Memorandum by the Federation of Small
Businesses (HSE 22)
1. INTRODUCTION
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. SUMMARY
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.
3. ISSUES IDENTIFIED
AS TERMS
OF REFERENCE3.1 Positive
comments:
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. CONCLUSION
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
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