Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
Chris Armstrong  
#1 Posted : 09 January 2013 13:56:27(UTC)
Rank: New forum user
Chris Armstrong

Over the last few years, I have carried out various risk assessments in conjunction with some of the employees who perform the activities. Due to the nature of the activities some of the assessments are quite detailed. The risk assessments are readily available for any employee wishing to look at them. It has been suggested by someone that all relevant employees have to read the assessments and sign that they understand them (this was done at this person’s previous employment) Is this common / good practice? My view is that this is not necessary. This does not appear to be a requirement in the Man Regs AcoP or anywhere else. Some of the control methods from the risk assessments are ‘information and instruction’ eg employees are informed of the hazards and the safe working method. Employees sign that they have received this information / instruction. This is in line with the Man Regs ACoP (para 63) which states the risk assessment will help identify the information which has to be provided under specific regulations as well as any further risks to employees' health & safety. It goes further, saying relevant information on risks and on preventive and protective measures will be limited to what people need to know to ensure their (and others’) health & safety. Therefore my approach seems okay rather than getting people to read and understand detailed risk assessments that a substantial part will have little relevance to them. Comments are most welcome.
colinreeves  
#2 Posted : 09 January 2013 14:04:41(UTC)
Rank: Super forum user
colinreeves

I had a long talk with my regulator a few years ago about employees signing to say that they had read and understood the Safety Management Manual. His advice was that this was, at best, not required. He recommended removing the signing sheet. I would suggest the same with risk assessments, unless they are very basic and simple. At the end of the day, the risk assessment is a means to prepare a safe system of work - this is the important thing, not how you got there. My own views ....
A Kurdziel  
#3 Posted : 09 January 2013 14:09:38(UTC)
Rank: Super forum user
A Kurdziel

We do get them to sign off the risk assessment (we are basically a lab based organisation and the staff need to understand what they are doing in detail). We are under no illusion that they read the assessment in detail and retain every single point in it. But we know at least that they have seen it and cannot pretend that it is figment of someone’s imagination. And as the have supposedly read it, when we audit the processes there should be no problems in us asking them questions about the work such as:” what sort of gloves should you be wearing for this job?” If they don’t know all we have to do is to tell them “read the assessments again!”
Zimmy  
#4 Posted : 09 January 2013 14:21:23(UTC)
Rank: Super forum user
Zimmy

If the person does not understand the risk assessment then perhaps they won't appreciate the risks? If they don't appreciate the risks and the method of reducing the risks then they should not be allowed to continue? Otherwise what is the point of the RA? It follows then that there would be a breakdown in the safe system of work somewhere along the line.
Azza  
#5 Posted : 09 January 2013 14:31:32(UTC)
Rank: Forum user
Azza

If you get employees to sign the R/A for understanding then isnt that a form of training? If so why not go to the next level and have a safe system of work which can demonstrate understanding of the risks through a small competency test?
Gunner1  
#6 Posted : 09 January 2013 14:31:36(UTC)
Rank: Forum user
Gunner1

Taking account of the compensation culture getting staff to sign they have recieved H&S Training / have read and understand RA's etc. is belt and braces really.
Seabee81  
#7 Posted : 09 January 2013 14:39:20(UTC)
Rank: Forum user
Seabee81

I usually put the relevant details from the RA into a tool box talk, with a reference to the RA number and get them to sign that
Ron Hunter  
#8 Posted : 09 January 2013 14:40:42(UTC)
Rank: Super forum user
Ron Hunter

This issue crops up frequently and tends to attract polarised views. My own view is that the "recieved and understood" signature approach is rather pointless. It quickly degenerates to a meaningless list of signatures. Information, Instruction, Training. List of attendance at toolbox talks, briefings, formal training. Where it is important that information is understood, retained and followed then it must be supervised, monitored, reviewed and refreshed. There are instances where employees will directly access a "RAMS" document (Lab Work SOPs, Permit Systems and the like). In most instance, I would suggest there is no real need for the employee to see the R/A, which is essentially the management tool to confirm the SSoW.
Gunner1  
#9 Posted : 09 January 2013 14:46:23(UTC)
Rank: Forum user
Gunner1

Verification - a word to ponder on.
Zimmy  
#10 Posted : 09 January 2013 15:15:05(UTC)
Rank: Super forum user
Zimmy

I explain the RA to our chaps. It allows them to follow my thoughts and they can contribute to it if necessary as I may well miss something. We tend to involve our people. We're a smallish firm so I guess that helps
Chris Armstrong  
#11 Posted : 09 January 2013 19:45:20(UTC)
Rank: New forum user
Chris Armstrong

Many thanks for all your views, some interesting points raised
ExDeeps  
#12 Posted : 09 January 2013 21:06:34(UTC)
Rank: Super forum user
ExDeeps

Hi, Just to give my experience. Signing to record seeing/understanding RA's was suggested at one point at my current site. The general feeling from the guys was "you only want my signature so when it goes wrong you can use it against me in a disciplinary". A very surprising reaction from my point of view but strongly held by all which revealed a deeply held suspicion about the motives of managers despite a superb safety record and industrial relations in general. But then it's just the way some sites roll I guess, Jim
Ron Hunter  
#13 Posted : 09 January 2013 22:02:07(UTC)
Rank: Super forum user
Ron Hunter

Not uncommon in my experience, Exdeeps. Interested to know if your managers had a convincing counter-argument for that?
Garfield Esq  
#14 Posted : 09 January 2013 22:34:32(UTC)
Rank: Super forum user
Garfield Esq

Chris Armstrong wrote:
Over the last few years, I have carried out various risk assessments in conjunction with some of the employees who perform the activities. Due to the nature of the activities some of the assessments are quite detailed. The risk assessments are readily available for any employee wishing to look at them. It has been suggested by someone that all relevant employees have to read the assessments and sign that they understand them (this was done at this person’s previous employment) Is this common / good practice? My view is that this is not necessary. This does not appear to be a requirement in the Man Regs AcoP or anywhere else. Some of the control methods from the risk assessments are ‘information and instruction’ eg employees are informed of the hazards and the safe working method. Employees sign that they have received this information / instruction. This is in line with the Man Regs ACoP (para 63) which states the risk assessment will help identify the information which has to be provided under specific regulations as well as any further risks to employees' health & safety. It goes further, saying relevant information on risks and on preventive and protective measures will be limited to what people need to know to ensure their (and others’) health & safety. Therefore my approach seems okay rather than getting people to read and understand detailed risk assessments that a substantial part will have little relevance to them. Comments are most welcome. [I can't see any significant benefit as employees undertaking the task should ideally be consulted during the RA process thus negating the need to sign something that they partially created. In reality, not every individual employee can be involved all the time, hence the legal requirement for employers to provide employees with 'comprehensible and relevant information' on risks, as well as the controls. SSoW don't necessarily ID the risks, therefore it would certainly be appropriate for staff to have easy access to RAs for review when/if required. I quite like the idea of incorporating a SSoW into the RA document which I have seen to be done effectively many times – nice clean links… I don't agree with your comment "substantial part will have little relevance to them" perhaps you could expand on this as I am probably missing something in your methodology? Perhaps not clearly defined in the 'regs', however the participation and consultation of employees in risk assessment is a mandatory part of OHSAS 18001:2007, albeit at an 'appropriate' level. Not quite convinced at Ron Hunter's comment "I would suggest there is no real need for the employee to see the R/A, which is essentially the management tool to confirm the SSoW" as this would potentially break the link described above and perhaps lead to NCRs if certified to OHSAS and/or legal breach of Reg 10...although the latter would be unlikely, unless there was a clear link to an incident/accident caused by lack of communication. As is said by many, just thoughts]
JohnW  
#15 Posted : 09 January 2013 22:59:13(UTC)
Rank: Super forum user
JohnW

No offence meant Garfield, but don't you feel the need to re-post your message and sort out the quotes so we can readily see what YOU said. <thumbs-up emoticon - if we had one> <maybe I'm reading this forum too late in the evening emoticon - if we had one>
Ron Hunter  
#16 Posted : 09 January 2013 23:12:05(UTC)
Rank: Super forum user
Ron Hunter

My point, garfield esq (if I might clarify--and yes your post was a bit of a slog!) is that the employer complies with MHSWR 10 by providing comprehensible (stress on that word) information, instruction and training in various appropriate ways - not by asking each and every employee to hope to comprehend a potentially baffling risk assessment. The flaw in this approach becomes more apparent when we consider risk areas such as COSHH, noise, hand-arm and whole body vibration, etc. The "Assessment" may on occassion constitute a mass of mathematical gobbledy-gook to the average employee (and if we're being honest, sometimes the manager too). Is it perhaps these well-intended audit compliance issues you mention that actually encourage and cause employers to default to this 'sign-off' approach? It may well readily serve the audit and satisfy the auditor, but wouldn't last 10 seconds in a Court of Law. We also seem to differ on the term SSoW. I would take your context to mean "method statement" (and thus the concept of a useful and compact "RAMS" document for some specialist and safety-critical situations). I recall Alan St John Holt used to provide a definition of the all-encompassing term "safe system of work" in his excellent 'Principles' publication. Alas, I don't have a copy to hand.
will1977  
#17 Posted : 10 January 2013 08:36:18(UTC)
Rank: Forum user
will1977

Good Morning, When I started in my current position we had poor perception, evidence of claims and limited H&S structure within the business. We were subjected to insurance audits, and HSE recomendations (not enforcement) As part of the training programme I involved all personel in Risk Assessment, Isolation Procedures, Safe System of Work, maintenance and training procedures. Collectively we all agreed that it would be wise to have sign sheets as proof of involvment and understanding. We make it very clear to all that if there is any concern they m ust not sign off until the issue is remedied or explained. This is after all proof of consultation. Many Thanks Will
Kate  
#18 Posted : 10 January 2013 08:37:23(UTC)
Rank: Super forum user
Kate

'Participation and consultation' (which has been given in this thread as a justification for this practice) means being involved in either completing or reviewing the risk assessment - not signing afterwards to say you have read and understood it. Saying you have read and understood it doesn't mean you have contributed to it or have agreed it is right, and so isn't participation or consultation at all. Information should be conveyed in an easily comprehensible and accessible way that is suited to the needs of the people receiving it. A typical risk assessment document with its mass of obscure-looking information about how the risk level has been derived isn't usually the best way to convey the crucial information for the person doing the job of what the risks are and what precautions to take. A summary of the relevant parts of the risk assessment is much better. That can easily be incorporated in a document that goes by the name of a safe system of work or a procedure or a method statement or a work instruction.
Kate  
#19 Posted : 10 January 2013 08:41:15(UTC)
Rank: Super forum user
Kate

Will, I do agree that if they are not to sign it until they are happy with it, it is evidence of consultation. But doesn't that lead to problems if someone resolutely refuses to sign it on the grounds that they genuinely disagree with it?
Invictus  
#20 Posted : 10 January 2013 08:46:54(UTC)
Rank: Super forum user
Invictus

What about people who can't read or understand the R/A do you make allowances for them. I worked for about 10 years with a colleague who sat reading the paper every morning, had books with him for breaks etc. and years after we stopped working together he confided that he couldn't read, he went through the motions to hide the fact. I know we have moved on in that department but people still don't want everyone to know.
B.Bruce  
#21 Posted : 10 January 2013 09:12:27(UTC)
Rank: Forum user
B.Bruce

ron hunter wrote:
Is it perhaps these well-intended audit compliance issues you mention that actually encourage and cause employers to default to this 'sign-off' approach? It may well readily serve the audit and satisfy the auditor, but wouldn't last 10 seconds in a Court of Law. quote] I dont agree Ron (and others). How else do you prove your employee has been given adequate information on hazards and controls? Of course, there is a program of TBT's then this would also help prove due diligence, and this is something I am working on this year. When I joined my company there was nothing - no risk assessments, little attention paid to safe working practices, and as a result a relatively strong claims culture. I introduced a program to provide information by means of a risk assessment which are signed off by employees, along with SSoW which is also signed. The R/A and SSoW were devised and reviewed by myself and a group of competent employees. Every employee was assessed via a competency assessment by the same trained and competent persons. Importantly, this program has led to a reduction in the number of accidents onsite, helped improve quality (SSoW/SOPs) and helped instill a more positive culture amongst staff. Afterall, isnt this is why we are hear, to help identify gaps in safety management and introduce effective programs to deal with them? Yes, there are the odd few who feel that signing a piece of paper is only 'assisting' the employer when it comes to the discipilnary process. Well, im sorry, but when companies are faced with increasing insurance costs becuase of a largely undeserved claims culture then something has to give. I would sooner put up with slight negativity from a small number of staff. I have been asked many times by ambulance chasing lawyers to prove an employee has read and understood his risk assessments. Without an employees how else can you prove it?
KAJ Safe  
#22 Posted : 10 January 2013 11:11:11(UTC)
Rank: Forum user
KAJ Safe

I present the RA and safe system to the workers at the same time. I also ask them to sign them off as being read. This has helped in any claim when providing evidence of training etc.
SP900308  
#23 Posted : 10 January 2013 11:41:32(UTC)
Rank: Super forum user
SP900308

'I recall Alan St John Holt used to provide a definition of the all-encompassing term "safe system of work" in his excellent 'Principles' publication' Extract from Principles of Health and Safety At Work, Allan St John Holt (fifth edition revised - 2000): 'A safe system of work is a formal procedure which results from a systematic examination of a task in order to identify all the hazards and assess the risks, and which identifies safe methods of work to ensure that the hazards are eliminated or the remaining risks are minimised'
Ron Hunter  
#24 Posted : 10 January 2013 13:28:48(UTC)
Rank: Super forum user
Ron Hunter

Thanks for posting that definition SP. SSoW is a term we all use, but that's the only place I ever recall seeing the term defined. I wonder if that term has been used in or was established from case law?
damelcfc  
#25 Posted : 10 January 2013 13:50:47(UTC)
Rank: Super forum user
damelcfc

Good debate this one. What I'd like to do and what I actually do are different things if I'm honest on this one currently but from experience at another role in particular in defence of civil claims the Insurance Inspector would ask for ' the sheet with the signature on it proving that the RA had been shown to the claimant' - If I could not produce said piece of paper regardless of all other parts of the disclosure pack he was extremely unlikely to want to defend the case and would immediately switch to 'settle on best terms mode' - I know, I know, I know but that's my personal experience.
lisar  
#26 Posted : 10 January 2013 16:36:31(UTC)
Rank: Forum user
lisar

When I asked my insurers if the signatures on the SSOWs would suffice instead of employees trawling through the risk assesments, I couldnt get a straight answer from them. However the SSOW does pick the bones from the risk assessment.
Garfield Esq  
#27 Posted : 10 January 2013 17:38:37(UTC)
Rank: Super forum user
Garfield Esq

ron hunter wrote:
My point, garfield esq (if I might clarify--and yes your post was a bit of a slog!) is that the employer complies with MHSWR 10 by providing comprehensible (stress on that word) information, instruction and training in various appropriate ways - not by asking each and every employee to hope to comprehend a potentially baffling risk assessment. The flaw in this approach becomes more apparent when we consider risk areas such as COSHH, noise, hand-arm and whole body vibration, etc. The "Assessment" may on occassion constitute a mass of mathematical gobbledy-gook to the average employee (and if we're being honest, sometimes the manager too). Is it perhaps these well-intended audit compliance issues you mention that actually encourage and cause employers to default to this 'sign-off' approach? It may well readily serve the audit and satisfy the auditor, but wouldn't last 10 seconds in a Court of Law. We also seem to differ on the term SSoW. I would take your context to mean "method statement" (and thus the concept of a useful and compact "RAMS" document for some specialist and safety-critical situations). I recall Alan St John Holt used to provide a definition of the all-encompassing term "safe system of work" in his excellent 'Principles' publication. Alas, I don't have a copy to hand.

It was late and yes my response was tiresome. I agree some RAs are baffling, however I strongly promote the idea of keeping them succinct, relevant and practical. Should staff be involved via effective 'Participation & Consultation' then I see no need for any signatures, which is what I said, only in a protracted late night drawl  Unfortunately in some cases, I agree that you’re right Mr Hunter, re following quote: "Is it perhaps these well-intended audit compliance issues you mention that actually encourage and cause employers to default to this 'sign-off' approach? It may well readily serve the audit and satisfy the auditor, but wouldn't last 10 seconds in a Court of Law" That’s sounds bad but fear not, this is not a swipe at you, rather a general comment on some safety managers perception of the requirements of OHSAS (and HSAWA if I remember – to a fashion?). That’s the problem with non-prescriptive standards and overzealous managers / consultants. The only thing that would satisfy me personally during an assessment would be if staff were aware of the risks, performance was good and improving and work was being done safely...end of. Auditors or Insurance bods that fidget about looking for everyone in the company to have signed RAs would be frankly wasting their time and the clients. Lastly and sigh of relief! SSoW / Method Statements / JSAs / SOPs / Safety Cases blah blah - All the same, all different, we have all heard it before, I would die a thousand times rather than enter that one. I gave up on that semantical (is that a word?) drama years ago, suffice to say that as long as the risks have been assessed and ‘something’ is in place to ensure safe working practices are maintained and assured, then crack on! Farewell for now!
Ron Hunter  
#28 Posted : 10 January 2013 23:54:31(UTC)
Rank: Super forum user
Ron Hunter

Thanks for coming back with that garfield. We're not so different in our views.
RayRapp  
#29 Posted : 11 January 2013 08:58:51(UTC)
Rank: Super forum user
RayRapp

There was a very similar debate only last year. The general consensus if I recall correctly was that there is little point in getting employees to read and acknowledge RAs because they are in effect a management tool in order to provide a SSoW. Many RAs are not end-user friendly...even I struggle to understand some more complex RAs, so what chance have employees! Some have mentioned the need for employees to sign RAs in order to defend any civil claim. Surely, as practitioners we are better than that. We should not be adopting poor or unnecessary practices in order to pander to ambulance chasers either.
IanF  
#30 Posted : 11 January 2013 09:12:31(UTC)
Rank: Forum user
IanF

Apologies if this is already covered, but just wanted to add my views from my organisation, and I haven't time to read all the responses in detail (at the moment). My Department uses generic risk assessments for various tasks, but as we all know, these have to be tailored to the individual. Each generic asks the line manager to sign, not the individual - however, this doesn't stop managers from simply passing a set of generics to an overworked staff member and saying, 'read these, sign them, and if you have any questions, ask me'. Surprise, surprise - they either don't recall getting them, sign them without reading them (or don't understand them) or I suspect simply just file them and they aren't chased for them. Whilst this is not set out in legislation, I try to encourage that the line manager and staff member sit down together and discuss which assessments apply, agree any changes to the listed controls and hazards; and make sure they are reviewed regularly. I believe this is the best way to have the process accepted, as it encourages the staff member's input. In a roundabout way, I don't see any value in getting the staff member to sign (at least in the process I have explained), as it holds no real value that they have understood the assessments.
Jake  
#31 Posted : 11 January 2013 09:15:55(UTC)
Rank: Super forum user
Jake

RayRapp wrote:
There was a very similar debate only last year. The general consensus if I recall correctly was that there is little point in getting employees to read and acknowledge RAs because they are in effect a management tool in order to provide a SSoW. Many RAs are not end-user friendly...even I struggle to understand some more complex RAs, so what chance have employees! Some have mentioned the need for employees to sign RAs in order to defend any civil claim. Surely, as practitioners we are better than that. We should not be adopting poor or unnecessary practices in order to pander to ambulance chasers either.
Ray totally agree re the use of risk assessment. We do however as part of our departments role identify ways for the business to better defend claims (it's part of the reason I'm employed!) (this is in addition to working to prevent such claims in the first place, clearly). Signing off risk assessments is not one of those controls.
Damelcfc wrote:
Good debate this one. What I'd like to do and what I actually do are different things if I'm honest on this one currently but from experience at another role in particular in defence of civil claims the Insurance Inspector would ask for ' the sheet with the signature on it proving that the RA had been shown to the claimant' - If I could not produce said piece of paper regardless of all other parts of the disclosure pack he was extremely unlikely to want to defend the case and would immediately switch to 'settle on best terms mode' - I know, I know, I know but that's my personal experience.
I'm surprised by this, working for a retailer as you can imagine we get enough EL and PL claims. The law doesn’t require people to sign risk assessments, and the significant findings form the procedures and associated training. We provide RA, procedure and signed training document. One only needs to cross reference all three to identify that the important (significant) information in the risk assessments has been communicated, via the training documents and monitoring procedures etc. Adopting this stance we are able to provide information to staff at all levels in an easily digestible, non-technical manner.
damelcfc  
#32 Posted : 11 January 2013 09:39:45(UTC)
Rank: Super forum user
damelcfc

I too was very surprised as I do indeed as has been mentioned know better than this but this rather large insurer (beginning with Z) clearly had their own ideas on its value. Personally I prefer the SOP to link (and at pertinent points reference) to the RA and obtain a signature against the SOP and ideally some sort of validation where appropriate for more complex activities - this can be great for showing not only that someone has read something but goes the extra yard to show actual understanding. It's not always appropriate for validation and this in fact can be the hardest part of all but it is worth its weight in gold if you can reach this utopia. People quite often sign things and don't actually read/digest a word of it and some will try and exploit this. An example of what I mean that we could all relate to is installing a new program on your PC - how many of you have really read and understood the End User License Agreement (EULA) word for word and not actually just scrolled to the bottom and clicked continue? If you were examined on the contents of said EULA in the next half hour for your last new program would you get your certificate?!
Jake  
#33 Posted : 11 January 2013 10:28:47(UTC)
Rank: Super forum user
Jake

damelcfc wrote:
I too was very surprised as I do indeed as has been mentioned know better than this but this rather large insurer (beginning with Z) clearly had their own ideas on its value.
A very strange stance, fortunately we don't use that company for insurance related business! It maybe related to the fact you are a higher risk business than us, still I would look to change insurer!
Users browsing this topic
Guest
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.