Posted By Robert S Randall Has there been a subtle shift in the theory and application of risk control measures in recent times? I am a consultant working with the motor vehicle repair industry, among others and I have identified an area where most motor vehicle repair businesses need to improve their risk control, namely the wearing of bump caps while working beneath vehicle hoists. In accordance with standard health and safety risk management theory I have identified the hazard, i.e. head height obstructions and quantified the risk, i.e. that soft tissue injury to the head is likely and have concluded that the only effective control is for operatives to wear bump caps. I am acutely aware that getting people in the motor vehicle repair industry to adopt the wearing of bump caps would require a significant culture change but I feel that this change is justified; and would have positive spin-offs in modifying the industry’s general attitude to PPE. I therefore recently asked the local HSE if they would support a drive to encourage or enforce the wearing of bump caps for operatives working beneath vehicle hoists. The response from the Inspector I spoke to was surprising in that he said “There is no duty to wear head protection and there is not a high incidence of head injuries from people working beneath vehicle hoists. We would therefore have no basis to support a drive to enforce the wearing of bump caps”. I remember that when doing my diploma (some years ago) I suggested that the historical incidence of a particular type of incident must have some bearing on the likelihood of injury, and therefore the need to apply control measures. I was very firmly slapped down by the lecturer who said that we are dealing with the pro-active control of risk and that if a risk exists it must be controlled He emphasised strongly that the lack of historical incidence did not in any way reduce the risk and was therefore not relevant. It seems that the HSE do not subscribe to this well established theory but take a reactive approach to risk management. Bob Randall

Posted By Lumpy Remember that HSE needs to consult before issuing guidance, and I expect the UK motor industry would have strong views with regards the cost of providing bump caps. Besides, as previously pointed out, the employer has a legal obligation to assess and control risks. If you, in you professional capacity, deem the risk significant, and it can't be controlled in another way, them stand by your recommendation and advise bump caps. Lumpy.

Posted By Robert S Randall Thanks to Frank & "Lumpy" for their advice for me to "have the courage of my convictions" but I have already recommended bump caps to my clients as "best practice". It seems however that there is still a dichotomy of opinion because Andy Petrie takes the view that historical incidence should be taken into consideration when deciding on risk control measures.

Posted By Frank Hallett Good evening all. If I may add a rider to my earlier comments for consideration. The value of historical data is in direct proprtion to the value attached to the need to gather it and the means used. Or, if there was no percieved need to report such events and there was no procedure to do so; then the absence of reported events is, in fact, an absence of data altogether, not an absence of events that may have caused injury. Go with it Robert. If you get adverse reactions then revisit your assumptions but conduct a rigorous information gathering exercise - this may extend the introduction of the hazard control measures by some time but it will provide some reliable data upon which to move forward. Good night all Frank Hallett

Posted By Mark Talbot As always, some good advice there. I would add that your lecturer might be right about being proactive, but there are limitations. There exists a risk of eye injury while playing conkers, but dozens of years of shared experience got us all worked up. So whilst you should consider it, it should also be tempered by data and failure mode. If the result of the first accident [no supporting data show a substantial risk yet] is serious injury or death [Titanic] then maybe a drive on the control method is correct. If however, the result of the first injury is a scratch to the cornea [conkers] then maybe we wait for a significant incidence. If bump hats will save a likely nasty head injury, I agree with you. If there are genuinely very few head injuries [allowing for non-reporting] I agree with the HSE. You are well placed to make the call for yourself, and to advise your industry of your actions through the appropriate forum. Maybe a student looking for a thesis subject could look into this?

Posted By Andy Petrie I guess I probably deal with a slightly different type of risk assessment than most of you guys. The areas I have dealt with generally have a pretty good data set to work with, which we use to infrom our descisions. A fact than an incident has not happened for 20 years is a good pointer that it is unlikely to happen in the next 20 years. We then work out a typical likelihood based on that, say 1 incident per hundred years. Of course, that incident could well happen tomorrow but at the same time it may never happen in the next thousand years. When looking at control measures you have to assess them based on the predicted figure using cost benefit analysis. Given the 1 in 100 year prediction, you would have to justify the cost of the control measures over 100yrs against preventing one incident. It is often the case that the risk is acceptable as it is and ALARP.

Posted By Adrian Watson Dear Robert, Can I ask, how did you come to the conclusion that there is a safety risk that warranted wearing bump cap beneath vehicles? I presume that: 1) This is a large company (100+ employees); 2) With records stretching back many years; and 3) They have accident & injury records? If so, they are likely to have sufficient historical data to form a valid conclusion that there is a low or trivial risk. Regards Adrian Watson PS: Regarding the Titanic, the problem was not that they didn't know ships sink, they did! That is why they installed watertight bulkheads. The problem was that they assumed that this safeguard was sufficient to prevent the ship sinking. As such they failed to install sufficient lifeboats in case this safeguard did fail! I would suggest that the real problem, was arrogance ... and the assumption, that we've done enough. How often do we see that?

Posted By Robert S Randall This response is intended for Adrian because I don't want to sound as if I am in elderly relative egg sucking tutorial mode with other respondents. Adrian you are not concentrating! You have made some unwarranted assumptions and have also completely missed the point of my original post. I am not asking for advice on what to do about this issue, I have already made my decision and I intend to stick to it. I am also not the one advocating the use of historical data, quite the reverse. I arrived at my evaluation of the risk by the usual route, however I will, for your benefit, give you chapter and verse: - 1) I observed that there was a hazard, namely that when motor vehicles are lifted off the ground there are hard lumpy bits that stick out all over the place, e.g. gearboxes and axles and suspension parts etc. 2) I also observed that vehicle hoists are not infinitely adjustable and will not go higher (hopefully) than they are designed to go. 3) I also observed that people are all different sizes and that some people have to stoop to avoid obstructions when working under hoists. 4) Furthermore some operations carried out beneath vehicle hoists require it to be lowered slightly so that the technician can reach the component he is working on. All of that being said the head height obstructions are there, they cannot be removed and there is the potential for injury. So what did I do next? Well, since the hazard could not be eliminated or reduced I then had to quantify the risk and decide on appropriate control measures. Every safety professional knows how we arrive at the risk, it is likelihood x severity. Now likelihood is not arrived at by using the Insurance industry technique of historical incidence but rather by establishing the numbers of people exposed to the hazard and how often they are exposed. Similarly severity is a product of the worst case scenario injury and how many people are likely to be affected. The people who work under vehicle hoists do so for most of their working day. The type of head injury that could be sustained at worst is laceration and concussion, or possibly even a fractured skull depending on the person involved. Short of banning people from working under hoists the only solution is an appropriate bump cap. Why do you assume that I am dealing with a large company when I quite clearly said I am a Consultant working mainly with SME's? What would be the significance of the 100+ employees unless they were all working beneath vehicle hoists all the time? What use are accident figures in establishing the level of risk unless I am sure that 100% of accidents are reported accurately? The whole point of my original post was to pose the question "should we be reactive or proactive?" The Insurance industry method of establishing risk is designed to protect THEM from the financial consequences of a claim. We on the other hand are trying to prevent and minimise injury. Let's not allow ourselves to be diverted from our goal by the "hedging your bets" approach of using dubious statistics. Bob Randall

Posted By Rob Randall Lumpy, you are just re-stating what I have already said. Oh, and bump caps without peaks are readily available. Bob