http://www.hse.gov.uk/risk/news.htm

Above referenced from recent HSE Bulletin. HSE purport to be seeking views but do not provide contact details for feedback.

Personally, I'm concerned the proposed text suggests that related documents alone constitute a suitable and sufficient assessment.

HSE seem to suggest that the risk assessment process itself, which fundamentally addresses the question "Am I doing enough, or do I need to do more" need not be recorded - an approach which would drastically reduce the possibility of any periodic proactive review of effectiveness of controls?

There was a consultation on this Ron, but it ended about a month ago and it was not very well advertised. I stumbled across it on the final day! From memory it was not about removing the requirement for documentation (where there are 5 or more employees) but more a suggestion that inspectors needed to be more flexible, so if you had a safe working procedure that the inspector felt showed you had considered all the hazards and risk's adequatly then that should be enough. (Still cannot find spell check have we lost it?)

I understand and agree in principle with your comments. A bit disappointing to learn that there was a past consultation when I've only just received word of it via the HSE subscription bulletin service.

Risk Assessments should 'point' to supporting records and resources, and I'm sure those of us in the profession grasp the intended context - but what of the small to medium enterprise reading that page?

I fear the wording on the referenced hse page could set things back decades. e.g.

"Your risk assessment can be part of an existing business document, such as:.........safety data sheets".

Noooooooooo!

I think the wording is back-to -front.  Maybe better to have stated: "Existing business documents may be referenced in and help to inform your Risk Assessment." ?

What I think Ron is concerned about (and I am not overly impressed with) is the tone of the HSE pages, rather than the guidance itself.  It implies that risk assessment is simple and straightforward and is just a case of collating information from SDS or other documents.  Risk assessment is first and foremost, a thinking process, where you look at what you are doing-not what you say or think you are doing but what you are actually doing and deciding whether it is being done in a safe manner.

See this document for more details:  https://osha.europa.eu/en/publications/e-facts/e-fact32/view

I detect an element of dumbing down creeping into health and safety management. Okay, I have argued there are too many bureacratic and onerous practices...but as my dear old dad would say, there is a difference between scratching your bum and ripping it to shreds.

It would be interesting to see if a case got to court and what a lawyer would make of a set of documents which were being passed off as a risk assessment - I think we know the answer to that one!

Agree with Ron the wording is the wrong way around on web site (attachment ok), and should be documents such as……. Can be part of your assessment.

I can imagine smaller company’s just reading the web site and not the attachment, and getting this wrong. When I first read it I thought the same as Ron, then I went back and read the attachment at a later date, which was ok.

Ok I know I have gone off topic

I agree supporting documents cannot replace suitable and efficient risk assessment. However, it is only because we have split documents into groups such as 'risk assessment record' and 'supporting documentation'. Every situation should be looked at differently. If you create a procedure with the mind set of assessing the risks as a step then you will find it is no longer a supporting document but the main document and in some cases the only document. A procedure must include the required control measure so you are ready half way there. It is just matter of working in the other apsects of a risk assessment.

I'm not saying this approach works for all situations but it does with some situations. I should note to enable the procedure to include the risk assessment the procedure format also has to change.

Originally Posted by: markwmansell

Hi Ron,

I feel you are missing the points of the other posters. If a method statement covers all of the hazards, risks and controls then why create a specific document called a 'risk assessment' this would just be gold plating and a waste or resources. Also, workers are more likey to read safe systems of work if they are kept to a minimum. Furthermore, it is not a 'risk assessment record' that prevents impacts it is the controls which would be captured within the method statement or other safe systems of work. Additionally, I have successfully used matrixes or maps to communicate the content traditionally recorded in a 'risk assessment record'.

If you want a document that tells workers about relevant documents then create a list. I agree risk assessment records can be useful in some situations but in other can be more useful if incorporated into other forms of safe systems of work.

In summary flexibility and adaptability is key to successful environmental, safety and health management.

 

 

Mark,

As someone who previously worked for a large UK main contractor and vetted 100's of sets of RAMS, I'm 100% with you on this. I now work for a contractor and have recently overhauled the old RA / MS / COSHH documents and, to be honest, with the way our method statements now work (they detail all the control measures required at each stage of the task) the RA's and COSHH are pretty much just there for the sake of being there.

If, for example, step 3 of my method statement says for a PASMA trained person to build/inspect a tower and step 6 says to lock the wheels and access using the correct ladder then why do i need ANOTHER document called "RA123/4.2016 (Rev A) Using Scaffold Towers" which just says the same things. Same goes with COSHH.

In practice, all they do is turn a small, simple 10 page document into an off putting 30-40 page document. For me, dumbing down isn't always a bad thing.

Let's be honest, how many people really think that anyone has every actually read a RA? A MS maybe, but a RA? I did a test at my last company where i put a completely ridiculous random word in a RA. 2 years later and still nobody had noticed. 

I really don't understand the fuss. The draft guidance still refers to - and talks through, the "5 steps" approach. As others have said, risk assessment is a process, not a document.

Originally Posted by: chris42

Originally Posted by: Stern

recently overhauled the old RA / MS / COSHH documents and, to be honest, with the way our method statements now work (they detail all the control measures required at each stage of the task) the RA's and COSHH are pretty much just there for the sake of being there.

If, for example, step 3 of my method statement says for a PASMA trained person to build/inspect a tower and step 6 says to lock the wheels and access using the correct ladder then why do i need ANOTHER document called "RA123/4.2016 (Rev A) Using Scaffold Towers" which just says the same things. Same goes with COSHH.

Yes but controls noted on a risk assessment are not necessarily only for those at the sharp end working from a method statement. There may be controls regarding purchase or hire etc to ensure the correct standards of equipment and external services are obtained.

Granted, but the duties of those hiring in the equipment are already specified in the roles and responsibilities section of our company health & safety policy. Why do these need to be repeated in a risk assessment?

I'm not arguing against the need for the risk assessment process, i'm just making the point that having a raft of documents titled "risk assessment" ultimately achieves nothing (except adding more paperwork and further alienating those at the sharp end).

If i was to delete all the risk assessments from our company database, would this translate to an increase in the number of accidents? And when all is said and done, isn't this game all about reducing accidents? 

Originally Posted by: biker1

I've always taken the view that there is a logical process to follow, which should start, as appropriate, with a task analysis, then a risk assessment of the process, and then a set of controls to control the risks identified, which you can call a safe system of work, method statement, or whatever. Only this last document needs to be supplied to the people at risk - they don't need to see the risk assessment, this is for the safety professionals to review as necessary. Clearly, if there isn't a risk assessment, and only a procedural document, then things will get missed, as you can't review something that doesn't exist.

As we know there's no right and wrong way to put together a risk assessment/method statement. For some it's RA then MS, whilst for others it's MS then RA. 

Starting at my new company a couple of months back i sat down with some of our supervisors in the first couple of weeks and put together some step-by-step method statements for all the services we provide, based on how the jobs were currently being done. From there, we made a few tweaks and were left with a set of good, solid, easy to follow safe systems of work without the need to actually write a risk assessment. Once that was done, i then spend, on and off, about a fortnight "backing up" what we'd done with an entire database of risk assessment documents.

The issue is that, in the construction industry at least, clients/principal contractors always want to see risk assessments. And, given that there could easily be half a dozen or more risk assessments for each method statement, plus COSHH, the result is that a small simple document becomes a large complex one.

I'm not against the process of risk assessing, I just don't agree with the need to prepare, maintain and provide a database of documents which are just repeating what has already been written elsewhere and (let's be honest) which nobody reads!

Anyone trying to quote reg 3 of the Mgt Regs needs to read the Regulation, and remember the requirement is there "for the purpose of identifying the measures he needs to take to comply with the requirements and prohibitions imposed upon him by or under the relevant statutory provisions and by Part II of the Fire Precautions (Workplace) Regulations 1997. "  

In other words - this reg has nothing to do with identifying, controlling or reducing risks to health and safety.  Which is probably the main reason the misleading ACoP was withdrawn - HSE tried to extend the legal obligation by overegging the pudding...

Personally, I think the new guide to RA is long overdue - but unfortunately, it will carry little weight with inspectors on the ground - or with ambulance chasing legal vultures, or with insurers... 

Originally Posted by: Steve e ashton

Personally, I think the new guide to RA is long overdue - but unfortunately, it will carry little weight with inspectors on the ground 

I beg to differ. ;)

I think proportionality just needs to be remembered here.  For some tasks, for some businesses, not having documents called risk assessments will be great because they've really got it nailed elsewhere.  For others, perhaps larger employers, or for certain high risk industries, that process may really need to be spelt out.  C'mon, we all know that health & safety is never one size fits all....

Although...again...I agree with Ron about MSDS.  The documents supporting a lack of a labelled RA, do need to still effectively fill the void.  I always argue that organisations should proactively 'own' their risks and policy choices by writing about them e.g. could stick it in the h&s policy that you're not going to produce risk assessment documents but then go on to describe the process being used instead.

Interesting discussion. I am very much of HSE's view on this. After all, the regulations say that employers must record the significant findings of their RA, there is no requirement to record the process used to arrive at these findings. I remember back in 92 when the Regs came out being a bit puzzled at the rapidly developing gold-plating that came along, making something I had regarded as very simple into something exremely complex. Don't get me wrong, I'm in favour of risk management (I have been a member of the IRM in the past), but I also don't like paperwork much.

In my view, if you have adequate control measures and ssows etc then you have 'done a risk assessment'; how else would you have chosen the control measures, ssows etc? I used exactly this argument with a fire officer (I know, different law but very closely related); he didn't like the way we had assessed the risk in one of our hospices (previous employer), in fact he said we hadn't done a risk assessment. He then went on to say that the control measures we had implemented had some gaps in them. I pointed out that in order to arrive at the control measures we would have had to have assessed the risk, though I did admit that we had missed a couple of minor points. I won that argument.

There is no need for a document with risk assessment written on it; what's needed is controls and mitigation to keep people safe,

John

"Suitable risk assessments had not been carried out, and the general risk assessment covering roll cages didn’t cover the hazards involved in manoeuvring them on uneven surfaces.

Furthermore, no assessment had been carried out on the manual handling of roll cages"

extract from

http://www.shponline.co.uk/wilko-fined-2-2m-for-horrific-workplace-accident/

Cant help but feel removing detail from a RA is all well and good until something goes wrong. Who would have thought that bumping a trolly cage over a slight step could cause it to tip - the average man on the street?

If you are in IOSH and access to their magazine, the story in there about the chap who had his leg caught in a collapsing trench. I could not get over the statement from the IP. He said he knew not to do it, but he had not been reminded in his daily brief !!!!! Darwin anyone.

If the trolley cage was not included in the RA was it part of the training for staff? I suspect the answer is no to both. A trolley cage loaded with tins of paint (cannot remember the weight but it was substantial) if it should tip over is likely to cause a serious injury - not rocket science.

And the person that wrote that particular RA (if it existed, let alone was trained to all staff) bothered to visit all locations to check the suitability of their generic document at all places of employers business.

Or maybe the assessmemt read do not fill above 50% for load stability - then someone in shipping decided we can save shipping cost if we fill the trolley.

The big message has to be the RA belongs to the business for all employees not just the person at the coal face.

All too often I find myself toe to toe with our transport manager because it is "more cost effective" to make the pallet higher / heavier forgetting that after it exits the truck our employees or our cutoemrs have to deal with it.

I agree with you there Walker, Alot of companies tend to keep things like this Hush Hush, and keep their employees in the dark.  Its all to do with bad management and supervision, the managers don't like to advertise that they perhaps have not been seen to be doing their work correctly.

I've been told several times for companies i've worked for in the past to keep quiet about a particular incident or accident, If i tried to promote the incident in Safety Talks or Bulletins to all staff, then i'm acused of stiring the poop etc. 

Although many businesses have made progress in getting to grips with risk assessment (looking forwards to anticipate and prevent harm before it occurs), many are still failing to gain maximum benefit from their approach to the investigation of accidents and incidents. Consequently, they are still failing to learn vital lessons, which could help them, improve their overall management of health and safety.

You simply cannot work like that or be allowed to ignore advice or recommendations. Perhaps Wilkinsons need to look a bit closer to home and see exactly how their managers and Supervisors deal with accidents and serious incidents at their stores

• Accidents are extremely costly in both human and financial terms but, if investigated correctly, they also represent highly valuable safety learning opportunities.
• Effective accident investigations can provide a 'window on reality' (providing a means of discovering what was really going on).
• All organisations need to develop a strong capability to 'dig deep' following accidents in order to develop a clear understanding of their immediate and underlying causes.
• Good investigations can provide unique opportunities for achieving learning and change in organisations. As well as yielding important lessons which can help prevent recurrence of accidents and incidents, investigation can be a powerful educational experience for those directly involved, for example, by improving understanding of health and safety management principles.