All

Just testing the water for some views!

I've received a report describing driving at work as being a "safety critical" activity - this has set off my latest CPD topic!

As many of you will be aware, we have UK legislation applying to "safety critical" work such as driving trains, operating signals and working trackside in the rail environment. Similar legislation applies to other highly regulated scenarios albeit sometimes with different terminology as in the COMAH Regulations covering "major hazards".

I realise that work related road transport involves significant risks and that there are specific requirements in place for those driving e.g. HGVs and passenger carrying vehicles.

However, do you think that it is appropriate to describe all driving at work as being "safety critical"?

I would be interested in your answers and the reasons for these!

I've found a couple of references to support the proposition but am by no means convinced by the rationale.

Thanks, Peter

“Safety Critical” is one of those terms that have developed from their original meaning and is probably overused. Originally “safety critical|” was engineering term that described a component whose failure would trigger a crisis- i.e. someone could be seriously injured or die, or there could be a major equipment failure or environmental problem.  Safety critical referred to an actual piece of kit e.g. brakes on a car rather than a situation or process e.g. driving.  When you identified a piece of kit as safety critical you had to decide how to reduce it failure rate to as low a reasonably practicable and if it did fail it failed to safe or as close to safe as possible. 

Driving for work is a risky activity which kills thousands of people a year the UK but these figures are not included in our H&S stats. Road-traffic accidents are not RIDDOR reportable. This contributes to the idea that driving for work is not a HS issue and that employers don’t need to really manage it.

So driving is not really “safety critical” but it is a safety issue.

For work or at work seems to derive different interpretation.

At work e.g. FLT drivers always seem to fall in to this broad definition.

For work invariably seems to be restricted to HGV, PSV, LGV but not the company managers and representatives who may spend an equivalent (or longer) time on the road.

Even though all drivers could have their contract terminated if they lose their road driving licence in many Drug & Alcohol policies I have seen it is only the "professional" drivers who are termed Safety Critical and subject to random testing.

For me all driving is a business risk, even more so when it is work related.

Regarding "Safety Critical" I am with A Kurdziel that the term has been miss-appropriated now being taken to mean any action by (e.g. substance use/miss-use) or condition affecting (e.g. fatigue, ill-health, age) an individual that may result in harm within the work environment, especially where machinery is involved.

Employers have duties under health and safety law for on-the-road work activities. The Health and Safety at Work etc Act 1974 states you must ensure, so far as reasonably practicable, the health and safety of all employees while at work.

Health and safety law applies to work activities on the road in the same way as it does to all work activities and you need to manage the risks to drivers as part of your health and safety arrangements. You must also ensure that others are not put at risk by your work-related driving activities. The self-employed have similar responsibilities.

Health and safety law does not apply to people commuting (ie travelling between their home and their usual place of work), unless they are travelling from their home to somewhere which is not their usual place of work. If you are commuting as part of business(ie travelling between offices for the purpose of work) then you are classed as driving at work.

If you are involved in an accident or simply stopped by the police whilst driving at work one of the first questions asked is what is the purpose of your journey and if work related they will then check to see that you have business insurance cover.

Whilst "safety critical" as teminology might be a little strong the fact is driving at work is a risk which needs to be assessed and managed.

Edited by user 19 June 2018 12:47:03(UTC)  | Reason: Typo

Hi Peter, coming from a railway background I may be biased, but I don't see that road driving per se is a 'safety critical' activity. I drove from Ipswich to London today and yes there are probably more risks on the roads than most face at work - that's a given. Nonetheless, there is little one can do about those everyday risks so unless it is specified in an authoritative document as a safety crtical activity then it is not one as far as I'm concerned. 

I think before you can classify anything you need to know the definition and any parameters that it should meet. You then dispassionately judge it against that criterion. The only definition I could find was as I noted above (with minor variations only). Where the criterion appears to be serious consequences / death of the individual or others. Even if we take others to mean more than one, so many different activities / jobs would easily fall under this term.

This is just a made-up term and I agree with its beginnings as per #3 it has been taken from engineering, then morphed into this term used it seems primarily in construction and rail work. Of course, all terms are just made up.

I think that as so many different tasks could fall under this definition that you end up with what is essentially the most important part varying degrees of control. Reference was made to medicals, but these vary by job roll and cynically appear to be pushed by organisations that for a fee can do these assessments and may have helped bring the term into use.  

However, if you then say that the assessment is specific to the task, then do we not already have such things in place for normal drivers. Your eyesight is tested by reading a number plate, if you find you have diabetes and it is controlled by insulin or certain tablets your licence is restricted and you have other controls when you drive, similar if you have sleep apnea, loss of licence until controlled.

Companies themselves normally have drug and alcohol requirements in policies, (indeed as does the law). Companies should have policies if long hours or night time driving is required.

So regardless of what you call it do we not already accept the appropriate level of control for the safety critical nature of driving as part of our work. Therefore, in a way it matters not if you want to call it safety critical work or not, a rose by any other name….

I don’t particularly disagree with what the others have said, in fact I agree with most of it. However, for me I would still say “yes, it is, but only to a degree”. 

Chris

Chris, agree with just about everything you say including the need for a dispassionate approach.

Aurora, thanks, but assuming you are not counting deaths other than resulting from RTCs (e.g. suicide) then you are exaggerating the numbers.

According to the DfT, the total number of fatalities from RTCs in 2016 in Great Britain was 1792 (down 44% over a decade) - add a few in Northern Ireland to get the number for the UK.

That means 100s rather than 100s of deaths per year associated with driving at work.

Noone has suggested that driving at work does not involve significant risk.

However, my initial Q asked whether those driving at work should be considered to be Safety Critical Workers. Subsequently I also asked whether some variables should be introduced into any assessment.

As Chris has pointed out, there are already some additional controls in place for all drivers, even if e.g. the alcohol in breath standard in legislation enforced by the Police are substantially lower than the threshold typically used for Safety Critical Workers.

As some readers will know the evidence is mixed as regards whether Drug and Alcohol policies reduce the number of accidents, particularly if applied in situations which would NOT have been traditionally considered to be Safety Critical, whilst at the same time being argued to be an infringement of human rights.

So, is an extension of the definition of Safety Critical largely based on a Faculty of Occupational Medicine paper referred to by Chris earlier justified. It's never been endorsed to my knowledgeby e.g. the HSE.

FWiW.. My understanding is that something (or someone?) is 'safety critical' if (and only if...) failure of the thing (or that person) can result in total mission (or business?) failure...  If there is no fail safe mode, if there is no back up system, and if monitoring systems are crucial.... Thus the O ring on the Challenger shuttle was 'safety critical' and the factors which led to the mission failure were understood but not given adequate priority in mission planning.  Would failure of a single driver result in 'total mission (or business) failure'???  If we are talking train drivers, responsible for several hundred commuter lives - then yes,  I believe they are.  If we are talking a sinlge private car driver - then probably not....  If an HGV driver... then would the business disappear of the vehicle was involved in total loss?  I think it depends....  In many scenarios, there might be loss of life, there might be third party casualties - but (for me at least) I think it is stretching the term 'safety critical' a little too far to include all drivers....  I know that language shifts, but sometimes it is important to maintain common understanding and definitions, and I think the drift to calling any safety failure as critical (read catastrophic?) is one I personally will continue to resist! 

Based on that post, and what we have seen of corporate failures (BHS, Carillion etc.) any Board member must be defined as Safety Critical - who signs off the company policy and who is not deemed a safety critical driver/employee?

You asked if all driving at work was "Safety Critical" - merely pointing out the decision makers (policy signers) have a tendency to exclude themselves

I do have a pertinent example but that would not be suitable to post as it would breach forum rules - needless to say it followed introduction of a site Drugs and Alcohol policy where "drivers" were defined as Safety Critical.