Memorandum by Water UK (HSE 12)|
1. Water UK welcomes the Sub-committee's
inquiry into the work of the Health and Safety Executive (HSE)
and are pleased to submit this short memorandum in support of
the Executive and to reinforce the existing regulatory framework.
2. Our members are all of the water and
sewerage suppliers in the United Kingdom (with the exception of
Mid Kent Water and Cholderton Water) and they have statutory duties
to supply water and to collect and treat sewage. The legal arrangements
under which these duties are performed differ between England
and Wales, Scotland and Northern Ireland but Water UK presents
its views in this memorandum on behalf of all of its members.
3. The nature of our members' core businesses
can have a significant effect on public health as well as the
safety, health and welfare of their 45,000 strong direct workforce
and an estimated further 200,000 indirect workforce employed on
construction and process activities. The undertaking of that business
requires our members to have regard for both the safety of their
workforce and the public at large. Water UK is therefore in an
excellent position to comment on the work of the HSE with whom
we and our predecessor organisations have collaborated intensively
for a number of years to reduce the incidence of accidents and
occupational ill health in the water industry.
4. Informal co-operation between the water
industry and the HSE has been in being for a large number of years.
The publication of the Health and Safety at Work Act in 1974 coincided
with the formation of the ten Regional Water Authorities in England
and Wales and the formation of the National Water Council.
5. Co-operation between the HSE and the
National Water Council's Joint Health and Safety Committee for
the Water Service resulted in the publication of six Health and
Safety Guidelines between March 1979 and April 1983 and four Employers
Guidelines in 1983. The Committee had representatives from the
employers' and the employees' sides of the water industry and
guidance covered a range of subjects from "Safety representatives
and safety committees" to "Safety in electric fishing
operations" and "Safety when hosing or spraying sludge
to land near overhead electric power lines".
6. At the same time the National Water Council
and its successor the Water Authorities Association, together
with the Water Companies Association, organised the Water Industry
Forum for Health and Safety which published a series of Advisory
Broadsheets with the co-operation of the HSE between 1977 and
7. Since that time Water UK and its predecessor
organisations, the Water Services Association and the Water Companies
Association, have formed a more formal liaison with the HSE through
its Utilities National Interest Group and this has resulted in
the publication of three occasional health and safety guidance
notes covering "Health hazards of work involving exposure
to sewage", "Radon in air" and "Public access
to open reservoirs". These documents contain risk assessment
and control criteria agreed with the HSE. Therefore as well as
being made available to the water industry, they have also been
distributed to HSE local inspectors so that they share a common
understanding of the subjects with the water industry.
8. This formal liaison is achieved by having
David Left, the Head of the HSE Utilities National Interest Group
(HSE UNIG), as a member of the Water UK Health and Safety Horizontal
Group. We believe that we are the only trade association to invite
HSE to fully participate in this way and we are said to be leading
the way for future industrial relations between regulators and
the UK economy. Horizontal Groups at Water UK are formed for the
important aspects of water industry business which span over two
or more business areas. To facilitate sensible training policies
regarding health and safety, a representative of Water Training
International (WTI) is also a member of the Health and Safety
Horizontal Group. WTI is the successor to the Water Industry Training
Board. The synergy produced by having the regulator, the regulated
and the training provider working in close co-operation has resulted
in a number of achievements.
AND HSE CO-OPERATION
9. In order that the whole of the UK water
industry can be kept informed of the results of the close liaison
between Water UK and HSE UNIG a Health and Safety Network has
been formed among Water UK members. The network can communicate
quickly through e-mail and facsimile and has a significant health
and safety incident reporting system in place.
10. When the water industry began their
formal liaison with HSE UNIG in 1994 this encouraged a close relationship
with Mr Frank Davies, the Chairman of the Health and Safety Commission,
and this relationship, in turn, resulted in the undertaking of
the "Frank Davies Project" which had as its strategic
To indentify accident and ill health costs
in the water industry and promote the commercial case for health
and safety management.
11. Close co-operation between HSE UNIG
and the water industry through the Frank Davies Project resulted
in the following definitions being agreed for the project:
Work accident: An unplanned event that could
result in injury to an employee.
Work related ill health: An evident reduction
in the health of an employee confirmed by an Occupational Health
professional as being due, or partly due, to working conditions.
12. Against these definitions the representative
cost of a work accident was calculated to be £3,580 for the
water industry and the representative cost of an incidence of
work related ill health was calculated to be £8,650.
13. In order to demonstrate the commercial
case for health and safety management the final report of the
project has been widely distributed and promoted within the water
industry. South West Water, who managed this water industry wide
project on behalf of Water UK, have since given presentations
at fora within many other industries to share ideas about leading-edge
health and safety management.
14. WTI in co-operation with HSE UNIG and
the water industry have held Health and Safety days at their management
centre at Tadley Hall. These seminars have been aimed at both
senior managers and health and safety practitioners within the
water industry and from the industry's contractors and suppliers.
15. Since it was agreed in April 1999, HSE
UNIG and the Water UK Health and Safety Horizontal Group are working
to "Water Ahead" their strategic plan for joint liaison
a copy of which accompanies this memorandum for the information
of the Sub-committee. The concept of agreeing long-term regulatory
priorities in this way has since been taken up by some of the
trade bodies representing other industries.
16. "Water Ahead" contains the
following key objectives:
Improving communications and working
Raising the profile of health and
Occupational health strategy for
Monitoring new developments.
17. Within the strategy of "Water Ahead",
the Water UK Health and Safety Horizontal Group and the HSE UNIG
are currently co-operating through focus groups on the holding
of a health and safety week in the year 2000, earth bonding of
water service pipes, confined spaces procedures and benchmarking
of health and safety management systems. In addition, the water
industry has made a commitment to a 10 year Occupational Health
Strategy which will be project managed for Water UK by the Chair
of its Health and Safety Horizontal Group in partnership with
the HSE Health Directorate.
18. Water UK draws the following conclusions
from its relationship with the HSE:
The HSE through its UNIG are willing
to co-operate with Water UK on health and safety initiatives and
policies with the potential to influence the working lives of
circa 245,000 direct and indirect employees with a knock-on effect
assisting many other industries.
Co-operation between regulators,
the regulated and training providers is productive and leads to
mutual understanding of each others ambitions. This has been linked
to clear agreed deliverables.
Water UK are pleased to be quoted
by HSE as a good example of HSE/industry co-operation to other
utilities and industry in general.
19. Water UK commends to the Environment
Sub-committee the attitude of the HSE to co-operation and consultation
with the water industry. We welcome any opportunities to contribute
to further developments, by presenting evidence to the Sub-Committee
should they wish it, sharing our perception of internal changes
in HSE and how they affect our industry.