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Forbez  
#1 Posted : 14 June 2011 09:54:07(UTC)
Rank: New forum user
Forbez

I would like to get the opinion of some of the members here at IOSH. I have recently had a debate with a colleague who is not a Health and Safety Practitioner but has participated in some safety training at Level 2. I was reviewing a risk assessment with this person, and in an effort to lower the final severity rating I stated we could lower the severity of the injury as the PPE put in place had significantly reduced the severity of any final injury even if the original hazard took place. I.e. a harness was being used that instead of making a fall from height result in death, would make the fall from height result in, at worst case, a broken bone but most likely not even that. However my colleague is of the opinion that you cannot under any circumstances lower the severity of injury figure as that severity is always present. His argument is that the control measures may not be adhered to etc etc and that accident severity remains. The thing is I remember the person who did my risk assessment training stating the same thing, but this wasn't an accredited course it was an in-house course. So my question is this; given that the only purpose of PPE is a last resort that doesn not to reduce the likelihood of an injury but is utilised to reduce the severity of an injury should an accident, is it acceptable to lower the final accident severity (after control measures have been implemented) in light of the use of PPE. I look forward to your response
David Bannister  
#2 Posted : 14 June 2011 10:21:23(UTC)
Rank: Super forum user
David Bannister

Forbez, I believe you are correct. Reducing both the likelihood of harm and severity of outcome are the aims of risk control i.e. what we put in place once we have done the risk assessment. The more effective controls (eg avoid the activity, substitute a less potent substance etc) will reduce the likelihood, whilst provision of PPE will not stop the event from occurring but should reduce the severity of harm, if correctly specified, made available, trained, properly used etc. Thus a hard hat will protect the wearer from skull damage when walking into the girder, maybe resulting in only bruised pride and goggles will stop the stone chipping from causing a puncture wound to the cornea; a fall prevention harness and line would prevent the user from falling and a fall-arrest device prevent the outcome being raspberry jam, merely bruised plums! If we accept that risk is the combination of both probability and severity and our assessments use both parameters, reducing either must lower the risk. If we continue to assume that the worst outcome will still occur, regardless of whether we use PPE, then we must question whether use of PPE has any merit at all (good subject for another thread?). Of course, the effectiveness of PPE depends on many factors, but provided it is used as expected, does do a job in lowering the severity of outcome.
Forbez  
#3 Posted : 14 June 2011 10:40:12(UTC)
Rank: New forum user
Forbez

stuff4blokes, I'm glad the first response is in agreement as this is something I find quite concerning. The whole purpose of PPE seems to be lost when it comes to a risk assessment and it's ability to reduce the severity of injury seems to be completely discounted during the risk assessment process. I am of course still keen to get feedback from as much people as possible to get an overall opinion.
Andrew W Walker  
#4 Posted : 14 June 2011 10:44:56(UTC)
Rank: Super forum user
Andrew W Walker

S4B has hit the nail on the head. Couldn't agree more Andy
Rory H  
#5 Posted : 14 June 2011 10:52:18(UTC)
Rank: Forum user
Rory H

Totally agree, your colleague should try the application of common sense to his argument and see what results he gets!
Peter Clifton  
#6 Posted : 14 June 2011 10:56:35(UTC)
Rank: Forum user
Peter Clifton

Hi, We back up the issuing of PPE with talk talks (otherwise known as toolbox talks). This goes down on the risk assessment form together with the PPE type & specification. So, the person has been issued with the PPE, told to use it (scripted task talks), then a record is kept of who told then and when. This must reduce the risk, as by not wearing the PPE they would be going directly against management instruction. I have introduced a "closed loop system" here, and am slowly rolling it out in all departments. Risk assessment 1 = summary of hazards, risk assessment 2 = details, scripted task talks & records. The system is quite simple .. e.g. risk assessment 1, number 5 = burns, risk assessment 2, number 5 = burns, task talk number 5 = (you guessed it) burns, and individual training records (has 1 - 30 across the top) number 5 = burns. Simple
Ron Hunter  
#7 Posted : 14 June 2011 10:59:26(UTC)
Rank: Super forum user
Ron Hunter

This is an all too common pitfall for those starting out in Risk Assessment. There is a temptation to consider the "worst case scenario" every time, as opposed to the most likely consequence. I personally refer to the example of someone falling from the 3rd or 4th rung of a ladder. We concede that on occasion, the best trained people using the correct equipment in the correct environment may come a cropper. Yes, people have died as a result of such a fall, but better to consider the most likely outcome of (say) a major injury. An over-focus on "danger of death" tends to bring the whole process into disrepute.
Kate  
#8 Posted : 14 June 2011 11:03:24(UTC)
Rank: Super forum user
Kate

If PPE doesn't reduce the severity, then what's the point of it?
michaelnebraska  
#9 Posted : 14 June 2011 11:05:20(UTC)
Rank: New forum user
michaelnebraska

Kate wrote:
If PPE doesn't reduce the severity, then what's the point of it?
couldnt agree more.
sean  
#10 Posted : 14 June 2011 11:12:08(UTC)
Rank: Guest
Guest

Forbez, ask your colleague to jump out of a plane wearing a parachute, the probability is he will land safely, then ask him to jump out again without a parachute, probability......
jay  
#11 Posted : 14 June 2011 11:28:37(UTC)
Rank: Super forum user
jay

Some risk assessments are taught using a format that calculates the initial risk without control measures and then with control measures. It appears that your employee has not understood the link between control measures and reduction in severity (in rare cases probability) and hence overall risk. In my view for the example you have given, probability of the fall will be the same with or without PPE, but the severity of injury will reduce.
RayRapp  
#12 Posted : 14 June 2011 11:34:43(UTC)
Rank: Super forum user
RayRapp

Forbez It is a very good question and has already solicited a number of good responses. Whilst PPE with suitable controls not only lowers the severity but also the risk of an adverse event occurring but...not always. For instance, wearing a hard hat might save a person from a potentially serious injury from a falling object, however if it was a twenty ton block of concrete the hard hat would be as good as useless. Some organisations implement a risk assessment based on a before and after concept with the severity rating adjusted to reflect the mitigating controls. I suggest that this is the only true way of identifying whether the controls will reduce the severity and likelihood of an adverse event occurring. Personally, I find these overly bureaucratic and unnecessary as it is only the final outcome that really matters. Ray
Forbez  
#13 Posted : 14 June 2011 11:37:10(UTC)
Rank: New forum user
Forbez

I am almost certain I am right, however I work in the oil industry and in line with what I was told at my risk assessment course at Weatherford (a massive oil service company) the severity should not be reduced after control measures implemented. This is evident across every risk assessment I have came across whilst working in the oil industry. PPE is stated as a control measure, but the severity of injury has not been reduced.
chris.packham  
#14 Posted : 14 June 2011 12:16:05(UTC)
Rank: Super forum user
chris.packham

Whilst PPE can reduce the severity of a hazard, there is one factor that should always be considered in any decision to rely upon PPE. This is that almost invariably (and I cannot think of an exception, though I am sure others will!) PPE when it fails, fails to danger. That butyl rubber glove may provide excellent protection against strong hydrofluoridic acid. However, except in a dire emergency, I would never isert my hand into hydrofluoric acid relying purely on the glove to prevent damage to health. So in a sense we almost have two risk assessments. The first assesses the primary hazard. We then control this by using PPE. We then should assess the risk of the PPE failing to protect. If that is deemed unacceptable then its back to square 1 - how can we reduce the risk by other means. The aim should always be to control the process, not the person. I can generally find a way to make the process controls fail to safe. Can anyone tell me how I make persons fail to safe? I would love to know. Chris
hopeful  
#15 Posted : 14 June 2011 13:43:19(UTC)
Rank: Super forum user
hopeful

In past companies we have reassessed the risk and shown both results, demonstrating the reduced risk if control measures are in place
Goose  
#16 Posted : 14 June 2011 13:43:47(UTC)
Rank: New forum user
Goose

You have already had many sensible and considered responses and your colleague may well be able to leave his/her severity unaltered at high but by introducing PPE you have reduced the liklihood of the event occurring and therefore your overall risk rating will come out low. The purpose of any risk assessment is to carefully consider and then manage risks and in reality there is no right or wrong way of doing it and you can arrive at the final decision in any number of ways but bottom line should always be to mitigate against any risks identified.
Kate  
#17 Posted : 14 June 2011 13:51:04(UTC)
Rank: Super forum user
Kate

But fall arrest does nothing to prevent a fall - it only provides any protection after the fall has happened. So it can't reduce the probability of a fall. I suppose you could argue it reduces the probability of hitting the ground ...
Borisgiles  
#18 Posted : 14 June 2011 15:13:20(UTC)
Rank: Forum user
Borisgiles

Surely some PPE reduces the severity of the accident (e.g. Safety harness, hard hat etc) and some reduces the likelihood of the accident (e.g. Hi Vis). As ever I'm left wondering if the purpose of the risk assessment is to come up with a perfect document to present to the HSE when they visit, or to identify the hazards and come up with suitable controls to stop the accident happening. Risk assessments don't stop accidents, control measures (probably identified by a risk assessment) stop accidents. In the real world it doesn't matter whether your bit of paper says the lively severity has reduced or not, what matters is whether or not the bloke hits the floor!
chris.packham  
#19 Posted : 14 June 2011 15:19:10(UTC)
Rank: Super forum user
chris.packham

Borisgiles has it right. Risk assessments only tell you the risk. Risk management then attempts to eliminate or adequately control that risk. But having introduced your risk management measures you then have to go round again and reassess the risk to ensure that the management measures are adequate, otherwise how do you know? you might then decide that there is still an unacceptable residual risk and this, to my mind, is where PPE comes in, not as a means of controlling the primary risk but as a means of controlling any residual risk. It would be at this stage that the probability of failure of the PPE would need to be assessed and, if appropriate, additional measures introduced. Chris
RayRapp  
#20 Posted : 14 June 2011 16:18:16(UTC)
Rank: Super forum user
RayRapp

As I suspected, there are a number of different slants on the subject, which reflects the fact there is no right or wrong answer with this particular topic. Generally if the hazard is realised then the controls which have been implemented have not been effective for whatever reasons. The controls may have reduced the severity but as a rule they do not. For example, if your RA for WAH identifies the severity from a fall as a probable fatality and the controls fail - a fatality is the most likely outcome. All the harnesses, edge protection, etc, in the world is not going to bring the person back to life. Therefore you can reduce the likelihood of an adverse event occurring with PPE and collective fall protection, but it does not reduce the severity of an unbroken fall.
jay  
#21 Posted : 14 June 2011 16:28:23(UTC)
Rank: Super forum user
jay

The risk assessment control measures would be supplemented by "safe systems of work". Yes, control measures may fail, but in essence the reliability of control measures is ensured by safe systems of work! Otherwise, if we want to include failure of control measures in the risk assessment, then we end up with more stringent/sophisticated risk assessments such as Failure Effect Mode Analysis ( FEMA ) , HAZOP, and so on. The question can control measures reduce severity, not about the reliability of control measures. To assess reliability of control measures, techniques are available, but generally not used as long as robust safe systems of work are in place
RayRapp  
#22 Posted : 14 June 2011 16:47:43(UTC)
Rank: Super forum user
RayRapp

'The risk assessment control measures would be supplemented by "safe systems of work". Yes, control measures may fail, but in essence the reliability of control measures is ensured by safe systems of work!' Control measures are part of the SSoW! There is never any guarantee that these, for whatever reason, will not fail and therefore normally the severity will be the same. It is the likelihood of the incident occurring ie the risk, which changes - not the severity.
pl53  
#23 Posted : 14 June 2011 16:53:25(UTC)
Rank: Super forum user
pl53

Risk is all about probabilities and therefore so is a risk assessment. In my view the general approach should be to maintain the severity as it is and reduce the risk by reducing the probability of that risk being realised. Like Chris Packham said, PPE for instance always fails to danger. If your control is PPE then when it fails, the severity of the injury will be just as severe. All the PPE does is make the injury less likely. Take as another example, the risks involved when crossing a road. The main hazard is moving traffic and the likey outcome of being struck by a car is death or serious injury. Crossing a country lane in Lincolnshire may be considered as low risk because the small amount of traffic, but if a car doies hit you then goodnight. Crossing a busy high street has a higher risk because of the larger volume of traffic making the probability higher. If you cross at a pedestrian crossing the risk is reduced, but again, if you are hit by a car them it's curtains. Try to cross the M6 - well you get the point. There may be instances when controls reduce the severity of an injury but in my view they usually only reduce the probability.
andybz  
#24 Posted : 14 June 2011 17:20:17(UTC)
Rank: Super forum user
andybz

The problem as I see it is that a lot of people want a single answer from their risk assessment. What you need to do is consider a range of possibilities from worst case scenario to minor outcome. You then factor in the probability and then have a good idea of what the risk is. In some cases the worst case scenario is the highest risk (due to the severity part of the equation) and in some cases it may be the minor outcome (due to the high likelihood). I'm pretty uncomfortable about the idea of using PPE as a reason to reduce severity. The hazard remains and so in the vast majority of cases the potential consequences are the same.
Canopener  
#25 Posted : 14 June 2011 19:30:43(UTC)
Rank: Super forum user
Canopener

It appears that most are singing from much the same hymn sheet. A 'reduction strategy' is a widely used method to help manage risk and can be used to reduce either the likelihood of an incident or injury occurring and/or the severity of an injury. In fairness I would say that most probably reduce the likelihood. However, your query concerns the latter and I suggest that a couple of simple examples where 'a severity' can be reduced are: Substituting a very toxic substance for one that is harmful Using 110v or battery powered kit instead of 240v
boblewis  
#26 Posted : 14 June 2011 23:02:46(UTC)
Rank: Super forum user
boblewis

Perhaps we should be really asking "what is the severity of the likely accident using the method of work that I am intending to use?" Bob
firesafety101  
#27 Posted : 15 June 2011 12:04:45(UTC)
Rank: Super forum user
firesafety101

Are we discussing risk assessment or risk rating here? The purpose of a risk assessment is to assess the hazard and risk in an effort to reduce, or eliminate the potential harm. Risk rating is when you give a number (rating) to the potential hazard/risk and the likelihood of that risk/hazard being realised. Example - electrical hazard could result in electric shock and death if contacted by person. Keep that person away from the hazard and you reduce the likelihood of the harm but the hazard is still there and contact could still be fatal. The hazard has not been reduced but the likelihood has been. The hazard has not been removed. Similar a water hazard could result in drowning but erect a fence and warning signs and the likelihood is reduced - the hazard remains. The parachute post - could still lead to severe injury or death if the PPE fails or is incorrectly packed. Simply by providing a parachute does not ensure no hazard remains.
firesafety101  
#28 Posted : 15 June 2011 12:08:16(UTC)
Rank: Super forum user
firesafety101

The use of a harness may result in reducing the risk from a fall from height but you introduce a new hazard of potential death from hanging in a harness. Eliminate one hazard but introduce another that requires risk assessment, emergency rescue plan etc. Risk assessment is not as easy as some people think.
RayRapp  
#29 Posted : 15 June 2011 13:04:45(UTC)
Rank: Super forum user
RayRapp

Chris, neither is health and safety management.
JESU  
#30 Posted : 15 June 2011 13:18:46(UTC)
Rank: Forum user
JESU

PPE is the last option in the heirachy of control measures, and there are cirtain operations where PPE are the only defensive mechanism, where the likelihood remain the same, impact get reduced. The other question hazard is, the improper use of PPE, we need to mitigate the same. Tool box talks, training and awarness, signages could help it. Cheers Jesu, DXB
Sutty31  
#31 Posted : 19 June 2011 10:39:26(UTC)
Rank: Forum user
Sutty31

I agree with some points in this thread but i personally preach that the severity should remain the same..depending on the identified hazard. The thread discusses WAH falls and harnesses..which seems to change the fatal fall to going for a swing in a harness (tongue in cheek) but my example is traffic management (working on a motoway). If hit by a HGV, you would probably die and no amount of PPE is gonna change the severity, so i think the issue and severity change are hazard specific
Fletcher  
#32 Posted : 20 June 2011 12:02:30(UTC)
Rank: Super forum user
Fletcher

This is much too academic for me. All I (and I know everybody else is the same) want to do is stop people from getting hurt. RA's that I get involved in (normally with others so varied views) identify what can happen and then how are we going to stop it, then in trying to stop it have we created another problem which needs additional controls. When we have thought of everything reasonably practical to control the risk then we document it, before and after controls. If the opinion is that severity and/or likelihood have been reduced then we give new values. I can follow the arguements that severity should stay the same but we will change if we think the severity has been reduced because of the control measures taken. Course if we have an accident then we may be proved wrong but so far the Gods have been on our side. Take Care
TomDoyle  
#33 Posted : 20 June 2011 17:00:26(UTC)
Rank: Forum user
TomDoyle

This is truly amazing. The concept of PPE reducing the severity of harm seems completely illogical. Let’s use safety eyewear as an example. Imagine that small metal projectiles are occasionally present in the workplace. We do the risk assessment and end up with PPE and training on its use in order to reduce the risk. As a result of our confidence in the effectiveness of the risk reduction strategy we decide that the severity of injury is very minor thus sufficiently lowering the risk. Low and behold, one day a worker temporarily removes the safety eyewear in order to read some small text (just for a moment). At that moment a metal projectile strikes the worker in the eye resulting in the loss of sight in one eye. In this circumstance would the incident investigation reveal that the worker had experienced a very minor injury? I think if we asked the worker they would very clearly state that their injury was quite serious. The PPE does not change the hazard. In my opinion: Injury severity should almost always be associated with the properties of the hazard in the circumstances that are being assessed. PPE can only effect the probability or likelihood of the worker experiencing the amount of potential harm that presented by the hazard. Cheers Tom Doyle Industrial Safety Integration
David Bannister  
#34 Posted : 20 June 2011 17:12:07(UTC)
Rank: Super forum user
David Bannister

TomDoyle, in your example the PPE is not being used. If it was used properly then the severity would have been reduced to a shocked worker. The projectile would still have contained the same energy, part of which is transferred to the eyewear, as opposed to the eyeball and the probability of the projectile being emitted remains the same. The outcome is different. Surely this is an example of severity being reduced by proper use of PPE. The hazard remains constant but the risk arising is reduced. What is agreed by us all I think is that PPE is a very hit & miss method of protection, rightly low down in the hierarchy of control, although still used as a primary control in many work situations.
James Martin  
#35 Posted : 20 June 2011 20:33:47(UTC)
Rank: Forum user
James Martin

Hi Forbez Responses to topics like this make me chuckle sometimes. In your post you state that PPE reduces the severity and not the likelihood. Why do you assume this to be a hard and fast rule? A hi visibility vest worn by a person who is hunting is used to lower the likelihood of another hunter shooting him by accident. This is an example of PPE reducing the likelihood however, the same item of PPE does not reduce the severity (unless it is a bulletproof hi viz vest :-) ) PPE is a last form of defense but it does not mean measures MUST be implemented before PPE is used it just means you need to explore other options (ERICPD) and if they are not reasonably practicable, PPE it is. You mention the use of a harness. This is a work at height issue and collective fall PREVENTION is required such as guard rails. If this is not 'reasonably practicable', individual and/or fall PREVENTION measures should be looked at. A harness is an individual measure of fall protection as it protects a person in the event of a fall it does not prevent the fall like guard rails would however there is no reason for a harness not to be used as a control measure. Follow the flow of ERICPD in your risk assessment and eventually you will stop at the correct measure. Sometimes it can be worse to go overboard than 'underboard?' It is always best to eliminate or reduce both the severity and likelihood but most of the time this is not reasonably practicable e.g. if you were working close to an open edge and there was a risk of falling, you would erect barriers to prevent the fall (fall prevention reducing likelihood). If this could not be done, you could use airbags to protect the person in the event of a fall (fall protection reducing the severity) or you could get rid of all that money and go way overboard by using both! To conclude, PPE CAN be used to lower severity and / or likelihood. It all depends on the situation at hand. Too many times I hear people say 'you cant do that' but most of the time there is no legislation to back this up just rumour. Sensible use of a hierarchy of control that will work depending on the particular hazards present is the way to go. Keep it simples. Simples!
David H  
#36 Posted : 20 June 2011 21:43:15(UTC)
Rank: Super forum user
David H

James Martin - I fully support Forbez comments and wonder why you would chuckle? If you are unable to eliminate the hazard and the potential risk, then you are depended on control measures. and PPE being the least dependable control as it is dependant on the person using it correctly and it has its own inherent limitations - again due to selection by someone who may have underestimated the potential. The high viz vest will not protect the wearer in the event of contact - but may reduce the likelyhood of the contact. The safety glasses may prevent injury - if they are worn correctly and able to withstand the impact. But they may also deflect the missile to an unprotected part of the face or even to a 3rd party. Either way it is a falure in control Now I advise my management team that the severity will not be reduced due to PPE - simply because there is so many ponderables that may go wrong. I am paid to keep my people safe and keep my bosses out of court. I would not like to try and convince a court of law that PPE would be an acceptable risk control. Yes it has its merits - but lets get things right here - we are talking real pain and suffering if it goes wrong. David
RayRapp  
#37 Posted : 20 June 2011 23:13:04(UTC)
Rank: Super forum user
RayRapp

'So my question is this; given that the only purpose of PPE is a last resort that doesn not to reduce the likelihood of an injury but is utilised to reduce the severity of an injury should an accident, is it acceptable to lower the final accident severity (after control measures have been implemented) in light of the use of PPE.' Forbez, I hope you have got the answer you sought. In short, PPE may reduce the likelihood of an injury and it may reduce the severity of an injury - it depends on the type of hazard and PPE. Moreover, any control measure will to reduce the overall risk rating, but not normally the severity if the risk is realised. I hope I have summarised that correctly...getting late. Ray
James Martin  
#38 Posted : 21 June 2011 07:32:47(UTC)
Rank: Forum user
James Martin

David H Dont wonder why I would chuckle, simply read my post again. (responses to topics like this make me chuckle) responses such as yours, not the question. For some reason on this forum it sometimes appears as though people are waiting to pounce. I fully understand your theory however to generically advise a management team that the severity will not be reduced with the use of PPE closes a number of possible options available. If PPE does not reduce severity, why on earth do we wear it? The fact of the matter is, in the real world, PPE does work. Although most of the time it is not the correct means of controlling a hazard, it does have its place and regardless of opinions, PPE does reduce severity. A butchers chain mail glove, firemans heat resistant clothing etc. I am merely saying that I find it a little harsh to simply eliminate the use of PPE as it is wrongly assumed that it does not reduce the severity. Sounds great on a clean sheet of A4 paper, but onsite, PPE has its place. Sensible H&S is the way forward. Go through the risk assessment process and the correct controls will be identified which may sometimes be PPE (butchers glove as mentioned above)
bob youel  
#39 Posted : 21 June 2011 07:45:46(UTC)
Rank: Super forum user
bob youel

I have seen the same risk assessment [identical in every way but for 1 aspect] undertaken in two ways. The first example gave the control measure and then left the risk rating as high and the second example gave the same control measure but then reduced the risk rating because of the control measure. Thereafter managers were left to their own devices In all cases where the risk rating had been reduced even though everything else was the same management became lax. Thereafter we always retained the risk rating level as if there was no control in place as it focused attention This is an example of a number of experiments we undertook via the nuclear and off-shore game when planning the channel tunnel whilst looking at how people brains worked [I was a very lowly member of a very cleaver & distinguished number of teams undertaking safety cases/experiments] So; in my personal view, there is an argument for both sides but the higher the risk the more we should look at retaining that high risk rating irrespective of the controls present instead of showing it as reduced because people become lax ---- I know of cases at this time where the PPE as the control has in theory reduced the possible severity. However where management see the lower risk rating thereafter they stop managing the people properly and allow poor practice which then reduces the protection of the PPE and in fact raises the severity level back to where it was without the PPE as they become focused on the reduced risk rating level instead of the severity present! Severity is reduced/controlled only where a combination of risk assessment and best practice management is present NB: I find that there are very few suitable & sufficient PPE risk assessments out there ----- at 1 specific seminar that I attended the HSE publicly admitted, after my open question on the subject, that they had completely missed the area [other than giving a general reference] in a very high risk industry
MEden380  
#40 Posted : 21 June 2011 08:53:04(UTC)
Rank: Super forum user
MEden380

I still find the concept of severity and likelihood in risk assessments something that we should be getting away from except in high risk industries. Look at the HSE R/A template - You identify a hazard and associated risks and you put in control measures to minimise the hazard, review as necessary. You do away with subjective opinions. You identify a hazard - you put in control measures to minimise said hazard, PPE being the last line of control. In UK construction we put temporary safety rails to prevent falls rather than have every body using fall prevention harnesses. If you produce a R/A that has a high risk rating and something goes wrong - how to explain to the HSE why you let that work continue when you considered it dangerous to do so. If you identify - control - monitor - review This may be considered a simplistic approach to R/A, but at the end of the day who are the R/A for. The HSE or the operatives carrying out the work.
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