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
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 worryingsinister 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.
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
hereto 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
one million work related injuries
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);
£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