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Taylor-Walters25924  
#1 Posted : 21 December 2010 15:35:36(UTC)
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Taylor-Walters25924

I'm just after a bit of clarification please if anyone can offer any advice. We are currently in the process of updating our PoWRA and have come up against resistance from the workforce. Currently the teams are issued with a number of jobs all on seperate job numbers. The teams complete one PoWRA per site. My argument is that the risks change per job/working area, so i'm proposing that they complete a PoWRA per job. This in my opinion, is the only way to capture the risks associated with each task and control/document as appropriate. Any thoughts ???????????
safetyinspector2009  
#2 Posted : 21 December 2010 15:48:23(UTC)
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safetyinspector2009

I agree entirely, they need to be committed to actually complete the POW and not making assumptions based upon previous assessments. We have the same issues here and we are actively issuing POW booklets to staff to ensure they have conducted assessments for each activity where there is clearly some residual risk that needs consideration. Then at regular intervals checks are made on their assessments, to ensure firstly they are doing them and also to ensure they understand the meaning of them and the clear benefits. Ultimately the point is to make them appreciate the risks are being controlled for their benefit and not yours, you agree?
Bob Shillabeer  
#3 Posted : 21 December 2010 15:53:23(UTC)
Rank: Super forum user
Bob Shillabeer

Come off it guys, do you really expect construction workers to complete a written point of work risk assessment that would hold up in court? The employer should undertake any risk assessments even if they are somewhat generic and when he becomes aware that the risk assessment may not fit the actual work being done must review it to check it is ok. The employee would do such a poor job of the RA because he wants to get the job done it would be worthless and if a defence in court was that the risk assessment failed to show the thing that caused the accident it would be deemed insufficient anyway.
SteveL  
#4 Posted : 21 December 2010 16:15:56(UTC)
Rank: Super forum user
SteveL

If you employ me as a groundworker what part of my job description would say complete the site specific RA as your employer cant or wont do it. Any way don't you only have to record significant risks, why make hard work and enemies on site when you want improvement And if that was part of my job, who is going to train me to do it, and if I don't do it how you want it , it wont be right any way.
Ron Hunter  
#5 Posted : 21 December 2010 17:07:48(UTC)
Rank: Super forum user
Ron Hunter

I believe it is the duty of the employer to undertake suitable and sufficient risk assessments, to ensure significant findings are brought to the attention of employees, and to ensure safe systems of work. You seem to describe a process which attempts to delegate this process to the employee. "risk assessment" is a formal process which establishes and confirms safe systems of work, and may be described as a "back office" activity of health and safety management. Such paperwork has no place with the man holding the tools about to do the job. Yes, I would expect my people to be telling me about things they encounter out of the ordinary, however I would expect them to have a suitable forum, method and time to do that, in conjunction with adequate supervision.
kdrew  
#6 Posted : 21 December 2010 17:20:00(UTC)
Rank: Forum user
kdrew

Surely this depends on what you think a point of work risk assessment (POWRA) is for? Most organisations that I have worked for use the POWRA to supplement a suitable and sufficient risk assessment not instead of it. A suitable and suffient risk assessment is produced prior to the work commencing including consultation with the work force, visiting the point of work,examining all available data, method statements, etc. The POWRA is completed, sometimes daily, when conditions or circumstances change that may negate some of the controls identified in the original risk assessment. It's a way of communicating any changes that may have taken place and feeding back to the originator and fits into the monitoring and review process. That's my take on it anyway. Kevin
Bob Shillabeer  
#7 Posted : 21 December 2010 17:24:40(UTC)
Rank: Super forum user
Bob Shillabeer

Regulation 3 (1) of the MHSAW Regs states that every employer shall make a suitable and sufficient assessment of the risks to the health and safety of his employees to whicch they are exposed whilst they are at work; and the risks to thier health and safety of persons not in his employment arising out of or in connection with the conduct by him of his undertaking. There is no requirement placed upon an emploee to undertake any such risk assessment so if an employee refuses to do this because he is not able to through competence in RA or even willingness the responsibility falls directly upon the shoulders of the employer so pushing it to the chap on the front line is likely to mean the RA is insufficent. The fact that anything the employee feels is not as it ought to be should be reported to the employer is a no brainer, but rsponsibility for the RA falls directly upon the employer.
boblewis  
#8 Posted : 21 December 2010 19:29:39(UTC)
Rank: Super forum user
boblewis

This is where I depart with the idea of PoWRAs and say things must be assessed Dynamically once the work is about to start. The task risk assessment is the start point and surely the supervisor would ensure this is correct or else how can the work be safely started. Surely we only need to record significant and potentially ongoing changes to the risk assessment. If we record everything aat this point then the overkill will drive everybody away from the use of any system Bob
Bob Shillabeer  
#9 Posted : 21 December 2010 19:52:07(UTC)
Rank: Super forum user
Bob Shillabeer

You have it exact Bob, the risk assessment should be done before any work starts, well before. Any changes in the conditions at the time work is aboput to start that could affect the controls or safety of the task must be recognised and if necessary lead to a review according to the conditions at the time, but doing a risk assessment every time and laying this responsibility at the door of the operative is wrong and quite frankly does not meet the requirements of the Management Regs.
wclark1238  
#10 Posted : 22 December 2010 09:04:29(UTC)
Rank: Forum user
wclark1238

I'm slightly ambivalent about this. I have implemented a solution that works well for me which allows for operatives to assess risks and to assign scores before starting work (work is of a field service nature and this RA is completed via a PDA script). My motivation is not to use these RAs as something to fulfill the RA requirements of the Management Regs but simply to encourage the operatives to pause before starting work to actually consider the risks associated with their activities. As such I think it works well - it's certainly not a substitute for a 'suitable and sufficient' RA (which is by necessity generic in nature) but it does allow for the operatives to account for site specific issues that may not be covered in the 'proper' RA.
bod212  
#11 Posted : 22 December 2010 09:34:20(UTC)
Rank: Forum user
bod212

I'm with kdrew and wclark1238 on this. POWRA is never intended to devolve responsibility to the guys or be used a suitable and sufficient risk assessment. We use it to augment the job specific risk assessment. It focuses the mind of the work party to the risks they will encounter during the job in hand. It's all well and good saying that a suitable and sufficient risk assessmment shall be carried out well before the work begins but conditions can and do change. The example I'll give is a large industrial site with various activities, contractors, processes, etc. going on at any given time. You can walk the job and risk assess it. You can address interface issues with others. You can brief your guys on the risk assessment. Then when they get to the job in a day, two days, three hours...whatever, the conditions may have changed. The job itself might still be the same but things around the work face could be different from the original risk assessment. Having a POWRA allows other emergent risks to be acknowledged and controlled. The main job specific risk assessment can then be more accurately reviewed based on whats on the POWRA. We use it and it works well. It is not and never has been a substitute for suitable and sufficient risk assessment. And yes, the guys are well coached and deemed competent to complete them. You do get some resistance from time to time but I believe that to a 'people don't like change' situation. It is then necessary for the supervision to coach them otherwise.
bob youel  
#12 Posted : 22 December 2010 09:43:30(UTC)
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bob youel

Taylor - there is some good advice here; as I agree that the primary RA is undertaken before work starts by the appropriate people and dynamic [PoWRA] RA's have a place where unexpected higher risk change is present at the point of undertaking the work Staff should be appropriately trained etc so as they understand RA's and the roles that they [the RA's] play and how to undertake dynamic RA's as needed Its the employers [managements] responsibility to manage e.g. Undertake RA;s etc noting that competence is the main criteria so the staff may undertake them as the most competent people with management acting as facilitators if nothing else and being one of the signatories
Ron Hunter  
#13 Posted : 22 December 2010 10:07:28(UTC)
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Ron Hunter

Employess do not have to understand risk assessments. They have to understand and comply (incorporating effective supervision) the safe system of work in accordance with information, instruction and training. There is a growing trend to attempt to apply a process of "dynamic" risk assessment in every-day trades and work activities which to me is a nonsense and reflects a poor approach by the employer in identifying reasonably foreseeable risks in the first instance. Yes, the employees have a wealth of experience to inform that process, but they do not necessarily need to understand it and they certainly should not be asked to apply it. I believe the principle of "dynamic risk assessment" has a limited and fairly well defined scope of application to areas such as the emergency services, disaster response and the armed forces - all highly skilled, VERY HIGHLY trained and motivated to work effectivelty as a team and in a position to make on-the-spot judgements. That said, we must acknowledge that on occasion these people get it wrong too. On that basis then, there is no justification in the employer attempting to apply this to every day work activities. It seems that many out there have picked up this "dynamic risk assessment" thing and are attempting to run with it. Don't join that race.
Bob Shillabeer  
#14 Posted : 22 December 2010 10:39:15(UTC)
Rank: Super forum user
Bob Shillabeer

Absolutly correct Ron, if an employer requires his staff to undertake a a PoWRA he is failing in his prime duty to assess the risk as far as is reasonably practicable because if he is saying the employee must do such a risk assessment he is failing to comply with the law. Yes there may be some circumstances that arise that are not previously known about but would you like to see an employee undertaking the work without you knowing that this additional risk being present, not me I would say.
walker  
#15 Posted : 22 December 2010 10:47:04(UTC)
Rank: Super forum user
walker

The mistake people make in their responses on this forum is that they forget that its a big diverse world out here, the replies might be correct in your tiny domain but not applicable elsewhere. POWRA has a place in "my world" it's for our highly skilled & trained operatives to evaluate the RA and decide if the current situation is fully covered by the RA. Abnd before you ask, yes they are skilled enough to do this. Its never used as a substitute for a suitable & sufficent RA. Several responses here match my thinking. People who "trot" out the regs demonstrate a lack of understanding about how H&S really works.
Bob Shillabeer  
#16 Posted : 22 December 2010 11:01:41(UTC)
Rank: Super forum user
Bob Shillabeer

Walker you are very privilaged to have people who understand exactly what they are doing, but there are many others out there who do not and it is those that this thread is concerned about. There is a very serious risk that the responsibility for undertaking risk assessments (of any type) is being pushed out to the front line staff, this is not enough under the law and no one can get away from that situation. The law is the first thing everyone must comply with so the risk of diluting this is very dangerous for both the company concerned and the employees.
kdrew  
#17 Posted : 22 December 2010 11:41:15(UTC)
Rank: Forum user
kdrew

I have been involved in too many accident investigations where circumstances and hazards have changed as the work has progressed and those involved have carried on regardless for whatever reason. None of us are perfect and can forsee all of the possible hazards and risks before work commences and it isn't always possible for us to be present overseeing all of the work all of the time. Proactive POWRA by the operators and supervisors actually doing the work is an effective way of managing the health and safety of the guys out there at the sharp end. Sure, it's percieved by some as a nuisance and nothing more than a tick box exercise but it can and does help if you can get the operators to understand why. I'll say again, it is not and was never intended to be a substitute for a suitable and sufficient risk assessment as required by the regulations.
Ron Hunter  
#18 Posted : 22 December 2010 11:55:00(UTC)
Rank: Super forum user
Ron Hunter

Walker, it seems that you have the necessary attributes in your workforce (positive culture, highly trained, highly motivated) to make this work and presumably a work environment that deems it necessary. Fair play to you. It would seem however that the original poster does not enjoy these same attributes within his workforce and hence my notes of caution and opinion. I do have a fairly wide view of the world of work and I'm all for "horses for courses" however I do think though that this whole "dynamic risk assessment" thing is being taken too far in some quarters, and I've first hand experience of employers attempting to "cop out" by attempting to apply this inappropriately. I'm only attempting in some small way prevent others from making those same mistakes.
Taylor-Walters25924  
#19 Posted : 22 December 2010 12:09:07(UTC)
Rank: New forum user
Taylor-Walters25924

kdrew wrote:
I have been involved in too many accident investigations where circumstances and hazards have changed as the work has progressed and those involved have carried on regardless for whatever reason. None of us are perfect and can forsee all of the possible hazards and risks before work commences and it isn't always possible for us to be present overseeing all of the work all of the time. Proactive POWRA by the operators and supervisors actually doing the work is an effective way of managing the health and safety of the guys out there at the sharp end. Sure, it's percieved by some as a nuisance and nothing more than a tick box exercise but it can and does help if you can get the operators to understand why. I'll say again, it is not and was never intended to be a substitute for a suitable and sufficient risk assessment as required by the regulations.
Kdrew - Exactly correct, the PoWRA is not and never intended to be a substitute for the risk assessment (which the company provides but are very generic) but to be used as a proactive tool by operatives to monitor, review and document the changing risks associated with their specifc task on site. Surely as safety professionals we must agree that this is a good thing and helps promote a proactive approach to health & safety and could prevent an incident occurring. All good advice though chaps, thanks very much
walker  
#20 Posted : 22 December 2010 12:14:03(UTC)
Rank: Super forum user
walker

Ron, IMHO Dynamic risk assessment is not the same thing as POWRA Your reading of the OP is different to mine taylor walters - I'll pm you later for an address to send you my POWRA booklet
Canopener  
#21 Posted : 22 December 2010 13:50:27(UTC)
Rank: Super forum user
Canopener

Some interesting views and I tend to share those of Gerry D, kdrew and the original poster. It’s all well and good saying that the responsibility lies with the employer, but in practical terms who or what is the employer in this context? My understanding is that depending on the circumstances, the HSE expect managers and supervisors to manage the health and safety of their staff; radical stuff hey? Arguably this is the only realistic and practical way of managing the whole health and safety process. Therefore many risk assessments are carried out by managers and supervisors (who are employees in themselves), acting on behalf of and with the ‘authority’ of the employer, within the context of reg 7. It seems reasonable to me that employees, usually someone with supervisory responsibilities, but in any case someone is competent, can and should be able to carry out POWRA or dynamic RA. In many cases, this is the only realistic, practical and pragmatic approach that they can take for numerous scenarios. With my feet firmly placed on the ground, while POWRA and DRA should not be a substitute for carefully considered generic RA’s and carefully constructed precautions and SSOWS, I suggest that that it is an essential and proactive tool that realistically plays an important part in the overall RM process.
SteveL  
#22 Posted : 22 December 2010 13:58:15(UTC)
Rank: Super forum user
SteveL

I presume, that reg 10, providing the RA has been overlooked then
Canopener  
#23 Posted : 22 December 2010 14:29:30(UTC)
Rank: Super forum user
Canopener

stevel - I am not sure who that is aimed at? Which reg 10 do you refer to? MHSWR R 10 refers to information for employees! Perhaps you might care to elaborate?
SteveL  
#24 Posted : 22 December 2010 15:11:19(UTC)
Rank: Super forum user
SteveL

Phil Rose You said "Therefore many risk assessments are carried out by managers and supervisors (who are employees in themselves), acting on behalf of and with the ‘authority’ of the employer, within the context of reg 7. It seems reasonable to me that employees, usually someone with supervisory responsibilities, but in any case someone is competent, can and should be able to carry out POWRA or dynamic RA" What it was aimed at Phil is Regulation 7 MHSWR states The employer shall ensure that- (a) any person appointed by him in accordance with paragraph (1) who is not in his employment- (I) is informed of the factors known by him to affect, or suspected by him of affecting, the health and safety of any other person who may be affected by the conduct of his undertaking, and (ii) has access to the information referred to in regulation 10; Regulation 10 MHSWR states (1) Every employer shall provide his employees with comprehensible and relevant information on- (a) the risks to their health and safety identified by the assessment; (b) the preventive and protective measures; Not the employee will conduct the POWRA
SteveL  
#25 Posted : 22 December 2010 15:18:12(UTC)
Rank: Super forum user
SteveL

Phil sorry quated wrong part reg 7 should have said (1) Every employer shall, subject to paragraphs (6) and (7), appoint one or more competent persons to assist him in undertaking the measures he needs to take to comply with the requirements and prohibitions imposed upon him by or under the relevant statutory provisions
walker  
#26 Posted : 22 December 2010 15:25:44(UTC)
Rank: Super forum user
walker

SteveL All the supporters (in this thread) of POWRAs have repeated time and again "POWRA should never be used as a substitute for a suitable & sufficent RA." Which bit of that sentence don't you understand?
SteveL  
#27 Posted : 22 December 2010 15:39:46(UTC)
Rank: Super forum user
SteveL

Walker the bit that says that I have to stand there and listen to the repeated POWRA that tells me the same info that was given yesterday and the day before and no doubt tomorrow. Which by the way was the same info I was given when I had to sign to say that I had read my RA. So if your not substituting the RA what are you doing other than wasting time
Canopener  
#28 Posted : 22 December 2010 15:56:19(UTC)
Rank: Super forum user
Canopener

Steve Thanks for both posts, they are more helpful than the ‘one liner’ about reg 10! It’s one thing to quote regs but another to put them into the context, and to apply this to the practical world of work. The point I am trying to make is who is this employer who carries out the risk assessment? I suggest that the employer is this case is a somewhat ‘nebulous’ entity and that in many cases the ‘employer’ in this context is often an employee, (usually but not always in a management or supervisory position) who may or may not have been formally appointed under reg 7. In most large organisations it is common and accepted practice for employers to use the safety policy to delegate the task of carrying out risk assessments and ultimately the management of risk to (perish the thought) managers, who are of course employees of the organisation. This is in most cases the only realistic and pragmatic way to achieve the goal of reg 3 and countless other regs. Assuming that the ‘safety officer’ will do them all (on behalf of the employer?) is a throw back to the 60’s and before and would have Lord R turning in his resting place. As I have already said, with my feet planted firmly on the ground, I suggest that for the majority of organisations, an employee of that organisation will carry out the formal RA’s, generic RAs, DRAs and POWRAs. I see little other choice in most circumstances. Or have I finally lost it? Again, quoting regs is fine, but I suggest that a significant part of our job is to put them into context of the workplace, and advise/demonstrate how they may be applied in a practical and pragmatic way. It would be interesting to hear from you and others who you/they think the ‘employer’ is in this context, i.e. who should carry out the RA’s?
SteveL  
#29 Posted : 22 December 2010 16:01:21(UTC)
Rank: Super forum user
SteveL

Phil Sorry about the one liners, am more used to just short and quick.I assume to much sometimes, I know what I mean and so should every body else. Still assume made an ass of u and me
jay  
#30 Posted : 22 December 2010 16:24:07(UTC)
Rank: Super forum user
jay

There are several versions of this termed as "last minute risk assessment" (LMRA), "Take Two", "Take Five" etc. The principle behind all of them is that they either supplement task/activity risk assessment (some of the generic) and are used as reminders/checklists. There is nothing wrong in using them as long as suitable and sufficient generic risk assessments have been carried out for the activities and those undertaking these assessment are properly trained and competent.
chris.packham  
#31 Posted : 22 December 2010 16:25:35(UTC)
Rank: Super forum user
chris.packham

Phil I work on the philosopy that: "He who controls how the work is done needs to be the person who carries out the risk assessment." It many situations it is unreasonable to expect the health and safety advisor to be aware of every small change that takes place locally, particularly where the organisation's operations are spread over a wide geographical area and the health and safety advisor is located at HQ. The local/department/site manager will often be confronted with situations that require a variation on what might have originally been the result of the risk assessment. If he or she takes a decision to make a change they need to be able to assess any change in the risk that results and act accordingly. Naturally, we cannot expect every one of them to be fully competent health and safety practitioners, but we can consider implementing a system that enables them to identify whether/when they need to enlist the professional help from the health and safety specialist. In my particular area of health and safety I believe that this is possible. Chris
Ant Elsmore  
#32 Posted : 22 December 2010 17:05:02(UTC)
Rank: Forum user
Ant Elsmore

The overall culture of the business will dictate whether these will be of any benefit, as it will be down to the wider issue of training, competence and willingness to work safely that will affect the decision making the worker undertakes. POWRA are only ever going to be records of the concious decisions the worker would have made anyway. It was noted by kdrew that in investigations workers carried on regardless of changing situations and had an accident. I think it's fair to say any of these workers would have carried on regardless of what box they ticked on form number xxx of the day. If your workforce is trained well enough to make effective use of a POWRA system they are undoubtably well trained enough to read a generic SSoW and apply good risk aware reasoning to the job they undertake without having to complete additional paperwork. I would suggest having a near miss or unsafe condition report for the occasional time a real problem was identified which is the ultimate goal of the forms anyway. Minimise the paperwork, spend the extra money on training.
boblewis  
#33 Posted : 23 December 2010 08:24:11(UTC)
Rank: Super forum user
boblewis

I am still uncomfortable where this thread is going. 1) For me dynamic assessment is NOT just for very high risk situations such as fire fighting - It is about a continuous assessment being done by the operative as the work proceeds. 2) DRA notes the deviations from the expected and asks the operative if what is expected is actually what is happening 3) It is not sufficient just to do such an assessment immediately prior to work, it is ONGOING On the above bases it cannot be written. It can however provide potentially useful information on any need for change to the formal task Ris Assessment Bob
bob youel  
#34 Posted : 23 December 2010 08:36:42(UTC)
Rank: Super forum user
bob youel

BobL the only thing I disagree with is the 'it cannot be written' statement as our lads in high risk areas do write down all significant situations as an on going action as they work and stop work where real significant hazards are discovered etc which have not been accounted for previously Regards B
boblewis  
#35 Posted : 23 December 2010 09:49:12(UTC)
Rank: Super forum user
boblewis

BobY We are not that far apart - in my view the significant that cannot be controlled must lead to a cessation of work until the immediate TRA is formally reviewed. But I would not alter the base TRA formally until the changes/hazards/environment etc are changed in some long term manner. The real importance is however the ongoing nature as we have discussed and agreed. Bob
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