A strange thought has started nagging me: when might it be acceptable to reduce the level of Health and Safety protection offered. I am imagining a scenario such as a company has insisted for as long as anybody can remember that people working with particular substances should work in a fumecupboard and that they should also wear RPE. A new H&S manager arrives and decides to actually measure the effectiveness of the LEV and find that it, by itself, reduces the exposure well below any exposure limits and that the RPE does  not contribute significantly to the effectiveness of the controls for that process. It would I assume, be acceptable to remove the requirements to wear RPE. Nevertheless someone could argue that even though the RPE has limited value as a control it might have some value as a control and that it should be retained as since it could be applied, it should be applied.

I think that they would be wrong  to go for a belt and braces’  approach but now we have to move to another scenario:  A work room is being redesigned and it is suggested that a hand-wash basin is removed as it takes up to much space.  The basin was installed following a risk assessment that suggested that it was needed as part of a hygiene control strategy.  It is suggested that that it could be replaced by providing wet wipes instead. The Health and Safety manager contends that the wet wipes are less effective that the hand-wash facility, while the operational people say that a) nobody actually uses the hand basin, b) it is  faff to a maintain c) and it takes up space which could be used for something more productive. Would it be acceptable to remove the handbasin following a “review” of the risk assessment?

When is it acceptable to reduce the controls being applied? What sort of justifications should be used to do this?  

"Bubble Wrap" what can we do (throw everything from the catalogue at it) versus what is reasonably practicable to do. If the engineering controls are demonstrated as suitable and continue to be so why PPE? More importantly is the on-going cost of PPE justified against a minimal benefit? That said I have worked where we had fume cupboards but the task involved transfer of materials to equipment on adjacent work benches so here it was a lack of proper engineering (too small a fume cupboard) that necessitated PPE use.

Regarding your wash basin scenario what is the contaminant necessitating provision - is it supposed to be used to prevent contamination of door handles? Wet wipes are not a solution in anything other than a domestic environment, generate unecessary waste and when disposed of cause many environmental issues. Re-visit the RA and work out what was the intention at time of installation - it could be you don't need a basin big enough for forearms merely a corner hand wash. Justification to remove could include eliminating an unused dead leg in a water supply (just make sure it is capped at the start of the supply spur and not where the sink gets ripped out).

• If the actual published risk level of something changes.   e.g.  you may have a policy in place to forbid all business travel to Nigeria, but then FCO/iSOS downgrade the risk rating of that country due to improved political stability or whatever. 

This happens quite a lot in the process industries:

Change of process conditions (lower temps & pressures, less hazardous material)

New/different equipment installed

Change of plant layouts

being a few reasons

I would start by reviewing the original risk assessment. Is it still valid or does it need revising? For example:

"The basin was installed following a risk assessment that suggested that it was needed as part of a hygiene control strategy"

What was the hygiene risk and is it still prevalent and such that it justifies hand washing. Remember that hand washing unnecessarily presents a risk of skin damage. If your risk assessment shows that it is still needed then management need to ensure that the hand hygiene standard practice is complied with. If it shows that there is no real need for hand washing, then get rid of the basin. Alternatively, if professional advice confirms that hand wipes are adequate (in my experience this is not as simple as many assume) then go for them. However, if hand washing is not being done how sure will you be that hand wipes will be used?

In other words, always start with the risk assessment, make sure it is still valid, then base your decision on this.

Chris

No Answer(didn't really expect one) but lots of food for thought.

Thanks for the thoughtful responses 

Originally Posted by: A Kurdziel

No Answer(didn't really expect one)

Oh. What was the question again? Do you mean, can you 'undo' a previous risk assessment's recommended control? Of course you can IMHO. Cost and need to control are considerations in ALARP, and in your example the existing sink is taking up space which is a cost (if it is needed for something else) so strike one, if it is not needed to achieve the control you require that's strike 2. No additional control required, so not needed. CBA isn't it? Or am I on the wrong track?

Edited by user 02 April 2019 13:37:39(UTC)  | Reason: Not specified

It's a great question. Someone alluded to reverse ALARP which is where CBA can be applied incorrectly. Removal of a control may still leave activity within tolerable levels of safety within a new CBA but if doing so is genuinely reducing safety standards that would be inconsistent with application of 'reasonably practicable'. Sacrifice has to be significantly disproportionate to benefit and should start from presumption of provision.

However, I'm quite used to seeing over the top safety requirements that demonstrably add no (or detract from) safety - they form the proverbial rod for the back of the company involved. Once set they can become hard to roll back on owing to fear of the above perception.

Chris P suggested the start again approach i.e. ignore what's there now, what is actually needed to control risk? Then do gap analysis as separate step. If done properly, that wouldn't be reverse ALARP to my mind.

An interesting example of controls occured in my plant management days (before my h&s days), where I inherited a blanket hard hat rule from a previous manager. However, this was unpopular and becoming difficult to enforce. Before cracking the whip, I assessed the situation and concluded that operators would get adequate protection from bump caps instead. These are a lot more comfortable to wear, and gained instant acceptance. Problem solved and eveyone is happy.

Some years later, in my consultancy days, I got into an argument with the MD of a company who laid cables and pipelines. Following a freak accident, he had imposed a rule that everyone wears hard hats all of the time. However, I pointed out to him that many of his employees were jointers, who spent most of the time bent over cables in shallow trenches, so a hard hat wasn't really of much use to them (apart from the problems keeping them on). What he needed to do was get the various jobs risk assessed, and decide on suitable controls on the basis of this. This went down like a lead balloon, so we had to agree to differ.

I tend almost always when visiting a site for the first time or when asked to review a specific task to start by doing my own risk assessment. The reason for this is simple. Due to the complexity, myths and misinformation in my particular field (mainly a specific sector of occupational health) it is almost a given that my risk assessment will differ significantly from the one that was in place. One example: in a large number of cases where gloves are being worn these are not providing the protection that the employer assumes they are getting. (How many on this forum have done ‘in-use’ testing?)

Chris