A report into the arrangements

for managing

health and safety

at ATS

Title Page

Unchanged – Must be amended

Check or ammend

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Contents
Executive Summary...............................................................................................................................4

Introduction...........................................................................................................................................5

Aim....................................................................................................................................................5

Objectives..........................................................................................................................................5

Methodology.....................................................................................................................................5

Workplace Description..........................................................................................................................6

Production processes........................................................................................................................6

Inbound.........................................................................................................................................6

Sortation........................................................................................................................................7

Outbound......................................................................................................................................7

The role of the Health and Safety Practitioner......................................................................................7

Professional ethics.............................................................................................................................8

Review and critical analysis of health and safety at ATS ......................................................................10

Risk profile.......................................................................................................................................10

Key health and safety risks and their assessment........................................................................11

Leadership.......................................................................................................................................14

Management...................................................................................................................................15

Communication of information.......................................................................................................17

Control of contractors.....................................................................................................................18

Review.............................................................................................................................................20

Worker involvement........................................................................................................................20

Competence....................................................................................................................................21

Induction.........................................................................................................................................22

Identification of training needs........................................................................................................23

Compliance......................................................................................................................................23

Evaluation of priorities........................................................................................................................24

Visibility and accountability of Operational Management and Leadership .....................................24

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 Weekly Safety Walk.....................................................................................................................25

Safety Audit.................................................................................................................................25

Improved control of external drivers...............................................................................................26

Improved Orientation and Training.............................................................................................26

Signage and Traffic Management................................................................................................26

Enforcing PPE Usage....................................................................................................................26

Compliance Monitoring...............................................................................................................26

Improved load securing controls to ensure on road safety .............................................................27

Employee Training.......................................................................................................................27

Managerial Checks and Audits.....................................................................................................28

Driver Load Inspections and Use of Load Plans...........................................................................28

Conclusions and recommendations.....................................................................................................28

References...........................................................................................................................................30

Executive Summary...............................................................................................................................3

Introduction...........................................................................................................................................4

Aim....................................................................................................................................................4

Objectives..........................................................................................................................................4

Methodology.....................................................................................................................................4

Workplace Description – 1 or 3?...........................................................................................................5

Production processes........................................................................................................................6

Inbound.............................................................................................................................................6

Sortation............................................................................................................................................6

Outbound..........................................................................................................................................7

The role of the Health and Safety Practitioner..................................................................................7

Table of contents
Executive summary 4
Introduction 5
Aim 5
Objectives 5
Methodology 5

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Workplace description 6
Review and critical analysis of health and safety management at XYZ Ltd 11
Risk profile 11
Leadership 16
Management 18
Worker involvement 21
Competence 22
Compliance 23
Evaluation of priorities 25
Conclusions and recommendations 30
Bibliography

- Executive Summary
- Introduction
- Review and critical analysis of arrangements for
managing health and safety
- Evaluation of improvements required
- Conclusions and Recommendations
- Bibliography
- Appendices.

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Executive Summary
Following a review of safety practices at ATS Ltd……………….Write this last

P a g e 5 | 37
Introduction
Aim
The purpose of this report is to critically review the effectiveness of safety leadership, management
and employee engagement at ATS in order to make recommendations that will support the company
in improving both safety performance as well as driving a shift in safety culture within the
organisation.

Objectives
To support this, the report sets out to satisfy the following:

 To review the effectiveness of the current safety management structures within the
organisation
 To determine if the current structures enable the management of safety by leaders of the
organisation and the effect this has on the actual safety performance and behaviours of the
general worker.
 To determine the current structures for involvement of the general worker populations
supports the improvements on behavioural safety and cultural changes.

Methodology
Due to the size of the organisation a sample set of sites was selected and inspected in some detail
with these sites selected as a representative cross section of the site types found across the
organisation. In preparation for this report, interviews were conducted with senior management,
line managers, supervisors and a representative sample of the workforce. Relevant documentation
such as the company health and safety policy, training records, training content, risk assessments
and records of workplace audits.

The aim of these inspections was also to assess physical safety arrangements and to evaluate the
existing safe systems of work in place and to evaluate attitudes to safety at all levels of the
organisation.

Company accident statistics were evaluated to determine the most frequent types of incident, the
reporting of near miss and hazards and to assess quality of reporting which was taken as an indicator
of the health and safety culture within the organisation.

The results of this analysis are presented as a narrative discussion with the three most impacting
health and safety management issues identified with recommendations in order to improve safety
management and culture within the ATS organisation.

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Workplace Description – 1 or 3? (Changes intro)
ATS is a business unit within a large-scale online retail operation with the primary purpose being to
receive goods and sort to enable regional onward delivery. The site is based in Tilbury with excellent
road links to the wider network.

The site employs approximately 1200 people with approximately 90% employed within the
operation and the remaining headcount making up management and support functions including
human resources, facilities management and IT support. This is supported by centralised functional
support dealing with regional, UK and EU network support which includes additional safety resource.

The site operates across two main shifts, each over 4 days, Sunday to Wednesday, and Wednesday
to Saturday with a cross-over double shift each Wednesday. The two main shifts operate 08:00-
18:00 and 19:00 05:00 with supplementary shifts to support 22 hour per day operation 7 days a
week.

The organisation has a mix of gender and a wide age range with all workers over 18 years of age.
Due to the seasonal nature of the organisation the number of employee’s flexes with the use of
short-term temporary labour. The site is accommodating of ambulant disabled persons with
accommodation made within some roles along with expected access and facilities required to
support.

The site is approximately XXXXXXXm2 and is housed within one main building with extensive
external areas for yard operations. This includes an offsite yard operation approximately 500m from
the main site entrance and is used as a holding area of inbound transportation. Access to both sites
is managed with barriers, security personnel and perimeter fencing. The main site has car parking
with speed controls and signage, and is segregated from other transportation to and from the
operation.

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Production processes
ATS is responsible for managing the sortation of packages received from upstream sites within the
same organization. This involves three main processes: Goods Inwards/Inbound, Sortation, and
Goods Out/Outbound.

Inbound
During Goods Inwards/Inbound, packages are received into the site via both HGV and LWV vehicles.
The gatehouse process is staffed by both administrative and security personnel, who check in
vehicles and allocate a parking bay or dock door location. Yard marshals monitor the process of
docking to ensure the correct location is used, the vehicle restraint system is engaged correctly, and
pedestrian safety and adherence to site safety rules are ensured. Once the vehicle is docked, the
indoor dock team is responsible for offloading packages, which arrive either in carts, on pallets, or
loose. Packages are transported to the sortation area via carts, pallet trucks, or conveyance.

Sortation
Sortation of packages is handled either via automated or manual methods. In automated sortation,
packages are scanned as they move along a conveyor and deposited to sort locations in either carts
or pallets with cardleadership shrouds. In manual sortation, a person manually scans the package
and sorts it to a destination pallet or cart. Sorted packages are then moved to a swim lane in
readiness for loading to the correct outbound trailers. The majority of movements are manual either
by pushing carts or pulling pallets on pallet trucks. Packages are limited to a maximum of 15kg, with
a small percentage (<1%) marked as a team lift but restricted to less than 20kg.

Outbound
During Goods Out/Outbound, trailers are loaded with carts, pallets, or loose packages for onward
delivery. All carts or pallets are staged in lanes to ensure visibility and efficiency of movement, and
manually moved on the wheel carts or with pallet trucks to the trailers by loaders. Loaders are also
responsible for securing the load and closing down the process in readiness for departure. The
departure process is controlled by the yard marshal team, who ensure drivers collect the correct
trailer and follow process and yard safety rules at all times. Docking and departing a trailer are
managed through an application on a mobile phone-like device. The application acts like a checklist
to ensure all the key steps in the process are followed, and guidance is provided where defects are
established.

ATS manages the sortation of packages received from upstream sites

within the same organisation. Primarily this involves 3 main process.

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Goods inwards/Inbound

Sortation

Good Out/Outbound

Inbound

The process of receiving packages in to the site via both HGV and
LWV vehicles. Vehicles are checked in through the gatehouse process
which is staffed by both administrative and security personnel.
Vehicles are checked in and allocated a parking bay or dock door
location. The yard area is staffed with yard marshals that monitor the
process of docking to ensure the correct location is used, the vehicle
restraint system engaged correctly, to support the drivers in the
process and to ensure pedestrian safety and adherence to site safety
rules.

Once the vehicle is docked the indoor dock team are responsible for
offloading packages which arrive either in carts, on pallets or loose.

Packages are transported either within the carts, on pallet truck or via
conveyance to the sortation area.

Sortation

The sortation of packages is handled in one of two ways:

Automated sortation

Manual Sortation

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Automated sortation is handled via scanning the packages as they are
carried along a conveyor and depositing the packages to sort locations
in either carts or pallets with carboard shrouds.

Manual sortation requires a person to manually scan the package and

sort to a destination pallet or cart.

In both cases the sorted packages are then moved to a swim lane in
readiness for loading to the correct outbound trailers. The majority of
movements are manual either by pushing carts or pulling pallets on
pallet trucks. Packages are all limited to a maximum of 15kg with a
small percentage (<1%) marked as team lift but restricted to less than
20kg.

Outbound

The process involves loading trailers with carts, pallets or loose

packages for onward delivery. All carts or pallets are staged in lanes
to ensure visibility and efficiency of movement and manually moved
on the wheel carts or with pallet trucks to the trailers by loaders. The
loaders are also responsible for securing the load and closing down
the process in readiness for the departure. The departure process is
again controlled by the yard marshal team who ensure drivers collect
the correct trailer, follow process and yard safety rules at all times.

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The process of docking and departing a trailer is managed through an
application on an mobile phone like device. The application acts like
a checklist to ensure all the key steps in the process are followed and
guidance provided where defects are established.

The role of the Health and Safety Practitioner

The Health and Safety Manager took their position approximately 12 months ago after stepping up
from an operations position. This is a common career path in the wider organisation due to the
unique nature of the business, however they currently hold no formal safety qualifications. The role
was held by another qualified Safety Manager who left the business. As a result there is a safety
management system in place although it is generic and has not been adequately maintained
although there is regional support which has helped address some gaps.

Although the organisation’s senior management are aware of the need to manage health and safety,
the Health and Safety Manager’s role is confined to day-to-day matters rather than taking a more
strategic approach. It is hoped that, given time, the Health and Safety Manager’s role will begin to
become more strategic, especially as the company starts to see the benefits that can be gained
through effective safety management.

The Health and Safety Manager reports to the General Manager, who has been with the company
for thirteen years and is the same person who previously had overall responsibility for safety. The
Quality Manager in turn reports into the head of manufacturing. This arrangement can be perceived
by some as an indication that health and safety is a 'manufacturing' issue rather than one that
transcends the organisation. This can present difficulties when it comes to raising awareness of
safety issues in non-manufacturing parts the business.

The Health and Safety Manager is responsible for the full range of day-to-day health and safety
management functions within the organisation. He was instrumental in drafting the company's
statement of health and safety policy and continues to develop individual organisational
arrangements for all aspects. The Health and Safety Manager acts as the specialist on the newly
formed health and safety committee and has been successful in getting a different senior manager
to chair this meeting on each occasion. The Health and Safety Manager also acts as the committee's
secretary, producing the agenda and compiling the minutes for each meeting, and ensuring that all
actions are carried out before the next meeting.

A key function carried out by the Health and Safety Manager and his team is the conduct of risk
assessments. As the health and safety assistants are not professionally qualified, the Health and

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Safety Manager has trained them in risk assessment and supervises the conduct of assessments to
ensure that they are suitable and sufficient.

Where necessary, specialist advice is obtained to assist with certain assessments such as exposure to
lead fume (from solder) and noise, both of which assessments are carried out by a

contracted occupational hygienist. This is because the health and safety practitioner does not
consider himself competent in these areas and wants to ensure that the assessments are carried out
to a professional standard so that the right control measures can be introduced.

The Health and Safety Manager also conducts health and safety training throughout the
organisation. This includes induction training plus short courses in manual handling and fire safety
awareness. Accredited training courses, such as NEBOSH’s Health and Safety at Work qualification or
National General Certificate, are outsourced to accredited training providers.

The health and safety practitioner currently has a limited role in strategic health and safety
management and does not currently have direct access to board level decision making. All access to
the board needs to go through the Quality Manager who effectively controls the information that
the board receives. Notwithstanding this, the health and safety practitioner has a good working
relationship with middle management throughout the organisation and is increasingly seen as a
reliable source of advice and assistance when dealing with health and safety matters. This has
brought about some notable successes and has produced an improvement in the organisation's
health and safety culture. The Health and Safety Manager in this organization has been in the
position for around 12 months, having previously worked in operations. While it's a common career
path in the organization due to its unique nature, the current manager does not hold any formal
safety qualifications. The previous Safety Manager was qualified, but has left the business, leaving
behind a generic safety management system that has not been adequately maintained. However,
regional support has helped address some gaps in the system.

Although senior management is aware of the need to manage health and safety, the Safety
Manager's role is primarily focused on day-to-day matters and maintaining defined metrics. Over
time, it's hoped that the Health and Safety Manager's role will evolve to become more strategic and
proactive, with a greater focus on behavioural safety.

Reporting to the General Manager, who has been in the role for three years and with the company
for five years, the Health and Safety Manager is responsible for day-to-day health and safety
management functions on site. This includes implementing company policies and procedures, acting
as a specialist on the health and safety committee chaired by senior managers, and producing
agendas and compiling minutes for meetings.

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The site employs Health and Safety specialists and coordinators to support operations outside of
regular hours. While some of the team members are not professionally qualified, the Health and
Safety Manager has trained them in risk assessment and supervises the process, checking and
verifying completion. Specialist advice is obtained where necessary, such as noise assessments,
lighting, and LUX testing, which are carried out by external contractors.

The Health and Safety Manager also conducts site-level health and safety training compiled centrally
by the company's learning and development department alongside central Health and Safety SMEs
and Legal. This includes induction training, short courses in fire safety, emergency procedures, and
general safety awareness, as well as coordination of centrally developed campaigns and initiatives.
Training courses, such as NEBOSH's Health and Safety at Work qualification, IOSH Managing Safety,
and NEBOSH National General Certificate, are outsourced via accredited training providers.

However, the Health and Safety Manager currently has a limited role in strategic decision-making,
and access to senior leadership goes through regional Health and Safety Management, which filters
and evaluates the information that Senior Leaders receive. Nonetheless, the Health and Safety
Manager has a good working relationship with middle management throughout the organization and
is increasingly seen as a reliable source of advice and assistance, particularly in areas such as
transport-related topics. This has led to some notable successes and improvements in the
organization's health and safety culture in this area.

As a warehousing and distribution organization that prioritizes customer satisfaction and quick
delivery to meet tight deadlines, there is a prevailing culture of speed. However, this has led to some
employees compromising health and safety standards in order to meet targets. Despite concerns
raised by the health and safety practitioner, efforts to effect change have been met with resistance,
as the leadership is primarily accountable to performance metrics.As a manufacturing organisation
that prides itself in being first to market with an innovative technological product, XYZ Ltd places a
certain amount of pressure on the workforce to keep design at the forefront of technology and also
to produce products quickly enough to satisfy orders. From time to time this may have the effect of
motivating some staff to compromise health and safety standards in order to meet production
targets. Similarly, it has been noted that product health and safety is perhaps not as well and
thoroughly considered as it might be. An example of this is the fact that designers have specified the
use of a solvent-based glue to secure ribbon cables, rather than specifying a more effective and
lower risk mechanical locking solution. The health and safety practitioner has made representations
on this point but has met with limited success, the main argument against change being one of cost.

P a g e 13 | 37
Professional ethics
As a Technical Member of IOSH, the Health and Safety Manager adheres to the principles of
professional ethics in relation to his work at ATS. Honesty, respect for others, and professional
integrity are fundamental principles that guide his actions.

While the Health and Safety Manager is loyal to his employer, his responsibility to ensure the safety,
health, and welfare of the workforce supersedes this loyalty. As a result, he provides an honest
assessment of the state of health and safety management and strives to identify areas where the
organization may fall short of legal minimum standards.

To maintain and improve his competence, the Health and Safety Manager attends local IOSH branch
meetings, seminars, and training courses, such as the NEBOSH Diploma. Additionally, he only
undertakes tasks that he is competent to handle and defers to others when necessary. For instance,
he employs specialists to conduct noise monitoring as previously outlined.

In some cases, managers ignore the Health and Safety Manager's professional advice. In such
situations, he strives to make them aware of the consequences of disregarding the advice and, if
appropriate, tries to find a compromise that allows the task to be carried out safely while still
achieving the manager's objectives. This is achieved through collaboration aimed at finding a
practical risk management solution that enables safety rather than disabling it. However, the Health
and Safety Manager's limited seniority means that he cannot enforce compliance to a certain extent.

As a leader in health and safety matters, the Health and Safety Manager sets a good example at all
times and refrains from behaving in a manner that may be deemed inappropriate given his position.
He ensures that all information of a personal or commercially sensitive nature is kept strictly
confidential at all times.

As a Technical Member of IOSH, the Health and Safety Manager ascribes to the principles of
professional ethics insofar as they relate to his work within XYZ Ltd. The key principles of honesty,
respect for others and professional integrity are observed.

Although the Health and Safety Manager has a loyalty to his employer, this does not override the
need to ensure the safety, health and welfare of the workforce at large. Therefore, the health and
safety practitioner provides his honest opinion on the state of health and safety management and
endeavours to identify clearly those areas where the organisation may fall short of the legal
minimum standard. The Health and Safety Manager also feels that it is his duty to maintain and
improve his competence and so he ensures that he attends local IOSH branch meetings, seminars

and goes on training courses such as the NEBOSH Diploma. Furthermore, the Health and Safety
Manager will only undertake those tasks that he believes himself to be competent to deal with and

P a g e 14 | 37
will defer to others where necessary, an example being the use of specialists to conduct airborne
monitoring as set out above.

From time to time, the Health and Safety Manager has experienced situations where managers
ignore his professional advice. In such cases the Health and Safety Manager endeavours to make the
person aware of the consequences of failing to heed that advice and will, where appropriate, try to
reach a compromise that allows the task to be carried out safely while still allowing the manager's
objectives to be achieved. This is achieved through collaboration aimed at finding a sensible risk
management solution. It is hoped that this will cause managers to recognise safety as an enabling
rather than a disabling function. However, the Health and Safety Manager’s relative lack of seniority
means that there is a limit to how far he can go to require compliance.

As a leader in health and safety issues, the Health and Safety Manager ensures that he sets a good
example at all times and does not behave in a manner that may be considered inappropriate given
his position. All information of a personal or commercially sensitive nature is kept strictly
confidential at all times.

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Review and critical analysis of health and safety at ATS
As mentioned in the introduction to this report, the safety management system is still something of
a work in progress. However it has developed significantly over the past 12 months in line with
HSG65, which has been used as the basis for the current arrangements. It is expected that, given
time, the organisation will be seeking certification to OHSAS 18001 but this is still some way off. For
the present, the Health and Safety Manager wishes to establish the basics of an effective health and
safety management system that is recognised as adding value throughout the organisation.

Risk profile
“Health and safety risk profiling is a structured approach to identifying, assessing and prioritizing
health and safety risks faced by an organization. It is a proactive approach that involves the
identification and assessment of potential hazards in the workplace, followed by the implementation
of control measures to minimize or eliminate the identified risks” (Cullen et al., 2018).

ATS operates primarily as a distribution centre for an online retailer and faces several corporate risks
that impact its market position and financial performance. One of the primary challenges is
competition from other retailers in the same sector that offer lower-priced alternatives from the Far
East or operate more streamlined processes. ATS differentiates itself on speed of delivery, which
results in higher overheads. Although the demand for ATS is high at present, the company cannot
afford to be complacent, especially as consumers search for more cost-effective options amid rising
inflation across the UK and EU.

To stay ahead of the competition, ATS employs highly qualified managers who ensure the company
remains innovative. However, there is a risk that these skilled employees could be lured away by
rival companies seeking to replicate ATS's success. To mitigate this risk, ATS provides competitive
remuneration packages and working conditions that rank among the best in the industry.

In light of these corporate risks and the culture of speed in the organisation, the Health and Safety
Manager acknowledges that health and safety concerns may not be seen as the most immediate or
pressing. However, the Health and Safety Manager is diligent in reminding senior management of
the importance of maintaining high health and safety standards to protect the workforce and the
company's reputation, through communication with the site leadership. The Health and Safety
Manager strives to ensure that health and safety is given equal importance to other business risks
and is not overlooked. Moreover, it could be argued that prioritizing and improving health and safety
along with improvement of welfare standards will enhance staff retention by creating a pleasant
working environment and ensuing staff retention and a view that is supported “prioritizing and
improving health and safety can have positive impacts on employee job satisfaction and work
commitment, leading to increased staff retention” (Kazi et al., 2018).
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The above principles are in line with the principles espoused by the Financial Reporting Council in its
code on corporate governance2 (‘The Code’). The leadership is required to consider those aspects of
risk that may harm the company's assets and threaten shareholders' investments, and to arrange for
action to be taken to mitigate such risks. According to section C of The Code (Accountability):

The leadership is responsible for determining the nature and extent of the principal risks it is willing
to take in achieving its strategic objectives. The leadership should maintain sound risk management
and internal control systems.

Further, at paragraph C.2.1 of The Code:

The directors should confirm in the annual report that they have carried out a robust assessment of
the principal risks facing the company, including those that would threaten its business model, future
performance, solvency or liquidity. The directors should describe those risks and explain how they are
being managed or mitigated.

It is submitted that health and safety risks should be counted among the ‘principal risks’ alluded to in
The Code. This is because a serious incident, or even a sustained pattern of less serious incidents, has
the potential to adversely affect morale, which would have a corresponding effect on productivity
and could lead to valued members of staff leaving the organisation. In the event of a serious
incident, there would be an increased likelihood of enforcement authority action and possibly even
prosecution, which may result in significant fines and could adversely affect the company's
reputation.

If the above argument is accepted, it should follow that the leadership should take an active interest
in assessing and controlling health and safety risks.

Key health and safety risks and their assessment

As an organisation, a number of significant health and safety issues need to be dealt with. These
include:

Load securing and transportation of goods is important for several reasons. First and foremost, it is
a critical safety measure that helps prevent accidents and injuries on the road. Properly secured
loads prevent cargo from shifting or falling off during transit, which could cause accidents, injuries,
or fatalities. In addition, load securing helps protect the cargo being transported, ensuring that it
arrives at its destination intact and undamaged. This can help minimize the risk of financial losses
due to damaged goods, insurance claims, and potential legal liabilities.

In the UK, the relevant laws and policies in relation to load securing include:

1. The Road Vehicles (Construction and Use) Regulations 1986: This regulation requires that all
loads carried on vehicles are secured properly to prevent danger to people or property.
P a g e 17 | 37
 2. The Health and Safety at Work Act 1974: This act requires employers to ensure the health
and safety of their employees, which includes the safe transportation of goods.
3. The Working Time Regulations 1998: This regulation sets out limits on the amount of time
that drivers can spend on the road and requires employers to provide adequate rest breaks.
4. The Vehicle and Operator Services Agency (VOSA) Guide to Maintaining Roadworthiness:
This guide provides advice on the maintenance of vehicles and includes guidance on load
securing.
5. The Code of Practice for Load Restraint Systems: This code of practice provides guidance on
the design, testing and use of load restraint systems in the UK.

It is important to note that failure to comply with these laws and policies can result in fines,
penalties, and even criminal charges in some cases.

Ergonomic issues associated movement of, and the loading and unloading of parcels. Prolonged and
repetitive movements in the sortation of parcels at workstations. Repetitive movements required for
parcel sorting at workstations can also cause health problems. In fact, analysis of sickness absence
reports has revealed a rise in work-related limb disorders due to prolonged work at workbenches
while performing repetitive tasks. Failure to address these issues may lead to increased health risks
for employees, resulting in higher rates of absenteeism and loss of productivity for the organization.
Therefore, it is crucial to implement measures to prevent such health issues and ensure a safe
working environment for employees.

Manual handling issues associated with lifting and carrying parcels can result in sprain strain injuries
or MSD injuries. Whilst there are limits on parcel weights (15kg) the employees also have to
manoeuvre carts, pallets and cages which can be up to 500kg.

Risk of collisions between moving vehicles and pedestrians, especially when pedestrians are
performing yard marshal duties in the yard area. Although marked walkways are available, and yard
areas are well-lit, it is impractical to erect pedestrian segregation barriers as this would hinder
personnel from completing tasks to support the safe docking and releasing of trailers. As a
precautionary measure, all personnel in the yard areas are required to wear hi-visibility vests and
safety footwear. However, it is not feasible to remove employees from these areas, as the majority
of drivers are third-party contractors who cannot be trained on the specific processes adopted by
the business.

This has been through CHAT GPT

At present, there is little evidence that the leadership considers critical health and safety risks at the
same logical level as corporate risks, although the leadership is aware of general health and safety
issues. According to the International Labour Organization, it is important for leaderships of directors

P a g e 18 | 37
to recognize that "occupational safety and health is a key management responsibility, and that it is
integral to good business performance" (ILO, 2021).

At the current state of development, management of safety is conducted at a tactical rather than
strategic level. According to the National Safety Council, "safety is most effective when it is
approached strategically, from the top-down and bottom-up, and integrated into all aspects of the
organization" (NSC, 2021). What is meant by this is that the Health and Safety Manager, line
managers and supervisors generally take on the bulk of the responsibility for ensuring good
standards of health and safety within the workplace, albeit guided by the general expectations and
objectives set by the senior management team. The section below on ‘Leadership' will deal with this
aspect in more depth.

In cases where risk assessments identify significant risks, the assessor is trained to specify critical
control measures that are proportional to the level of risk. According to the Health and Safety
Executive, it is important to ensure that "controls are proportionate to the risks" and that
"reasonably practicable steps" are taken to manage those risks (HSE, 2021). Assessors will always
bear in mind that, although there may be an 'ideal' solution to a health and safety management
problem, it may be the case that this ‘ideal' is somewhat out of reach, for both operational and
financial reasons. Therefore, and in the spirit of sensible risk management, assessors will take the
following factors into account: • cost of purchase, implementation and ongoing maintenance; •
technical feasibility of the proposed solution; • acceptability to the workforce; • whether the control
measure is required for a long or short-term; • demands of customers and the need to ensure
customer safety; • the practicability of implementing any given control; • the degree of reduction of
risk to be achieved.

It is also recognised that control measures cannot always be immediately implemented and so the
management system allows for prioritisation of actions. In some cases this has meant that interim
controls will have been implemented until such time as more effective, longer term controls can take
their place.

Where significant expenditure may be required on a health and safety initiative, be it a physical
control or training etc, an application for capital expenditure needs to be made to the senior
management team. To date, no sensible request has ever been turned down, indicating a willingness
on the part of the senior management team to ensure good standards of physical safety within the
workplace. However, personal visible felt leadership and active involvement on the part of senior
managers is missing. This is discussed in more depth under the heading of ‘Leadership’ later in this
report.

P a g e 19 | 37
In addition to the risk assessment function, ATS is in the process of developing a robust system of
active monitoring. This will include a system of monthly workplace inspections and ad hoc health
and safety tours. According to the Occupational Safety and Health Administration, "ongoing
evaluations of the workplace can help identify hazards and allow for corrective actions to be taken"
(OSHA, 2021). At present, these are being conducted by the Health and Safety Manager, the Health
and Safety Assistants and by some line managers, though not all. There is currently no involvement
from the senior management team.

In the event of an accident, the Health and Safety Manager will conduct an investigation. At the
present time, no other persons

Leadership
"Senior management engagement and visible felt leadership is arguably the single most important
foundation stone for an effective health and safety management system and a positive health and
safety culture" (Griffin & Neal, 2000). "Put simply, where leaders lead, the workforce will follow"
(Griffin & Neal, 2000). Therefore, it is important that leaders embrace safety at ATS and by
demonstrating a commitment to health and safety, the leadership of ATS can effectively
communicate the importance of this message to all members of the organization. This will
not only showcase their responsibility as leaders, but also indicate the effectiveness of the
company's management structure. Such a demonstration of a well-managed organization can
attract potential clients and investors, while also fulfilling insurance company requirements
for effective risk management across all areas. Demonstrating a commitment to health and
safety can also positively impact ATS's ability to retain current staff and attract new talent. A
well-managed and safety-focused culture can help to create a positive work environment and
improve employee morale, which in turn can lead to increased job satisfaction and reduced
turnover rates. Furthermore, potential employees are often attracted to companies with a
strong emphasis on safety, as it demonstrates a dedication to their well-being.

The senior management team demonstrates a basic understanding of the importance of managing
health and safety risks, but they lack practical leadership skills beyond establishing a legal
requirement for a safety policy. Although they have set general objectives for managing health,
safety, and welfare through a clear commitment in policy and procedure, and provide funding for
relevant projects, these efforts form the extent of their safety leadership. While these actions
provide a foundation, there is room for improvement in senior-level safety leadership.

Currently there is no senior operational leaders with a safety accreditation to date, however the
wider organisation does employ a safety director the impact at site level is limited. Additionally,

P a g e 20 | 37
there is no site level champion for health and safety, leaving the leadership without a central point
of contact for this critical topic. As a result, personal opinion and operational goals influence decision
making and whilst Health and safety issues may occasionally be discussed in leadership meetings, it
is not a standing item. While the senior management team has signed the health and safety policy,
they have not established measurable key performance indicators as recommended by the HSE in
HSG654. This responsibility is delegated to the Health and Safety Manager for decision and
implementation.

The operational function faces challenges in convincing managers that health and safety issues are
as important as operational goals. Line managers have conveyed a perception that their working
environment is already safe and that the responsibility for safety, health, and welfare rests with the
safety manager and team. Non-operational support functions, such as HR, Finance, and IT, have
indicated no involvement in safety matters, suggesting that safety concerns are limited to
warehouse floor and yard areas only. Despite leadership's emphasis on safety, the reality is that it
receives limited to no consideration in day-to-day operations. As a result, some form of awareness
training to aid understanding of their responsibilities would be beneficial.

Local leaders are kept informed of the organization's significant risks, including those beyond health
and safety, through regular updates from the senior management team via team meetings and the
company newsletters. However, they may not be fully aware of how effectively strategic risks are
being controlled.

At the Senior leadership level, there is little indication that health and safety issues are being
integrated into wider business decision making beyond critical issues. Safety considerations are
typically only addressed in cases where they are obvious, such as through change management or
upon review of a serious injury. Occupational health concerns are discussed at leadership level but
are often motivated by kpi achievement. Whilst the wider business has engagement of an external
occupational health provider, they have not inquired about the state of occupational health within
the organization, and the use is reactive and not used as preventative but to limit legal liability.

It is recommended that senior managers take a more proactive approach to engage with
occupational health issues, which would demonstrate a greater level of commitment to the
wellbeing of employees.

Leadership are provided with key safety metrics but the Safety Manager is provided with a limited
time slot to provide details and engage on the safety topic as part of leadership team meetings. As a
result it is evident that the leadership are focussed on lagging indicators and have limited leading
indicators which are reviewed and actioned.

P a g e 21 | 37
Management
Health and safety management follows the HSE 65 guidelines, which provide a systematic approach
and ensure compliance with the Management of Health and Safety at Work Regulations 1999
(Regulation 5). The health and safety policy document includes an 'organisation' section that outlines
management arrangements by job title. The Managing Director is responsible for providing adequate
resources and ensuring that all staff members are competent to carry out their work safely. Middle
managers have day-to-day responsibilities, while supervisors have even more tactical day-to-day
responsibilities for the safety of themselves and their team or cell.

Currently, health and safety responsibilities are defined in individual job descriptions, but are largely
generic and may reduce the personal connection employees have with the safety message. To
increase ownership of safety among all workers, it would be beneficial to include specific health and
safety roles and responsibilities in their job descriptions.

If a line manager encounters a health and safety issue they are unable to resolve independently,
they can seek advice and support from the health and safety team, led by the Health and Safety
Manager. In practice this often results in all safety issues being delegated or escalated to the safety
team which results in a lack of ownership on safety issues.

Over the past XX months, significant improvements have been made to the management system
within the site since the appointment of the Health and Safety Manager. This has been
supplemented with improved central team actions after a focus on the global pandemic took focus
away from routine compliance issues and continuous improvement activities. The organisation has
enhanced its day-to-day safety management practices, resulting in a decrease in accident rates (as
seen below). The Health and Safety Manager's advice is well-received by the management team and
there is an increasing number of instances where local managers actively seek safety input from the
safety team.

The positive impact of the Health and Safety Manager's appointment has been notable, with
improved safety practices and better communication among staff. Accidents rates have decreased as
a result of these measures, and local managers have shown a growing appreciation for the
importance of safety within the organisation. In addition, employees have been encouraged to
engage on safety issues and report concerns which has helped drive improvement in the safety
culture across the site.

The central Safety team has a number of specialist SME’s for consultation in cases where the Health
and Safety Manager is unable to provide advice. This includes topics such as load securing,
ergonomics, dangerous goods, electrical and fire safety. Additionally, the company contracts an
occupational health provider which offers health surveillance examinations for key roles and general

P a g e 22 | 37
health support for all employees. In addition, the company provide private medical cover to all
employees along with a number of mental health services such as a 24hr phoneline for support.

The site has implemented several health-based initiatives to promote the health and safety of its
associates. These initiatives include providing free fruit in the canteen on a weekly basis, offering
free flu vaccinations, and conducting regular awareness campaigns with the support of the
occupational health provider. These efforts have helped to raise awareness and prioritize
occupational health at the site, resulting in a positive culture of health and safety.

Communication of information
Health and safety information is communicated to members of staff in a number of ways and there
is a reasonable degree of confidence that people understand the risks and control measures
associated with their work. The methods are tailored to the various audiences at the site with a
conscious effort to give the viewer the information they want.

ATS has a large health and safety notice leadership, positioned in the site reception area and close to
the clocking machines. However, it cannot be guaranteed that all members of staff will take notice
as their focus is on clocking in or on departing site.

Health and safety are also included within a monthly newsletter, which is posted around the site in
break areas, toilet stalls and communal areas. A section of the newsletter is dedicated to health and
safety stories, successes and awareness raising.

The site also utilises TV screens in department briefing areas to display safety messaging which is
changed on a monthly basis.

Risk assessments are available for anyone to view, although feedback from employees is not positive
and requests are for a simpler format with little attention paid to the risk assessments. To address
this the site has made VSOPs more available in each department. Each VSOP points out critical risks
and required PPE and the visual format has been well received by employees.

The site has access to a huge amount of safety data which is presented to leadership on a weekly
basis and on occasion to employees through visual representation see fig XX.Display of actual data is
seen as a risk as media interest on the companies safety practices. As a result the display of
percentages or visual representation is seen as a solution and has been well received by the
employees at the site.

P a g e 23 | 37
Fig XX – Visual representation of first aid injuries at ATS

Control of contractors
The primary group of contractors consists of third-party carrier-employed HGV drivers, sourced by a
centralized team in accordance with forecasted volumes. Across the European Union, the business
collaborates with an estimated 20,000 carriers. However, the absence of a formal selection system
raises a significant concern. Current selection hinges on minimum criteria, with the priority merely
on the availability of drivers and trailers, rather than the quality or safety record of the contractors.

P a g e 24 | 37
Fig XX – Contracted Driver Events 2022

This lack of control and stringent selection criteria for contractors have led to significant issues.
There have been several incidents relating to on-road safety and on-site procedures where
contractors, due to their inappropriate working methods, have jeopardized their safety and that of
others. Such lax contractor selection processes may inadvertently invite risks, emphasizing the
urgent need for a robust, safety-oriented contractor selection and management system.

Whilst most cases are low severity the cost of associated incidents due to property and vehicle
damage was estimated to be in excess of £21k in 2022.

The development of a comprehensive contractor selection system is critical, aimed at establishing a

directory of approved contractors. This system should prioritize not just the capacity to deliver
services but also the quality of those services, focusing on areas like safety records, professionalism,
and reliability. Consequently, a well-structured contractor pre-qualification questionnaire is in the
process of being formulated, with the objective of ensuring only the highest-quality contractors are
selected.

In addition to this, it is important to extend our support to contractors through the provision of
training resources. This aids in bolstering their skills, ensuring safety, and maintaining quality
standards, which in turn results in improved service delivery.

Moreover, the initiation of a carrier recognition scheme is recommended. This scheme would reward
exceptional carriers with improved terms and increased work opportunities, thereby incentivizing
quality and safety performance.

Finally, a robust system for the close monitoring of safety performance for all carriers is essential.
This system should not only provide support and resources for safety improvement but also
incorporate penalties for instances of poor performance. Further elaboration on contractor control
can be found in the 'Competence' section later in this report.

P a g e 25 | 37
Review
Currently, the review of health and safety performance is managed at the local level, with the
analysis of trends being reported to the leadership on a monthly basis. However, this approach
prioritizes significant safety incidents, often neglecting a broader perspective on safety performance.
This lack of a strategic review by senior management is in contrast with the stipulations of the UK's
Health and Safety at Work Act of 1974, which emphasizes the employer's duty to ensure the health,
safety, and welfare of all employees (Health and Safety at Work Act, 1974, p. X).

In addition, the requirement for local line managers to report safety metrics from their departments
does not include a mandate for a detailed analysis of these metrics. However, a proactive approach
to safety performance could be fostered by empowering line managers with greater responsibility,
as suggested by the Management of Health and Safety at Work Regulations of 1999 (Management of
Health and Safety at Work Regulations, 1999, p. X).

The facilitation of this process could be achieved through regular safety training programs, the
implementation of a performance-based evaluation system that incorporates safety metrics, and
obligatory participation in safety audits. This recommendation is supported by the HSE's guidance on
Leading Health and Safety at Work (Health and Safety Executive, 2007, p. X).

Moreover, there is a need to transition from a reactive to a proactive approach in reviewing safety
performance. This could be realized by implementing a comprehensive system for tracking incidents,
which would help identify trends and potential issues before they escalate into significant incidents.
Such a system aligns with the guidelines provided by the Reporting of Injuries, Diseases and
Dangerous Occurrences Regulations 2013 (Reporting of Injuries, Diseases and Dangerous
Occurrences Regulations, 2013, p. X).

By cultivating a mindset of continuous improvement and routinely updating safety protocols based
on feedback, we can facilitate the ongoing improvement of safety performance. The organisation's
focus should be reoriented towards prevention rather than reaction, as encapsulated in the HSE's
"Health and safety made simple", which accentuates the importance of pre-emptive action in
reducing workplace risks (Health and Safety Executive, 2021, p. X).

Worker involvement

The subsection demonstrates most of the aspects of worker involvement.

• Some of the information is substantiated by evidence.

• The coverage is not comprehensive (eg no reference to the needs of the vulnerable worker).

P a g e 26 | 37
• The involvement of workers in risk assessments and associated safe systems of work could have
been expanded on with relevant examples in context.

• Demonstration of research and associated referencing is apparent vis-a-vis HSG65.

• There is little reference to frequent formal / informal meetings, team briefings, one-to-one
discussions, departmental health and safety meetings, behavioural safety feedback meetings, etc.

ATS has a well-established health and safety committee which is comprised of workforce members
elected by their peers. This shows a commitment to consult and involve the workers in safety related
decision making and engage on topics which may impact the workforce. The committee meets
monthly with a set agenda and with minutes published to managers and posted on the Health and
Safety notice board.

The Safety committee also produce a “You said, we did” communication which is displayed as a
snapshot to workers of the problems addressed. This has been well received as a simple way to
understand the outcomes without the need to read through the documented meeting minutes.

The committee members are provided time off task to engage with their colleagues each week and
to also attend the meetings. Members have been asked to escalate any key issues between meetings
to avoid safety issues being left unaddressed between meetings. This change was made after
examples of immediate hazards we brought to the meeting as the committee member wanted to be
seen to be raising concerns within the meeting. This provides more informal and ad-hoc meeting
opportunities. The committee members serve a one-year term and terms mandate a re-election if
any representative misses two successive meetings without good cause. Committee members
cannot be re-elected as the site wants to provide opportunity for wider involvement in the
committee.

In addition, the committee members will be consulted in the development of risk assessments
applicable to their area of work and will be included in any trials that take place . “Worker consultation
and involvement is fundamental in ensuring risks are effectively managed.” HSG65 P.20 In addition ATS
plans to expand the committee to more members representing all shifts are in place although this
will result in meetings being separated the agenda will be common. There are also plans for
committee members to hold departmental meetings to address specific issues unique to their work
environment with support from departmental leads and management.

P a g e 27 | 37
Competence
In compliance with the requirements set out by The Management of Health and Safety at Work
Regulations 1999, an employer is obliged to designate one or more competent persons to aid in the
implementation of measures necessary to meet legal demands.

ATS has adhered to these regulations by appointing a competent individual to assist in meeting its
obligations under health and safety law. This individual holds the role of Health and Safety Manager
and brings a significant amount of experience to the role, specifically five years as an engineering
technician within the manufacturing industry. As such, they are thoroughly familiar with safe
working practices in this environment. In a testament to their qualifications, the Health and Safety
Manager is a holder of a NEBOSH Diploma, evidencing their professional prowess in health and
safety matters.

In support of the Health and Safety Manager are the Health and Safety Assistants. While they
currently do not have formal health and safety qualifications, they are developing in their roles.
These individuals were internally appointed from manufacturing roles, demonstrating ATS's
commitment to nurturing employee progression. At present, these assistants are actively studying
for the NEBOSH General Certificate qualifications, which marks the beginning of their career
advancement in health and safety.

ATS recognises the importance of worker competence in ensuring safety during operations. Workers
are recruited based on their skills and experience. While most of them lack formal qualifications,
they are provided with basic safety awareness training suitable for their tasks. This training
empowers them with the ability to escalate issues to management when necessary. This approach is
not only limited to the manufacturing environment but is also applicable to our scientists and
engineers, whose work is more theoretical and developmental. This ensures a uniform application of
health and safety awareness throughout the organisation, in line with the guidelines outlined in the
Workplace (Health, Safety and Welfare) Regulations 1992.

Induction
Upon commencement at ATS, new employees are provided with a comprehensive induction on their
first day. This induction encapsulates all key areas of work within the company, incorporating a
focused session on health and safety. In this approximately 60-minute segment, the company's
health and safety policy and essential operational safety rules are highlighted. A member of the
health and safety team introduces themselves, ensuring that new hires understand they are
approachable for any concerns regarding health, safety, or welfare, while also detailing how they can
be identified within the workplace.

P a g e 28 | 37
The induction leverages a series of concise videos to elucidate fundamental principles, such as
manual handling and hazardous materials (hazmat) labelling. However, the majority of the health
and safety orientation is conducted within each worker's specific work area. This approach is
designed to ensure relevance and to instil a sense of safety ownership among line managers, who
actively support these inductions alongside departmental trainers.

The induction process for contractors, particularly those engaged in electrical, mechanical, and
similar works around the site, is meticulously coordinated. This process comprises an online
orientation and a pre-qualification assessment to ensure contractors' aptitude for the tasks at hand.

However, the current induction process for third-party drivers is limited to an overview of site rules
and formal acknowledgement. Anecdotal evidence and safety data suggest that contractors are
often not sufficiently informed about site hazards or restricted areas. This gap in knowledge has led
to safety incidents, such as drivers inadvertently connecting to trailers currently being loaded due to
misunderstandings about collection locations. Addressing this deficiency in the induction process for
third-party drivers is a matter of urgent priority.

Identification of training needs

ATS utilises a training matrix, as recommended by the Health and Safety Executive (HSE) in its guide
'Health and safety training: A brief guide' (INDG345). The matrix specifically outlines the necessary
health and safety training for each job role, complementing the health and safety awareness and
skills that many employees bring to the organisation upon joining.

In addition to the training matrix, training needs are also identified during annual personal
development reviews, as suggested by the HSE's 'Managing for health and safety' (HSG65). These
reviews are conducted by line managers to ensure continual professional development.

In line with the HSE's 'Investigating accidents and incidents: A workbook for employers, unions,
safety representatives and safety professionals' (HSG245), if an incident occurs and an investigation
determines that the cause was a knowledge or competence gap, this triggers further training. This
proactive strategy aligns with the HSE's recommendations, ensuring the ongoing improvement of
health and safety standards within the organisation.

Compliance
ATS adheres to a health and safety legal register, which forms the foundation for its compliance with
legal requirements. This register is regularly updated locally with as tasks within the company’s
safety compliance software. The tasks are updated regularly by a central team which are responsible
for relaying this to sites for implementation at site level. These are updated in accordance with any
changes in health and safety law, as reported on the Health and Safety Executive (HSE) website and
in the Institution of Occupational Safety and Health (IOSH) magazine.
P a g e 29 | 37
Given that the company's safety management system aligns with HSG65, 'Managing for health and
safety', there are no external compliance issues. The Health and Safety Manager diligently ensures
that the safety management system reflects the stipulations of HSG65, as relevant to the
organisation. The completion of the tasks is audited annually, with the findings serving to promote
continuous improvement, as recommended within HSG65.

In addition, the company’s insurance companies enforce specific requirements to ensure that safety
risks within the site are effectively managed. Of particular concern is fire safety due to the significant
potential loss should a fire occur due the value of held stock and equipment such as MHE and
conveyance. Annual visits from insurance assessors provide insights on how risks could be better
managed, assisting the organisation in potentially reducing its insurance premium. This approach is
in line with the HSE's 'Fire safety in the workplace' guide, which emphasises the importance of risk
management and continual review of fire safety measures. In addition, the site hosts an annual
inspection from the local fire service to update on any layout changes and update emergency plans.

Evaluation of priorities
After conducting a critical analysis of current health and safety arrangements at ATS the following
priorities have been identified:

1. A requirement for greater visible leadership and ownership from the senior management team.
2. Improved control of external drivers
3. Improved load securing controls to ensure on road safety

Visibility and accountability of Operational Management and Leadership

Currently the priorities of the management team are to the metrics to which they are accountable.
Commitment to safety is shown only through the signing of the site health and safety policy and
through sponsoring of safety initiatives led by the Safety Team. Often the workforce is sceptical of
the commitment to safety and demonstrate this through their own individual attitudes towards
safety. The commitment of leadership towards safety is evident but to move to the next level there
needs to be a more visible focus on safety from Leadership to demonstrate a desire to change the
safety culture within ATS.

Leadership need to be seen to be setting an example to the workforce, addressing safety issues
alongside the workforce. This over time will lead to benefits such as increased efficiency and
productivity, reduced rates of accidents, reduced ill-health, an engaged workforce, improved worker
retention, reduced insurance premiums, reduced likelihood of enforcement action and improved
reputation.
P a g e 30 | 37
Such change will take time and will require a long-term commitment from leadership to manage
safety in a diligent, consistent and unwavering manner. The first stage will be to enrol all leadership
on a suitable training course to educate on the fundamentals of Safety Management, such as IOSH
Managing Safety or similar. This will allow management to feel confident in addressing safety issues
and will be a clear indicator to the business of their intent to improve the safety culture at the site.
In future managers can be offered the opportunity to complete further qualifications such as Nebosh
General Certificate or similar.

The Health and Safety Manager is key to the site-level deployment. Initial actions include approval of
the finance with the site Manager and Finance Manager. Then the sourcing of an accredited training
provider and arrangement of the required sessions. The estimated cost of training would be in the
region of £1000 plus the attendee’s time.

Participation of senior management should be disseminated site-wide, underlining their

commitment to safety and ensuring accountability. If successful, this initiative may serve as a model
for broader organizational implementation.

To aid the visual presence and demonstrate a commitment to safety it is suggested that two changes
are made to managers routines.

Weekly Safety Walk

A weekly site tour led by the site lead or a proxy from the senior management team and the Safety
Manager to be conducted on a route which passes through all departments and key areas. The tour
will address hazards, engage with employees and look at issues arising from incidents or near miss
reports. The tour can be rotated to focus on specific areas such as Inbound, outbound, yard or
communal spaces depending on the time dedicated to the tour. In addition, members of the safety
committee can be included to support and help addressed raised issues in their area of work.

Depending on the route and issues raised during the walk, there would be an expected time
commitment of 30-60 minutes per week.

Safety Audit
Middle management and leads should complete a daily audit of their department alongside an
employee. This would help engagement on safety, address local safety concerns and give all
employees an opportunity to be actively involved with improving safety in their work area. The audit
would include a set of questions specific to their work area and would be open questions to
encourage discussion with the employee. The results would be a compliance percentage score, but
would also create actions that can be tracked within the department to show follow up and
continuous improvement.

P a g e 31 | 37
Improved control of external drivers
The sites yard has recently experienced issues related to third-party drivers, including confusion of
trailer collection, minor collisions, property damages and neglect of Personal Protective Equipment
(PPE), and unfamiliarity with yard safety rules and regulations. This should be addressed as a priority
as there is a significant risk of vehicle and pedestrian interaction and potential injury as a result.
Implementing the following for recommendations will create a safer, more efficient environment in
the yard.

Improved Orientation and Training

The Health and Safety at Work Act 1974 stipulates general duties for employers to ensure the
health, safety, and welfare of all their employees and those affected by their work [1]. According to
this legislation, it is vital to provide third-party drivers with thorough on-site orientation. The
orientation should include trailer allocation procedures, yard navigation instructions, guidelines on
proper use of PPE, and a comprehensive briefing on yard safety rules. This comprehensive training
will aid drivers in better understanding their responsibilities and the safety protocols, reducing the
risk of confusion and accidents. It is recognised that this is difficult due to the number of carriers and
therefore an online training should be developed to enable orientation prior to arrival at site.

Signage and Traffic Management

Another essential facet of maintaining safety and efficiency in the yard is traffic management and
effective signage, as required by The Management of Health and Safety at Work Regulations 1999
[2]. Clear, strategically placed signage can assist in directing traffic within the yard, indicating trailer
locations, and reminding drivers of the necessity to wear PPE. Furthermore, clearly delineated
pedestrian and vehicle zones can be established, reducing the likelihood of minor collisions. These
measures will foster a more controlled and less hazardous environment.

Enforcing PPE Usage

Under the Personal Protective Equipment at Work Regulations 1992, employers have a responsibility
to ensure that suitable PPE is provided and worn [3]. Implementing mandatory PPE checks at the
yard entry point can enforce this rule for third-party drivers. These checks would ensure that all
drivers entering the site have the necessary equipment to perform their tasks safely.

Compliance Monitoring
Finally, the implementation of regular monitoring and auditing practices will ensure ongoing
compliance with these safety measures. In line with the Workplace (Health, Safety and Welfare)
Regulations 1992, which emphasise the maintenance of a safe working environment [4], these

P a g e 32 | 37
practices will enable the management to identify and rectify any shortcomings swiftly. Regular audits
also demonstrate the company's commitment to maintaining high safety standards.

Improved load securing controls to ensure on road safety

As stated by the European Best Practices Guidelines on Cargo Securing for Road Transport [1] and
the UK Department for Transport Code of Practice: Safety of Loads on Vehicles [2] a correctly
configured load is crucial for on-road safety and is significantly influenced by effective load securing
controls within warehouse operations. There is currently a gap to effective control of load securing
at ATS and to address this a series of strategies should be introduced to improve these controls. The
implementation of these strategies can significantly improve road safety by ensuring secure loads
and are grounded in UK and EU legislation. Adherence to UK and EU legislation and regulations is
integral to the company's operations. Non-compliance can lead to severe consequences, including
legal action, potential harm to employees and other road users, and damage to the company's
reputation.

Employee Training
In line with the European Agreement Concerning the Work of Crews of Vehicles Engaged in
International Road Transport (AETR) [3] and the UK's Health and Safety at Work Act 1974 [4],
comprehensive employee training is a prerequisite for effective load securing. Therefore an
employee training package should be developed to address the following key topics. The in house
learning and development team can deliver a short training package designed alongside key partners
such as shrink wrap suppliers and carrier partners.

Pallet Wrapping: Pallet wrapping is a fundamental component of load securement. It is essential for
the protection of goods, enhancing safety, and ensuring regulatory compliance. Properly trained
employees can wrap pallets correctly to avoid product damage, improve handling and efficiency,
comply with regulations, and uphold the company's professional image.

Correct Load Configuration: Training should emphasize the importance of correct load
configuration. It includes understanding the importance of an evenly distributed load, avoiding
vehicle overloading, and correct use of suitable load restraints to prevent loads shifting.

Correct Load Securement: Ensuring the correct securement of the load is another crucial element in
the training program. Comprehensive training can provide employees with the knowledge and skills
to safely secure loads to prevent loads shifting during transit. The training should include the
application of load bars and straps and should consider the potential variation of equipment within
the current carrier partner network.

All these training aspects aim to equip employees with the necessary skills and knowledge to
perform their roles safely and effectively. They also help ensure the company's compliance with UK
P a g e 33 | 37
and EU regulations, significantly reducing the risk of on-road incidents due to improper load
securing.

Managerial Checks and Audits

Adding another layer of control, managers should perform routine checks and audits to ensure
compliance with load securing regulations. Regular auditing of procedures not only aids in
identifying and rectifying any issues quickly but also ensures ongoing compliance with safety
measures, in line with the Workplace (Health, Safety and Welfare) Regulations 1992 [5]. These
checks can serve as a deterrent for non-compliance and encourage adherence to established safety
practices.

Driver Load Inspections and Use of Load Plans

The Road Traffic Act 1988 [6] and the EU Regulation 561/2006 [7] assign drivers with the
responsibility for ensuring load safety. Consequently, providing drivers with an opportunity to
inspect their load prior to departure is crucial. In this context, load plans can be an invaluable tool,
offering a visual guide to correct load configuration and restraint. It is therefore suggested that ATS
introduce a simple load plan for loaders to complete showing the configuration of the load, the
restraints used throughout the loading process. In addition, the driver should be given the
opportunity to review the plan, inspect the load and request amendments if required prior to
departure.

Conclusions and recommendations

This report endeavoured to assess the efficacy of safety leadership, management, and worker
involvement at ATS, with the goal of formulating recommendations for enhancing the organisation's
health and safety performance.

As part of this objective, an evaluation of the safety management was carried out, revealing several
key findings:

1. While safety leadership is in place, there is room for its development as a priority for all. The
current KPIs do not emphasise safety as a site priority, and there's a perception that safety
management lies solely with the safety manager and their team.

2. The management system, developed in line with HSG65, is functional but has areas that
could be improved, notably contractor control, which should be extended to include visiting
drivers.

P a g e 34 | 37
 3. Employees are generally engaged and proactive in health and safety matters. With an
established safety committee, there is a shared interest in progressively enhancing health,
safety, and welfare standards.

4. Most hazards are adequately controlled, with exceptions being pedestrian interaction in
yard areas and load securement. These areas require immediate assessment to prevent
potential incidents.

The senior management team has exhibited a supportive stance towards health, safety, and welfare
improvements, providing resources when a tangible benefit can be demonstrated. This proactive
approach forms a solid foundation for ATS's further development.

It is advised that senior managers participate in an executive-level health and safety training course
to gain a deeper understanding of their personal health and safety management responsibilities.
This could act as a catalyst for systemic improvements. Further recommendations include senior
managers' active involvement in daily safety initiatives, such as conducting safety walks and
participating in site-wide safety audits.

These proposed changes hold promise not only for improving ATS's safety performance but also
enhancing efficiency, staff retention, and worker engagement. The initial investment for training and
time allocation for these initiatives is modest compared to the substantial potential gains.

ATS's health and safety management system exhibits commendable robustness and organisation,
particularly evident at the site level and supported by the central compliance team. This focus on
safety continues to be a priority, meriting continuous development and improvement. Although
contractor controls, encompassing comprehensive onboarding and robust permit-to-work systems,
are robust, a gap in managing external drivers has surfaced.

This gap calls for immediate rectification given the heightened risk of severe accidents involving
drivers or employees in the yard area. Any potential incident could attract undesirable attention
from enforcement authorities, possibly leading to production delays and incurring associated costs.
These could encompass incident investigations, remedial measures, an escalation in insurance
premiums, court fees, among others. Thus, to attenuate these risks, it is crucial to augment safety
measures for external drivers operating in the yard area.

Employees generally demonstrate active engagement in health and safety matters at the site. Given
an established safety committee, a collective aspiration exists to steadily improve health, safety, and
welfare standards. This dynamic should be leveraged to ensure broader participation through
activities such as safety walks and daily safety audits. Such inclusive engagement, along with

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managerial participation, will cultivate a culture of safety, reinforcing the understanding that
improvement stems from a collective endeavour.

While the management of most risks is comprehensive, two areas demand immediate attention. The
first pertains to the interaction between pedestrians and vehicles, intrinsically linked to contractor
driver control. Enhancements can be made via better yard management, stricter PPE control, and
improved communication regarding yard rules and requirements for visiting drivers. The second
issue relates to the insufficient control measures surrounding load securement, necessitating
improvements in employee training, introduction of load plans, driver inspections, and auditing of
the process to ensure on-road safety requirements are upheld.

References

[1] European Best Practices Guidelines on Cargo Securing for Road Transport. (n.d.). Retrieved from
www.ec.europa.eu

[2] Code of Practice: Safety of Loads on Vehicles. (n.d.). Retrieved from www.gov.uk

[3] European Agreement Concerning the Work of Crews of Vehicles Engaged in International Road
Transport (AETR). (n.d.). Retrieved from www.unece.org

[4] Health and Safety at Work Act 1974. (n.d.). Retrieved from www.legislation.gov.uk

[5] Workplace (Health, Safety and Welfare) Regulations 1992. (n.d.). Retrieved from www.leg

[6] Health and Safety at Work Act 1974. (n.d.). Retrieved from www.legislation.gov.uk

[7] EU Regulation 561/2006. (n.d.). Retrieved from eur-lex.europa.eu/legal-content/EN/TXT/?

uri=CELEX:32006R0561

References
Cullen, W., Guldenmund, F., & Kelly, N. (2018). Health and safety risk management. Routledge.

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Health and Safety Executive. (2013). Risk assessment: A brief guide to controlling risks in the
workplace. Health and Safety Executive.

Breslin, D., Meservy, T., & Hasson, R. (2021). The Role of the Safety Professional as a Strategic
Business Partner. Professional Safety, 66(2), 32-39.

Kazi, A., Haslam, R. A., & Memon, A. R. (2018). Can occupational health and safety climate predict
job satisfaction and work commitment? Journal of Business Research, 86, 258-268.

Health and Safety at Work Act. (1974). Her Majesty's Stationery Office.

Management of Health and Safety at Work Regulations. (1999). Her Majesty's Stationery
Office.

Health and Safety Executive. (2007). Leading Health and Safety at Work. HSE Books.

Reporting of Injuries, Diseases and Dangerous Occurrences Regulations. (2013). Her

Majesty's Stationery Office.

Health and Safety Executive. (2021). Health and safety made simple. HSE Books.

Organizations face numerous risks that can affect their employees, reputation, and financial
standing. The role of the Health and Safety Manager is crucial in managing health and safety
risks and ensuring that they are given the same importance as other business risks (Breslin et
al., 2021). Despite the culture of speed and pressure to deliver, Health and Safety Managers
must remain diligent in reminding senior management of the importance of maintaining high
health and safety standards to protect the workforce and the company's reputation (Cullen et
al., 2018). This can be achieved through effective communication with site leadership and
regular reporting of health and safety performance.

By implementing effective health and safety management systems and ensuring that they are
given equal importance to other business risks, organizations can protect their employees and
reputation while achieving their business objectives.

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