Yes - speak to them, and they seem to be saying the opposite of what Lord Young was gradually aiming for/wanted/wished/desired. Written risk assessments are good for SMEs, but let's try to simplify the process.........now that's H&S-competent advice and beats hands down the unresearched notion that you can put all H&S requirements into one set of Regs. for SMEs.
"The potential benefits to be reaped from OSH are particularly large for SMEs. Firstly,
SMEs are more vulnerable to the effects of accidents or illness as they have fewer
resources. Secondly, SMEs are more likely than larger companies to not have a wellestablished
OSH policy. However, recent research indicates that when small companies
lag behind larger companies in terms of OSH management, it is not so much due to lack
of time and financial resources - these barriers are more or less equally important for
small and large companies. Rather, it is about knowledge-related barriers. Thus, lack of
OSH awareness and expertise, or not seeing the benefit of OSH management, plays a
bigger role in smaller companies than in large ones.
The financial benefits which can accrue from improved OSH management do however
vary between Member States, not least due to considerable variations in insurance and
social security systems (for instance, the extent to which employers are obliged to offer
sick pay). This leads to very different cost/benefit structures which may again affect the
level of motivation to invest in improved OSH. This could indicate that the differences in
national context call for specific national arguments towards employers rather than a
'standardised' EU approach. In other words, it may be best left to the Member States to
design their own OSH policies fitting their national systems, rather than to try to set up a
common EU system. This is, in fact, recognised in the Community strategy 2007-2012 on
health and safety, which largely leaves it up to the Member States to define and
implement their own national strategies.
Although it is not possible to quantify the potential financial benefits of OSH, it is clear
that they can be significant. The obligatory written risk assessment is a key element in
OSH management, and completely eliminating the requirement for a written risk
assessment for the smallest companies, as proposed in the Commission’s Action plan for
reduction of administrative burden, may have a detrimental effect on the level and quality
of OSH in small companies. The proposed measure is therefore assessed as not feasible in
its current form. Instead, introducing risk-based approaches, based on the specific risks
associated with sectors and types of companies, preferably combined with simplified
procedures for the smallest companies, seems a more productive way forward."