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#1 Posted : 09 May 2008 08:12:00(UTC)
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Posted By andyp As it is a Friday before hopefully a nice weekend for a change, may i put this forward for contemplation. Completion of risk assessments, bread and butter of the minefield that is health and safety. Now, if a suitable and sufficient risk assessment is completed on any given task within the workplace and most 'insignificant' risks can usually be ignored (as stated in L21, the Management ACOP), then all is well and good. However, should an accident / incident occur within the future involving the insignificant risk, does this not then make the risk significant? A predicament then occurs, the insignificant risk has been ignored (as recommended) within the risk assessment, yet the risk assessment is found to be lacking should an accident / incident occur as a result of the insignificant risk. Example of a catch 22??? Just a little something to lighten up a Friday morning.
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#2 Posted : 09 May 2008 08:31:00(UTC)
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Posted By Pete Longworth The risk may have been insignificant for 2 reasons. Firstly it may be felt that the level of harm is so low that no further action is required eg a small paper cut etc. Secondly it may have been felt that although the level of harm may be higher, the likelihood of the harm occurring may be extremely low. In this instance, if an accident occurs it then becomes reasonably foreseeable that it could occur in the future and your risk assessment should be reviewed accordingly.
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#3 Posted : 09 May 2008 08:46:00(UTC)
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Posted By andyp Would it not therefore appear to contradict itself dependant upon which view is taken? If the risk is insignificant and ignored then it has obviously been foreseen also. In which case, as you rightly state, the risk assessment would need to be reviewed accordingly. Therefore the insignificant risk would no longer be insignificant, as regardless of how insignificant it may be, if an accident occurred in the future the risk would become resonably forseeable and significant.
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#4 Posted : 09 May 2008 09:44:00(UTC)
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Posted By Sally The example I use on training courses is to liken it to winning the lottery. The 'risk' of winning the lottery with a single ticket is insignificant (1 in 14 millon.) But it still happens to about 52 people a year - around one a week. Just because a risk assessment identifies something as a low risk and it happens doesn't mean the assessment was wrong or that it's any more likely to happen in future.
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#5 Posted : 09 May 2008 10:01:00(UTC)
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Posted By Chris Packham I have to agree with the last posting. Let's face it, a risk free working environment is impossible to achieve. So we are always going to be left with some residual risks that we either cannot eliminate or that our assessment judges are so unlikely that they do not need any "risk management" action. I judge that the probability that the ceiling in my office will fall on me is extremely unlikely, i.e. the risk is insignificant. However, supposing we had an earthquake (which has happened on two occasions, albeit minor) that was strong enough to cause the ceiling to collapse, does this mean that I should now take action to shore up the ceiling just in case? (Actually this might present a problem as I live and work in a very old building that is class 2 listed, so permission to take the necessary action might be denied.) Of course, if the experts were to predict a series of earthquakes in our location and that these might be severe, then I would review my risk assessment! Equally, were the event to happen unexpectedly and the ceiling to fall in then (assuming I survived the event)I would, of course, review my risk assessment. The new ceiling would have to be earthquake proof! Chris
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#6 Posted : 09 May 2008 10:03:00(UTC)
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Posted By Steve Cartwright I'll throw a spanner in the works. You decide that a particular task has insignificant risks, so decide not to bother recording the ra as recommended. Employee has an accident whilst carrying out task resulting in an injury. Employee makes a claim and their solicitor requests a copy of the risk assessment. You reply that you have not got one as you thought the risk was insignificant. They then claim you have breached reg 3 of the management regs. The problem is that insurance companies and solicitors will request ra's when someone is envolved in an accident no matter how insignificant you think the risk is. Steve
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#7 Posted : 09 May 2008 10:06:00(UTC)
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Posted By David Bannister Sally has it spot on. Aircraft do fall from the sky but just because this has happened at Stockport, Lockerbie and Kegworth does not mean that the risk of this happening in any of these places is more significant now. In fact it may be argued that as the causes of these incidents have been established and additional controls put in place, the risk is less significant now.
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#8 Posted : 09 May 2008 10:19:00(UTC)
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Posted By Richard Beevers I totally agree with Sally. In my training I use the risk of paper cuts as insignificant, and not worth formally recording. Yes, people sometimes cut their fingers, but it's so rare and minor that I tell my office based managers to not lose sleep about it. Could be different in a printers of course. I don't think that just beacuse a hazard causes an injury it automatically reveals itself as any more significant. I really think it depends on your industry and the relative significance of a risk. When you've got the major risks that commonly injure staff under control, then the lesser risks do become more significant, but until then, ignore them. Al.
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#9 Posted : 09 May 2008 10:38:00(UTC)
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Posted By Garry Adams andyp In my opinion their is no such thing as an insignificant risk...perceived risks no matter how insignificant usually fall into the category of precursors and therefore the instigators of the onset of a Heindrick domino theory...cited as insignificant are paper cuts, Occupational Health and Hygiene cover lacerations and highlight the repercussions of infection...hemophiliacs ect...RA's are there to mitigate against Risks of all denominations and degree of severity. Its like the "in so far as reasonably practicable" again...No clear Autocratic Direction. Garry...thank crunchie it Friday...
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#10 Posted : 09 May 2008 11:19:00(UTC)
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Posted By Richard Beevers Garry, I know it's Friday, but I've got to ask..... If you believe there's no such thing as an insignificant risk - what do you record on your risk assessments, given that you only need to record the significant findings? Would you record paper cuts & the controls necessary to prevent them for an office worker? And at the other end, would you record falling air craft for a business located underneath the Heathrow flightpath? Al.
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#11 Posted : 09 May 2008 11:31:00(UTC)
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Posted By Robert K Lewis This all boils down to whether you assess Hazards or Tasks. Hazard based assessments always have a potential for throwing up issues that appear insignificant but which may not be so in the context of eveery task in which the hazard occurs. Moral Assess the tasks not simply the hazards. Bob
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#12 Posted : 09 May 2008 11:32:00(UTC)
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Posted By Eddie Interesting take on the concept of risk re the example given of paper cuts and hemophiliacs . Surely the paper cut would be a hazard and the consequences of a paper cut to the haemophiliac would contribute to the overall level of risk. To suggest than any task that involves the possibility of someone "suffering" a paper cut must be considered a significant risk cannot be right.
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#13 Posted : 09 May 2008 11:38:00(UTC)
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Posted By Chris Packham Doesn't the item re paper cuts and haemophiliacs demonstrate one of the problems with risk assessment? We are dealing with individuals who will each have an individual susceptibility to some particular workplace condition. For example, in my particular field of interest, i.e. skin, we have a significant percentage of the population who are what is termed 'atopic'. These people, who may never have been diagnosed as such and who may well be unaware of their condition, are particularly susceptible to skin problems from contact with chemical exposure that would not affect the majority. Do we reflect this in our risk assessment, or do we rate the risk as being that which will relate to the majority? If so, do we then need to have every member of the workforce clinically checked to see if they are atopic? Chris
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#14 Posted : 09 May 2008 11:55:00(UTC)
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Posted By Ron Hunter Horses for courses? (leaving aside 'planes falling from the sky) Making a cup of tea would fall within the everday/trivial risk category for most of the working population. If the tea making facilities in my workplace throw up an obvious problem (trailing cables, overloaded socket, poorly maintained or unauthorised appliances, cramped or inapprpriate or even downright unauthorised location) then I fix it. A record would be available from regular workplace safety inspections. Were this same scenario to be translated to a LA or Charitable Organisation supported accommodation for vulnerable groups, THEN a Risk Assessment would most likely be appropriate. The Management Regs do not specify a format for risk assessment. I would argue that evidence of regular workplace inspection against a checklist including welfare provision, electrical safety etc. satisfies the requirement and effectively constitutes a 'risk assessment'. Hazard issues are acknowledged, standards are recognised and enforced, the process is routinely applied and a record of remedial action is available =R/A =part of SSoW?
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#15 Posted : 09 May 2008 12:18:00(UTC)
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Posted By Sally To answer Steve's comments- If a claimants lawyer comes asking for a RA for an insignificant risk then I would expect the company lawyers to explain to them that because it was considered an insignificant risk the results weren't written down and that this is in accordance with the Management Regs. Just because an insurance company asks for a RA doesn't mean we are at fault for not having one. We need to stop living in fear of insurance claims and start defending our decisions.
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#16 Posted : 09 May 2008 13:16:00(UTC)
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Posted By Stephen D. Clarke If the we have followed the ACoP/guidance/industry best practice etc then I would have thought we would have done all that is reasonably practicable. If an accident still happens then the organisation would be judged to have complied with the law even though the risk was assessed originally as insignificant. Risk assessment is subsequently reviewed and changes made as necessary to the risk controls.
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#17 Posted : 10 May 2008 10:31:00(UTC)
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Posted By Garry Adams Richard Yet again the Regs do not quantify or categorise an insignificant Risk,it is left for the reader to put their own interpretation and significance upon the degree of Risk, this liaise fair situation gives no clear and concise guidance. The insignificance of a Risk may be perceived in varying degrees my individuals...i.e.a bull fighter may perceive the Risk of Him being gourd to death by the marauding bull as insignificant because his perception is that his level competency mitigates against the Risk being realised. It is all down to the perception and to what level of diligence one is prepared to go. Stephen out lined a good example of Sensitisation of the epidermis with exposure to varying products... Garry...
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#18 Posted : 10 May 2008 19:49:00(UTC)
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Posted By Chris Pope I have always understood that an adequate ability to employ sufficient level of forseeability is a characteristic of a competent person. I mean the person who has to do the risk assessment should have been around long enough and networked enough in the particular type of work to have a pretty good idea how dangerous something is. There is no book on every risk stating how likely it is to have an accident. To illustrate this point consider the following predictions I recently saw in the BOHS paper Risk assessment is prediction. Heavier than air machines are impossible – Lord Kelvin President Royal Society 1895 I think there is a world market for maybe 5 computers Thomas Watson Chair of IBM 1943 We don’t like their sound, and guitar music is on the way out - Decca Recording rejecting the Beatles 1962 $640k ought to be enough for anybody Bill Gates 1981
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#19 Posted : 11 May 2008 22:26:00(UTC)
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Posted By Chris Jerman Leaving aside the obvious confusion of 'risk' language, yet again, we must remember that identification and then recording of findings are two separate functions. If you follow the task driven method advocated by Rob K Lewis, and ensure that you systematically identify what your people do for you (normal and RF abnormal activities) you are part way there. Decide upon the significance of the task (NOT risk - you don't know that yet) and whether further, more formalassessment would be deemed necessary. For those activities that you deem that further written proof would NOT be needed, annotate them 'NSF' no significant findings. This decision IS your risk assessment. All you need to do is have your system recorded in your documentation as to what YOU believe significance to mean. This needs to be in the context of your business. It is not the same for everyone. So if you work in the armed forces, bomb disposal, a firework factory, a school, a nursing home, a corner shop - you need to define your rules! Children falling over in a creche - or the elderly falling over in a nursing home? Your risk assessments MUST be put into context by writing down something somewhere. Do you all have YOUR definition of significant recorded somewhere? In answer to the original question - what happens if something that you discounted results in an incident? A) You simply got it wrong - where's your quality checking? Can you prove that you tried and were not negligent in you process? B) It was completely bizarre (ie not REASONABLE to have anticipated that this might occur C) That's life - sometimes, whilst not bizarre, the odd factor creeps in that you couldn't have spotted. But if you had known, you would have made a different assessment. eg the hemophiliac cutting their finger on paper! A hemophiliac bleeding isn't bizarre, but one who happens to pop in and use the photocopier in your newsagent is! We are not going to be able to spot everything. The truth here is that whilst we (and the HSE) could all sit down and sensibly chat this through, it is the initial reaction of insurers and solicitors that sets the tone "You haven't got a risk assessment - then you're guilty and you're going to pay" We have to stop this. Evidencing what you will and won't have formal written assessment for must be available. To consider and dismiss based on sound reasoning is NOT negligence. OK, fair enough, you are still going to justify why the wheels came off on this occasion. Can't help you there. The fact is that even if you did have an assessment, something went wrong. Failure to act perhaps? By the way - an injury outcome that would be major, but the likelihood of the circumstances that could cause the event being relatively unlikely would not be insignificant risk as suggested, it would be medium. That's the point of a risk assessment and the whole concept of medium - it stops things like that from slipping off the radar. People have to stop simply seeing insignificant, low and high. There is a world of mediums and they're some of the most crucial; the overlooked. Whilst the arguments rage over the insignificant etc etc, I do hope that everyone has used risk assessment in their workplaces to identify the IMPORTANT stuff first. If you have and you work down the task list in the right order, it becomes apparent very quickly where your own line of insignificance falls. It's when you start running out of anything to actually record. Start with 'making cups of tea and sharpening pencils and you will be wallowing around in this for another decade. Chris Jerman CFIOSH
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#20 Posted : 12 May 2008 15:53:00(UTC)
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Posted By GeoffB4 Chris, this is an informal discussion so why do you feel the need to put your membership grade in?
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#21 Posted : 12 May 2008 16:39:00(UTC)
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Posted By Robert K Lewis Chris has it just about right. Although not explicit the Management Regs do actually require you to identify the significant risks and in order to do this you will need to evidence a consideration of ALL risks. It is the Hazard based approach that the HSE themselves drive forward that bedevils much of the risk assessment activity, including the bonkers brigade. No one encounters one hazard alone in any task that I can think of, at least if useful work is being undertaken. If this is so what use is a series of assessments for a series of individual hazards. Assess the hazards of the task and those which are trivial and/or well controlled leave them and record. Those hazards which are not controlled move forward and assess the controls and risk more closely. At the end of the process your RA should provide the basis of a bullet point system of safe working for the task. I still smile at an RA I received last month for lifting a cabin over a building in a pedestrian area. Pedestrian Access was considered a significant risk and the extra control measures put in place were: Ensure there is adequate welfare facilities!! Obviously for the operatives to sit in during any inquiry following a failure of initial control. Happy Days Bob
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#22 Posted : 12 May 2008 16:39:00(UTC)
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Posted By Chris Jerman Because it suits me. I also use my full real name so that people know who they are conversing with. I have nothing to hide and as a member, it is part of my role to be 'available' to other members and the wider community in general. That way they have a degree of reassurance that they are not dealing with someone who is merely serving their own ends or trying to be devious in any way. These pages, as we know, are open and all too often comments are taken out of context. I agree that they are informal, but they should be accurate and well informed nonetheless. People post questions on here, the answers that they receive perhaps being conveyed back to an employer. Therefore knowing that the source is, let's say, verified could matter. There have been many posts about post nominals etc and I feel that at the very least the postings should be Member / Non Member. Anyway, that's a different thread. Chris Jerman blah blah etc
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#23 Posted : 12 May 2008 17:38:00(UTC)
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Posted By GeoffB4 To put it in a nutshell then Chris, it is to give your postings more credibility. Doesn't mean they are right of course, but that's a different discussion.
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#24 Posted : 12 May 2008 18:30:00(UTC)
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Posted By Chris Jerman Quite! Chris
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#25 Posted : 13 May 2008 09:28:00(UTC)
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Posted By Robert K Lewis But seeing as Chartered Fellows are less than 3% of the membership we should be happy to listen to them as they may well have useful experience and ideas to add to a discussion. The use of postnomials is problematic but there are some strange ideas on this forum at times and the value of answers does need to be assessed - it is about assessing the risk of using the wrong ideas. Bob CFIOSH And not afraid generally to let people know but tend to remain anonymous wrt to it :-)
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#26 Posted : 13 May 2008 12:03:00(UTC)
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Posted By Rob T There is also the other proviso in the guidance - that you don't need to RA something associated with everyday life! You know - like walking up and down stairs, picking up pieces of paper, making a cup of tea, running around in a playground (although I haven't done that for a while!) etc. I can't believe that someone would be so obscure that they felt the need to assess the risk of a paper cut. What about children playing on grass and falling over and getting tetanus - to use the same type of scenario as the haemophiliac? That's just conkers bonkers. Sometimes I despair at my own profession. Have the strength of character to take on the insurance companies - they're not H&S experts. I would be quite happy to tell them to go forth if they are wrong as I have done with the HSE on occasion.
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#27 Posted : 13 May 2008 12:30:00(UTC)
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Posted By Raymond Rapp Well said Rob. I too do not get bogged down with trivialities and as professional practitioners we should not be frightened of saying so. Ye Gods, has 'elf & safety not got enough perception problems. In order to gain respect we must earn it. Of course unexpected incidents can arise from trivialities, but we are not expected to have the wisdom of hindsight. The problem is that too much emphasis is put on reactive measures -after the event. Unfortunately, our dear old friends the Regulators, are some of the worst culprits! Ray
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#28 Posted : 13 May 2008 12:48:00(UTC)
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Posted By VJM Bob, I got a risk assessment where death was considered a significant hazard and the control measure was a first aider. That still makes me giggle from time to time. Vanessa
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#29 Posted : 13 May 2008 13:18:00(UTC)
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Posted By GeoffB4 If death was the hazard what on earth was the severity?
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#30 Posted : 13 May 2008 13:19:00(UTC)
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Posted By GeoffB4 Damn, forgot to put down those silly letters.
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#31 Posted : 13 May 2008 13:37:00(UTC)
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Posted By Ron Hunter To Rob T and others, and with reference to my post above, just a caveat that for those whose undertaking includes social care and supporting vulnerable groups, these 'trivial and everyday risks' are very often no longer so.The Risk Group is an important consideration. As I already said, horses for courses!
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#32 Posted : 13 May 2008 13:47:00(UTC)
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Posted By IOSH Moderator We would like to remind all posters that the thread is about "Insignificant Risks" and their recording or otherwise. Those wishing to discuss the use of post nominals should start a new thread in the Members Forum. Further hijacking of the thread on this subject may result in it being locked under AUG 1.
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#33 Posted : 13 May 2008 17:46:00(UTC)
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Posted By GeoffB4 My apologies. I get diverted like this at work as well!
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#34 Posted : 13 May 2008 23:42:00(UTC)
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Posted By Tony Priest It is my understanding that "Every employer shall make a suitable and sufficient assessment of the risks to the health and safety of employees" Therefore all risks must be assessed. But the employer only has to record significant findings. For example I have assessed the risks (in my head) of people getting a paper cut, and deem it to be insignificant to record it in/on a risk assessment form, so just because I dont have a formal risk assesment recorded for the task, it dosent mean that the risks have not been assessed. Remember we carry out a risk assessment every time we cross the road. Therefore andyp I do not think that this is a catch 22 because we are not ignoring insignificant risks we are just not recording them.
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#35 Posted : 14 May 2008 07:40:00(UTC)
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Posted By Chris Jerman Spot on Tony - the point here, as I have said before, is that your task identification process should be designed to pick up the activities that your people do from which you decide which of those would need written records. The remainder stay on the list as a demonstration that you considered it, but there was nothing significant to record. Otherwise the accusation would be "No you didn't - you're making that up!" This is called a plan. Even without any assessments to your name, you could demonstrate which ones you were going to write and the order that you are going to write them in. How many companies have a list of the assessments that they have written but not of the ones that they decided not to record? If something were to occur, you could still prove that you were going to get there and why there more important ones to write first. Your observation NSF no significant findings IS you assessment, done in your heads - perhaps, but still recorded. It also demonstrates the lengths that you went to in looking and underpins the decisions made over those that ARE significant - ie the important ones. Chris
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#36 Posted : 14 May 2008 07:43:00(UTC)
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Posted By Mark Want I agree that It is down to the assessor to deem something insignificant when carrying out the assessment, a paper cut that occurs once in while in an office environment could be deemed insignificant, but would it be if it happened in a HIV laboratory? We can all make comments form our own experiences but one size does not fit all in this business, this is why we do what we do. Good thread Mark
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