There remains much complexity in health and safety compliance. So much so, that BSRIA recently staged an event for delegates to discuss the following practical steps.
19 November 2015 | BSRIA
The most dramatic change in health and safety enforcement since 1974 - giving new sentencing guidelines for health and safety offences - was published this month. It is set to revolutionise punishment for health and safety offences.
The Sentencing Council's intention for the update is to increase fines for serious offences, especially for larger companies, while reserving prison sentences for serious offences. Therefore, company compliance is more critical than ever.
The most important point is that in any organisation it should be clear who holds responsibility for ensuring compliance and those who hold such responsibilities need to understand their roles.
A company-wide level of evidence of compliance is essential, with a clear audit trail. Ensuring staff competency is a must, and this should be confirmed and approved. An induction for all staff on how to manage compliance is a useful step to support compliance activities. Ongoing and refresher training helps to record evidence of compliance is in place.
Engineers should sign worksheets confirming that tasks have been completed - in doing so they will verify that they have the skills and competence to complete that task. If maintenance reports used for verifying compliance could be standardised with specific measurements captured, such as water temperatures, that would be a good form of evidence. Safe systems of work and authorisation of personnel were also seen as critical, as is a premises hazards checklist. Where F-gas, gas, heating and ventilation, and lifts are concerned, company and individual certification is required.
What level of auditing is needed?
The objective and scope of the audit must be established along with a way to track outcomes.
It must be established who the audit is for. An executive summary is essential for any audit report to ensure that the main messages can be appreciated across the organisation, and the audit should be visible to staff. There is the potential to use dashboards or a 'traffic light system' for staff notification, which BSRIA regards as an efficient way to publish results.
All audits should be considered 'live documents' that require the actions stated within them to be addressed. FMs should incorporate evidence to prove there is a 'feedback loop' in place to ensure that inspection recommendations that require action are followed up.
What is competence?
Stephen Gathergood, head of infrastructure services, G4S Facilities Management, told the meeting: "While the obvious responses akin to the acronym of SKATE - skill, knowledge, attitude, training and experience - are frequently quoted real competence is so much more. Competence is discussed as not just being a standard of proficiency, but a level of achievement that is not uniform.
"The level of competence is seen as being a standard of achievement that is made from the combination of a wide variety of 'ingredients'. Like a cook is able to make a variety of different cakes from a common set of ingredients in different proportions - so is the make-up of competency."
'Ingredients' touched on included qualifications, exposure to work role and function, certification, continuing professional development and other indicators associated with training and experience. But these should be overlaid with more personal attributes such as motivation, interest, engagement and other factors that are part of a person's behavioural or value set.
What makes an engineer competent is not easy to define, but is a complex mix of both tangible and non-tangible attributes. But without appropriate investment in people, competency could be lost, so robust competency management systems should be put in place.
What is covered?
The Equality Act 2010 comes into play here, as do other industry directives governing:
- Waste from electrical and electronic equipment; safety for mobile elevating work platforms and ladders, lifting beams, hoists and cradles;
- Thermostatic mixing valves;
- Exhaust ventilation;
- Energy performance certificates, residual current devices, COSHH, natural gas, and F-gas;
- CO2 alarms, fixed electrical testing, portable appliance testing, escape routes and fire exits, fire and gas suppression, fire alarms and safety, fire doors, fire evacuation, sprinklers, dry risers, and room integrity checks.
- Water regulation, closed water systems, domestic water systems and cooling towers, waste separation, drainage maintenance discharge and disposal documents.
- Noise in plant rooms, workplace lighting and water temperature, lighting protection, EM lighting, portable appliances, high-voltage issues, grease traps, kitchen extract ducts, building regulations, and oil storage bunds.
- Metering, edge protection, powered pedestrian doors, structures - safety stairways, compressed air pipe work and food safety.
There is a need for organisations to stop 'firefighting' by getting on top of what compliance means and showing that your organisation is operating within the law.