.gov.uk/construction/induction.pdf
Visitors to premises are usually intending to stay for a short time, and so it is not normally practical to give them full induction training. However, they can still be at risk and this needs to be controlled.
The first thing to consider is safe access to the premises when they first arrive. It should be clear where visitors are supposed to go, how they can get there safely and what they do when they arrive. If reception facilities cannot be arranged at the entrance, a safe route should be marked out with signs at the entrance informing visitors that they must stay on this route.
Once they have arrived it is usually safest to have the visitor accompanied by someone who knows the risks, rules and procedures (e.g. employee or fully inducted contractor). In a low hazard environment (e.g. office) this may not be necessary. In this case some simple instructions should be issued about where they can and cannot go, what they can and cannot do, how to contact someone if they need to and what to do if the emergency alarms sound.
Supervision does not seem to be a very ‘trendy’ subject at the moment, with far more interest being shown in self-managed teams and the like. However, supervision is an important management function when it comes to managing safety, and not matter what way teams are organised it needs to be carried out.
Supervision has a key role in:
Supervision is not an easy job, and many people are not suited to it. A good supervisor will know his/her team very well, including their capabilities and limits. He/she will allow them a certain degree of free reign, but know when intervention is required.
Reference – ‘Different Types of Supervision and the Impact on Safety in the Chemical and Allied Industries’ available free at http://www.hse.gov.uk/research/rrhtm/rr292.htm
Studies suggest that up to 80% of accident causes involve some form of human failure. These failures involve people:
It is important to understand that human failures are not random events and that they have causes. This means they can be predicted and their likelihood reduced. HSE guidance document HSG48 Reducing error and influencing behaviour HSG48 (HSE guidance document) shows that the causes fall into three main categories:
Understanding the root causes of human failures and general performance problems is essential if effective solutions are to be developed.
Reference – ‘Identifying human failures’ available free at http://www.hse.gov.uk/humanfactors/topics/core3.pdf. HSG48 is available to download free at http://www.hse.gov.uk/pubns/priced/hsg48.pdf
There are many different types of error, but most fall into the following categories:
This list can be used during risk assessments to consider the potential consequences of different types of error.
Error is a natural part of human communication. It occurs when someone understands a message differently to the way sender of the message intends. Communication errors are particularly common when one person is much more knowledgeable than another (i.e. experienced person talking to a trainee).
One-to-one face-to-face communication is usually most reliable because people have an opportunity to discuss the message so that both parties can be sure it has been understood properly. Of course that requires the people to choose to discuss. Other forms of communication including remotely (i.e. by telephone or radio) and written usually cause more errors.
One reason why people fail to pay sufficient attention to what they are doing or choose to either not read a procedure or to knowingly violate it is because their perception of the risk is less than reality (i.e. they think they are safer than they really are). Equally there are many high profile cases where people perceive the risk of something to be higher than it probably is (e.g. nuclear power, travelling by train in the days after an accident).
The reality is that people are pretty poor at evaluating risks. Lack of knowledge clearly has an influence, but there are greater powers at work. Complacency is one of these, and is a natural reaction when people become familiar with a hazard so that they can almost forget it exists. Also, people seem to make an automatic evaluation of risks vs. benefits, and will instinctively accept a risk where they feel the benefit is worthwhile. Road travel is a good example. People are happy to continue this activity even though an average of 10 people die per day on UK roads, but would not accept anything like this risk from any work setting.
The challenge for health and safety is to get people having a realistic perception of risks. We want them to understand that there are reasons for controls, but we do not want them to become overly risk averse as this can stifle the business and stops people actually engaging with the risk management process. Getting this level of understanding is not easy, and will require continuous attention. As with many things, communication is the key and will involve finding ways of informing people about risks in a way they will understand.
As well as a realistic perception of risk, people need to be motivated to work safely. In general terms people at work are motivated by:
These can present a challenge to health and safety. In particular, the desire for variety and autonomy can lead to people deviating from laid down procedures. Also, if people do not perceive the risks to be high, some of the activities they do for safety can seem to have little significance.
Avoiding too much unnecessary prescription in the way things are done can assist in motivating people. It has the added benefit that people understand that when methods are being prescribed that there is a safety reason. It helps if the safest way of doing a job is the easiest and most efficient as people are more likely to choose these methods over others. Putting it simply, people like to take short-cuts, and so it is best to make the short-cut the safest method available rather than trying to stop them taking it.
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