Annex 4
EXAMPLES OF HSE RECOMMENDATIONS TO MoD AND
MoD RESPONSES
As mentioned in the original HSE Written Evidence,
HSE's interaction with MoD has been primarily reactive in recent
years, with only a limited number of major audits as distinct
from contacts on specific topics or incident investigation visits.
HSE has established an effective working relationship with MoD
and many of the contacts follow requests from MoD for information,
participation by HSE in seminars, etc.
The short free-text records of inspections entered
on the HSE database are not searchable for information on MoD
responses to HSE activity. Specific examples of MoD responses
to HSE activity given below are largely based on a selection of
the short texts which happen to specifically refer to MoD responses
and from information in the HSE's operational policy unit that
covers Defence. Reports of inspections of weapons training and
military exercises indicate a generally high standard.
MATTERS DEALT
WITH BY
HSE'S REGIONALLY-BASED
INSPECTORS
1. HSE investigation of the near drowning
in a swimming pool of a Phase 1 recruit undergoing initial training
revealed a wider problem of inadequate cover by qualified PT staff
for supervision of potentially hazardous physical training throughout
the army.
HSE issued a Crown Improvement Notice on the
ATRA (Army Training Recruitment Agency) to ensure adequate numbers
of PTIs within Army Training Regiments (ATRS) to conduct training
sessions safely. There was an immediate and positive response
by ATRA, who altered the training programme for PTIs to increase
the flow of PTIs. The situation was followed up several months
later and considerable improvements were found.
2. Following on investigation of two unrelated
fatal accidents during naval diving training (one leading to a
Crown Censure, one still with CPS), MoD suggested that HSE carry
out a major audit of Defence Diving School. The audit was conducted
with good co-operation from MoD. Subsequently, there have been
major changes in procedures at the Defence Diving School and an
increase In the number of training staff.
3. As a separate initiative, MoD—supported
by HSE—has carried out a fundamental reassessment of diving
safety management for all military and civilian diving activity
in MoD which has led to development of a robust safety management
system. Central liaison between HSE and MoD on diving activity
continues.
4. Investigation by the Army of a fatality caused
by collision between army vehicle and a soldier during a training
exercise disclosed, amongst other things, inadequate maintenance
arrangements by the Army for maintenance of wheeled vehicles.
HSE issued a Crown Notice on MoD [Army] requiring
that suitable arrangements were put into place to ensure that
vehicle maintenance was carried out in accordance with manufacturer's
instructions. This Notice, affecting 55,000 road vehicles, was
supported at high level in the Army and was fully complied with.
5. Triggered by a number of accidents and
incidents at Marchwood Military port, HSE issued a Crown Improvement
Notice requiring a thorough review of health and safety management
arrangements in the port area. At HSE's suggestion, the military
port consulted health and safety managers in the civilian dock
sector. Following the review, HSE was invited by MoD to carry
out a further survey to demonstrate that appropriate action had
been taken, as was found to be the case.
6. HSE has done much work with the Defence
School of Transport concerning health risks to instructors from
whole body vibration exposure in their training vehicles. The
work has influenced MoD in its vehicle purchasing policy.
7. Following an HSE audit of a training
regiment, amongst other measures in response, the barracks changed
the recruit selection process. This reduced the number of unsuitable
candidates recruited with consequent reduction of the number of
training injuries because more unfit/unsuitable candidates were
identified at the outset.
8. A major HSE audit of an army training
establishment showed a positive attitude to health and safety,
including effective dynamic risk assessment for training activity.
HSE made some further recommendations on risk assessment. The
Army Training and Recruitment Agency (ATRA) sought a central meeting
with HSE to discuss the issues raised to ensure that appropriate
messages could be communicated nationally by ATRA.
9. After a major road accident (Police investigation)
and a fatal accident during unloading of armoured personnel carriers
at a dock (HSE investigation), HSE intervened and served a Crown
Improvement Notice. This required MoD to review and update its
policies on the provision of information to haulage contractors
hired to move armoured vehicles nationally. MoD accepted that
they needed to improve the information provided to armoured vehicle
haulage contractors.
MATTERS DEALT
WITH CENTRALLY
BY HSE
1. HSE's current relationship with MoD is
such that the MoD central health and safety department and Armed
Forces chief safety officers will routinely seek HSE advice on
new policies/procedures.
2. An HSE MoD Joint Liaison Committee was
formalised to provide a central forum for resolving difficulties
between HSE and MoD.
3. HSE investigation of a cadet fatal accident
resulted in central review of management of health and safety
in cadet forces. HSE is involved centrally and still actively
involved in clarifying status of Sea Cadets.
4. Whilst MoD land ranges take account of
public safety, intervention by HSE generated explicit public safety
risk assessments for range procedures.
5. HSE advice to ACPO during the firefighters'
dispute also reassured MoD commanding officers over their own
individual liability (Armed Forces commanding officers have had
concerns over any individual liability they might incur out of
their command of service personnel in a firefighting situation).
6. HSE has recently reviewed the Army's
Generic Risk Assessment for firefighting in any future firefighters'
strike. Further advice may be given following Sector involvement
in Government contingencies fora.
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