Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by the Institution of Occupational Safety and Health (HSE 24)


  The Institution of Occupational Safety and Health (IOSH) strongly supports the role and function of the HSE and the comments appearing below should be read in that context.


  The enforcement regime operated by the HSE is widely seen as being firm and fair. However there is concern that due to a lack of adequate resources enforcement tends to be reactive rather than proactive. The majority of effort is directed towards major industries and companies incurring comparatively few accidents and incidents of ill health. On the other hand, in SMEs where collectively the majority of incidents occur enforcement appears almost non existent. SMEs receive little scrutiny and generally appear to regard high profile prosecutions of larger organsiations as being "largely out of their court".


  Inevitably there is variance between regions due doubtless in some cases to local HSE knowledge of companies concerned and their commitment to health and safety. However, as an enforcing authority the HSE gains significant benefit from its place within the civil service and an arm of government. In that sense it is seen as being both authoritative and independent of commercial or political pressure. This is an important element which in our view needs to be retained and which would be lost in the event of any form of privatisation.


  The charging regime has provoked considerable controversy and in our view needs to be reconsidered. Its retention and extension could lead to an adverse effect on the level of co-operation between the HSE and industry and commerce. This is particularly true of the offshore industry where a much wider charging regime is currently under consideration.


  Research by the HSE into the causes of accidents and occupational ill health should continue to be a priority. However there have been cases in which, in our view, a wider and more effective form of consultation with appropriate "players" could have provided effective knowledge and guidance at considerably less expense than formal, academic research.


  Given the HSE's statutory requirement to provide information concern has been expressed in many areas in recent years over the increasing cost to the public in obtaining HSE publications which originally were either inexpensive or free. Whereas we fully understand the HSE's reason for doing this given the need to prioritise its contracting resources, the concern is that SMEs (who arguably most need the information) are dissuaded from doing so on grounds of cost.


  In our opinion the work of the HSE is vital in maintaining and improving health and safety standards in the workplace within the United Kingdom. The work of the HSE is generally regarded as both professional and authoritative and is a valuable source of good practice, guidance and of materials for training purposes notwithstanding the cost of such material.

  The HSE's current role and position within the civil service and government structure should remain unchanged but it does need to improve its communication with SMEs and should consider doing so in partnership with other organisations having strong links with SMEs if this would be an advantage.

  We would be pleased to have an opportunity to provide for the enquiry oral evidence from senior health and safety practitioner members of this Institution to elaborate on the issues contained within this document.

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Prepared 26 October 1999