Memorandum submitted by the Police Federation
of England and Wales
The Police Federation of England
and Wales represents the interests of 140,000 police officers
from Constables to Chief Inspectors.
The HSC Consultative Document
on the proposed new Executive suggested that the governing body
should have scope to increase in size from nine to 11 members.
The Police Federation proposed
that one of the additional places could be filled by a member
representing the emergency services.
The 2007 DWP Consultation Document
on the HSC/HSE merger proposed that four places on the governing
Board should reflect such interests as the Welsh and Scottish
Ministers or other appropriate organisations.
The Police Federation expresses
its disappointment that this proposal appears to have lessened
the opportunity for the emergency services to be represented on
the new governing Board.
The Police Federation of England and Wales is
a staff association which represents 140,000 police officers ranging
from Constables to Chief Inspectors. We were set up by Act of
Parliament in 1919 to look after the welfare and efficiency of
We welcome the opportunity to contribute to
the Select Committee's Inquiry into the Health and Safety Commission
and Executive. Our submission deals with our concerns about the
published proposals for the membership of the governing Board
of the proposed new Health and Safety Executive, and in particular
our strong support for the appointment of an emergency services
The Health and Safety Commission Consultative
Document A Stronger Voice for Health and Safety CD210 set
out the Commission's proposals for the merger of the Commission
and the Executive into a single body. The conclusion reached in
paragraph 63 of the CD was that "We envisage a body of a
similar size to the current Commission, but with the scope to
increase in size from nine to 11 independent members in addition
to the Chair should the need arise".
Overall, we supported the proposals in the CD,
but expressed our concern that, while the present Commissioners
"reflect the interests of their broader stakeholder constituences"
in the words of paragraph 16 of CD210, there is no member who
can claim to represent the emergency services, nor is there an
Industry Advisory Committee (IAC) covering that area of employment.
The police and fire services in particular are high risk occupations
and we invited the Commission to consider whether the interests
of the many thousands of employees concerned would be better served
by an additional IAC and/or a dedicated member on the proposed
new governing body of the merged Health and Safety Executive.
Subsequently, the August 2007 DWP Consultation
Document The Merger of the Health and Safety Commission and the
Health and Safety Executive contained proposals in Chapter 3 for
the membership of the governing Board of the new Executive. In
addition to the members appointed after consultation with organisations
representing employers, employees and local authorities (seven
in all), there is a proposal in paragraph 3.21 for up to four
other members to be appointed "to reflect such interests
as the Welsh and Scottish Ministers or other appropriate organisations,
including professional bodies." This appears to reduce the
possibility that some of those additional appointments could be
nominees from employers' and employees' representative bodies.
We had hoped that one of the additional seats
on the new Board could be filled by an emergency services representative,
but now, sadly, this latest proposal appears to make that less
likely, and we have expressed our concern in our response to DWP.
As we understand it, health and safety is not a devolved matter
for either the Welsh or Scottish administrations, and we question
whether it is appropriate that such political interests should
be represented on this non-political body. Instead, we suggest
that the opportunity be taken to provide for additional suitable
representation from employers' and employees' organisations.