The Health & Safety at L&M is managed on the model based on BS OHSAS 18001 which provides a systematic approach to and a formal and logical way of planning and controlling management of risk in the organisation and it also provides compliance with the necessary requirements as set out in the Management of Health & Safety at Work Regulations (MHSWR) 1999 – Regulation 5 (Health & Safety Arrangements). As the BS OHSAS 18001 model reflects the elements of the plan, do, check, act approach of HSG 65 model, the Head of Health & Safety advised that she also uses this approach in implementing the arrangements.
The organisation roles and responsibilities section of the health & safety policy document sets out the health & safety management and reporting structure which shows that the UK CEO and the board is responsible for the overall health & safety of the organisation and the Head of Health & Safety and the regional managing directors report to them. The Head of Health & Safety reports to the CEO and is responsible for Office responsible persons, Delegated office representatives and Employees and contract staff. Global intranet manager and the HSEQ Assistant report directly to the Head of Health & Safety.
The health & safety responsibilities of the key people are defined in the next section. The board of Directors responsibilities include that this policy: meets statutory requirements, is implemented and that relevant health and safety considerations inform all UK board decisions, communicated to all levels of the UK business, safe systems of work, rules and procedures are implemented, regularly reviewed and suitable records are kept, sufficient resources are available to manage all aspects of health and safety.
It is interesting to note that regarding consultation it states that, consultation between management and staff; this would typically be via the office responsible persons, office delegated representatives, employees and head of HSEQ. It does not mention any direct communication between the board and the staff regarding health & safety, which would be welcomed by the staff and show the boards commitment to health & Safety.
The Head of Health & Safety has further responsibilities. The daily overall management of health and safety is vested in the head of HSEQ who shall provide a monthly report to the UK senior management team, which will be reviewed at each UK senior management team meeting. She is responsible for annually reviewing and updating the health & safety policy, provide training & guidance to responsible persons, delegated office representatives, all directors and managers, accident and incident statistics, reviewing and approving all risk assessments. Then there are responsibilities of responsible/appointed persons and delegated office representatives, employees and subcontractors.
There seems to be no mention health & safety responsibilities allocated to regional managing directors, senior or middle managers. It is felt that the mangers within the organisation could play an important role in raising awareness of health & safety within the organisation.
Even though all the responsibilities are mentioned in the health & safety policy arrangements, these are not included in individual job descriptions. It is believed that Including responsibilities in the job description would be an important step in individuals being responsive and having better perception of their health & safety roles and responsibilities.
There is setting of performance monitoring measures in the health & safety policy as it mentions a yearly review of health & safety policy so there is periodic review of documents. Monthly and quarterly reports have to be done by the Head of Health & Safety and submitted to the board for their meeting. There is an internal and external audit system in place to ensure that we maintain external certification by the British Standards Institution. All the workplace equipment is PAT tested yearly. The Head of Health & Safety also has a check sheet whereby they ensure that all the office landlords are maintaining their plant and equipment and fire safety equipment that they supply to us which is complimentary.
There is access to competent advice in the organisation, the Head of HSEQ has NEBOSH diploma occupational H&S and is graduate member of IOSH, there is access to an external health & safety consultancy if specialist advise is sought. Various technical staff in possession of NEBOSH qualifications to carry out the Principal Designer consultant role but currently these staff are not utilised for office health & safety advice. If there is any health & safety issues that staff come across, they can email or speak to the Head of health & safety for advice and if the she is unable to offer advice then external advise is sought. There is an opinion that there are extremely qualified fellow members of IOSH within the organisation that the company can sought competent advice from and should consider the inhouse resources going forward.
All health and safety documents including the policy, risk assessments etc are available to all staff via the intranet portal. All staff have to also complete a mandatory e-learning course on the portal on health and safety as part of their induction, with annual refreshers there on. Apart from the above the Head of Health & safety would send an email once in a blue moon if there is any changes to the existing policies. The Health & safety communication we believe is very robotic and one way. There seems to be a lack of communication and discussion of health & safety issues within the organisation. The organisation could benefit by the introduction of a H&S newsletter, notice boards etc. There was also a suggestion made by the health & safety practitioner to introduce communication via posters regarding for example mental awareness in the kitchen/welfare area.
The contractors are sourced by the organisation as and when there is a demand of a particular consultant for a construction project and if there is no availability within the organisation, an external contractor is sought by the various department Directors. The board does prefer that the use of contractors is kept to a minimum but the industry we are in there is often a need to employ contractors especially right now as the industry is booming and we have winning so much work. There is no formal procedure in place for vetting the contractor. Generally, they are employed for their expertise or competence in the field. So, they are always competence checked by requesting their CV’s for experience and appropriate qualifications and memberships for skills and knowledge checking. Saying that there is no evidence of the company checking if they have any H;S training or demonstrate previous health ; safety performance or checking their CSCS cards. Once they join L;M they have to complete the H;S induction on the intranet portal which is a good thing as they are made aware of the risks in our workplace, they are also advised of the location of the H;S policy. Under L;M’s H&S policy section, it makes the contractor responsible for making themselves aware of the L&M’s policies and procedures, comply with H;S legislation, carry out their own risk assessment in relation to their activities which is not surprising. There is no joint risk assessment carried out nor do the Directors employing them hold any progress meetings, so health ; safety issues can be raised as they occur. The control of contractor’s process and procedure can be improved by putting in procedures for ongoing consultation with the contractors.
C. Worker Involvement
According to the HSE guidance, the minimum requirements for workforce consultation involve providing information, instruction, training and engaging in consultation of the employees. At L&M the health & safety information, instruction and training is provided to the workforce via the intranet portal to comply with minimum legal compliance. There is an email address online that I discovered whilst carrying out my research where staff are encouraged to send feedback, but it is not advertised and hence very few people know about it.
The situation regarding worker involvement is the same situation as the H&S tours, all the documentation mentions that the H&S tours are carried out at least once annually, but the reality is that the last one was done in 2014. Likewise, the last staff survey was done in 2014 as well.
This is the weakest link we believe in the company’s operation of health ; safety management system. Currently there is very little to none worker involvement in the health ; safety issues. The Directors do not discuss with the staff how their job could be done safely.
The responsible persons and office representatives carry out the workplace risk assessment and checks they need to carry out and regarding fire and emergency procedures. These are also checked by Head of Health ; safety to ensure that this is being done as required which is good for compliance purpose. The responsible persons or office representative do not currently consult with the staff in the offices regarding the results of the risk assessments and which is evident from a recent fire drill as there were staff who went for lunch or some new employees were not sure where the assembly point was, which showed there is lack of awareness of the emergency procedures.
The health ; safety seems to be a one-way stream whereby the information regarding health ; safety is passed down by the Head of Health ; safety via email updates or once yearly through the yearly e-learning module. Hence the workforce involvement mechanisms are based on minimum legal compliance. To have an effective management system, good practise would be if the Directors and employees had team meetings with open discussions and make joint decisions regarding health ; safety.
The Head of Health ; Safety is at hand to assist with needs of vulnerable workers. Currently there are no disabled workers in the organisation. The managers and HR advise her if there is vulnerable person in the business for example a young person or a pregnant worker and she usually sends a form to be filled in and the liaise with them to carry out a risk assessment. Results of survey
This is also evident from my recent involvement in getting an accreditation for the company regarding health ; safety. The Head of health ; safety struggled to provide evidence regarding worker consultation. When asked about worker involvement in our interview, she said she recognises this and is keen to develop this area so there is workforce partnership and a positive health ; safety culture.
The Head of Health and Safety fulfils the role of the health ; safety competent person within the organisation. She has done the NEBOSH diploma and has the adequate training, skills, knowledge and experience to carry out the role of the competent person and manage health ; safety. She has been in this role for almost 10 years and has sufficient experience in managing the organisation of this size in the UK.
The Health ; Safety assistant HSEQ assistant has not had had any prior H;S training to carry out her role. She has moved from an administrative based role to health ; safety. She seems very keen to progress her career in health ; safety, so the organisation has sponsored her, and she is undertaking two NEBOSH certificate courses: one in occupation health and safety and the second in fire safety and risk management.
The appointed persons and office representatives have not had any formal training to carry out their roles. Local responsible persons and office representative have been provided some training by the head of H;S and also mandatory in-house courses with some information/updates provided to them by e-learning. They are selected for these tasks since they are non-fee earning professionals. The head of H;S has identified lack of competence in this area as there is nothing at present to cover the delegated reps and she is developing a training package to train them as first aiders/ fire wardens in the near future and put them through relevant courses.
There are arrangements in place to ensure that workers are aware of their health ; safety responsibilities through the health ; safety induction and e-learning refresher courses which informs works what the organisation expects from the employees as regards health ; safety.
According to Judith Hackett, ‘Competence is the ability for every director, manager and worker to recognise the risks in operational activities and then apply the right measures to control and manage those risks.’ At L;M the technical Directors and employees have adequate skills, knowledge and experience of the construction industry and generally understand the hazards and risks involved in their work. Most of the staff are required to have CSCS cards as it is an industry standard for visiting sites so have a basic understanding of health ; safety and dangers in construction.
The employees that are more at risk are the young apprentices, in the business who lack the competence and ability to understand completely the risk involved in construction. They should be given more on the job and other forms of training to ensure that they understand the risks on site.
The training needs are usually identified by the immediate superiors or Directors responsible in various departments. The professional development review process includes the question for the employee and reviewer regarding training needs identification. Once the need is identified, the Director would discuss this with the employee and if reasonable put in a request for internal or external training as required.
The contractors receive an appropriate induction