Posted By Neil Budworth Has anyone else pulled this off the HSE web site yet. I'd love to hear what people think about it al 13 pages (including questionnaire, covers and appendices) Best Regards Neil

Posted By Bill Fisher Neil Saw it last night and have read it a few times! Is it just me or do you (and others) think this is a waste of paper and time - I didn't see anything new or taxing that would challenge Directors to tackle Revitalising. Perhaps a good starting point for new SMEs? I am prepared to change my mind if someone can draw me to the positive. Regards Bill

Posted By Allan St.John Holt In my opinion this is a complete and shallow climb-down. Not an ACoP, Neil, just 'guidance', and not even new at that. Unless this is put into a stronger format such as an ACoP it is predictable that 'business as usual' will continue. Experience shows that to achieve any meaningful culture change, a business has to get its key values set down and translated into actions. These might well be some of the actions. I am very disapppointed, but not too surprised to find this appearing so close to a general election. No corporate brownie points (or corporate donations?) to be gained by clobbering business, as this is probably seen as being too much like 'Old Labour'. Politics intrudes, methinks. Allan

Posted By Phil Roberts Neil, Having read the document and coming to the same conclusion as most of you, do you know if IOSH be making a formal response to the Consultative Document? Regards Phil

Posted By Ian Waldram Yes we will, in fact HSE kindly gave Leicester early sight of the document, so some people there saw it a few days ago (not me, I was alerted by Neil's posting!). As for other CD's, Richard Jones, Head of Technical Affairs, is responsible for collating the IOSH response, and I'm sure would be pleased to have your views by e-mail (use 'Contact Us' above). That should not of course preclude members from making an individual response, or supporting those from other bodies.

Posted By Arran Linton - Smith I totally agree with the points that have been made both by Allan St.John Holt and Neil Budworth and I believe that this document has no real added value to the spirit of Revitalising Health and Safety. I am very disappointed with this much awaited document. As an observation I checked back on the wording of the Action point 11 in the Revitalising Strategy Statement and it states the following: The Health and Safety Commission will develop a code of practice on Directors responsibilities for health and safety, in conjunction with stakeholders. It is intended that the code of practice will in particular stipulate that organisations should appoint an individual Director for health and safety, or responsible person of similar status (for example in an organisation where there is no board of Directors). The Health and Safety Commission will also advise Ministers on how the law would need to be changed to make these responsibilities statutory so that Directors and responsible persons of similar status are clear about what is expected of them in their management of health and safety. It is the intention of Ministers when Parliamentary time allows, to introduce legislation on these responsibilities. I believe that on this occasion, that the HSC have had their hands tied by the Scope of this action point, particularly with the words of the first paragraph. I like many, naively believed that this proposed code of practice, would eventually become a HSC Approved Code of Practice rather than a HSC Guidance Code document as it now appears in the consultative document. It will be interesting to see how the HSC will undertake the tasks laid out in the second part of this action point, especially when advising Ministers about making these responsibilities Statutory. I shall be responding to this Consultative Document by the 9th March and pressing for an ACOP.

Posted By Jay Joshi The general view of responses on the forum is the need for an ACoP as guidance will be too much of a "soft" option.I fully agree. However, I feel that perhaps the HSC had no option in the short term. In order to have an enforceable ACoP, there has got to be relevant legislation in the form of regulations - For the Directors Responsibilities, there doesnt appear to be any relevant explicit regulations for an ACoP unless new/amending regulations are made. Perhaps that is why there is a hint in the action plan-i.e."The Health and Safety Commission will also advise Ministers on how the law would need to be changed to make these responsibilities statutory so that Directors and similar responsible persons are clear about what is expected of them in their management of health and safety. It is the intention of Ministers to introduce legislation on these responsibilities." We on our part must put credible responses to HSC on the need for an ACoP that supports regulations--even if new/amending ones have to be enacted!!