Further memorandum submitted by PCS
1. The Public and Commercial Service Union
(PCS) is the largest civil service trade union, with a total membership
of 325,000 working in over 200 civil service departments, non-departmental
public bodies and related areas. We currently represent over 1,000
members who are employed by the Health and Safety Executive (HSE).
2. Our previous submission (January 2008)
drew attention to the proposed removal of 270 policy, legal and
support staff from Rose Court in London. In that submission we
estimated that 10% of staff would be prepared to move. We now
know that even this low number was an over estimate. As a result
of an initial preference exercise held in February, the number
of people prepared to move out of London is likely to be about
12. HSE's business case originally projected that 40% (108) would
be prepared to move.
3. This submission argues that this will
seriously undermine the HSE and its ability to fulfil business
objectives. We argue that this over estimate in the numbers of
staff prepared to move reveals fundamental problems with the whole
exercise, its management and the financial assumptions about the
level of efficiency savings made in the original business case.
Staff are not on side. The loss of expertise will take many years
to make up at a time of rising fatalities, accidents and ill-health.
PCS says it is time to think again.
HSE RELIES ON
4. Time and again HSE staff are recognised
for the invaluable advice, guidance and intimate knowledge of
health and safety they provide. Their personal commitment to working
with employers and workers and those that represent them have
been demonstrated over many years of service. Over time they have
built an excellent reputation and close working relationships
with all those individuals and institutions influencing the health
and safety of Great Britain. They are flexible and open-minded
in finding new ways to engage to develop new policy tools and
levers that ultimately make HSE the modern, world recognised and
relevant organisation that it is today.
5. Of course a critical role for policy,
legal and support staff is to support HSE's enforcement regime.
As Prospect said in its submission to the committee "evidence
from the HSE and elsewhere shows that enforcement remains the
most effective form of intervention for reducing accident rate".
PCS also affirms that policy, legal and support staff deliver
improvements to health and safety in their own right.
6. Successful inspection of employers by
inspectors relies on specialist policy, legal and scientific support.
In particular we note the critical role of HSE lawyers who provide
essential specialist legal advice on complex issues and who, for
the most part, will not transfer out of London. It is only in
the combination of the professional judgement of experienced HSE
staff, managers with responsibility for health and safety and
employees that inspections work.
7. Staff in Rose Court are also providing
advice and making improvements to health and safety in their own
right. Senior managers rely on experienced staff to provide the
best evidence to make the right decisions that have maximum impact
with the limited resources they have at their disposal (PCS has
already submitted its views on the inadequacy of current funding).
HSE's policy, legal and support staff are constantly engaged in
discussions with stakeholders and analysing material to develop
such evidence. The success of HSE's staff, notwithstanding years
of under-funding, is based on these core policy skills magnified
by years of experience.
8. Policy staff are also delivering improvements
through policy tools they have developed; be they stress management
standards, levering worker involvement and Workplace Health Support.
Such innovative approaches have together been key to achieving
HSE's business objectives. They require close and constant relationship
building with other Government Departments, project and financial
management skills, technical knowledge and deep understanding
of the political environment.
9. The European Union is an important source
of HSE's legislative framework. It is key that HSE has the expertise
and relationships to enable the UK to best shape EU Health and
safety legislation. This requires HSE to retain sufficiently skilled
and experienced policy and legal experts.
10. Clearly then, attempting to move such
a large number of experienced staff from their workplace and homes
where ever they are based must be justified by a water-tight and
compelling business case. Any business case needed to analyse
as a whole the impact on people, business and finances of a single
HQ. This was not done. HSE published its business case on 27 June
2007 and only concentrated on the impact on HSE's finances. Even
this argument was weak: PCS believes that the difference in financial
terms between the proposed "dual HQ" and "single
HQ" options amounts to only a few hundred thousand each year
out of a total annual budget of £235 million.
11. The business case is fatally undermined
by its assumption that 40% of staff would move. In fact staff
have indicated that only 12 are prepared to go. The rest will
leave HSE, representing the loss of hundreds of years of experience.
This is a difference of such an order of magnitude that we question
the validity of the business case at all. We argue that the business
case used a projection of 40% to justify a decision to move that
was already taken. In fact HSE have stated that 40% was used with
no sound basis or evidence to support it.
12. Recruiting and sharing knowledge between
new and experienced staff in a short period of time now looks
highly unlikely. Experienced staff are leaving now, and will not
be around to train the 19 new recruits due to start soon, let
alone the many more that will need to be recruited in the coming
13. In this context we note with concern
that the business case did not present a "Do Minimum"
option, contra to Cabinet Office guidance in the Green Book. The
initial preference exercise has exposed the poor quality of judgement
by those who are supposed to have a good grasp on HSE and its
future, and, for those at the top of the organisation, in the
main will not be relocating themselves.
14. Such a loss surely can only have a negative
impact on the health and safety of Great Britain. This is of real
concern at a time when the number of workers fatally injured has
risen by 11% (30 more workers killed at work in 2006-07); when
we are not on track to meet ill health or days lost PSA targets
or when the level of HSE's enforcement and prosecution actions
has been dwindling.
15. To lose experienced staff who are levering
improvements through the whole health and safety system, who have
such close links to Local Authorities, OGD's, the EU, employers
and workers, is bound to have a detrimental impact. In our view
negative consequences will range from poorer advice and deficient
analysis over the next few years, making for weaker evidence to
base decisions on, a health agenda left stranded that will undermine
delivery of already challenging targets, and a loss of political
influence over opinion leaders and significant decision makers,
16. HSE has just concluded a recruitment
exercise in Bootle for "Policy and Delivery Managers",
as part of the attempt to build capacity. It yielded 19 successful
candidates from 273 applicants. On this basis it will take another
15 similar exercises to replace the number of staff leaving HSE.
Even with three such exercises a year, with a staff turnover of
only 10%, it will take six years to re-build Policy Group, just
in numerical terms.
17. PCS propose that HSE think again about
the move. The importance of experience cannot be over stated and
any initiative to put their position at risk must be absolutely
compelling. We understand that plans for building capacity in
the North West are in progress and have no doubt that they will
be fulfilled in time. If staff from London HQ had been prepared
to move then the risks to the future of HSE would have been minimised.
However, with such a negative response from HSE's experienced
London HQ based staff, the current timetable for the move is in
our opinion unrealistic.
18. PCS call upon HSE's senior managers
to review the business case and assess fully the impact of losing
wholesale such experienced staff on HSE's ability to meet its
business objectives. Assumptions in the business case have shown
themselves to be so inaccurate we call into question the judgements
made not only about the preferences of staff, but also its estimation
of the costs, savings, likely business benefits and improved ways
of working. For HSE not to pause and think again shows that this
is just a money saving exercise that puts workers lives across
GB at greater risk.