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#1 Posted : 31 May 2022 12:24:14(UTC)
Rank: New forum user

How do others feel about documenting significant risks on a register (i.e a spreadsheet) in a similar process to project management risk register.  My thoughts are that all significant hazards can be collated in one register for a number of different tasks in a large multi discipline factory.  The sheet could document the work areas (maybe even have a sheet for each work area e.g  production, loading, finishing etc) then list the hazards and controls on that particular sheet.  The filters on the headings could then be used to drill down to a particular task.  so if, say an insurer wanted to see the risks for a particular task, then we could apply the filter and essential show them all the hazards and control associated with that task.  My main reason for this proposed approach is to help our supervisors and operatives in the hazard identification process.  As the workplace evolves, there may be another hazard identified (yes people, sometimes the workplace changes without warning or proper planning).  We can then add any additional hazards and controls to the register.  If there are any additional controls to be put in place then these could be noted down and then reflected as a number in another column.  We would then have anohter column which records how many of the controls have been implemented, so for example 5 controls required,  next column tells us that only 3 have been impleented and 2 are still required  (we could even apply a percentage score to this to highlight how much of our deemed controls are in place) which could help when reviewing the register.

We have many different activities, alot of which require very similar controls e.g. work with overhead cranes and most of the control measures are similar e.g statutory inspections, trained competent operators, pre-use inspections, use of correct lifting accessories etc.  I just cant see the benefit of having multiple risk asessments which state this time after time.  My thoughts are have it all in one place and regularly review the register to check if the percentages of controls in place are increasing.   Obviously, in terms of communication, we would ensure the significant findings are put on the SSOW for the task along with the safe method of working.  I get the impression from our supervisors that they would be comfortable with the process of identifying additional hazards this way, rather than them writing multiple risk assessments, many of which contain the same information on repeat.  Any thoughts?  I hope I have explained this relatively clearly.

Ian Bell2  
#2 Posted : 31 May 2022 12:55:12(UTC)
Rank: Super forum user
Ian Bell2

Not so sure there is anything new here.

Having a risk register as described is common practice.

Excel is ok for very simple databases, but its not really a database program. Its not very user friendly when trying to do more complex searches much beyond simple filtering.

Even Access does a better job, as its a database program, if you take the time to develop a database with the reuired tables and search queries.

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bradaz1 on 31/05/2022(UTC)
#3 Posted : 31 May 2022 15:15:55(UTC)
Rank: New forum user

So no issues in reality to providing a risk assessment (not worried about HSE as we would have the significant risks identified and documented in this and the SSOW)  more for insurers, auditors etc.  I have been through numerous threads on these forums and cannot see myself why this would not constitute a suitable and suffiicent risk assessment format. I totally see where you are coming from in terms of using Access as a database.  I am looking at various software solutions online and have seen one where users could actually identify hazards, complete a form on a phone / tablet with their relevant control measures in, which would then be automatically added to a cloud spreadsheet database.  The submission would then be reviewed by H&S bods after referring to relevant standards etc.  The majority of the register would be taken from our current risk assessments, all the while removing unnecessary duplicate entries from similar activities. 

peter gotch  
#4 Posted : 31 May 2022 16:08:29(UTC)
Rank: Super forum user
peter gotch

Hi bradaz

1. I wouldn't even bother to worry about what HSE might think. If something goes wrong, HSE's default these days if going for enforcement action appears to be to apply hindsight and conclude that the risk assessment was NOT "suitable and sufficient" - then you have to make the decision as to whether to challenge whatever action they might take.

2. If you have tasks A, B and C each of which require the use of an overhead travelling crane, you don't need to repeat what you say about working with OH cranes in each task risk assessment as you can have a risk assessment for work with OH cranes that remains in place UNLESS you think that something else needs to be done in relation to the use of the crane.

3. In terms of 2, it doesn't make one iota of difference if you use a piece of paper to document your task based risk assessment (or method statement or SSOW or whatever you want to call it) or go techie on the cloud. Many things on the shop floor about can be about simply adapting generic risk assessments to the specifics at the time of each task.

4. Do you really want to a H&S bod to review each and every task risk assessment? Do they actually know better than those doing the task how to do it safely? Should the process not be owned as an integral part of the line management function from Board level to coal face? If you insist on putting in a hold point to have an H&S bod reviewing each and every task risk assessment what will almost certainly happen is (A) the job gets held up and/or (B) the sign off by the H&S bod becomes a tick box exercise in which the H&S bod doesn't have the time to properly think through all the variables. We dropped the idea that every construction site with more than 20 workers should have a "safety supervisor" decades ago - revoked with support from both employers and workers as it was counter-productive, partly as it tended to deflect ownership of H&S from the line managment function.

So, wouldn't it be better to enable the line management function to do their own risk assessments and call on the expertise of the H&S bods when they have difficulty in working out what is the optimal way of doing each task?

Edited by user 31 May 2022 16:09:26(UTC)  | Reason: Typo

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A Kurdziel on 07/06/2022(UTC), aud on 11/06/2022(UTC)
#5 Posted : 07 June 2022 08:30:52(UTC)
Rank: New forum user

Many thanks for your input. much appreciated and it shows that it's good to get others viewpoints.  I really should come on these forums more often.  cheers and have a great day.

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peter gotch on 07/06/2022(UTC)
#6 Posted : 11 June 2022 17:05:23(UTC)
Rank: Super forum user

The MHAS regs speak of "a risk assessment". Singular. So in theory, a risk register overview of organisational risk and general broad controls ticks that box. RA done.

I recognise that this may feel too thinly spread for a complex organisation, who may wish to cascade more specific and detailed recorded assessments, however, where do you stop? And whatever you do, the enforcer will just say the RA was not suitable & sufficient. There is a strong chance that this obsession with documenting RAs for everything, all over the place will simply provide more evidence for the enforcer. 

My ideal model would be an overarching RA via a risk register, referencing regulation, and thus satisfying other stakeholders. Then having more local risk discussion and identification of where detailed controls are needed, focussing most on building competence, rather than writing pages of guidance.

The outcome of this could be some (some!) simple guidance for managers, even simpler guidance for workers which is actually related to their training, (outcome = safe systems of work) and a return of emphasis on competent supervision and coaching to improve.

The Risk Register can be done in Excel, seen many versions. The answers - safe systems - can take any form which suits - pictures, tik tok videos, lists of do & donts, wordy documents.

I'll get my coat. . . .

peter gotch  
#7 Posted : 12 June 2022 12:21:46(UTC)
Rank: Super forum user
peter gotch

Hi Aud, sorry but that argument won't stand up in Court.

When interpreting legislation you have to go down three lines of interpretation:

1. What the legislation directly or indirectly says. So in the Health and Safety at Work etc Act 1974, that is mostly in Sections 53 and 54

2. The Interpretation Act 1978

3. Which failing the Oxford English Dictionary.

Here, No 2 is the key:

The 1978 Act says that the singular is to be interpreted to include the plural unless the contrary is clearly intended.

So - "a suitable and sufficient assessment of the risks" in MHSWR can mean however is appropriate.

There is a similar situation with the Construction (Design and Management) Regulations 2015. 

Many read those as if there can only be one of anything whether it be duty holder or deliverable, such as the Health and Safety File.

Very often there are, or should be, more than one of each.


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