Memorandum by the Institution of Occupational
Safety and Health (HSE 24)
INTRODUCTION
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.
ENFORCEMENT
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".
PROSECUTION
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.
CHARGING
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
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.
PUBLICATIONS
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.
CONCLUSIONS
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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