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David Bannister  
#1 Posted : 04 January 2013 09:06:07(UTC)
Rank: Super forum user
David Bannister

HSE has published its consultation on Local Authority approach to Inspections for anyone who is interested. This is the risk based approach that is designed to push the available resources towards the "higher risk" businesses and activities, leaving the "lower risk" operations to just get on with it.

http://consultations.hse...459909.1/PDF/-/CD247.pdf
N Burrows  
#2 Posted : 04 January 2013 10:13:43(UTC)
Rank: Forum user
N Burrows

Thank you for bringing this consultation to the Forum's attention. It is very important that those interested in occupational H&S law have a look at this and comment.

I realise that members have mixed views of the interventions they receive from regulators (whether HSE or Local Authority) but the result of this 'National Code', if it comes into force as described would be the virtual cessation of proactive inspections by Local Authorities.

That HSE (a national body with very limited intelligence re activities on a local scale) should try to list (see Annex A) activities that can be inspected by LAs is laughable. The hazards identified are all well worth dealing with but are also likely to be affected by 'knee jerks' to calm political embarrassment. For example - HSE's reversal of policy with respect to routine cooling tower inspections after the Edinburgh outbreak in 2012 but how would outbreaks like that in Stoke on Trent be prevented?

In trying to prioritise premises/activities why have certain issues been omitted? 'Low risk' premises may still contain significant hazards that, if not well managed can harm employees or the public. As examples I give you some issues not mentioned:

Asbestos
Maintenance of gas systems and electrical installations
Prevention of slips & trips (always number one cause of injuries?)

I urge all members (particularly those representing compliant businesses) to respond to this consultation. With little or no chance of an inspection by a regulator those businesses that chose not to comply with H&S law may benefit commercially?
Phil Grace  
#3 Posted : 04 January 2013 15:38:29(UTC)
Rank: Super forum user
Phil Grace

Am I missing something here? One has to assume that Lofstedt didn’t conjure up his comments out of thin air. There must have been some basis for his comments.

With the best will in the world LAs are separate bodies… anything that improves consistency, provides for improved transparency in their operation etc. can surely only be for the common good. As for the reduction of inspections are we not in the position of having to “cut our coat according to the cloth”. Whatever the merits of inspection, there is Govt based challenges, an ever present need to cut costs etc. and ultimately inspections will reduce. So, they must be focussed on higher risk activities/trades/sectors.

Whilst not wanting to give the impression of being against inspection I have to question their value/impact. In the insurance sector (my area of work) we would love to visit every policyholder… but that is impossible. So we focus our efforts, our visits, on those that seem - to us - to present the greatest risk. And we do this in the full knowledge that we will receive claims following accident such as falls from height involving employees of smaller firms that fall below our survey/visit triggers. But these are random events - even visiting every policyholder (which is obviously not practicable) wouldn’t necessarily ensure that such accidents could be prevented.

I feel that LA employed EHOs are in a similar position. They cannot visit every firm or business so there must be policies and procedures to ensure targeted use of scarce resource and in turn consistency across all LAs.

N Burrows mentioned slips and trips - something that is the cause of many, many accidents. But is a visit the most cost effective way of imparting risk management information on this pretty basic issue? Businesses have the primary responsibility for identifying hazards and controlling risk. Slip & trip issues are not rocket science...! Surely firms can be directed towards self-help material?
Phil
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