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Please take this as a "fun" topic for discussion.
Has anyone got an opinion as to what is too great a volume of health and safety paperwork as we keep hearing how H & S is a burden. The reason I ask is that I had a look at a small builder with 20 workers who's policy, written by a consultant ran to over 250 pages, I have also seen a small to medium sized holiday / amusement park who's play equipment checksheets alone run to over 1100 pages in a season, I've also come across 9 page induction forms, 30 to 40+ page risk assessments for relatively small to medium sized businesses in a medium to high risk environment (engineering workshop, manufacturing with associated admin) or low risk as redefined by Chris Grayling.
I'm a great believer in keeping good records, from experience having seen paperwork save companies from civil action, but believe it should be kept to a minimum of what is necessary and be easily read, shown to and understood by the workforce, I often come across companies that just don't have the time to fill out large numbers of forms. I would be interested in other members views on what would be sensible levels of recording and what sort of volumes of H & S paperwork they come across whatever size of business.
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Rank: Super forum user
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My views on 'paper safety' has been aired on these forums on may occasions. There is far too much documentation and much of it adds little value to health and safety - the general excuse is it is for the ' audit trail'. I feel sorry for those at the coal face who are obliged to fill end endless documents to prove they are doing their job properly, working on the tools some can barely read or write. I wonder when someone will realise that a piece of paper with signatures on only proves that 'someone' has signed a piece of paper!
I recall a situation some while back with a couple of electrical guys fitting comms where I asked to see their method statement. This chap reached into his van and produced a 70 page method statement neatly bound and insulated in a plastic folder. I asked if he had read the MS - he said "nope, would you?" I said "no, crack on".
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Rank: Super forum user
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The amount of records required is generally proportionate to the business, however I fear the ongoing ignorance by many companies of the actual requirements of H&S leg, associated systems and over zealous consultants looking after their next pay packet is a (the) real problem. Many companies still think they can buy compliance via 'off the shelf' systems with cut and paste (XXXXXXXXX) sections to 'place you company name here' Grrrrrrrrrrrrrrr. The only paper trail this leads to is the lavatory.
G
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Rank: Super forum user
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RayRapp wrote:My views on 'paper safety' has been aired on these forums on may occasions. There is far too much documentation and much of it adds little value to health and safety - the general excuse is it is for the ' audit trail'. I feel sorry for those at the coal face who are obliged to fill end endless documents to prove they are doing their job properly, working on the tools some can barely read or write. I wonder when someone will realise that a piece of paper with signatures on only proves that 'someone' has signed a piece of paper!
I recall a situation some while back with a couple of electrical guys fitting comms where I asked to see their method statement. This chap reached into his van and produced a 70 page method statement neatly bound and insulated in a plastic folder. I asked if he had read the MS - he said "nope, would you?" I said "no, crack on".
Whilst I whole-heartedly agree with all your points, the cold reality is that should an incident / accident occur the courts (be it criminal or civil) really are only interested in documentation..
Clearly excessive documentation is counter productive (and our corporate policy is to produce the minimal amount of paperwork to satisfy our requirements and use lay terms etc. etc.) however for some tasks more is more.. Speaking with our primary authority they recount times in court with other similar buisiness where they had lost a court case due to a lack of documentation to demonstrate they did what they did! (i.e. in practice the checks were being made but a decision was made (in good intentions) to not document everything due to the practicialities of filling in forms and filing compelted forms).
I suppose it goes back to they why are we employed, to protect the employees, the company or both!
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I had to 'check' a 97 page H&S Policy which had a statement....
"This policy contains codes of practice, this does not imply that others do not apply."
Further on it said......
"This policy must be read and followed by all staff and volunteers."
not worth the paper it was written on.
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At my last company we had a least 12 different method statements for our range of clients (mostly UKCG companies) these ranged from half a dozen pages up to approximately 25 pages all for the same task!
Each company would issue a different guidance document for method statements which basically ranged from a 6 point plan right up to a 17 point plan and if you did not format the method statement following the respective plan it would be rejected out of hand.
Surely these companies could get their heads together and come up with a common method statement format therfore reducing the amount of paperwork required - or is this too much to ask for?
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Rank: Super forum user
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Paperwork is all part of the job these days with audits, papertrails,etc. If an employee went to a solicitor no win no fee, at least you can prove that you have done everything, reasonably practicable to reduce the risks etc in the workplace,
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Rank: Super forum user
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Does it serve a useful purpose? (Does it ensure we meet legal obligations? Does it help ensure the health and safety of our workforce, and others?)
Does it achieve this?
Is the effort/cost commensurate with the benefits?
If answer is 'yes', can it be simplified?
If answe is 'no' then don't do it.
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Rank: Super forum user
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There is far too much paper for paper sake, not for safety, none (or not all of it anyway) of this paperwork filters to the operatives.
Its not safety its making sure the company is covered in the event of an accident, should be not be focusing on the prevention of such, as that is the best cure.
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Rank: Super forum user
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The amount of paperwork should be proportionate to the sort of work being carried out. Our organisation employs 900 ish people and unlike some places, we are not doing just one job but hundreds of different tasks for many clients (basically R&D covering everything from labs to fieldwork). Therefore the paperwork is ‘owned’ by the people who do the work: they create the Sops and risk assessments and they ensure that training records are kept upto date. Apart from that we don’t need anything else really. We’ve had the HSE on site and they have looked at this paperwork and have been happy it it.
As far as civil claims are concerned there is never enough paperwork to keep the lawyers off your back so we don’t bother. They once asked for risk assessment for carrying a cup of tea down the corridor!
I like to keep paperwork to a minimum, I tell staff I expect something to be written down, but I don’t expect pages and pages of stuff for its own sake. As far as COSHH is concerned I don’t expect a document for every substance used- we use thousands, just for the process we do, of which there are dozens.
I have recently had a clash with our QA team who have informed me that for the sake of document control all risk assessments should use the same format- it makes them easier to audit. This would mean telling people to scrap all of the documents they are using and replace them with documents which look ‘nice’ but might actually be useless. I have dug in my heels and told them to get lost!
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Rank: Super forum user
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in the late 80's when we were going for both BS5750 and stars on the Internationaal Safety rating system, my boss made the comment that you would not hurt yourself from a fall since there was so much paperwork you would always have a safe landing
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Rank: Super forum user
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quote=terry556]Paperwork is all part of the job these days with audits, papertrails,etc. If an employee went to a solicitor no win no fee, at least you can prove that you have done everything, reasonably practicable to reduce the risks etc in the workplace,
Does it prove that you have done everything reasonably practicable, because you have a piece of paper. Does even having written risk assessments reduce the risk, I don't think it does. I work on a site with over 500 employees although we have over a thousand people working on the site. I ask all the time if they have read the risk assessments, SSOW or method statements and the answer 99% is no. We also have corporately 27 different polices ranging from 50 to 200 pages long. I have reduced theses for site purposes to 1-2 pages. When I ask people why they work in accordance with the R/A if they have never read them the answer is because your always there telling us.
I believe that hands on and training are the valuable assets to having a safe work force.
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Invictus wrote:
I believe that hands on and training are the valuable assets to having a safe work force.
Defo this is the key, prevention before cure
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And returning back to the real world from cloud cukoo land.....
Yes of course paperwork is a pain in the backside and of course some companies go OTT and have reams of unnecessary paperwork and minimal documentation really is best....I don't think any of us dispute that do we????.........BUT this is the real world and like it lump it paperwork is needed as a back up when a certain substance hits the fan. Do it, document it - or you really can't prove it in court. That's reality
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Clairel you're probably right as is everyone else.
I quite often think the safety profession is inclined to forget the point of H & S documentation and seems to direct it at lawyers rather than the important people it's designed to protect, after all a simple "fag packet" risk assessment or policy that can be understood by a poorly educated worker that actually tells them how to do their job without getting hurt must be worth a riem of paper written to satisfy a barrister or judge who probably hasn't too much idea of the working mans world. I spoke to a client today who said they didn't give their policy and RAs (consultant produced) to the workers as they wouldn't understand them, they preferred to edit out the jargon and deliver it in shortened form verbally (with a signed sheet indicating reciept of the info).
I tend to take some pleasure when I do safety reviews and ask either a senior manager or director if they have actually read their policy & RAs etc and watch the reaction, so far I've only come across 1 company director who claimed to have read it all, most don't get past page 2. Similarly with check lists some of them don't even bother to swap pens when filling them out by the batch. If I'm honest I don't really blame them.
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There is never enough paper when you are in court or similar situation but there is always to much paper in day to day situations
My advice is that all 'management' type paperwork should be such that it is suitable and sufficient for a court case but day to day paperwork should be suitable for the people directly involved - I have cut down many pages to just one page for day to day staff on many an occasion
Its interesting to note that when it suites management they will produce reams of paper on spurious, political, self praise etc. points but its always to much effort when it involves helping the workforce
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Rank: Super forum user
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terrypike wrote:Clairel you're probably right as is everyone else.
I quite often think the safety profession is inclined to forget the point of H & S documentation and seems to direct it at lawyers rather than the important people it's designed to protect, after all a simple "fag packet" risk assessment or policy that can be understood by a poorly educated worker that actually tells them how to do their job without getting hurt must be worth a riem of paper written to satisfy a barrister or judge who probably hasn't too much idea of the working mans world. I spoke to a client today who said they didn't give their policy and RAs (consultant produced) to the workers as they wouldn't understand them, they preferred to edit out the jargon and deliver it in shortened form verbally (with a signed sheet indicating reciept of the info).
I tend to take some pleasure when I do safety reviews and ask either a senior manager or director if they have actually read their policy & RAs etc and watch the reaction, so far I've only come across 1 company director who claimed to have read it all, most don't get past page 2. Similarly with check lists some of them don't even bother to swap pens when filling them out by the batch. If I'm honest I don't really blame them.
Although I agree overall with what is being said: too much paperwork for it’s own sake, I am rather concerned that “a poorly educated worker” only needs a “fag packet” RA while someone that is more qualified should be burdened with loads of instructions and documentation. Surely it should be the other way around. If you recognise that your staff are poorly educated you should be doing more to make sure that they are aware of all the risks involved. Not necessarily making them read reams of paper work but making sure that they have adequate instruction, supervision etc. not less.
Have a look at the recent issues of SHP and notice how many nasty accidents have involved foreign workers (ie workers whose first language is not English). What these guys needs is more instruction, supervision etc. not less, this, for some people, amounts to more red tape and paperwork.
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quote=Clairel]And returning back to the real world from cloud cukoo land.....
Yes of course paperwork is a pain in the backside and of course some companies go OTT and have reams of unnecessary paperwork and minimal documentation really is best....I don't think any of us dispute that do we????.........BUT this is the real world and like it lump it paperwork is needed as a back up when a certain substance hits the fan. Do it, document it - or you really can't prove it in court. That's reality
I actually find myself agreeing with ClaireL. Although I think I have a slightly more positive outlook on paperwork. Yes it can get excessive, ineffective, involve too much waffle/jargon etc. However, paperwork has lots of benefits besides covering the legal backside. Done properly, it can distill complicated thought processes into clear guidelines, it can help channel complex thinking into manageable chunks, it can enable the passing of knowledge from one person to the next. Also, checklists serve as a useful memory jogger for what to look for and can provide a very satisfying sensation for people to tick - 'compliant' - or exceeds compliance!
Here's a nice little Einstein quote: "Everything should be made as simple as possible, but not one bit simpler. " I think that sums it up nicely.
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A Kurdziel, what I mean is, the wonderful 10 page psudo-legal template cross referenced to SSWs, legislation, ACOPS and indgs is nothing more than useless to most less educated workers or those who's first language isn't English, a simple "fag packet" RA properly discussed is worth much more in practical terms. Any safety documentation should be aimed at the worker not the lawyer and be consise, simple and straight forward. I don't think a more educated worker needs more complex documentation, in my experience the more educated are less inclined to read and understand anyway.
Instruction and supervision doesn't necessarily equate to paperwork, it's all to easy to produce riems of paper and write a complex document, shove it under a workers nose, get them to sign it and stand up in court and use this as proof of due diligence, when in fact it's just giving lip service to H & S (then moaning that it's a burden).
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Most companies do not take the time to think what paperwork they actually need. The suggestion that the paperwork is required by HSE or in the event of a claim is simply an excuse because no one wants to make a decision to not create another piece of paper, even if they think it is a waste of time or counter-productive.
Procedures is one area I do a lot of work in. Most companies try to write one for every task and have decided that all procedures should look the same. This makes no sense to me because we end up with loads of procedures that are used very rarely. I work with companies to identify the tasks they perform. We then use a method of ranking them according to the benefit of having a procedure. We invariably find that there are lots of procedures that have little or no value yet there are some tasks where a procedure would be very valuable but one has not been developed.
My view is that companies start by writing the easy procedures, they keep going until it gets too difficult and then they stop. It would be much better if they accepted that a procedure cannot be written for every task, but aimed to cover all the tasks where a procedure is of greatest value. Using a method to prioritise means you have a defence if someone wants to know why a procedure was not written.
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terrypike wrote:A Kurdziel, what I mean is, the wonderful 10 page psudo-legal template cross referenced to SSWs, legislation, ACOPS and indgs is nothing more than useless to most less educated workers or those who's first language isn't English, a simple "fag packet" RA properly discussed is worth much more in practical terms. Any safety documentation should be aimed at the worker not the lawyer and be consise, simple and straight forward. I don't think a more educated worker needs more complex documentation, in my experience the more educated are less inclined to read and understand anyway.
Instruction and supervision doesn't necessarily equate to paperwork, it's all to easy to produce riems of paper and write a complex document, shove it under a workers nose, get them to sign it and stand up in court and use this as proof of due diligence, when in fact it's just giving lip service to H & S (then moaning that it's a burden).
Agree with you. Is it not our job is to advise, inform and protect workers through IIT, not doing all this paperwork for a court case.
The guys I work with just want to get on with their job, they dont want to sit in an office for a day doing inductions/ method statements/ risk assessments/ COSHH assessments/ how to complete a permit/ this procedure that procedure etc.... They dont take the information in anyway after the first half hour.
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I'm not sure I go with all this holier than thou sentiment that we're not in the job of protecting the employer in the event of a court case.
Of course the primary job we have is to prevent accidents BUT we also have to make ensure that employers (and workers) comply with the law. In some cases that requires paperwork and in others it requires the ability to prove that compliance has taken place through paperwork.
Let's not get all snotty nosed about protecting employers and workers in a court case, like somehow it's beneath our moral compass.
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Clairel wrote:I'm not sure I go with all this holier than thou sentiment that we're not in the job of protecting the employer in the event of a court case.
Of course the primary job we have is to prevent accidents BUT we also have to make ensure that employers (and workers) comply with the law. In some cases that requires paperwork and in others it requires the ability to prove that compliance has taken place through paperwork.
Let's not get all snotty nosed about protecting employers and workers in a court case, like somehow it's beneath our moral compass.
The initial post was regards how much paperwork is too much, I am not saying cut all paperwork, I am saying it needs to be short and to the point and FOR THE WORKERS, the persons who will get injured in the event of an accident, and not just produce paperwork for the sake of it to cover ones back. Some of the workers I work with are middle age men, some who never attened school, and if you give them a 20 page document they will not read it, and if you read it to them they will zone out.
I know paperwork is required as part of IIT, I do the paperwork, but if you can get the info across in 2 pages why write 20??
And can I say, my above opinion is taken with the worker in mind, not other safety related paperwork such as reports/meetings etc.....
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But not all paperwork is for workers though. Records of training, maintenance and other checks are also part of the paperwork system. Those are there as nothing more than proof really.
I actually don't agree with giving employees risk assessments at all. I think employees should be talked through what the risks are to them and what they need to do. Most RA's are too long and too complicated and also usually include what still needs to be done. IMO a RA is there as a tool to check everything is being done that could / should be done and to provide a legal document should the need arise. The employee just wants to know what to do and why at the end of the day but that level of detail is not enough to satisfty the courts that enough has been done.
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Folks, if I may?
Lets face it we can't avoid paperwork, but we can apply some proportionality. The key is to look at what your business needs, possibly to comply with a management system standard or internal requirements. Then keep is simple. There's lots of comment about RA's and RAM's but remember these are only the record of a risk assessment, not the process itself. Don't get caught up in trying to cover the proverbial rear end, its just not worth it because if someone is taking legal action against you its rarely ever enough! No matter how good you thought your risk assessment was, if someone got injured it wasn't good enough. Don't be driven by the fear of litigation, do what's needed to keep people safe and where necessary keep a record.
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jontyjohnston wrote: No matter how good you thought your risk assessment was, if someone got injured it wasn't good enough. quote]
What nonsense.
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Clairel wrote:jontyjohnston wrote: No matter how good you thought your risk assessment was, if someone got injured it wasn't good enough. quote]
What nonsense.
Not nonsense, its true...cause if it does go to court, the RA will be ripped apart. Have any of you seen the True cost of an accident video?? )Construction site, scaffolder removed a clip, answered his phone, fell, got injured....but a scaffold board also flew off the scaffold, over the boundary fence and killed a passing woman). No matter what my RA would have been like I doubt I would have added that factor into it.
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You don't need two pages to hammer in a nail.
Alternatively, a single page isn't going to be adequate to lift in a dozen beams, over a railway at night.
It's all relative to the task / operation, commercial / statutory / stakeholder expectations etc.
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Lawlee45239 wrote:Clairel wrote:jontyjohnston wrote: No matter how good you thought your risk assessment was, if someone got injured it wasn't good enough. quote]
What nonsense.
Not nonsense, its true...cause if it does go to court, the RA will be ripped apart. Have any of you seen the True cost of an accident video?? )Construction site, scaffolder removed a clip, answered his phone, fell, got injured....but a scaffold board also flew off the scaffold, over the boundary fence and killed a passing woman). No matter what my RA would have been like I doubt I would have added that factor into it.
You're talking to an ex-inspector so I know a fair bit about investigating accidents and prosecuting thank you. Just becuase an accident occurs that doesn't necessarily mean that the RA wasn't good enough.
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"Just because an accident occurs that doesn't necessarily mean that the RA wasn't good enough."
Claire,
I would prefer to agree with you but we had a recent injury on site where someone fell on uneven ground( no worse than Judith's hopscotch rink) and our inspector said the fact that he suffered significant injury - cracked rib- meant that we had a significant risk so it should have been assessed.
Ken
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quote=redken]"Just because an accident occurs that doesn't necessarily mean that the RA wasn't good enough."
Claire,
I would prefer to agree with you but we had a recent injury on site where someone fell on uneven ground( no worse than Judith's hopscotch rink) and our inspector said the fact that he suffered significant injury - cracked rib- meant that we had a significant risk so it should have been assessed.
Ken
RedKen
You should have referred the inspector to the Independent Regulatory Challenge Panel at
http://www.hse.gov.uk/contact/challenge-panel.htm
and given them something to do.
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