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#1 Posted : 01 May 2007 09:39:00(UTC)
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Posted By GARRY WIZZ
This week I took the time to have a detailed look at the example risk assessments on the HSE web site.

If I might forward my conclusion and not the bits of how I got to said conclusion.

In the event of an incident I would want my risk assessments to be more detailed and more demanding in the controls and requirements placed upon the employer.

I thought the document might be a little light weight if defending a claim even with the supporting documentation that would be attached ( eg trg records etc).

However the examples may be bang on and it is I who needs to lower the bar a little.

They are only examples but opinions drawn from real life will allow me to judge my own work with an appropriate constructive critical eye
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#2 Posted : 01 May 2007 10:32:00(UTC)
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Posted By Steve Conway
Garry

I had a discussion with a colleague last week about the same issues you raise in your posting.

While it is important to focus on the outcome, i.e. the protective measures put in place, there are situations where we need to demonstrate to others how we got there. I'm not convinced that the examples provided would provide proof that a suitable and sufficient assessment had been made. For example I would be looking to see how the risks arise and the potential consequences described.

I do however like that the examples don't use a rating system.

Steve

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#3 Posted : 01 May 2007 10:34:00(UTC)
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Posted By David MacFarlane
Garry,

I think you are spot on with your remarks! I thought the HSE example RA's were a little lightweight too. Personally, I rather having too many control measures than too little, I fully understand the reasoning behind it and appreciate that too much information doesnt necessarily mean sufficient. However, If I was up against it in court or similar, I would be a lot happier with my own Assessments rather than HSE's example!!!

David.
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#4 Posted : 01 May 2007 11:05:00(UTC)
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Posted By Bob Youel

The HSE are playing a political game at this time as they want to make H&S easier re paperwork - I wish them well re this area

However when in court/with your insurers etc you need as much evidence as you can get - depth being a part of that evidence
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#5 Posted : 01 May 2007 11:41:00(UTC)
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Posted By Peter Leese
Except Bob, a corner has now been turned. There is a movement to reduce paperwork and to start to put the actions of the employees in the frame.

I personally think this is just the start and that the administration will start to be reduced - and that the courts (or is it the lawyers?) will not be demanding timewasting/jobsworth reams of paper which in some (many?) instances serves no purpose.

I'm all for it, except I don't really want to lead by example.
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#6 Posted : 01 May 2007 12:17:00(UTC)
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Posted By Darren J Fraser
I think they are a good starting point, especially for a small business that is not sure what is required , or just wants to clarify the information from an appointed competent person.

However they are just that a starting point and an example, I too would expect to see a greater detail of information.
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#7 Posted : 01 May 2007 12:48:00(UTC)
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Posted By Peter Leese
The HSE don't use the phrase 'starting point', they publish them as examples.

What's confusing me is that most H&S professionals quote and use HSE publications as gospel, but in this case are denigrating an HSE attempt to keep things simple.

Is it a case of 'I'll adhere to those I agree with, but not with those I don't like?'
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#8 Posted : 01 May 2007 13:05:00(UTC)
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Posted By J Knight
Me I like them; they look very much like the ones we use but are even simpler. The only problem I can see is that based on our recent contacts with Fire Officers they aren't going to buy the very rudimentary fire stuff for the motor vehicle repair shop. Right now it seems that nobody is interested in simplifying RAs under the RR(FS)O, and we are under pressure in some quarters to use a commercial 'methodology'; something which is not required in the RRO or its supporting publications.

Anyway, that's an aside. Its about time HSE put RA back to what the ACOP has always said it should be; of a level of complexity appropriate to the environment and the risk,

John
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#9 Posted : 01 May 2007 13:32:00(UTC)
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Posted By Peter Leese
Spot on John, and until you said it, not mentioned on this thread.

If we could 'all' get it in our heads that it is the extent of the risk that is the biggest factor - and not how thick we can make our risk assessment file, then we would all gain.

Slightly off topic (but related) I've just seen a H&S file for a one storey building which measures 50m x 50m at the very most, is mainly open plan with some offices and a kitchen off, and has air conditioning. The file is at least 6 volumes and all of them in the widest binders you can get. Not only is most of it unnecessary, but it's also a manual handling risk!
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#10 Posted : 02 May 2007 23:29:00(UTC)
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Posted By Pete48
As the great Colin Chapman once remarked. "design simplicity and then add lightness". Seems appropriate to me.
If the purpose of your risk assessments is to enable you to feel comfortable about mounting a defence in court, then produce as much paper as you wish. It may be your downfall as much as your support of course.
If, however, the purpose of your assessment is to sensibly manage and minimise risks, then produce only that needed to help you achieve that objective. It is this second point that I see the HSE examples as demonstrating. No need for numbers, matrices, complex narratives, divers references to obscure legislation, codes and standards. Just recording where you are, where you need to improve together with how and when you will improve. It also clearly talks about what research was done to support the assessment and links to available codes, guidance etc that identify the required controls.
Of course any generic style of example is unlikely to be comprehensive but to suggest they would not be "suitable and sufficient" and are therefore in some way devalued is a leap too far for me. The web page clearly tells you that simply adopting them without further thought is not suitable and sufficient.
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#11 Posted : 03 May 2007 07:30:00(UTC)
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Posted By Adrian Watson
Dear All,

If anybody cares to email me I'll send a risk assessment format that is short and sweet, effective and, dare I say it, that will meet the requirements of any court!

Regards Adrian
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#12 Posted : 03 May 2007 08:25:00(UTC)
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Posted By Chris Jerman
Having discussed this at length with the HSE unit responsible for the new assessments, I understand that they are attempting to give an example of what 'good enough' would look like for a small employer. However, once again it's a case of what they don't say rather than what they do. They agreed that risk assessment has many uses beyond what was originally thought of way back in the early '90's and an organisation has to decide what it wants from the undertaking of assessments. For us, 5 steps simply doesn't work; our assessment model is still simple but highly effective at communicating (up from the branches) the most significant issues to a board level across many sites and functions. However, for Mr X and his corner grocery store, it has functions that he would never need. He can see his entire empire from the till. He doesn't need assessments to communicate any higher - he's the Boss. My argument was that in effect, the new examples were less risk assessments (as there is no element of actual conclusive assessment in them) and more workplace inspections and control documents. They agreed. My suggestion was that for small employers, they'd be better served by a 'guide for small employers' with a prediction of the typical problems / issues that they will undoubtedly encounter and some suggested controls.The list is pretty obvious. This could have example inspection sheets in it etc. I have to ask what is to be gained from risk assessment in a more formal manner from these companies? If you want evidence that they have looked, thought and acted you are more likely to get them on board with 'tick box' assessment than something that has to be created in the first place.
My final point was that when ever you see example assessments they always look relentlessly good. in other words, there's nothing wrong. This in my view makes they inclusion of additional control measures fairly pointless. They are going to work on some examples that paint a less rosy picture and then the controls will make more sense to the reader.
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#13 Posted : 03 May 2007 09:11:00(UTC)
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Posted By Andy Brazier
I had some correspondence with HSE when the examples were published. My concern was that if you only look at the examples (which I would assume many people will) there is no encouragement to implement the hierarchy of control or to evaluate the overall risks of the activity to decide if they are tolerable.

The reply I received from HSE was that the aim was to show 'good enough' risk assessments, and that these points were covered in the accompanying guidance. I kind of understand this, but feel the examples could have been presented better. In fact the guidance for fire risk assessments has as step 3 to 'evaluate, remove and protect from risk' which I think is clearer than HSE guidance. I would also have thought each assessment should have some form of summary or conclusion of whether the overall risks are tolerable.
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#14 Posted : 03 May 2007 09:59:00(UTC)
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Posted By Andrew Joule Land
Garry,
I agree, however, they are examples.
my personnal opinion is that in a lot of cases risk assessmnets, for some, are as a tick in a box.
The examples are almost one liners and i was taught that a risk assessment may be a simple statement or depending on the complexity of the process or activity be a very detailed document almost like a method statement and also may have to refer to other assessments that require to be in place and take into consideration that in putting the controls from an assessment that you do not create other hazards.
If the mitigating action is identified as on the lines of "vigilant supervision should be in place" it ain't worth a thing when the man with the curly white hair says that the risk assessment did not fully take into account all the hazards of the process
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#15 Posted : 03 May 2007 13:20:00(UTC)
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Posted By Steve Conway
A few years ago the HSE published a research paper on Good practice and pitfalls in risk assessment http://www.hse.gov.uk/research/rrpdf/rr151.pdf.

I put together a checklist based on it to help managers and assessors evaluate their approach to risk assessment and the adequacy of the assessment record. I'd be happy to share it with anyone willing to provide comment on it.

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#16 Posted : 03 May 2007 13:34:00(UTC)
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Posted By Diane Thomason
I completely agree with the HSE's philosophy here, and the message they are trying to give, but I have 2 concerns about these assessments.

1. The depth in them is less than HSE inspectors look for, in my experience.

2. The examples include "one-liners" for manual handling and chemicals. For these, we are supposed to do specific RAs under the relevant regs - manual handling and COSHH - and the specific factors to take into account in these RAs are spelled out.

As they stand, the examples would not be S&S for the specific regs.

I discussed these examples with an inspector, who implied that they would be "top-level" RAs to be expanded as necessary.

For the more general issues I quite agree that in the examples given, the risks do not justify lots of detail, matrices and all the rest.
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