Select Committee on Work and Pensions Written Evidence

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.


  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 months.

  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, including Whitehall.

  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.

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