Hm, Pete, what makes you think that the press is not controlled already? It is indeed very tightly controlled, and is about as far from a free press as could be imagined. Sure, there is no government control, and I'm not sure I would ever advocate such a thing. What it is a control by a very small number of very rich individuals with predictable oligarchic agendas; this does not act to promote democract and debate. I haven't got an answer to the press problem, but it has played a big role in getting us to where we are, and it's been a terribly positive contribution.

I would have preferred a review which looked at the real industrial death rate (including e.g. RTAs, ill-health effects etc) and proposed some way forward. Instead we have a report which treats H&S as a system beset by problems - to me the only problem is PR. All the other issues are myth (compensation culture, heroes stifled by restrictive laws) and white-van man rantings,

John

NEBOSH General Certificate gives you Tech IOSH, and you can run CPD

NGC in itself doesnt give you TechIOSH, you need to also demonstrate you have a suitable level of experience in an H&S role.

Kate,

'Some people have read the regs'?

John

Many thoughts but commentators above have covered most of the ground.

Re risk assessments and guidance, I'm worried how the two are still separated. In most simple situations we should be able to go to one source of "what good looks like" then compare ourselves to it by way of assessment. The idea that assessment has to be done from scratch really is unsustainable away from challenging situations; see HSE guidance on RAs prepared in relation to COMAH safety cases. If it's good enough in COMAH to assess against standards then it's sure good enough to do so for an office. Young envisages HSE taking the lead in EHO enforced areas - perhaps not before time!

In this day and age, couldn't the HSE put up simple on-line accident book that would automatically flag up RIDDORS? I appreciate that it's bread out of the mouths of some software houses but maybe the time has come...

I obatined a copy of Lord Young's Report from the Internet on Friday, and sat down and read it Friday evening... my comments are:

1) I was suprised by the reports contents, as it appears to be little more than a quick desk-top study based almost entirely on conkers bonkers press reports and 'information' that could be taken straight off the internet, with inuendo and assumptions made throughout, with little hard evidence from businesses or their professional bodies presented to provide meaningfull results....

Where businesses actually consulted? There certainly appears little evidence to show for any consultation if this was indeed done?

2) We all knew the Consultants Register was coming... no shock there then, but again... the Professional Bodies in their eagerness to be involved and ultimately 'control' the register... have acted too fast and too furiously.... there are ramifications in this....forget the unqualified for a minute and consider the qualified and highly expereinced, but un-chartered professionals - you know who I mean... those who support the profession from the bottom up.... some of whom may work no doubt for consultant organisations and who now find, as from January, that they may be unemployable in a consultancy role once insurers suddenly decide that if businesses want to remain insured, they can only use a person with CMIOSH or such after their name....

When you consider that most 'consultants' provide information to SME's, a fact recognised in the report it seems, where are in fact most of the lesser mortals assigned... it appears it's OK for these 'not worthy' to be directly employed by larger businesses who can afford to directly employ a health and safety advisor in, for example, manufacturing, logistics, shops, and just about any other business you can think of, but not as a 'Consultant'....

Surely the emphasis of providing qualified advise, is not who it is provided to, but who it is provided by, and to coin a phrase...their qualifications, knowledge, experience and such other qualities.... that provide and establish their competence...!!!

I see big ripples on the pond arising out of this.... and see lots of people (membership paying members of Professional Bodies) who work hard to feed their families day in and day out, by being well trained and experienced consultants (many self employed) and not cowboys, being sent down the swanny.... lets hope the 'Professional Bodies' decide to represent ALL their members interests here dam quick, and not just those at the top of the tree.... or are we seeing the caring institutions becoming less caring, just like other Professional bodies who, experience shows, simply revolve around the Chartered members at the expense, most of the time of their 'less worthy' members... !!!

3) Red tape... this apparently can be totally resolved by;

A) Low risk bussinesses not having to do risk assessments - Low risk is defined as offices and shops in the report... but does not state, for example how big/small, number of persons ect to be considered 'low risk'. would it be Marks and Spencer or Citi Group, or bloggs and co solicitors on the corner and the bakers down the road.... Reports need to justify decisions, not just apply a blanket to it all... as of course that's how accidents happen....!

B) Not having to make RIDDOR Reports unless absence is over 7 days (is that 7 working days or just a week...?) not qualified in the report but I guess, but given the standard of the report His Lordship probably means a week and not 7 working days... but I stand to be corrected...

C) Excluding sole traders and self-employed persons from certain mandatory requirements in respect of their own undertakings... and home working of course....no problem with that, but it rather depends how their undertakings are likely to affect and endanger others really, but the report does not offer much else to enlighten us further....? Perhaps the consultant working at home will now be justified in not be doing a risk assessment for the design he's just produced for high pressure reaction vessel....;)

D) Schools and other similar organisatons being free of incumberances in respect of risk in their normal activities... no problem with this either... (does this include school trips to climb mountains, do white water rafting, potholing, skydiving etc etc...? are these 'normal' school activities or is his Lordshoip thinking of conkers in the playground?...) not qualified with much detail here either really...!

So there... red tape resolved... You know, I was wondering how much his Lordship is being paid by the Government to produce this report, (or is he keen just to collect his £500 a day no questions asked expenses from the Lords for turning up each day....) and to continue in his capacity as adviser to the Government on H&S matters until such time as the reports recommedations etc are reviewed and interpreted by someone else at tax payer expense, all the leg work done, by someone else, or an army of someone elses; introduced, implemented and where needed, as stated in the report, enshrined in law....

As you may have guessed by now, I'm not entirely convinced that Lord Young has done such a great job here... in fact, I think I've seen better reports produced by unqualified consultants, and the recommendations on the whole, like the report itself, seem to be, and please forgive me for saying so..., a bit Del-Boy, ergo, 'so whats so dificult about this elf n safety stuff then', quick and easy fix that will probably end up needing years of further codecils to sort out and exemplify...etc etc etc... Unfortunately it appears that Lord Young is no Lord Roben.... and boy does it show....

Let's hope the Professional Bodies, who I might add appear very pleased with the outcome (no doubt ecstatic at getting their hands on a national register....I can hear the hands being wrung with delight even now).... are able to bring their professional judgement to bear on the report, although I don't think for one moment that Lord Young, and no doubt in the very near future his team of unpaid graduate interns, will offer the opportunity to discuss and evaluate, review and consider....

I only hope 'common sense in health and safety' rears is head somewhere along the line....!!!

Yours... somewhat disappointed....

John, I couldn't help but have a wry smile at you accusing Lord Young of being cynical! :-)

We must differentiate between what could be reported - near misses and minor injuries - to what must be reported - O3D's and major injuries. Excuses like ' I can't be bothered' are often cited, off the record, as a reason for not informing management that a near miss or minor injury has occurred but rarely is it a reason for not reporting an O3D or major injury (where hospital treatment is often involved). These are most commonly not reported by the business rather than the injured party and therefore fear of prosecution is a significant factor.

I doubt tougher enforcement will work. It has little affect on other behaviours, like using mobile phones while driving, or murder! So why should it work for something that the 'offender-in-waiting' sees no real benefit. After all we can intellectualise why it is good to report but the bottom line is it will always be seen as a blame game by those involved. Therefore if we agree that something must be done to improve reporting we ought not to be dogmatic in our approach. We know that the use of incentive schemes to increase near misses and hazard reporting works so why not consider a similar approach with RIDDOR - the incentive being avoidance from prosecution. Obviously, it would be incumbent upon the business concerned to show contrition and real management improvements otherwise they would be subject to the usual sanctions.

Stuart

I rather agree with your comments. Young hasn't done a thorough job. Quite the reverse. He gives only anecdotal evidence for all his conclusions and if he were putting H&S on trial he certainly wouldn't convince the CPS that his evidence was adequate on the basis of what he has written.

Yes I agree a register of consultants is a good move. There are a number of associations out there that have little hope of achieving a royal charter and so there members need some way of being favourably compared with our Institution. So long as we don't see our professional status watered down in any way I will be supportive of the move.

With respect to many of Young's other points I have little confidence in his abilities as a lawyer and can clearly see why he turned to politics. It is interesting to know that he still touts his legal credentials as credible even though he only practised for a year back in the 50's! Obviously he has forgotten how to conduct credible legal analysis if indeed he ever knew how.

Let's hope our institution argues against the recommendations where they are unjustified and supports them where they are credible.

Pete

Not wishing to put words in John M's mouth but do you not think.....

'It' could have been done better by gathering consultative evidence from employers, trade unions, the authorities (HSE/LA's) & professional bodies and presenting their respective testimonies as part of the report for all to see. This real evidence would allow third parties to assess whether Young's conclusions and recommendations are based on a correct interpretation of the facts or made up as he went along.

Young's report is so lightweight it is quite staggering to think anyone with any understanding of report writing can give it any praise at all. It will probably rank as the first government report to be shorter in its entirety than most others have in their contents pages. 58 pages! That's not a report that's a party conference speech.

God help us!

Totally agree with JohnMurray, and the even worse news is that the information about our armed services was leaked deliberately to soften the blow about tomorrows really bad news on the spending review! God help us all.

How can anyone take this review seriously, it took a couple of months to prepare, it is produced very poorly, and there is no mention how or when any of these changes will take place, its a smoke screen, and if we ignore it, it will go away!

To add to BB's comment, I am only an affiliate member of IOSH. I have no intention of working towards full CMIOSH, as most of what I would have to learn would, for me, be completely inappropriate.

I have worked in one particular area of occupational health and safety now for over 30 years and believe that in that time I have developed a level of expertise in my particular area of interest that a CMIOSH would (and could) not be expected to possess. Incidentally this expertise is recognised internationally. My work has taken me around the world and I am an invited member of two EU projects aimed at reducing ill health in my particular area. Yet under the present scheme, were it to be extended to include occupational health, presumably I would be deemed to be incompetent compared with someone with a broad knowledge of health and safety but no particular expertise in my field.

Where is the sense in that?

Chris

To illustrate the above - it's not long ago that I saw a major employer - the largest employer by far in their HQ city, and a UK-wide household name - advertise for "a NEBOSH-qualified H&S professional". If we're not careful, we're just going to replace "NEBOSH qualified" with "on the register"

On the issue of reporting injuries. The HSL report 'Literature Review on Reporting of Workplace Injury Trends' [HSL/2005/36] identified the estimates still used today, namely:

59% of workplace non-fatal injuries to employees that should be reported are not reported.

95% of workplace non-fatal injuries to self-employed workers are that should be reported are not reported.

This is just to underline the extent of the problem, for whatever the reason. Raising the over 3 day reporting to over 7 day is likely to reduce reporting, thus improving our national safety record at a stroke, as they say. It will not improve the quality of the national database.

In 1981 there was a system that had a premium payment to encourage workers to report industrial accidents. The Tories deliberately destroyed this system in favour of one [Employer Statutory Sick Pay] that handed all the previous administration [Red Tape?] costs to the employers and led to them directly reporting accidents under RIDDOR when the previous system did not. [Even more 'Red Tape'?]

Why don't we introduce a system that pays workers - for it is they who get injured - for reporting industrial injuries? That way we create a financial incentive for workers to report, making it clear that for such a claim to succeed, it must be registered in their employer's accident book. Any employer failing to report the accident under RIDDOR should then be automatically fined.

Cheers.

Nigel

Pete

Why not?

There were 412,498 reports before ESSP in 1981. Give workers, say £10 each then annually we are looking at £4,124,980: equivalent to the annual salary, pension, bonus, expenses etc of a decent Chief Executive Officer or a bit less than the value of the Government's wine cellar, maybe.

The key point is to make sure a report directly from the worker to say DWP for some cash is checked against the employer accident book before payment.

This allows:

1 No record in the accident book means no payment. So the report has to be made in the book. If the employers monitor the accident book, there should be an investigation. So if the entry remains uncontested, it was an industrial accident.

2 A photocopy of the accident book entry sent to the DWP verifies the claim and payment can be made.

3 The DWP to report the accident details to the HSE who can interrogate the database to identify trends etc, so long as the DWP know how to classify injuries according to RIDDOR. The HSE has spent shedloads on their computers so should be able to handle a massive increase in reporting.

4 Any employer not submitting a report in the required time should be automatically fined. As accident reports are critical for the HSE - and others - to determine where to focus their resources perhaps an automatic £1,000 fine for each single failure to report a RIDDOR accident should help employers comply with their legal duties. The fine is for failure so it should provide an incentive to get it right first time.

5 The reports are for RIDDOR injuries therefore they will need to be recorded separately in the accident book.

The issue here is to report accidents. The employer should already have a system in place for absence from work.

Not easy perhaps but not impossible!

Cheers.

Nigel

Bibby, in response to your comments at #102.

The report lists 139 stakeholders who contributed to the report including a cross section of all sectors.

I cannot let the irony of your comment about the length of the report pass by. Isn't OSH and the government constantly accused of producing far too much paper!
If it is long enough to achieve it's purpose then it is long enough. Just because it is seen as vitally important doesn't mean it has to run to volumes at this stage.

I guess, for me, it is the purpose of the report that is more important than the detail at the moment.
And to start the day, some bar room philosophy
" the real challenge is to take the first step, the journey is the test and there are many paths, some of which will only become apparent as you journey; beware making too many choices at the beginning that may limit your success during the journey"

p48

[quote


Don't get me wrong, I know the cowboy consultants need to be reined in. I just haven't yet seen a proposed model that would work in the real world.

Jim

Thanks for the reference.

Cheers.

Nigel

As already said, it should really be about competence, not letters after your name. And again, as already said, it is recognising what you don't know. As I get tired of saying: "The danger arises when you don't know that you don't know!"

As someone who is not CMIOSH, and has no intentions of becoming so, and with over 30 years experience now in just one small area of health and safety, I frequently encounter situations where 'qualified' health and safety practitioners have taken decisions that have been counter-productive, simply because they thought they knew enough about this aspect and had not recognised its complexity.

Given how little on my speciality (prevention of damage to health due to workplace skin exposure) is covered in most health and safety training, I suppose I should not be surprised, but I think it illustrates the nonsense of a blanket accreditation.

How will the manager in a small SME be able to tell if that 'accredited' person has the necessary expertise in the particular aspect of health and safety that they need advice on? And how will this help them to identify those specialists who may not have the letters after their name but have the experience and expertise to provide the right advice?

Chris