SHP11- Seven Deadly Sins p23-25 10/12/00 11:56 AM Page 23

www.safetymags.com SHP RISK ASSESSMENT

7
Risk assessments are
an integral part of the

SEVE
practitioner’s job, but
their very routinism
makes it easy to do

The
them incorrectly, or
even overlook them
altogether. Jane
Blunt has identified

DEADLY
the seven main pitfalls.
Illustrations by John
Knight.

large part of Health and

A Safety legislation requires risk

assessment, but what

differentiates a good risk
assessment from a poor
one? It is perfectly obvious that a risk
assessment which records ‘Danger of death’
in the hazard section, but simply declares
‘Take care’ in the section that describes
control measures, is poor. However, it is not
easy to give constructive criticism to a non-
specialist unless the safety practitioner can
communicate a concept of what risk
assessment is trying to achieve.
While some of the following observations
are particularly relevant to research and
development environments, others are much
more universal. You may recognise similar
sins in your organisation. May you profit
from recognising them for what they are!
To gain insight into what risk assessment
is intended to achieve, it is essential to go
back to the original statement. The explicit
legal requirement arises from Regulation 3 of
the Management of Health and Safety at
Work Regulations,1 which states:
“Every employer shall make a suitable and
sufficient assessment of
a) the risks to the health and safety of their
employees to which they are exposed
while they are at work; and
b) the risks to the health and safety of
persons not in their employment arising
out of, or in connection with, the conduct
by them of their undertaking for the
purpose of identifying the measures they
need to take to comply with the
requirements and prohibitions imposed on
them by, or under, the relevant statutory
provisions, and by part II of the Fire
Precautions (Workplace) Regulations.”
Risk assessment is therefore carried out to
identify what the employer needs to do in
order to abide by the legal constraints
placed upon him/her. In some cases the
legal constraints have been described
through Regulations and Approved Codes of
Practice. For the thousands of situations
that fall within the category of ensuring
safety ‘so far as is reasonably practicable’,
guidance documents and industry codes of
practice are immensely valuable. With such
S INS
of risk
assessment
an enormous amount of
quality written guidance, it is
only necessary to work from
first principles on relatively
rare occasions, so what
could possibly go wrong?
Sin 1 Failing to translate the risk
assessment into a safe system of work
Here, just fill in this form and you’ll be OK
Sometimes the risk assessment is treated
as an end in itself. Unfortunately, safety
practitioners often fall into the trap of asking
people: “Have you done your risk
assessment?” So it shouldn’t be a surprise
if all that has been done is an analysis of
hazard and a risk assessment, particularly if
they were given a piece of paper called a
‘risk assessment form’ to fill in.
There are other reasons for this failure. It
is relatively easy for people to list the
hazards and to decide what could go
wrong, but it is much more difficult for
people to come to a decision about how to
control risk. In some instances the decision-
making process carries quite serious
responsibility. The provision of a safe
system of work may involve sanctioning
expenditure, which may create a conflict of
interest for the assessor. The culture of the
organisation may pressurise the manager to
believe that compromises should be made
in the interest of profit.
Most people find it difficult to describe a
system of work in the kind of language that

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RISK ASSESSMENT SHP
It is difficult for a safety practitioner would like. A manager
people may use words like ‘careful’, ‘experienced’
undertaking a and ‘vigilance’, and completely forget to
risk assessment mention the control measures already in
to gauge place. When challenged, he or she may be
whether what able to give quite a good account of what is
their company meant by the term ‘careful’. It may be a
does is process that already has extensive
acceptable, as engineering controls, or there may be a
they may well formal system of work incorporating such
know of some measures as restriction of access, search
organisation that and lock up, audible and visible warnings,
is worse! If, in and the restriction of work to named
addition, there competent persons. ‘Careful’ can also mean
has been no ‘just do it and don’t have an accident’.
history of If the training for risk assessment does
accidents not emphasise the desired outcome – the
associated with safe system of work – and the hierarchy of
the activity being control measures that is needed to achieve
assessed, then it it, then that aspect of the process may be
may be difficult very weak, or non-existent.
to persuade
people that there Sin 2 Reinforcing the status quo
is any need to
change.
But we’re fine the way we are!
For various reasons, risk assessments may
often be carried out retrospectively for
operations that have been going on for some
time. Clearly in these cases there is already a
system of work, but there is no guarantee
that that system follows industrially accepted
practice. It may not even be legal! There are
large variations in standards between
workplaces, which have their origins in the
resources available to the companies
concerned, the image they would like to
project, their culture and their safety policy.
It is difficult for people undertaking a risk
assessment to gauge whether what their
company does is acceptable, as they may
well know of some organisation that is worse!
If, in addition, there has been no history of
accidents associated with the activity being
assessed, then it may be difficult to persuade
people that there is any need to change. In
these circumstances, the risk assessment
will probably have been completed, but it
may describe in detail the safeguards and
the systems of work that are already in place,
with no areas identified for improvement.
In extreme cases, where an organisation
has a substantial history of ‘custom and
practice’, the ‘safe system of work’ may even
describe how the interlocks are overridden
on a machine in order to allow access while
the machine is running.
Risk assessment, properly applied, can
act as an opportunity to audit the workplace
against the current legal standards and
24 T H E S A F E T Y & H E A LT H P R A C T I T I O N E R NOVEMBER 2000
industry norms, and to put into place such
improvements as are necessary. Instruction
needs to be given to outline the basic legal
requirements, targeted to eliminate any
wrong practices that are observed.
If the risk assessment form is modified to
have a section that is headed ‘Standards
that should be achieved’, this could prompt
the person undertaking the assessment to
find out what is an acceptable standard.
This concept has been used in the HSE
publication 5 Steps to Risk Assessment:
Case Studies,2 where it acts as the link
between the existing controls and the future
actions. In my experience the inclusion of
this in the risk assessment form has had a
very positive influence on the quality of risk
assessments produced by non-specialists.
Sin 3 Doing the risk assessment too late
In many workplaces the pattern of work can
change on an almost daily basis. The project
manager is keen to get on with the work. He
or she may perceive the risk assessment as
getting in the way of this, and conveniently
forget to do it. The safety practitioner can
find him/herself frustrated by encountering
projects that are completed, without any risk
assessment having been carried out.
To stop this from happening it is
necessary to build into the core rules of the
organisation a mechanism to ensure that
work cannot be authorised to begin unless a
risk assessment has been carried out.
Management support at a very high level is
required to bring this about.
Sometimes an employer embarks on the
design and fabrication, or installation, of
entire assemblies of equipment. The proper
use of risk assessment under these
circumstances can enable the equipment to
be placed in the best location, and for
design and installation to be completed to
appropriate standards. The necessary fixed
guarding, shielding or interlocking will also
have been identified at an early stage.
OK, reactor going critical ... now, what
was that about a risk assessment??
However, all too often risk assessment is
carried out retrospectively, or near the end of
the process. This can result in expensive
modifications, as it is possible that the
equipment may have been placed in a
position where providing services such as
piped gas or exhaust ventilation are very
expensive. Designing guarding and shielding
for such things as exposed electrical
terminals, pinch points, rotating shafts, etc.
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is easiest early in the project and tends to be
quite difficult at the later stages. The project
leader faced with this problem may well put
considerable pressure on the safety
practitioner to accept the standards as they
are. The safety practitioner will need to have
a very clear idea of priorities in order to put a
case to the senior management for making
improvements late in the project.
Sin 4 Being dazzled by numbers
It must have been my fault – the risk
rating was only 7.492 ...
Scientists and engineers love numbers and
they like to quantify what they do.
Unfortunately there are several quite serious
drawbacks to numerical risk assessment,
and it can even be abused. Most numerical
risk assessment methods rely on calculating
the product of the severity of the outcome by
the likelihood of it happening. If subjectivity
creeps in, or the result is used
inappropriately, the method fails.
Quantifying the likelihood and severity of a
mishap can be extremely difficult owing to
the lack of data on which to base the
assessment. The first time that a particular
activity is carried out the probability of having
an accident might be quite high because of
inexperience. Conversely, it might be quite
low, since the adrenalin will be flowing
copiously the first time the job is done, and
attention levels will be very high!
The frequency with which the job is to be
carried out is generally embedded explicitly
or implicitly in the calculation. If an activity is
undertaken infrequently the figure decreases
and this can seriously skew the figures
relating to overall risk, even in the case of a
mishap that can have a fatal outcome.
Once the product of the severity and the
likelihood has been calculated, the result still
requires interpretation. In most risk
assessment systems, the results are used to
decide whether measures are necessary to
reduce the risk, on the basis that the higher
the number, the more urgent the need.
Unfortunately this can polarise behaviour.
The workers may go ahead with an operation
which has a high ‘risk figure’ without taking
any additional precautions – drawing on a
sort of ‘macho’ acceptance of risk.
Alternatively the work may be perceived as
too risky and abandoned altogether.
Attempts to analyse how the risk could have
been reduced may be forgotten.
Total reliance on a numerical risk
assessment strategy can result in a diversion
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of valuable time towards calculations, at the
expense of time spent on devising control
measures or researching into the legal
constraints. The control measures need to
be stressed, and the precautionary principle
applied: if we do not know what is likely to
happen, assume the worst reasonably
foreseeable outcome.
Sin 5 Not doing your homework
While many decisions in safety can be
made solely by the use of common sense,
some legal knowledge is necessary. Many
people believe that the test of whether a
system of work is safe and legal is whether
they have an accident or not. For example,
some believe that work with live electrical
apparatus can be done legally and safely if
you put one hand in your pocket!
And we can machine the guard out of
beryllium!!
Most degree programmes do not include
specific education on the legal constraints
on the workplace, or the safety jargon, such
as MEL, OES, respiratory sensitiser, etc.
Therefore, even extremely well-qualified
personnel will need specific training to
undertake risk assessments. They need to
be given specific instruction in the hierarchy
of control measures. Without it they may
tackle problems by imposing layers and
layers of procedural control, while
neglecting the possibility of removing the
problem altogether by suitable engineering
means, such as guarding or interlocking.
Unfortunately, if all of this information is
crammed into the initial risk assessment
training it can lead to information overload.
Sin 6 Thinking it is someone else’s job
Does this person work for us?
This arises in two very common situations.
Sometimes employees need to visit the
premises of another employer to undertake
work at the host’s premises. An employee
engaged in the service industries, research
or consultancy may typically be called upon
to visit a site to undertake some
maintenance or repair, give a professional
opinion, or to carry out some investigative
work. There is a danger that he/she may
believe that a risk assessment is not needed
at all, because his/her safety is the
responsibility of the host.
This is potentially dangerous for both
parties. Case law shows that the legal
situation between employees from different
employers, working side by side, is
complex. If there is a mishap, questions
would be raised about whose undertaking it
was and who had been negligent. It would
be all too easy for the risk assessment for
the operation to fall through the cracks, with
each employer believing that the other had
done what was necessary.
In consultancy and R&D, the employees
that this affects are often those in quite
senior positions. They may not be in the
normal line management structure, owing to
their specialisation, and it may be quite
difficult to bring this issue to their attention,
and give them the necessary instruction.
Fortunately, once the subject is broached
with such individuals, it is not unusual for
them to relate ‘horror stories’ about some
site visits that they have made. They may
welcome the risk assessment as a means to
enter into formal negotiations with their host
and to communicate their needs. There
needs to be good communication between
the distant worker and his/her organisation,
so that the risk assessment can be revised
as necessary. It may be necessary to
establish how the distant worker can
withdraw from the situation if reasonable
conditions cannot be met, and what criteria
to apply in order to reach this decision.
Sin 7 Getting bogged down in trivia
Many people, especially those engaged in
research and development, are imaginative.
They can work out solutions to problems
and have creative minds. This is just the kind
of mind that can generate an almost infinite
supply of ‘what if?’ scenarios.
It can be difficult for imaginative people to
stop producing more and more of these
ideas, and to concentrate on what are
perceived to be the most important hazards
and risks. They could never escape from the
risk assessment process; they could never
reach a decision on what to do!
They may even reduce the whole risk
assessment process to an absurdity, by
arriving at the conclusion that almost
anything could happen, so they should go
home and forget it. They need guidance to
define both the boundaries of
reasonableness, and the number of
simultaneous potential failures to be taken
into account.
The solution. . .
Those are the problems, but how can they
be tackled? To avoid these deadly sins, any
of which is capable of rendering our risk
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SHP RISK ASSESSMENT
There needs to
be good
communication
between the
distant worker
and his/her
organisation, so
that the risk
assessment can
be revised as
necessary. It may
be necessary to
establish how the
But we’ve never had an iceberg in the distant worker
Trent!! can withdraw
from the situation
assessment process completely worthless, if reasonable
perhaps consideration should perhaps be conditions
given to the following: cannot be met,
• Emphasise the safe system of work and what criteria
during risk assessment training. to apply in order
• Stress the hierarchy of control measures. to reach this
• Outline only the major legal constraints, to decision.
avoid information overload.
• Follow it up with a resource, such as a
handbook, or website.
• Admit that you don’t know everything
about everyone’s specialisation.
• Stress that you do know the principles on
which safety law is based.
You should also consider incorporating a
section on the risk assessment form to
record the desired outcome, so that the
logical sequence is:
• What am I planning to do?
• What are the hazards?
• Who do they affect?
• What are the risks and how serious is the
outcome?
• How do we control the risk at present?
• What should we be doing to control it?
• How are we going to improve in order to
meet this standard?
• By when?
The safety practitioner has an essential role
to play in rooting out these sins. We should
not be afraid to be encourage, coach, cajole,
push and act as devil’s advocate. The
serious consequences of failing to do so are,
unfortunately, many and well-documented.
References
1 The Management of Health and Safety at
Work Regulations 1999, SI 3242.
2 5 Steps to Risk Assessment: Case
Studies, HS(G)183.
About the author
This article is based on a talk delivered to
the East Anglian Branch of IOSH in 1999.
Jane Blunt, PhD, C Eng, MIOSH, MIM is
currently safety officer at the Department
of Physics, University of Cambridge. She
has worked as a research chemist and
turned to a full-time career in safety about
four years ago, achieving the NEBOSH
Diploma in 1998.
John Knight is health and safety manager
at Goodmans Loudspeakers Ltd.