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achrn  
#1 Posted : 17 December 2014 11:22:57(UTC)
Rank: Super forum user
achrn

Turban-wearing Sikhs are exempt from wearing hard-hats on construction sites, but the exemption that grants that (section 11 of the Employment Act 1989: "Any requirement to wear a safety helmet which …would, by virtue of any statutory provision or rule of law, be imposed on a Sikh who is on a construction site shall not apply to him at any time when he is wearing a turban") does not apply to other locations.

There was a consultation at the start of the year about extending this exemption - http://www.hse.gov.uk/co.../condocs/sikh-letter.htm - but I have not found what (if anything) happened following the consultation - does anyone know? Has there been any change to the exemption?
Isaac J Threadbare  
#2 Posted : 17 December 2014 17:29:46(UTC)
Rank: Forum user
Isaac J Threadbare

Putting religion to one side.

I have yet to find out the impact protection afforded by turbans in relation to the standard hard-hat.

Are follows of the Sikh faith statically less likely to suffer head injures?

Please note: The is no malicious undercurrent or over tones in this posting

firesafety101  
#3 Posted : 17 December 2014 18:56:57(UTC)
Rank: Super forum user
firesafety101

Simple fact is you cannot force a Sikh to remove the turban.

I suppose if you can get a hard hat to fit over/around a turban effectively you could ask the question but Equality Act may kick on?

Risk assessments may require such people to work outside working at height zones?
johnmurray  
#4 Posted : 17 December 2014 20:26:34(UTC)
Rank: Super forum user
johnmurray

"Should a Sikh wearing a turban be injured on a construction site, liability
for injuries is restricted to the injuries that would have been sustained if
the Sikh had been wearing a safety helmet"

http://www.equalityhuman...faith_guidance_final.pdf
achrn  
#5 Posted : 18 December 2014 09:06:02(UTC)
Rank: Super forum user
achrn

FireSafety101 wrote:
Simple fact is you cannot force a Sikh to remove the turban.

I suppose if you can get a hard hat to fit over/around a turban effectively you could ask the question but Equality Act may kick on?

Risk assessments may require such people to work outside working at height zones?


Yes, this is what HSE suggest.

http://www.hse.gov.uk/fo...ernalops/og/og-00003.htm

Basically it says the employer needs to have controls in place so that Sikhs don't need to wear hard-hats. I think there's some double-think there - if you can put in controls so Sikhs don't need helmets, then why are the controls not in place so non-Sikhs don't need helmets? The implication seems to be that it's OK to rely on PPE for non-Sikhs, which to my mind contradicts the general mantra that PPE is the last resort.

If the controls are such that hard-hats are still needed, the guidance talks about either "suitability of the head protection provided if turban-wearing Sikhs are prepared voluntarily to wear it", which I think means turban-compatible hard-hats, or "re-deploying them away from exposure to those residual risks, and/or preventing them from entering areas of such risk if they are not prepared to wear head protection."

Most of our work is construction sites, so we are covered by teh exemption. However, we sometimes do work pre-construction (inspection and surveys) in areas that do have hard-hat requirement, but aren't (yet) a construction site. For these, we don't send any of our Sikhs.

However, there was the consultation about extending the exemption that applies to construction to cover a wider range of situations, which would make the process easier - you could then say to your Sikhs that it's their choice, and they would then be liable for consequences (as highlighted by JohnMurray - a Sikh not wearing a hard-hat can't hold the employer liable for the consequences). At the moment, I think there's a risk of being stuck between conflicting requirements - if you let the Sikh not wear a hard-hat and they are injured HSE will argue that's a failure of your controls, but if you don't let the Sikh do that element of work there's a risk that they'll argue that's religious discrimination (if they perceive the redeployment to be a less good role).
Isaac J Threadbare  
#6 Posted : 18 December 2014 09:17:44(UTC)
Rank: Forum user
Isaac J Threadbare

As a non religious person I find the whole thing quite strange to be honest. It should be rather straight forward. If a hard hat needs to be worn then wear one.

Taking the point to its obvious conclusion then, the notices outside some building sites should not read

'No Hard hat, boots of hi vis NO JOB' as this would not include Sikhs but would discriminate against a non religious person like myself. So I would not have a choice as to wear one or not. Don't seem right to me.
kevkel  
#7 Posted : 18 December 2014 10:42:32(UTC)
Rank: Super forum user
kevkel

If my memory serves me correctly I think Trotters Independent Traders had a solution for this.
jay  
#8 Posted : 18 December 2014 10:50:06(UTC)
Rank: Super forum user
jay

All the references pre-date the HSE consultation letter.

The formal exemption, apparently based on the HSE Consultation is now a part of the Deregulation Bill which is at the Committee Stage.

http://www.publications....2014-2015/0058/15058.pdf

http://www.theyworkforyo...ill/17-0_2014-03-25a.9.0

Sikhs, not only in UK, but in various parts of the world have "dispensations" regarding their turbans. The right or wrong about this is a matter of opinion.

achrn  
#9 Posted : 18 December 2014 11:00:47(UTC)
Rank: Super forum user
achrn

Jay wrote:

The formal exemption, apparently based on the HSE Consultation is now a part of the Deregulation Bill which is at the Committee Stage.


Thanks Jay, that's what I was looking for - some outcome from the consultation.
johnmurray  
#10 Posted : 18 December 2014 12:37:50(UTC)
Rank: Super forum user
johnmurray

Hmmmm....not so much an exemption, as an extension.

"The Government introduced an amendment, new clause 18, (clause 5 of the current Bill) to
extend current exemptions for turban-wearing Sikhs on the wearing of safety helmets in
workplaces. Currently, section 11 of the Employment Act 1989 (as amended) exempts
turban-wearing Sikhs working on building sites from the requirement to wear safety helmets.
##The effect of the amendment is to extend this current exemption to other workplaces, with
some exceptions## It would also extend the existing limited liability provisions of the exemption to those persons, such as employers, who hold a legal requirement in respect of the wearing,
provision or maintenance of safety helmets by exempted individuals"

"The amendment was agreed without a vote"

http://www.parliament.uk...efing-papers/rp14-28.pdf
achrn  
#11 Posted : 18 December 2014 13:06:52(UTC)
Rank: Super forum user
achrn

John, I don't understand your comment.

It is an exemption. There has long been an exemption for turban-wearing Sikhs on construction sites. It is now proposed to extend the exemption to all workplaces.

Why do you say it is not an exemption? It's not a fundamentally new exemption, but it is an exemption (and will be new in some workplaces).

MrsBlue  
#12 Posted : 18 December 2014 13:18:48(UTC)
Rank: Guest
Guest

So how do you control hazards / risks which may affect turban wearing employees.

What are the control measures? and what would happen if a turban wearing employee suffered an accident which otherwise would be preventable (or the outcome less servere) by the wearing of a hard hat.

Is there any case law where a turban wearing worker has sued their employer following an accident?

And finally do turban wearing employees accept the increased risks and do you make them sign a declaration off acceptance of this increased risk>
achrn  
#13 Posted : 18 December 2014 13:25:16(UTC)
Rank: Super forum user
achrn

MrsBlue wrote:

So how do you control hazards / risks which may affect turban wearing employees.

What are the control measures? and what would happen if a turban wearing employee suffered an accident which otherwise would be preventable (or the outcome less servere) by the wearing of a hard hat.


That is explicitly covered in statute (and referenced in the thread). That aspect is nothing new - it's been law since 1989.

"If a Sikh who is on a construction site—
(a)does not comply with any requirement to wear a safety helmet, being a requirement which for the time being does not apply to him by virtue of subsection (1), and
(b)in consequence of any act or omission of some other person sustains any injury, loss or damage which is to any extent attributable to the fact that he is not wearing a safety helmet in compliance with the requirement,that other person shall, if liable to the Sikh in tort (or, in Scotland, in an action for reparation), be so liable only to the extent that injury, loss or damage would have been sustained by the Sikh even if he had been wearing a safety helmet in compliance with the requirement."

MrsBlue wrote:

Is there any case law where a turban wearing worker has sued their employer following an accident?

And finally do turban wearing employees accept the increased risks and do you make them sign a declaration off acceptance of this increased risk>


So I don't think either opf those questions are relevant - it's explicitly addressed in the statute.
MrsBlue  
#14 Posted : 18 December 2014 13:30:01(UTC)
Rank: Guest
Guest

Thanks achrn - good concise answer and yes it makes the other questions irrelevant.
peter gotch  
#15 Posted : 18 December 2014 13:45:08(UTC)
Rank: Super forum user
peter gotch

Here's one I wrote in 2000, so it is likely that the website references have been overtaken....

Exclusion of a turbaned Sikh from a work area may constitute racial discrimination, and therefore not be reasonably practicable. See the following (edited) extract from the UK Commission for Racial Equality Code of Practice on Employment

(Incidentally other Commonwealth countries have come to similar conclusions).......

".........Where employees have cultural and religious needs which conflict with work requirements, it is recommended that employers consider whether it is reasonably practicable to adapt these requirements to enable such needs to be met."

For example, it is recommended that they should not refuse employment to a turbanned Sikh because he could not comply with unjustifiable uniform requirements

S.12 of the Employment Act provides that if, despite S.11, an employer requires a turban wearing Sikh to wear other protective head gear such as a safety helmet on a construction site, the employer will not be able to argue that this is a justifiable requirement in any proceedings under the Race Relations Act (now the Employment Act) to determine whether or not it constitutes indirect racial discrimination

Although the Act does not specifically cover religious discrimination, work requirements would generally be unlawful if they have a disproportionately adverse effect on particular racial groups and cannot be shown to be justifiable*.

* (footnote) Genuinely necessary safety requirements may not constitute unlawful discrimination......."

It's a matter of degree of risk, as to what would constitute a reasonable rule.

See extracts from

http://www.austlii.edu.a...scripts/1996/S194/1.html

Canadian case, Ontario Human Rights v Borough of Etobicoke (1982) 132 DLR (3d) 14. was a case involving firemen over 40 where the borough, largely it seems on the basis of anecdotal material that firefighting is a young man's game, had said that firefighters had to retire at 40.

The Canadian Act used the same sort of language as American cases; "bona fide occupational qualification".

It must be related in an objective sense to the performance in that it is reasonable necessary to assure the efficient and economical performance of the job -

The same sort of test was applied in Bhinder's Case which is referred to there.

That was a Sikh case involving the question as to whether a safety helmet had to be worn. The argument was that the Sikh employee who will not wear the safety helmet in the yard is creating risks, and so on.

Again, the approach taken was that one looks at the reasonableness. If the situation is that it is only once in a thousand years that you are going to have an accident where the safety helmet is going to protect him, then it is unreasonable to require him to wear it.

If he is in a position where quite regularly heavy objects fall on one's head and there is a serious risk, then it is reasonable to say that a Sikh who will not wear a safety helmet is unable to perform that job.

So it is always a question of degree and looking, on that test, at what is reasonably necessary to assure the economic and efficient performance.

The provisions of this section relating to any discrimination, limitation, specification or preference for a position or employment based on age, sex or marital status do not apply where age, sex or marital status is a bona fide occupational qualification and requirement for the position or employment.

Also UK's leading Trade Union solicitors:

http://www.thompsons.law...uk/ltext/l0100004.htm#12

Is a requirement or condition one with which persons of a racial group 'can comply'? This question commonly arises in racial discrimination cases in respect of Sikh turbans, where there may be an attempt to make it a condition that turbans may not be worn. The courts have interpreted the phrase as meaning 'can comply' in practice rather than meaning can physically comply. A school which refused admission to a Sikh boy because he wore a turban was held to have indirectly discriminated against the racial group to which he belonged. (But see also Justifiability below.)

Disproportionate Impact

Having established that the employer has applied a requirement or condition to the employee, the employee must establish that that requirement or condition has a disproportionate adverse impact on persons of the same racial group as him or her; that the proportions of the same racial group who can comply with the requirement or condition is considerably smaller than the proportion of persons of another racial group who can comply.

What is or is not a considerably smaller proportion is a matter for the Employment Tribunal. Considerably smaller are ordinary words in common usage.

Justifiability

The next requirement for indirect discrimination, having shown a discriminatory condition which has a disproportionate impact and which is to the detriment of the person complaining, is that the discriminatory action cannot be justified irrespective of the racial origins of the complainant. The applicant does not have to show that the condition cannot be justified - that is assumed - but the employer may seek to prove that the condition is justified.

Sometimes a condtion, which on the face of it is discriminatory, can be justified by the employer. The wearing of a turban may be incompatible with a safety requirement that the individual should wear a safety helmet. It is for the court to strike a balance between the discriminatory effect of the requirement or condition and the reasonable needs of the person who applies it (1) though Parliament has now stepped in to allow Sikhs not to wear helmets on building sites.

A rule forbidding beards at work, which is indirectly discriminatory to Sikhs, is justified as a matter of public health in the context of food preparation or manufacture. (2)

(1) Hampson v. Department of Education & Science [1989] IRLR 69 CA.
(2) Singh v Rowntree Mackintosh Ltd [1979] ICR 554, [1979] IRLR 199
Stern  
#16 Posted : 19 December 2014 14:49:32(UTC)
Rank: Super forum user
Stern

JSP (one of the major PPE manufacturers) had an open day a few years back which involved a tour of their factory out in the Oxfordshire countryside.

As part of the tour we saw hard hats being tested to ensure they comply with the relevant standards. This involves putting a hat on a mannequins head, winching up a weight on a kind of guillotine contraption, dropping it onto the head/hat and measuring the result.

A few years before they told us that they tested a turban. They got a load of fake hair (Sikhs generally have A LOT of hair under their turbans) and had a Sikh man tie it all up and wrap it in a turban as he normally would. They then tested it and the results were surprising....

With the blunt weight it performed better in "cushioning the blow" than a standard EN397 hardhat. However, with the pointed weight it didn't perform well at all.

Bit of Friday afternoon useless information there for you all! Right, off to the pub!
Route66  
#17 Posted : 05 October 2015 16:01:47(UTC)
Rank: Forum user
Route66

Just to update on this. Many people have focused on the Deregulation Bill and it's exemption of certain self Employed persons from any H&S compliance.

However, s 6 of the Bill (s7 for NI) has broadened the exemption from just Construction to essentially any workplace situation were other workers are being told to wear standard 'Safety Helmets'.

http://www.hse.gov.uk/co...segen&cr=1/05-oct-15

However, if you're a profession where a more robust helmet is required for personal safety, i.e. Fire Service, Riot Police, Armed Forces (but seemingly not Bank/Cash deliveries...) then when actively engaged in those duties, or training for them, you're NOT exempt....
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