Memorandum submitted by NHS Plus
Thank you for the opportunity to submit evidence
to the inquiry. The key points we wish to submit in respect of
Occupational Health are:
1. The controlling legislation is the Health
and Safety at Work, etc. Act 1974. The Act refers to responsibilities
relating to "health, safety and . . ..", not "health
& safety and . . ..". It was clearly envisaged from the
start that health and safety are two separate matters.
2. Safety performance over the last 30+ years
has been excellent. It is based on a risk management approach
involving hazard identification, risk assessment, design of controls
and monitoring the outcome, making changes where necessary.
3. This paradigm works well with safety issues
and indeed may work for some, though not all, diseases caused
by simple exposures at work. It is less effective in the health
setting (as compared with the safety setting) as the feedback
for failure is not immediate and indeed be very long term (eg
asbestos related disease).
4. Traditional occupational diseases, where
the disease was caused by an exposure at work, fit the medical
model well. More recently, we have seen occupational illnesses
where there is not necessarily the same direct linear model and
the symptoms caused may reflect complex interactions between the
individual and their workplace do not fit this model. Certainly
our understanding of the complexities has grown extensively in
the last decade or so.
5. There is increasing recognition that the
bio psycho-social model is required to understand the causations
and produce effective solutions. The safety paradigm does not
6. The issues of health and of safety in
the workplace need very different solutions.
7. NHS Plus is concerned with occupational
health, that is to say the two way relationship between work and
health. We do not see improving health at work as being a direct,
legislationguidanceenforcement matter. Legislation
has a place in setting out employer's duties, but this is really
a scene setting exercise rather than the main action.
8. Banning smoking (exposure to a carcinogen)
in the workplace has been an important move; it is not suggested
that this will of itself stop people smoking but it is an important
9. It has sometimes been difficult for HSE
to focus on the two separate approaches ie safety and occupational
health. As safety failures give rise to immediate consequences,
often of dramatic proportions, it is not surprising that this
has been the main focus of the HSE. We feel that the development
of occupational health has been inhibited as a result.
10. For the future, a different approach
is required. We believe that a health focused body, perhaps as
a part of health service structures, working in partnership with
HSE would produce the best outcome.
15 February 2008