Memorandum submitted by the Institute
of Occupational Safety and Health after the publication of the
Welfare Reform Green Paper
The Institution of Occupational Safety and Health
(IOSH) recognises the value to people's health and well being
that well managed work can bring. We note the government's increased
focus on occupational safety and health (OSH) and its aim of improving
access to competent occupational health advice and support, rehabilitation,
return to work programmes and early interventions, as outlined
in its Green Paper on proposed welfare reforms "A new deal
for welfare: Empowering people to work". The evidence that
follows will also form the basis of the forthcoming IOSH response
to the Green Paper, due for submission in April 2006.
In our evidence, we would like to take the
opportunity to highlight the key role of OSH practitioners in
supporting employers and workers, helping to prevent injury and
illness occurring in the first place and where it does occur,
helping to bridge the gap between absence and a safe return to
work, as part of a co-ordinated multidisciplinary approach. We
would also like to draw attention to the need for much improved
national occupational health awareness and service provision,
outlining some important IOH work in this area. And finally, we
would like to comment on the Green Paper consultation question
"What else should we consider to give the right incentives
to employers to provide increased health support to their workforce?"
and emphasise the need for appropriate health and safety awareness
training for those entering or re-entering the workplace.
1. THE ROLE
OSH practitioners help to protect and improve
the health and Safety of workers and can give advice on absence
management, reasonable adjustments and flexible working arrangements,
helping those who have been ill or injured to remain in I return
to or join the workforce as appropriate. Working closely with
employers and workers, they can advise on practical solutions
to prevent people being) made ill or injured by work, especially
potentially at-risk groups, such as young, inexperienced or older
workers, expectant mothers, migrant workers and people with disabilities
and special needs. They are also involved in promoting health
by using the workplace to communicate and share important health
improvement messages, covering issues such as stress management,
smoking cessation, fitness and healthy eating.
In order to support those with illness or disability
seeking to remain in/return to or join the workforce, we believe
a co-ordinated multidisciplinary approach is needed, involving
workers, GPs, managers, human resource officers, employment advisers,
OSH practitioners, occupational health nurses and physicians and
others. As the government's proposals to support people on incapacity
benefit back into work and to increase the number of older workers
in the workplace take effect, we believe OSH practitioners could
also help provide mentoring or advocacy, assisting new entrants
to settle safely into new working environments.
However, with 35 million days lost last year
to work-related injury and ill health and 2 million people suffering
from an illness they believe was caused or made worse by work,
we think a fundamental "sea-change" is needed in how
well the country manages its workplaces, with everyone pulling
in the same direction: government, employers, professionals, advisers
and workers. As a nation, we must ensure that everyone understands
how to protect and improve health and emphasise the message that
good health really is good business. Competent advice is essential,
as is a flexible and sensible approach to adapting workplaces
and work arrangements to meet the needs of an ageing workforce,
those managing illness; disability or caring roles and also, the
needs of employers.
2. NATIONAL OCCUPATIONAL
We support the government's intention to tackle
the enormous challenge of occupational health. although we hope
that extending Pathways to Work nationally and introducing the
Workplace Health Connect scheme will go some way to improving
access to occupational health services; we believe long-term planning
and resourcing is necessary. As research
indicates only 15% of UK firms employ OH support such as hazard
identification, risk management, and provision of information
and that applying a wider definition (to include modifying work
activities, providing training on OH-related issues, measuring
workplace hazards and monitoring health trends) only 3% of UK
firms do so, we believe it'd vital that other support sources
are made more widely available. We note that the Constructing
Better Health scheme, a construction industry-led OH support pilot
facilitated by the Health and Safety Executive/Commission, is
currently testing a sector-specific model, providing a central
access point for free OH services to constriction firms within
the Leicestershire region. We believe early reports show positive
impact and look forward to the project's evaluation, so lessons
can be drawn regarding possible future delivery of similar services
to other sectors and on a national basis.
We are concerned that the former Downing Street
adviser, Lord Layard has described mental health provision as
"desperately under funded"if the almost 40% of
incapacity benefit claimants suffering mental illness are to be
adequately treated and supported back into work, this lack of
provision needs to be properly addressed.
IOSH has long-called for increased national
OH support and has been actively engaged in developing this area,
with examples including:
(a) Organising workshops for professionals
in support of the government's "Health, Work and Well being"
strategy, to develop tools for facilitating early non-medical
interventions and multidisciplinary working. This is a pioneering
conceptinitiated, led and funded by IOSHin which
all the major UK occupational safety and health professional bodies
are collaborating to produce web-based OH toolkits. The purpose
of these will be to provide essential information for occupational
safety and health (non-medical) practitioners on key OH issues,
such as musculoskeletal disorders, stress, inhalation hazards
and skin disorders. The emphasis will be on preventing occupational
ill health and on early recognition of problems and appropriate
(b) Recommending that the revised GPs curriculum
ensures, adequate training in occupational health for all trainee
(c) Advising on the competence levels for
advisers involved in the "Workplace Health Connect"
(d) Co-sponsoring research and distributing
via our Branches new British Occupational Health Research Foundation
guidance on occupational asthma and workplace interventions for
people with common mental health problems.
(e) Supporting the launch of free guides
for employers and professionals "Creating a healthy workplace".
(f) Participating in a workshop to explore
development of a management tool for shift work sleep disorder.
(g) Facilitating distribution of the organisational
stress assessment tool, developed by the Health Education Board
of Scotland and the Health and Safety Authority (Republic of Ireland).
(h) Contributing to the development of the
HSE stress management standards.
(i) Co-sponsoring and contributing to an
Institute of Directors (IoD) guide Health and well being in the
(j) Supporting SMEs by the provision of free
resources such as an interactive website <au0,1>www.safestartup.orq
and leaflet, a risk management toolkit and free training and technical
enquiry line access for Worker Safety Advisers, to assist their
work with small firms.
(k) Participating in the government's long-term
occupational health strategy Securing Health Together (SH2) Programme
(l) Producing and distributing a free OH
guide "Professionals in partnership" in support of SH2.
(m) Providing professional development courses
on a wide range of occupational health issues, including stress
and musculoskeletal disorders.
(n) Setting up national and international
"umbrella groups" for occupational safety and health
professional organisations (POOSH, ENSHPO and INSHPO)
to share best practice.
We note that the Department of Work and Pensions
and Department of Health are soon to jointly appoint a National
Director of Occupational Health. We look forward to this appointment
and to working with the new Director. We hope this appointment
will help ensure the effective implementation of the Health, Work
and Well being strategy and help raise the profile, resourcing
and co-ordination of occupational health across the country.
3.1 The following are suggested as a means
of helping employers to understand and access available financial
support for employing and rehabilitating people with temporary
or permanent disabilities:
(a) To encourage more people to make use
of appropriate tax relief, we believe the HSE information sheet
"Tax rules and the purchase of occupational health support"
(2004), could perhaps be retitled "Tax and NIC relief on
adjustments, services and equipment provided for workers with
disabilities", to give a better idea of its content.
(b) To clarify eligibility on capital allowances,
we think it would be helpful if the HSE information sheet on tax
could explain why only "qualifying hotels" (which requires
definition) and industrial or agricultural buildings are eligible
for capital allowances for money an employer spends on the fabric
of the building eg fitting ramps or widening a doorway, and not
other places of employment.
(c) To support choice in appropriate treatment
options, we suggest that where employers are prepared to give
financial assistance (in the form of a limited cash sum) to employees
seeking private treatment (eg physiotherapy) for non work-related
injuries, the employee should not be required to pay tax on this,
as currently is the case. We feel that this is short-sighted and
that provided receipts are obtained and submitted, such transactions
should not penalise the employee, who is, after all, trying to
improve their health and maintain their employability.
(d) To help communication on financial support,
we suggest thel HSE "tax rules sheet" should cross-refer
to the Jobcentre Plus section of the DWP website, on "Access
to Work" grants and vice versa.
3.2 In addition to publicising the "good
health is good business' message and any possible insurance premium
benefits, the following are suggested as legal and business drivers
to encourage the increased provision of health support:
(a) Introduction of enforceable directors'
health and safety duties; supported by the provision of practical
guidance and an approved code of practice. IOSH is currently working
in partnership with the Health and Safety Executive to produce
improved guidance in this area
(b) Introduction of mandatory Operating and
Financial Review, requiring appropriate inclusion of occupational
health performance reporting
4. HEALTH AND
In respect to preparing people for the world
of work, we believe it is essential that those entering the workplace
for the first time, returning after a long-term absence, or embarking
on a change of occupation, be given adequate health and safety
awareness training before entering the workplace. IOSH emphasised
the importance of this and discussed it in more detail in our
response to the government's consultation on its White Paper,
21st Century Skills: Realising our potential (2003), please see
229 The Institute of Occupational Medicine report
Survey of Use of Occupational Health Support (RR44512002) commissioned
for the HSE. Back
POOSH = Professional Organisations in Occupational Safety and
Health, UK; ENSHPO = European Network of Safety and Health Practitioner
Organisations; INSHPO = International Network of Safety and Health
Practitioner Organisations. Back