Why not RIDDOR and replace it with something that is easy to understand and identifies real issues

DSE Regs and absorb them in to PUWER. Provide guidance instead, why have separate Regs?

DSE regs Make them part or PUWER, and issue guidance.

I'd be interested in whether a more fundamental variation could be made to the way we frame our H&S duties in the UK. As someone with an H&S remit, I do like the fact that most of our law is based around it being up to ME to ensure I've done "enough" to control the risk, rather than (as in some jurisdictions) consulting the relevant regs for the work in hand and implementing what they say. This makes me focus on exactly the task in front of me, because it may differ from the industry norm subtly in a way which presents additional risk. However I suspect that this doesn't help engage smaller contractors, or one-man-bands, who don't have anywhere like the safety training to do this for themselves and often fall prey to the cheap-as-chips, copy&paste consultancies (not that there's any of them on here of course!). How many times have you received a PQQ submission from some poor sole trader or small company with dozens of pages of guff which is clearly generic and much of which he didn't even need to posses? Some of the HSE guidance and ACoPs go a little bit down this path (eg the chart of heights / weights / positions in the MH regs, which help people decide whether an operation is "unlikely to create a risk sufficient to warrant a detailed assessment"), but I wonder whether we'd get more compliance by writing into Regulation more thresholds like (for example) CDM has - if a construction project is above a certain trigger point then additional rules apply. COSHH, for example, ties many small companies in knots over what can be highly insignificant risks. Would obviously need a bit of thought, but we do have a real problem with people failing to grasp how simple or complex, and how safe, their job is. Failing that, then it's got to be the Licensing Act 1872, as us poor Scots are STILL waiting so we can be drunk in charge of a cow again.

There is nothing wrong with RIDDOR itself - the problem is it has been highjacked by number crunchers and has thus developed commercial implications for many of us.

I'm with Walker and Chas on this. There was a specific need when it came into force but now there is no reason why it cannot be absorbed into PUWER and have specific guidance such as power presses and FLT's.

I disagree, the assessments are a good way of pulling the things you list together If you read COSHH regs it specifically says you don't need to do assessments for the low hazard substances. I can name a quite a few substances that can be bought on the high street where a low volume will certainly kill. Also most deaths from substances occur in the home. Spend a few days in the nearest A&E if you need evidence.

This was considered during the various reviews, the most recent being Lofstedt and there was coinsultation/opportunity to contribute! DSE, COSHH etc transposes EC/EU Directives that have specific requirements. Even if one consolidates several directives into one regulation ( as in Republic of Ireland) , the so called " burden" will not significantly reduce . Very often, our profession, the Health & Safety supply industry and excessive procedural outputs from management systems complicates matters when there can be simpler outcomes. Unfortunately, the HSE has not further promoted its concept of control banding, which takes into account quantity, the hazards, state etc other than its use in the online COSHH Essentials Tool

Dave Hartnett: ¨Of course. Maybe I can start with the easiest part of your question. We in HMRC cannot think of a group who are less like the self-employed. Self-employed people are independent and carrying out work and endeavours and the like for themselves for gain, so we do not think you are self-employed. The opposite position is that it is very hard for us to think of a group who are more like office holders. Our working definition of an office holder is somebody who works in a role that exists independent of what they themselves bring to it, so we see you as office holders, the Member of Parliament for wherever has endured for a long time, boundary changes and all of that allowing, and we do not see you as employees¨ http://www.publications....emex/c1484-v/c148401.htm

I'm with the DSE crowd here. The essential elements are covered by PUWER, and in any event the tech landscape changes so quickly that a great deal of the detail is rapidly becoming irrelevant. I mean, workstations? Yes, we still have them, but we also have phones and tablets and we skype and we video-conference and we have smart eyewear (still a toy but in five years time???). The rate of change is beyond a single piece of dedicated legislation, a general goal-setting approach based on risk is what we need, John

1. I'd go for the current Corporate Manslaughter legislation and replace it with a much better tougher one that would see some of the individual perpetrators at the highest level in large businesses residing in the slammer and address the current problems with the law as it stands. Or even apply the joint enterprise action.? 2. And replace reasonably practicable with the tougher standard of practicable. [cf Earlier Mines legislation of 1954 when there were many MPs from the mining communities] Yes, I know its been through the ECJ once.

But COSHH is goal setting which is why it is based around a risk assessment. The problem is that a lot of people seem unable or unwilling to do the risk assessment. Just because a business is small does not mean that it not using hazardous substances.

I think its unable, like maths most folks "can't do science" and are almost proud of it. Mention a chemical name and they go to pieces

quote=hilary]I like COSHH.... just saying.. It's not H&S, it's environmental and I would get rid of the The Producer Responsibility Obligations (Packaging Waste) Regulations which have to be the most challenging and difficult to understand of all Regulations ever produced. What on earth were they thinking!!! Mind blowingly useless stuff.

#19, 23, 24 Where did I say that small companies don't use high hazard materials? Clearly some do. You are reading something into what I said, that I didn't actually say. Again, the whole point of COSHH/DSEAR is that a company of any size/work activity/hazardous materials/processes in use can adopt a risk assessment methodology for both DSEAR/CoSHH that produces a 'suitable and sufficient' assessment in line with the risks and hazards of the hazardous/dangerous substances that they use.

Its funny cos its true ! They could possibly be the most ill considered iteration yet.

I didn't mean we should not have environmental legislation covering the things they cover, but it could be better written. ie Some of it is hard to distinguish which parts are for us and which parts are for the regulators etc. Most people, I think, just want to know what they have to do to comply, but some of it is so very convoluted. Even some of the waste company's seem to be confused over which set of SIC codes are to be used for waste. Ie 2003 for hazardous and 2007 for non hazardous. I remember having to look something up in the water industries act once, and discovered it was over 400 pages long ! Even the EA web site has now gone and been replaced by a .gov waste of time. But as normal just IMHO Chris

I'd repeal all safety legislation and see how quickly everyone misses it when it goes wrong :-)

In 1996, there indeed was an HSE Discussion Document proposing to consolidate the Lead & Asbestos Regs into COSHH--majority of respondents wanted to keep them seperate, The HSE website consulation archive only goes back to 2000, but this article says it all! http://www.lgcplus.com/h...asbestos/1541999.article

I am involved in applying fire safety legislation across the UK, and despite a re-write of the UK's legislation over a 5 year period, I remain frustrated that there are 3 x separate bits of law, all pretty much saying the same thing. This causes me a lot of problems when explaining & communication responsibilities to senior management with no FS knowledge, who move from one site to another. It is a ludicrously inefficient way of running the UK and does little to help business remove H&S red tape, although it does keep scores of needlessly required lawyers in business So excuse me for being greedy, but I am not repealing, I am merging: The Fire Safety (Scotland) Regulations 2006, The Fire Safety Regulations (Northern Ireland) 2010 and The Regulatory Reorm (Fire Safety) Order 2005 Into 'The Fire Safety (United Kingdom) Regulations 2015' - where all the best bits are cherry picked and packaged into a one-size-fits-all law: Bliss!!