I see nothing wrong with WAH regs, why do you think they are poor? For me, is would be dumping DSE - relevant at the time, but now not needed

I'm with walker. The WAH regs are fine for me. They allow me to explain to builders etc what options they have, and we choose. And with walker and chas, DSE is overblown, and dated to when PCs first came in and folks were worried. Their use should be part of the Workplace/Welfare regs and be a self-assessment exercise with guidance on furniture, window glare, posture etc

Quite agree.

Risk assessment - good idea originally, badly interpreted. Sigh. Then this poor approach is perpetuated by the profession. How ever did we get into this tangle?

RayRapp I'm baffled by your belief about "the need to complete a risk assessment for all and sundry" and your view that "risk assessing activities....has become a time consuming bureaucratic nightmare..." My understanding and that of various other OS&H people is that the risk assessment process starts with a fairly quick look at any activity or situation to decide whether or not it entails SIGNIFICANT risk. If it doesn't, simply note the decision and don't do any more. This is what my colleagues and I tell our employer's headteachers and other managers during training sessions about risk assessment & management. Time, effort and money, etc needs should be devoted to dealing with significant risks, not trivial insignificant ones. If some OS&H people think otherwise, no wonder there is confusion and misperception about the alleged burdens of "health & safety". Also, my colleagues and I rarely do risk assessments ourselves. That's because it's a function for line managers who should know the activities, people and the other factors involved far better than us or anyone else, and then effectively manage the significant risks involved. We certainly provide guidance and training about risk assessment & management, and also support line managers who ask us for help about some aspects. If a line manager were to ask us to provide a full risk assessment about something we would politely put them straight, perhaps suggest some aspects to consider and also offer to work with them if necessary but not do the work for them. As for ChrisBurns' suggestion about bringing PAT (portable appliance testing) into regulation and getting rid of the HSE recommendation, this also seems to reflect confusion and misperception by some OS&H people and others - as mirrored by the number and length of topics about PAT on this forum. The regulations concerning electrical safety at work are reasonably clear in their aims and also sufficiently flexible as regards ways of complying with them. With guidance available from HSE to help people decide on what appliances should be tested and at what intervals - as just one facet of maintaining such equipment in an electrically safe condition - why would anyone wish to replace the guidance with rigid prescriptive regulations?

...even some of the regulators are jumping on the bandwagon of audit in favour of the traditional workplace inspection. It's pretty grim really...

And I agree too, very strongly. Ken

Correct me if am wrong but there is no need to complete risk assessments for all and sundry. I agree it has become a process where everything and anything is subject to risk assessment with large manuals full to the brim with unnecessary paperwork. This has only come about through a lack of understanding what risk assessment is all about. It is only 'significant risks' that need to be documented. We had 'safe systems of work' long before risk assessment which somehow became the be end and end all. Risk assessment certainly needs some radical overhaul.

I think it should all be reassessed, every last piece of legislation, and it should be in plain english, and not with words such as 'so far as is reasonably practicable' or 'competent persons'. I agree too on the risk assessments, i'm sorry but its getting rid of common sense in a lot of areas.

There is nothing wrong with Risk assessment - only how some seem to think it is needed for everything. This was never the intention and was not how I was trained. I'm also confused about the use of of the phrase SSoW and the context you use it -for me, this is just a low hierachy control measure that we were all taught was less than reliable as it depends on human response

Agree with all the comments about the need to update DSE, its outdated and I suspect few businesses are fully compliant or even bother trying, how high are the risks for the vast majority or employees? As far as Risk Assessment goes I think the big issue is how the controls are communicated and put into practise not the Risk Assessment itself. Far too many businesses write the assessment, have everyone sign it, then put it in a nice neat file on a shelf then sit back smugly thinking all is OK. I have audited many different business where all the risk assessments are signed annually on the same day! My philosophy for complying is where significant risk is identified then to control the risk documentation is not enough on its own, proof of implementation of the controls is required and I don’t mean a signature on a document. I use a SSoW document as one of many controls and it always forms the basis for the training for the task and is designed to use language the end user will understand not the technical language a HS expert will use in a RA. Any changes to Risk Assessment should focus on the implementation of the controls.

Nothing wrong with the principles of RayRapp's argument, however the processes he describes were never the purpose of Reg3. R/A is a management process, and a necessary one to allow the employer to determine he has a process in place to manage risk via continuous review and reduction. This process is in turn the essential cornerstone to Regulation 5. R/A has generally fallen into disrepute via contract and tender processes, mistaken attempts to use the Risk Assessment as a direct means of communicating the SSoW to all involved, or as some definitive instructional or training resource. R/A, in the context of what it should be, and what the Regs actually require is essentially fine by me. The original post was about changing the Regulations, not about inappropriate application. I'm with revocation of DSE (hopefully the EU review in 2013 will recognise this). Free eyecare for DSE is also quite ludicrous. Notable that neither Lofsted or LY commented on that.

Perhaps we need a national standard for risk assessment training and I would nominate Ray Rapp and Ron Hunter to produce it! ken

All good stuff but......Can someone answer my original question.

Tony, like Ron I thought people had answered your question, albeit not necessarily in a direct way. With regards to WAH regs there is evidence that both injuries and fatalities have fallen in the last ten years, although the latest HSE stats show fatalities have increased by 16%, this could be a statistical blip, but they do not break down the types of injuries for some odd reason. I do not know of any other data specifically for WAH and since the WAH Regs were intorduced. Notwithstanding that, I have no doubt data would show a reduction of injuries and fatalities since the regs were introduced - but at what cost? It is not enough to justify a regulation or initiative merely by looking at the accident stats, a practice which is quite common when people are looking at PPE controls. We need to understand whether the implementation was worthwhile, value for money and so on - but a much harder task. There is a tendency to measure what is easy to measure, rather than what should be measured.

If you don't record the significant findings, then what will you record as a result of your risk assessment findings. Also what is significant? Still a wide area for debate as to what is significant, depends upon the skill and experience of the risk assessor, at the very least, I would say.

You do not record anything. You carry out your risk assessment and then do what is necessary to ensure a safe place of work. The test is in what is actually done, not in what is written down. It would be sea change to many who have always lived in a bureaucratic world of health and safety where there has to be documentation. To quote Professor Lofstedt in his recent report when he was referring to civil claims "Steps need to be taken to ensure that the absence of a particular document is not in itself proof of non-compliance". This should apply equally to criminal law. I think the Professor missed a trick here. He should have gone further. He should have recommended a dramatic reduction in the requirement for things to be written down. Paperwork does not make people safe.

Al, I agree that there is too much documentation in general and paperwork alone does not make for good safety but, it's a big but, the world we now live and work in requires lots of initiatives to be documented. For example, audits, without evidence for an audit you will not pass the audition. Moreover, when something goes awry, you are asked by the accident claims lawyer, insurance company, client, regulators and so on, for the evidence, without which you be left hanging. Not sure what, if any, measure Prof Lofstedt could have recommended which will put a stop to this? I think we can only keep chipping away by curbing the constant fear of litigation and unnecessary demands made by accident claims lawyers.

It's hard to find year on year figures for death from W@H but this shows stats for deaths over the last 5 years and although there was a slight increase last year (many possible reasons) the figures show a decent drop from 2005 in general. Considering deaths from falling from height were amongst the largest percentage, it's fair to say the regs have helped to reduce the number of fatalities pro rata. IMO http://www.hse.gov.uk/st...ics/overall/hssh1011.pdf

I was taught many years ago when I did the NEBOSH Cert and it was reiterated in the diploma that a Risk Assessment is a management tool. From this management tool, policy and procedures are written (i.e. after identifying significant risk) and these policies and procedures are diseminated to the work force. In other words RAs told you that you needed a policy and procedures and your policy and procedures told you what to put in place (method statements / SSoW etc) - not the other way round. Therefore I reckon most of you who have commented on this subject are wrong(!!) in that you have failed to appreciate exactly what an RA is and any follow on action necessary!! Or was I taught incorrectly when I did the cert and dip!! Rich