Hello,

I've just been handed the DEF STAN 00-56, and told we need to be compliant to this standard for an upcoming (imminent) audit of our site.

"Prior to the audit they will need to review the documents that set the safety requirements (the SoW and the Equipment Spec(ES)) (where these exist) and the suppliers Safety Management System (SMS) documentation which would generally comprise of:

•  Safety Management Plan (SMP)
• Safety Case Report (SCR)
• Hazard Log (HL)

 I'm not familiar with any of these terms, I just googled SMP and SCR and these seem to be Australian safety terminologies?

We have a health and safety policy in place.

We have risk assessments system and reports in place.

We have COSHH lists and product specs (MSDS's) in place.

We have incident/accident reporting and analysis in place.

These are all the equivalents as far as I can guess. Is this right? How much do I have to change to provide compliance to this standard? How many new documents am I going to have to write?!

Any advice you can give would be helpful as I'm on page 7 of 131 of this standard and it's already melted my brain!

SoW - systems of work = Standard Operating Procedure / Safe System of Work / Process Instruction / Task Briefing

The other items SMP, SCR, HL you have already spotted your equivalents

You possibly need to be prepared to challenge the auditor(s) to justify any Non Conformance Reports they may be thinking of raising.

Just because you don't speak and write in MoD speak does not mean that your systems are deficient.

Any attempt to try and rewrite them at this stage is likely to be counter-productive (unless you have other reason to be improving them!)

I have never heard of DEF STAN 00-56 until I saw this thread. I then, out of curiosity had a look at what was out there about this and I could not believe the amount of technical bumf that it required and I especially felt aggrieved by the use of a bizarre jargon- one thing I read was this line: “The term Hazard Log (which is in the standard) may be seen as misleading since the information stored relates to the entire Safety Programme and covers Accidents, Controls, Risk Evaluation and ALARP justification, as well as data on Hazards.” Which seems  to say that even the people who wrote this standard did not understand what they meant!  Who wrote this and why?

The real question I want to ask is does this actually make things safer?

The documents were written and approved two years ago, and you didn't know this?  Someone didn't do a very good job of embedding these documents into your organisation and communicating their crucial safety requirements and findings to all staff!

No, wait - I've heard of something like this - the job was to write the documents and store them in preparation for audit, was it?

Lets start with the fact the Ministry of Defence have been around for a lot longer than the Health & Safety at Work Act and the HSE - their terminology was concurrent with the time of initial writing and the fact later systems have appeared with different wording is just an unfortunate effect of the evolution of language.

By example what was Defence Standard 51 became "privatised" as BS 5750 in the 1980's - nowadays even the language of that document has changed for the firms who apply BS EN ISO 9001 Quality Management Systems.

MoD standards are written in a particular manner as there is a requirement for repeatability, consistency and reliability from all defence spending.

The MoD also enjoys Crown Privelege

Originally Posted by: Kate

No, wait - I've heard of something like this - the job was to write the documents and store them in preparation for audit, was it?

Exactly this! these documents have been written specifically for this contract and have NEVER been used by the companies, we run to the regular civil HSE standards and these documents haven't even been looked at since they were written, I've now just got to scan through them make sure they are current and then present them at the audit as if it's how we actually run... not what I like to do but as it was a system that was in place before my time and I've only just been told about it and the imminent audit I don't have the time or energy to amalgamate the system into ours in good working order so I think it will just have to be a stand alone paper exercise.

Self, if you want to PM me to discuss - I used to be an MOD safety auditor and may be able to shed some light on thi or at least offer some sympathy..

 The Def stan has been around for ages, its mainly used by the commercial "side" when they are setting up contracts, IIRC there is little in there that a well run organisation will not already be doing it is just wrapped up in some rather archaic languauge.

The downside is that many of the people involved in setting contracts do not understand safety in the same way as we do here , so dialogue can become stilted and it is easy to get confused.

To me this sounds like "contracts speak from DE&S".

Crown Immunity is the principle that organisations that are part of the Crown cannot be prosecuted as the Crown cannot prosecute itself.  The principle used to be very widely applied so the whole NHS had Crown Immunity. Nowadays NHS Trusts, like any other organisations can be prosecuted. Crown Immunity only applies today to government departments (ie the Civil Service), some non-departmental bodies and the armed forces.  Health and Safety at Work Act makes it clear that although the organisation as an employer has immunity, individuals working for tem, are still liable under the Act and can be prosecuted in a court of law.  

If the HSE believes that body that has Crown Immunity could be prosecuted in court but for their Crown Immunity they can apply for a Crown Censure, which is an official telling off that is recorded on the HSE prosecutions database.  

The Corporate Manslaughter Act reduces Crown Immunity even further. See Sections 11 and 12. There is a list of organisations in Schedule 1 which can be prosecuted under that Act.

The principle of  Crown Immunity is sometimes misunderstood, it does not mean that the MoD or other government body is not held accountable for its failings. As Mark mentions the MoD is subject to Crown censure which is basically holding them to account, it is a long intensive process & certainly not a token slap on the wrist.

Exemptions from legislation have to be applied for,with the exeption of some activities related to defence  they are not automatically in place and are usually of limited duration/ application.

There was a good article about this in SHP a couple of years ago, if anyone wants the full explaination of why the Crown (HSE) does not prosecute another Crown body in the same way as it would a business or individual.