Select Committee on Work and Pensions Written Evidence

Memorandum submitted by the Royal Society for the Prevention of Accidents (RoSPA)

  RoSPA welcomes the opportunity to make a short submission in advance of the Committee's one-off evidence session looking at the work of the Health and Safety Commission and Executive. Some key points we want to make are as follows.

  HSE is a key national resource and a vital H&S leadership body. Government has a responsibility to safeguard its future. Our perception is that, whatever criticisms they might have of particular aspects of HSE's activities, all the major organisations involved in the promotion and delivery of better H&S in the UK share this view.

  HSE is an exemplary regulator whose practices many other government bodies are advised to follow.

  It is a unique repository of hazard knowledge and H&S expertise. We are concerned at a major loss of expertise and corporate memory in HSE due to retirement, re-organisations and downsizing (over 500 posts have been lost in the past five years).

  We are particularly concerned at the further loss of experienced staff that is likely to result from the move of HSE's headquarters from Rose Court in London to Bootle. Notwithstanding the purely financial arguments that can be made in favour of the move, these should not be allowed to override the very practical reasons why a national leadership organisation such a HSE needs to retain a very significant London presence.

  HSE's resources are in a critical condition. Over the last five years in particular HSE resources have been squeezed. We hear that a further 15-16% cut is mooted over the life of the current Comprehensive Spending Review. This is extremely worrying. Already there are insufficient resources for regular proactive enforcement. HSE is becoming overwhelmingly reactive but even so, the number of major injury and other events which HSE would have investigated (in line with its operational criteria) is continuing to fall. This resulting in a widening gap both in terms of safety learning and justice.

  At the same time HSE continues to be unfairly attacked in many parts of the media as allegedly bureaucratic, incompetent, over-bearing and authoritarian. There seems almost to be a conspiracy against HSE in particular (and occupational H&S in general). HSE rebuts these allegations very professionally but they keep coming. We find this stream of innuendo and scepticism about HSE's role extremely worrying—sinister even.

  HSE has many major tasks to do, not just to regulate in a formal sense but to help develop all those other vital elements in the UK H&S system which actually help ensure the delivery of safe and healthy working in all workplaces in the UK. HSE in this sense is a prime mover, but in practice delivery of its targets depends on many other players. HSE needs sufficient resources to work effectively with those players to ensure the delivery of results.

For example

  HSE has been tasked to help lead the Government's plans for health and work and the reduction of sickness absence generally. They can only do this by working with other bodies that share in this key agenda. But at the same time the number of occupational health specialists has been drastically reduced. There are now only seven full time occupational physicians working in HSE as medical inspectors and 25 occupational health nurses working as medical inspectors.

  HSE has a major task to help bring H&S standards in small firms up to the level now enjoyed by workers in most larger concerns which have in-house H&S support. It needs to be working with clients, contractors and other players in the market to rationalise and simplify H&S pre-qualification schemes (where RoSPA is currently doing research) and contractor personnel passport schemes. There is massive "win/win" potential here—to both cut "third party red tape" and improve H&S outreach to hundreds of thousands of SMEs.

  Similarly HSE needs to be looking closely at bodies providing H&S training, auditing and certification, to check on standards, effectiveness and whether key themes are being covered. It is mistaken in our view to assume that these vital inputs to better H&S will be delivered automatically by the market without HSE support and guidance.

  HSE has a massive role to play in promoting safety and risk education not just in schools and colleges but in vocational training and above all, in businesses schools. Future business leaders need to understand H&S risk management. HSE resources devoted to this vital agenda have been cut back.

  RoSPA has continued to press the view (shared by colleagues in HSE and in business and the trades unions) that here needs to be a much greater focus on raising awareness of the key role of directors and on facilitating business to business learning, for example from and between higher performers in H&S. HSE needs more resources to help improve the capability of other players such as trade associations, colleges, safety groups, trades unions etc who together have a massive role in the delivery of better H&S performance for the UK. There is a real need, for example, to develop better interactive E based systems for business to business learning from accidents and incidents. All this requires major outreach effort by HSE, including mobilising others outside who can deliver key messages.

  As a key part of this HSE needs to continue to promote H&S as a key aspect of business performance, requiring companies to have clear targets, evidence of H&S management system status (including policies, leadership, workforce involvement, access to advice and services etc) and accessible reporting on performance. This too requires resources, particularly in the area of communications.

  Much more targeted enforcement is needed but there also need to be more creative approaches to alternative penalties and remedies. But this means HSE needs the time to diagnose underlying causes of accidents and develop systematic remedies rather than just reacting to accidents and incidents.

  HSE needs to be able to develop much better data and intelligence not just on accidents and incidents or on ill health but on hazardous exposures, on efficacy of solutions and so on.

  HSE has a key role to play in more joined up working with other key safety agendas, not just safety and risk education and the whole health, and work and well-being agenda, but in prevention of falls of older people, managing work related road safety, promoting accident prevention outside work, creating safer communities projects and so on.

  Looking beyond the UK, as an immensely well respected organisation internationally, HSE has a key role to play in sharing its expertise and knowledge as part of worldwide efforts to raise standards, particularly in emerging economies where accident and disease rates are quite horrendous. RoSPA continues to press for the Government to make H&S a much stronger part of the sustainable development agenda, especially given the UK's world lead in the area.

  The Government cannot afford not to invest properly in H&S. It is a mistake to think that improved H&S performance has rendered HSE less relevant. Some of the stark facts are:

    —    not just 241 notified fatal injuries to workers in 2006-07, but

    —    over 100 plus members of the public killed in connection with undertakings,

    —    1,000 fatal work-related road injuries (involving workers and the public),

    —    328,000 reportable injuries (according to Labour Force Survey 2006-07),

    —    perhaps as many as 12,000 to 24,000 deaths due to work related health damage, particularly occupational cancer,

    —    one million work related injuries (all severities),

    —    two million cases of work related ill health (mainly musculo-skeletal disorders and stress) which in total result in:

    —    36 million working days lost (30 million due to ill health and six million for accidents); and

    —    £20-30 billion or between 2-3% of GDP!

  The danger is that HSE will become unsustainably stretched in delivering its core functions such as those around nuclear, offshore and major hazards safety and that its capacity to seize fresh opportunities to further meet the evolving needs of our workforce, the public and the economy in general will be severely compromised.

November 2007

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