Posted By Geoff Burt
Good question Jason.

A number of companies have been issued with improvement notices for not carrying out risk assessments.

So - could their defence be, on appeal, yes they had undertaken them but there were, in their opinion, no significant findings to record?

Geoff

Posted By Gavin Gibson
Lets be pragmatic here, you will not be prosecuted for keeping a high level risk assessment that identifies no significant hazards, but you could be prosecuted for not having a record.

An inspector can always disagree with the detail of your assessment, but with nothing on paper / electronic you are sure to make life difficult for yourself

Posted By Steve Sedgwick
A risk assessment is nothing more than a
careful examination of what,in your
work,could cause harm to people,so
that you can weigh up whether you have
taken enough precautions or should do
more to prevent harm.The aim is to
make sure that no one gets hurt or
becomes ill.
If you have fewer than five employees
you do not need to write anything down,
though it is useful to keep a written
record of what you have done.But if you
employ five or more people you must
record the significant findings of your
assessment.This means writing down the significant hazards and conclusions.

You may recognise the above, its from the Five Steps.

In practice if we injure someone, make them ill, or have a situation that creates unnecessary or unacceptable risk then it is almost certain that the Risk Assessment was not adequate, suitable or sufficient. If it had been then in most cases the situation would not have occured. The exception is safety systems not being followed or being by-passed

regards
Steve

Posted By Sean Fraser
This debate has arisen quite frequently of late, with an excellent discussion still going on (see Site audits - "risk assessments- What do you feel is reasonable?" - 53 messages and counting!), there is something else I would like people to consider, which could be added to the debate.

The question as I see it is how a risk assessment is documented - should it include all the considerations and responses, or just the significant factors and if so, how could that be shown?

Would it therefore be acceptable that if written procedures were in place for all tasks (however they are done, in text or diagrammatical format) and the safety related issues are clearly identified WITHIN the procedure, especially control measures in place or to be employed, that this would meet the requirement?

As someone who is keen to progress the Integrated Management Systems concept, I feel that the changes to the ISO9001:2000 Quality Management Standard where the emphasis is more on process control and less on production of procedures, that simplification needs to become paramount in any contemporary business management system. By adding layer upon layer of documentation and producing volumes of manuals, we may have a tangible product of our work but are we really kidding ourselves if we think that anybody actually reads them? From a behavioural point of view, I believe that most people do NOT come to work to do a rubbish job or to put themselves into unsafe conditions, but they don't necessarily read or follow laid down procedures unless they accurately reflect the predominant culture of the organisation - they do what they do as they were shown and how others conduct work around them. If the actual job process involves a toolbox talk immediately prior to conducting the day's work or that particular task and includes reference to any significant safety factors involved or changes from the last time the job was assessed, then this encourages the involvement of staff at the most basic level and there does not need to be a written Risk Assessment in sight! If the culture is to produce swathes of paperwork that people do not have the time or inclination to read, let alone implement, then it is irrelevant whether it is documented or not, and when the inevitable happens the prosecution will not really be that interested if the assessment was present, but more on how it was applied (or ignored as the case may be), which I feel is the key point.

So what am I saying? In short, the debate about how the significant risks are actually recorded is less important than how they are actually implemented. If they are built directly into the operational plans, procedures and instructions, this should be a more effective means of employing them at staff level as they are then unavoidable - and separate additional RA's are then unnecessary UNLESS the decision making process needs to be demonstrated. The rest relies on adequate and appropriate training for ALL staff (including management) and a safe beaviour-based working culture within the organisation.

Food for thought?