A day in the life ... of a safety consultant

All employers must either display the HSE Health and Safety Law Poster in their premises or provide each of their employees with a copy of the HSE leaflet entitled “Health and safety law: What you should know”. The Health and Safety Law Poster includes basic health and safety information and informs people as to who is responsible for health and safety in your workplace.

A Midhurst store has been fined £11,000 and made to pay costs of about £4000 following an inspection of the premises and discovery of some breaches of food hygiene legislation.
During a routine food hygiene inspection, Officers of Environmental Health Services found mouldy food for sale within the store. Council Officers also found that the company had failed to implement and maintain their food safety management systems, which are designed to ensure that all food sold is safe to eat.

The Council wrote to the company telling them of the failings to comply with food hygiene legislation and gave them a date to rectify the problems by.

In line with usual practice, lots of help and assistance was offered by the Council to the company. However, during a further visit by Officers of the Environmental Health in Jan 2009, the same problems were found to exist.

The Deputy Leader of the Council at Chichester District Council, says: "We are very supportive of businesses and we always go the extra mile to explain their legal responsibilities and to assist them with specialist advice. Our role is in education and improvement. However, we do take breaches of food hygiene legislation very seriously and when we see insufficient improvements being made, we will prosecute anyone who is found to be contravening that legislation. "In the vast majority of cases, the Chichester District is a source of fine food, through its many restaurants and public houses, national food retailers and more unusual local specialist food suppliers. Our Commercial Safety Team regularly inspect premises within the district to ensure that all food is safe to eat and prepared in clean and well run establishments."

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According to HSE statistics, about 2000 workers are seriously injured every year as a result of falling from a vehicle, with an average of five people suffering fatal injuries. Most of the instances (about 90%) involve falls from below head height and the HSE have estimated that the economic and human cost of these incidents is in the order of £36.7 million. The main purpose of the campaign is to raise awareness of the risk of falling that workers are exposed to when they are accessing and/or working at height on vehicles and of the actions that should be taken to minimise these risks. As far as the HSE campaign goes, there are two important messages:
• falls from vehicles can cause serious injuries
• simple, cost effective solutions are available to prevent these injuries

Falls from vehicles and the law

In common with most work activities, there is no specific law dealing with falls from vehicles. However, as well as the Health and Safety at Work Etc Act 1974 (HSAW), there are two sets of regulations that are applicable to falls from vehicles:
• Management of Health and Safety at Work Regulations 1999 and
• Work at Heights Regulations 2005
Amongst other thing, the Management of Health and Safety at Work Regulations 1999 creates a duty on employers to assess the risks arising from their operations and undertakings and requires them (in conjunction with the requirements of HSAW) to reduce these risks to as low a level as is reasonably practicable. The Work at Heights Regulations 2005 creates some simple, but never-the-less important duties on employers. In order to comply, the employer must ensure that:
• all work at height is avoided where reasonably practicable to do so
• all work at height is properly planned and organised
• workers involved in work at height are competent
• the risks arising from work at height have been properly assessed
• appropriate work equipment has been selected and is used as appropriate
• equipment is properly inspected, serviced and maintained
Falls from height does not have to means a fall from a great height (historically considered to be falls from over two metres). The Work at Height Regulations 2005 apply to all work at height where there is a risk of a fall liable to cause personal injury.

Typical Hazards
Employers should consider their operations and determine where there are risks of falls (from height) from vehicles. These may include:
• accessing and egressing the driver’s cab
• loading and unloading vehicles
• working on tail lifts
• working on trailers or vehicle platforms
• sheeting and unsheeting of loads
• working on top of tankers (dipping operations, etc.)

Control measures that can be introduced

General issues and general control measures
Several simple steps can be taken to help to reduce the number of workplace accidents involving falls from vehicles and many of these are both cheap and easy to implement. These include:
• restrict access to vehicle areas to authorised persons
• avoid the need to work at height when it is reasonably practicable to do so (by way of example, many tankers are now fitted with bottom loading systems, removing the need for the driver, or other person, to access the top of the tanker)
• provide a safe means of access to, and egress from, work areas (including vehicles)
• avoid the need for working at different heights (consideration may be given to a well constructed loading bay or platform, etc.)
• maintain good standards of housekeeping (in the vehicles and in the surrounding areas, such as loading bays, etc.)
• make appropriate arrangements for poor weather (poor lighting, rain, snow, ice, high winds, etc.)
• ensure that lighting in the general work area is suitable and adequate for the tasks to be done and consider the need for suitable emergency lighting
• ensure that workers wear appropriate footwear for the job
• carry out routine checks (such as visual inspections and tests) on equipment and workplaces
• Ensure that vehicles can be moved unexpectedly during loading, unloading, sheeting or unsheeting operations, measures may include:
o Immobilising vehicles
o Removing keys from vehicles
o Requiring drivers to leave the cab of the vehicle during operations
o Chocking the vehicle wheels
o etc

Controls for walking on vehicles
Many people are injured when they fall as a result of the load shifting underfoot when walking on the load or otherwise on the vehicle. It is therefore recommended that measures to avoid the need to walk on the vehicle or on the load are introduced where it is reasonably practicable to do so. Where it remains necessary, typical measures to control the risk of falling include:
• walking while facing the direction of travel
• keeping feet well apart and free to move
• consideration of the stability and grip of the surface being walked on and consideration of how this may change in different parts of the load or different parts of the vehicle
• avoid reliance on the support offered by ropes, sheets and by the load (these may move, rip or tear)
• consideration should be given to the use of suitable fall arrest or work restraint systems

Controls for accessing and egressing the cab
Tail lifts can be an invaluable aid to loading and unloading vehicles and can negate the need for fork lift trucks in certain instances and can significantly reduce the risks from manual handling. There are a range of measures that may be used to reduce the risks associated with working on tail lifts. These include:
• ensure that workers are aware of the hazards associated with general access to and egress from the cab and the types of injuries that they sustain and the potential effects of these injuries on the workers (generally drivers).
• Instruct drivers to:
o use the steps provided
o use the grab handles to assist access/egress and not the steering wheel
o when leaving the vehicle, visually check the ground for obstructions
o when leaving the vehicle, use the steps and grab the handle provided and exit the cab backwards

Controls for working on tail lifts
Tail lifts can be an invaluable aid to loading and unloading vehicles and can negate the need for fork lift trucks in certain instances and can significantly reduce the risks from manual handling. There are a range of measures that may be used to reduce the risks associated with working on tail lifts. These include:
• ensure that workers are aware of the hazards associated with working on and from tail lifts
• ensure that the tail lift is suitable for the vehicle and for the loads to be handled
• ensure that the tail lift is serviced and maintained in accordance with the manufacturers’ recommendations
• ensure that statutory examination is carried out (as required under the Lifting Operations and Lifting Equipment Regulations 1998)
• where appropriate, provide edge protection to the tail lift

Controls for working on vehicle platforms and trailers
Tail lifts can be an invaluable aid to loading and unloading vehicles and can negate the need for fork lift trucks in certain instances and can significantly reduce the risks from manual handling. There are a range of measures that may be used to reduce the risks associated with working on tail lifts. These include:
• avoid the need to work on vehicle platforms and trailers where it is reasonably practicable to do so
• ensure that workers are aware of the hazards associated with working on vehicle platforms and on trailers
• providing suitable hand holds and steps to allow easy access to, and egress from, the platform or trailer
• providing trip guards along the platform or trailer edge
• ensure that the platform or trailer is kept clear of trip hazards, such as rubbish, ropes, chains, packaging materials, dunnage, etc.
• ensure that the floor of the platform or trailer is secure and in good condition, without tripping hazards
• ensure that the operator wears appropriate footwear and other personal protective equipment
• ensure that lighting is adequate, including in potentially shaded areas
• prohibiting the practices of jumping down from a vehicle or load or of jumping between vehicles

Controls for sheeting operations
There are a range of measures that may be used to reduce the risks associated with sheeting operations. Some of the methods (which may be used singly or in combination) are outlined below:
• ensure that workers are aware of the hazards associated with sheeting and unsheeting operations, especially in poor weather
• consider whether the load needs to be sheeted (avoid the hazardous operation)
• create a documented safe system of work for sheeting and unsheeting operations and train workers in this system
• arrange for automatic sheeting systems to be fitted to vehicles
• consider safe means of access, such as:
o use of work platforms
o use of suitable fixed gantries
• provide and use suitable fall arrest or work restraint systems
• where reasonably practicable, avoid climbing upon the load
• where reasonably practicable, avoid the use of ladders and consider safer and more robust access systems

Special factors
Consideration should be given to loads or conditions that have special factors associated with them that may increase the level of risk. Such factors may include:
• bad weather
• loads that have leaked
• unstable loads or loads that have slipped or moved in transit
• loads or goods known to be slippery (such as oil, silicone based materials, waxes, etc.)
• loads involving the transport of live animals (faeces, urine, etc.)
• refrigerated transport
• etc.

Summary
In some cases, the amount that needs to be done to control the risks of injury and death from falls from vehicles can be costly, such as building new loading bays or replacing tankers with new, bottom loading systems. However, in most cases the costs are low, as what is often needed is more attention to the tasks undertaken and greater enforcement of the control measures that the company believes are already in place. Training is an important part of the process as this will raise the awareness to dangers in the tasks undertaken and the consequences on the well being of those involved if things go wrong. Regular active monitoring is important to ensure that the workplace environment is right and that the appropriate workplace practices are being adhered to.

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A few recent client visits have reminded me of the importance of Records and of Active Monitoring. In common with the many other aspects of running a successful business (such as sales, production, finance, quality, etc.) companies need to measure their health and safety performance to find out if they are truly being successful. Monitoring of the health and safety activity may be split into two important, yet distinct areas: Active Monitoring and Reactive Monitoring.

Most people are familiar with, and comfortable with the concept of reactive monitoring. This is the process of investigation into things that have gone wrong (such as accident investigation) and involves learning from mistakes. These mistakes may have resulted in injuries and illness, property damage or near misses.

Active monitoring is an important aspect of modern safety management that appears to be very difficult for some companies to accept and to buy into. It is the things that we do that generally keep employees (and other persons) from harm; but it is the records and documents that we keep (and complete) that will help to protect the Company. The court case described below puts some of this into context.

Reactive Monitoring and Active Monitoring

Reactive monitoring occurs when companies investigate (suspected) failures in their health and safety systems. Typical examples include accident and incident investigation as well as investigations into cases of ill heath, and near misses etc. Even from these few examples, it can be seen that reactive monitoring involves responding to some form of health and safety failure, such as: an accident, incident, near miss, failure of equipment, etc.

The role of active monitoring is very different. Active monitoring aims to avoid failures and help to improve (health and safety) performance by looking at the operations, systems, equipment and people to ensure that there are no faults or failings (or to identify them before they lead to accidents and incidents are correct them). Active monitoring gives the company feedback on its performance without the need for an accident, incident or case of ill health. It allows companies to measure successes rather than merely to respond to recorded failures. It also allows shortfalls to be identified and addressed before accidents, incidents and ill health occur. Monitoring and checking is an essential part of the model for “Successful Health and Safety Management” espoused in the HSE publication: HSG65. In this model it is referred to as measuring performance. Similarly, monitoring is also a requirement of OHSAS 18001 and BS8800. Active monitoring involves checking conditions, plant, and systems, to ascertain if performance is being maintained to the defined standards, using the techniques of safety inspections and safety audits. Active monitoring measures the effectiveness of an organisation's defences against accidents whereas reactive monitoring simply measures the number of times loss has resulted from a breach of these defences.

Active monitoring can be used as an effective means of promoting the Corporate and Social Responsibility of a business. According to the information placed prominently on the website of a large UK based company: “What sets us apart from our peers in the management of health and safety is the extent and depth of our active monitoring programme. The traditional approach of reactive monitoring (recording accidents and incidents) only measures where things have gone wrong. The active monitoring programme we employ provides information on the effectiveness of our systems and hence allows us to identify potential weaknesses before they result in accidents.”

Active Monitoring and its relationship to the risk assessment process

The effectiveness of the risk assessment process in helping to ensure the health, safety and welfare of employees and the health and safety of non-employees bends on several factors. Two of the most important are:
• The quality, accuracy and relevance of the original risk assessment, and
• The appropriate use of the control measures identified in and arising from the risk assessment.

Having completed the risk assessment, the significant finding of the assessment need to be communicated to employees to:
• ensure that they are aware of the hazards to which they may be exposed, and
• ensure that they are aware of the control measures that are to be used to avoid or, where avoidance is reasonably practicable (or practicable - as the case may be), to control the risk to the lowest level that is reasonably practicable (or practicable)

The role of active monitoring is to supplement and support this training by checking that:
• the control measures identified in the risk assessment are being used appropriately, and
• the control measures are effective in avoiding or reducing the risk.

Who should carry out Active Monitoring activities?

Active monitoring can be carried out by a range of people, some of whom are third parties, not direct employees, including:
• Operatives/workers
• Charge hands, leading hands, foremen, supervisors, etc.
• Managers
• Service engineers
• Insurance engineers (often used for statutory examinations)
• Consultants/auditors
• Customers, clients, etc.

It is normal practice for the daily safety checks of the fork lift truck(s) to be carried out by the fork lift driver, store man, etc., while it is also good practice for these records to be checked regularly by the manager or supervisor responsible for the area or operation where the fork lift trucks are used. The role of this second check is to ensure that the daily checks are being made, not to repeat them. The fork lift trucks would then be subject to a more detailed check and maintenance process from the (third party) person or company contracted to maintained and service the fork lift trucks. On top of this, the lift trucks will also be subject to statutory inspection and test (under the Lifting Operations and Lifting Equipment Regulations 1998, LOLER) at twelve monthly intervals (or six monthly is used to lift people).

Some case Law Involving Active Monitoring

In a Scottish case, M (a Scottish tyre-fitting firm) was fined £10,000 for failing (in the words of the Procurator Fiscal) to “give effect to arrangements that were appropriate for monitoring and reviewing its health and safety policy. It didn’t check that people were actually following it.” Regulation 5 of the Management of Health and Safety Work Regulations 1999 places a duty on employers to ensure effective planning, control, monitoring and review of the preventive and protective measures within their health and safety arrangements. This point is expanded with the Approved Code of Practice that supports the Regulations where the point is made that “Active monitoring reveals how effectively the health and safety management system is functioning”

The case followed a road traffic accident (RTA) in which one of T’s employees and the driver of a broken down (client) lorry were killed at the road side. One of M’s tyre fitters attended an early morning breakdown on the A90 Dundee-Aberdeen road. The broken down vehicle had stopped in the nearside lane (there being no hard shoulder available on this particular stretch) and the hazard warning lights had been switched on. The section of the road in that area was unlit and, according to witnesses also on the road at the time of the crash, the two drivers could barely be seen. This indicates that they were not wearing high-visibility jackets. Unfortunately, the driver of a third vehicle that was travelling north failed to spot the breakdown in time. This third vehicle collided with the broken down truck, shunting it into the recovery vehicle, which had been parked in front and killed the two men on the scene.

The driver of this third vehicle pleaded guilty to a charge of reckless driving. During the investigation into the incident, the HSE discovered that M had a good, up to date, written Health and Safety Policy that addressed issues such as the wearing of Hi-visibility fluorescent jackets, the placing of traffic cones at the site of the breakdown and parking the recovery vehicle between the broken down vehicle and the oncoming traffic. It also discovered, however, that none of these measures had been implemented in practice. The court heard that M’s driver had seen the policy and had signed it to acknowledge that he had read it. It also heard that the Company had carried out a vehicle check about a month before the accident. According to Procurator Fiscal, the failing of M was in not putting into practice what it had put down on paper. The Company could not demonstrate that it monitored the use and effectiveness of policies and procedures or the control measures arising from its risk assessments. It did not take enough steps to ensure that its employees were working to the Company’s procedures.

This case highlights the fact that it is not enough to have a health and safety policy and expect everyone within the organization to understand it and to work to that policy. People must receive suitable and sufficient training in the policy and then the effectiveness of the policy must be established.

An example of what some sectors are doing to carry out and promote active monitoring

The Association of Charity Shops has created a series of information sheets for its members; one of these outlines the importance of active monitoring in the (charity) retail arena (www.charityshops.org.uk). It outlines the importance of regular monitoring activities over the range of potential health and safety issues in this market sector. Suggested frequencies for checks vary from daily (such as checking that fire escapes are unobstructed) through weekly, monthly and quarterly and on up to half yearly (such as a review of COSHH and manual handling assessments).

Examples of Records

Record keeping is an important aspect of the management of health and safety at work. There are, however, still many companies that, despite carrying out checks, do not keep suitable records. Most companies are better at making and keeping records of failure (such as accident investigations) than they are keeping making records of good performance (such as: housekeeping standards and lighting levels in access corridors clear at the time of the check). Some records are easier to generate and to keep than others. Most companies keep records of statutory examinations (such as of local exhaust ventilation systems or of lifting equipment) and most keep records of their completed risk assessments. Few keep records of internal inspection and testing of their machinery guarding, operational checks on their local exhaust ventilation systems, etc. Fewer still keep records of their internal checks on the operation and effectiveness of their health and safety policy. Some aspects of this are simple to do and can be delegated to a range of managers, supervisors and other employees. These simpler aspects include maintenance logs and recorded checks on the presence and operation of machinery guarding, light guards, perimeter guards, etc. Other aspects are more complicated, involved or specialised and need to be organized and controlled by directors and managers or delegated to other competent persons.

Keeping records of Active Monitoring need not take much time

One of the important points to consider when keeping records of active monitoring is to design the paperwork to minimise the amount of time taken in recording the information while still obtaining meaningful records that be kept and, where necessary, referred to. In most cases, this can be achieved by designing a simple (yet suitably comprehensive) checklist.

The checklist should be designed such that in cases where is as it should be, the use of a tick, initials or other simple mark suffices. In certain cases, it may be necessary to record other simple data, such as the date, pressure, operative’s names, etc. The default position should be that the checklist is easy and quick to complete in situations where there are no defects. In the event of defects being found (such as a missing machinery guard or disabled safety interlock, etc.) then checklist will take longer to complete as details of the defect and of the (proposed) corrective action need to be recorded. It may also be necessary to go into more detail if the corrective action required action by somebody else.

Typical examples of simple daily/weekly checks and records:

Daily fork lift truck driver checklist
Condition of battery charging stations checklist
Daily or weekly recorded checks on the presence and effectiveness of (fixed and adjustable) machinery guards and safety features (such as the DC injection brakes on radial drills)
Daily checklist for the operation of the light guard on a guillotine, etc.
Daily (or shift based) records of the operation of the safety features (fixed guarding and interlocked guarding) on power presses
Housekeeping checklist/site walk down checklist
Road vehicle regular inspection checklist

Typical examples of Monthly/Quarterly checks and records:

Racking inspection checklist
Fire extinguisher location and condition checklist
Fire door condition and operation checklist
Access equipment inspection checklist (such as step ladders, steps, etc.)
Monitoring of the general condition of the premises, walkways, lighting, heating, etc.
Availability, condition and use of personal protective equipment
First aid box and emergency eyewash station checklists
General housekeeping checklist
Workplace inspections and audits
Visual inspection records for portable electrical equipment

Typical examples of six monthly/annual checklists:

Formal review of the suitability and effectiveness of the Health and Safety Policy (such as through an audit)
Formal review of the suitability and relevance of risk assessments and checking that they are up to date
Checks that all statutory examinations are being carried out at the appropriate frequencies (such as those applicable to lifting equipment, pressurized systems and local exhaust ventilation systems)
Training needs assessments for employees and training records
Portable appliance testing/inventory
General condition checking of the fixed electrical installation

Typical examples of “as used” checks and records:

Safety harnesses and lanyards that are not used often may be subject to inspection and checking before each use, rather than on a more regular basis.
The condition of guarding and safety devices on equipment that is not used often may be tested and inspected before each use rather than as part of a regular machinery safety inspection regime.

Personal Protective Equipment: Records of availability and condition of issued PPE

Most employers need to provide personal protective equipment (PPE) to employees. Some companies record the issue of such PPE, but in most cases this is only done the first time that PPE is issued or in the case of more expensive items of PPE. Very few companies are able to demonstrate that employees still have the PPE that they were issued with and that it is in good condition. This is particularly the case in companies where the employees do not work on the company’s own site (such as contractors). Potentially, many companies are leaving themselves exposed in this area. This sort of record keeping is often seen as difficult and time consuming to undertake. A relatively simple solution is to create a PPE condition monitoring sheet that the employees complete or, preferably, that is completed in conjunction with a supervisor, charge hand, foreman, etc. The sheet can be devised a number of ways, but two ones include:
• A simple table of the issued items of PPE against the employee’s name. The resulting boxes are initialled to indicate that the employee still has the PPE and that it is in good condition (clean and free from defects). In this case, the sheet is used to record the details of a group or team of workers and a new sheet is used each month.
• A simple table of issued items of PPE against the month. Initialling the boxes has the same meaning as above In this case, the form is used month on month (until completed), allowing one form to be used for several months, reducing the amount of paperwork involved. Other information may also be obtained and recorded on this single employee form, such as the condition of hands and lower arms in cases of work that may have a risk of dermatitis, etc.

COSHH: Workplace exposure monitoring as an example of Active Monitoring

If the COSHH risk assessment (as required by Regulation 6 of the Control of Substances Hazardous to Health Regulations 2002, COSHH) shows it is necessary, then workplace exposure monitoring may be required to meet the requirements of Regulation 10 of COSHH. This requires the use of and suitable occupational hygiene techniques to estimate the amount of employees’ exposure to substances hazardous to health. In the case of airborne contaminants, this measurement will normally involve collecting a sample of air from the employee’s breathing zone using some form of personal sampling equipment. Alternatively, it may involve sampling the air at the workplace periodically, or even require the use of continuous static sampling equipment.

What ever the method used, this is a form of Active Monitoring. The purpose of measurements is to demonstrate that the control measures in place (arising from the COSHH risk assessment) are suitable and sufficient to protect the health of employees and of others who may (potentially) be exposed to the hazardous substance.

In the case of workplace exposure monitoring, employers must keep and maintain a record of any for at least five years. In the case of personal exposure monitoring, as opposed to (general) workplace exposure monitoring, then the details should be recorded as part of the employee’s health file and, as such, the record must be kept for at least forty years.

Monitoring of common areas

Common areas within shared occupancy premises are areas that are often neglected in instances where the landlord is not on site and does not have a (regular) site presence. In a recent case, a firm of architects occupying second floor offices in a multi-let building were found liable to one of its employees for injuries the employee sustained as they left the lift on the ground floor. Safety devices that should have prevented the lift doors from closing failed and the doors shut on the employee's hand. The firm was found to be in breach of its statutory duty to meet minimum health and safety requirements regarding the use of work equipment by workers at work, even though the accident occurred outside of the architects' demise, in equipment which formed part of the common parts of the building and which it was the landlord's responsibility to maintain and repair.

The fact that an employer can be in breach of statutory duty in respect of equipment such as a lift that is outside of its demise within the premises and also outside of its control should be of concern to tenants. It should also be considered that this case may provide some useful ammunition to tenants who are experiencing difficulty in getting their landlords to comply with repair and maintenance obligations. The potential for statutory liability on the part of a tenant as an employer may help persuade a court that an injunction against the landlord compelling compliance with its repair and maintenance obligations is an appropriate remedy. This case also implies the need for some level of active monitoring of common areas. Part of the active monitoring procedure may include requesting the landlord to confirm, in writing, that certain issues that may be taken for granted are actually being addressed. This may include confirmation that the landlord has arranged:
• Inspection and testing of the fixed electrical installation
• Inspection, test and maintenance of the fire alarm system
• Inspection, test and maintenance of the emergency (or escape) lighting system
• Inspection, test and maintenance of the lift

Monitoring of off-site activities

In cases where much of the activity takes place off site, other routes for carrying out monitoring and checking need to be considered. Companies should consider periodic, unannounced site visits by either their own staff or by specifically contracted staff (such as consultants, etc.). Where may of the activities carried out on different sites are similar, simple audit (or monitoring) checklists may be developed.
Alternatively, feedback may be sought from other interested parties, such as other contractors working on the site or from customers on whose site (or behalf) work is being carried out. This can be as simple as a few questions added to documentation that the customer needs to sign anyway (such as delivery notes, job completion dockets, etc.).

Summary

It is the law, as well as good management, that the health and safety policy and the risk assessments carried out for the undertakings of the business must be both operational and effective. It is well established (refer to HSG 65) that the effectiveness of the health and safety policy and of the risk assessments should be verified and checked through some form of monitoring or auditing process. Active monitoring of systems allows the (potential) failures to be identified before they cause loss or harm. The effectiveness of the health and safety policy and of the risk assessments may be established, and demonstrated, through various active monitoring techniques and records. Organisations are now becoming more aware of active monitoring and of the advantages that it can bring.

Michael Ellerby
LLB BSc CMIOSH MIIRSM CChem MRSC CSci
Director
LRB Consulting Limited
Michael@Lrbconsulting.co.uk

How about a bit of controversy?

We all know that (in the UK) it's against the law to use a hand held mobile while driving a car. Currently, however, the use of a hands-free phone is not against the law. The whole area is one of intense disagreement. I suggest a simple test - hold a conversation with someone and look into their eyes while doing so. Now, ask them a tricky (at least tricky to us mere mortals) maths question (such as "what is seven times thirteen") and see what they do. Most people will look away from you while they think about this - they are concentrating on the problem. If they were driving, they would look away from the road and would not be concentrating on their driving.

If the conversation is one that is important, then stop and hold it when you can give it your full attention. If it is not important, then it can wait.

I don't think this will make me popular, but it should help people to understand why I am against using even handsfree phones while driving.

Research shows that hands-free phones are no safer
than hand-held phones. The main danger of being on the phone while driving is disruption of concentration. (Royal Society for the Prevention of Accidents)

This is just one example of poor housekeeping. I will be adding more photos as time allows.

Why pick on housekeeping? Simple - it pervades many industries and causes many accidents. More importantly, it is easy to address and geneally costs little to sort out. Companies can make large improvements in health and safety at work by the simple, common sense expedience of tidying up. - I'd better stop at this point as I don't want this to become a rant.

Please follow this link to my website or to the article on Slips, trips and falls.

Slips, Trips & Falls

Amazingly, about a third of reportable workplace accidents arise from slips, trips and falls. The HSE's slips, trips and falls campaign (Shattered Lives) has made a return for 2009. This time the focus is on accident prevention in education and healthcare environments, supported by online tools to assess and reduce risks. The principles extend into all workplaces.

What are the common reasons that people slip, trip and fall?

There are many reasons why people slip, trip or fall. The most common reasons are associated with:

the floor
contamination on the floor (or footwear)
obstacles on the floor
cleaning of the floors
damaged flooring
missing handrails inappropriate footwear • environmental factors, such as: poor lighting
etc

Are there any simple steps that can be taken to reduce the incidence of slips, trips and falls?
Although slips, trips and falls may be the most common cause of accidents, they can be controlled and managed by appropriate work practices and (generally) with very little expenditure. The actions relevant to a particular property should be determined by risk assessment. Some of the key areas to address are discussed below.

Floors
Design - The floor should be suitable for its intended use and environment and for the type of work activity that may take place on it. Walkways should be wide enough to allow safe passage of the type and volume of foot (and other) traffic that is expected. If a floor is situated in places where it cannot be kept dry, then people should still be able to walk on it without fear of a slip. This is an important design feature in place such as leisure centres, swimming pools, cold storage areas, kitchens, etc. The floor must be fitted correctly to ensure that there are no trip hazards.

Floor cleaning - Floor cleaning can make the floor slippery during cleaning and as a result of the materials used in cleaning. The floor must be cleaned correctly to ensure that it does not become slippery or keeps its slip resistance properties (if a non slip floor). Although it is often not possible, normal cleaning activities should be carried out when the premises are unoccupied (or last thing at night). Appropriate barriers (such as Yellow “A” Frames) should be provided to warn people that the floor is still wet. Appropriate cleaning techniques should be introduced, such as: using a dry mop/squeegee to reduce floor drying time. In some cases, it would be appropriate to arrange alternative bypass routes. Consideration should be given to the tripping risks created by trailing vacuum cleaner cables, etc.

Maintenance of floor - The floors and floor coverings (carpets, tiles, etc.) must be maintained in good condition in order to ensure that trip hazards are not present and that they do not develop. Holes in the floor should be filled in and carpets and other floor coverings should be secured into place. It should be ensured that mats do not slip and slide on the floor surface. It may be appropriate to use a lay of materials to adhere the mat to the floor in normal use. It should be ensured that mats and carpets do not turn up and the edges to create tripping hazards.

Awareness of changes in elevation - Where reasonably practicable, ramps, raised platforms and other changes of level should be avoided. Where they cannot be avoided, they should be highlighted, such as by suitable warning notices, signs, use of colour or other highlighting techniques.
Steps and stairs - Steps and stairs should be well lit and designed so as to be suitable for their intended use and environment. They should be well lit and provided with robust handrails, ideally on each side. Consideration should be given to the height and width steps. The risers should be consistent and the nosings on the steps and stairs should be clearly marked in colours that contrast with the rest of the steps.

Housekeeping and Active Monitoring

Even if walkways are suitable and satisfactory, they need to be maintained in this condition. Further to this, good standards of housekeeping need to be maintained. Regular, active monitoring of walkways is essential to prevent issues from developing. Regular walk rounds of the premises can identify issues such as:

inappropriately routed or protected trailing wires (such as may be associated with short term building maintenance activities)
water or other fluids from leaking roofs or pipework
spillages
general accumulation of detritus and other obstructions
lighting

Trailing cables

Trailing cables should be avoided whenever possible. Equipment should be positioned to avoid cables crossing pedestrian routes and proprietary cable covers should be securely fixed into place if cables need to be trailed. Consideration should be given to the use of cordless portable tools.

Spillages

Suitable arrangements should be in place to deal with (wet and dry) spillages. These should be reported and dealt with as soon as they happen or as soon as they are noticed. The nature of any spillage response provision or spillage cleaning kit will depend on the nature of any expected spillages.

Other issues

Known slippery surfaces or conditions - Where certain floors are known to be slippery or are known to be slippery when wet, then these areas should be assessed and the cause of the slipperiness should be treated accordingly. By way of example:
it may be appropriate to weather mats at the entrances to premises to prevent water from being brought in on peoples shoes and making a polished marble floor extremely slippery
it may be necessary to have a floor chemically treated and to introduce the use of appropriate cleaning methods and materials
gritting materials may need to be provided to make external paths and walkways safe in cold weather
Drinks machines and dispensers - The floors around drinks machines and dispensers may become slippery due to spillages of water, tea, coffee, etc. It may be appropriate to:
resite such machines to be away from main walkways and through routes
to fit absorbent carpets around the machines
Lighting - Ensure that lighting levels are suitable for the area and should avoid casting shadows across the walkway or staircase. Ensure that defective lighting is addressed as soon as it is reported.
Footwear - Instruct workers to wear suitable footwear, particularly with the correct type of sole. If the type of work requires protective footwear to be provided, then the employer is required by law to provide it free of charge. Unfortunately, occupiers of premises have virtually no control on the type of footwear worn by visitors.

Committing to safety

Safety is not a barrier to doing good and profitable business. Some of my clients now see a robust and positive management of safety as a marketing tool. In this harsher economic climate, they are seeing some of their competition fall by the wayside as other companies (their potential clients) have time to check into questionnaires and applications more thoroughly. That they have been "doing things well" for a while now has increased their stabilty during this downturn - they don't need to start the process.

I will be talking to some of my clients about signing up to the HSE pledge. Signing up to playing your part (as an employer) to reducing the number of work-related deaths, injuries and ill-health in Great Britain cannot be a bad thing. Living up to that committment is just good business.

Testimonials
We all like it when people say nice things about us. This is part of what testimonials are about - letting people know what other like about us:

"Having worked closely with LRB Consulting on a number of key Health & Safety issues, we have always found them to be friendly, approachable and knowledgeable. The advice given is accurate, practical and, most importantly, tailored specifically to our business circumstances and requirements, as well as being presented in a clear and professional manner." BioCity Nottingham

Please take the time to look at my website.

Sunny Weather

My recent article about protecting yourself in sunny weather has been remarkably effective - it has dispelled the sunshine and brought rain! Sorry.

Business focus
It is easy, when things are tough in the economy (as they are now), to forget some of the basics of good business as we chase work, clients and prospects. Don't forget to do the basics well: service clients, send out invoices, pay bills, stay on top of things and run the business (don't let the circumstances run you), talk to people (clients, employees, prospects) and continue to develop relationships, continue with sensible marketing activities.

The Month ahead
I'm pleased to say that I have a busy month ahead. There are lots of projects that are on-going and others that are about to start. Some of the projects relate to policy writing and Newsletter articles while others relate to Risk Assessments for major building refurbishments. I also have to carry out a compliance audit at a huge building in London that has recently been refurbished. All this and I have to keep a stong focus on my business (as I have blogged previously).

I have several Networking events that I need to attend. Over that passed few years, I have grown to appreciate that some Networking brings great advantages. Social networking (for business) is, however, fairly new to me. This is an area of challenge and, hopefully of growth and success over the next few months: regualr blogging, developing facebook and using twitter.