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#1 Posted : 11 January 2004 19:44:00(UTC)
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Posted By Raymond Rapp
Do risk assessments actually contribute towards health and safety or have they become nothing more than 'paper safety' exercise?

The original concept of identifying workplace risks and formally recording them to identify control measures may have been a good idea in theory. But in practice do they serve any real purpose?

There are a number of inherent flaws associated with risk assessments e.g. where the outcome is uncertain; the event rarely occurs; the risk and the harm is often subjective; control measures are not properly identified or sometimes not implemented; often risks are only identified after an incident and therefore with the benefit of hindsight. Obviously this list is not exhaustive, but bearing in mind the resources needed to comply with Reg 3 MHSW Regs one wonders if the cost is proportionate to the gain.

I would be interested to hear the views of others both for and against risk assessments and if there has been any research in this area.

Regards

Ray
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#2 Posted : 11 January 2004 21:03:00(UTC)
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Posted By Robin V Boughton
Of course 'Risk Assessment' contributes to health and safety. It is not 'rocket science' as every individual in this world undertakes many risk assessment as they navigate their way through an often dangerous environment that is called life. Regulation three of the MHSAWRegs requires that only significant risks are assessed and the identified control measures implemented.
It is the mis-interpretation of what is 'significant' that causes the problem in what is a systematic approach to managing hazards wether inherent or introduced to the workplace.Having to follow a defined protocol makes people stop and think about what they are doing and that must contribute to their's and others safety.
I have seen risk assessment for really trivial mundane tasks that are not necessary and tend to give the whole process a bad name in terms of both the 'value' and the cost.
The first question in any assessment process should be is this hazard significant in terms of its possible effects. Forget backside covering by including everything it is not necessary!
Hope this helps!
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#3 Posted : 12 January 2004 09:49:00(UTC)
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Posted By Shane Johnston
Robin,

At last, another individual who can see that the main problem with Risk Assessment is that far too many people document the trivial. I have seen risk assessments covering the use of window-lean right along side a risk assessment for a Category 1 carinogenic paint. Trouble is in a file containing 100's of risk assessments the employee can't see the wood for the trees.

If you want to improve safety, concentrate on communicating to the employees in a manner they understand. Handing employees a file containing a 100 risk assessments, and expecting them to read them is not good enough. If a control measure is simply PPE for example, put up a poster next to the process showing an employee wearing the correct PPE. Much easier for the employee to understand, and much easier for the line manager to see when someone is deviating from the control measure.

Risk Assessment is the foundation of any Safety Management System. If it is not working for you, then that is because you are doing it wrong! Bite the bullet, stop documenting trivial risks, concentrate on the significant, ensure that controls are communicated to the employees in the most effective manner rather than just refered to in a documented risk assessement.

Shane

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#4 Posted : 12 January 2004 10:48:00(UTC)
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Posted By Raymond Rapp
I think you will find that the term 'significant' risk was in the original 1992 Regualtions and has been ommitted in the revised 1999 Regs and probably not by an oversight. Even the HSE are aware of possible litigation for failing to provide appropriate legislation. Hence of one my arguments that risk assessments have 'lost' the intended concept.

I agree far too many minor risks are now included, but perhaps for good reason. In the case of Griffiths v Vauxhall Motors(2003)the company were found to be in breach of Reg 3 MHSW Regs for failing to provide a suitable and sufficient RA on a piece of equipment. Most would argue that the equipment would have been considered to be a minor risk. Sadly, we are living in a 'claim and blame' era, and it appears to me that h&s is caught up in it. In common parlance it is known by the acronym ACE (and the A does not stand for anatomy...)

Ray
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#5 Posted : 12 January 2004 14:32:00(UTC)
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Posted By Alan Hoskins
Hi Ray,

I don't think you'll find significant risk mentioned in any version of the Management Regs. The requirement was (and still is) to record significant findings arising out of risk assessments (which have to be suitable and sufficient!!!).
This creates a problem because if you don't assess all risks how will you know which are significant? There is some help in the ACoP that suggests that trivial risks and routine (everyday) risks can be ignored, but that still leaves a lot to be assessed - and if you don't record that a risk is not significant, how do you prove it's been assessed at all...?

Alan
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#6 Posted : 12 January 2004 14:44:00(UTC)
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Posted By Geoff Burt
Ray

I wasn't aware 'significant' had been dropped from the regs, indeed I wasn't aware it was there in the first place.

The words 'suitable & sufficient' are used.

You may be getting mixed up with the guidance & ACoP where it uses (still uses!) the words ' insignificant risks can be ignored'. Which means only 'significant' risks need to be looked at.

Whilst a small number of people risk assess everything in sight the vast majority treat the topic as it should be ie proportionate to the risk. And, importantly, the level of risk .... should determine the degree of sophistication.

My experience points to risk assessment as being an invaluable tool - in the right hands. You'll always get the ones going OTT - frequently on this forum!

Geoff

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#7 Posted : 16 January 2004 20:08:00(UTC)
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Posted By Kieran Duignan
One of the issues to consider in relation to risk assessment is the category of hazard under consideration.

In assessing risks of occupational stress, the hazards are human behaviour and omissions.

Complex difficulties arise simply because to some extent, the potential for harm depends on subjective interpretation of individual employees as well as the cultural climate of the organsiation, which influences what is tolerable and permitted in an organisation.

So, the borderline between 'significant' and 'insignificant' depends on ultimately on what the consensus is in the organisation - which is NOT the same as what management wish to impose, ignore or condone.

Having been involved in some horrendous occupational stress incidents as an expert witness, a risk assessor and as a counsellor, my experience has revealed how the only reliable prediction is that where management neglect to assess and manage risks of occupaitonal stress, it is only a matter of time before Life throws a major stress incident in their faces. A true example? A a female executive alleging sexual harassment by the m.d., in a company without any health and safety policy or grievance process) but with a regular use of formal discipline procedures.
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#8 Posted : 16 January 2004 20:40:00(UTC)
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Posted By k p connor
We all know that there seems no place for common sense in health and safety in recent years. The developing science of risk assessment using statistics, human reliabilty etc. is enlarging the problem. The basic concept surely must be to be proactive in identifying, and preventing serious hazards becoming an accidents. I would agree certain over reactions to minor hazards are becoming an overload on the systems. I was once asked to carry out, and write a RA and procedure for a fitter of numerous years experience, to flatten a small piece of metal plate with a hammer. I concluded that the main hazard was where the hammer would end up after presenting the fitter with the procedure.
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#9 Posted : 16 January 2004 20:57:00(UTC)
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Posted By Geoff Burt
Well said kp. It's a pity we can't get more people on our side.

My theory is similar to Sean's on another thread.

Generally, the ones with the background and work experience prior to coming into H&S are the ones with a practical and pragmatic attitude - just how it should be.

Nice to see in today's paper - the prison officer accused of racism has been completely cleared. His boss has been accused by the tribunal panel of not living in the real world.

I can relate to that!



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#10 Posted : 16 January 2004 21:29:00(UTC)
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Posted By Mike Miller
Yeh! and Shipman Hung himself Thats good too! Just Need Huntley and Carr to do the same. Just a thought!!!!!!!!!!!!
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#11 Posted : 17 January 2004 10:41:00(UTC)
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Posted By Raymond Rapp
Thanks for your responses and some interesting thoughts too. It appears the concept of 'significant' and trivial risks has dominated the discussion. But this is only one facet concerned with risk assessment. There are many other problems that have not been discussed.

Playing Devil's advocate for a moment with the following example. I work in a safety critical industry (railway) and few years ago I questioned why risk assessments were not available for Signals Passed at Danger (SPADs). Basically the response was that they are far too complex. Having some considerable experience dealing with SPADs it is true they are very complex and individualistic. However, arguably the biggest risk for train drivers is passing a signal at danger. So, now we have a situation where complex and dynamic hazards such as SPADs are not risk assessed! Against others arguments that too many trivial risks are assessed. Is there a conundrum here?

In truth I would have to say that if SPADs were properly risk assessed it would not make a jot of difference anyway. The only purpose of identifying risks is to implement appropriate control measures. Moving a running signal due to say poor sighting would cost something in the region of 100K. It just would not happen, unless there had been a train crash due to poor signal sighting.

Ray

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#12 Posted : 17 January 2004 11:18:00(UTC)
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Posted By Geoff Burt
You'll give yourself a headache Ray!


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#13 Posted : 17 January 2004 12:18:00(UTC)
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Posted By Martyn Hendrie
I agree with many repondants that far too much emphasis is put on recording trivial matters in written risk assessment.

I would point out that the guidance to the work equipment regulations (referring directly to Regulation 3 of MHSW Regs) states that a significant risk is one that may lead to a "Major Injury"

I have some difficulty with this definition and would rather consider something that may lead to a "reportable injury" as significant. However, it is clear that whilst considering all hazard/risks and taking appropriate controls, the paperwork does not need to record every possible thing.
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#14 Posted : 17 January 2004 22:16:00(UTC)
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Posted By Ian Waldram
There seems to have been much discussion so far on the paperwork - but that isn't the actual risk assessment, merely the 'record of significant findings'.

In a very recent HSE training package on Slips/Trips there are the wise words "Its the action as a result of the risk assessment process that matters". I know lots of people will be able to quote Inspectors who behave as if the paperwork is the most important thing, but really it isn't!
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#15 Posted : 18 January 2004 08:13:00(UTC)
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Posted By Geoff Burt
I think we all took that for granted Ian - otherwise what's the point?
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#16 Posted : 19 January 2004 09:24:00(UTC)
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Posted By John Allen
To get back to the original question risk assessment was an important step forward when it was introduced. For years as a safety practitioner I was asked "We are going to do X. You tell us if it's safe." Usually I had no idea what X was and wheter or not it was safe. Now the people who create the risk have to sit down and work out what it is and what the control measures are. This was Robens original idea if you can remember back that far.

Since the Regs came into force two things have happened. Firstly the diligent employers have assessed all the "significant" risks and some have moved on to the insignificant risks and this is what has given the process a bad name.

Unfortunately the majority of employers have done nothing at all. I am still asked to investigate accidents where clear and very significant risks have not been assessed at all. Occaisionally the risk has been assessed but poorly and the risk assessment locked away in a drawer and not shown to the person at risk, far less ask him to get involved in assessing it.

Of course the latter is unreported by the media who would far rather publicise "safety going over the top" than "employee needlessly injured by failing to assess and control the most obvious of risks".

Hopefully the attachment of civil liability to reg 3 will help to improve the situation. the simple fact is that despite the claims made in the media and repeated parrot fashion in most bars we do not live in a "claim culture". People are still being injured in circumstances that could be prevented and if they do claim at all their compensation is typically low and does not meet the full cost of their losses.
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#17 Posted : 19 January 2004 09:30:00(UTC)
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Posted By Kate Graham
Can I have a prize please for the most trivial risk assessment. It was "using a photocopier in the office". The reason I did it was that a senior person got it into their head that photocopiers are dangerous (in a company using machinery and toxic chemicals). Documenting that the risk was trivial got them off my back.

Kate
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#18 Posted : 19 January 2004 09:49:00(UTC)
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Posted By Nigel Hammond
I was the Risk Assessment Officer for the Corporation of London. It was my job to advise, train and give a big push on risk assessments.

Directors who thought risk assessments were a waste of time proved they were a waste of time. Those who thought they were useful proved they were useful!

It's like many things in life - if you embrace something with energy and enthusiasm, you are likely to get something positive out of it. If you take a negative outlook you'll set everything up to fail.

I am concerned that if us health & safety advisers take a sceptical or cynical outlook on the basic tools of health & safety, then how do we stand a chance of motivating non-health & safety professionals?



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#19 Posted : 19 January 2004 10:36:00(UTC)
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Posted By Diane Thomason
I agree with everyone who says that recording of trivial risks brings the whole thing into a degree of disrepute. But surely this does not mean that the concept of risk assessmnt is wrong, or that the Regs are wrong - it means that people don't understand risk risk assessment well enough to do it properly and logically. Someone truly competent will not fall into the traps that Ray and others have outlined.

Of course the fault often lies with organisations rather than with the individuals who are told to "do a risk assessment", but surely this again is due to a failure of understanding by members of management?
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#20 Posted : 19 January 2004 11:37:00(UTC)
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Posted By Sean Fraser
There's another element to risk that we often seem to miss out, highlighted by Eddie Newall's request - attitude to risk.

How many of us consider the human element beyond training? The hazard remains the same - the risk controls adopted are usually based on the unconscious presumption that those involved are going to apply good sense when working. However, if we had three people doing a task and all were ultra cautious, then the risk is reduced without any further interventions. If we had three chronic gamblers (over-exageration for illustrative purposes only!) who have a laissez-faire attitude to risk, then it is significantly increased. Add to that the general understanding of risk and hazard perception, and off we go again.

The problem comes back to adequate understanding and practical application of knowledge - if people do what they are told to believing that it is safe as a result, they aren't questioning why we do it that way. But if they understand what the hazards are, and are constantly challenging the why and not the how things are done, then we will all work together to make the workplace and activities safer for everyone.

Over-documentation might look good on the surface - but we all know it isn't used and therefore isn't effective. A thourough understanding of "why" would alleviate the perceived necessity of alot of what we write down.

After all, as has already been pointed out, the first and only thing a Risk Assessment really needs is - before you start, think!
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#21 Posted : 20 January 2004 10:42:00(UTC)
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Posted By Ken Taylor
Think what, Sean?

Before they start they need to know how a competent person appointed by management has determined (hopefully in consultation with them) the job can be done safely (eg safe method, right equipment, full needed information, training, etc).

The problem with risk assessment it that it has developed, in some cases, into a pseudo-scientific/mathematical exercise involving reams of paperwork to be confined to largely unconsulted files - whereas the intention was to require management to work out what risks they have, record what's significant and how to control them and make sure the people that need to know this do so and carry out the job accordingly.
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#22 Posted : 20 January 2004 11:00:00(UTC)
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Posted By Fiona Cowan
Once again, is it not a case of commitment from the top being important in helping create a culture of acceptance of the value of the process of risk assessment in an on-going and active manner.

It might be extremely difficult to get managers to commit real time and effort to carrying out risk assessments etc where findings are dismissed by very senior powers as safety once again takes a budget cut and the same managers see safety as someone else's job.

Your point about different managers making a difference is extremely valid Nigel. In recent training courses, the committment of the manager can be seen at worker level for example in sections where all staff know where and how to refer to risk assessments and others where the esitance of such documents let alone their relevence is unheard of.
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#23 Posted : 20 January 2004 23:14:00(UTC)
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Posted By Raymond Rapp
Once again some excellent points regarding the pragmatic approach to risk assessment. I think Ken has summed up the issue of over complication of the process by technocrats who attempt to make a 'science' out of a basically simple process. The subjectivity of risk does not lend itself to quantatitive assessement in most cases.

Without wishing to trivialise risk, take for example the risks arising from a household such as fire, burglary, electrocution etc. There are many hazardous activities and substances but who would ever think of a risk assessment. Clearly, most people would consider it a waste of time. But how many people have not fitted a smoke detector or considered what type and where it should be fitted? Do you really need a risk assessment to identify the problems, no not really. Just some plain good sense ! Which was the essence of my point regarding the benefits of complying with Reg3 MHSW Regs and the cost of compliance, proportionate to the gain?

Ray
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#24 Posted : 21 January 2004 16:21:00(UTC)
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Posted By Wilf Archer
Great question.

I think everyone agrees that a ‘suitable and sufficient’ Risk Assessments MUST be an active part of every job. However the determination of suitable and sufficient is a totally subjective decision based on the perception of the person carrying out the risk assessment. Unfortunately when something goes wrong ‘suitable and sufficient’ is determined by everyone else. So in the interest of self preservation the original author of the risk assessment tries to make sure that all bases are covered. This unfortunately creates a tome of paperwork and the risk assessments tend to take a life of their own and grow exponentially. This then creates another problem because there is an inverse proportionality between the number of sheets of paper to the risk assessment and its likely benefit to the workforce. In one organisation I needed a COSHH Assessment for the dust exposure blown off the Risk Assessment file box as I was sure it exceeded the 10mg/m3 exposure for airborne particulates. :-)

In order to overcome the problem of shelves full of dusty multi-paged and detailed risk assessments not being read I produced a 1 to 2 page Pick and Mix Risk Control system. This had the advantage of the supervisor/workforce picking out relevant Generic Task related documents that combined to cover the entire job i.e. Putting up the Christmas decorations in the local High Street required several documents to be assembled – (Working in a Public Thoroughfare; Working at Height; Use of Elevated Work Platforms; Work in Adverse Weather; etc). The accumulated documents highlighted the controls and specific consideration necessary to perform the job safely. They also formed the basis for the manager’s toolbox talk.

The advantage is that the documents can be assembled to create a specific risk assessment that is not only suitable and sufficient but also up to date.

So in answer to the question:
Do risk assessments actually contribute towards health and safety or have they become nothing more than 'paper safety' exercise?

Yes Risk Assessments do contribute to health and safety if the workforce consider them relevant but they very often become just a paper exercise if they don’t. I often hear from fellow health and safety colleagues that “…Risk Assessments are not their responsibility…” which is technically true but it is our responsibility to give appropriate support and advice. So if the Risk Assessments have become just a paper exercise then we should look at the advice and support we are giving.

Wilf Archer


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#25 Posted : 21 January 2004 22:30:00(UTC)
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Posted By Raymond Rapp
Wilf,

You cannot be serious? Risk assessments for dust on RAs, air borne particles! Now I know the world has gone mad. As for xmas decorations...no, I am not going there.
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#26 Posted : 21 January 2004 22:53:00(UTC)
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Posted By Wilf Archer
Hi Raymond

I hope you noticed the smiley face after the dust assessment :-) I didn't really carry one out.

But the idea behind my comments were that RA should be an integral part of the pre-work programme otherwise they are just a paper exercise. Perhaps Risk Assesments are a necessary evil on the road to producing a Safe System of Work, etc.?

Regarding Christmas Decorations: The example was used to show that when installing the Christmas decorations across the busy Main street where I live my managers asked for a Risk Assessment. I felt like you that we tend to get bogged down producing pointless bits of paper that only gather dust so I pulled together (in consultation) a series of Pick and Mix control documents. This allowed the manager to then create a relevant risk assessment and discuss this with the employees.

Because they are used we now have a Win-Win situation. The solution is far from perfect but at least managers are now thinking about safety before commencing the job.

Wilf
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#27 Posted : 22 January 2004 14:37:00(UTC)
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Posted By Jonathan Breeze
Wilf,

I'm glad you clarified the point about "...basis for the managers toolbox talk."

I had visions of the manager mounting the pile of unread Risk Assessments in order to deliver a homily on putting up decorations.
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