Health and Safety Management - Revision history

Rebekah Hook at 09:43, 3 January 2025

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Rebekah Hook at 09:39, 3 January 2025

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Rebekah Hook: /* 2.4 Implementing the Control Measures */

2025-01-02T13:03:01Z

2.4 Implementing the Control Measures

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	* 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’.		* 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’.

	===== ~~'''~~2.4 Implementing the Control Measures~~'''~~ =====		===== 2.4 Implementing the Control Measures =====
	The principles to be applied when implementing preventive and protective measures to control risks are as follows:		The principles to be applied when implementing preventive and protective measures to control risks are as follows:

Rebekah Hook at 13:02, 2 January 2025

2025-01-02T13:02:36Z

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Rebekah Hook: Created page with "== 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..."

2025-01-02T12:29:56Z

Created page with "== 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..."

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== 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.

==== 1. 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.

==== 2. 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:
{| class="wikitable"
|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: <sup> </sup>

* Operators

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

'''3. State existing control measures: <sup> </sup> '''

* 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.

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

	===== ~~4.2~~ Training Outline for Directors/Managers/Supervisors =====		===== 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 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.

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	* The requirements under any specific legislation which is applicable to their role		* The requirements under any specific legislation which is applicable to their role

	===== ~~4.3~~ How to Provide the Right Training =====		===== 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.		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.

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	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.		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.

	==== 1. Guidance and Records ====		==== Guidance and Records ====

	===== ~~1.1.~~ Introduction =====		===== 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.		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.

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	* '''L'''imitless feedback provided to all – verbal, graphical and written etc.		* '''L'''imitless feedback provided to all – verbal, graphical and written etc.

	===== ~~1.2.~~ Near miss and incident investigation =====		===== 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.		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.		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.

	===== ~~1.3.~~ Whistleblowing =====		===== 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.		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.

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	* Conduct regular surveys to ascertain the satisfaction of whistleblowers.		* Conduct regular surveys to ascertain the satisfaction of whistleblowers.

	===== ~~4.4.~~ Behavioural based observations =====		===== 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.		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.

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	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.		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.

	===== ~~4.5.~~ Employee Evaluation and Mentoring =====		===== 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.		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.

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	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.		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.

	===== ~~4.6.~~ Communication Plan =====		===== 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 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.

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	* Encourage worker participation to help keep an interest in the programme and ensure that they have an input into the working of the plans		* Encourage worker participation to help keep an interest in the programme and ensure that they have an input into the working of the plans

	===== ~~4.7.~~ Action 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.		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.

	===== ~~4.8.~~ Evaluation of the Behavioural Safety Programme =====		===== 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.		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.