Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by the Federation of Small Businesses (HSE 22)


  1.1  The Federation of Small Businesses was founded in 1974 and is the major organisation in the UK and Europe representing the interests of the self-employed and those who direct small businesses in the UK. It is non-profit making and non party-political. A membership in excess of 140,000 benefits from the nation-wide lobbying force committed to furthering the interests of the self-employed and owners and directors of small businesses.


  2.1  This evidence is based on feedback received from FSB members at a regional level. There have been visible changes of approach and a much more positive view emerging about the importance of small firms to the UK economy. The following identifies the positives and negatives we see in relation to the role and work of HSE.


  The FSB welcomes the following:

    —  the provision of the HSE Infoline, which is extremely valuable;

    —  the development of telephone reporting under RIDDOR, which we would like to see extended nationally;

    —  closer working with other government departments BUT only in a limited way, for example, HSE and Home Office on fire issues; HSE and Department of Health on lifestyle/public health issues;

    —  the improvement in the content and layout of guidance on Health and Safety over last few years.

3.2  Further Positive Developments:

  Further positive developments include:

    —  the work of HELA and Local Authority liaison at national level which is very good. Unfortunately, this does not always filter down to the regional level where there is a perceived barrier between HSE and local authority inspectors;

    —  the fact that HSE is starting to work more closely with the FSB on specific issues such as the Gas Safety Review, which we believe has worked extremely well.

3.3  Negative Comments:

  Negative comments include:

  3.3.1  the shift to a charging policy for some elements of their inspection work which we totally oppose, an example being the Proposals for the making of Regulations to enable Competent Authority to Charge for Activities Carried out under Control of Major Accident Hazards Regulation 1999 (COMAH). Here the FSB expressed concern about the principle of charging for fundamental enforcement activities that are part of HSE's role. We questioned the levels of suggested fees at a daily rate of £750, a level much higher than the fees charged by many private consultances which do not have the benefit of government backing and support;

  3.3.2  the reduction in the emphasis on the work of the Workplace Contact Officers (WCOs), who we view as potentially a positive link for businesses at regional level, is to be regretted;

  3.3.3  we believe that apparently there are fewer resources available for inspectors to carry out information and guidance visits, concentrating more on enforcement action;

  3.3.4  the reluctance to produce sector specific rather than generic guidance despite identified need from the FSB and other representative groups, Health & Safety professional and many inspectors is to be regretted;

  3.3.5  we believe that there are not enough cross-functional links on policy and strategy on enforcement that encompass health, safety, food hygiene, environment, fire, planning, etc.


  4.1  The FSB is particularly concerned that despite government statements of intention to take on board the concerns of small businesses, actions demonstrate loud and clear that this is not actually the case, and there is still no genuine small firms' voice within the Health & Safety Commission.

  4.2  Where the FSB has been involved in discussions at an early stage, such as in the Gas Safety Review and in the current DETR review of Health & Safety generally, we believe our contribution has been positive, constructive and valuable. However, we do believe the small firms' perspective should be taken into account when developing all new or amended regulations at a much earlier stage than public consultation. In some areas this is starting to happen now, but there is still some way to go before it becomes the norm.

Jacqueline Jeynes

Health & Safety Adviser

September 1999

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries

© Parliamentary copyright 1999
Prepared 26 October 1999