Select Committee on Work and Pensions Written Evidence

Memorandum submitted by Industrial Health Control Ltd


    —    This DWP consultation period (4 Dec 2007-7 Jan 2008, including the Christmas/New Year break) is too short to obtain representative responses, and overlaps with a concurrent consultation by BERR.

    —    The cutbacks in HSE resource have almost certainly had an adverse effect on H&S performance.

    —    In the chemicals industry, HSE needs more expertise in ordert to reduce ill health from exposure to chemicals.

    —    To meet its occupational health PSA targets, HSE should increase its occupational hygiene expertise among its inspectors.

  1.  We are a Health and Safety consultancy, specialising in occupational hygiene, and providing advice to a wide spectrum of organisations.

  2.  This DWP consultation period (4 December 2007--7 January 2008, including the Christmas/New Year break) is too short to obtain representative responses, and overlaps with a concurrent consultation by BERR (Department for Business, Enterprise and Regulatory Reform) which is running from 27 November 2007—31 January 2008. This gives the impression that one government department is unaware of what another one is doing. The BERR consultation is likely to be more effective purely because its aims are set out more clearly in the consultation document, and more time has been allowed for a considered response.

  We have restricted ourselves to a few points in this DWP consultation.

3.   Resources: Does the HSE have sufficient resources to fulfil its objectives as the health and safety regulator and meet its PSA targets? Inspection, enforcement and prosecutions: What impact has the reduction in inspection rates had on standards of occupational health and safety? Does HSE get the balance right between prevention and enforcement?

  With the shift over recent years to an emphasis on risk assessments rather than clear, detailed standards, there is much anecdotal evidence that many SMEs now wait for enforcement officers to tell them what they need to do rather than try an identify potential H&S improvements. The reduction in inspection rates means that they are less likely than before ever to be visited. These two factors are leading to a reduction in standards of occupational health and safety.

4.   Is HSE doing enough to maintain health and safety standards in the chemicals industry?

  If one looks at the figures, there are far more cases of occupational ill health, including ones with a fatal outcome, than there are occupational accidents. Occupational ill health causes greater losses to industry and commerce. In order to tackle this, HSE needs to shift its expertise towards the prevention of ill health, by increasing its expertise in occupational hygiene rather than purely safety, including within its work in the chemical industry.

5.   Occupational Health: What must HSE do to meet its PSA targets for ill health and days lost per worker?

  Firstly, more accurate figures on the incidence and prevalence of occupational ill health need to be collected, in order to accurately monitor any changes.

  In order to reduce occupational ill health, HSE should aim that at least 50% of its inspectors obtain a working knowledge and/or qualifications in occupational hygiene in order to be able to recognise working conditions that are likely to give rise to ill health. This compares with the current situation of only 1-2 inspectors within each HSE region with the appropriate expertise in the subject.

Industrial Health Control Ltd

January 2008

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