Billy O'Brien CIOSH
Health & Safety Professional and Director of Customer Success
The HSE has issued a proposal to update the guidance on risk assessment (known as INDG 163) in order to place “more emphasis on controlling risk and less on written assessments.”
Nothing in health and safety legislation says “for every activity and piece of equipment you must draw up a table, list everything that can go wrong in the first column, come up with numbers for likelihood and severity of each hazard, multiply these together, and then add extra controls in the last column if any of the numbers are quite big.” The Management of Health and Safety at Work Regulations instead require you to “make a suitable and sufficient assessment of risks” and to record “the significant findings of the assessment”.
The HSE have been concerned for some time that this simple, sensible requirement has become an industry in itself, with companies selling generic risk assessments which sit on shelves without making the workplace any safer. In the previous 2014 version of the guidance the HSE did emphasise that “a risk assessment is not about creating huge amounts of paperwork, but rather about identifying sensible measures to control the risks in your workplace.”
The new HSE proposal goes further by asking employers to look at the types of documents they already have, and see how these are used to communicate health and safety controls. Disappointingly, there is no mention of any technological solutions to reducing the paperwork burden. The Effective Method Statement software module, for example, makes use of information in risks assessments, as well as other modules on PPE, equipment or people to efficiently create appropriate instruction sets.
The HSE suggest method statements as an example of an existing document which would provide a record of your “significant findings”, so let’s see how that would work. Where a method statement focuses only on the mechanics of the task, the technician is expected to read a separate risk assessment for the hazards and controls. However, if a method statement is well written, the person doing the job doesn’t need to refer back to a risk assessment. Consider a boiler repair where working on hot equipment could result in a burn. If step 1 is “check the boiler has cooled down” there is no need to refer to a separate risk assessment.
Whilst the technician might follow the method statement for a boiler repair, warehouse staff carrying out routine manual handling are unlikely to refer to a method statement. So look around, and see what else you “may already have” to communicate and manage risks in your business. What about signs and posters?
Take a typical manufacturing plant that needed to improve risk assessment practices – trolleys were sometimes overloaded, people didn’t always ask for help when they needed it, and a cluttered workspace resulted in awkward working positions. A risk assessment could have been issued to each member of staff asking them to sign a piece of paper to agree they had received it. A detailed method statements could have been created for each process. Compliant, yes, but unlikely the assessments or method statements would ever be referred to. Instead, colourful posters positioned at the appropriate places in the workspace – a picture of a correctly loaded trolley where the trolleys are loaded, a reminder of the impact on posture of an untidy working area by the shelves where the clutter problem occurred most often, and pictures reinforcing the idea that asking for help was the right thing to do rather than a sign of weakness.
Although too many signs and posters can be distracting, putting a reminder on a piece of equipment of the essential safety checks needed, or photographs of how furniture should be stacked will have more impact than the same information hidden in the last column of the risk assessment in the shiny folder on the shelf.
The evidence that appropriately positioned signs can change behaviour is so convincing that NICE (National Institute for Health and Care Excellence) recommend employers put signs by lifts and escalators to encourage staff to use the stairs, to promote physical activity in the workplace.
Contributor: Billy O'Brien is a Health & Safety Professional and Director of Customer Success at Effective Software. Effective Software can help you with the management of your organisations Risk Assessments and Method Statements please do get in touch for more information.