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#1 Posted : 30 September 2002 12:33:00(UTC)
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Posted By Peter Wright I have been asked by my organisation to conduct a "Gap Analysis" relating to our compliance with health and safety law. Where do I start - has anyone out there done this before - the actual company will not matter because the law is the same and I dont want to einvent the wheel!! - any help is much welcome
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#2 Posted : 30 September 2002 16:38:00(UTC)
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Posted By George Wedgwood Peter, there is no real short-cut to doing a base-line audit based on (for example) HS(G)65. This can be as detailed as you like but I suspect what you need is a good auditor, who will ask questions aside from the main key areas and weave the findings into the report on compliance. Many organisations will tell you they can do this but it helps if the auditor understands some of your business beforehand. Then you can agree a protocol to work from. The generation of findings will then allow you to start constructing more detailed audit protocols in the main work areas that concern you - i.e. if you main area is manufacturing, you would probably want a detailed protocol on PUWER for example. The main output will be to quickly identify the key hazard areas and those will let you see where the relevant lagal compliance should be focused. It is then easy to pick up the im portant non-compliances. Don't get me wrong - if this has not been done before, you will probably find many non-compliances and some very large gaps! The important thing is to start and be prepared to manage some significant outcomes. These can be prioritised in terms of risk and then built into an action plan for compliance and given back to each manager to implement to an agreed timescale. Short term, be prepared for some showstoppers and deal with them firmly. My final message would be not to get bogged down in the minutia of legal compliance as it will only confuse and divert from some of the major cultural aspects of poor safety management that really need sorting along with the fire-fighting! Regards, George
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#3 Posted : 30 September 2002 16:38:00(UTC)
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Posted By Jane Blunt Dear Peter I did this once, and started with the Management Regulations. Then I moved on to the rest of the 6 Pack and finally other relevant major items of llegislation. At each regulation I asked the questions Do we have something in the company documents that ensures that this happens? Does it in fact happen (all the time or only some of the time)? For this you will need to produce some evidence in your report. Evidence could be from inspection, the accident records, or other sources. Example: "Electricity at Work Regulations, Reg 14, Work on or near live conductors. Company Policy and the safety manual both advocate conditions that are in accordance with the legislation, but incident no. XYZ in the accident book indicates that not all personnel are aware of these policies." This generated a list of things to do which ranged from drafting of major items of policy down to more inspections and walk-abouts to ensure that standards did not slip, and training and communication requirements. At this stage you may want to reorganise your report and findings so that instead of reading like a list of regulations, it has the actions grouped together like with like - e.g. all the policy alterations in one heading, all the training requirements in another, but with a justification for each that refers back to the regulation that was not being met. Regards Jane
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