Select Committee on Work and Pensions Written Evidence

Memorandum submitted by Prospect


  1.  Prospect represents 102,000 scientific, technical, management and specialist staff in the civil service, and major utility companies. Our membership includes professionals in a number of regulators including HSE.

  2.  We welcome the opportunity to comment before the one-off evidence session looking at the work of the Health and Safety Commission and Executive: We believe that given the combination of tighter funding and increased accident rates the Select Committee should consider holding a wider-ranging inquiry to consider what type of health and safety regulation is in the public interest and how it should be funded.

  3.  This submission should be taken along with the submissions from other trade unions and in particular with reference to the submission from the other unions representing members working for HSE. Our submission focuses on what we believe to be a pressing need to secure medium-term investment in the HSE to reduce work-related health and safety risks that reduces the costs to the economy of industrial injury and disease and decreases the number of individuals who suffer due to poor health and safety: currently public policy seems to be working in the opposite direction by cutting investment. Thus the submission reflects the impact on public health and safety of current and potential cuts in each of the seven key areas of the inquiry:

    —    Performance;

    —    Resources;

    —    Occupational health;

    —    Governance;

    —    Public and ministerial expectations;

    —    Enforcement and Inspection; and

    —    Construction.


  4.  We believe that progress has been made in recent years to reduce the risk of industrial injury and illness: however the targets set in Revitalising Health and Safety will not be met due to a shortage of resources. Not only does this cost the taxpayer more through lost production, insurance costs, benefit claims, increased NHS spending, but also there is the distress to victims and their families. Therefore the question is not to explain the underperformance of the HSE that is largely due to a lack of funding but to assess the most effective way of improving future performance.

  5.  We also believe there to be a large gearing effect, with small amounts spent on increasing enforcement having a large impact on health and safety behaviours amongst employers. Poor health and safety costs the economy billions of pounds (between £20-30 billion), so investing just small amounts in regulation would have significant financial benefits as well as being morally justified. Effective management of health and safety achieves benefits for the employers of all Prospect members; eg in electricity improved safety performance has improved productivity.


  6.  Since 2002 the HSE's funding has been squeezed at the same time as concern over health and safety has increased: as a consequence staff numbers have dropped by about 1,000 from 4,200 to under 3,200. Even if we factor in the transfer of railway inspectorate staff this indicates that over 500 jobs have been lost. The majority of these posts have been lost in the past 18 months so the impact of job cuts has yet to work through to performance.

  7.  Given the HSE's inability to meet its current targets, we would query the value of a further 15-16% cut in funding over the life of the Comprehensive Spending Review that could lead to the loss of a further 500 posts. Even with some of the initiatives set out in the How and Where We Work programme, we are sceptical about the anticipated efficiency gains when the organisation is already over-stretched. In particular, the HSE will lose significant policy knowledge as policy work is moved out of London as most experienced policy staff are unable to follow the work to Bootle.


  8.  Occupational health is major priority for Government employers and unions as ill health is responsible for 10 times as much absence as injury. However, the funding for the HSE's provision of occupational health advice has fallen dramatically over the past 15 years. Without adequate funding the HSE can not provide an adequate service, far from growing its expertise, the very existence of the Employment Medical Advisory Service is under threat. This service has dropped from 120 staff in the early 90s (half doctors and half nurses) to the equivalent of seven full time doctors working as medical inspectors and 25 occupational health inspectors. At these levels the HSE is simply under-resourced to drive forward occupational health and provide leadership to employers and unions.

  9.  There has been no explicit decision to downgrade occupational health: the rundown is simply due to a lack of resources. Indeed both the DWP and the Select Committee have emphasised the importance of occupational health. Employers of Prospect members also recognise its contribution.

  10.  A fully funded and restored Employment Medical Advisory Service, would be effective in providing incentives to employers to make occupational health provision and would provide the necessary advice to employers, as parliament originally intended under the Health and Safety at Work Act. The Fourth Report of the Select Committee on Work and Pensions in 2004 specifically drew attention to reduced funding for EMAS as this had considerably reduced the capacity of the HSE to provide advice on occupational health.

  11.  General Health and Safety Inspectors, cannot replace medical and occupational health inspectors. Without these vital preventive work on occupational disease is neglected. Recent figures show that there could be 16,000 deaths a year from occupationally related cancer: However, the HSE has not have sufficient funds to perform much preventive work in this area. Prevention should be the focus of our efforts rather than rehabilitation not least considering studies have shown that much of the effort on rehabilitation is misplaced.


  12.  Whilst we recognise the arguments for the merger of the HSE and HSC, we believe that the future of the HSE relies on good quality partnership between employers and unions as well as a higher regard for the professional expertise of HSE staff. The key decisions about health and safety require professional judgments over a range of options and therefore we believe that the DWP should set realistic targets and provide adequate funding but allow the HSE and its external stakeholders to use their experience to devise an effective strategy to meet the explicit goals of public policy.


  13.  The strongest evidence on producing effective changes in health and safety behaviour supports enforcement interventions over other interventions. Prospect argues that we should be increasing inspector numbers to secure greater improvements in health and safety to the mutual benefit of both employers and employees.

  14.  Research shows small and medium enterprises to be more reactive organisations: with a greater reliance on external interventions to ensure compliance. SMEs are more likely to value inspector enforcement and guidance than introduce a complicated assessment system. Most such employers rely on inspection to determine whether they comply; reducing inspection and relying on employer assessment of often-complex guidance creates a further burden in small businesses.

  15.  Prospect is aware that prosecutions, justifiable under the enforcement policy statement are not being taken simply because there are not the resources to do so. HSC has set Incident Selection Criteria to determine those reported accidents it believes should be investigated. The number of these HSE failed to investigate due to lack of resources has increased in recent years (188 in 2004-05, 255 in 2005-06 and 307 in 2006-07). Whilst we place a high value on the professional judgment of our members, we do not believe that this should be unduly skewed by the lack of staff.


  16.  Britain's international reputation is threatened if the 2012 Olympics build causes any deaths. There are only 15 inspectors in London to cover all construction work in the capital. Given that workload, it is hard to see how the Olympics build can be adequately regulated which we fear could lead to corners being cut on safety. We should aim for a zero deaths Olympics. This is an example of the need for higher standards in construction.

  17.  The Secretary of State has rightly taken a strong line on construction safety, and has said that the number of health and safety inspectors in construction should be maintained. We agree. However, if this is to be done additional funding will be required.


  18.  Despite some misconceptions and adverse media reporting HSE consistently achieves high levels of public, business and trade union trust as a regulator. The Hampton report has recommended that HSE increase the scope of its activities by including some smaller regulators, HSE was the body specifically called in to investigate Purbright and the Ministerial Task Force used HSE to progress work on managing sickness absence and work related stress in the public sector. The apparent increase in demand on HSE's resources and the removal of key policy links from London at a time when those very resources are being cut appears perverse.


November 2007

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2008
Prepared 21 April 2008