Memorandum submitted by Hazel Hartley
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
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
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
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
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
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
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
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
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
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
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
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
(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
3.1.10 I would recommend that the Government
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
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.
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
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
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
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.
Relationships (conflict, bullying,
Role (including clarity of role)
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
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
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
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
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
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
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
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,
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
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
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
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
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
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
This is an aggravating factor considered in any decision on whether
or not to prosecute. Back
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
See Memorandum 160, Ev 330-332, 2005. Back
Presentation by Lord McKenzie at the CCA conference on 19 November
in London. Back