Select Committee on Work and Pensions Written Evidence


Memorandum submitted by Hazel Hartley

1.0  EXECUTIVE SUMMARY

  This submission will argue that:

    —  The inclusion of core actions on legal duties in the IOD/HSE (2007) Guidance on Leading Health and Safety at Work is logically incompatible with classifying this document as merely voluntary guidance.

    —  The IOD/HSE (2007) Guidance should be placed on a statutory basis or at least be classified as an Approved Code of Practice formally linked to the HSWA 1974 and the Management of Health and Safety Regulations 1999.

    —  There is an urgent need to clarify the criteria, evidence and timescale to be used for keeping the 2007 Guidance "under review".

    —  The HSE (2004) Management Standards for Work-Related Stress are excellent. Furthermore, they so accurately reflect so many of the key organisational features which lead to deaths at work and major disasters that they are perfect as THE organisational performance toolkit to accompany the IOD/HSE (2007) guidance above.

    —  Work-Related Stress (WRS) is a "creeping" disaster itself. It is a significant occupational health issue in the UK. The factors which lead to WRS are also the factors which can increase accidents and systems failures.

    —  The HSE 2004 Management Standards on WRS and the IOD/HSE 2007 Guidance on Leading Health and Safety at Work have captured these key organisational factors which cause death so well. This means that both documents used together, could become invaluable tools in future investigations and prosecutions under the Corporate Manslaughter and Corporate Homicide Act 2008. (If an organisation fails to implement them or improve their targets, HSE inspectors can always use the organisational performance toolkit and apply the questionnaire to employees as part of their investigation and evidence).

    —  There should be some evaluation of the national statistics on investigations and prosecutions into breaches of health and safety under the HSWA 1974 and the Management of Health and Safety Regulations which have used or referred to the HSE 2004 Management Standards on Work-Related Stress.

    —  If the organisational factors which impact on WRS and other occupational health matters are not addressed, then the targets for rehabilitating employees back into the workplace after sickness absence are unlikely to be met, as the same damaging factors will be present when they return to work.

    —  That the Government might consider allocating additional resources to investigating and prosecuting deaths at work as well as the dissemination, education and support necessary to place the HSE 2004 Management Standards on WRS at the heart of the prevention programme used alongside the IOD/HSE 2007 Guidance.

    —  The more recent changes to the Corporate Manslaughter and Corporate Homicide Act 2008, as now drafted, have the potential to make a difference in the attitudes and practices of businesses and organisations to occupational health and safety, particularly in the areas of the senior management test, the use of health and safety guidance, attitudes, tolerance, and accepted practices in the "gross breach" test.

2.0  PROFILE OF THE SUBMITTER: A BRIEF INTRODUCTION

  Dr. Hazel Hartley is a Principal Lecturer and has been working in the area of sport, law and ethics for 27 years. Her areas of research over the last 17 years include concepts and contexts of disasters in the UK, predispositions to disasters, corporate manslaughter, health and safety duties, civil cases in stress and nervous shock, public inquiries and coroner's inquests. Her doctoral thesis in the Dept. of Law and Criminology at the University of Lancaster, on the socio-legal aspects of the 1989 Hillsborough and Marchioness Disasters in sport and leisure, made 60 recommendations for legal and policy reform and contributed to:

    —  Law Commission Consultation Paper on Involuntary Manslaughter 1995

    —  Home Office 2000 Reforming the Law on Involuntary Manslaughter

    —  Verbal and written evidence to LJ Clarke on the case for a public inquiry into the 1989 Marchioness Disaster

    —  HSE 2000 consultation on the health and safety duties of directors 2000-01

    —  ESRC funded International Seminar series and residentials for international working group on Disasters (UK, Norway, Canada) 2000-02

    —  House of Commons Home Affairs and Work and Pensions Joint Select Committee : Draft Corporate Manslaughter Bill 2005.

  Hazel teaches undergraduates and postgraduates topics such as negligence, natural justice principles and sport disciplinaries, strict liability, doping rules and human rights, socio-legal aspects of violence, masculinity and criminal assault on the sports field. In recent years she worked as a national subject specialist in sport and law for the Higher Education Academy, Hospitality, Sport, Leisure and Tourism, subject network. She also worked in major event management in international gymnastics for many years after competing in trampolining for several years. Hazel was Vice-President of the Union of European Gymnastics General Gymnastics Technical Commission in the early 1990s and teaches risk and event management in sport and leisure.

    —  Member Advisory Board International Sport Law Journal. The Asser Institute, The Hague, Netherlands.

    —  Member Editorial Board, Sport and the Law Journal, London.

    —  Respondent to Law Commission Consultation Paper on Consent and the Criminal Law 1995.

    —  International Master Class presentations International LLM in Sport and Law (Griffith University Law School, Brisbane; International Sport Law Centre, The Hague, Anglia Polytechnic University, England).

  Hartley, H J (2001) Exploring Sport and Leisure Disasters: a socio-legal perspective London: Cavendish.

3.0  MAIN SUBMISSION

3.1  Are director's health and safety duties appropriately covered by voluntary guidance?

  3.1.1  The IOD/HSE (2007) Leading Health and Safety at Work: Leadership Actions for Directors and Board Members launched on 29 October 2007, is certainly welcomed. As one of those individuals who provided feedback on the 2000 draft paper on Health and Safety Duties of Directors and the IOD/HSE 2007 voluntary guidance, I believe that the principles, core actions, good practice, case studies, checklist and key resources are all excellent.

  3.1.2  "Many high profile safety cases over the years have been rooted in failures of leadership. Health and safety law places duties on organisations and employers, and directors can be personally liable when these duties are breached: members of the board have both collective and individual responsibility for health and safety. By following this guidance, you will help your organisation find the best ways to lead and promote health and safety, and therefore meet its legal obligations" (emphasis added) (IOD/HSE 2007:1).

  3.1.3  Located clearly in the core actions which refer to legal obligations are some very significant standards which are like a breath of fresh air, as they go to the heart of the matter in terms of some of the senior management errors which often feature in public in inquiries and research into major (sudden) UK disasters. Such inquiries have included details of organisational culture, workplace practices, the accumulation of risk over many years and management of change whose pace and planning played a significant role in the broader context of causing death. This can apply equally to "creeping" disasters such as injuries, deaths or occupational health issues or work-related stress, as it does to "sudden" major disasters. These include:

    The Board should consider the health and safety implications of introducing new processes, new working practices or new personnel, dedicating adequate resources to the task and seeking advice where necessary (IOD/HSE 2007:4).

    Boardroom decisions must be made in the context of the organisation's health and safety policy; it is important to design-in health and safety when implementing change (IOD/HSE 2007:4).

    The health and safety policy is a "living" document and it should evolve over the time eg in the light of major organisational changes such as restructuring or significant acquisition (IOD/HSE 2007:3).

  3.1.4  "Health and safety is integral to success. Board members who do not show leadership in this area are failing in their duty as directors and their moral duty, and are damaging the organisation" (IOD/HSE 2007 inside page of front cover).

  "Core actions for boards and individual board members that relate directly to the legal duties of an organisation. These actions are intended to set a standard" (IOD/HSE 2007:2).

  3.1.5  At the launch event at the Institute of Directors in London on 29 October 2007:

    The starting point for any Board of Directors is effective corporate governance- central to that corporate governance is the leadership on health and safety. Effective control of business risks is linked with effective leadership in health and safety risks ie the health and safety risks of the workforce . . . failure to address health and safety can cause significant damage to the workforce, as well as serious damage to the reputation of the corporation or organisation.

    (Lord Mckenzie, Minister for Health and Safety, presentation at the launch on 29 October 2007)

    Health and safety is a key area of Directors Duties. Directors, Board of Directors set the tone and set the scene for everyone, be engaging with employees, including listening to the concerns of employees (Lord Mckenzie, 29 October 2007).

  3.1.6  Lord Mckenzie emphasised that the core actions on the left hand side of the page "referred to present legal duties of directors". In addition, although the HSC could "not recommend at this point in time, a move to introducing legal health and safety duties for directors, the HSC is keeping this under review" (Lord McKenzie, 29 October 2007).

  Judith Hackitt OBE Chair of HSC informed the audience at the launch that:

    This is not an Approved Code of Practice in the formal sense of the word but is does have legal standing in the sense that it will be used as a Benchmark standard in relation to relevant statutory duties, by HSE inspectors in their inspection visits.

    (Judith Hackitt, OBE, presenting as a panel member at the launch of the IOD/HSE guidance 29 October 2007).

  3.1.7  Alongside Lord McKenzie's comment that the HSC is keeping this under review, Judith Hackitt observed "we may need to look to further clarify then role of directors duties". This may be over the next two or three years. When questions were posed from the floor at the launch event, as to the criteria which would be used for keeping this matter under review or the organisational performance criteria, no answers to such questions were forthcoming at the time of the launch. I do not have any issues with the content of the IOD/HSE 2007 "voluntary guidance". It could be argued, however that the IOD/HSE themselves have perhaps inadvertently, presented a logical argument for the guidance to be put on a statutory basis, or at the very least, be classified as an Approved Code of Practice formally linked to the Health and Safety at Work Act 1974, the Management of Health and Safety Regulations 1999.

  3.1.8  Are the following two statements A and B logically incompatible?

    A.  The core actions throughout this document relate directly to (present) health and safety legal duties of individuals and boards. The five point summary of legal responsibilities of employers on page 2 of the IOD/HSE (2007) document relate to health and safety law and uses the term must. (Presumably they relate to statutory duties under the 1974 Health and Safety at Work Act 1974, the Management of Health and Safety Regulations 1999). This document is the benchmark/standards which will be used by HSE inspectors (presumably when they are investigating statutory breaches of the health and safety, as well as individual and corporate manslaughter).

    B.  The IOD/HSE 2007 document Leading Health and Safety at Work does not have a statutory basis. It is not even an Approved Code of Practice (ACOP). It is merely voluntary guidance.

  3.1.10  I would recommend that the Government consider:

    a.  Putting this guidance on a statutory basis, logically consistent with A above. Or

    b.  At the very least reclassifying the IOD/HSE 2007 voluntary guidance as an Approved Code of Practice, formally linked to relevant sections of the Health and Safety at Work Act 1974, The Management of Health and Safety Regulations 1999 (s.3), logically consistent with A above.Consistency and clarity regarding the status and application of the IOD/HSE 2007 guidance are also important in relation to the evaluation of any gross breach of duty under the Corporate Manslaughter and Corporate Homicide Bill 2007 to which this submission turns in section 3.2.

  3.1.12  In relation to the questions posed by the audience at the launch of the 2007 guidance:

    How and by what criteria might the IOD/HSE 2007 guidance be kept under review?

    How is the performance of organisations and in particular boards to be evaluated?

    At the very least, the core actions, the checklist, the health and safety checklist on page 8 and the health and safety checklist on the RoSPA website under key resources on the last page would be a good place to start on organisational performance.

  3.1.13  In addition, as I suggested to the panel at the launch event, the following would be very useful as an organisational performance toolkit to accompany the IOD/HSE 2007 guidance:

    The HSE 2004 Management Standards on Work-Related Stress, including the HSE Management Standards Indicator Tool, the HSE Management Standards Indicator Tool (organisational performance), and the HSE Management Standards Analysis Tool.[91]

  Why argue that the HSE 2004 Management Standards not only have a broader application but are suitable for use alongside the IOD/HSE 2007 guidance as an indicator of organisational performance at board or senior management level?

  3.1.14  The role of senior management failures, inter-agency risk assessment and organisational structures and cultures in major disasters and individual deaths at work is well documented (Bergman, 1991, 1997, 1999; Hartley 2001; Sheen J.1987; Taylor LJ 1990). Instead of focusing on the final "catalyst" of a disaster, it is useful to consider the interface between the vulnerability of organisational/corporate systems, their structural arrangements and cultures, long-term history of risk assessment and the final catalyst (for example the person who left the bow doors open on a cross-channel ferry or the train driver who fell asleep or passed a signal at danger).

  3.1.15  Common features of disasters and deaths at work in the UK include:

    —  Complicated structural arrangements-poor internal communications.

    —  Problems with the pace and management of change, particularly before during and after a major organisational restructuring or new work practices.

    —  Role ambiguity (lack of role clarity, often as a result of a restructuring process).

    —  Lack of support, training and resources relating to an individual moving into a new role.

    —  Inadequate thinking through to operational level and implications for vulnerable systems and health and safety roles.

    —  Unreasonable demands- conflicting tasks and working unreasonable hours and lack of sleep.

    —  Marginalisation or absence of unions or health and safety representatives and a lack of good practice in joint risk assessments by management and union health and safety representatives or poor management/union relations.

    —  Failure to listen to concerns/warnings of employees, union representatives, inspectors or members of the public.[92]

    —  An organisational culture of fear. Employees including managers subject to bullying, harassment, with inadequate systems in place to respond to such matters.

  3.1.17  There is a significant commonality between these features of disasters and deaths at work, the very relevant content of the IOD/HSE 2007 voluntary guidance and in particular, the HSE 2004 Management Standards on Work-related Stress. The HSE 2004 national Management Standards cover six key areas of work which, if not properly managed, are associated with ill-health, lower productivity, work-related stress and accidents. These are:

    —  Demands

    —  Control

    —  Support

    —  Relationships (conflict, bullying, harassment)

    —  Role (including clarity of role)

    —  Management of Change

  3.1.18  Like the core actions in the IOD/HSE 2007 voluntary guidance, these management standards are clearly linked to legal statutory duties:

    Under the health and safety at work Act 1974, employers have a general duty to ensure, as far as is reasonable practicable, the health and safety of their employees at work. This includes making sure they do not suffer stress-related illness as a result of their work (HSE 2007:12). The law requires that employers have duties to take measures to control that risk (HSE 2007:5).

    Regulation 3 of the Management of Health and Safety at Work Regulations 1999 requires employers to assess the risks to health and safety from the hazards of work. This includes the risk of employees developing stress-related illness because of their work. You are required to carry out a "suitable and sufficient risk assessment" (HSE 2007:12).

    If you follow this risk assessment and management process correctly, you will be adopting an approach that is considered suitable and sufficient (HSE 2007:13)

  3.1.19  As a researcher and lecturer in, among other things, the organisational predispositions to disasters, I was delighted to see the introduction of these excellent HSE Management Standards in 2004. As I pointed out at to the panel at the launch of the IOD/HSE voluntary guidance, intentionally or inadvertently, this policy document had clearly managed to embrace some of the key features of senior management failures leading to disasters. Such features are centrally addressed in some of core actions and good practice in the IOD/HSE voluntary guidance.

  3.1.20  The HSE reported stress-related absence at 13 million working days lost per year in the UK. This was the biggest cause of working days lost through occupational injury and ill-health (HSE 2004). Predispositions to disasters overlap with key institutional factors of work-related stress. These in turn can have a negative impact on increased accidents. In relation to sloppy, complicated "systems" of internal communications and roles, if an employee cannot answer the simple question of "who does what, when and how in relation to X?" under "normal" conditions, why would one expect that to suddenly improve if that organisation was faced with a major crisis or incident?

    HSE research in 2003 into offshore work found approximately 70% of common work-related stressors are also potential root causes of accidents when they were caused by human error[93] (HSE 2007:4).

  3.1.21  About one in seven people reported that they find their work either very or extremely stressful (Psychosocial working conditions in Britain 2007, cited HSE 2007:4). In addition, in 2005-06 just under half a million people in Great Britain reported experiencing work-related stress at a level they believed was making them ill (HSE 2007:4). The HSE's own contracted research reported that one in five (20%) of the UK workforce was experiencing bullying/harassment in the workplace in 2006. Civil law cases involving stress or nervous breakdowns which are work-related are small in number, but significant. A cluster of four cases in the Court of Appeal, in 1998, laid down some principles for the employers and the courts in such cases. More significantly, in the case of Daw v Intel Pentium CA March 2007, the CA held the employer liable for a nervous breakdown suffered by an employee, where relevant circumstances included an organisational restructuring, lack of role clarity, conflicting demands and lack of clarity in terms of line management. There have also been at least two cases of "work fatigue" fatalities. In one of those cases, in relation to "demands" an employer was fined £30,000 and ordered to pay £24,000 costs after one of its workers "died while driving home after a third consecutive shift of nearly 20 hours and it admitted two breaches of health and safety" (see R v Produce Connection, Cambridge Crown Court, June 2006, cited Hazards no p5, 2006 and www.hazards.org/youngworkers ). There have been coroners inquests into several suicides in the UK related to stress or bullying or harassment in the workplace, with the true toll in the UK estimated at 100 work-related suicides per year (see Hazards no 95, 2006:14).

  3.1.22  In the light of all of the above, I would want the Government and the HSE to consider the following questions and proposals:

    a.  Where are the national statistics on the organisational performance in relation to the HSE Management Standards on Work-Related stress, which were introduced in 2004? Does or should the data remain private? Which companies or organisations have actually used the management standards and the toolkit and analysis tool?

    b.  Have there been any prosecutions or convictions under relevant statutory duties (1974 Act and 1999 Act) which made use of or made reference to the HSE 2004 Management Standards on Work-related stress?

    c.  With the formal links between the HSE 2004 Management Standards on managing work-related stress and the statutory duties under the 1974 and 1999 Acts, should the HSE Management Standards be placed on a statutory footing? What is their status at present? Are they classified as an Approved Code of Practice, formally linked to the 1974 and 1999 Acts?

    d.  Would the Government consider using the HSE 2004 Management Standards organisational performance toolkit as THE organisational performance toolkit to be used alongside the IOD/HSE 2007 guidance Leading Health and Safety at Work?

  3.1.23  The HSE notes that the HSE 2004 Management Standards are about risk assessment and prevention. This select committee is asking the questions "What must the HSE do to reach its PSA targets for ill health and days lost per worker?" and "Does the HSE do enough to embed vocational rehabilitation in the workplace?" Dame Carol Black is leading a review of health issues in the workplace. Stress-related absences from work are often the longest periods away from the workplace for occupational health reasons. If the organisational factors which can adversely affect large numbers of employees are not addressed, then there is a high probability that the same risk factors will face an individual employee on his or her return to work after a work-related stress absence.

  3.1.24  Such organisational factors and board/senior management responsibilities are centrally located in both the IOD/HSE voluntary guidance 2007 and the HSE 2004 Management Standards for Managing work-related stress.

    e.  Would the Minister consider the allocation of additional resources to the area of the dissemination, education and support (of both employers and HSE Inspectors), monitoring and evaluation of the HSE 2004 Management Standards of work-related stress, alongside the area investigating deaths at work and monitoring of the Corporate Manslaughter and Corporate Homicide Bill after it becomes law in April 2008?

    f.  The HSE has contracted a wide range of research projects including work on Attention, awareness and Occupational Stress (R54.094), and Defining a Case of Work-related stress (R54.085), Managing Stress and Sickness Absence (JN3287) (see http://www.hseresearchprojects.com). How are these disseminated and how are national statistics on management of work-related stress fed into the employers' associations own targets?

3.2  What impact will the Corporate Manslaughter and Corporate Homicide Act 2007 have on businesses' approach to occupational health and safety?

  3.2.1  Following my written submission to the Joint Select Committee on the Draft Corporate Manslaughter Bill in 2005,[94] I welcomed the revisions around deaths in custody and the "senior management" as opposed to the "senior manager" test. I feel that there will be many other written and oral submitters who will be able to contribute much more than I can to this question. I will, however, make one or two brief points. Lord McKenzie[95] suggested that the Corporate Manslaughter and Corporate Homicide Act, 2008, "will provide an important new enforcement option in cases where a fatality results from serious management failures" used where "organisations fall far short of what the law requires" (CCA 2008:5 "Directors' duties law still on the table" says Minister, Corporate Crime Newsletter No. 23 Spring 2008)

  3.2.2  The real test will be in the number of prosecutions and their rate of conviction under the 2008 Act. I believe that the key features of the 2008 Act which could enhance the chances of prosecution and convictions and positively affect the approach of businesses to occupational health and safety are concentrated in the following areas:

    Under S. 1 The Offence . . .

    An organisation is guilty of an offence if the way in which its activities are managed and organised

    (a)  causes a person's death; and

    (b)  amounts to a gross breach of the relevant duty of care owed by the organisation to the deceased.

  3.2.3  The way in which its activities are managed or organised in s.1 above applies to "by its senior management".

  s.1 (b) a breach of duty of care by an organisation is a "gross" breach if the conduct alleged to amount to a breach of that duty falls far below what can reasonably be expected of the organisation in the circumstances. The term `senior management' refers to people who play significant roles in:

    (i)  the making of decisions about how the whole or a substantial part of its activities are to be managed or organised; or

    (ii)  the actual managing or organising of the whole or a substantial part of those activities.

  3.2.4  Finally under s.8 Factors for a jury.

  If a duty of care is owed then it is the jury which decides whether there was a gross breach of that duty. Under s.8 (2) the jury must consider whether the evidence `shows that the organisation failed to comply with any health and safety legislation that relates to the alleged breach and if so:

    (a)  How serious that breach was; and

    (b)  How much of a risk of death it posed.

  3.2.5  S.8 (3) The jury may also:

    (a)  consider the extent to which the evidence shows that there were attitudes, policies, systems, or accepted practices within the organisation that were likely to have encouraged any such failure as is mentioned in sub-section (2), or have produced tolerance of it; and

    (b)  have regard to any health and safety guidance that relates to the alleged breach.

    (4)  In this section "health and safety guidance" means any code, guidance, manual or similar publication that is concerned with the health and safety matters and is made or issued (under statutory provision or otherwise) by an authority responsible for the enforcement of any health and safety legislation.

  3.2.6  The ways in which activities are managed or organised by senior management and cause a persons death, appears to cover both board members/executive officers and key operational managers looking after a substantial part of an organisation. It is in the factors for a jury, where some of the most encouraging developments are located. In considering a gross breach of duty, failing to comply with relevant health and safety legislation can be considered by a jury.

  3.2.7  In s. 8 (3) and (4) the evidence of "attitudes, policies, systems, or accepted practices within the organisation that were likely to have encouraged any such failure or have produced tolerance of it, have regard to any health and safety guidance" is in my view the most significant section of the Act, where most progress has been made. This links to s.37 of the HSWA 1974 (neglect, consent or connivance), recognises the relevance of organisational culture and setting the tone of the organisation in relation to health and safety, which is a feature of the IOD/HSE 2007 voluntary guidance on Leading Health and Safety at Work.

  3.2.8  The fact that the health and safety guidance means any code, guidance or manual as outlined in s.(4) would allow the IOD/HSE 2007 guidance and the HSE 2004 Management Standards on work-related stress to be used by the prosecution to illustrate falling far below what can reasonably be expected etc. Due to the presence in s.8(2) of failing to comply with any health and safety legislation, it would enhance chances of prosecution and conviction if the IOD/HSE voluntary guidance was placed on a statutory basis or at the very least an Approved Code of Practice linked to the HSWA 1974. It would also help if the HSE 2004 Management Standards on work-related stress were placed on a statutory basis, or at the very least an Approved Code of Practice formally linked to the 1974 HSWA and s.3 of the Management of Health and Safety Regulations 1999.

Recommendations

  1.  Place the IOD/HSE (2007) voluntary guidance Leading Health and Safety at Work on a statutory basis or at least classify it as an Approved Code of Practice, formally linked to the HSWA 1974 and the Management of Health and Safety Regulations 1999.

  2.  Place the HSE (2004) Management Standards on Work-related stress on a statutory basis or at least classify them as an Approved Code of Practice formally linked to the HSWA 1974 and the Management of Health and Safety Regulations 1999.

  3.  Use the HSE (2004) Management Standards on Work Related Stress as THE organisational performance toolkit to accompany the IOD/HSE (2007) guidance on Leading Health and Safety at Work.

  4.  Ask the HSE what are the national statistics for organisational performance on the HSE (2004) Management Standards on Work-Related Stress? What percentage of companies have actually used them since they were introduced in 2004?

  5.  Ask the HSE have there been any investigations, prosecutions, or convictions for health and safety breaches in relation to the 1974 and 1999 Acts, which referred to the HSE 2004 Management Standards on Work-Related Stress? If not why not, when one considers the statistics on stress related occupational health matters outlined in this submission alone?

  6.  If 1, 2, and 3. above are addressed then the IOD/HSE (2007) guidance and the HSE (2004) Standards on Work-related Stress could play a central role in investigations and prosecutions under Corporate Manslaughter and Corporate Homicide 2008. They could provide invaluable assistance in the areas of proving a gross breach of duty, falling well below the required standard, as well as providing evidence of poor attitudes, accepted practices encouraging failures or tolerance leading to such failures.

  I would like to thank the HOC DWP select committee for all their work on this matter and for taking time to read my submission.

Dr H J Hartley

Leeds Met University







91   See HSE (2007) Managing the Causes of work-related stress: a step-by-step approach using the Management Standards. Second edition. ISBN 978-0-7176-6273-9. www.hse.gov.uk Back

92   This is an aggravating factor considered in any decision on whether or not to prosecute. Back

93   See HSE (2003) Development of internal company standards of good management practice and a task-based risk assessment for offshore work-related stressors HSE Books ISBN 978 0 7176 225 2. Back

94   See Memorandum 160, Ev 330-332, 2005. Back

95   Presentation by Lord McKenzie at the CCA conference on 19 November in London. Back


 
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