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Health and Safety
Executive
Managing for health and safety
Health and Safety
Executive
Managing for health and safety
This is a free-to-download, web-friendly version of HSG65 (Third edition,
published 2013). You can order a printed version at www.hse.gov.uk/pubns/books/
hsg65.htm or visit the website at www.hse.gov.uk/managing.
This revised edition of one of HSE’s most popular guides is mainly for leaders,
owners, trustees and line managers. It will particularly help those who need to put
in place or oversee their organisation’s health and safety arrangements. The advice
may also help workers and their representatives, as well as health and safety
practitioners and training providers.
The guidance explains the Plan, Do, Check, Act approach and shows how it can
help you achieve a balance between the systems and behavioural aspects of
management. It also treats health and safety management as an integral part of
good management generally, rather than as a stand-alone system.
The revised edition has advice on:
■ the core elements of managing for health and safety;
■ deciding if you are doing what you need to do;
■ delivering effective arrangements;
■ useful resources.
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Executive
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© Crown copyright 2013
First published 1991
Second edition 1997
Third edition 2013
ISBN 978 0 7176 6456 6
You may reuse this information (excluding logos) free of charge in any format or
medium, under the terms of the Open Government Licence. To view the licence visit
www.nationalarchives.gov.uk/doc/open-government-licence/, write to the Information
Policy Team, The National Archives, Kew, London TW9 4DU,
or email [email protected].
Some images and illustrations may not be owned by the Crown so cannot be
reproduced without permission of the copyright owner. Enquiries should be sent to
[email protected].
This guidance is issued by the Health and Safety Executive. Following the guidance is
not compulsory, unless specifically stated, and you are free to take other action. But if
you do follow the guidance you will normally be doing enough to comply with the law.
Health and safety inspectors seek to secure compliance with the law and may refer
to this guidance.
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Introduction 6
How this book can help you 6
How to use the book 6
The Plan, Do, Check, Act approach 7
Part 1: Core elements of managing for
health and safety 10

Legal duties	11
Risk profiling	11
Health and safety management systems	12
Documentation	12
Attitudes and behaviours	12

Part 2: Are you doing what you need
to do? 13

Risk profiling	13
Leading and managing for health and safety 14
What are you doing?	14
Additional factors to consider	16
Competence	17
What are you doing?	17
Additional factors to consider	18
Worker consultation and involvement	19
What are you doing?	19
Additional factors to consider	20

Part 3: Delivering effective
arrangements 21

Plan	22
Determining your policy	22
What should your policy cover?	22
Who is best placed to write it?	23
Consulting and acting on your policy 23
Planning for implementation	23
Why planning is essential	23
Effective planning Key actions in effective policy development and planning	23
24

Contents
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Do	25
Profiling your organisation’s health and safety risks	26
Assessing the risks What types of risks need to be considered?	26
26
Who should do the assessment? 26
Who could be affected? What the law says on assessing risks	27
27
Assessing the level of risk	27
Small businesses Medium-sized businesses or those with greater risks	27
28
Large and high-hazard sites	28
Risk controls	28
Recording your findings	28
Health surveillance Key actions in effective risk profiling	29
29
Organising for health and safety Controls within the organisation: the role of supervisors Key actions in supervising for health and safety effectively	31
31
32
Managing contractors Key actions in managing contractors effectively	32
33
Co-operation	34
What is worker involvement?	34
Co-ordination with contractors	35
Ways of involving workers	35
Contacts with external services 35
Emergency procedures Emergency planning and co-operation with the emergency services	35
36
Danger areas Key actions in co-operating effectively	36
37
Communication How size and structure affect communication Key actions in communicating effectively	38
38
39
Competence Who should be the competent person?	39
39
Key actions in competence	40

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Capabilities and training What capabilities do employees need to have? Where training is particularly important Training is not a substitute for risk control Key actions in capability and	40
40
41
41
effective health and safety training 41
Specialist help	43
When you may need specialist help 43 What the law says on specialist help 43 Additional checks for employing an
occupational physician Key actions in managing specialist help effectively	43
45
Implementing your plan	46
The key steps	46
Documentation	46
Implementing risk control plans Key actions in implementing your plan effectively	46
47

 

Check	48
Measuring performance	48
Monitoring	48
How to monitor	49
Types of monitoring	49
Selecting the right measures Key actions in measuring performance effectively	49
50
Investigating accidents and incidents	51
Why investigate?	51
Reporting incidents Key actions in effective accident/ incident investigation	52
53

 

Act	54
Reviewing performance Key actions in reviewing performance effectively	54
55
Worker consultation and involvement 56
Competence	56
Learning lessons Common factors when things go wrong	56
56
Organisational learning	57
Human factors Key actions in learning lessons effectively	57
57
Part 4: Resources	58
Further information	62

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Executive
This book is mainly for leaders, owners, trustees and line managers. It will
particularly help those who need to put in place or oversee their organisation’s
health and safety arrangements.
The advice may also help workers and their representatives, as well as health and
safety practitioners and training providers.
How this book can help you
Organisations have a legal duty to put in place suitable arrangements to manage for
health and safety. This book provides a framework to help you do that effectively, in
a way that your organisation can tailor to your own circumstances.
In implementing your arrangements, you should consult with your employees or
their representatives, including trade unions where they are recognised.
The framework described in this book is universal but how far action is needed will
depend on the size and nature of the organisation, and the risks from its activities,
products or services.
The guidance is also available on HSE’s ‘Managing for health and safety’ website
at www.hse.gov.uk/managing and you can order a printed copy or download a
PDF version at www.hse.gov.uk/pubns/books/hsg65.htm.
If you need information on how to minimise particular risks in your organisation then
‘The health and safety toolbox: How to control risks at work’ will be helpful
(www.hse.gov.uk/toolbox).
If you just need basic information or are getting started in managing for health and
safety in your organisation, then the best place to look is ‘Health and safety made
simple: The basics for your business’ (www.hse.gov.uk/simple-health-safety).
If you are a microbusiness, you can get information from the Federation of Small
Businesses (www.fsb.org.uk).
How to use the book
This book will help you, as leaders, owners, trustees and line managers, put the right
measures in place to manage the real risks to health and safety in your organisation.
Part 1 gives you the core elements of managing for health and safety and how they
can fit with how you run the rest of your business.
Part 2 shows you what to look for when deciding if you’re doing what you need to do.
Part 3 gives advice on delivering effective arrangements. It will be particularly useful
to those who need to put in place or oversee their organisation’s arrangements for
health and safety, eg health and safety managers.
Part 4 signposts resources from HSE and other organisations. There are also short
‘Find out more’ lists with relevant sources of advice throughout the book.
Introduction
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The Plan, Do, Check, Act approach
HSE has moved away from using the POPMAR (Policy, Organising, Planning,
Measuring performance, Auditing and Review) model of managing health and safety
to a ‘Plan, Do, Check, Act’ approach.
The move towards Plan, Do, Check, Act achieves a balance between the systems
and behavioural aspects of management. It also treats health and safety
management as an integral part of good management generally, rather than as a
stand-alone system.
The high-level descriptions may vary, depending on the industry or sector you are
working in, but a summary of the actions involved in delivering effective
arrangements and how they are frequently described is given in Table 1, under the
headings of Plan, Do, Check, Act.
Table 1 The read-across between Plan, Do, Check, Act and other management
systems

Plan, Do, Check, Act	Conventional health and safety management	Process safety
Plan	Determine your policy/Plan for implementation	Define and communicate acceptable performance and resources needed
Identify and assess risks/Identify controls/Record and maintain process safety knowledge
Do	Profile risks/Organise for health and safety/Implement your plan
Implement and manage control measures
Check	Measure performance (monitor before events, investigate after events)	Measure and review performance/Learn from measurements and findings of investigations
Act	Review performance/Act on lessons learned

Plan
■ Think about where you are now and where you need to be.
■ Say what you want to achieve, who will be responsible for what, how you will
achieve your aims, and how you will measure your success. You may need to
write down this policy and your plan to deliver it.
■ Decide how you will measure performance. Think about ways to do this that go
beyond looking at accident figures; look for leading indicators as well as lagging
indicators. These are also called active and reactive indicators (see ‘Types of
monitoring’ on page 49).
■ Consider fire and other emergencies. Co-operate with anyone who shares your
workplace and co-ordinate plans with them.
■ Remember to plan for changes and identify any specific legal requirements that
apply to you.
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Do
■ Identify your risk profile
■ Assess the risks, identify what could cause harm in the workplace, who it could harm
and how, and what you will do to manage the risk.
■ Decide what the priorities are and identify the biggest risks.
■ Organise your activities to deliver your plan
In particular, aim to:
■ Involve workers and communicate, so that everyone is clear on what is needed and
can discuss issues – develop positive attitudes and behaviours.
■ Provide adequate resources, including competent advice where needed.
■ Implement your plan
■ Decide on the preventive and protective measures needed and put them in place.
■ Provide the right tools and equipment to do the job and keep them maintained.
■ Train and instruct, to ensure everyone is competent to carry out their work.
■ Supervise to make sure that arrangements are followed.
Check
■ Measure your performance
■ Make sure that your plan has been implemented – ‘paperwork’ on its own is not a
good performance measure.
■ Assess how well the risks are being controlled and if you are achieving your aims.
In some circumstances formal audits may be useful.
■ Investigate the causes of accidents, incidents or near misses
Act
■ Review your performance
■ Learn from accidents and incidents, ill-health data, errors and relevant experience,
including from other organisations.
■ Revisit plans, policy documents and risk assessments to see if they need updating.
■ Take action on lessons learned, including from audit and inspection reports
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PLAN DO
ACT CHECK
Reviewing
performance
Investigating
accidents/
incidents/
near misses
Measuring
performance
Implementing
your
plan
Organising
Risk
profiling
Planning
Policy
Learning
lessons
You may need to go round the cycle more than once, particularly when:
■ starting out;
■ developing a new process, product or service; or
■ implementing any change.
Figure 1 The Plan, Do, Check, Act cycle
Plan, Do, Check, Act should not be seen as a once-and-for-all action:
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Managing business risks
Managing for health and safety
Worker
involvement Competence
Leadership Management
Legal
compliance
Risk
profiling
Part 1: Core elements of
managing for health and safety
Organisations have a legal duty to put in place suitable arrangements to manage for
health and safety. As this can be viewed as a wide-ranging, general requirement
HSE encourages a common-sense and practical approach. It should be part of the
everyday process of running an organisation and an integral part of workplace
behaviours and attitudes.
Whatever your industry, or the size or nature of your organisation, the keys to
effectively managing for health and safety are:
■ leadership and management (including appropriate business processes);
■ a trained/skilled workforce;
■ an environment where people are trusted and involved.
HSE advocates that all of these elements, underpinned by an understanding of the
profile of risks the organisation creates or faces, are needed. This links back to
wider risk management and can be pictured in the following diagram.
Figure 2 The core elements
Successful delivery can rarely be achieved by one-off interventions. A sustained and
systematic approach is necessary. This may not require a formal health and safety
management system but, whatever approach is used, it probably contains the
steps Plan, Do, Check, Act. However, the success of whatever process or system
is in place hinges on the attitudes and behaviours of people in the organisation.
Health and Safety
Executive
Legal duties
All organisations have management processes or arrangements to deal with
payroll, personnel issues, finance and quality control – managing health and
safety is no different.
The Management of Health and Safety at Work Regulations 1999 require
employers to put in place arrangements to control health and safety risks. As a
minimum, you should have the processes and procedures required to meet the
legal requirements, including:
■ a written health and safety policy (if you employ five or more people);
■ assessments of the risks to employees, contractors, customers, partners, and
any other people who could be affected by your activities – and record the
significant findings in writing (if you employ five or more people). Any risk
assessment must be ‘suitable and sufficient’;
■ arrangements for the effective planning, organisation, control, monitoring and
review of the preventive and protective measures that come from risk
assessment;
■ access to competent health and safety advice, for example see the
Occupational Safety and Health Consultants Register (OSHCR) at
www.hse.gov.uk/oshcr;
■ providing employees with information about the risks in your workplace and
how they are protected;
■ instruction and training for employees in how to deal with the risks;
■ ensuring there is adequate and appropriate supervision in place;
■ consulting with employees about their risks at work and current preventive and
protective measures.
Risk profiling
Effective leaders and line managers know the risks their organisations face, rank
them in order of importance and take action to control them. The range of risks
goes beyond health and safety risks to include quality, environmental and asset
damage, but issues in one area could impact in another.
Although you may not use these precise terms, you will most likely have built a risk
profile that covers:
■ the nature and level of the risks faced by your organisation;
■ the likelihood of adverse effects occurring and the level of disruption;
■ the costs associated with each type of risk;
■ the effectiveness of the controls in place to manage those risks.
Find out more
For more advice on risk profiling see pages 13–14 and 26–30.
Management of Health and Safety at Work Regulations 1999:
www.legislation.gov.uk/uksi/1999/3242/contents/made
HSE provides advice and templates on these processes – see our risk
management site (www.hse.gov.uk/risk) for more information.
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Health and safety management systems
A formal management system or framework can help you manage health and
safety; it’s your decision whether to use one or not. Examples include:
■ national and international standards such as:
■ ISO 45001 Occupational health and safety management systems;
■ BS EN ISO 9001 Quality management system;
■ in-house standards, procedures or codes;
■ sector-specific frameworks such as:
■ the Energy Institute’s High-level framework for process safety management;
■ the Chemical Industries Association Responsible Care framework.
Although the language and methodology vary, the key actions can usually be
traced back to Plan, Do, Check, Act (see the summary on pages 7–8).
Documentation
Keep health and safety documents functional and concise, with the emphasis on
their effectiveness rather than sheer volume of paperwork.
Focusing too much on the formal documentation of a health and safety
management system will distract you from addressing the human elements of its
implementation – the focus becomes the process of the system itself rather than
actually controlling risks.
Attitudes and behaviours
Effectively managing for health and safety is not just about having a management or
safety management system. The success of whatever process or system is in place
still hinges on the attitudes and behaviours of people in the organisation (this is
sometimes referred to as the ‘safety culture’).
Find out more
See Part 2 for examples of positive and negative health and safety attitudes, and
situations where there may be underlying cultural issues.
British Standards can be obtained in PDF or hard-copy formats from BSI:
http://shop.bsigroup.com
Energy Institute’s High-level framework for process safety management:
www.energyinst.org/eipss
Chemical Industries Association: www.cia.org.uk
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Part 2: Are you doing what you
need to do?
This part of the book gives you, as leaders, owners, trustees and line managers,
examples of evidence to look for when deciding if you are doing what you need to
do to manage for health and safety effectively. It will help you answer fundamental
questions such as:
■ What are the strengths and weaknesses of your organisation’s health and
safety performance, and are there any barriers to change?
■ How reliable and sustainable for the future are the measures currently in place?
■ If your organisation is getting risk control right, why is that? For example, does
performance depend on one person’s dedication and enthusiasm or is it a key
value across the organisation?
■ If there are problems, what are the underlying reasons, eg competence,
resources, accountability, lack of engagement with the workforce?
■ Have you learned from situations where things have gone wrong?
The advice also reflects the areas that the health and safety regulator will consider
when assessing the effectiveness of your arrangements.
The examples in the following pages with key areas of ‘What it looks like when
done effectively’ indicate positive health and safety attitudes and behaviours. On the
other hand, the examples also cover facets of ‘What it looks like when done badly
or not at all’ as this could indicate underlying cultural issues.
Risk profiling
The risk profile of an organisation informs all aspects of the approach to leading
and managing its health and safety risks.
Every organisation will have its own risk profile. This is the starting point for
determining the greatest health and safety issues for the organisation. In some
businesses the risks will be tangible and immediate safety hazards, whereas in
other organisations the risks may be health-related and it may be a long time before
the illness becomes apparent.
A risk profile examines:
■ the nature and level of the threats faced by an organisation;
■ the likelihood of adverse effects occurring;
■ the level of disruption and costs associated with each type of risk;
■ the effectiveness of controls in place to manage those risks.
The outcome of risk profiling will be that the right risks have been identified and
prioritised for action, and minor risks will not have been given too much priority.
It also informs decisions about what risk control measures are needed.
Health and Safety
Executive
Find out more
For small/medium businesses and those new to health and safety: Health and safety
made simple: The basics for your business Leaflet INDG449 HSE Books
www.hse.gov.uk/pubns/indg449.htm Microsite: www.hse.gov.uk/simple-health-safety
For larger/more mature businesses: The health and safety toolbox: How to control
risks at work HSG268 HSE Books ISBN 978 0 7176 6587 7
www.hse.gov.uk/pubns/books/hsg268.htm Microsite: www.hse.gov.uk/toolbox
British Standard BS 31100:2008 Risk management: Code of practice
http://shop.bsigroup.com
Leading and managing for health and safety
‘There is a need for a sensible and proportionate approach to risk
management, in short, a balanced approach – this means ensuring
that paperwork is proportionate, does not get in the way of doing the
job, and it certainly does not mean risk elimination at all costs.’
Judith Hackitt, HSE Chair
Leaders, at all levels, need to understand the range of health and safety risks in
their part of the organisation and to give proportionate attention to each of them.
This applies to the level of detail and effort put into assessing the risks, implementing
controls, supervising and monitoring.
What are you doing?
Leading for health and safety
■ Is there leadership from the top of your organisation? Is it visible?
■ What example do you set? Do you talk about health and safety? When did you
last do this?
■ What are your significant risks and how do you know they are being controlled?
■ Are the health and safety implications of your business decisions recognised
and addressed?
■ Is there evidence that the board or leader of your organisation is responsive to
the health and safety information that is reported?
Management tasks
■ How is health and safety included in the processes or management
arrangements you have for running the business?
■ Are the health and safety responsibilities of key people set out, for example:
■ Who is the champion/focus at the board?
■ Who sets policy and standards?
■ Who monitors performance?
■ Are these responsibilities reflected in their job descriptions?
■ How do you ensure access to competent advice?
■ How do you ensure health and safety information is communicated effectively
within and beyond your organisation?
■ How do you control your contractors?
■ How do you review your health and safety performance?
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Table 2 Leading and managing for health and safety – what to look for
Use the following examples of effective and ineffective health and safety management
to check if you are doing what you need to do on leadership.

What it looks like when done effectively	What it looks like when done badly or not at all
Leaders ■ Maintain attention on the significant risks and implementation of adequate controls. ■ Demonstrate their commitment by their actions; they are aware of the key health and safety issues. ■ Ensure consultation with the workforce on health and safety. ■ Challenge unsafe behaviour in a timely way.	Leaders ■ Set no health and safety priorities. ■ Don’t understand the need to maintain oversight. ■ Don’t meet their own organisation’s standards/ procedures, eg wearing correct PPE on site/shop floor. ■ Lack of engagement with health and safety by workers. ■ Health and safety is seen as an add-on, irrelevance or nuisance. ■ Poor incident history (accidents, near misses, plant damage or other indicators, eg poor maintenance, poor housekeeping).
Management of health and safety ■ A systematic approach is used to manage health and safety. ■ People understand the risks and control measures associated with their work. ■ Contractors adhere to the same standards. ■ Appropriate documentation is available: current, organised, relevant. ■ People understand their roles and those of others. ■ Performance is measured – to check controls are working and standards are being implemented, and to learn from mistakes after things go wrong.	Management of health and safety ■ Incomplete or missing paperwork. Does not link to actual risks in workplace. ■ Confusion over roles, inaction as no one takes responsibility for health and safety, distrust of management motives. ■ Widespread, routine violations of procedures. No oversight of contractors. ■ Information is not passed on, not understood, or not implemented. ■ Managers are unaware of employee concerns or do not respond appropriately. ■ Lessons are never learned.
Beyond compliance ■ If a formal system (such as ISO 45001, ISO 9001) is used, has it been externally certified –is the certification accredited? ■ Health and safety is integrated into business processes. ■ Benchmarking is used to compare performance with others. ■ Supply chains are influenced to improve health and safety. ■ A ‘wellness’ programme is in place.

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Additional factors to consider
Board members or directors
■ Joint advice from HSE and the Institute of Directors will help you set your agenda for
effective leadership of health and safety (see the leaflet in ‘Find out more’ below).
Smaller and medium-sized businesses
■ A formal, documented system is not always necessary.
■ The behaviours and attributes of a very small group, or perhaps one person such as the
business owner, are critical.
■ What the owner does to set an example and to provide a lead on health and safety to
their staff determines the outcome.
■ Medium-sized enterprises can show a mix of the formal and informal when it comes to
health and safety arrangements.
Larger organisations
■ Is there someone in senior management who champions health and safety on
the board?
■ Who sets the organisational policy and standards and how are they monitored?
■ Does the board receive and act upon reports on health and safety matters?
■ What key performance indicators (KPIs) do you use to monitor health and safety
performance?
■ Do you periodically review your arrangements for managing for health and safety in light
of any organisational changes?
Process industries
■ Leadership on the key area of process safety is critical.
■ Board level involvement and competence are essential – constant and active
engagement in, and promotion of, process safety by the leadership sets a positive safety
culture – ‘rigour in leadership’.
■ Key factors to address are:
■ How do you maintain corporate knowledge, overall technical leadership and
competence?
■ How do you monitor process safety performance to ensure business risks are
effectively managed?
■ Do you publish safety information to provide public assurance?
Managing occupational health issues
■ Dealing with a work-related ill-health issue in an organisation may not be as
straightforward as it is for a safety issue. It is important to get the right competent advice
to identify what needs to be done. Remember that you need to consider both immediate
ill-health risks and those which can have a latency period before any ill health is seen.
■ Key occupational ill-health issues include diseases arising from exposure to asbestos,
chemicals, biological agents, dusts, noise, manual handling and vibration.
■ Questions to ask:
■ Do I have an occupational ill-health problem in my business and have I taken steps to
prevent ill health in my workforce?
■ Do my workers know which health risks in my business could affect them?
Find out more
There is more advice on leading and managing in Part 3.
Leading health and safety at work: Leadership actions for directors and board members
Leaflet INDG417(rev1) HSE Books www.hse.gov.uk/pubns/indg417.htm
The TUC’s ‘Worksmart’ website: www.worksmart.org.uk/health/questions.php
The IOSH website’s ‘Occupational health toolkit’: www.iosh.co.uk
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Competence
‘Truly effective health and safety management requires competency
across every facet of an organisation and through every level of
the workforce.’
The health and safety of Great Britain: Be part of the solution (www.hse.gov.uk/strategy/
document.htm)
Competence is the ability to undertake responsibilities and perform activities to a
recognised standard on a regular basis. It combines practical and thinking skills,
knowledge and experience.
The Management of Health and Safety at Work Regulations 1999 require an employer
to appoint one or more competent people to help them implement the measures they
need to take to comply with the legal requirements. That could be a member of the
workforce, the owner/manager, or an external consultant. The competent person
should focus on the significant risks and those with serious consequences.
The competence of individuals is vital, whether they are employers, managers,
supervisors, employees or contractors, especially those with safety-critical roles (such
as plant maintenance engineers). It ensures they recognise the risks in their activities
and can apply the right measures to control and manage those risks.
What are you doing?
■ Health and safety responsibilities of managers/supervisors
■ How are they made aware of them?
■ What training have they been given to fulfil roles and responsibilities?
■ How are they held accountable?
■ Do they recognise continuing development needs, eg in annual appraisals?
■ Who fulfils the role of health and safety competent person?
■ What are their background, training and qualifications?
■ What is their awareness of current health and safety law relating to key risks?
■ Are they allowed enough time to dedicate to health and safety?
■ External provider of competent advice
■ How were they selected?
■ What is their competence to provide advice to this particular organisation?
■ Do they allocate adequate resources and tailor advice to this particular
organisation?
■ Check that the documentation provided, eg visit reports, is suitable, covers the
key hazards, assesses the right risks and gives the right advice.
■ Does the organisation act upon advice from the competent person?
■ If there is an identified lack of competence in a particular area, what are you doing
to deal with the problem?
■ How are staff selected for the tasks carried out?
■ Are arrangements in place to ensure staff are aware of roles and responsibilities?
■ Have you identified the training they need?
■ Ensure relevant and sufficient training is delivered. Look for use of training
schedules, operating manuals, sampling delivery of training, training for trainers etc.
■ Check the necessary level of competence has been reached.
■ Check that training is applied.
■ Provide update/refresher training.
■ Ensure training records are kept.
■ Have you provided enough competent cover for absences?
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Table 3 Competence – what to look for
Use the following examples of effective and ineffective health and safety
management to check if you are doing what you need to do on competence.

What it looks like when done effectively

What it looks like when done badly or not at all

■ All know the risks created by the business and understand how to manage them. ■ Key responsible people/job holders are identified and there are clearly established roles and responsibilities. ■ People have the necessary training, skills, knowledge and experience to fulfil their responsibilities and are given enough time to do so. ■ Training takes place during normal working hours and employees are not charged. Beyond compliance ■ Lessons learned and good practice are shared internally and externally.

■ Lack of awareness of key hazards/ risks. ■ People lack the skills, knowledge and experience to do their job. ■ Health and safety advice and training are irrelevant, incompetent or wrong. ■ No standards set; people not held accountable. ■ Insufficient action is taken to comply with the law. ■ Knee-jerk reactions follow incidents/ near misses. ■ The organisation does not know what it needs to do to move forward.

Additional factors to consider
Smaller businesses
■ In small businesses the responsibility of providing competent advice often rests
with the owner/manager.
■ If you’re considering going to a specialist or adviser for competent advice read the
HSE guidance at: www.hse.gov.uk/simple-health-safety/gettinghelp/index.htm
Larger organisations
■ Who has the board lead on health and safety?
■ What is their competence in, and awareness of, health and safety issues?
■ Do they play an active part and how do they support the health and safety
competent person?
■ See the HSE competence-related guidance for a specific industry, task or
working environment (www.hse.gov.uk/competence).
Process industries
■ At least one board member should be technically competent in process safety
management. The competence of plant maintenance engineers is also crucial.
■ You can find more information in the joint HSE/Process Safety Leadership
Group guidance on the Principles of Process Safety Leadership.
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Find out more
There is more advice on competence in Part 3.
Management of Health and Safety at Work Regulations
www.legislation.gov.uk/uksi/1999/3242/contents/made
Principles of Process Safety Leadership HSE/Process Safety Leadership Group
www.hse.gov.uk/comah/buncefield/pslgprinciples.htm
Worker consultation and involvement
‘I find it hard to imagine how one could ever put in place an effective
workplace health and safety system that did not include real
participation and engagement of the workforce.’
Judith Hackitt, HSE Chair
The legal requirements for consultation and involvement of the workforce include:
■ providing information;
■ instruction;
■ training;
■ engaging in consultation with employees, and especially trade unions where
they are recognised.
Beyond the required legal minimum standard, worker involvement is the full
participation of the workforce in the management of health and safety.
At its most effective, full involvement creates a culture where relationships between
employers and employees are based on collaboration, trust and joint problem
solving. Employees are involved in assessing workplace risks and the development
and review of workplace health and safety policies in partnership with the employer.
What are you doing?
■ How are employees or their representatives consulted and involved in health
and safety matters?
■ How effective are those mechanisms in relation to the organisation’s size and
structure, or the rate of workplace change?
■ Are the needs of any vulnerable workers (temporary or agency staff, or those
whose first language is not English) appropriately met, including through, for
example, the use of interpreters, use of symbols and diagrams rather than
written instructions?
■ Are employees consulted in good time?
■ Do health and safety representatives have sufficient time and access to the
facilities they need to carry out their functions?
■ Do contractors have an appropriate level of induction and training?
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Table 4 Worker consultation and involvement – what to look for
Use the following examples of effective and ineffective health and safety management
to check if you are doing what you need to do on worker consultation and involvement.
Additional factors to consider
Dynamic situations where the working environment changes regularly
■ Worker consultation and involvement is fundamental in ensuring risks are
effectively managed.
■ How do you support the necessary increased emphasis on the workforce to
work in a safe manner?
Smaller businesses
■ Smaller businesses tend to have simpler, less formal systems in place such as
face-to-face discussion, toolbox talks, or periodic meetings on specific issues.
■ Do your arrangements allow employees to have a say?
Larger organisations
■ Larger organisations are likely to require or have some form of formal system of
consultation, although informal systems may be present as well.
■ There should be effective consultation arrangements, including an appropriate
number of health and safety representatives and representatives of employee
safety, as well as safety committees and meetings for key issues such as
organisational changes.
Find out more
There is more advice on worker consultation and involvement in Part 3.
HSE’s worker involvement pages: www.hse.gov.uk/involvement
Consulting employees on health and safety: A brief guide to the law Leaflet
INDG232(rev2) HSE Books www.hse.gov.uk/pubns/indg232.htm

What it looks like when done effectively

What it looks like when done badly or not at all

■ Instruction, information and training are provided to enable employees to work in a safe and healthy manner. ■ Safety representatives and representatives of employee safety carry out their full range of functions. ■ The workforce are consulted (either directly or through their representatives) in good time on issues relating to their health and safety and the results of risk assessments. Beyond compliance ■ Feedback mechanisms exist for health and safety matters, such as: ■ ‘suggestions boxes’ or more formal open meetings with management; ■ team meetings are held and may be led by employees. ■ Joint decisions on health and safety are made between managers and workers.

■ Employees lack the right level of information, instruction and training needed to do their job in a safe and healthy manner. ■ Representatives cannot carry out their functions. ■ Employees don’t know who they would go to if they had health and safety concerns. ■ Health and safety controls don’t seem practical or employees are having to work around difficulties. ■ Line managers don’t discuss how to safely use new equipment or how to do a job safely. ■ There is little or no evidence of information being cascaded through the organisation (eg team meetings, notice boards etc).

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Health and Safety
Executive
Part 3: Delivering effective
arrangements
This part of the book is for those who need to put in place their organisation’s
arrangements for health and safety or have particular responsibility for
overseeing them.
The guidance will help you address any specific issues you have identified in
answering the questions posed for leaders, owners, trustees and line managers in
Part 2.
It does this by taking the Plan, Do, Check, Act framework, identifying the key
actions needed in each part of that cycle and relating them back, where
appropriate, to leadership, management, worker involvement and competence.
The key actions covered are:
■ Plan
■ Determining your policy
■ Planning for implementation
■ Do
■ Profiling your health and safety risks
■ Organising for health and safety
■ Implementing your plan
■ Check
■ Measuring performance
■ Investigating accidents and incidents
■ Act
■ Reviewing performance
■ Learning lessons
See Figure 1 on page 9 for a flowchart that illustrates the Plan, Do, Check, Act
framework.
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To implement your health and safety policy, you need to establish and maintain an
effective health and safety management system that is proportionate to the risks.
You should set the direction for effective health and safety management, and a
policy that sets a clear direction will help to ensure communication of health and
safety duties and benefits throughout the organisation.
Policies should be designed to meet legal requirements, prevent health and safety
problems, and enable you to respond quickly where difficulties arise or new risks
are introduced.
■ Think about where you are now and where you need to be.
■ Say what you want to achieve, who will be responsible for what, how you will
achieve your aims, and how you will measure your success. You may need to
write down this policy and your plan to deliver it.
■ Decide how you will measure performance. Think about ways to do this that go
beyond looking at accident figures – look for leading and lagging indicators.
These are also called active and reactive indicators (see ‘Types of monitoring’
on page 49).
■ Consider fire and other emergencies. Co-operate with anyone who shares your
workplace and co-ordinate plans with them.
■ Remember to plan for changes and identify any specific legal requirements that
apply to you.
Determining your policy
What should your policy cover?
An important part of achieving effective health and safety outcomes is having a
strategy and making clear plans.
You need to think about what you are going to do to manage health and safety, then
decide who is going to do what and how. This is your health and safety policy. If your
organisation has five or more employees, that policy must be written down.
Your policy sets a clear direction for the organisation to follow and should be
shared throughout the workforce, so that everyone understands how health and
safety will be managed.
PLAN
Planning
Policy
Plan
Plan Do Check Act
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Who is best placed to write it?
It is best written by someone within the organisation rather than someone from outside,
as it needs to reflect the organisation’s:
■ values and beliefs;
■ commitment to provide a safe and healthy environment.
Consulting and acting on your policy
It should be written in consultation with the workforce, and should be signed by a person
at the top of the organisation – the owner or a director. Most importantly, you should
make sure your actions, and those of your workers, mirror the statements you have made.
Find out more
HSE have created a basic template to help you develop your policy:
www.hse.gov.uk/simple-health-safety/write.htm
Planning for implementation
Why planning is essential
Planning is essential for the implementation of health and safety policies. Adequate control
of risk can only be achieved through co-ordinated action by all members of the organisation.
An effective system for health and safety management requires organisations to plan to:
■ control risks;
■ react to changing demands;
■ sustain positive health and safety attitudes and behaviours.
Effective planning
Effective planning is concerned with prevention through identifying and controlling risks.
This is especially important when dealing with health risks that may only become apparent
after a long period of time.
In addition to setting your policy, planning should include steps to ensure legal compliance
and procedures for dealing with emergency situations. It should involve people throughout
the organisation.
Planning the system you will use to manage health and safety involves:
■ designing, developing and implementing suitable and proportionate management
arrangements, risk control systems and workplace precautions;
■ operating and maintaining the system while also seeking improvement where needed;
■ linking it to how you manage other aspects of the organisation.
In order to plan successfully, you need to establish:
■ where the organisation is now, by considering accurate information about the
current situation;
■ where you need to be, using legal requirements and benchmarking to make comparisons;
■ what action is necessary to reach that point.
Plan Do Check Act
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Key actions in effective policy development and planning

Leaders ■ Make a statement of intention. Say what you will do to keep a safe and healthy environment for your workers and anyone else who could be affected by your work activities. ■ Clearly set out everyone’s roles and responsibilities. Include those with particular roles, for example directors, supervisors/managers, safety representatives, workers, fire wardens, first-aiders and the competent person. ■ Say how things will be done and what resources will be allocated to make things happen. Include details of the systems and procedures that will be in place to help to meet your legal obligations, such as: ■ how risk assessments will be carried out; ■ what your plans are for training and safe use of equipment; ■ what controls you will have in place to ensure your specifiers and buyers are competent in assessing the risks in procurement, for example they know the requirements for purchasing suitable personal protective equipment (PPE); ■ how accidents/incidents will be investigated; ■ how workers will be consulted; ■ how equipment will be maintained; ■ how you will measure the success of your plan. ■ Consider how you will measure health and safety performance. Will there be performance targets, for example reductions in accidents or absences, or an increase in reporting issues or near misses? ■ Prioritise actions. ■ Sign the policy statement to demonstrate commitment to health and safety. Managers ■ Think about management of contractors when developing a policy, if this is relevant to your organisation. ■ Identify when you will revisit your policy and plans, for example: ■ when changes have taken place, such as in processes or staff; ■ following accident or incident investigations, both within the organisation and where lessons have been learned from others; ■ following consultation with employees’ representatives; ■ if you receive new information, eg from manufacturers or others in the same sector or industry. ■ Talk to other occupants not employed or managed by you, but who share the same premises. Worker consultation and involvement ■ Discuss your plans with workers or their representatives. ■ Communicate the plan so that everyone knows what is required. Competence ■ When developing plans and policies, consider the level of competence necessary to comply with the law.

Plan Do Check Act
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Delivery depends on an effective management system to ensure, so far as
reasonably practicable, the health and safety of employees and other people
affected by your work.
Organisations should aim to protect people by introducing management systems
and practices that ensure risks are dealt with sensibly, responsibly and
proportionately.
■ Profiling your organisation’s health and safety risks
■ Assess the risks, identify what could cause harm in the workplace, who it
could harm and how, and what you will do to manage the risk.
■ Decide what the priorities are and identify the biggest risks.
■ Organising for health and safety
In particular, aim to:
■ involve workers and communicate, so that everyone is clear on what is
needed and can discuss issues – develop positive attitudes and behaviours;
■ provide adequate resources, including competent advice where needed.
■ Implementing your plan
■ Decide on the preventive and protective measures needed and put them in place.
■ Provide the right tools and equipment to do the job and keep them
maintained.
■ Train and instruct, to ensure everyone is competent to carry out their work.
■ Supervise to make sure that arrangements are followed.
What does ‘so far as reasonably practicable’ mean?
This means balancing the level of risk against the measures needed to control the
real risk in terms of money, time or trouble. However, you do not need to take
action if it would be grossly disproportionate to the level of risk.

Plan

Do

Check Act

Do
DO Implementing
your
plan
Organising
Risk
profiling
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Profiling your organisation’s
health and safety risks
Effective leaders and line managers know the risks their organisations face, rank
them in order of importance and take action to control them.
The range of risks goes beyond health and safety risks to include quality,
environmental and asset damage, but issues in one area could impact in another.
For example, unsafe forklift truck driving may have a service or quality dimension as
a result of damage to goods.
A risk profile examines the nature and levels of threats faced by an organisation.
It examines the likelihood of adverse effects occurring, the level of disruption and
costs associated with each type of risk and the effectiveness of the control
measures in place.
Although you may not use these precise terms, you will most likely have built a risk
profile that covers:
■ the nature and level of the risks faced by your organisation;
■ the likelihood of adverse effects occurring and the level of disruption;
■ costs associated with each type of risk;
■ effectiveness of the controls in place to manage those risks.
Assessing the risks
What types of risks need to be considered?
In some organisations the health and safety risks will be tangible and immediate
safety issues, eg machine guarding, whereas in others the risks may be healthrelated and it could be a long time before the illness becomes apparent. Degrading
plant integrity could also lead to later emerging risks in some businesses.
Health and safety risks also range from things that happen very infrequently but with
catastrophic effects (high-hazard, low-frequency events, such as an oil refinery
explosion) to things that happen much more frequently but with lesser consequences
(low-hazard, high-frequency events).
Clearly, the high-hazard, low-frequency example could destroy the business and
would be high-priority in a risk profile.
Who should do the assessment?
A risk assessment should be completed by someone with a knowledge of the
activity, process or material that is being assessed. Workers and their safety
representatives are a valuable source of information.
If an adviser or consultant assists with the risk assessment, managers and workers
should still be involved.

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Who could be affected?
Consider all your activities, taking account of possible harm to:
■ employees;
■ contractors;
■ members of the public;
■ those using products and services;
■ anyone else affected by the activity, such as neighbours.
Remember to think of how a risk could affect different groups, such as young or
inexperienced workers, pregnant workers, workers with a disability, migrant workers
or ageing workers. Also consider your supply chain – if that is not properly
managed, the actions of others in those networks can impact on your health and
safety risks.
What the law says on assessing risks
The law states that a risk assessment must be ‘suitable and sufficient’, ie it should
show that:
■ a proper check was made;
■ you asked who might be affected;
■ you dealt with all the obvious significant risks, taking into account the number
of people who could be involved;
■ the precautions are reasonable, and the remaining risk is low;
■ you involved your workers or their representatives in the process.
The level of detail in a risk assessment should be proportionate to the risk and
appropriate to the nature of the work. Insignificant risks can usually be ignored, as
can risks arising from routine activities associated with life in general, unless the
work activity compounds or significantly alters those risks.
Your risk assessment should only include what you could reasonably be expected
to know – you are not expected to anticipate unforeseeable risks.
Find out more
HSE’s risk assessment website: www.hse.gov.uk/risk
Management of Health and Safety at Work Regulations:
www.legislation.gov.uk/uksi/1999/3242/contents/made
Assessing the level of risk
The level of risk arising from the work activity should determine how sophisticated
the risk assessment needs to be.
Small businesses
For small businesses, with few or simple risks, a suitable and sufficient risk
assessment can be a very straightforward process based on informed judgement
and using appropriate guidance.

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Medium-sized businesses or those with greater risks
In these cases, the risk assessment will need to be more sophisticated. You may
need specialist advice for some areas of the assessment, for example:
■ risks requiring specialist knowledge, eg a particularly complex process
or technique;
■ risks needing specialist analytical techniques, eg being able to measure air
quality and to assess its impact.
Large and high-hazard sites
These sites will require the most developed and sophisticated risk assessments.
For manufacturing sites using or storing bulk hazardous substances, large-scale
mineral extraction or nuclear plant, the risk assessment will be a significant part of
the legally required safety case or report, and may incorporate such techniques as
quantified risk assessment.
Other statutory requirements, eg the Control of Major Accident Hazards Regulations
(COMAH) and nuclear installations licensing arrangements, include more specific
and detailed arrangements for risk assessment.
Risk controls
When considering risk controls, discuss the issues with your workers and think
about what is already being done, then compare it with the industry standard. For
example, this could be industry-specific advice from HSE, an employer body, a
trade association, a trade union or a safety organisation.
The risk assessment might have to concentrate more on the broad range of risks
that can be foreseen:
■ where the nature of the work may change fairly frequently or the workplace
itself changes and develops (such as a construction site);
■ where workers move from site to site.
Recording your findings
Record the significant findings. These should include a record of the preventive and
protective measures in place to control the risks, and what further action, if any, needs
to be taken to reduce risk sufficiently, for example health surveillance (see page 29).
If you have fewer than five employees you don’t have to write anything down.
Find out more
More advice for small or low-risk businesses: Health and safety made simple: The
basics for your business Leaflet INDG449 HSE Books
www.hse.gov.uk/pubns/indg449.htm Microsite: www.hse.gov.uk/simple-health-safety
More advice on medium-sized businesses or those with greater risks: The health
and safety toolbox: How to control risks at work HSG268 HSE Books
ISBN 978 0 7176 6587 7 www.hse.gov.uk/pubns/books/hsg268.htm
Microsite: www.hse.gov.uk/toolbox
More advice on large and high-hazard sites: HSE website on the Control of Major
Accident Hazards Regulations (COMAH): www.hse.gov.uk/comah

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Health surveillance
The risk assessment will identify circumstances in which health surveillance is
required by specific health and safety regulations, eg the Control of Substances
Hazardous to Health Regulations 2002 (COSHH).
Health surveillance should also be introduced where the assessment shows all the
following criteria apply:
■ there is an identifiable disease or adverse health condition related to the work
concerned;
■ valid techniques are available to detect indications of the disease or condition;
■ there is a reasonable likelihood that the disease or condition may occur under
the particular conditions of the work;
■ surveillance is likely to help protect the health and safety of the employees to be
covered.
Find out more
HSE’s COSHH site: www.hse.gov.uk/coshh
HSE’s health surveillance site: www.hse.gov.uk/health-surveillance

Key actions in effective risk profiling

Leaders ■ Identify who takes ownership of health and safety risks: ■ This might be the owner, or chief executive – in larger organisations it may be a risk committee or a senior board champion for health and safety. ■ Think about the consequences of the worst possible occurrence for your organisation: ■ How confident are you that plans are in place to control the effects? ■ Ensure that risk assessments are carried out by a competent person: ■ This is someone who has the necessary skills, knowledge and experience to manage health and safety effectively. ■ Maintain an overview of the risk-profiling process: ■ Make sure you are aware of the major risks within your organisation. ■ Check that minor risks have not been given too much priority and that major risks have not been overlooked. ■ Identify who will be responsible for implementing risk controls and over what timescale. ■ Remember to assess the effects of changing technology: ■ Think about issues related to changes in asset ownership. This may increase the risk profile if design information and knowledge haven’t been passed on. ■ Have the effects of ageing plant and equipment been examined?

 

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Managers
Identify the risks
■ Identify the health and safety risks from the business and prioritise them. Think
about the severity of the harm and the likelihood of occurrence. Concentrate on
priority risks.
■ Ensure that risks are owned so that appropriate resources can be allocated.
■ Consider whether other risks are due to health and safety lapses.
Who might be affected?
■ Think about everyone who might be affected by your work activities.
Remember that certain groups may be at increased risk, eg young or
inexperienced workers, pregnant workers, workers with a disability, migrant
workers or ageing workers.
Control measures
■ Consider whether any control measures are already in place or if further action
is needed.
■ Recognise that full implementation of control measures may take time, and
implement interim measures to minimise the risks.
Report, record and review
■ Report risk control performance regularly internally and consider whether it
should be done externally.
■ Make sure paperwork is kept to the minimum levels necessary. You only need
to record the risk assessment if you employ five or more people.
■ Review the organisation’s risk profile regularly. Change within the organisation will
affect the risk profile, eg during economic cycles such as recession and recovery,
when there is an increase in workload, or when experience levels drop.
Worker consultation and involvement
■ Do workers understand the organisation’s risk profile?
■ Do they have the necessary information, instruction and training to deal with
the risks that have been identified?
■ Consult with workers and their representatives in all parts of the organisation to
ensure that all areas of risk have been identified.
Competence
■ A broad knowledge of the entire organisation will be needed to draw up its
risk profile.
■ In high-hazard organisations, identify what specialist advice may be necessary
to identify hazards and analyse the risks.
■ Make sure workers are trained and have information about risk controls.

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Organising for health and safety
‘Organising for health and safety’ is the collective label given to activities in four key
areas that together promote positive health and safety outcomes:
■ Controls within the organisation: the role of supervisors – leadership,
management, supervision, performance standards, instruction, motivation,
accountability, rewards and sanctions
■ Managing contractors – anyone engaging contractors has health and safety
responsibilities, both for the contractors and anyone else that could be
affected by their activities
■ Co-operation – between workers, their representatives and managers through
active consultation and involvement
■ Communication – across the whole organisation, through visible behaviour,
written material and face-to-face discussion
■ Competence – of individuals through recruitment, selection, training, coaching,
specialist advice and avoiding complacency
■ Capabilities and training – help people gain the skills and knowledge, and
ultimately the competence, to carry out their work safely and without risk to
their health
■ Specialist help – you may need specialist help if your business has
hazardous or complex processes
Controls within the organisation: the role of supervisors
The actions of leaders, line managers and supervisors are all important in delivering
effective control of health and safety risks. Those actions are covered in ‘Are you
doing what you need to do?’ (Part 2 of the book). This section complements that
by focusing on supervisors.
Organisations will decide their own approach to supervision. Whatever method of
supervision is used, the role of a supervisor or team leader is important in
implementing effective controls.
Because of the regular contact they have with workers, they can make an
important contribution to making sure:
■ everyone knows how to work safely and without risk to their health;
■ all workers follow the organisation’s rules.
A supervisor can coach, help or guide workers to become and remain competent
in these areas as well as others.

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Key actions in supervising for health and safety effectively

Leaders ■ Define supervisors’ roles and responsibilities, and make sure they are trained and competent in carrying out their role, recognising the importance of supervision as a part of risk control. ■ Make sure the supervisor/team leader has sufficient resources to deal with health and safety issues as part of ‘getting the job done’. Managers ■ Consider the level of supervision necessary for each task according to its complexity and level of risk. Recognise that differing levels of supervision may be needed at certain times, for example during shift changeover or where there are young or inexperienced workers. ■ Include supervisors in assessing risks and managing the effects of any changes. ■ Encourage supervisors/line managers to have a positive attitude to health and safety – they should lead by example and encourage safe systems of work. ■ Make sure supervisors understand the job, so they can make effective, safe decisions. ■ This includes checking that they understand what is expected of them, especially during an emergency. ■ Confirm that supervisors have planned the work and allocated sufficient resources to allow tasks to be completed safely and without risks to health. ■ Make sure that a good example is being set for the workers, and that supervisors enforce the rules. ■ If more than one supervisor/line manager is involved in a process, make sure that communication, co-ordination and co-operation take place. Worker consultation and involvement ■ Supervisors can help involve workers and their representatives: ■ by facilitating discussions on the likely risks in their work and precautions they should take; ■ in the introduction of any measures that may affect their health and safety. Competence ■ Supervisors must be competent to supervise the workers, and know the critical safety aspects of the job.

Managing contractors
Anyone engaging contractors has health and safety responsibilities, both for the
contractors and anyone else that could be affected by their activities. Contractors
themselves also have legal health and safety responsibilities. Make sure everyone
understands the part they need to play in ensuring health and safety.
Use of contractors in itself does not result in poor health and safety standards, but
poor management can lead to injuries, ill health, additional costs and delays.
Working closely with the contractor will reduce the risks to your own employees
and the contractors themselves.

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Remember that contractors may be at particular risk; they may be strangers to your
workplace and therefore unfamiliar with your organisation’s procedures, rules,
hazards and risks. Even regular contractors may need reminding. The level of
control needed will, of course, be proportionate to the complexity of the task.
On sites with major accident hazards, consider turnarounds and span of control –
given the potentially very high numbers of contractors on-site (compared with the
numbers in routine operations).
Find out more
Using contractors: A brief guide Leaflet INDG368(rev1) HSE Books
www.hse.gov.uk/pubns/indg368.htm
Managing health and safety in construction. Construction (Design and
Management) Regulations 2007. Approved Code of Practice L144 HSE Books
ISBN 978 0 7176 6223 4 www.hse.gov.uk/pubns/books/l144.htm

Key actions in managing contractors effectively

Leaders ■ Be clear about the work you expect the contractor to do and think about the standards of competence that will be required. ■ Think carefully about contingencies if things don’t go to plan. ■ Demonstrate the importance your organisation places on health and safety in the selection of contractors. ■ Ensure short cuts are not taken to reduce costs and there is no conflict of performance versus safety. ■ Allocate sufficient time and resources to the job – in planning, preparing and carrying out the task. ■ Support management decisions to stop work if there are serious health and safety concerns. ■ Be ready to address health and safety failings by engaging directly with the leader of the contracting organisation, and acknowledge successes. Managers Monitor the contractor’s health and safety performance ■ Consider how the work will be managed and supervised before the work starts. ■ Obtain the contractor’s health and safety plans. ■ Hold a pre-start meeting to ensure co-ordination and communication – ensure that incorrect assumptions are not made. Will the contractor need a site induction before beginning work on your site? ■ Include contractor’s activities in all inspections and checks. ■ Hold regular progress meetings and raise health and safety issues as they occur. Carry out a joint risk assessment of the work with the contractor ■ Remember that some of the risks in your workplace may not be obvious to the contractor. ■ Tell the contractor about any specific risks within your workplace, eg the presence of asbestos. ■ Share method statements or safe systems of work. ■ Tell employees and contractors about the risks, and make sure that the contractors let you know of any additional risks they will be introducing to your site.

 

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Have the right procedures in place
■ Ensure safe systems that are documented are carried out in practice.
■ Make sure everyone is competent to carry out the tasks and that contractors
receive induction.
■ Make sure isolation procedures for machinery and plant are clear.
If you have an incident
■ Stop the work if there are serious health and safety concerns.
■ Investigate and address the root cause of any incident, feeding back results of
the investigation to everyone involved.
Check that everyone understands the risks
■ Ensure that work does not start until the contractors fully understand the risks
and measures to control them.
■ Make sure contractors understand the information, instruction and training you
are giving them, taking account of any language difficulties or disabilities. You
may need to provide information in a language other than English.
Worker consultation and involvement
■ All workers should have clear lines of communication to report concerns.
■ Communicate and co-ordinate so that employees and contractors know what
is expected of them and when, and everyone understands their individual roles.
Competence
■ Address training issues through toolbox talks, instruction or coaching.
■ Consider how the competence of the contractor will be verified:
■ Can they demonstrate previous health and safety performance,
eg references/pre-qualification questionnaire?
■ Can they verify health and safety training?
■ Can verification of licensing be obtained where required, eg Gas Safe
registration?
■ Will the contractor’s lack of experience within your organisation lead to
additional risks? If so, how will this be addressed?
Co-operation
What is worker involvement?
This means involvement of the workforce beyond the required legal minimum
standard (ie more than consultation), where you develop a genuine management/
workforce partnership based on trust, respect and co-operation.
With such a partnership in place, a culture can evolve in which health and safety
problems are jointly solved and in which concerns, ideas and solutions are freely
shared and acted upon.
The effect of workforce involvement is that operational practices and health and
safety risk management are aligned for the benefit of all and with the co-operation
of everyone (workers, their representatives and managers). The advice on pages
19–20 will help you decide if you are doing what you need to.

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Co-ordination with contractors
The second aspect of co-operation is co-ordination with contractors (see pages 32–4), as
well as others in an organisation’s supply chain.
As health and safety affects the entire workforce of an organisation, it makes sense for
all workers to be involved in managing health and safety.
Ways of involving workers
Involving workers is key to integrating health and safety as part of everyday business
rather than being seen as something done by somebody else.
Organisations can find appropriate ways to involve their workers in managing health and
safety. For smaller firms, this may be simply:
■ encouraging open communications (eg toolbox talks, suggestion schemes, notice
boards, or health and safety walkabouts) where workers can discuss or raise their
concerns;
■ giving recognition when workers identify risks.
For larger businesses, more formal health and safety forums or committees can be a
means of enabling worker involvement which may need to cater for part-time workers
and contractors.
Contacts with external services
Employers need to ensure that any necessary contacts with external services are
arranged, and procedures are put in place so workers know what to do in situations
presenting serious and imminent danger, such as a fire.
You need to have effective arrangements for first aid, emergency medical care and
rescue work. This may only mean making sure that workers know the necessary
telephone numbers and, where there is a significant risk, they are able to contact any
help they need.
Contacts and arrangements with external services should be recorded, and should be
reviewed and revised as necessary.
Shared workplaces
Where a number of employers share a workplace and their workers face the same risks,
one employer should arrange contacts on behalf of themselves and the other employers.
High-hazard or complex workplaces
In high-hazard or complex workplaces, employers should designate appropriate staff to
routinely contact the emergency services and utilities.
They should provide enough information for those services and utilities to take appropriate
action in emergencies, including those likely to happen outside normal working hours.
Emergency procedures
Employers must explain clearly the procedure for any worker to follow in serious and
imminent danger.
Employees and others at work need to know when they should stop work and how they
should move to a place of safety. In some cases this will require full evacuation of the
workplace, in others it might mean some or all of the workforce moving to a safer part of
the workplace.

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Emergency planning and co-operation with the emergency services
Police officers, fire-fighters and other emergency service workers, for example, may
sometimes need to work in circumstances of serious or imminent danger in order to
fulfil their commitment to the public. The procedures should reflect these
responsibilities, and the time delay before such workers can move to a place of safety.
Work should not be resumed after an emergency if a serious danger remains. If
there are any doubts, expert assistance should be sought, eg from the emergency
services and others.
Danger areas
A danger area is a work environment where the level of risk is unacceptable, but an
employee must enter without taking special precaution. Such areas are not
necessarily static, in that minor alterations or an emergency may convert a normal
working environment into a danger area.
The hazard involved need not occupy the whole area (as in the case of a toxic gas)
but can be localised, eg where there is a risk of an employee coming into contact
with bare, live electrical conductors. The area must be restricted to prevent
inadvertent access.
Exceptional circumstances for re-entering danger areas
For emergency service workers there may be circumstances when re-entering serious
danger areas may be deemed necessary, for example where human life is at risk.
When such exceptional circumstances can be anticipated, the procedures should
set out the special protective measures to be taken (and the pre-training required),
as well as the steps needed to authorise such actions.
Principles that help clarify how Fire and Rescue Authorities can strike the balance
between their operational and health and safety duties are set out in an HSE
publication at www.hse.gov.uk/services/fire/duties.pdf.
Similarly, for police activities see www.hse.gov.uk/services/police/duties.pdf,
which is expanded in an explanatory note: www.hse.gov.uk/services/police/
explanatory-note.pdf.
Find out more
For more information on requirements to consult health and safety representatives
and employees in existing health and safety legislation:
Consulting workers on health and safety. Safety Representatives and Safety
Committees Regulations 1977 (as amended) and Health and Safety (Consultation
with Employees) Regulations 1996 (as amended). Approved Codes of Practice and
guidance L146 (Second edition) HSE Books ISBN 978 0 7176 6461 0
www.hse.gov.uk/pubns/books/l146.htm
HSE’s worker involvement site: www.hse.gov.uk/involvement
Consulting employees on health and safety: A brief guide to the law Leaflet
INDG232(rev2) HSE Books www.hse.gov.uk/pubns/indg232.htm
HSE guidance for the Police Service: www.hse.gov.uk/services/police
HSE guidance for the Fire and Rescue Services: www.hse.gov.uk/services/fire

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Key actions in co-operating effectively

Leaders ■ Gain commitment from your managers to consult and involve the workers. ■ Show commitment to involving workers by being visible, communicating and listening to concerns, and jointly solving problems. ■ Allocate resources to allow effective consultation to take place. ■ Discuss with employees and representatives the best ways for information to be shared (see www.hse.gov.uk/involvement/involveemployees.htm). Consider issues of language, literacy and learning disabilities if appropriate. Managers ■ Find out how your workers want to be consulted. How you consult will be affected by: ■ the size and structure of your organisation; ■ the diversity of your workforce; ■ the type of work carried out; ■ trade union representation; ■ people who work offsite; ■ the nature of the risks present. ■ Think about how you will share information – remember to consider contractors and those who may have language barriers. ■ By law, you must consult your workforce about any change that may substantially affect their health and safety. Such changes may include: ■ new or different procedures; ■ types of work; ■ equipment; ■ premises; ■ ways of working, eg new shift patterns; ■ your arrangements for getting competent people (www.hse.gov.uk/involvement/ competentperson.htm) to help you meet your obligations under health and safety laws, eg appointing a health and safety manager; ■ information you must give your workforce on the likely risks in their work and precautions they should take (www.hse.gov.uk/involvement/riskassessments.htm); ■ planning of health and safety training (www.hse.gov.uk/involvement/training.htm); ■ health and safety consequences of introducing new technology. ■ Formulate plans to ensure the workforce is consulted (either directly or through their representatives) in good time on issues relating to their safety. This will mean workers feel health and safety is a part of normal work activity, not something that is left to ‘specialists’. ■ Decide what your procedure will be if there are disagreements. ■ Have shift-workers and part-time workers been considered? ■ Make sure you make contact with external services, if needed, when formulating your emergency procedures. Competence ■ Make sure you are familiar with the legal requirements to consult and involve workers (www.hse.gov.uk/involvement/whattoconsult.htm). ■ Plan joint health and safety training sessions for managers and workers so they can share views and experiences. ■ Managers should be confident about speaking to workers. ■ If your workforce has appointed safety representatives, you must ensure they are provided with paid time off as is necessary to have training that enables them to carry out their role. ■ Make sure workers know what to do in an emergency.

 

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Communication
To achieve success in health and safety management, there needs to be effective
communication up, down and across the organisation.
Organisations need to communicate information to their workers on the risk to their
health and safety identified in their risk assessments, and the preventive and
protective measures necessary to control risk.
The information provided should be communicated appropriately, taking into account:
■ workers’ levels of competence;
■ the size and structure of the organisation.
How size and structure affect communication
A high-risk workplace, with a large unionised workforce spread over multiple sites,
may have trade union representatives from different sites as members of a formal
health and safety committee that meets regularly, and feeds into a corporate health
and safety committee.
A non-unionised, smaller workplace located on one small, low-risk site, is more
likely to consult directly with employees on a day-to-day basis (eg through toolbox
talks, or short safety briefings).
Find out more
Consulting and involving your workers – ways to engage:
www.hse.gov.uk/involvement/factorstoconsider.htm
More advice on human factors: www.hse.gov.uk/humanfactors/topics/culture.htm
HSE human factors briefing note on safety-critical communications:
www.hse.gov.uk/humanfactors/topics/08communications.pdf
HSE human factors guide on common topics in safety-critical communications:
www.hse.gov.uk/humanfactors/topics/common3.pdf

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Key actions in communicating effectively

Leaders ■ Ensure that time is allocated so that communications can take place. Managers ■ Formulate plans for cascading information. Remember to plan how you will get messages across to contractors, anyone with low levels of literacy, or those whose first language is not English. ■ Think about what needs to be communicated and to whom. How will your health and safety policy, risk assessment findings and safe systems of work be shared? ■ Lay out clear communications procedures for safety-critical tasks. ■ Where needed, plan your communications with emergency services. Who will co-ordinate this and how will it be done? ■ Ensure that communication is included in change management procedures. ■ Ensure that written instructions are clear and up to date. ■ Make sure that safety-critical messages have been given attention and are understood. Worker consultation and involvement ■ Involve workers or their representatives in planning communications activities. They will be able to help identify and resolve barriers to communication within your organisation. ■ Are workers able to give feedback and report their concerns? ■ Have you considered vulnerable groups within your workforce in your communications plans, eg young or inexperienced workers, workers with a disability or migrant workers? Competence ■ Plan training or coaching to ensure that line managers have the skills needed to carry out face-to-face discussions at all levels within the organisation.

Competence
Organisations must appoint one or more competent people to help carry out the measures
needed to comply with the law. It is important for organisations to decide the level of
competence necessary to comply with the law. A judgement can be made using the
organisation’s risk profile (see pages 26–30).
Who should be the competent person?
Smaller, low-hazard environments
The role could be allocated to the owner or someone else in the organisation who does not
necessarily have a qualification but does have knowledge and experience of the business.
However, it is important that the nominated person is able to recognise issues outside
their competence, so that more experienced advice can be sought where necessary.
Larger or more hazardous environments
The risk profile may point to employing a specialist adviser to comply with the law.
Find out more
HSE advice on competence in health and safety: www.hse.gov.uk/competence/
Competence-related guidance for a specific industry, task or working environment:
www.hse.gov.uk/competence/industry-specific-competence.htm

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Key actions in competence

Leaders ■ Consider the organisation’s risk profile and establish whether you have enough in-house competence to comply with your legal obligations. Plan ahead to ensure you retain enough experienced, competent employees. ■ Ensure that workers and managers are able to deliver their responsibilities. ■ Ensure that the nominated competent person(s) has time available to keep up to date with changes in the law and industry good practice. Managers ■ Carry out proper induction and reinforce learning through peer behaviour, coaching and supervision. ■ Make sure all workers have the necessary training, knowledge and experience to carry out their job safely and without risk to their health. ■ Make sure workers understand the information, instruction and training you are giving them, taking account of any language difficulties or disabilities. You may need to provide information in a language other than English. ■ Consider workers’ individual capability before allocating work. Will they have the capacity to react safely to circumstances or changes? If they are unable to do this, what might the consequences be? ■ Set out arrangements to capture workers’ ideas and suggestions. ■ Make sure there are arrangements for retaining and sharing corporate knowledge. ■ Identify workers with knowledge and experience who could help others develop their level of competence. ■ Training alone does not achieve competence – make sure competence is achieved through consolidation and practical experience. ■ Make sure human factors are covered, for example the effects of fatigue. Worker consultation and involvement ■ Encourage workers to identify gaps in their knowledge or experience. ■ Discuss plans for learning and development with workers or their representatives.

Capabilities and training
What capabilities do employees need to have?
To comply with the law, employees need to have the skills, knowledge and
experience to carry out their duties safely.
Organisations should take into account their employees’ capabilities, to ensure the
demands of the job do not exceed their ability to do the work without risk to
themselves or others.
Everyone in an organisation requires adequate health and safety training. Training
helps people gain the skills and knowledge, and ultimately the competence, to carry
out their work safely and without risk to their health.

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Training isn’t just about formal ‘classroom’ courses – it can be delivered in a number of
ways, for example:
■ informal, ‘on the job’ training;
■ written instructions;
■ online information;
■ simply telling someone what to do.
Employees must be given information about the risks involved in their work, and the steps
that need to be taken to reduce or remove those risks.
Where training is particularly important
There are situations where health and safety training is particularly important, for example:
■ when people are new to the job;
■ on exposure to new or increased risks;
■ where existing skills may have become rusty or need updating.
Training is not a substitute for risk control
Training should not be a substitute for proper risk control, for example to compensate for
poorly designed equipment. It may be appropriate as a temporary measure of control until
permanent improvements can be made.
Find out more
Health and safety training: A brief guide Leaflet INDG345(rev1) HSE Books
www.hse.gov.uk/pubns/indg345.htm

Key actions in capability and effective health and safety training

Leaders ■ Provide resources to enable training to take place. Ensure that sufficient time is given for training. ■ Ensure a system is in place which provides assurance that workers and managers involved in safety-related work remain competent. ■ Make sure that contingency plans are in place. What would happen if a key member of staff were to suddenly leave the organisation? ■ Ensure that your organisation has access to competent health and safety advice. This may be through a trained in-house adviser, or a competent external consultant – see the Occupational Safety and Health Consultants Register (OSHCR): www.hse.gov.uk/oshcr. ■ Demonstrate personal compliance with health and safety training. Workers will follow your example. Managers Planning for training ■ Decide if training is necessary. Think about the job, the person who carries it out, the processes and equipment required. ■ Remember that contractors will need to be trained. ■ Ensure there is a system in place to identify training needs during recruitment and when there are changes of staff, plant, processes, substances or technology. ■ Find out which specific training you must provide by law, such as for operating forklift trucks. ■ Prioritise training needs.

 

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■ Decide the format that training will take, for example:
■ formal course coaching;
■ informal, ‘on the job’ training;
■ written instructions;
■ online information;
■ simply telling someone what to do.
■ Remember that additional arrangements may be necessary for those whose
first language may not be English, or those with low levels of literacy.
■ If the task is new, can you learn from other organisations?
■ How will you make sure workers receive refresher training?
■ Newly trained workers should receive close supervision to ensure that they are
competent in carrying out their duties.
Monitoring and measuring training’s effectiveness
■ How will training records be kept?
■ Monitor learning outcomes and training methods.
■ Review training material regularly to ensure that it remains current.
■ Consider remedial training if lack of competence is identified as the cause of
an incident.
■ Gather feedback on training.
■ Decide whether the training delivered its objectives. Consider whether there
have been any improvements following the training – if not, initiate changes.
Worker consultation and involvement
■ You must consult workers or their representatives during the planning and
organising of training.
■ Appointed safety representatives must have paid time to carry out their
functions, and to have training in those functions.
Competence
■ Ensure that training material or information comes from a reliable source and
that the person carrying out the training is competent to do so.
■ If training is outsourced, make sure the trainer has a good understanding of
your organisation and its requirements.
■ Decide how the organisation will keep up to date with changes in legislation
and methods of risk control.
■ Remember that competence levels will drop if skills are not used on a regular
basis – schedule refresher training at regular intervals.
■ Simulation exercises and drills will be required for some high-risk activities,
eg control room operators’ full-site emergency exercises.
■ Don’t assume that workers will be competent following a course or
instruction – check.
■ Review your employees’ capabilities and provide additional or refresher training
if needed.

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Specialist help
When you may need specialist help
You may need specialist help if your business has hazardous or complex processes.
However, for many organisations a manager, leader, or competent member of staff
should be able to take the necessary action to comply with the law.
See ‘Find out more’ on page 45 for other sources of information.
What the law says on specialist help
If you need to engage outside help, you must remember that you cannot devolve
the management of health and safety risks to others. However, specialist or
consultant help can be used to contribute to your overall health and safety
management.
Using advisers does not absolve the employer from responsibilities for health and
safety under the Health and Safety at Work etc Act 1974 and other relevant
statutory provisions under the Regulatory Reform (Fire Safety) Order 2005
(www.hse.gov.uk/toolbox/fire.htm). It can only give added assurance that these
responsibilities will be discharged adequately.
It is essential that the specialist or consultant is competent to provide your
organisation with correct, proportionate advice.
Useful sources of advice may include:
■ trade associations;
■ safety groups;
■ trade unions;
■ consultants registered on the Occupational Safety and Health Consultants
Register (OSHCR): www.hse.gov.uk/oshcr;
■ local councils;
■ health and safety training providers;
■ health and safety equipment suppliers.
Additional checks for employing an occupational physician
If there is a need for medical support in the workplace it is not sufficient to engage
any doctor. Specialist knowledge is required in occupational medicine – doctors
with a Diploma in Occupational Medicine (DOccMed) are able to give basic advice
with some understanding of main issues affecting work and health.
Members or Fellows of the Faculty of Occupational Medicine (MFOM or FFOM)
have had in-depth training and are fully knowledgeable in occupational medicine
(www.fom.ac.uk).
Associates of the Faculty of Occupational Medicine (AFOM) have core knowledge in
occupational medicine, but are not specialists in this field (www.fom.ac.uk/
membership/associate-afom).

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Table 5 Some examples of specialist help

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Specialist	Expertise
Ergonomists	■ Field of vision, sight lines ■ Manual handling/repetitive tasks ■ Workspace layout ■ Body size ■ Aspects of guarding and containment ■ Demands of tasks/equipment on people ■ The equipment used and whether it is appropriate for the task ■ Effects of the physical environment, including lighting, temperature and humidity on people ■ Issues of fatigue and opportunities/defences for human failure
Microbiologists	■ Assessment of biological hazards ■ Advice on risks and control measures to prevent or control health risks ■ Sampling for micro-organisms
Noise and vibration specialists	■ Measure levels ■ Advice on causes, elimination and practical solutions to reduce exposure
Occupational health professionals (doctors and nurses)	■ Diagnosis and treatment of work-related disease (doctors) ■ Assessment of risks to health and advice on managing those risks ■ Health surveillance and other health checks ■ Fitness-for-work issues ■ Advice on pre-employment health screening, sickness absence and ill-health retirement ■ Providing health education, advice on rehabilitation after illness or injury
Occupational hygienists	■ Assessment and practical advice on preventing or reducing health risks from chemical, biological and physical agents arising from work activities ■ Environmental monitoring
Physiotherapists	■ Provide treatment and rehabilitation advice ■ Advice on preventing musculoskeletal disorders
Radiation protection advisers	■ Advice on complying with legislation on the use of ionising radiation in the workplace ■ Conducting environmental monitoring
Specialist engineers	■ Advice on issues including control and instrumentation (C&I), electrical, chemical, mechanical engineering

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Key actions in managing specialist help effectively

Leaders ■ Make adequate resources available to provide competent advice to your organisation. ■ Review the effectiveness of the arrangements for obtaining specialist help – poor or misinterpreted advice could have an adverse effect on your organisation. Managers ■ Think about exactly what you need help with. ■ Make sure you have understood the advice given by the specialist, and that any solutions offered are sensible and workable. ■ Implement the advice – monitor its effect and review. ■ Meet with the specialist to discuss your requirements. It is essential that they have a good understanding of your organisation before offering advice. Worker consultation and involvement ■ Make sure the specialist or consultant works with workers or their representatives in assessing risk and establishing control measures. Competence ■ How will you check that the specialist is the right person to help? ■ Do they have experience in your type of work? ■ Have you checked that the specialist or consultant is competent? A good indicator is to check OSHCR (www.hse.gov.uk/oshcr).

Find out more
Institute of Occupational Safety and Health (IOSH): www.iosh.co.uk
Royal Society for the Prevention of Accidents (RoSPA): www.rospa.com
British Safety Council (BSC): www.britsafe.org
Competence in health and safety: www.hse.gov.uk/competence
National Examination Board for Occupational Safety and Health
(NEBOSH): www.nebosh.org.uk
Trades Union Congress (TUC): www.tuc.org.uk
Federation of Small Businesses (FSB): www.fsb.org.uk
Chartered Institute of Environmental Health (CIEH): www.cieh.org
Royal Society of Chemistry (RSC): www.rsc.org
EEF – The Manufacturers’ Organisation: www.eef.org.uk
BOHS (The Chartered Society for Worker Health Protection): www.bohs.org

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Implementing your plan
In addition to ensuring everyone is competent to carry out their work safely, and that there
is adequate supervision to make sure arrangements are followed, workplace precautions
will be easier to implement if:
■ risk control systems and management arrangements have been well designed;
■ those systems and arrangements recognise existing business practice and human
capabilities and limitations.
The key steps
■ Decide on the preventive and protective measures needed and put them in place.
■ Provide the right tools and equipment to do the job and keep them maintained.
■ Train and instruct, to ensure everyone is competent to carry out their work.
■ Supervise to make sure that arrangements are followed.
Documentation
Documentation on health and safety should be functional and concise, with the emphasis
on its effectiveness rather than sheer volume of paperwork.
Focusing too much on the formal documentation of a health and safety management
system will distract you from addressing the human elements of its implementation – the
focus becomes the process of the system itself rather than actually controlling risks.
In some cases, the law requires suitable records to be maintained, eg a record of risk
assessments under the Management of Health and Safety at Work Regulations 1999
(MHSWR) and the Control of Substances Hazardous to Health Regulations 2002 (COSHH) –
see ‘Find out more’ below.
Implementing risk control plans
The control of relatively minor risks affecting all employees (such as ensuring passages
and gangways remain free from obstruction) can be dealt with by a number of simply stated
general rules.
The control of more hazardous activities may need more detailed risk control systems. The
control of high-hazard activities may demand detailed workplace precautions and a risk
control system that needs to be strictly followed, such as a permit-to-work system.
The type, frequency and depth of maintenance activities should reflect the extent and nature
of the hazards and risks revealed by risk assessment. The balance of resources devoted to
the various risk control systems will also reflect your risk profile (see pages 26–30).
Find out more
Management of Health and Safety at Work Regulations:
www.legislation.gov.uk/uksi/1999/3242/contents/made
Control of substances hazardous to health. The Control of Substances Hazardous to Health
Regulations 2002 (as amended). Approved Code of Practice and guidance L5 (Sixth edition)
HSE Books ISBN 978 0 7176 6582 2 www.hse.gov.uk/pubns/books/l5.htm

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Key actions in implementing your plan effectively

Leaders ■ Leaders should take positive steps to address human factors issues and to encourage safe behaviour. They need to recognise that the prevailing health and safety culture is a major influence in shaping people’s safety-related behaviour. ■ Make the necessary resources available to successfully implement your plan. Resources include human resources and specialised skills, organisational infrastructure, technology and financial resources. Managers ■ Keep any documentation proportionate to the complexity of the risks concerned. Keep it to the minimum needed for effectiveness and efficiency. ■ Agree realistic timescales for implementation of any plans with your workforce. ■ Ensure all concerned are clear on their role and responsibilities, and understand the steps they need to undertake to meet the objectives. Clearly communicate who is responsible, accountable and competent to undertake specific tasks. ■ Demonstrate your commitment to delivery at all levels within the organisation, using a variety of communication channels to engage your workforce in implementation. This can be through visible behaviour, written material and face-to-face discussions. ■ Keep people informed of progress and maintain a focus in the key risks and issues. Use review meetings (or make use of existing internal forums) as a basis for helping to make further improvements. ■ Measure progress of implementation against clear milestones or performance indicators and make necessary adjustments if there is early evidence that requirements are not being met. ■ Recognise contributions and safe behaviours that help create or reinforce positive attitudes and behaviours. ■ Do your arrangements give you the assurance that workers and contractors are following workplace precautions and risk controls? ■ Make full use of expertise available on safety committees and other forums (where these are in place) to deliver. Worker consultation and involvement ■ Involve and consult workers and representatives throughout any implementation, by ensuring you have systems in place that allow workers to raise concerns and make suggestions, eg staff suggestion schemes, online communities, committees etc. ■ Make sure you consider all feedback, take action or provide a prompt response. Competence ■ Ensure the competence of individuals is developed through experience and training, managers are providing coaching and the organisation learns by making use of specialist advice as required. ■ Use the results of progress reviews to feed into future training plans – this helps with continuous improvement and avoids complacency.

 

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Monitoring and reporting are important parts of health and safety arrangements.
Management systems allow organisations to receive both specific (eg incident-led)
and routine reports on the performance of health and safety policy.
■ Measuring performance
■ Make sure that your plans have been implemented – ‘paperwork’ on its own
is not a good performance measure.
■ Assess how well the risks are being controlled and if you are achieving your
aims. In some circumstances formal audits may be useful.
■ Investigating accidents and incidents
■ Investigate the causes of accidents, incidents or near misses.
Measuring performance
Checking that you are managing risks in your organisation is a vital, sometimes
overlooked step. It will give you the confidence that you are doing enough to keep
on top of health and safety and maybe show you how you could do things better in
the future.
Checking involves setting up an effective monitoring system, backed up with
sensible performance measures.
Investigating and analysing incidents will also make a big contribution to
understanding health and safety in your business (see pages 51–3).
Monitoring
You need to be sure that your monitoring adds value and isn’t just a tick-box exercise.
Good-quality monitoring will not just identify problems but will help you understand
what caused them and what sort of changes are needed to address them. Poor
monitoring might tell you that something is wrong but may not help you understand
why, or what to do about it.
Plan Do Check Act
Check
CHECK
Investigating
accidents/
incidents/
near misses
Measuring
performance
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How to monitor
Use the same approach to monitor your health and safety performance as you
would when you monitor other aspects of your business.
Monitoring requires time and effort. So you need to allocate appropriate resources
and possibly train staff involved in it ahead of time. Businesses may monitor health
and safety in different ways, depending on size and sector, but there are some
basic principles that apply across the board.
Monitoring needs to be timely. As with all other business systems, you want to
know what is happening in your organisation at the moment rather than at some
point in the past.
The outcome of your monitoring will have most impact if it is reported back to key
decision makers in your organisation. Unless there’s a board-level commitment in
advance, so you can act on what your monitoring tells you, then all your efforts to
collect information could be wasted.
Types of monitoring
There are many different types of monitoring but they can generally be categorised
as either ‘active’ or ‘reactive’:
■ Active methods monitor the design, development, installation and operation of
management arrangements. These tend to be preventive in nature, for example:
■ routine inspections of premises, plant and equipment by staff;
■ health surveillance to prevent harm to health;
■ planned function check regimes for key pieces of plant.
■ Reactive methods monitor evidence of poor health and safety practice but
can also identify better practices that may be transferred to other parts of a
business, for example:
■ investigating accidents and incidents (see pages 51–3);
■ monitoring cases of ill health and sickness absence records.
Selecting the right measures
Most organisations use performance measures as part of their monitoring.
Checking performance against a range of pre-determined measures is one of the
most frequently used techniques of monitoring.
Selecting the right measures to use is the critical step. Using the wrong measures
will cause a lot of unnecessary and unproductive effort, with little benefit to your
organisation.
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Key actions in measuring performance effectively

Leaders ■ Demonstrate commitment to the process. ■ Ensure that systems are in place to report performance upwards so that you, as leaders or directors, can review and be assured that legal compliance is achieved and maintained. ■ Make certain there is a process in place to report serious incidents upwards immediately. ■ Receive and review reports at regular intervals. ■ Question results and ensure that action is planned to tackle poor performance and ensure the system you use to manage health and safety works. Managers Think about who will monitor what ■ You may need to involve different levels within the management chain, as well as workers’ representatives and health and safety advisers. Decide how often monitoring will take place ■ Be proportionate. ■ Think about your risk profile. ■ Monitor key risks and precautions more often and in more detail. ■ Remember that the frequency of some monitoring or inspections is determined by law. Plan what action you will take if your measure goes up or down ■ There’s no use getting information about performance if you haven’t got some idea of what you will do if performance looks like it needs to improve. Use performance measurement results ■ To improve health and safety performance. ■ To learn from human and organisational failures. ■ To share lessons learned within your own organisation and with other organisations. Review your performance measures every so often against your policy ■ Changes in your business could mean that existing performance measures are out of date. ■ You may also find the measures you’ve chosen don’t help you understand how well you’re managing health and safety. In these circumstances, you will need to update your approach. For sites with major-accident hazards, focus on performance measures for critical activities or plant ■ Safety-critical tasks with much human interaction. ■ Operational performance of safety-critical devices, eg relief valves. Worker consultation and involvement ■ Involve your workforce in setting and monitoring your health and safety performance measures. ■ Workers may have important information as to which measures make the difference when it comes to risk. ■ Involve everyone in the monitoring process. ■ Encourage workers to monitor their own work area, reporting any issues they observe. ■ Make reports available to everyone within the organisation. Competence ■ Use the results of monitoring to feed into future training plans.

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Investigating accidents
and incidents
In any business or organisation things don’t always go to plan. You need to prepare
to deal with unexpected events in order to reduce their consequences. Workers
and managers will be more competent in dealing with the effects of an accident or
emergency if you have effective plans in place that are regularly tested.
You should monitor and review any measures you have put in place to help control
risk and prevent accidents and incidents from happening. Findings from your
investigations can form the basis of action to prevent the accident or incident from
happening again and to improve your overall risk management. This will also point
to areas of your risk assessments that need to be reviewed.
An effective investigation requires a methodical, structured approach to information
gathering, collation and analysis.
Why investigate?
■ Health and safety investigations form an essential part of the monitoring
process that you are required to carry out. Incidents, including near misses, can
tell you a lot about how things actually are in reality.
■ Investigating your accidents and reported cases of occupational ill health will
help you uncover and correct any breaches in health and safety legal
compliance you may have been unaware of.
■ The fact that you thoroughly investigated an incident and took remedial action
to prevent further occurrences would help demonstrate to a court that your
company has a positive attitude to health and safety.
■ Your investigation findings will also provide essential information for your
insurers in the event of a claim.
An investigation can help you identify why the existing risk control measures failed
and what improvements or additional measures are needed. It can:
■ provide a true snapshot of what really happens and how work is really done
(workers may find short cuts to make their work easier or quicker and may
ignore rules – you need to be aware of this);
■ improve the management of risk in the future;
■ help other parts of your organisation learn;
■ demonstrate your commitment to effective health and safety and improving
employee morale and thinking towards health and safety.
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Investigating near misses and undesired circumstances, where no one has been
harmed, is as useful as, and may be easier than, investigating accidents.
In workplaces where a trade union is recognised, appointed health and safety
representatives have the right to:
■ investigate potential hazards and dangerous occurrences in the workplace;
■ examine causes of workplace accidents.
Reporting incidents
All employers, the self-employed and people in control of work premises have
duties under the Reporting of Injuries, Diseases and Dangerous Occurrences
Regulations (RIDDOR).
They must report certain work-related injuries, cases of ill health and dangerous
occurrences. RIDDOR applies to all work activities but not all incidents are reportable.
Reporting incidents should not stop employers undertaking their own investigation
to ensure risks are controlled effectively.
Further information about what must be reported and how to report it can be found
on HSE’s RIDDOR site (see below).
Find out more
Investigating accidents and incidents: A workbook for employers, unions, safety
representatives and safety professionals HSG245 HSE Books
ISBN 978 0 7176 2827 8 www.hse.gov.uk/pubns/books/hsg245.htm
HSE’s RIDDOR website: www.hse.gov.uk/riddor
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Key actions in effective accident/incident investigation

Leaders ■ Verify that plans are in place to deal with immediate risks following unforeseen events. ■ Make sure there is a reporting process so that leaders are informed of accidents, incidents or cases of occupational ill health. ■ Consider lessons from the accident/incident history of others in similar industries or organisations – could the same mistakes be avoided? ■ Ensure that people are held to account if failings reoccur. Managers ■ Formulate plans: ■ What must workers report? ■ How will reporting procedures be communicated to workers? ■ How will work-related ill health, accidents or near misses be notified? ■ Who will assist in the investigation? ■ What action will be taken as a result? ■ How will you identify trends? ■ Ensure reporting procedures are suitable and workable. ■ Examine all incident/accident/near-miss reports and identify trends. ■ Be proportionate in any investigation, according to the level of risk identified. Establish what happened, when, where and why. Collect evidence: ■ consider what the evidence shows; ■ compare what you have found against industry standards/HSE guidance etc. ■ Investigate accidents with a high priority – before people’s memories fade and while evidence is still available. ■ Look at root or underlying issues, not just immediate causes: ■ immediate causes – premises, plant and substances, procedures, or people; ■ underlying causes – management arrangements and organisational factors such as design, selection of materials, maintenance, management of change, adequacy of risk controls, communication, competence etc. ■ Record and keep findings: ■ They may be required later in a formal investigation or legal proceedings. ■ Engage specialist help to support complex investigations, eg an operation involving major accident hazards. Worker consultation and involvement ■ Involve workers or their representatives in the planning process and in the target-setting process. ■ Carry out joint investigation with workers’ representatives. ■ Involve workers or their representatives in monitoring performance. Competence ■ Consider how competency is achieved, tested and maintained. ■ Do investigators have the necessary training, knowledge and experience to carry out their duties? ■ Consider whether training issues contributed to causes of accidents/incidents/ near misses. ■ Seek specialist advice if needed.

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It is important that organisations review their health and safety performance.
It allows you to establish whether the essential health and safety principles –
effective leadership and management, competence, worker consultation and
involvement – have been embedded in the organisation. It tells you whether your
system is effective in managing risk and protecting people.
■ Review your performance
■ Learn from accidents and incidents, ill-health data, errors and relevant
experience, including from other organisations.
■ Revisit plans, policy documents and risk assessments to see if they need
updating.
■ Take action on lessons learned
■ Include audit and inspection reports.
Reviewing performance
Carrying out reviews will confirm whether your health and safety arrangements still
make sense. For example, you’ll be able to:
■ check the validity of your health and safety policy;
■ ensure the system you have in place for managing health and safety is effective.
You’ll be able to see how the health and safety environment in your business has
changed. This will enable you to stop doing things that are no longer necessary
while allowing you to respond to new risks.
Reviewing also gives you the opportunity to celebrate and promote your health and
safety successes. Increasingly, third parties are requiring partner organisations to
report health and safety performance publicly.
The most important aspect of reviewing is that it closes the loop. The outcomes of
your review become what you plan to do next with health and safety.
Plan Do Check Act
ACT
Reviewing
performance
Learning
lessons
Act
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Key actions in reviewing performance effectively

Leaders ■ Consider the review findings. If improvement is needed act now, rather than reacting to an incident in the future. ■ Make sure the review is carried out according to the plans, and that a report is issued to senior leaders at least annually. ■ Ensure the scope of the review will give assurance that risks are as low as reasonably practicable (see page 25), and that your organisation is complying with health and safety law. Managers What are the objectives of the review? ■ Making judgements about the adequacy of health and safety performance ■ Assurance that the system for managing health and safety is working ■ Ensuring you are complying with the law ■ Setting standards ■ Improving performance ■ Responding to change ■ Learning from experience Who will carry out the review? ■ Someone independent, perhaps from another business area, could add value to the process. What type of information will be collected? ■ Active monitoring (before things go wrong) ■ Reactive monitoring (after things go wrong) ■ Accident/incident/near-miss data ■ Training record ■ Inspection reports ■ Investigation reports ■ Risk assessments ■ New guidance ■ Issues raised by workers or their representatives ■ Checks required by law, eg on lifting equipment and pressure systems How often will you need to carry out a review? ■ This will depend on your risk profile (see pages 26–30). Think about the supply chain ■ How could the actions or health and safety performance of suppliers or contractors affect your organisation? Consider incidents that have occurred in similar organisations ■ Could they be repeated in your organisation? Report the review findings ■ It is crucial that you report any findings to everyone within the organisation. Ensure remedial actions have been carried out ■ You also need to make sure that the measures work.

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Worker consultation and involvement
■ Discuss plans for review with workers or their representatives.
■ Use information from safety representatives’ inspections to feed into review.
■ Discuss the findings from your review with workers or their representatives – you
will have more success in securing improvements if your workers are fully involved.
Competence
■ Ensure that those carrying out the review have the necessary training,
experience and good judgement to achieve competence in this task.
■ See the section on ‘Measuring performance’ (pages 48–50) or use a trade
association to assist with planning and benchmarking where you are now. Talk
to similar organisations to compare performance and management practices.
■ If risks are complex and could have serious consequences, consider getting
specialist advice, or supporting one of your own workers by providing additional
training.
■ Check that training needs identified by the review have been addressed.
Learning lessons
Learning lessons involves acting on:
■ findings of accident investigations and near-miss reports (see pages 51–3);
■ organisational vulnerabilities identified during monitoring, audit and review
processes.
Even in well-designed and well-developed management arrangements there is still
the challenge of ensuring that all requirements are complied with consistently.
After an accident or case of ill health, many organisations find they already had
systems, rules, procedures or instructions that would have prevented the event but
were not complied with.
The underlying causes often lie in arrangements which are designed without taking
proper account of human factors, or where inappropriate actions are condoned
implicitly or explicitly by management action or neglect.
Common factors when things go wrong
Analysis of major incidents in high-hazard industries, with different technical causes
and work contexts, has identified several common factors involved when things go
wrong. These factors are related to:
■ leadership;
■ attitudes and behaviours;
■ risk management and oversight.
When these aspects of an organisation become dysfunctional, important risks can
become ‘normalised’ within it, leading to serious consequences.
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Organisational learning
Organisational learning is a key aspect of health and safety management. If
reporting and follow-up systems are not fit for purpose, for example if a blame
culture acts as a disincentive to reporting near misses, then valuable knowledge will
be lost.
If the root causes of precursor events are not identified and communicated
throughout the organisation, this makes a recurrence more likely.
In many cases, barriers within an organisation – where different departments
operate in ‘silos’ – inhibit organisational learning.
Human factors
Leaders and managers need to be aware of the people-related, cultural and
organisational issues that may prevent lessons from being learned effectively in
their organisations.
Find out more
HSE’s human factors website: www.hse.gov.uk/humanfactors

Key actions in learning lessons effectively

Leaders and managers ■ Show by your actions that safety is a core value. ■ Promote a questioning attitude. Make sure you are not only receiving ‘filtered good news’ – do you welcome feedback and constructive challenge? ■ Resolve ineffective procedures that result in ‘workarounds’ or violations of procedures. ■ Be clear about your organisation’s risk profile (see pages 26–30). ■ Make sure your workers understand the risks that are being controlled. ■ Avoid complacency – take responsibility for keeping your own knowledge and capability up to date. Worker consultation and involvement ■ Discuss plans with workers or their representatives. ■ Avoid overburdening workers with initiatives. ■ Involve workers in organisational change. Competence ■ Ensure that those providing top-level scrutiny have sufficient expertise to judge the importance of emerging health and safety issues and integrate those with other business decisions. ■ Contractors must be competent and there should be checks in place to ensure they remain so. ■ Take steps to avoid the loss of corporate memory.

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Part 4: Resources
Leadership and management
HSE guidance on leading for health and safety and managing risk
Leading health and safety at work: www.hse.gov.uk/leadership
Leadership for the major hazard industries: Effective health and safety management
Leaflet INDG277(rev1) HSE Books www.hse.gov.uk/pubns/indg277.htm
Joint guidance with the Institute of Directors (IOD):
Leading health and safety at work: Leadership actions for directors and board
members Leaflet INDG417(rev1) HSE Books www.hse.gov.uk/pubns/indg417.htm
Risk management: www.hse.gov.uk/risk
Guidance for small and micro-businesses: Health and safety made simple:
The basics for your business Leaflet INDG449 HSE Books
www.hse.gov.uk/pubns/indg449.htm
Microsite: www.hse.gov.uk/simple-health-safety
For businesses that need more detailed guidance: The health and safety toolbox:
How to control risks at work HSG268 HSE Books ISBN 978 0 7176 6587 7
www.hse.gov.uk/pubns/books/hsg268.htm Microsite: www.hse.gov.uk/toolbox
Writing a health and safety policy for your business:
www.hse.gov.uk/simple-health-safety/write.htm
Management systems
The British Standards Institution (BSI) produces internationally recognised standards:
http://shop.bsigroup.com
The International Standards Organisation (ISO) develops and publishes international
standards: www.iso.org/iso/home.htm
HSE and local authorities in Wales and South-West England have produced a
Management Assessment Tool for SMEs (MAST). This is a toolkit for assessing
health and safety management in small and medium-sized businesses:
www.hse.gov.uk/foi/internalops/fod/inspect/mast
Institution of Occupational Safety and Health (IOSH) Risk Assessment Routefinder:
www.ioshroutefinder.co.uk
Attitudes and behaviours
Reducing error and influencing behaviour HSG48 (Second edition) HSE Books
ISBN 978 0 7176 2452 2 www.hse.gov.uk/pubns/books/hsg48.htm
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Measuring and reviewing performance
The Safety Climate Tool, published by the Health and Safety Laboratory (HSL),
enables businesses to measure workforce attitudes to health and safety:
www.hsl.gov.uk/products/safety-climate-tool.aspx
The Energy Institute (EI) Process Safety Survey is a process safety measurement
and benchmarking tool, based on the Energy Institute’s High-level framework for
process safety management: www.energyinst.org/eipss
EEF – The Manufacturers’ Organisation – Health and Safety Balanced Scorecard:
www.eef.org.uk/members/healthandsafety/scorecard/About-the-scorecard/default.htm
SHEIIBA – Safety, Health, Environment Intra Industry Benchmarking Service:
www.sheiiba.com
BSI Standards – self-assessment tool: http://ohsonline.co.uk
RoSPA – Quality Safety Audit: www.rospa.com/consultancy/safetyaudits
Worker consultation and involvement
HSE guidance on worker consultation and involvement
How to involve workers in your business: www.hse.gov.uk/involvement
Worker involvement – ‘do your bit’ guidance and workplace materials:
www.hse.gov.uk/involvement/doyourbit
Protecting migrant workers: www.hse.gov.uk/migrantworkers/employer/protecting.pdf
Other organisations that provide advice on consultation and involvement
The TUC produces guidance on workers’ rights at work: www.tuc.org.uk
ACAS promotes employment relations and has produced the Model Workplace Toolkit
that contains advice for managers: www.acas.org.uk
The following organisations conduct ballots, surveys and other ways of consulting
employees, on behalf of businesses:
■ Electoral Reform Services: www.erbs.co.uk
■ Popularis: http://popularis.org
■ IPA: www.ipa-involve.com
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Competence
HSE guidance ‘hub’ on competence in health and safety:
www.hse.gov.uk/competence/
Competence-related guidance for a specific industry, task or working environment:
www.hse.gov.uk/competence/industry-specific-competence.htm
Passport schemes for health and safety can be a useful way for employers to
check that somebody working on their premises, or elsewhere doing work on their
behalf, has received basic health and safety awareness training:
www.hse.gov.uk/competence/health-and-safety-passport-schemes.htm
HSE produces a range of guidance on health and safety at work, organised by
industry and topic: www.hse.gov.uk/guidance/industries.htm
Other organisations that provide advice on competence
The following organisations provide advice, guidance, training and/or qualifications
to industry in the field of health and safety.
■ The Health and Safety Laboratory (HSL) offers a range of training courses on health
and safety-related topics:
www.hsl.gov.uk/hsl-shop/health-and-safety-training-courses.aspx
■ Chartered Institute of Environmental Health: www.cieh.org
■ European Agency for Safety and Health at Work: https://osha.europa.eu/en
■ Access Industry Forum: www.accessindustryforum.org.uk
■ EEF – The Manufacturers’ Organisation: www.eef.org.uk
■ LANTRA: www.lantra.co.uk
■ National Examination Board for Occupational Safety and Health (NEBOSH):
www.nebosh.org.uk
■ Institution of Occupational Safety and Health (IOSH): www.iosh.co.uk
■ International Institute of Risk and Safety Management: www.iirsm.org
■ Royal Society for the Prevention of Accidents (RoSPA): www.rospa.com
■ British Safety Council: www.britsafe.org
■ British Safety Industry Federation: www.bsif.co.uk
■ Olympic Development Authority: http://learninglegacy.independent.gov.uk
■ National Compliance and Risk Qualifications: https://www.ncrq.org.uk
Specialist advice
HSE specialist guidance
HSE publications: www.hse.gov.uk/pubns/books
Other organisations that may help provide businesses with specialist advice
■ Occupational Safety and Health Consultants Register: www.oshcr.org
■ British Psychological Society: www.bps.org.uk
■ Human Factors and Ergonomics Society – European Chapter:
www.hfes-europe.org
■ BOHS (The Chartered Society for Worker Health Protection): www.bohs.org
■ Chemical Hazards Communication Society: www.chcs.org.uk
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Process safety
Guidance from HSE
Developing process safety indicators: A step-by-step guide for chemical and major
hazard industries HSG254 HSE Books ISBN 978 0 7176 6180 0
www.hse.gov.uk/pubns/books/hsg254.htm
Leadership for the major hazard industries: Effective health and safety management
Leaflet INDG277(rev1) HSE Books www.hse.gov.uk/pubns/indg277.htm
The Process Safety Leadership Group (PSLG) Final Report – Safety and
environmental standards for fuel storage sites
www.hse.gov.uk/comah/buncefield/fuel-storage-sites.pdf
PSLG principles of process safety leadership
www.hse.gov.uk/comah/buncefield/pslgprinciples.htm
Guidance from the Organisation for Economic Co-operation and
Development (OECD)
Guiding Principles for Chemical Accident Prevention, Preparedness and Response
(2003) www.oecd.org
Addendum to Guiding Principles (2011) www.oecd.org
Corporate Governance for Process Safety: Guidance for senior managers in highhazard industries (2012) www.oecd.org
Guidance from the Energy Institute (EI)
High-level framework for process safety management (‘PSM framework’):
www.energyinst.org/technical/PSM/PSM-framework
Human factors performance indicators for energy and related process industries:
www.energyinst.org/hofpi
Other sources of information
■ Center for Chemical Process Safety (CCPS): www.aiche.org/ccps
■ Chemical Industries Association: www.cia.org.uk
■ European Process Safety Centre: www.epsc.org
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Further information
For information about health and safety, or to report inconsistencies or inaccuracies
in this guidance, visit www.hse.gov.uk. You can view HSE guidance online and
order priced publications from the website. HSE priced publications are also
available from bookshops.
British Standards
British Standards can be obtained in PDF or hard copy formats from BSI:
http://shop.bsigroup.com or by contacting BSI Customer Services for hard copies
only Tel: 0845 086 9001 email: [email protected].
The Stationery Office publications
The Stationery Office publications are available from The Stationery Office, PO Box 29,
Norwich NR3 1GN Tel: 0870 600 5522 Fax: 0870 600 5533 email: customer.services@
tso.co.uk Website: www.tsoshop.co.uk (They are also available from bookshops.)
Statutory Instruments can be viewed free of charge at www.legislation.gov.uk, where
you can also search for changes to legislation.
This guidance is available at: www.hse.gov.uk/pubns/books/hsg65.htm.
HSG65 12/13 Published by the Health and Safety Executive