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Posted By Andrew Walsh
Hi,
I am interested to hear what people know about the enforcement management model. It has been brought to our attention that an incident scenario has been tested through the framework and the most appropriate course of action determined. Local authorities and HSE seem to be using it. Has anyone used it for managing their own standards?
thanks
Andrew
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Posted By markl
The Enforcement Management Model came up in a recent conversation I had with the HSE. The Management Model sets out what enforcement action the HSE (or local authority) can take in various circumstances, e.g. when a notice or prosecution can be taken, with the aim of a consistant approach.
There are a number of aspects involved but simple terms, if an organisation has a serious accident, the HSE will look at the past record of the company, and if notices or written advice have been given to the company previously on the same area as the accident, the HSE will escalate the action they take. Depending on the seriousness of the situation, if a letter was received previous a notice will be issued, if a notice was issue a prosecution is likely to follow.
As to using the model in an organisation as a standard, it is conceivable, depending on the systems that are in place in your Company, that it could be used (for example, a poor audit outcome followed by an accident caused by an element highlighted in the audit could mean an escalation in the action taken against the responsible manager, loss of bonus etc) but I would probably suggest that you be aware of its existence but leave the model itself to the enforcers as it is a model of enforcement rather than running a successful management system.
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Posted By CRT
Just to clarify the last post, the EMM is used to promote consistency amongst the enforcement authorities, however in my opinion whilst HSE use it extensively, LA`s vary in its uptake.
It may be used by LA`s as a tool to arrive at a decision on an appropriate level of enforcement action whilst also conforming to their own enforcement protocols, consequently it does not always follow that one set of circumstances automaticaly means a particular enforcement action. It also allows for the public interest test.
Finally, no i would`nt use it as a management tool.
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Posted By Bunny
As someone who has used the EMM for enforcment purposes I can state that it is definately not for use outside of enforcement purposes. It has been developed for consistency but to be honest HSE inspectors hate using it because it is a paperwork excerise. It will be filled in after the enforcement action has been taken just to satisfy the head bods. It can also be easily manipulated by a section called 'local factors', which basically means that you can always validate your reasons for not following the outcome of the EMM. A paperwork exercise devised by the managament bods to try and satisfy the public at large that the enforcers are consistent, which they are not. EMM isn't worth the paper it is written on.
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