Posted By Dave Wilson No! you haven't it's always a battle mate. Problem you have here buddy is that your management have gone a step forward and are looking at preventative safety which is a good thing and leaving behind the 'compliance with statute' as the goal. something which Andy Shaw was on about some time ago in the SHP. I would enhance this mate and let him spend the money or do a RA with him as he will be 'experienced' in this as he has done the Cert, and cover all angles as he will decide the outcome, at this stage he may see this as not necessary or may deem it necessary. This should in essence make your job easier ! a win win scenario management happy, staff happy and Safety manager happy.

Posted By Jim Taking on board what you say I would suggest that you MAY well have been very LUCKY in the past? All you need is the pain and suffering of one e.g. broken toe to tell you that the issue of safety footwear may very well have acted as the last line of defence and prevented the injury from being either not so serious or even no injury at all. You already recognise that it is good practice to issue footwear (without getting too legal, wonder how that would stack up in court?)so why not just recognise that a fresh pair of eyes has pointed out a good safety improvement. This could be backed up by loads of bits and pieces that help to justify what makes it "good practice" Merry Christmas and a Happy New year

Posted By Stuart Nagle Steve. I don't think you have lost the plot, just taken into consideration facts that relate to the low risk (proven by your stats) of the potential for an accident in the environs you speak of in the factory. However, don't be driven aginst the move forward here by the new manager. He obviously has concerns over this issue and moves to 'improve' safety in such a manner have a direct bearing on the safety culture and will further enhance it for you. I suggest the following action: 1) Drag out your risk assessments for this work and review them. Consider all facts, including accidents and near misses in the past. 2) Talk to and engage the employees to gain their views on the provision of safety footware as an improvement in safety measures. It may be that some accidents where the occassional dropped package hits a foot goes unreported!! 3) Investigate the market for types and costs of protective footware suitable for use in this environment and prepare a simple report for the manager 4) Support the manager in his assertive stance for improvements. This can be done by employing serveral factors; - Accidents involving foot injuries in the industry (bearing in mind that the vast majority of employees wear steel toecapped footwear. Low figures may in fact prove that the protection works rather than little incidence of accidents. - Consult with your companies Employers Liability Insurers and get their views/input on the suggested improvement and ask how your company compares with others they insure in similar industrial situations. - Look at the liabilities and costs if something were to go awry and an accident did occur. Whilst they may be few, heavy loads falling generally tend to have high level consequences and typically high costs in court fees and claims, without all the added costs associated. - After doing this you should be able to balance the reasonableness of the improvement against the risk of the hazard being realised. One writer above mentions, correctly, that PPE is only intended to be provided to guard against residual risk from the work activity. Therefore I would suggest that an appraisal of improvements in the workplace (i.e. engineering improvements) should also be made to see if the hazard can be reduced and the costs weighed against those protective footwear, thus meeting the 'so far as is reasonably practicable' element. This may well significantly enhance the comparitively low cost option of supplying protective footwear. Whilst this may seem a little drawn out, I believe it will provide a full and practical reporting approach that no one could argue with in respect of doing all that was necessary to ensure the safety and health of your company's employees (agency as well), and would serve both with the new manager and the board who will no doubt have to approve costs, as well as yourself. Hope this provides some ideas for you...

Posted By John Webster Steve You state "In two and a half years of accurate accident reporting not a single reportable incident has taken place". I note your use of the qualification "reportable". Are you sure all employees are encouraged to report EVERY incident and especially near miss that could have resulted in injury? Or do you only encourage reporting of actual injury needing some sort of attention? If so, the basis of your reluctance to provide safety footwear is fatally flawed.

Posted By Pedro Luís Sande Taborda Nunes de Oliveira Dear Steve, In Portugal, we have a saying that states: "So many times the cup goes to the fountain, that one day it will get broke". In my opinion, you should support your new manager, because I totally agree that "the big problem with risk is that the possibility of an uncontrolled event occurring may be the next time". (in "Operational Analysis Control Model - ISSA Paris 2001" by Philip and Ciaran MacAleenan). In the 52000 seat football stadium where I work I must not forget this because with so many safety measures existing in a brand new stadium it is very easy to be complacent. Have a Merry Christmas and a Happy 2004 Pedro

Posted By Steve Holliday Thanks to all that have responded so far. (If you are wondering why I am posting a response on Xmas Day the answer is simple, nephew with new electric guitar! Distance used as main control measure. If grammar is poor may apologies but the secondary control, alcohol, is likely to be the cause) The points raised are all valid and have been considered, but without writing a ten page posting it is hard to give a full picture. The exception being Peter’s, as my company has not been in the banana business for over a decade, sorry to ruin your analogy. To clarify some main points. Accident stats have only been used as a guide in the RA process and not the defining piece of the puzzle. I myself use the line “You’ve not had an accident! Have you been working safely or have you been lucky?” in training courses about accidents. Luck certainly plays a part and the one accident may be just around the corner, but no employees have been struck by lightning either, should controls be set for this? Near misses are rarely reported, however talking to the employees working in the area is often more valuable that trying to form a pattern from near-miss data. (I find that in all but the most advanced safety cultures, most near misses are reported by a small number of individuals, sometimes trying to make a point. This does not detract from reporting near misses but the results need to be interpreted carefully) FLT’s and POEP’s do not operate in this area, safety shoes are mandatory where they do. Individual items are relatively light and unlikely to cause anything other than minor bruising if dropped. Loaded pallets are the main concern. Three consecutive safety reps have agreed with the decision. I am desperate to encourage this new manager; however they have issues that should be a higher priority to deal with. My point about being a new Cert holder is that I feel that as the cert tends to give standard solutions to standard scenario’s new holders tend to jump in without taking the big picture into account as people with diploma’s and other higher learning will tend to do. It should also be noted that the manager mentioned does not have the authority to allocate the money required. The reason behind my thread title is this. Is this such an obvious and easy fix that I should stop with all the complicated justifications and considerations of the big picture and agree that safety shoes should be specified? There is only a finite pot of money, despite all the valid reasons for spending it, but is it worth the risk of spending it on this, which I still see as low risk, and maybe not having the money available to upgrade a machinery guard from the legal minimum with a greater potential for injury? Answers are always easier with hindsight and in the ideal world, shame it’s not that easy the rest of the time. Still if it was that easy there would be nothing for us to do, as managers could sort safety out without us!

Posted By Chris Abbott Sometimes the simple solutions can result in the highest rewards... As many of you know, I'm quite new to this role, but there is one thing that is beaten into you when you qualify : It is not sufficient to control a risk, if it can be easily be eliminated. I know it can be very difficult (if not impossible) to completely eliminate the potential for injury but as I said, this message is drummed into you constantly along with responsibilities etc etc.. Management can be seen as a hindrance, maybe your new manager is just trying to show you that he can break the mould? Happy new year! Chris

Posted By Ian Waldram Well done Steve for trying to take a balanced approach, including the practical managerial issues which you detail and no one seems to feel worth commenting on. I do concur that you need to get alongside your newly-trained colleague and help him to constructively challenge the existing risk assessment, in case it has weaknesses that those involved to date, including you and the 3 employee reps, may have overlooked. But it seems to me that you have a pretty sound case - a key point is to demonstrate to him (and thus to others who will jump on you and the management if/when someone does injure their toes) is what is being done with the cash that would otherwise be spent on endless pairs of shoes. As long as you can show you're reducing some higher risk it is money/effort well-expended. A problem we have in UK is that few are prepared to stand up and resist 100% conformity to 'established good practice', even when it is pretty clear that such practice was adopted long before the days of formal risk assessments, and possibly when the work environment was quite different. Sometimes we need to be brave enough to say that some 'standard precautions' are NOT cost-effective. [My personal favourite in this area is life-jackets on fixed-wing passenger aircraft. Does anyone know of a single life saved by these in recent years - and what is the cost of providing them on global airlines, including the regular overhaul, replacement of CO2 cartidges, etc? But who has been brave enough to present the argument to ICAO etc? - not even Andy Shaw I don't believe!! I'm very willing to be told the life-jackets ARE cost-effective, but perhaps in another thread, as I think Steve should be allowed to reserve this one for shoes in a low-risk environment]. By the way, do all those respondents who advocate shoes in this workplace insist on them for ALL employees? If not, what criteria have they set for how low the risk must before safety footwear isn't compulsory? - and don't say that you are just following 'established good practice' by not insisting on them within office environments, that's a cop out as it means you don't actually believe Steve's site-specific risk assessment, which should be weighted more highly than a generic approach!