Name: Carl Bater

Unit: 8623-418 Manage Health and Safety in own area of responsibility

1 Understand responsibilities and liabilities in relation to health and safety legislation

1.1 Evaluate personal responsibilities and liabilities under health and safety legislation

As an employee of Conwy LEA, my legally defined responsibilities and liabilities are defined by the
health and safety act as follows:

i. I have personal responsibility to look after my own health and safety, and that of other
people that nay be affected by my work.
ii. I am required to inform my employer of any dangers to health and safety caused by any
work activity.
iii. I am required to inform my employer of any shortcomings in any arrangements in place to
protect health and safety.
iv. I am obliged to not do anything that compromises any protective arrangements in place to
protect health and safety.
v. I am required to conform to my employers health and safety measures.

In practice, as a teacher of science, this places a binding requirement on me to operate in a safe and
legal manner, not only to protect my own health and safety, but also the health and safety of my
colleagues and the pupils in my classes. To this end, I am expected to undergo relevant training in
the use of various practical apparatus (and to keep this training up to date), as well as to engage with
internal health and safety audits to identify any shortcomings. These duties are clearly spelt out in
Ysgol Eirias Health and Safety policy document:
1.2 Describe an organisation’s responsibilities and liabilities under health and safety legislation

Similar to the obligations outlined in section 1.1, the Health and Safety Act 1974 sets out legal
requirements for employers with regards its responsibilities and liabilities. These are as follows:

i. My employer is expected to provide a safe place in order for me to undertake my duties

ii. My employer is obliged to ensure safe access into and out from the place of work.
iii. My employer is legally obliged to enable access to support and training in relation to Health
and Safety.
iv. My employer is responsible for ensuring the safety of the working environment where risks
are kept to as low a level as is practical.

In practice, as a school, this means my workplace is required to provide me with a teaching

environment that presents no inherent risks to myself, my colleagues, or the learners we are
responsible for. In addition, if we have any training requirements linked to the use of technical
apparatus the school is obliged to enable access to said training. Ysgol Eirias policy document states
these high-level requirements in the following sections:

1.3 Identify specialists to consult with when health and safety issues outside own remit are
identified

The “Electricity at Work Regulations (1989)” state that all electrical equipment that has the potential
to be a risk to health and safety must be maintained in good working order to minimise this risk. UK
government guidance to schools makes to specific ruling as to how this requirement is met, or how
often appliances are to be tested. However, schools are still required to produce evidence that they
are fulfilling this obligation, and PAT testing is a good way of doing so. This is a test carried out by a
competent individual that checks for the safety of a mains device that can be moved. Any devices
that fail the test are deemed unsafe for use and should not be used. As nominated individuals, The
school’s deputy head responsible for Health and Safety (Drew McKenzie) and the school’s business
manager (Gwyn Jones) are responsible for arranging PAT testing on an annual basis. Typically, a local
electrical contractor is commissioned to carry out the testing of many hundreds of devices during
the summer holidays. Tested devices are marked with a green “pass” sticker featuring a timestamp,
or a red “failure” sticker, and taken out of circulation until repaired or disposed of. By maintaining a
record of this PAT testing, Ysgol Eirias ensures it is compliant with this branch of health and Safety
Law. The schools Health and Safety policy identifies this here:

Within the science faculty, there is a curriculum requirement to perform a range of practical
activities. These require the use of substances and apparatus that present risks to Health and Safety.
As a school we have adopted the COSHH procedures to help manage the risks presented by
hazardous substances. Wherever practical, Science staff follow CLEAPPS guidelines via the
HAZCARDS system. These provide easy to understand and at a glance support and advice about how
to safely use a range of substances, and also what actions to take in the event of accidents and
spillages. The school’s health and Safety policy document stets the following in relation to hazardous
substances:

Here is an example of a CLEAPPS HAZCARD for Sulfur Dioxide:

The science department also holds a source of ionising radiation. CLEAPPS document L93 titled
Managing Ionising Radiations and Radioactive Substances in Schools and Colleges, which spells out
the legal obligations, as well as best practice, is used to ensure that the school meets its obligations
in the safe and proper use of this potentially hazardous material. As part of the best practices the
school is required to appoint a Radiation Protection Supervisor. This just so happens to be myself. I
am required to keep our policy and practices in relation to the ionising radiation source up to date,
to monitor its condition, usage, and storage, and to ensure that staff are informed with any changes
to policy or best practice, as well as liaise with Drew McKenzie and Gwyn Jones in their role of H+S
leads. As part of our legal obligations, part of the role of the RPS is to report to a Radiation
Protection Officer and a Radiation Protection Adviser. The RPO role is undertaken by Conwy Council
Health and Safety executive – they are responsible for ensuring compliance to the relevant laws
surrounding the storage and use of the ionising radiation source by the school. The RPA role is filled
by a technical expert from the company MainCal. This individual is responsible for periodically
visiting Ysgol Eirias to inspect our implementation of policy and best practice. This inspection allows
them to prepare an advisory report as to how best meet our legal obligations surrounding the
storage and use of a radioisotope.

Extract from L93, showing information on the use of a typical classroom source:
Recently, changes to L93 meant that we were legally required to dispose of one of our radioactive
sources. CLEAPSS guidelines specified that this source needed to be disposed of via a method known
as “Grout and Dustbin”. CLEAPPS provide a step-by-step method as to how carry this out, and it was
followed to the letter. As part of this method, both the RPO and RPA are required to be informed as
shown, in order for them to confirm that disposal has occurred in a legal manner.

A recent Health and Safety issue at Ysgol Eirias that has required external consultation has been the
discovery of roof structures that potentially contain asbestos. As part of the management of this
potential health and safety risk Ysgol Eirias has consulted with the relevant council bodies to
formulate a management plan that complies with all relevant health and safety law. Below are some
extracts from this policy.
This policy clearly identifies how Ysgol Eirias has consulted with outside agencies as a result of how
the health and safety risk lies beyond the sole responsibility of the school itself.

2 Understand how to assess, monitor and minimise health and safety risks in own area of
responsibility

2.1 Describe the types of hazards and risks that may arise in relation to health and safety

When thinking about health and safety, “hazards” are defined as potential sources of harm to a
person. In terms of health and safety, “risk” is most commonly defined as the likelihood that a
person may be harmed if exposed to a hazard.

Considering my own area of practice, one basic potential hazard would be the spillage of water
during a science practical. This hazard creates the risk of a pupil slipping and coming to harm as a
result of the spillage. This would necessitate the implementation of some basic control measures in
order to manage the risk. Pupils would be moved away from the area initially. A wet floor warning
sign would be placed to identify the risk to those in the area. The risk would then be eliminated by
mopping up the water spillage.

A second basic hazard would be the high temperatures and exposed flames associated with the use
of a Bunsen burner for heating substances during a science practical. These high temperatures and
flames present the risk of someone burning their skin if they contact the flame, or of starting a fire
through accident or improper use. One way of managing the potential risk is through the
enforcement of proper working practices in order to minimise the probability of burns or fires.

2.2 Explain how to use systems for identifying hazards and assessing risks

Prior to performing any new science practical, it is departmental policy for all teaching staff to
conduct a basic risk assessment using CLEAPSS HAZCARDS as a basis for identifying hazards, and to
perform the practical themselves in advance of using it in a lesson to familiarise themselves with the
potential for risk. This is enforced by our lab technicians, who check with staff members that they
are aware of potential health and safety issues as part of our general operating procedures when
fulfilling practical requisitions. In section 1.3 I referred to a specific HAZCARD:

A common practical linked to Sulfur Dioxide is

the chemical reaction between Iron and Sulfur
to demonstrate the forming of a compound
from two elements. Moderate amounts of SO2
are produced as a by-product. By consulting
the relevant HAZCARD, teachers are made fully
aware of the risks associated with this specific
hazard, and actions to take in the event of any
of these risks occurring. However, the smell still
takes many people by surprise the first time
they encounter this substance!
As a faculty, we maintain extensive guides as to the hazards and risks inherent in practical work:

All staff are signed off by our senior technician when she is satisfied that we understand the
guidance in this particular policy document.

As part of practical work, it is a standard requirement for pupils to complete a basic risk assessment.
This is specified by the WJEC exam board, who provide pupils with a simple template (included
below) for identifying Hazards, Risks, and Control Measures:

This ensures that learners are made aware of any potential hazards and risks in advance of
performing any practical work, and also of what control measures they are expected to follow.

Further to this, specific items of apparatus have “standard operating procedures” clearly defined as
a result of inherent health and safety risks associated with their use. Three notable examples of this
would be our laser source, out Van der Graaf generator and our ionising radiation source. The first
two are only to be used after a new staff member is signed off by a competent individual (typically,
head of faculty, head of department, or senior lab technician) has instructed them in the safe and
proper use of the apparatus. The use of the ionising radiation, as discussed earlier, is at the
discretion of the named RPS – myself. I am responsible for ensuring that staff members are trained
in following the standard operating procedures that minimise all health and safety risks created
through exposure to ionising radiation. A section of the lengthy standard operating procedure is
shown below:

The standard operating procedure, along with the risk assessment for the source shown in section
1.3, along with all other relevant documentation, are stored in a defined location in the school near
the storage safe that the source is required to be locked in. One of these documents is a log. This log
identifies who has used a source, when it was used, and how long for. The purpose of this is to
ensure that no individual exposes themselves or their pupils to a harmful level of ionising radiation.

One major concern with regards the identification of hazards and risks in relation to health and
safety is the planning of extracurricular trips. Our whole school policy identifies a system of best
practice where any potential trip is planned initially using the EVOLVE planning system – an set of
web based software that uses a standard template to collate and communicate all relevant
information about a trip to all involved.

Once the EVOLVE form is completed, the proposed trip is then submitted to a named “Educational
Visit Co-Ordinator”. This is done by adding an entry to a centrally managed spreadsheet. The EVC
then either checks and submits to the headteacher for approval, or checks and approves themselves.
As shown in the school policy, some level of risk assessment appropriate to the planned activity
must have taken place as part of the trip planning.
While completing the EVOLVE form, Conwy LEA require staff to make use of guidance sheets that
indicate a wide range of hazards and risks that might feature as part of an extracurricular trip. This
makes sure that there are no oversights in planning for health and safety.

Through the use of EVOLVE, and the Conwy LEA guidance, teachers and schools can be satisfied that
they have met their health and safety obligations, identified any and all relevant hazards and risks,
and have plans in place to follow in the event of any incidents.

2.3 Explain how to monitor, evaluate and report on health and safety within own area of
responsibility

2.4 Describe the types of actions which should be undertaken to control or eliminate health and
safety hazards

One example of an “active system” that monitors health and safety hazards that I am personally
responsible for within the science department at Ysgol Eirias is the ongoing work required as part of
the best practice in using ionising radiation sources as described by CLEAPSS L93.
As already discussed, a log must be filled in whenever the source is used. I am required to make a
monthly visual check of the source and its storage arrangements. Annually, I am required to perform
and record a “leak check” where the level of activity of the source is measured, and an assessment
of its continued integrity is made. This annual check also includes a more detailed analysis of the
storage arrangements.

In addition to the “active” system discussed above, L93 also describes a number of “reactive”
systems. In the event of an incident involving the radioactive source, I am the initial person of
contact with responsibility for co-ordinating any response. L93 contains a guide to best practice in
the event of a health and safety issue linked to the use of a radioisotope, and describes a range of
potential health and safety risks that could arise through the use of an ionising radiation source.
Some minor ones are included below. For each incident, there are specific actions to undertake in
order to prevent any risks to health and safety. Any incidents require logging, and also require the
RPO and RPA to be informed of any details, including my response, if relevant. To date, we have not
had a single incident.

A similar pair of “active” and “reactive” systems are in place in the science department led by our
senior technician with regards the use of chemical substances that may present a risk to health and
safety. Our faculty health and safety policy is based on CLEAPPS guidance, and reviewed and
updated annually. As discussed earlier, we maintain an up-to-date guidance document regarding
best practice in the use of a range of substances, including how best to respond to incidents. The
technician ensures that staff wishing to use potentially hazardous substances have consulted the
relevant HAZCARDS. As a faculty we maintain an incident log to check both incidents and our
responses – in section 2.2 I included a screenshot of our “working guidelines” for some basic
expected incidents. Fortunately, it is very rare that any are logged. Below is an extract from this
policy document that details the individuals with responsibility for health and safety in all relevant
areas.

All labs and science prep/storage areas are annually “inspected” for potential health and safety
issues as an “active” measure. This is done internally as a faculty, and our findings feed into an
annual school wide health and safety review (completed as an excel spreadsheet, discussed in a later
section), and added to a maintenance log (available via the schools Teams account). The aims of
both are to identify any potential hazards before they cause anyone to come to harm. Issues
identified by these reviews are either dealt with by our science technicians, in school maintenance
staff, or external agencies – whichever is most relevant. Annual reviews to our fume cupboards are
carried out each November as part of “active” monitoring of health and safety. PAT testing is
another area of “active” monitoring, occurring each summer.

An example of a school wide “reactive” health and safety policy is the use of a standardised LEA
accident form. Any accidents require one of these forms to be filled in. the form is then reviewed
and logged by Drew McKenzie in his role as health and safety lead, before deciding if any further
action needs taking.
It is stated in the whole school policy regarding health and safety that all incidents are taken
seriously, and used as a learning experience in order to prevent repeat incidents.

This combination of both continual and scheduled “active” monitoring and comprehensive
“reactive” reporting act to protect the health and safety of all working in the school.

3 Be able to review health and safety policy in own area of responsibility

3.1 Review written health and safety policy against requirements for own area of responsibility
3.2 Communicate any recommendations for changes to health and safety policy to relevant
individuals.

5.5 Evaluate health and safety requirements in project or operational plans within own area of
responsibility

For this section, I will focus on my health and safety obligation in my role as RPS. The guidance
document L93 contains a checklist of obligations relating to health and safety that I am expected to
fulfil.

 The school has informed the HSE of the usage of a

source of ionising radiation in writing.
 An RPA and RPO has been appointed via the CLEAPSS
advisory service.
 As discussed, I hold the role of RPS.
 Standard operating procedures and contingency plans
are applied.
 The source is stored according to guidelines.
 Appropriate monitoring apparatus is available (GM
tube of at least 15mm diameter, suitable
scaler/counter).
 The Fire service has been informed in writing of the
use and storage of the source.
 All logs and records are up to date.
 I am personally satisfied with the level of competency
of the staff authorised to handle the material.
 We do not permit students to handle the material.
 Below is evidence that our policy meets requirements
– a screenshot of the annual inspection log, and a
screenshot of the annual leak test record. On the
advice of my RPA, the leak test was changed to a raw
count of activity rather than a count rate for reasons of
clarity.
In 2017 our RPA conducted an audit of our policy and practices as a result of my appointment as
RPS. A copy of the findings and my responses to health and safety leads Gwyn Jones and Drew
McKenzie are shown below:

Responses to a review such as this show clearly the need to communicate changes to relevant staff.
Recent changes to the L93 guidance meant that we were required to safely dispose of one of our
sources – a radium paint source. It was determined that these sources were unsafe to continue using
due to age.

Complying with guidance provided by CLEAPSS I arranged for disposal of the source as outlined in
GL220, shown above.

Following the disposal, the RPA and RPO were informed via email (as shown in section 1.3). In
addition, I informed our health and Safety leads via email, reminding them of their duty to inform
the Fire service. All internal records were updated accordingly.
4 Be able to communicate health and safety policy in own area of responsibility

4.1 Communicate written health and safety policy to all people in own area of responsibility and
other relevant parties

4.2 Ensure all people in own area of responsibility and other relevant parties understand written
health and safety policy

Again, for this section, the most relevant example is my role as RPS. Below are extracts from our
policy documentation that show I have communicated with relevant staff to ensure awareness and
compliance with this policy.

This is the front page of our standard operating

procedure documentation held with the sources
prior to the disposal of our second unsafe source. It
clearly spells out the expectations held by the school
in regards to its use.

List of staff trained and authorised to use the source:

Section of usage log showing compliance with need to record all usage:

The continued correct use of this log shows that staff are aware of the policies and practices that
they have to follow when working with this material.

5 Be able to monitor health and safety in own area of responsibility

5.1 Evaluate systems for identifying and assessing health and safety hazards and risks within own
area of responsibility

The overall philosophy with regards health and safety at Ysgol Eirias is one of a Kaizen model.
“Kaizen” is a Japanese word that roughly translates to mean “continual improvement”. With regards
to health and safety, it embraces the idea that work relating to making the workplace safer is never
really finished (which the school maintenance staff would agree with, considering the ever-growing
maintenance log), and that there are always improvements to be made and lessons to be learnt
from incidents. This philosophy is identified in our health and safety policy where it clearly states
that any and all incidents and near misses will be investigated as a way of preventing repeat
occurrences (shown in section 2.3/2.4). This system is clearly preferable to one where incidents are
merely logged and filed away – continuous improvement is obviously more desirable than simply
standing still. The downside of such a philosophy is that it requires a shared embracing of the
philosophy in order to be effective – and it is a lot more effort to learn from issues and to make
improvements than simply acknowledging them. It is also a burden on staff to monitor and assess
changes that are made in response to issues, but the improvements in efficiency and safety that can
be produced are generally worth the efforts. One major plus point of such a model that involves all
staff is that it empowers all workers to have a role to play in ensuring a safe workplace – this can
empower staff to take responsibility for maintaining a safe work environment. Kaizen can also be
seen to be a form of “marginal gain” improvement – that is, each individual improvement might only
have a small impact, but the overall effect of dozens of small changes can add up to a big overall net
effect. A recent conversation with one of our senior staff with regards health and safety auditing has
suggested that we could potentially “streamline” our processes linked to identifying and logging
health and safety hazards and risks. The way that issues are first somewhat formally audited and
then logged in the maintenance book (shown in 5.4 below) in order to be put right creates extra
potentially not needed work, consuming the time of both staff logging issues and the maintenance
staff in dealing with the logs. This sort of “redundancy” of documentation seems unneccesary, and
the plan is now to move to a system where the audit and maintenance log are merged into a single
system or document via Teams. This recommendation will move us away from considering health
and safety reviews to be a “one shot” annual consideration into a continual process of reflection and
development. This could serve to help identify issues just after they become apparent, and even out
the workload of maintenance staff.

A second model that we operate at Ysgol Eirias is that of a “Swiss cheese” model. Under such a
model, it is accepted that a single form of mitigation is not capable to preventing all potential
hazards and risks. A second layer of mitigation might cut down on some of the issues that escape the
first, but not all. A third might reduce them even further, then a fourth, and so on. A good example
of this was the layers of mitigation that the public were encouraged to follow during the covid
pandemic. Mask wearing represented one layer of mitigation, backed up by social distancing,
reinforced by improved hygiene, further supported by social bubbles, testing, and contact tracing.

In Ysgol Eirias, these layers are made up of high level whole school policy control (audits, the
maintenance log), layered over individual faculty policies (e.g. Science faculty policy over practical
activities), on top of specific policies for specific activities (e.g. the protocols relating to the use of the
radioactive source), with more reactive protocols forming the last slices of cheese (e.g. accident
logging and investigating). Each layer of control reduces specific risks, combining to overall greater
reductions in risk than one overarching system. The downsides of such a system is that it can
become bureaucratically complex, with redundances in effort unavoidable – for example, internal
science department policy will inevitably echo advice from whole school policy from the layer above,
but also contain protocols that will be repeated in layers below it, such as advice for specific
apparatus. However, this form of redundancy reduces the risk of accidents caused by unaware staff
who are more likely to know about best practice if it is expressed to them by more than one form of
guidance. When reviewing the layers of protection, we operate at Ysgol Eirias it became apparent
through discussions that staff and leaders have varying and inconsistent levels of knowledge about
differing layers of health and safety protection. I have made the recommendation to my line
manager that we run a refresher for science department staff on 3 of these layers. The first is
ensuring that all science faculty staff have read the whole school policy in relation to health and
safety. The second is that all staff review the science department health and safety policy document
relating to general lab use shown/discussed in section 2.2 - whilst this advice comes from CLEAPSS, it
has been some time since we reflected on its implementation within our specific environment. Our
senior lab technician was highly in support of this recommendation! As part of this, we are going to
require all staff to sign a declaration to show they are aware of current best practices. The third and
final layer is to offer staff the opportunity to refresh any specific training linked to individual items of
apparatus, if relevant. For example, it has been some time since some staff used the radioactive
source, and staff would clearly benefit from a quick refresher if they intend to use it in the future.

An example of a “reactive” system used to analyse health and safety incidents is the “5 Whys”
system. This system attempts to generate a comprehensive explanation as to how and why an
incident occurred by repeating the basic question of “why?” as a means to understanding cause and
effect. A hypothetical application of this method might look as follows:

Incident: A pupil has cut their hand on an item of broken glass in a science lesson.

Why? There was a broken beaker in the sink they were working at.
Why? The pupil had dropped the beaker by accident and wanted to clean away the debris.
Why? The pupil was worried about getting in trouble for breaking a beaker
Why? The pupil was not aware of the lab rules about broken glass.
Why? The lab rules had not been fully explained or communicated to the pupil.
Cause: Pupil was unaware that they should leave an adult clean the broken glass and that
they were not in trouble.
Correction: Clearly communicate lab rules to pupils prior to practical work, and have them
clearly displayed in science labs.

The key to this method is to keep asking “why” until a failing of policy or practice is revealed. It is
essential that the cause revealed is an issue with a policy or practice, and not merely a person –
immediately obvious issues will be caused by underlying problems, and holding a person responsible
will not usually lead to any meaningful improvements. In order to apply the “5 Whys” effectively one
must approach the investigation with an open mind – framing the incident in neutral language that
clearly describes it without pre-emptively giving a cause is essential. The answers to the “whys” need
to be generated through speaking to people who are linked to the incident it is pointless to try and
generate an understanding of an incident without interacting with those who have first-hand
experience of it. This method is not without disadvantages – it can be tricky to maintain an open
mind, as it is very easy to be decided on the root cause of an incident before investigating it. It is also
very tempting to ascribe human incompetence as a root cause rather than admit an institutional
failing. It can also be tricky to know how many layers of “why” to ask – sometimes, a satisfying but
shallow cause might emerge after 2 or 3 layers of asking, but for more complex incidents you might
be on your 11th or 12th “why” and still not have identified a root cause. It would also be easy to keep
asking “why” after the root cause has been identified, leading to no meaningful improvement being
made. This level of rigor currently does not exist in our science faculty policy when considering the
logging of incidents. I have strongly recommended to my line manager that we incorporate the “5
whys” method of questioning in response to completing accident report forms. This will require a
redesign of our accident report form, and also create the need for all science faulty to be informed
of the change and why it has been made – it will also be worth giving staff the opportunity to apply
the “5 whys” method as a practice before needing to apply it in a real-world incident. It is highly
possible that we have become somewhat complacent in our reporting and logging of incidents as we
have not had one in so long – a shake up like this could serve as a timely reminder to people to not
take health and safety for granted.

5.2 Assess working environment within own area of responsibility against organisation’s health and
safety policy

5.3 Identify and evaluate non-compliance with health and safety policy and practices within own
area of responsibility

5.4 Take appropriate action to eliminate or control identified hazards and identified risks

As part of our health and safety protocols, staff are required to complete an annual audit, identifying
areas of concern. Below is my audit prior to a set of health and safety concerns that emerged as a
result of normal wear and tear in my classroom which had been suffering from a lack of basic
maintenance during the periods of school closures linked to the covid lockdowns. Following this
audit, it was clear that some attention was needed to cover holes in the floor that were presenting a
trip hazard, that the missing roller blinds were a potential hazard, that non-functional taps were
interfering with a protocol designed to mitigate the risk of legionnaires disease, and that some
looseness in the door closure mechanism was violating fire safety rules. A copy of this audit is shown
below.
Once these concerns had been identified, I was required to log them as concerns in the school’s
maintenance log, as so:

Caretaking staff then either follow this up in person, make contact via email/Teams chat to organise
a repair, or contact outside agencies in order to enact repairs.

Unfortunately, due to financial resources, time pressures, and workload issues sometimes there is a
significant time lag in reporting an issue, and it getting repaired. The taps were a relatively low
priority with quite a financial impact and the need for a plumber to complete the work, so they took
many months to be repaired. However, the poorly closing fire door was repaired in under an hour of
it being logged as it was a high priority with no financial impact able to be repaired by in-house staff.
The blinds were replaced in the summer term of 2023 by an external company. As of yet, I am still
waiting on anything other than the most rudimentary repairs to the lab floor.

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