The
employer has ultimate responsibility for safety and health. In most firms
in the office, retail, commercial, service and light industrial sector,
the hazards and hazardous work activities are few and simple. Checking them
is common sense, but necessary. In small firms, employers understand their
work and can identify hazards and assess risks themselves. There are many
information sources such as Codes of Practices, guidelines, legislation
and standards available to support employers when compiling safety statements.
Consultation should always take place with the employees, including safety
representatives, as they are the ones doing the work and dealing with the
hazards on a daily basis.
For larger firms, a responsible experienced employee or safety officer should
be used. If external advisers are used to help prepare the safety statement,
it must be ensured that they know the work activity and have the appropriate
experience. If you do the work yourself, walk around the workplace and look
afresh at what could reasonably be expected to cause harm. Ignore the trivial
and concentrate on the significant hazards that could result in serious
harm or affect several people. Ask employees and their representatives what
they think. They may have noticed things that are not immediately obvious.
According to the Safety, Health and Welfare at Work Act 2005, a person is deemed to be a competent person where, having regard to the task he or she is required to perform and taking account of the size or hazards (or both of them) of the undertaking or establishment in which he or she undertakes work, the person possesses sufficient training, experience and knowledge appropriate to the nature of the work to be undertaken.
The safety statement is required by law under Section 20 of the Safety, Health and Welfare at Work Act 2005. A HSA inspector may review a Safety Statement during an inspection of a workplace. If he/she finds that it is inadequate, he/she can direct an employer to revise it within 30 days.
A safety statement is your specific programme, in writing, for safeguarding the health and safety of your employees. The Authority does not supply safety statements. Guidelines on preparing your Safety Statement and carrying out Risk Assessments can be obtained from the HSA Publications Unit. These guidelines are designed to help employers or self-employed to manage safety and health in the workplace.
A
comprehensive safety statement, if properly implemented, is a practical
tool for reducing accidents and ill health at work. For small to medium-sized
businesses, the preparation of a safety statement should be simple and straightforward.
In developing a safety and health management programme for an organisation,
there are 6 important steps to be followed.
Draw up a health and safety policy:
The safety statement should begin with a declaration, signed at senior,
responsible management level on the employer’s behalf. The declaration
should give a commitment to ensuring that a workplace is as safe and healthy
as reasonably practicable and that all relevant statutory requirements will
be complied with. This declaration should spell out the policy in relation
to overall safety and health performance, provide a framework for managing
safety and health, and list relevant objectives.
Because the safety statement must be relevant at all times to the safety
and health of employees and others in the workplace, the policy declaration
should indicate that the safety statement will be revised as changes occur
and evaluated at set intervals, and how the relevant contents of the statement
are to be brought to the attention of employees and any other people in
the workplace who might be affected by the statement.
Identify the hazards
The
first step in safeguarding safety and health is to identify hazards from
materials, equipment, chemicals and work activities. The employer is required
to systematically examine the workplace and work activities to identify
workplace-generated hazards.
If an employer controls more than one work location, different types of
work activity or changing work locations (as in road repairs or building
work), it may be necessary to prepare a safety statement that has separate
sections dealing with the different locations or activities. Employers will
be familiar with the hazards associated with the type of work they are involved
in. But to identify the main hazards and put risks in their true perspective,
employers can also check:
•
records of accidents, ill health and insurance claims
• any relevant legislation or standards covering the hazard (e.g.
the Construction Regulations for construction-site hazards, the Chemical
Agents Regulations and Code of Practice for chemical hazards and their control)
• manufacturers’ instructions or datasheets
Some
hazards are obvious, such as unguarded moving parts of machinery, dangerous
fumes, electricity, working at heights, or moving heavy loads. Less obvious,
but at the root of many accidents, are hazards presented by untidy workplaces
and poor maintenance. In the case of some hazards, such as excessive noise,
it may take months or even years before damage materialises.
In most firms in the office, retail, commercial, service and light industrial
sector, the hazards and hazardous work activities are few and simple. Checking
them is common sense, but necessary. In small firms, employers understand
their work and can identify hazards and assess risks themselves. For larger
firms, a responsible experienced employee or safety officer should be used.
A checklist of hazards can be found in the HSA Guidelines on Risk Assessments
and Safety Statements, available from the HSA at 1890 289 389. This checklist
provides a systematic, though not exhaustive, approach to identifying hazards
in the workplace. This checklist covers physical hazards (e.g. manual handling,
falls from heights, falling objects, electricity, housekeeping, slips/trips),
health hazards (e.g. noise, lighting, vibration, radiation, dusts, temperatures),
chemical hazards (e.g. glues, industrial solvents, dyes, pesticides, acids),
biological agents hazards (e.g. bacteria, viruses, plant and animal substances)
and human-factor hazards (e.g. vulnerable workers, mental/physical capability
of workers, bullying, violence).
What should be contained in the Safety Statement regarding representation, consultation and participation of employees?
The safety statement
must specify the arrangements to be used for consultation with and participation
by employees on safety and health matters. These would include the procedures
to facilitate effective co-operation and communication on safety and health
matters between the employer and employees. Consultation and participation
arrangements and the extent of their usage will depend on the size and complexity
of the organisation. This may range from informal one to one discussions
to a more formal safety committee. Consultation areas include:
• any issues which can substantially affect safety and health
• the employment of competent persons and safety and health experts
to study company safety and health activities
• appointment of persons to deal with emergencies and any prevention
measures
• carrying out risk assessments and the outcome of such assessments
• provision of safety and health information to employees
• the planning and organisation of safety and health training
• procedures to be used to facilitate effective co-operation and communication
on safety and health matters between employer and employees
• preparation, and revision of, the safety statement, with particular
reference to the written procedures covering the role of the safety representative,
the operation of safety committees, or informal safety discussions by work
crews, which might take place as necessary
• the introduction of new technology, equipment or chemicals and their
affect on working conditions and environment
Planning is the key to ensuring that the safety and health efforts really
work. It involves setting objectives, assessing the risks, implementing
standards of performance and developing a safety culture. The employer should
record the safety and health plans in the safety statement. Such planning
should provide for:
• identifying hazards and assessing risks, and deciding how they can
be eliminated or controlled
• complying with the safety and health laws that apply to the business
• agreeing safety and health targets with directors, managers and
supervisors
• board decisions which reflect the safety and health policies as
set out in the safety statement
• a purchasing and supply policy which takes safety and health into
account
• the design of tasks, processes, equipment, products and services,
and safe systems of work
• procedures to deal with emergencies and serious and imminent danger
• co-operation with neighbours and/or subcontractors
• setting standards against which performance can be measured
• ensuring co-operation between managers so that safety and health
obligations are complied with
The two key components
of measuring safety and health performance are:
• Active monitoring (before things go wrong). The employer needs to
carry out routine inspections and checks to see that standards are being
maintained. Are the objectives and standards that were set being achieved?
Are they effective?
• Reactive monitoring (after things go wrong): investigating injuries,
cases of illness, bullying complaints, property damage and near misses -
specifying in each case why performance was sub-standard.
Implementing
the safety statement should be an integral part of everyday operations and
so it must be relevant at all times. Therefore, it should be revised periodically,
at least annually, and whenever significant changes take place, or when
risk assessments are carried out and improvements are made that have an
impact on safety and health. Such changes may include changes in work processes,
organisational structure, equipment or substances used, technical knowledge,
and legislation or standards.
Changes in the workforce may also have an impact that would require a review
of the safety statement, e.g. altering the number of workers on a particular
process, replacing more experienced workers with trainees or as a result
of experience gained through training.
However, it is not necessary to revise the safety statement for every trivial
change, or for each new job, but if a new job introduces significant new
hazards, you need to assess the risks assessments and implement the necessary
prevention measures.
In reviewing the safety statement, employers should consider at least the following:
• Were the aims
in the safety statement relevant and appropriate?
• Did it identify the significant hazards, assess their risks and
set out the necessary preventive and protective safety measures?
• Were the safety and health measures, which were identified, implemented
in practice? Was the planned progress achieved?
• Were new work practices or processes introduced since the last review
and if so were they risk-assessed?
• Did you put in place the measures necessary to comply with the relevant
statutory provisions (e.g. on safety and health management, safety consultation
and training, etc.)?
• Did you comply fully with safety and health performance standards
(including legislation and approved codes of practice)?
• Are there areas where standards are absent or inadequate?
• Have you analysed your data to find out the immediate and underlying
causes of any injuries, illness or incidents? Have you identified any trends
and common features?
• What new safety and health measures were applied following any reportable
accidents or other incidents, or following any enforcement measures relating
to your workplace?
• Were adequate financial, physical, human and organisational resources
committed to safety and health?
• What improvements in safety and health performance need to be made?
As part of the review, employers will find it helpful to refer to any records which have been kept, such as accident/incident reports, health-surveillance results, training records, inspection and audit reports, maintenance logs, or atmospheric monitoring figures. Employers must also consult safety representatives and others who may be affected by the review.
Employers should bring
any changes made to the attention of the safety representatives, employees
and any other persons who may be affected by the new measures set out in
the safety statement. They must be informed about the new findings and of
any changes in the required safety and health precautions. Make sure all
modifications or improvements required by the new risk assessments and safety
statement review are implemented as soon as possible.
Is anyone exempt from carrying out a risk assessment and/or preparing a
safety statement?
A risk assessment must always be prepared for that place of work. However,
if 3 or fewer people are employed and a code of practice relating to safety
statements, prepared by the Authority, exists for a sector or work activity,
then compliance with that code is sufficient.
Am I qualified enough to prepare a Safety Statement correctly?
Who approves a Safety Statement?
My insurance company is requesting a Safety Statement; can the HSA send me one?
How do I prepare a Safety Statement?
What are the two key components of measuring safety and health performance?
How often should the Safety Statement be reviewed?
How should the Safety Statement be reviewed?
What should the employer do after the Safety Statement has been reviewed?