Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by Dr R K Bentley (HSE 09)

  Recently it has been announced that work undertaken by the Competent Authority in respect of the Control of Major Accident Hazard Regulations will be charged out at the rate of £102 per hour. Clearly this reflects not only the salary of an inspector, but the many otherwise irrecoverable overheads associated with supporting the inspectors' work. Whilst there has been some adverse comment about both the introduction and the level of these charges, and most of us who work as consultants in health and safety are not able to demand such a rate, it does not seem disproportionate when compared with what one is charged to consult, say, a solicitor.

  It is not therefore the purpose of this submission to criticise this charging rate. What I do wish to bring to the attention of the inquiry, is the disparity between how an inspector's time is being charged, and estimates of costs incurred by industry which are used in the cost benefit assessments which are part of regulatory impact assessments now published for proposed new legislation.

  Example 1. Consultative Document 142.

  In annex 3, at para 15, the HSE costs in preparing the regulations are stated as "the full economic cost" and at a guess are more than double the salaries involved. Yet in the same annex, at para 7, it is argued that the costs incurred by businesses will be "on a salary cost basis".

  Example 2. Consultative Document 147.

  Similarly in annex D of this document, at paragraph 10, the costs to the HSE/other enforcing authorities are again given as "the full economic cost". The compliance costs stated are only for the ACoP at cost price. No mention is made of the time spent (and thereby costs incurred) in:

    ordering the ACoP

    paying for the ACoP

    reading the ACoP.

  Example 3. Consultative Document 150.

  Paragraphs 12-14 and annex 3B give costs of complying with MEL's. But where is any recognition made of the time spent by industry's managers and advisors in studying the new requirements? I probably spent a couple of hours just reading the consultative document. If this is multiplied by the number of copies supplied (a figure which is not available to me, but I'll guess at 5,000), and an hourly rate similar to that charged for an inspector's time, just studying the proposals has cost £1,000,000.

  Example 4. Consultative Document 149.

  Appendix 5 at para 8 states the costs to industry is mostly in staff time. No allowance is made for overheads.

  Example 5. Consultative Document 114.

  I refer to this document from two years ago, because it is one which gives an hourly rate for a manager's time. This is quoted as £12.72. Whilst I do not imagine a manager controlling power presses commands anything like the salary of an HSE inspector, I do consider that if the full economic cost is used for HSE employees, the same should be used for industrialists.

September 1999

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Prepared 26 October 1999