Health and Safety Management

Risk Assessments and Managing Health and Safety at Work

Policy

We will examine all workplaces and activities under our control to assess the risks to the health and safety of employees or others who may be adversely affected by our activities.  We will ensure that the significant findings of the assessments are recorded and the control measures identified are fully implemented.  We will review and amend all assessments where necessary.  We will apply the principals of prevention of risk detailed in the regulations to all assessments and ensure that effective arrangements are in place for the planning, organisation, control, monitoring and review of the preventative and protective measures.  We will ensure that health surveillance is provided for all employees where required and that procedures are in place for serious and imminent danger.  We will appoint a competent person to provide health and safety assistance to enable compliance with the requirements of the Regulations and ensure that contact with external services are arranged.  We will ensure that all employees are given comprehensive and relevant information on the results of the risk assessments and the requirements of the Regulations.  We will ensure co-operation and co-ordination with other employers regarding the requirements of the Regulations and ensure that the employees of those employers are provided with appropriate health and safety information. We will ensure that all employees are competent to undertake their duties and are provided with appropriate information, instruction and training.  We will ensure that all employees comply with their duties under the Regulations and that specific arrangements are in place to ensure the health and safety of temporary workers.  Specific assessments of the risks to new and expectant mothers will be carried out where required and arrangements for the protection of young persons will be implemented as necessary.

Arrangements for Risk Assessments

The Risk Assessment Co-ordinator will ensure that:

1.1          An initial audit is carried out to identify significant hazards, determine the adequacy of existing control measures and highlight areas where further assessment is required.

1.2          Significant findings of risk assessments are recorded to show how the risks arise and how they impact on those affected, that a proper check has been made and to assist in future monitoring and review.

1.3          Implementation of control measures are scheduled on an action plan and sufficient time and resources allowed for their completion.

1.4          Sufficient guidance, training and support are given to those in charge of activities to ensure their competence to assess risk, and their awareness of the requirements of relevant legislation.

1.5          Information on risks and the preventative and protective measures are communicated to employees in a clear and easily understood manner, limited to what is relevant and necessary to ensure health and safety. Consideration is given to any employees with specific needs such as a language, visual impairment, hearing deficiencies or learning difficulties.

1.6          Co-operation and co-ordination of activities takes place where our activities and those of other people interact to ensure that respective obligations are met.  Relevant information on hazards and precautionary measures are exchanged and arrangements for ensuring health and safety agreed prior to the work or activity commencing.

1.7          Levels of competence required for activities are identified through risk assessment and any training needs are met.

1.8          The control measures implemented are monitored, including fire precautions and emergency measures, to maintain their effectiveness.

1.9          Risk assessments are reviewed and revised at appropriate intervals.

1.10       Competent technical advice on health and safety matters is provided to assist in the effective management of health, safety and welfare matters.                      

Guidance and Records

The Risk Assessment Process

A risk assessment is a systematic examination of the premises and all activities associated with the business to help determine what measures are necessary to comply with duties under the Health and Safety at Work Act 1974 (HASAWA) and also with more specific duties in the various regulations made under its umbrella and other Acts.

A ‘suitable and sufficient’ risk assessment must:

• Identify risks arising from the work.
• Keep the level of detail proportionate to the risk.
• Ignore routine activities associated with life in general unless the work activity compounds or significantly alters those risks.
• Consider all those who might be affected (employees, visitors, contract cleaners, etc).
• Include what the employer could reasonably be expected to know e.g. from supplier manuals, trade press, national standards and good practice.

There are five recognised steps to carrying out risk assessments:

Step 1	Identify the significant hazards.
Step 2	Decide who might be harmed and how.
Step 3	Evaluate the extent of the risk and decide whether existing precautions are adequate or if more should be done.
Step 4	Record the significant findings where there are five or more employees.
Step 5	Review the assessment periodically and when there are any significant changes.

Each of these steps is dealt with in more detail below.

Step 1: Identifying Hazards 

A hazard is something with the potential to cause harm.

Significant hazards may be found through deficiencies in the workplace environment, slipping and tripping hazards, inadequate fire precautions, unsafe equipment, electricity, chemicals, poor lighting, manual handling, work practices etc.

Refer to:

• Suppliers as they must provide health and safety information about the products they supply
• Manufacturers’ instructions and data sheets
• Specific acts or regulations to be complied with as these may help identify specific hazards
• Approved codes of practice, national standards, trade association as these will help identify appropriate control measures
• Accident book records.

Check:

• Non-routine operations e.g. maintenance, use of temporary staff
• Consult employees to ensure all aspects of the work activity are reviewed.

Step 2: Who might be harmed?

Anyone who might be affected by the hazards identified will need to be considered i.e. employees, non-employees and any others in the workplace.

Groups who may not be in the workplace at the time of the assessment will also need to be considered, e.g. cleaners, maintenance personnel.  Formal provision will be needed to protect visitors and contractors on the premises or sharing the workplace.

Some groups of people are recognised as being vulnerable and therefore more susceptible to risk and require particular consideration.

These include:

• Young persons and inexperienced workers
• Temporary workers
• New or expectant mothers
• Those with special needs or disabilities
• Lone workers.

Specific requirements are described below.

Young Persons

No ‘young person’ (below the age of eighteen) should be employed without first making, or reviewing, risk assessments and taking into account:

• Their inexperience, immaturity and lack of awareness of risks
• The fitting-out and layout of the workplace and their workstation
• The nature, degree and duration of exposure to physical, biological and chemical agents
• The form, range and use of work equipment and how it is handled
• The organisation of processes and activities
• The extent of health and safety training provided or to be provided
• Specific risks defined in relevant legislation.

The findings of the assessment will be recorded and where significant risk remains no child (under compulsory school age) will be employed to do the work.

Other young persons cannot do the work unless it is necessary for their training, they are supervised by a competent person, and the risk is reduced to the lowest level reasonably practicable.

Temporary Workers

The levels of competence determined through risk assessment are also applicable to temporary workers.  The employment business through which they are recruited must be informed of the qualifications and skills required and aspects of the work that might affect health and safety.

The ‘user employer/organisation’ must provide temporary workers with induction and specific training on the risks to which they are exposed and the necessary control measures, including personal protective equipment and arrangements for emergency evacuation.

Where personal protective equipment (PPE) is necessary and not commonly available within the workplace, the employment business must ensure it is provided.

New or Expectant Mothers

Where there are women of childbearing age and any aspect of the work could involve risk to the health and safety of a new or expectant mother or to that of her baby, risk assessments should be used to identify any additional precautionary measures.  

Once notified in writing that an employee is pregnant, has given birth within the previous six months, or is breast-feeding, the employer must take appropriate action.

However, where further action will not avoid risk, and if it is reasonable to do so, the employer should:

• Alter the working conditions or hours of work, or;
• Offer her suitable alternative work if available, or, if it is not;
• Suspend her from work.

Special Needs and Disabilities

Where appropriate, the risk assessment should identify any reasonable adjustments necessary to our arrangements or physical features of the workplace, to remove any disadvantage to people with special needs or disabilities.  Many people may need only minor adjustments.

Lone Workers

Where there are people working by themselves without close or direct supervision, including anyone working away from their fixed base, the risk assessments should firstly determine whether one person can adequately control the risks, and then, what particular or additional measures are required to control them.  The precautions should take account of the work activity and foreseeable emergencies such as fire, equipment failure, illness and accidents.

Step 3: Evaluating the Risk

Risk expresses the likelihood of harm arising from the hazards identified and therefore the following must be considered when evaluating the risk:

• Are there foreseeable risks arising from the hazards?
• Who is affected and how often?
• What is the nature and extent of the risk, taking into account existing control measures?

Where control measures exist, evaluate the remaining risk:

• Check the effectiveness of the preventive or precautionary measures
• Observe actual practice, which may differ from manuals or procedures
• Is the remaining level of risk acceptable/negligible?
• What more could be done to eliminate/reduce it?
• How can the effectiveness of control measures be maintained?

Step 4: Record Significant Findings

To be considered suitable and sufficient the risk assessments will need to:

• Identify the significant hazards
• Identify the people affected by the hazards
• Identify the significant risks arising out of the work
• Identify existing preventive and precautionary measures for controlling risks
• Identify further action required to eliminate or reduce risks
• Stipulate reasonable timescales for implementation
• Provide sufficient detail to demonstrate a suitable and sufficient risk assessment and to allow future review.

Step 5: Review and Revision

Risk assessments should be reviewed at intervals dependent upon the type of work and degree of change likely to occur as well as on the timescales indicated in the risk assessment action plan.

Significant changes, where the risk assessment may no longer be valid, to the work method, equipment or processes, or where trainees or other inexperienced employees have been introduced, should also prompt a review of the relevant risk assessments.

Accidents and incidents may also prompt a review of related risk assessments to ensure they sufficiently cover the hazards and necessary control measures and that the requirements are fully understood by the workforce.

Use of Risk Assessment Forms

An initial rough assessment may be made to help identify significant hazards. Then, using the risk assessment forms provided carry out a more detailed assessment of each significant hazard or activity, e.g. collecting broken glass, working at height.

• Identify the hazards associated with each activity, e.g. falls from height, and consider whether they can be eliminated or replaced with something safer
• Identify the different groups of people at risk
• Consider each group, list existing control measures to protect them on the form and tick the ‘Existing/Proposed’ column to signify this
• Taking into account the existing controls listed, determine the severity of any harm and the likelihood of this happening if no further action were taken, then estimate the overall risk rating which will either be High, Medium or Low
• Consider whether the existing controls meet standards set by legal requirements, Approved Codes of Practice or best practice

For example, a machine may be safeguarded sufficiently to protect the operator and others who may gain access.  However the risk is only controlled while the safeguards are in place and working effectively.  The assessment should consider what measures are required to ensure and maintain effectiveness, such as regular inspection and testing, and that all aspects of the activity are considered e.g. what happens during maintenance?

• Determine what further measures are required to reduce the risks as far as reasonably practicable.  List them under control measures, with a ‘P’ against each of them in the Existing/Proposed column
• Review all control measures listed, together with the overall risk rating and where appropriate propose a reasonable timescale for implementation.
• The assessor should sign and date the form.  If no further action is required the Y at the foot of the form should be deleted and the date of the next review (e.g. a year from the date of the assessment) inserted.  Where additional control measures are indicated, the N should be deleted and proposed measures transferred onto the Action Plan. Reasonable timescales should be set for implementation and the Action Review dates on the risk assessments set accordingly.
• The Action Plan should be monitored according to the proposed timescales and once improvements have been made, the relevant risk assessments reviewed and revised.  The assessor should then complete the final column on the risk assessment form to verify that the risks have been reduced to an acceptable level, delete the Y to indicate that no further action is required and specify the ‘next review date’.

Implementing the Control Measures

The principles to be applied when implementing preventive and protective measures to control risks are as follows:

• Avoid a risk altogether if possible e.g. by not using or stocking a particular dangerous substance, contracting out a hazardous operation
• Combat risks at source, rather than by superficial measures. So, if steps are slippery, treating or replacing them is better than a warning sign
• Adapt work to the individual, through consultation on the design of workplaces, choice of work equipment and the choice of working and production methods
• Use technological and technical advances, which often offer opportunities for improving working methods and making them safer
• Implement risk prevention measures in a logical and consistent manner to progressively reduce those risks that cannot be prevented or avoided altogether, and to take account of the way work is organised, working conditions, the working environment and any relevant social factors
• Employees must be made aware of what they are required to do
• The avoidance, prevention and reduction of risks at work must be accepted throughout the organisation and apply to all its activities in order for a positive health and safety culture to exist

Monitoring Control Measures

Even where suitable and sufficient risk assessments have been made, adverse events may occur.  The control measures, whether engineering controls or safe working procedures, must therefore be monitored to check and maintain their effectiveness. This proactive monitoring is necessary for accident and ill-health prevention and the risk assessment will identify the frequency required.

Near misses, accidents and cases of ill-health will be investigated to determine underlying causes and appropriate improvements.  By definition this reactive monitoring takes place after an event and is therefore most effective when applied to near misses.

The results of both proactive and reactive monitoring will prompt a review of the relevant risk assessments and revision of the safe systems of work where deficiencies are found.

Risk Assessment in Practice

1. Identify significant hazards:   

Walk around the premises (inside & out)   

Review injury/ill health records.    

Look for significant hazards, whilst dealing with small hazards immediately. Examples:  

• Slips and trips
• Moving parts of machinery
• Vehicles (e.g. fork lift trucks)
• Poor lighting or temperatures
• Dusts and fumes
• Noise
• Work at heights
• Specific task analysis

2. Identify people who may be harmed:  

Consider both routine and non-routine  operations:  

• Operators

• Cleaners
• Maintenance personnel
• Young or inexperienced workers
• Contractors
• Visitors
• Lone workers
• Those with disabilities

3. State existing control measures:    

• Consider the worst possible outcome if no further action is taken.
• Evaluate the level of remaining risk to those identified and
• Assign a risk rating and action level e.g. High Risk = immediate action to eliminate or reduce the risk.

4. What further control measures are needed to eliminate or control the risk?

• Remove the risk completely
• Prevent access e.g. guarding
• Further training
• State an appropriate timescale for action and transfer to the action plan.

5. Some hazards and certain regulations

e.g. COSHH, DSE, Manual Handling will require in-depth assessments, procedural policies & written guidelines.

6. Use a step-by-step approach to assess the hazards associated with the use of machinery or hazardous processes to ensure safe working, from setting-up and operation to locking off for maintenance.

7. Assessments must be suitable & sufficient, not perfect.  

Key points:

• Are precautions reasonable?
• Is there a record to show that a proper assessment was made for inspectors and any civil liability which may arise?
• Monitoring and review information recorded

8. Monitor control measures and review the assessments:

• If developments suggest it may no longer be valid
• On change of process, equipment or new employees
• Periodically to ensure they are still valid
• Following accidents and near misses. Ask your consultant to review them with you.

Consultation with Employees

Policy

We recognise the importance and benefits to be gained by consultation with our employees on all health and safety matters.  We will ensure that arrangements are in place to consult our employees on the introduction of any measure at the workplace which may substantially affect the health and safety of those employees, our arrangements for appointing a competent person, the planning and organisation of health and safety training and the consequences of introducing new technology into the workplace.  We will ensure that all employees with whom we consult (or their representatives) are provided with sufficient information to enable them to fully and effectively carry out their functions.  We will provide employee representatives with information on reportable accidents and allow them to make representations on general health and safety matters, potential hazards and dangerous occurrences in the workplace.  We will allow employee representatives to consult with inspectors from the enforcing authority and ensure that they are adequately trained to fulfil their role.  We will meet any reasonable costs associated with such training and allow time off with pay to enable the representative to perform their functions.  We will deliver information to workers who do not speak or read English through a translator or we will use visual presentations, rather than delivering written or oral instructions. We will also make use of photographs and diagrams in our work instructions etc. Where the use of safety signs and signals are necessary within the workplace, changes will be made where necessary.

Arrangements for Consultation with Employees

The Consultation with Employees Co-ordinator will ensure that: 

1.1 Arrangements are in place to consult employees or their representatives on health and safety issues.

1.2  Consultation takes place on the arrangements for appointing a competent person.

1.3 Employee representatives are provided with sufficient information and training to enable them to carry out their functions effectively.

1.4 Employee representatives are provided with information on reportable accidents.

1.5 Employee representatives are encouraged to make representations on general health and safety matters, potential hazards and dangerous occurrences in the workplace.

1.6 Employee representatives are allowed to consult with inspectors from the Enforcing Authority.

1.7 Employee representatives are allowed sufficient time off from their normal work to allow them to perform their functions.

1.8 Where workers do not speak or read English, effective arrangements are established, such as a translator or translated or graphic documents and signs, to successfully communicate our requirements, particularly for health and safety.

Guidance and Records  

The simplest way to involve employees is to talk and listen. It is important to do this, not only because the law requires it, but also because everyone from managers to individual employees can play a part in getting health and safety right. Employees often know best about the health and safety issues and how to deal with them.  There is also evidence to show that businesses which involve workers in managing health and safety actually have better health and safety standards, better productivity and a more motivated workforce.

Consultation can simply mean talking to your employees regularly and considering their views before you take decisions about health and safety.  It can be more effective to have a simple process, rather than something complicated.

Consultation does not remove your right as an employer to manage.  You must still make the final decision, but talking to your employees is an important part of successfully managing health and safety.

In addition, as an employer you have a legal duty to display the Health and Safety Law poster in a prominent position in each workplace or provide each worker with a copy of the equivalent leaflet outlining British health and safety laws.  The poster, pocket cards and other formats can be ordered from HSE Books (https://books.hse.gov.uk/) and are distributed by and booksellers.

What must you consult about?

You must consult with your employees on the following:

• any new measure which may substantially affect their health and safety at work, for example new equipment, new ways of working and new procedures, introduction of new technology
• your arrangements for getting competent people to help you satisfy health and safety laws
• the information you must give to your employees on the risks to health and safety arising from their work, measures to reduce or get rid of these risks and what they should do if they are exposed to a risk, including emergency procedures
• planning and organising health and safety training

What information do I have to provide?

You need to give employees or their representatives enough information to enable them to take part in any consultation effectively. This information should include risks, the control measures in place to control these risks and what to do if exposed to a risk, including emergency procedures. This should include such things as copies of risk assessments or accident records.

There are some circumstances where you do not need to provide information e.g. where information was obtained for legal proceedings or it is about a person who has not permitted that information to be handed out etc.

What does consultation involve?

Consultation means giving employees a chance to help you make the final decision.  To enable them to do that you need to provide them with the necessary information in a form that can be easily understood by them.  

Consideration should be given to ensuring employees with low literacy levels, those who have difficulty with English, etc. are provided with information.

Once employees are provided with information, make sure that you allow them enough time to consider the issue and respond with their views.

You should take your employees’ views into account before a final decision is made.  You may not always agree with the views of your employees and you should respond to their concerns and questions, explaining your final decision and why it has been taken.  Feedback to those employees who contribute will let them know that theirs views were appreciated and that their participation has been effective and may encourage other workers to participate.

Employees must not suffer or be penalised as a result of taking part in consultation.

Ways of consulting

You must consult any employees not in groups covered by trade union safety representatives.  You can ask your employees if they would like to be consulted directly or through representatives.  You can consult in several ways, for example:

• Directly with employees using regularly scheduled team meetings, such as toolbox talks, team meetings, etc.
• Indirectly with employees using staff surveys, employee suggestion schemes and notice boards.

You can use direct, indirect or a mix of these methods, depending on your workplace.

Advantages of consultation

Consulting with your employees has a raft of benefits, including:

• Healthier and safer workplace.
• Increased motivation, co-operation and trust.
• Better productivity, quality and efficiency.
• Joint problem solving.
• A stronger commitment to change, procedures or decisions.
• Better decisions about health and safety.

Do you have a health and safety representative?

Health and safety representatives can be either appointed in writing by a trade union (Safety representatives) or elected by the workforce, where the employer has decided not to consult directly (Representatives of employee safety). Such representatives must be provided with help, training and assistance by you, as follows:

• paid time as is reasonable in all the circumstances during their normal working hours for them to carry out their functions
• paid time as is reasonable in all the circumstances for them to undergo training to perform their functions. In the case of elected representatives you should pay any reasonable costs to do with such training, including travel and subsistence costs.
• access to facilities and other appropriate assistance so they can carry out their functions.  This may include
  • a telephone and quiet area where they can have private conversations as part of their role
  • a lockable cabinet or desk for paperwork, records or reference material
  • intranet and internet facilities
  • a photocopier and a noticeboard to circulate information to the employees they represent
  • time with you to discuss health and safety issues.

Foreign workers

Over recent years there has been an increase in the number of foreign workers in the United Kingdom.  These workers, like any other must be fully engaged and consulted on health and safety matters.  As an employer, you must find an effective way of doing this if you employ foreign workers who do not speak, read or fully understand English.  Adequate mechanisms to achieve this may include one or all the following;

• The provision of a translator
• The provision of translated documents – you will need to arrange that such documents are checked for quality and accuracy by a competent person
• The provision of information and instruction using non verbal visual methods, e.g. pictures or signs
• The use of learning materials such as videos instead of written information
• The provision of clear signs and instructions for emergencies
• Use a ‘buddy’ system, pairing less experienced workers with experienced co-workers who speak the same language
• Train supervisors in how to communicate clearly.

It is important that foreign workers have received and understood the information, so you will need to consider how you will ensure and establish that it has been understood.

Safety Training Arrangements

Policy

We will ensure that the capabilities of our employees with regard to health and safety are taken into account when carrying out their work.  We will ensure that adequate health and safety training is provided for all employees on commencement of their employment and on their being exposed to new or increased risks because of a change to their responsibilities, the introduction of new work equipment, changes to existing equipment, the introduction of new technology, changes to existing systems of work or the introduction of new ones.  All training will be repeated periodically where appropriate, be adapted to take into account new or changed risks to the health and safety of the employees concerned and will take place during working hours.  All training will be reviewed regularly and updated to comply with the introduction of new legal requirements as they occur.  Comprehensive training records will be maintained for all employees.

Arrangements for Safety Information, Instruction and Training

The Health and Safety Training Co-ordinator will ensure that:

1.1 The training needs of all employees are assessed and formal training plans are documented.

1.2 New employees are given induction training and are issued with our Code of Conduct booklet as soon as is practicable following commencement of their employment.

1.3 Particular attention is given to the needs of young, inexperienced or vulnerable employees.

1.4 Suitable and sufficient information, instruction and training is given to temporary employees such as agency staff, those on work placement and youth training schemes.

1.5 Managers, supervisors and other persons with designated roles for co-ordinating health and safety receive adequate information, instruction and training to enable them to fulfil their duties.

1.6 No-one is asked, to undertake tasks for which they have not been adequately trained and are not competent.

1.7 Effectiveness of training is measured by continual assessment.

1.8 Training needs are monitored and refresher training provided periodically to maintain levels of competency.

1.9 Comprehensive training records are in place for all employees.

Guidance and Records

Induction Training

Induction training for new employees, including those joining the Company for a short period will include:

• Company and departmental organisation
• Location of the Health and Safety poster and its purpose
• Company and individual responsibilities for health and safety
• Common hazards in the workplace
• Appropriate arrangements from the health and safety policy including:
  • Fire safety and procedures
  • Accident reporting procedures
  • Location of first aid equipment and names of first aiders
  • Welfare facilities
  • Hazard and defect reporting procedures
• A Code of Conduct booklet summarising the essential points.
• Specific training applicable to the work will cover relevant risk assessments and safe systems of working, including:
  • Safe use of machinery/equipment required for the task
  • Safe handling, use and storage of articles and substances
  • Use of personal protective equipment

Individuals will not be allowed to undertake any task until they have demonstrated the level of competence required for the activity and this will be reflected in the level of supervision provided.

The induction process will be adapted as necessary for young or inexperienced persons and those with learning difficulties or other disabilities, in consultation with line management and the individual concerned.

The induction process will also be adapted for those whose work responsibilities change or when new procedures are introduced.

All rules and safe working practices will be clearly explained and the induction record completed only when the individual has demonstrated their understanding.

Training Outline for Directors/Managers/Supervisors

Directors, managers and supervisors are responsible for implementing the health and safety policy and enforcing safe systems of work and will be given sufficient resources to enable them to do this.

Directors, managers and supervisors will receive adequate information, instruction and training as appropriate in the following areas:

• How health and safety is managed within the Company
• Their role and responsibilities for managing health and safety in their work area and for people under their control
• Identifying hazards and assessing risks
• Determining appropriate measures to eliminate hazards or adequately control risks arising from them
• Reactive and proactive monitoring of control measures implemented
• Accident recording and investigation
• The requirements under any specific legislation which is applicable to their role

How to Provide the Right Training

Employers must provide information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable the health and safety of employees.

Training should be documented and subsequently monitored, so refresher training can be provided as necessary.

Any training that is provided must be during working hours and not at the expense of employees.  This may require special arrangements for part time or shift workers.

When considering what training is necessary, the following questions should be addressed:

1.       What training does the Company and its employees need?

• Identify the skills and knowledge that employees need to do their job safely, then review this against skill sets and identify additional training needs
• Review incident statistics, including near misses
• Look at risk assessments, as these often detail training as a control measure
• Consult employees, which should be included as an element in your employee appraisal process. 

2.        What are the Company’s training priorities?

Priority should be given to training that is required by law (e.g. first aid), training required to minimise the risk of serious harm, and training for new starters or those taking on new roles.

3.          What training methods and resources are suitable?

There are various training methods that can be considered, for example:

• ‘Classroom’ training
• Coaching/on the job training
• Providing information and instruction
• E-learning/computer based training
• Distance learning
• Group learning
• One to one learning
• In house training
• Training delivered by external experts.

Employers should also consider who can help them deliver training, for example consultants, manufacturers or suppliers, trade unions, further education colleges, employer bodies etc.

4.       How to deliver the training?

• Training should be clear and information provided must be easy to understand, regardless of the format it is in
• Keep training interesting by using a variety of delivery methods, e.g. group work, games, anecdotes, relating training to the workplace, photographs, physical demonstrations, DVD’s or videos, flip charts, overhead projectors, etc.
• Ensure the training is well planned and the trainer is prepared
• Deliver training at the speed of the employees being trained.

5.       Has the training has worked?

There is no point in delivering a training course if the employees do not understand what they have been trained in, or work in the way that they were trained.  This can be assessed by testing on completion of the training and/or ongoing supervision and monitoring.  Feedback from employees is also important, so any necessary improvements can be made to training courses and any further training needs are identified.

Behavioural Safety

Policy

A significant number of accidents are reportedly caused by inappropriate behaviour at work. We will therefore ensure to promote a culture of safe behaviour in our employees. We will review our procedures and culture to identify any risks to safe behaviours and develop action plans to minimise the risks. We will monitor our employees and where identified provide feedback to reinforce positive and safe behaviour but also to highlight any unsafe behaviours and provide training to reeducate and refresh knowledge to ensure that the unsafe behaviours are not repeated. We will ensure our safety management systems arrangements are suitably implemented to promote safe behaviours and discourage unsafe behaviours.

Guidance and Records

Introduction

Health and safety in the workplace is influenced by a number of factors including the organisational environment, managers’ attitude, commitment to the nature of the job or task and the personal attributes of the worker. Safety-related behaviour in the workplace can be changed by addressing such influences.

Behavioural safety processes are one way of trying to establish good safety working practices that identifies and reinforces positive safety behaviours and reduces unsafe behaviours. These processes include near miss and incident investigations, whistleblowing, monitoring and feedback. Implementation of behavioural safety processes can be established using the following method.

• Identify unwanted behaviours,
• Develop observation checklists targeting unwanted behaviours,
• Educate everyone by briefing all i.e. train all those involved,
• Assess & monitor actual behaviour via regular observations, checking of documentation submitted etc.
• Limitless feedback provided to all – verbal, graphical and written etc.

Near miss and incident investigation

If your company has experienced a near miss or incident it is best practice to investigate how, where and why it happened. This investigation can form a process that looks at how the behaviours of managers and employees may have caused the incident and is a tool for helping to reduce the risk of this reoccurring. By looking at the behaviours that may have impacted the incident you will be able to assess if the safe schemes of work for the tasks are adequate, if more training is required, reinforce safe behaviours (good habits) and change unsafe behaviours (bad habits), if the risk assessment does not have adequate controls for human errors etc. When looking at the incident from a behavioural safety view the investigation also needs to take in to account the actions of management and top management as the responsibility will ultimately lie with them.

All Near misses and incidents should be recorded as this will create a record and will help to identify if any trends in behaviour can be seen and help with correcting any unsafe behaviours that are repeated.

Whistleblowing

Whistleblowing is the term used for when a worker passes on information concerning wrongdoing. This can cover fellow workers, procedures or management. To be covered by whistleblowing law, a worker who makes a disclosure must reasonably believe two things. The first is that they are acting in the public interest. This means in particular that personal grievances and complaints are not usually covered by whistleblowing law.

It is considered good practice for the company to create a safe, open environment where an employee feels comfortable in bringing to management any concerns they have over any unsafe behaviours witnessed. Employees are often best placed to help with identifying any unsafe behaviours being exhibited and can be a valuable tool when establishing safe schemes of work and training needs. A person whistleblowing may feel daunted about raising concerns on fellow workers and therefore it is advised that all whistleblowing is confidential and the person’s identity would be kept secret.

Once a disclosure has been made it is good practice to hold a meeting with the whistleblower to gather all the information needed to understand the situation. In some cases, a suitable conclusion may be reached through an initial conversation with a manager. In more serious cases there may be a need for a formal investigation. It is for the company to decide what the most appropriate action to take is.

It is important to note that if an investigation concludes that the disclosure was untrue it does not automatically mean that it was raised maliciously by a worker.

When dealing with disclosures, it is good practice for managers to:

• Have a facility for anonymous reporting
• Treat all disclosures made seriously and consistently
• Provide support to the worker during what can be a difficult or anxious time with access to mentoring, advice and counselling
• Reassure the whistleblower that their disclosure will not affect their position at work
• Document whether the whistleblower has requested confidentiality
• Manage the expectations of the whistleblower in terms of what action and/or feedback they can expect as well clear timescales for providing updates
• Produce a summary of the meeting for record keeping purposes and provide a copy to the whistleblower
• Allow the worker to be accompanied by a trade union representative or colleague at any meeting about the disclosure, if they wish to do so
• Provide support services after a disclosure has been made such as mediation and dispute resolution, to help rebuild trust and relationships in the workplace

It will be useful to document any decisions or action taken following the making of a disclosure by a worker. It is also good practice for organisations to:

• Record the number of whistleblowing disclosures they receive and their nature
• Maintain records of the date and content of feedback provided to whistleblowers
• Conduct regular surveys to ascertain the satisfaction of whistleblowers.

Behavioural based observations

Behavioural based observations are a useful tool to help with determining the safety culture and attitudes of your company however it needs to be good quality observations to be effective. Good quality observations not only identifies problems but can help you understand what caused them and what sort of changes are needed to address them. Poor quality observations can also help you identify issues but may not help you address them.

The best methods of observation require time, effort and a commitment from management to act on the findings. It needs to be based on a current moment of time and not something that happened in the past (unless it is an accident/incident investigation). It needs to be conducted at different points of the day/process to see how each work process is effective. The results of observation and inspection will help with determining not only if the safe schemes of work are suitable but also if the controls of the risk assessment are adequate.

There are two types of monitoring Active and Reactive. In regard to behavioural safety active observation may be best practice as you would be able to witness any behaviours both positive and negative firsthand and react accordingly when giving any feedback on the findings of the observations.

Employee Evaluation and Mentoring

The main focus of behavioural safety is the changing of negative behaviours to more positive behaviours. One way of doing this is by encouraging the positive behaviours in employees using feedback.

Completing employee evaluations helps establish any positive behaviours already being carried out and can be used to identify any negative behaviours that can indicate training needs or changes required. The evaluations would need to be carried out on all employees from the top down to ensure a comprehensive evaluation of the safety culture and using positive reinforcement can help to improve the safety of your employees. The behavioural safety programmes should be agreed mutually between top management and employees and employees should feel that they are playing a part in creating the safety culture of the business and have an opportunity to express any concerns.

Mentoring systems can help with providing this opportunity with employees having a person they can turn to if they need to air any concerns. It can also help with training needs as having a more experienced mentor can reinforce positive safety behaviours and provide excellent opportunities for constructive feedback on the negative behaviours that may have been learnt/ been picked up.

Communication Plan

The success of the behavioural safety policy of the company can largely depend on the successful implementation of communicating changes and updates to all employees in the company. One way this can be successfully achieved is by creating a communication plan.

The communication plan is useful tool for the behavioural safety programme as it can increase awareness and recognition for the safety programme, increase awareness of any risks that may arise in the workplace, help to increase and foster trust between management and employees and improve health related behaviours.

The communication plan will need to be constructed to provide concise information in a variety of forms and materials to ensure that they are understood by all and applicable to all employees in the business.

The success of the behavioural safety plan will be based on the employee participation and understanding of the communications presented to them.

This can be achieved by:

• Branding the plan to show that all communications are coming from the company by using the logo and company name.
• Engaging employees and management to learn how they react with the communications and information being presented to them.
• Use a variety of communication channels such as e-mail, newsletters, Intranet and team meetings.
• Be used to reinforce and praise good practices and celebrate successes and achievements rather than just communicating the bad news.
• Encourage worker participation to help keep an interest in the programme and ensure that they have an input into the working of the plans

Action Plans

As well as a communication plan it is advised that action plans are also used to help put in place the recommendations of change that may come from the observations and discussions. By creating an action plan the changes required can be tracked and given a timeframe to be completed by. It is advised that all employees who would be impacted by the changes are included in the creation of the action plan and that the opinions they have are taken into consideration while setting out the goals. The goals set would need to be realistic in nature and take in to account the impact it will have on the behaviours and safety culture of the business while being reasonably practicable to carry out. Communication will be a key feature of the action plan as it would need to be adopted and accepted by all employees and management.

Evaluation of the Behavioural Safety Programme 

The Behavioural Safety Programme will itself need to be evaluated and reviewed periodically to ensure that it is still fit for purpose. The frequency of this review will be based on needs, but annual review would be recommended.