Select Committee on Work and Pensions Written Evidence

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 work.

    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, legislation—guidance—enforcement 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 adjunct.

    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

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