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terrypike  
#1 Posted : 26 August 2011 18:48:18(UTC)
Rank: Forum user
terrypike

Hello I work for a consultancy as a safety adviser and CDM co-ordinator. I am being told that quantititive risk assessments are not suitable and sufficient and indicate incompetence on the part of the prospective PC when presented during the competency process. I have an opinion on this and would like to know the following: Are there any RAs that use numbers that have been endorsed or accepted by the HSE in any way shape or form and can be presented as evidence. Does anyone know (an inspector preferably) whether the HSE would consider these not suitable and sufficient. What would be the possible repercussions if I even indicated to the client or prospective PC that numeric RAs were not suitable and sufficient (even if I didn't indicate incompetence). Finally would it be ethical or appropriate to suggest that the prospective PC needed help with their RAs either from myself or another consultancy (given that the quantatitive nature of the RA is the only issue). I'm seriously thinking of leaving the safety consultancy game on the strenth of this. Thanks for any opinions.
boblewis  
#2 Posted : 26 August 2011 21:06:38(UTC)
Rank: Super forum user
boblewis

Someone is talking utter bull manure to you. The HSE has not made any such statements either. As long as the PC recognises and adequately controls risk then competence is less likely to be an issue. BUT RA ability is not a good measure of competence.
terrypike  
#3 Posted : 26 August 2011 21:09:48(UTC)
Rank: Forum user
terrypike

What really pees me off is that I know it's bullshine but how do you argue with unfounded predudice?
boblewis  
#4 Posted : 26 August 2011 22:40:57(UTC)
Rank: Super forum user
boblewis

Simply say to them that you have it on good authority, mine if you like, that people who believe this about quantative assessments are not undertsanding the risk assessment process properly and are therefore not competent to judge competence Bob
Ron Hunter  
#5 Posted : 26 August 2011 23:09:55(UTC)
Rank: Super forum user
Ron Hunter

Are we all talking about the same thing? QRA for many is about measuring the risk involved with a single event (in a risk management context) for others it is a highly complex way of determining the toxicity or relative toxicity of hazardous substance. QRA in its purest form is most likely not an appropriate or useful approach to Risk Assessment satisfying Reg 3 of the management regs, (it may have a place in COMAH)however use of scoring matrices therein along with qualitative and subjective assessment is an accepted practice and useful for ranking and priortising risk reduction in a convenient numeric convention. Using a scoring matrix does not in itself make an assessment "quantitative". The HSE have tended to drop scoring matrices recently and I can understand that, people do tend to get hung-up on or hide behind inappropriate scoring. Sometimes we don't even get the word right. Quantitative. From certain perspectives, the people you disagree with are correct?
terrypike  
#6 Posted : 27 August 2011 00:37:08(UTC)
Rank: Forum user
terrypike

Ron could I expain this as it was explained to me. Company policy is that if as a CDM-C I receive an RA which contains numbers, i.e.hazard = 4 x likelihood =3, nomatter what is written otherwise then this RA is not suitable and sufficient. I have been told that enforcement officers are considering these as not S & S and that comanies using this method or RA are not competent. It really is as simple as numbers within an RA = not sutitable and sufficient = not competent to take the role of PC
firestar967  
#7 Posted : 27 August 2011 07:10:31(UTC)
Rank: Forum user
firestar967

Terrypike the HSE state that it is a ‘common and very effective method’ the only thing that they say against it is not to over complicate it by having too many categories? So the HSE do recognise the use of a matrix, point them at http://www.hse.gov.uk/risk/faq.htm There is a nice colourful example of one...
firesafety101  
#8 Posted : 27 August 2011 16:19:52(UTC)
Rank: Super forum user
firesafety101

IMO it is a bit dangerous to tell contractors how to risk assess as you may become liable if they follow your instructions and are found to be not suitable and sufficient. As far as I am concerned if I assess competence and that includes sample ra's as long as they show competence that should be it.
Ron Hunter  
#9 Posted : 27 August 2011 17:00:14(UTC)
Rank: Super forum user
Ron Hunter

Thanks for clarifying terrypike. This "company policy" then, is just complete and utter tosh. Is it written down I wonder? Is your Client at all aware of this? If it is avialable in a document, you could send off a copy to the HSE................. A savvy PC is going to challenge this one day, maybe in a Court of (civil) law. His claim would be against the Client who failed to appoint him when all other things were equal. It is the Client's tender process after all. A rather sad situation you find yourself in here, but stick to your guns and good luck!
terrypike  
#10 Posted : 27 August 2011 17:22:41(UTC)
Rank: Forum user
terrypike

I've CDM-C'd contracts and let the quantitative RAs go because I don't think it's professional to act in the way I'm expected. A CDM-C isn't there as a policeman and by ripping into the PC over things like this can in effect make my role impotent. As you say a savvy PC will probably be able challenge it and use this lunatic idea to his advantage. I'm not sure of the reasons for the "policy" which does say we will not deal with generic RAs in letters to client and PC and RAs by numbers being generic is written in another document about risk assessment so the two together state the case,. When I was on the PC side and a CDM-C got a bit "uppetty" I used to bury them in paper and just say it's all in the documentation to any queries.
boblewis  
#11 Posted : 28 August 2011 10:11:07(UTC)
Rank: Super forum user
boblewis

We should not forget that most PCs do not in fact prepare the RAs for work - this is done by the trade subcontractors and the PC vets them. The PC must however prepare the overall RAs for the contract and often use matrices for assistance - it is these that can be supplied unless the contract documents ask for specific detailed RAs. In this latter case the CDMC may ask for more information. BUT if the specific RAs are not requested in the tender documents then the CDMC has no powers to demand them subsequently even to assess competence. In fact to do so suggests that the CDMC is actually not competent. This is regardless of any internal policies of the CDMC. In actual fact too often are PCs asked for RAs that they will never actually prepare when on site and this really points to deficiencies in the design and CDMC team advising the client. the RAs requested in a tender document should reflect the reality of the PC role on the project being offered NOT that of the individual trades. By all means ask about the RA for traffic management but not for say laying the slate floor or roofing. The role of the PC and what he does needs to be properly understood. Bob
chris42  
#12 Posted : 28 August 2011 11:22:01(UTC)
Rank: Super forum user
chris42

Further to Firestar967's post the HSE link goes on to say “People working full time in health and safety often use a version of this method. It provides a good alternative to the 'good practice' approach in Five Steps To Risk Assessment.” The HSE example risk assessments provided on their web site are for what has been termed by the government “low risk businesses / activities” such as betting office, newsagents, estate agents, admin work in a manufacturing company, car park attendants, office cleaning and call centres etc. These are probably best not assessed using a matrix as it is not particularly warranted ( note they don’t have one for doing something more complex like building a leisure centre). They could still be carried out using a matrix, if for instance the admin work in the Manufacturing company was only one of a series of more complex assessments for the rest of the factory and you wished to keep the same format. The HSE site also states “However, it does require a fair degree of expertise and experience” so not for your newsagent who does his own assessment, more for a COMPETANT H&S practitioner. I agree with Ron Hunters post that Quantitative assessments in their purest form and on their own may not be sufficient. My understanding from the course book while taking NEBOSH Diploma was that Quantitative assessments were ETA and FTA type assessments, but that the matrix type are classed as Semi Quantitative and are useful to allow a common approach, in an attempt to overcome individual differences ( unless I got this totally wrong) So if the assessment:- 1) Identifies the hazards 2) Determines who is at risk 3) Evaluates the risks via Likelihood x consequence to give a rating 4) Determines current and new controls that when implemented would change the above calculation to give a new rating at a lower and acceptable level. 5) Implement the controls and record who is responsible for ensuring the controls are in place, used and possibly monitored. 6) Is reviewed periodically or when something changes. What’s the problem ? I find the matrix method allows me to methodically focus on each issue and come review time remind me of what was going through my head, at the time I produced it. I also found the ratings allowed me to target improvement activities, especially useful when you have an accredited management system. It also allowed others to question consequence or likelihood I had attributed, so I could explain further if necessary. I used to work for a specialist contractor for the larger PC's and we never had a problem with the above. If you work for a consultancy what do the others think, you cannot be the only one there?
terrypike  
#13 Posted : 28 August 2011 19:48:33(UTC)
Rank: Forum user
terrypike

Personally I'm comfortable using either method of risk assessment, when I managed construction sites and then as a contracts manager I used both. I often tried to use the method I thought would be the easiest to be understood by the workforce. I often find that risk assessments are aimed at consultants, directors or other professionals and not at the most important people in the chain, which I believe are the workers undertaking the work. I find the RAs our company produces to be very well written but if I gave these to a worker (say a labourer or tradesman) then the eyes would glaze over and an explanation would be a waste of everyone's time and effort, they all tend to be able to understand odds (hazard / severity X likelihood) maybe from a misspent youth in the bookies. When I was contract managing and provided information to CDM-Cs as competency checks I never had a problem when providing numerical RAs or matrices. As with most firms acting as CDM-C we churn out the usual contractor competency form based loosely on appendix 4 of the CDM acop and like most we expect the prospective PC to provide evidence for each of the criteria listed, no 11 is for evidence of hazard management and risk assessments. It's at this point that I've been told that if the RAs that come in are numerical then this is a fail on the part of the prospective PC and they are not competent to undertake the work and they then need help with the RA process. Sadly it seems to me that often the spirit of the CDM regs is being lost both by my own company and may others (I was once contacted by a CDM-C when tendering for a contract to point out that in our policy arrangements we didn't specifically mention that we would avoid work at height SFARP when the arrangements did state we would follow the WAH regs).
boblewis  
#14 Posted : 28 August 2011 21:58:23(UTC)
Rank: Super forum user
boblewis

Cart before horse comes to mind. Why assess competence after appointment - it does nothing to protect the client or the CDMC - The PC has been appointed and therfore the client has deemed them competent. This ticking the boxes approach brings the whole CDM process into total disrepute and if I was PC I would be talking to the HSE firmly about such incompetent rear end covering by the CDMC. Once tendering is complete and the contract awarded then it is ridiculous to try and recapture what should have been done before appointment, even if the tender did require the submission of RAs. If your company's QA system required the completion of such paperwork I as an Auditor would be imposing a non compliance because it was done at the wrong point. Bob
terrypike  
#15 Posted : 28 August 2011 22:37:18(UTC)
Rank: Forum user
terrypike

boblewis, I am talking about the competency checks prior to appointment, note I've said prospective PC. Agreed there is little point trying to assess competency after appointment all you can do as a CDM-C at that point is firefight.
Ron Hunter  
#16 Posted : 29 August 2011 09:39:19(UTC)
Rank: Super forum user
Ron Hunter

I would also hope that your company (and your Client) are making full use of SSIP and other commercial pre-qual schemes to save everyone a lot of unnecessary work. Assuming this to be the case (and it would be daft not to) then the "level playing" field issues become more apparent. Commercial PQQ schemes do not concern themselves with such arbitrary issues and will have no problem at all in accepting the use of scoring matrices. I wonder just how far away your organisation is from a challenge on this, a challenge which will no doubt be brought to the attention of your client as well..........
Duxbury-Williams3741  
#17 Posted : 29 August 2011 10:11:56(UTC)
Rank: New forum user
Duxbury-Williams3741

Providing your RA identifies the hazards, who maybe harmed, the Risk and the appropriate controls why should anyone try to disprove the method of calculation? I find both methods of quantifying the Risk and Controls appropriate in different scenario's. Horses for courses I believe is the approach to adopt, as I was always taught in the forces and when undertaking NEBOSH KISS - Keep It Simple S*****
boblewis  
#18 Posted : 29 August 2011 11:38:17(UTC)
Rank: Super forum user
boblewis

Ron The commercial systems can never fully replace a proper internal system especially as they will never have sufficient resources to undertake all that is necessary. The real issue is that this organisation, like many, has not developed a proper competence assessment system and someone with clout in the organisation has a bee in their bonnet concerning this style of risk assessment. The acop appendix provides some good broad bones but a little knowledge is a dangerous thing when used by people who do not understand what they are doing. I have concerns and issues with SSIP but they are minor compared to concerns with organisations such as outlined in the OP. Bob
terrypike  
#19 Posted : 29 August 2011 13:54:53(UTC)
Rank: Forum user
terrypike

Bob, I agree with your comments on SSIP, this should just form part of the process and be taken as a good indication that the prospective PC is competent and subject to some kind of audit. In defence of our (company) competence assessment system the information we ask for is well above and beyond what is required in appendix 4, is very comprehensive, I don't have a real difficulty with the type of information we ask for and if applied proportionately does the job well. I'm not concerned about the process just some attitudes which I think are wrong. I get the impression that in the recent past (before my involvement) the process went to the nth degree, with detailed, very critical analysis of the supplied evidence, often leading to the conclusion that the prospective PC is in all likelihood in need of H & S help. I tend to be a more pragmatic (as with the RAs which I accept). My original post came after an interesting email discussion over the views on risk assessments and how they are to be treated, I finally requested clarification and didn't like what I was told or how it should by dealt with. I suppose I am looking for support and confirmation that I'm not mad and a reasonable and proportionate approach to competency should be taken, with many factors being taken into account, based on the ACOP. I'm also putting togther as much evidence as I can to enable me to put together a cogent argument, which I suspect will be dismissed out of hand. My view is that if it is policy or opinion (written or not) to view the companies producing these RAs as not competent then we should put our money where our mouth is. I was presented with the statement during the discussion that these RAs are not suitable & sufficient as a statement of fact. I finally replied that if a company's RAs were not S & S then the company is in fact breaking the law and the client should be told for their and our protection (now awaiting a reply or months notice). I do not believe for one minute this is the case and any such advice to the client would be unethical at best, make a mockery of the role of CDM-C and be very much against my professional duty to give good advice and ultimately positively affect H & S on the project.
boblewis  
#20 Posted : 30 August 2011 21:56:54(UTC)
Rank: Super forum user
boblewis

terrypike I actually mean that ALL contractors etc will never be asseesed under SSIP as there are simply not enough assessors around to do the necessary volume of work. The number assessed will I guess peak at around 30% of the total number of construction involved organisations Bob
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