Health and Safety Risk Assessments

 

As part of managing health and safety, the law requires that the risks in the workplace are controlled. To satisfy this requirement, a process of risk assessment for all aspects of business operations must be carried out, the key measures for which should include:

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• Appointment of a competent person to undertake risk assessments.

• Accurate identification of potential hazards in the workplace.

• Identification of those who might be harmed (as well as employees, this should include other persons such as contractors or visitors).

• Evaluating the risks and determine the controls required.

• Recording significant findings – the hazards, how people might be harmed and the risk controls in place (where there are less than five employees, there is no legal requirement to write anything down although in these circumstances creating a formal record is recommended practice).

• Reviewing risk assessments on an ongoing basis with particular regard to when workplace or operational changes have taken place, or where an incident has occurred.​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​

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There are also specific risk assessments that are required by law, including:

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• Fire

• Manual handling

• Display screen equipment (DSE)

• Control of substances hazardous to health (COSHH)

• Noise

• Confined spaces

• Dangerous substances and explosive atmospheres (DSEAR)

• Pressure systems (PSSR)

• Lifting operations and lifting equipment (LOLER)

• Provision and use of work equipment (PUWER)

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Guidance on risk assessment can be found in HSE publication INDG163, available at https://www.hse.gov.uk/pubns/indg163.htm.

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In the event that it is decided to commission the services of a health and safety consultant to assist with risk assessment (or, for that matter, any other occupational safety and health advice), it is recommended that an appointment is made from the Occupational Safety and Health Consultants Register (OSHCR), details of which can be found at www.oshcr.org.

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Health and Safety Policy

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Fundamental to the effective management of health and safety, and to comply with statutory obligations, a written health and safety policy statement as required by the Health and Safety at Work Act must be prepared to reflect the commitment to health and safety, and to define the organisational structure and working arrangements currently in place.

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Where there are five or more employees, the policy must be written down. Where there are less than five employees, there is no legal requirement for the policy to be written, but it is helpful to do so.

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In accordance with HSE guidance, the health and safety policy should consist of the following:

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Part 1: Statement of intent

A statement of the company’s general policy on health and safety at work, including its commitment to managing health and safety, together with its aims and objectives. This should be signed by the employer, or most senior person in the company, and should be regularly reviewed.

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Part 2: Responsibilities for health and safety

The names, positions and roles of the people in the business who have specific responsibility for health and safety need to be listed.

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Part 3: Arrangements for health and safety

Details of the practical arrangements in place, outlining how the health and safety policy aims and objectives are to be implemented. This could include, for example, conducting a risk assessment, training employees and using safety signs or equipment.

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The health and safety policy should be communicated to all employees and should be reviewed at regular intervals to reflect changes in the organisation, working environment and hazards.

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Further information concerning the preparation of a health and safety policy, including a sample policy template is available from the HSE at https://www.hse.gov.uk/simple-health-safety/policy/the-law.htm.

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Health and Safety Training

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The Health and Safety at Work etc Act 1974 requires an employer to provide whatever information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of all employees.  This is expanded by the Management of Health and Safety at Work Regulations 1999 which identifies situations where health and safety training is particularly important, e.g. when people start work, exposure to new or increased risks, and where existing skills may have become rusty or need updating.

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In order to identify and implement appropriate training programmes, the HSE recommends adopting the following five-step approach:

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• Step 1 Decide what training is required

• Step 2 Decide on the training priorities

• Step 3 Select the appropriate training methods and resources

• Step 4 Deliver the training

• Step 5 Check that the training has worked

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When planning and reviewing health and safety training, it is important to ensure that:

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• All employees have sufficient health and safety training which is repeated periodically or when changes in working practices are made.

• An assessment is made of the training needs of all members of staff.

• The stringent legal requirements for training are undertaken and recorded (for example, first-aid, fork-lift truck operations).

• Special training needs are identified such as young persons, new recruits, trainees, existing workers, those moving jobs and part-time workers.

• In-house training, as well as that provided by external sources, is fully documented, including supervised or ‘on the job’ training.

• Refresher training is identified and implemented.

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Guidance on health and safety training can be found in HSE publication INDG345: Health and safety training – A brief guide, available at https://www.hse.gov.uk/pubns/indg345.pdf.

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Slips, Trips and Falls

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Slips and trips are the most common cause of injury at work. According to the HSE, on average they are the cause of around 30% of all reported major injuries and can also lead to other types of serious accidents, for example, falls from height. Slips and trips are also the most reported injury to members of the public.

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Key risk control measures include, but are not limited to:

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• Ensuring that walkways are clearly marked and together with work areas are kept clear of obstructions and debris.

• Avoiding trailing cables and wires. Where there is an unavoidable temporary feature, provide suitable cable covers and, where necessary, restrict access to prevent people having to cross them.

• Depositing waste and discarded materials into suitable bins placed in convenient locations.

• Maintaining floor, car park and other surfaces in sound condition.

• Ensuring that the risk of leaks and spillages is reduced by adopting correct maintenance and handling procedures, as most slips happen on wet or dirty floors. Where spillages occur, they should be cleaned up immediately and the floor left dry. Wet floors arising from cleaning operations should be protected by barriers as signs and cones only warn of a hazard and if the spill is not visible these are usually ignored.

• Keeping paths and parking areas free of snow and ice.

• Ensuring that adequate lighting is provided both internally and externally.

• Ensuring that stairways are kept clean, adequately lit and equipped with handrails and non-slip treads.

• Providing suitable access for work at height.

• Inspecting ladders, steps and platforms and record the findings. Faulty access equipment must be taken out of service until repaired.

• Never using ladders that are unsecured or on unstable ground.

• Never allowing people to climb racking to retrieve goods.

• Ensuring that edge protection is provided to mezzanine floors.

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Detailed guidance on how to manage the risk of slip and trips in the workplace is available at the HSE website - https://www.hse.gov.uk/slips/index.htm.

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Accident Reporting and First-aid

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An accident book (reference BI 510, available from the HSE) must be held in which all accidents at work are recorded. Accidents resulting in major injuries, or involving dangerous occurrences, must be additionally reported in accordance with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR). Guidance on RIDDOR can be found in HSE publication INDG453: A Brief Guide to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) available at https://www.hse.gov.uk/pubns/indg453.pdf

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Adverse events (incidents leading to injury or other loss such as property damage) can happen at any time and can result in accidents or near misses. Accident investigation procedures need to be established to identify root or underlying causes of such events as an aid to accident prevention and the overall ongoing management of risk.

In addition to having an accident book, first-aid arrangements must be provided. The nature and extent of which will depend on the particular circumstances of the workplace and the outcome of a specific assessment.  As a minimum, there must be in place:

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• A suitably locked first-aid box;

• An appointed person to take control of first-aid arrangements;

• Information for all employees giving details of first-aid arrangements.

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The outcome of the assessment may determine that a fully trained first-aider is required.

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The Control of Substances Hazardous to Health Regulations (COSHH)

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The COSHH Regulations impose duties on employers to safeguard the health and safety of employees and others (such as contractors and visitors) that may be affected by hazardous substances within the workplace through a combination of risk assessment, exposure control, monitoring, health surveillance and incident planning.

The Regulations apply to a wide range of substances and preparations (mixtures of two or more substances) which have the potential to cause harm to health if they are ingested, inhaled, absorbed by, or come into contact with, the skin, or other body membranes. The term “substances” may relate to products that are bought in or used as part of a process, in addition to any substances generated during a process (by-products) that may be hazardous to health. Hazardous substances can take many forms including:

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• chemicals

• products containing chemicals

• fumes

• dusts

• vapours

• mists

• nanotechnology

• gases and asphyxiating gases and

• biological agents 

• germs that cause diseases such as leptospirosis or legionnaires disease and germs used in laboratories.

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COSHH Regulations do not apply to asbestos, lead or radioactive substances which have their own specific regulations

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In general terms, the legal obligations imposed by COSHH can be broken down into the following six essential elements:

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1. Assessment. An assessment must be carried out in order to identify and assess the potential health risks on the premises.​

2. Prevention. The exposure must be prevented or substituted by a less hazardous substance or process.

3. Control. When prevention or substitution is not reasonably practicable, the exposure must be controlled.

4. Maintenance. Control of Asbestosmeasures must be routinely inspected and maintained to ensure continued effectiveness.

5. Instruction. Information, instruction and training must be made available to all employees.

6. Surveillance. Where appropriate, health surveillance should be carried out where exposure may result in an identifiable disease or adverse health effect.

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Most businesses use substances, or products that are mixtures of substances, whilst others conduct processes which create substances, many of which have the potential to cause harm to employees, contractors and others. As such, it is important that management pay close attention to the COSHH Regulations 2012in accordance with the information and guidance published by the HSE, available at https://www.hse.gov.uk/coshh/.

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Machinery, Plant and Equipment Safety

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The Provision and Use at Work Regulations 1998 (PUWER) place duties on people and companies who own, operate, or have control over work equipment. PUWER also places responsibilities on businesses and organisations whose employees use work equipment, whether owned by them or not.

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Under PUWER, equipment provided for use at work must be:

 

• Suitable for the intended use;

• Safe for use, maintained in a safe condition and inspected to ensure it is correctly installed and does not subsequently deteriorate;

• Used only by people who have received adequate information, instruction and training;

• Accompanied by suitable health and safety measures, such as protective devices and controls. These will normally include machinery guarding, emergency stop devices, adequate means of isolation from sources of energy, clearly visible markings and warning devices;

• Used in accordance with specific requirements for mobile work equipment and power presses.

 

Work equipment under the scope of PUWER is extremely wide and relates to any machinery, appliance, apparatus, tool or installation for use at work (whether exclusively or not) and extends to equipment which employees provide for their own use in the workplace. The use of work equipment is also very widely interpreted and '...means any activity involving work equipment and includes starting, stopping, programming, setting, transporting, repairing, modifying, maintaining, servicing and cleaning'.

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Some work equipment is subject to other health and safety legislation in addition to PUWER. For example, lifting equipment must also meet the requirements of the Lifting Operations and Lifting Equipment Regulations LOLER,  pressure equipment must meet the Pressure Systems Safety Regulations (PSSR) and personal protective equipment must meet the PPE Regulations.

 

Ensuring that plant and equipment is correctly maintained is a vital discipline. Establishing a planned maintenance programme is an important step towards reducing risk, together with implementing reporting procedures for employees who may notice problems while operating machinery.  Some items of plant and equipment may have safety-critical features for which routine inspection will be required. 

 

It is important to recognise that serious accidents can occur whilst maintenance is undertaken. Key safety measures include, but are not limited to, ensuring that:

 

• Employees have the necessary competence to carry out the work. If not, specialist contractors should be appointed;

• Work is correctly planned before commencement, referring to the manufacturer’s maintenance instructions and a safe system of work is produced;

• Maintenance staff are provided with the appropriate clothing and equipment;

• Where possible, maintenance work is carried out during downtime;

• Safe areas in and around maintenance activities are established;

• Plant and equipment is made safe before maintenance starts, such as ensuring electrical isolation, machine lock off, isolation of plant and pipelines containing pressurised fluid, gas, steam or hazardous material, stored energy released etc.

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Detailed information relating to PUWER is contained in HSE publication L22: Safe use of work equipment - Provision and Use of Work Equipment Regulations 1998. Approved Code of Practice and guidance, available at https://www.hse.gov.uk/pubns/books/l22.htm.

 

 

Manual Handling

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According to the HSE, manual handling causes over a third of all workplace injuries. These include work-related musculoskeletal disorders (MSDs) such as pain and injuries to arms, legs and joints, and repetitive strain injuries of various sorts.

 

Manual handling is defined as ‘transporting or supporting a load by hand or bodily force.’  It includes lifting, lowering, pushing, pulling, moving or carrying a load. A load is a moveable object, such as a box or package, a person or an animal, or something being pushed or pulled, such as a roll cage or pallet truck.

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Manual handling injuries are part of a wider group of musculoskeletal disorders (MSDs). The term ‘musculoskeletal disorders’ includes injuries and conditions that can cause pain to the back, joints and limbs. Manual handling is one of the main causes in the development of musculoskeletal disorders, particularly back pain. Manual handling risks can be found across all kinds of workplaces. Heavy manual labour, repetitive handling, awkward postures and previous or existing injuries or conditions are all risk factors for developing MSDs. Work may also make worse an injury which was not caused at work, such as a sports injury.

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The Manual Handling Regulations set out a clear hierarchy of measures that are required to be followed to prevent and manage the risks from hazardous manual handling. These are as follows:

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• Avoid hazardous manual handling operations, ‘so far as reasonably practicable’.

• Assess the risk of injury to workers from any hazardous manual handling that can’t be avoided.

• Reduce the risk of injury to workers from hazardous manual handling to as low as reasonably practicable.

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It is important that effective collaboration between managers and the workforce on all health and safety matters is achieved and maintained, which in the case of manual handling will help to identify and rectify hazardous activities.

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For detailed guidance on manual handling, reference should be made to material available on the HSE website at www.hse.gov.uk/pubns/manlinde.htm?msclkid=821464e1c63611ec93a2f5b381767eea

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Display Screen Equipment (DSE)

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The Health and Safety (Display Screen Equipment) Regulations 1992 apply to employers whose staff regularly use DSE as a significant part of their normal work (daily, for continuous periods of an hour or more). Whilst the Regulations do not apply to workers whose DSE use is infrequent or for short periods of time, best practice may be to adopt the same risk control principals.

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For the purposes of the Regulations, DSE comprises all devices or equipment that have an alphanumeric or graphic display screen such as PCs, screens, laptops, smartphones, touch screens and other similar devices, and applies to workers who are:

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• At a fixed workstation

• Home-workers

• Mobile workers

• Hot-desking

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Health risks associated with the overuse or improper use of DSE include fatigue, eye strain, upper limb disorders and backache. This can be adversely influenced by poorly designed work stations or work environments. The causes may not always be obvious and will often involve a combination of factors.

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Under the Regulations, employers with DSE users have a duty to:

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• Analyse workstations to assess and reduce risks.

• Ensure that controls are in place.

• Provide information and training.

• Provide eye and eyesight tests on request, and special spectacles where needed.

• Review the risk assessment when the user or workstation changes, or when users complain of pain or discomfort.

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A record of the significant findings of the risk assessment should be made.

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Key risk control measures include:

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• Provision of DSE training and assessments of workstation carried for new starters.

• Workstation and equipment set to ensure good posture and to avoid glare and reflections on the screen.  

• Shared workstations are assessed for all users.

• Work planned to include regular breaks or change of activity.

• Lighting and temperature suitably controlled.

• Adjustable blinds provided at windows to control natural light on screen.

• Laptop users trained to carry out own DSE assessment for use away from office. When used at office, laptop should be used with docking station, screen, keyboard and mouse.

 

Detailed guidance on DSE is contained in HSE publication L26: Work with display screen equipment, available at www.hse.gov.uk

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Noise at Work

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The Control of Noise at Work Regulations (CNAWR) 2005 places a duty on employers to make an assessment of the noise exposure within the workplace and ensure that the levels of noise exposure are reduced to as low as reasonably practicable. In addition, there is a specific requirement for those employees exposed to average noise levels exceeding 80dB to undergo an ongoing regime of health surveillance.

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Noise at work can cause permanent and disabling hearing damage. As a result, it can interfere with communications making warnings harder to hear and can reduce people’s awareness of their surroundings leading to safety risks.

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Depending on the level of risk, employers should take action to reduce the noise exposure, and also provide employees with personal hearing protection.

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Other duties under the Regulations include the need to ensure that:

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• The legal limits on noise exposure are not exceeded.

• The equipment provided to control noise risks is correctly used and maintained

• Employees are provided with suitable information, instruction and training.

• Health surveillance (monitor workers’ hearing ability) is conducted.

 

​​Risk Assessment

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When assessing the risk of noise in the workplace it is essential to show that the estimate of employees’ exposure is representative of the work they do or are likely to do, the method by which it is conducted and how it may vary from one day to the next.

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Estimates should be based on reliable information such as measurements in the workplace, information from other similar workplaces, or data from suppliers of machinery.

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The findings of the risk assessment must be recorded, together with an action plan on remedial measures which have been identified as needed to comply with the law.

Importantly, the risk assessment must be reviewed when any changes in the workplace are made which may affect noise exposures and routinely, at least once every two years.

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It must be ensured that the risk assessment is conducted by someone who is competent to perform the task  and that it is based on advice and information from a competent source.  Depending  on the circumstances , the services of an external consultant may need to be employed. 

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Detailed guidance concerning The Control of Noise at Work Regulations is published by the HSE, available at www.hse.gov.uk

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Safety Signs and Signals

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Under the Health and Safety (Signs and Signals) Regulations, employers are required to ensure that safety signs are provided (or are in place) and maintained in circumstances where there is a significant risk to health and safety that has not been controlled by other methods.

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The deployment of safety signs should be determined by the results of the risk assessment where, despite control measures having been introduced, a significant residual risk remains.

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The Regulations make it clear that safety signs must not be used as a substitute for other risk control means, but rather that they are to warn of any remaining significant risk or to instruct employees of the measures that should be taken in relation to these risks.  

 

It should be noted that in addition to the provisions of the Health and Safety (Signs and Signals) Regulations, certain fire safety signs may have to be displayed under separate legal provisions.   

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For detailed information regarding these regulations, reference should be made to HSE guidance publication L64: Safety Signs and Signals - The Health and Safety (Signs and Signals) Regulations 1996, available at https://www.hse.gov.uk/pubns/books/l64.htm.

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Lone Working

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Under the Management of Health and Safety at Work Regulations, employers must manage the risk to lone workers; this applies to any person contracted to work for the business, including the self-employed.

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Lone workers comprise of those who work by themselves without close or direct supervision, for example:

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• Delivery drivers, health workers or engineers

• Security staff or cleaners

• Lone workers in warehouses or petrol stations

• Persons working at home

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Persons working alone will always be at greater risk, many of whom will also be exposed to work-related road risks. Managing the risks to employees who drive at work, whether this is in a company or hired vehicle or the employee’s own vehicle, is more than just compliance with road traffic legislation, but extends to taking all reasonable steps to manage these risks and to do everything that is reasonably practicable to protect people from harm in the same manner as they would in the workplace.

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Full information concerning the health and safety of lone workers is published by the HSE and is available at https://www.hse.gov.uk/lone-working/employer/index.htm

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Managing Asbestos in Buildings

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The duty to manage asbestos is contained in regulation 4 of the Control of Asbestos Regulations 2012. It requires the person who has the duty (i.e. the ‘dutyholder’) to:

 

• Take reasonable steps to find out if there are materials containing asbestos in non-domestic premises and if so, it’s amount, where it is and what condition it is in.

• Presume materials contain asbestos unless there is strong evidence that they do not.

• Make, and keep up to date, a record of the location and condition of the asbestos-containing materials (ACMs) or materials which are presumed to contain asbestos.

• Assess the risk of anyone being exposed to fibres from the materials identified.

• Prepare a plan that sets out in detail how the risks from these materials will be managed.

• Take the necessary steps to put the plan into action.

• Periodically review and monitor the plan and the arrangements to act on it so that the plan remains relevant and up to date.

• Provide information on the location and condition of the materials to anyone who is liable to work on or disturb them.

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There is also a requirement on others to co-operate as far as is necessary to allow the dutyholder to comply with the above requirements.

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The dutyholder is the owner of the non-domestic premises or the person or organisation that has clear responsibility for the maintenance or repair of non-domestic premises, for example through an explicit agreement such as a tenancy agreement or contract. The Regulations also apply to the common areas of domestic buildings such as entrance halls, stairwells, lift shafts and roof spaces.

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ACMs can be found in any industrial or residential building built or refurbished before the year 2000. According to the HSE, past exposure to asbestos causes around 5000 deaths a year in the UK. ACMs include, but are not limited to:

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• Asbestos cement roof and wall claddings;

• Lagging;

• Sprayed coatings on ceilings, walls and structural frame members;

• Asbestos insulation board;

• Roofing felt;

• Loose asbestos in ceiling or floor voids;

• Textured coatings;

• Floor tiles, textiles and composites;

• Rope seals and gaskets;

• Naturally occurring asbestos in some types of marble and other stone.

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All types of ACMs can be dangerous if disturbed owing to the release of fibres that can cause mesothelioma, lung cancer and asbestosis if they are inhaled. The more asbestos fibres breathed in, the greater the risk to health. As a result, workers who may be exposed to asbestos when conducting repair or maintenance activity are particularly at risk.

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Where in any doubt as to the presence or extent of asbestos-containing materials, it is recommended that an asbestos survey of the premises is undertaken by a specialist contractor. Organisations that sample and analyse asbestos need to be accredited by the United Kingdom Accreditation Service (UKAS). UKAS also run an accreditation scheme for organisations that do asbestos surveys. An accredited company is likely to employ suitably trained people for these types of work, but a check should be made on what the firm is accredited for as some will only be qualified to do surveys and take samples and others only to analyse samples (the UKAS website address is: www.ukas.com).

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It must be remembered that most work on asbestos insulation, asbestos insulation board and lagging, including sealing and removal, should normally only be carried out by a contractor licensed by the HSE, details of which can be found at Asbestos Licensing (https://www.hse.gov.uk/asbestos/licensing/index.htm)

 

Extensive information and guidance on managing asbestos in buildings is published by the HSE, available at www.hse.gov.uk/asbestos/. https://www.hse.gov.uk/asbestos/ .This includes a web-based tool which takes the participant through the whole process of managing the risk from asbestos for which the link is https://www.hse.gov.uk/pubns/indg223.pdf

 

The Asbestos Removal Contractors Association (https://www.arca.org.uk/) is a further source of reference.

 

With Britain having left the EU, the HSE has set-up a website for the publication of an index of changes which have taken place concerning health and safety matters -  https://www.hse.gov.uk/brexit/index.htm

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