When the Health and Safety Executive visits a workplace, the circumstances can vary enormously. Different businesses, different sectors and different reasons for HSE involvement.
But there are some common themes worth thinking about.
Many of the issues being identified aren’t obscure points of health and safety law. They are often relatively straightforward things: controls that aren’t being used, welfare arrangements that aren’t adequate, fire precautions that don’t reflect the site, occupational health arrangements that haven’t kept pace with the risks, or management systems that look better on paper than they do in practice.
That’s worth thinking about.
Because if there is a lesson to take from HSE interventions, I don’t think it is that businesses need ever more complicated health and safety systems.
If anything, it may be the opposite.
We need to get the simple things right, and make sure they continue to work.
Having a control isn’t the same as controlling the risk
One recent HSE intervention involved exposure to respirable crystalline silica.
There was extraction equipment. There was water suppression. The business clearly wasn’t oblivious to the risk.
But during the HSE visit, work was taking place away from the extraction and the extraction itself wasn’t operating. The inspector also identified deficiencies around its examination and the way the system had been configured. The subsequent intervention addressed those matters alongside respiratory protection and other controls.
If we walked into one of our workplaces today, what controls would we find that are technically available, but aren’t consistently being used?
That could be extraction that isn’t switched on.
A guard that has been moved.
RPE that is available but isn’t worn.
A pedestrian route that has gradually become obstructed.
An inspection regime that exists on a spreadsheet but has quietly fallen behind.
None of those necessarily requires another policy.
They require somebody to notice.
There is an important distinction here between being able to show that we have a control and being confident that the risk is actually being controlled.
Would the arrangement actually work?
Much the same principle applies on construction sites.
In more than one recent intervention, HSE inspectors have challenged arrangements for raising the alarm in the event of a fire. On one site an air horn was available, but the inspector considered this inadequate for the circumstances and expected an interconnected alarm system.
Another intervention involving work on an occupied building questioned how both workers and others who could be affected would receive an effective warning if a fire occurred.
Again, there is a simple question behind all the technical detail:
- Would it actually work?
- If a fire occurred at the furthest point of a construction site, would everybody who needed to hear the warning hear it?
- Could someone raise the alarm quickly?
- Would people know what the alarm meant and what they were expected to do?
Those questions are far more important than whether the words “fire alarm arrangements” appear somewhere in the construction phase plan.
This applies well beyond fire safety.
The next time you’re reviewing a risk assessment or procedure, instead of starting with “Have we documented this?”, try asking:
“If this went wrong tomorrow, would the arrangements we’ve put in place actually protect somebody?”
It’s an uncomplicated question, but sometimes the simple questions are the most useful.
Don’t forget the health in health and safety
Another area that deserves particular attention is occupational health.
In one case, HSE identified the absence of suitable health surveillance covering risks including lung function, hand-arm vibration and noise, alongside concerns about exposure to silica. The same intervention also considered biological risks arising from a recirculating water system.
This shouldn’t really surprise us.
We are generally quite good at seeing immediate safety risks. An unguarded edge, an unsafe machine or a vehicle moving close to pedestrians attracts attention because we can readily imagine what might happen.
Health risks can be different.
Silica dust doesn’t necessarily injure someone today.
Noise-induced hearing loss develops over time.
Hand-arm vibration syndrome doesn’t announce itself after one morning using a power tool.
That can make these risks easier to overlook during the normal pressures of running a business.
But preventing somebody becoming ill because of their work is just as much part of good health and safety management as preventing an accident.
Again, the starting point doesn’t need to be complicated.
What are our people being exposed to? Have we reduced that exposure as far as we reasonably can? Where health surveillance is required, is it actually happening? And if somebody’s results indicate a problem, do we know what happens next?
Sometimes the gap is the management system itself
Some of the most fundamental issues in health and safety management aren’t necessarily about individual hazards.
A business may have policies and risk assessments but still lack clear arrangements for obtaining competent health and safety assistance. Regulation 7 of the Management of Health and Safety at Work Regulations requires employers to appoint one or more competent people to assist them in meeting their health and safety obligations.
Having access to competent advice isn’t about giving responsibility for health and safety to somebody else.
Businesses still need to own their risks.
Good advice should help an organisation understand what those risks are, decide what sensible controls look like and, importantly, recognise when something has changed and the existing arrangements need another look.
The objective isn’t to create dependence on a consultant.
It’s to help the business manage risk well.
Could an issue quietly return?
This is perhaps the part that interests me most.
Following an HSE intervention there is usually a great deal of activity.
Actions are completed. Equipment is purchased. Documents are updated. Training is arranged. Evidence is submitted. Everyone focuses on satisfying the inspector that the problem has been resolved.
But what happens six months later?
It’s an important question. Not simply how to complete the actions required by HSE, but how the business will check that those controls remain in place after the regulatory action has been closed out.
For me, that’s where the real learning sits.
The objective shouldn’t be to make a workplace safe enough for an inspector to close a notice.
It should be to prevent the circumstances that resulted in the notice from gradually returning.
And that rarely needs an elaborate auditing regime.
A supervisor checks that the extraction is being used.
Someone notices whether the fire alarm arrangements remain suitable as the construction site changes.
Health surveillance dates are reviewed before they become overdue.
Managers spend time where the work actually happens and talk to the people doing it.
Actions from inspections are followed through to completion, rather than simply recorded.
Simple things, done consistently.
What if the HSE arrived tomorrow?
That’s probably the most useful question to take from all of this.
Not because we should run our businesses in fear of an HSE visit. We shouldn’t.
And not because avoiding enforcement should be our principal motivation for managing health and safety. It isn’t.
The purpose is preventing people from being harmed by their work.
But imagining an HSE visit can be a useful test.
If an inspector walked through your door tomorrow, could you show that the controls in your risk assessments are actually being used?
Could you explain how you’re managing the significant health risks as well as the obvious safety ones?
Would your emergency arrangements work in the workplace as it exists today, rather than as it existed when the procedure was written?
Could the people doing the job explain the precautions that matter to them?
And when something isn’t right, would somebody notice and do something about it?
You don’t need to wait for an inspector to ask those questions.
We can ask them ourselves.
Because the best outcome from any HSE intervention isn’t simply closing out a notice or responding to a letter.
It’s learning something that prevents somebody from being harmed in the future.
And often, that doesn’t begin with another policy, another complicated system or another folder full of paperwork.
It begins with getting the simple things right and making sure they stay right.