Unit IA Revision Guide

NEBOSH International Diploma
Unit IA
Managing Health and Safety
Revision Guide
NEBOSH INTERNATIONAL DIPLOMA UNIT IA
MANAGING HEALTH AND SAFETY
REVISION GUIDE
RRC acknowledges with thanks the co-operation of NEBOSH in the production of this
guide.
RRC Ref. NIDARG.3
© RRC International
All rights reserved
No part of this publication may be reproduced, stored in a retrieval system, or
transmitted in any form, or by any means, electronic, electrostatic, mechanical,
photocopied or otherwise, without the express permission in writing from RRC.
ISBN for this volume: 978-1-911002-84-0

Third edition Autumn 2018
Contents
Welcome to your NEBOSH International Diploma Unit IA Revision
Guide! 1
Element IA1: Principles of Health and Safety Management 13
Element IA2: Regulating Health and Safety 29
Element IA3: Loss Causation and Incident Investigation 46
Element IA4: Measuring and Reviewing Health and Safety
Performance 65
Element IA5: The Assessment and Evaluation of Risk 79
Element IA6: Risk Control 98
Element IA7: Organisational Factors 112
Element IA8: Human Factors 143
Element IA9: The Role of the Health and Safety Practitioner 168
4 © RRC International
Unit IA Revision Guide: Introduction
Welcome to your NEBOSH International

Diploma Unit IA Revision Guide!
This Revision Guide has been created to help you build a structured revision plan
towards your end-of-unit exam for Unit IA, including some guidance on how to answer
exam-style questions. It’s split into elements as defined by the NEBOSH syllabus and
each element-section contains two main parts:
Revision Notes
When revising for an exam, many students rely on either trying to learn the whole
course, which is virtually impossible, or spending most of their revision time on
topics they believe are likely to come up in the exam - neither are good revision
techniques as they leave too much to chance. This part of your Revision Guide
provides a summary of the RRC course material; it’s designed to remind you of the
key principles and ideas you studied in this Unit.
Exam-Style Questions
This part of your Revision Guide provides some example exam questions and
model answers; it will give you an insight into what your NEBOSH examiner expects
from you and some common mistakes to avoid. Within each mock question and
answer scenario is an Interpretation, Plan and Suggested Answer; this will provide
a framework upon which you can base your approach to answering each question.
These model answers have been written as ideal answers and not under exam
conditions or time restraints, so it may not always be possible to write up such
a detailed answer in the actual exam. It is also worth keeping in mind that some
questions will require you to use knowledge from more than one element of the
course.
Remember, this booklet has been prepared with the exam in mind - it is not intended
to replace a proper course of learning! By combining an overview of each topic with
practice exam questions, you’re revising the course content and improving your exam
technique at the same time - it’s perfect preparation for your NEBOSH exam.
There’s no substitute for hard work, and the more study time you can spare the better,
but the key is to use this time effectively.
Revising Effectively
Using the Syllabus
Your secret to success is the Guide to the NEBOSH International Diploma. This sets out
the structure of the course and contains the syllabus. If you don’t already have a copy
of the syllabus, we strongly recommend that you buy one, keep it with you and read
it every day. All NEBOSH exam questions are set from the syllabus, so as you become
more familiar with it you’ll be less likely to be ‘thrown’ by a surprise question.
Keep in mind that you’ll be expected to apply your knowledge to both familiar and
unfamiliar situations!
© RRC International 1
As exam questions are taken from the syllabus, mapping your study notes against the
syllabus can be a very useful revision technique. If you have studied with RRC you will
see that the material follows the syllabus quite closely, but this exercise is important to
help you appreciate the overall ‘picture’. When you’re studying one specific section
in isolation, it can be very easy to lose sight of how the material fits together, what
practical use it is, or how a health and safety practitioner might make use of it in real life.
Referring back to the syllabus will put each topic in perspective and help you see how
it relates to the field of health and safety generally. It will also help you cross-reference
the material with other related topics, which you may have to do in more complex exam
questions.
To get this overview, you need to know the elements that make up the course and how
they relate to the RRC sections. Each element (e.g. Unit IA, Element IA1: Principles of
Health and Safety Management) includes two important sections:
Learning Outcomes, which detail what you should be able to explain, understand,
assess, carry out, etc. after completing the element.
Content, which gives you the topics you should be fully familiar with.
You can use both these sections of the syllabus to test whether you have the relevant
skills, knowledge and understanding for each element, or whether you need to look
again at certain topics.
An idea for an effective revision technique is to take a pin (blunt, of course, for health
and safety reasons!) and randomly stick it in any part of the syllabus. Then write down
what you know about that topic. This might be very little at first, in which case go back
to your study notes and summarise the key issues that you need to work on. Make a
note of this topic, then return to it a few weeks later and see how much more you can
remember. If you practise this regularly, you will eventually cover the entire syllabus and
in the process find that you understand and retain the material much more effectively.
This is ‘active revision’, as it actively tests your memory to see what you have learnt - and
it is far more effective than ‘passive revision’ where you simply read your study notes and
usually switch off after 30 seconds, taking in little of the material.
You will find it easier if you make sure that you have an overall understanding of the
topic first, then fill in the detailed knowledge requirements later. Ask yourself searching
questions on each topic such as:
‘What use is this?’,
‘How would a health and safety practitioner apply this in real life?’,
‘What is the point of this topic?’,
until you feel that you fully understand why a health and safety practitioner would need
to know about each area. Once you have this level of general understanding, the details
will be much easier to retain, and in some cases you may be able to derive them from
your own workplace experiences.
Your revision aim is to achieve this comprehensive overview of the syllabus. Once you
have done this, you will be able to at least say something about each of the topic areas
and tackle any question set on the syllabus content.
Overview of the Exam

Students taking the NEBOSH International Diploma qualification are often very
concerned about the assessments that they have to pass.
NEBOSH qualifications are not easy! Each person who passes a qualification has to work
hard to do so, which makes it all the more rewarding when you succeed!
But, when you are preparing for the assessment, the practicalities of revision, preparation
and exam nerves can get the better of you.
Unit IA is arguably the hardest of the three Diploma Unit exams to pass. This may be
due to the fact that Unit IA has far more content than either of the other two units;
or it may be due to the fact that Unit IA covers a wide variety of topics, some of them
rather demanding in nature (take human factors, for example) and some of them just
downright intimidating in their complexity (the law!). It may also be due to the fact
that Unit IA is almost always the first Diploma exam that you will sit and is therefore
your first exposure to the reality of sitting a three-hour exam. This first exam can be a
hard learning experience to go through, and the national pass rates would indicate that
once through Unit IA, candidates do progressively better in both the Unit IB and Unit IC
exams. This is perhaps because some hard lessons have been learnt during that first Unit
IA exam experience.
Success in Unit IA depends on your performance during just three hours in the exam at
the end of your studies, and your exam performance will depend on two key factors:
How much you can remember about the different topics.
How well you can apply that knowledge in the exam situation.
It’s no use being good at one thing without also being good at the other. Staying calm
under pressure and interpreting questions won’t help if you don’t have the knowledge
to answer those questions. Getting that knowledge is the whole intention of the
revision process, but will count for nothing if you can’t function in an exam situation.
The overall purpose of this guide is to focus on both of these elements of success:
effective revision and good exam technique.
The Exam
You should aim to arrive at the exam venue early. Exams are stressful enough at the best
of times. Travelling to get there just in time or, worst case scenario, arriving late will not
help your nerves.
You have three hours to complete your answers. Ten minutes’ reading time is allowed
before the start of the exam during which you may read the exam paper but you may
not write anything.
Your answers should be written into a standard answer booklet. This answer booklet
contains lined A4 paper with a cover. You complete the cover with a few personal details
as instructed and then write your answers inside. There is a space at the top of each
page for you to indicate which question you are answering on that page.
The exam contains six compulsory short questions in Section A; each of these is worth a
maximum of 10 marks. The exam paper states that you are advised to spend 15 minutes
on each of these questions.
It also contains five long questions in Section B. You have to answer any three of these
five questions. Each of these is worth a maximum of 20 marks. The exam paper states
that you are advised to spend 30 minutes on each of these questions.
The only difficulty with following the advice on the exam paper is that it leaves you no
time to pause during the exam and no time for reviewing your answers at the end.
It is recommended that you reduce the amount of time that you dedicate to each of the
short questions. Here is a suggestion:
Six questions × 12-13 minutes each = 75 minutes (approx.)
and
Three questions × 30 minutes each = 90 minutes (total)
This leaves around 15 minutes of spare time. You might use some of this time to:
Pause briefly between questions to give yourself a short break from thinking and
writing.
Make a careful decision about which three Section B questions you intend to answer.
Briefly review your answers before the exam ends.
Whichever time management plan you decide is right for you, you must put this plan
into effect. Don’t forget - you can take a watch into the exam with you. Take your
watch off and put it on the table in front of you. As you start each exam question write
the start time and projected finish time on the exam paper next to the question. You
don’t need to remember what time you started or intend to finish - it is written down in
front of you. As you write your answer, make sure that you check your watch to ensure
that you do not run over your intended finish time.
If you write the finish time down, check your watch and stick to your intended plan
- then you cannot go wrong with time management during the exam. If you do not
have a plan, or if you have a plan but fail to follow it in the exam room, then time
management can go horribly wrong.
Plenty of students run out of time. Don’t let it happen to you!
Exam Strategy
Understanding everything in the syllabus is of no use if you have poor examination
technique. To achieve maximum marks, you will need to:
Read the question carefully.
Understand what information is being requested. It is important to identify the
command word within the question, as this will give you an indication of the depth
of knowledge required in your answer. Typical command words used by NEBOSH in
Diploma exam questions include identify, outline, explain and describe. (The next
section of this guide has further information about these command words and their
meaning.)
Understand the breadth of knowledge required.
Look at the marks available for the question or part of the question – that is a clear
indication of the amount of information required and time to be spent on it.
Read the question again to ensure you understand its meaning.
Produce a plan to organise your thoughts.
Provide the information in a logical and coherent way.
Manage your time effectively – you need to allocate your time evenly throughout
the exam to take into account the number of marks allocated per question.
NEBOSH Command Words

It is important to identify the command word within the question as this will help you
understand the meaning of the question and the depth of knowledge required in your
answer. The following command words are routinely used by NEBOSH in Diploma exam
questions:
Identify
Give the item its name or title, often requiring just a word or short phrase.
Example:
Question: Identify FOUR organisational factors that might give rise to a poor health
and safety culture within an organisation.
Answer: Lack of management commitment.
Absence of good quality training.
Lack of consultation on health and safety matters.
Inadequate resourcing of health and safety management.
Outline
Give a brief summary of the item or its key features. A detailed explanation is not
required, but the answers must be more than just a single word or phrase.
Example:
Question: Outline TWO categories of worker who might be more vulnerable to risk in
a workplace.
Answer: Lone workers – workers who work away from immediate and direct
contact with their work colleagues.
Young people – workers who because of their age lack experience in the
workplace, are immature and have a poor perception of risk.
Describe
Give a detailed written account of the subject or item. Sufficient so that someone
reading that description can visualise the item in their mind’s eye.
Example:
Question: Describe the ‘statement of intent’ section of a health and safety policy
document.
Answer: The statement of intent is usually a one page document with a title at the
top of the page followed by several paragraphs of text. At the bottom of
the document there will be the name and signature of the person at the top
of the organisation (e.g. the Managing Director), along with the date the
document was signed and a date when the document will be reviewed. Each
paragraph of text on the page will summarise the key aims and objectives of
the organisation with regards health and safety.
Explain
Give an understanding of why or how something happens. With more detail than an
outline would require.
Example:
Question: Explain the moral reason why an organisation should maintain high
standards of health and safety.
Answer: The moral reason for maintaining high standards of health and safety arises
from the basic human sense of right and wrong. When workers or others are
injured or made ill by work activity they will experience pain and suffering.
This pain and suffering is morally unacceptable if it can be avoided.
Give
Provide without explanation. Is often used in conjunction with example (as in: ‘give an
example of’).
Example:
Question: Outline the meaning of the word ‘hazard’ and give one work-related
example.
Answer: The word hazard means ‘something with the potential to cause harm’. An
example of a work-related hazard would be an electrical flex trailing across
the floor of a workroom that presents a risk of tripping.
If you have studied at NEBOSH Certificate level you may well recognise these command
words from Certificate-level exam questions.
NEBOSH also uses other command words in Diploma exam questions. These words,
and an interpretation of their meaning, are presented below, along with part-question
examples to illustrate their use:
Analyse
Break down the subject into its component parts and examine their relationship.
Example:
Question: Analyse the data presented in the table and suggest reasons for the
difference in safety performance.
Assess
Present judgments of relevant factors and their importance.
Example:
Question: Assess the significance of the court ruling in R. v. Swan Hunter concerning
the interpretation of Section 2(2)(c) of the Act.
Calculate
Undertake a mathematical process. N.B. It is important to always show your working out
when presenting calculations.
Example:
Question: Using the data in the table, calculate the 8-hour TWA exposure to flour
dust for bakery operatives.
Comment
Give a justified opinion on the issue.
Example:
Question: Comment on the Managing Director’s point of view and give reasons why
they are incorrect.
Compare and Contrast

Identify the similarities and differences between the subjects. N.B. You must cross-
reference between the two subjects and not just write two completely separate
descriptions.
Example:
Question: Compare and contrast X-ray and alpha particle ionising radiation.
Consider
Show your thinking about the subject matter.
Example:
Question: Consider the impact of the Director’s decision on the safety culture of the
organisation.
Define
Give a broadly acceptable meaning of a word or phrase.
Example:
Question: Define the phrase ‘safety culture’.
Demonstrate
Prove by logical reasoning.
Example:
Question: Using the data in the two tables, demonstrate that the trend in accident
frequency rate is upwards and discuss possible reasons for the increase.
Determine
Come to a decision or conclusion by investigation.
Example:
Question: Determine the root causes of the incident.
Discuss
Critically analyse the subject matter.
Example:
Question: Discuss the findings of the committee and analyse the strengths and
weaknesses of its recommendation.
Distinguish
Separate the subjects by highlighting differences.
Example:
Question: Distinguish between Acts of Parliament, Regulations and Orders.
Evaluate
Show the value of the subject by careful examination.
Example:
Question: Evaluate the use of risk-rating matrixes in the risk assessment process.
Justify
Support by using fact or reasoning.
Example:
Question: Justify this choice of respiratory protective equipment as opposed to the
cheaper alternative.
Recommend
Present as a personal choice of action with some justification.
Example:
Question: Recommend a course of action for the Managing Director to follow that
will allow the company to discharge its legal duties in these circumstances.
Review
Overview the subject matter and summarise .
Example:
Question: Review the information that is likely to be requested by the insurance
company when investigating this claim for compensation.
Further information on these command words and their use is available directly from
NEBOSH. A full guide giving specific examples of exam questions and full suggested
answers that clearly illustrate the use and meaning of each word is available at no cost
from www. nebosh.org.uk.
The examination process may seem complex, but success is simply a case of averaging
around half marks or more for each question. Marks are awarded for giving ideas that
are relevant to the requirements of the question, and convincing the examiner that you
understand what you’re talking about. If you have the knowledge and understanding
gained from studying the syllabus as set out above, then this should not be a problem.
Another important exam skill is to carefully read and analyse the question so that you
are clear about what is required to answer it. Once you have done this, you will be ready
to plan your answer (though for some short answers you can get away with not doing a
plan). This will help you structure your thoughts in order to provide a coherent response
to the question. The other important reason for planning is to allow you to jot down key
words, which may help you recall memories associated with those subjects.
The more you study past exam questions, the more familiar you will become with the
way they tend to be phrased and the kind of answer the examiners are looking for.
Students often make the mistake of going into too much detail on specific topics and
failing to address the wider issues. If you only deal with half of the relevant issues you
can only achieve half of the marks! Try to give as broad an answer as you can, without
stepping outside the subject matter of the question altogether. Ensure that you explain
each issue to convince the examiner that you have a sufficient understanding. Giving
relevant workplace examples is a good way of doing this.
You can find a sample Unit IA exam paper in the NEBOSH guide to the Diploma. You
can obtain Examiners’ Reports from NEBOSH.
Last-Minute Preparation
Finally, a useful way to combine syllabus study with exam practice is to attempt to set
and answer your own exam questions. By adding a question word, such as ‘explain’
or ‘describe’, in front of the syllabus topic areas, you can produce a whole range of
questions. This is excellent exam practice because it serves as a valuable topic revision
aid, and, at the same time, requires you to set out your knowledge just as you would
under exam conditions.
Unit IA Revision Guide
Element IA1: Principles of Health and Safety

Management
Reasons for Effective Management of Health and
Safety
We can identify three main reasons for the need to manage health and safety risk.
Moral
Employer owes a duty of reasonable care to his employees.
Society expects employers to ensure the health and safety of their workforce.
It is unacceptable to place employees in situations where their health and safety is at
risk.
Legal
Preventive - enforcement notices issued by enforcement inspectors.
Punitive - criminal courts impose fines and imprisonment for breaches of legal
duties.
Compensatory - employees are able to sue in the civil courts for compensation.
Economic
Insurance will cover some costs of accidents and ill-health, such as:
Compensation claims from employees.
Damage to motor vehicles.
Other costs that cannot be insured against:
Fines from criminal prosecutions.
Loss of highly trained and/or experienced staff.
Effects on employee morale and the resulting reduction in productivity.
Bad publicity leading to loss of contracts and/or orders.
Organisations can find it very difficult to fully quantify costs of accidents for a variety of
reasons. The company may:
Lack resources (expertise/time/people) to perform the analysis.
Lack understanding that some costs exist and so miss them entirely.
Suffer from under-reporting/non-reporting (and so be unaware).
Not know the full cost for a long time (on-going civil case, effect of loss of goodwill,
etc.).
Societal Factors which Influence an Organisation’s

Health and Safety Standards and Priorities
Certain societal factors influence health and safety standards, particularly:
Economic climate - wealthy countries can afford to give occupational health and
safety a higher priority.
Government policy - those who work tend to be healthier than those who are
unemployed. Improving workers’ health will help keep people at work, who can then
contribute financially to society.
Risk profile - higher-risk activities demand greater standards than for lower-risk
activities.
Globalisation - businesses that operate across the world may adopt different
standards depending on the requirements of the host countries.
Migrant workers - in recent years immigration policies have increased the
proportion of migrant workers.
National level of sickness and incapacity – in the UK, for example, the proportion
of the working-age population on incapacity benefits is much higher today than in
the 1970s.
Societal expectations of equality - health and safety standards and priorities can
be determined by changes in societies’ expectations of equality.
Uses of, and the Reasons for, Introducing a Health

and Safety Management System
What is a Management System?
All management systems have the same common elements:
Plan - implies having a considered policy.
Do - concerns the arrangements for putting the plan into practice.
Check – means it is necessary to assess or monitor performance.
Act – means performance should be reviewed leading to continuous improvement
in the management system.
Health and Safety Management Models

Most organisations have management systems for one or more aspects of management.
In relation to safety, two good sources of advice are ISO 45001 Occupational Health and
Safety Management Systems and the UK HSE publication HSG65 Managing for Health
and Safety (2013). A characteristic of these management models is that they view the
organisation as a system with inputs, internal processes and outputs.
The general principles of the guidance are illustrated in the following figure:
The Plan, Do, Check, Act cycle based on the approach in HSG65
Application of the PDCA Cycle

The Plan, Do, Check, Act cycle achieves a balance between the systems and behavioural
aspects of management and treats health and safety as an integral part of good
management rather than as a stand-alone system.
The cycle starts with a planning process to control risks which is implemented through
risk assessment, checked by measuring performance and reviewed so that action is taken
to improve.
The Reasons for the Introduction of Health and Safety

Management Systems
Management system models offer a framework for management to focus on in order to
manage health and safety.
The following are key issues that require a health and safety management system to
deliver:
Appropriate allocation of resources.
Appropriate allocation of responsibilities.
Setting and monitoring performance standards.
Feedback and implementation of corrective action.
A simple justification for introducing a health and safety management system is to
improve the business through:
Better health and safety performance which will reduce the costs from accidents and
incidents.
Greater awareness of legal requirements which will reduce the chances of
committing an offence.
Improved relations and morale as employees see that their health and safety is being
looked after.
Improved image and positive PR from a publicly responsible attitude towards
employees.
Greater business efficiency which will reduce costs.
Reduced insurance premiums by demonstrating more effective risk control.
Greater confidence from banks and investors by showing more effective risk
management systems.
Principles and Content of Effective Health and Safety

Management Systems
Health and Safety Policy
Health and Safety Management Systems
Sets the whole framework of the safety management system (SMS) and should:
Demonstrate commitment.
Frame the company vision on health and safety.
State the overall health and safety objectives of the organisation.
Express commitment to improving health and safety performance.

Be authorised by top management.
Commit the organisation to compliance with legislation.
Be communicated to all employees and other interested parties.
Be kept up to date by periodic review.
Communication of Health and Safety Information

Communicates:
–– The company’s approach to managing health and safety.
–– The organisation’s commitment to health and safety to existing employees
(preferably by means of their own copy).
Can be used:
–– In the induction of new employees (to stress the importance of safety).
–– To involve workforce representatives in writing and amending the policy, when
necessary.
–– At regular briefing sessions to communicate information relating to different
sections of the policy.
Requirements for a Written Health and Safety Policy
A health and safety policy may be a requirement of national legislation in some regions.
Even if it is not a legal requirement, it is required by ILO-OSH 2001 (which supports ILO
conventions) and ISO 45001.
General Principles and Objectives of a Health and Safety Policy Document

The principle of the health and safety policy document is that it sets out:
What needs to be done.
Who needs to do it.
How it’s going to be achieved.
The policy is therefore usually made up of:
A statement of intent that sets out the aims and objectives of the organisation
regarding health and safety.
An organisational structure that details the people with health and safety
responsibilities and their duties.
The systems and procedures in place to manage risks.
Practical objectives might include:

Supporting human resource development.
Minimising the financial losses which arise from avoidable unplanned events.
Recognising that accidents, ill health and incidents result from failings in
management control and are not necessarily the fault of individual employees.
Recognising that the development of a culture supportive of health and safety is
necessary to achieve adequate control over risks.
Ensuring a systematic approach to the identification of risks and the allocation of
resources to control them.
Supporting quality initiatives aimed at continuous improvement.
Key Elements of a Health and Safety Management System

ILO-OSH-2001 Guidelines on Occupational Health and Safety
Management Systems
The elements of this system are as follows:
Policy.
Organising.
Planning and Implementation.
Evaluation.
Action for Improvement.
Continual Improvement.
Model Health and Safety Management System (ILO-OSH-2001)

Copyright © International Labour Organisation 2001
The basic elements are very similar to ISO 45001. It is intended that the safety
management system should be compatible with, or integrated into, other management
systems within the organisation.
ISO 45001 - Occupational Health and Safety Management Systems

ISO 45001 requires an organisation to determine its existing health and safety activities,
and to develop programmes and systems that focus on the elimination of risk to staff
and other parties.
These processes are then developed into a management system that primarily aims to
ensure that health and safety performance is continuously monitored and improved.
The elements of the system are:
Context of the organisation.
Leadership and worker participation.
Planning.
Support.
Operation.
Performance evaluation.
Improvement.
The ISO 45001 Occupational Health and Safety Management System
Benefits and Limitations of Integration of Quality, Environmental,

and Health and Safety Management Systems
Integrated Management Systems
For organisations wishing to have control over more than one aspect of risk
management, e.g. safety, environment and quality, it may be possible to implement an
Integrated Management System (IMS) rather than individual systems.
Though it may make sense in theory, implementing an IMS is not an easy task, and there
is a variety of factors to be taken into account.
Arguments in favour of the integration of management systems include:
More cost-effective.
Avoidance of duplication.
Improvements in one system are more likely to carry over to other systems,
including a positive safety culture.
Disadvantages of integration include:
Possible increased bureaucracy.
Creation of unnecessary change.
Relevant staff may require more training.
Long Questions
1. Explain the purpose and key features of each stage of the safety management
model described in the UK HSE document Managing for Health and Safety
(HSG65). (20)
2. A multi-site business has a quality management system compliant with ISO

9001. It also has a health and safety management system and an environmental
management system that operate independently. The Board of Directors is now
considering the possibility of developing an integrated management system
encompassing all three elements. In order that a decision can be made objectively,
prepare a brief for the board that outlines the key potential benefits of:
(a) An integrated management system. (10)
(b) Retaining the existing system of separate management systems. (10)
3. A financial review within your organisation has resulted in a proposal to the Board of
Directors to cut its health and safety budget and to cancel a capital project that was
designed to lead to significant improvements in the working environment.
As the organisation’s Health and Safety Manager, explain why this proposal should
be rejected and justify your opinion. (20)
Model Answers
Long Questions
Question 1
Interpretation
This is a straightforward question but there are a few key words to pick up on. An
explanation is required - so depth and detail is expected. Each stage of the HSG65 Plan,
Do, Check, Act model must be analysed. The purpose and key features of each element
must be discussed, so for each element consider: what is it for, what does it do and what
is it made up of, what does it look like, what ideas does it encompass?
Plan
Plan - what you want to achieve, who will be responsible for what, how you will
achieve your aims, and how you will measure your success.
Do - identify your risk profile, organise your activities to deliver your plan.
Check - measure your performance, assess how well the risks are being controlled
and investigate the causes of accidents, incidents or near misses.
Act - review your performance and take action on lessons learned, including from
audit and inspection reports.
Suggested Answer
The diagram of the HSG65 Plan, Do, Check, Act model would be useful to include in
your answer to this question.
The model starts with Plan, where we need to think about where we are now and
where we need to be. What do we want to achieve, who will be responsible for what,
how will we achieve our aims, and how will we measure success? We will need to write
down this policy and the plan to deliver it. We also need to decide how we will measure
performance, using leading and lagging indicators (active and reactive indicators) rather
than just accident figures. Planning should also consider fire and other emergencies and
the need to co-operate with anyone who shares the workplace, future changes and any
specific legal requirements that apply to the organisation.
The Do stage starts with identifying the organisation’s risk profile, assessing the risks,
identifying what could cause harm in the workplace, who it could harm and how, and
what needs to be done to manage the risk. From this, priorities can be identified (i.e.
the biggest risks). Activities need to be organised to deliver the plan, including involving
the workforce and providing adequate resources and competent advice. To implement
the plan we need to decide on the preventive and protective measures required and
put them in place. These can include providing and maintaining the right tools and
equipment to do the job, training and instruction to ensure competence and supervision
to make sure that the arrangements are followed.
Check involves measuring performance to make sure that the plan has been
implemented. We need to assess how well risks are being controlled and investigate the
causes of accidents, incidents or near misses. In some circumstances formal audits may
be useful.
The final Act stage requires review of performance and learning from accidents and
incidents, ill-health data, errors and relevant experience, including experiences of other
organisations. We can then revisit plans, policy documents and risk assessments to see if
they need updating and take action on lessons learned, including those from audit and
inspection reports.
Question 2
Interpretation
This question is scenario based and, though a lot of detail is not presented on the
scenario, there are a few key features that must be recognised. Firstly, the QMS is ISO
9001 compliant. We can safely presume that that compliance must stay in place, which
can complicate integration. Secondly, there is an SMS and an EMS, but these are not
stated as being certificated to a standard, i.e. we are not told that they are ISO 45001
and ISO 14001. We can perhaps assume that they are not.
We are asked to prepare a brief; in other words write a report. It should look passingly
like a report, though detailed report formatting is not required. The target audience
is the Board (of Directors), so technical language can be used, provided it is explained.
Most importantly we are asked to outline the potential benefits of integration and of
staying put. The marks are evenly divided between the two options. Note that we are
not explicitly asked for the disadvantages of either option.
Plan
(a) Integration - consistency of format, avoidance of duplication of procedures,

record-keeping, auditing, software. Holistic solutions rather than just optimising
for quality or environment. Synergy (benefits from one area applied to other
areas), encouraging interaction between specialists, etc.
(b) Existing system - flexibility, safety standards set by legislation, quality set
internally. May not need such a complex system in one area compared to
another; why fix what isn’t broken? Integration may be a costly exercise; may
encourage more detailed auditing, if kept separate, specialists stay specialists.
Suggested Answer
The business has a quality management system compliant with ISO 9001. It also has a
health and safety management system (SMS) and an environmental management system
(EMS) that operate independently. The business is now considering the possibility of
developing an integrated management system encompassing all three elements. This
report has been prepared in order that a decision can be made objectively. In it, the key
potential benefits of integrating the three management systems and also of retaining the
existing independent management systems will be outlined.
The benefits of integration

There are many benefits that might potentially flow from integration of these three
independent management systems. These are outlined below:
Consistency of format - integration will require that a consistent format is applied to
all three areas. The same basic philosophy underpins each area (conformance to a
standard) and therefore the same management process and language can be applied to
each.
Avoidance of duplication of procedures - consistency of approach reduces duplication,
leading to efficiencies. These efficiencies might show in terms of indirect labour costs,
productivity increases and reduction in direct labour paperwork.
Record-keeping - (as referred to above) since systems are integrated, personnel will look
at three areas of concern once rather than looking at three separate areas of concern
independently. This should lead to improved record-keeping and a reduction in the
amount of paperwork generated by the three independent systems.
Auditing - once integrated, all three management areas will be audited together.
Certainly from an internal audit perspective this should lead to improved auditing across
three areas and may lead to a reduction in the time taken to audit. In short one audit will
look at one management system rather than conducting three separate audits to look at
three separate management systems.
Software - the integration of management systems will require the integration of
software systems. Again this should lead to efficiencies in time spent interacting with the
system.
Holistic solutions rather than just optimising for quality or environment - one of the
major benefits of integration is that a holistic approach is adopted. Unlike current
arrangements, where one system (and therefore the personnel who run that system)
is looking at one area of improvement and has little interest in improving other areas,
the integrated system gives ownership of all three areas to all personnel. Therefore it
is in everyone’s interest to see improvements across the board. In other words, with
an integrated system an improvement that enhances quality but is detrimental to
environmental performance is not seen as worth making. One that enhances health and
safety (H&S) and has no negative impact on environment and quality is worth making.
Synergy - another key benefit of the integrated system approach is synergy; i.e. the idea
that benefits from one area can be applied to other areas and that when this happens
the whole becomes greater than the sum of the parts.
One final benefit of integration is that it encourages interaction between specialists and
will require specialists to branch out into other areas of knowledge. Though specialists
may retain a higher level of competence in a chosen area, they will have to develop their
competence in other areas. This can be of great benefit since cross-pollination of ideas
should then flow within the organisation; there is greater sharing of knowledge and
practice and less ring-fencing of know-how.
The benefits of retaining the existing system of separate management systems

Flexibility - current arrangements are highly flexible. This is especially the case with
the SMS and EMS since these are not in compliance with an external system and can
be operated as we see fit. The QMS is less flexible since it is ISO 9001 compliant and
therefore must meet external standards in order to retain certification. It must be
recognised that in order to retain this certification, any integration of systems would
have to remain ISO 9001 compliant. This complicates the integration process.
Safety standards set by legislation, quality set internally - while the general philosophy of
all three systems is the same (conformance to standard) both H&S and environmental
systems are driven by the need to comply with the law. Quality, however, is driven by
our own internal need to meet customer expectation. Current arrangements allow
internal standards to carry equal weight with legal standards. Integration may lead
to more weight being given to legal standards and a dilution of quality standards as a
consequence.
May not need such a complex system in one area compared to another - integration
inevitably leads to complexity because the need to achieve compliance in one area
ripples out across all three areas of concern. This can lead to an over-complication
of systems. The QMS is driven by the requirements of ISO certification. This might
therefore drive complexity into the SMS and EMS.
Why fix what isn’t broken? All three management systems are functioning acceptably
across the multi-site operation and look to be working well. Any attempt to change
these systems may lead to disruption (at least in the short term) for little benefit.
Integration may be a costly exercise - inevitably there are costs associated with
integration. An IMS will have to be selected, tailored to our needs and then
implemented across the whole operation. Personnel, both specialists and others, will
require re-training in new systems. The potential for business disruption exists, which
may have unforeseen cost implications.
May encourage more detailed auditing if kept separate - current audit arrangements
require detailed focus on the three areas of concern independently. This separate focus
does mean that greater scrutiny is applied to each topic area.
Specialists stay specialists - the current system requires that QMS staff are specialists in
quality management only. The same applies to EMS and SMS staff. These staff have
developed their competence over years of practice and study. Retaining the current
system allows these people to stay specialist, rather than requiring them to move into
other areas where they have little or no experience or knowledge and therefore no
competence.
Question 3
Interpretation
This is a straightforward question requiring a defence to be presented to the threat of
financial cutbacks. Note that the short scenario given threatens cuts to the health and
safety budget and the cancellation of a capital project.
While a separate defence does not have to be presented to both threats, the arguments
used must be applied to both threats. Note that your answer should look report-like and
your language should be for the non-specialist.
Plan
Moral, legal and economic arguments.
Moral - policy obligation to staff. Personal impact of accidents and ill-health.
Industrial relations and PR implications of moral failure.
Directors’ personal values. (Put last.)
Legal - compliance with legal requirements, enforcement notices, prosecution,
avoidance of legal action against directors and/or managers, compensation.
Economic - costs of failure; direct costs, indirect costs. Uninsured losses, hidden
nature of losses. Financial benefits of good standards, especially working
environment.
Suggested Answer
This report has been prepared following the proposal to the Board to cut the health
and safety budget and cancel the health and safety capital project. The report will argue
for the rejection of this proposal based on three basic principles: the sound economic
argument that underpins good health and safety management within this organisation,
the legal implications of failing to manage health and safety effectively, and the moral
imperative. Each of these arguments will now be discussed in detail.
The Economic Argument
Health and safety (H&S) failings cost money; in fact they can cost a lot of money. And
while it is true that putting good H&S standards in place also costs money, the costs
associated with failures far outweigh the costs of implementation. There are two ways
in which this organisation may fail to ensure H&S - one is a failure to ensure safety. This
leads to accidents. The other problem is failure to ensure health; this leads to ill-health,
sickness and chronic disease. Both accidents and ill-health have direct costs associated
with them. For example, a workplace accident leads to production downtime, damage
to equipment, plant and premises, and loss of product. Damaged equipment and
premises must be repaired or replaced. This in turn usually leads to indirect losses to
the organisation - losses that do not stem directly from the event itself, but flow from
it as inevitable consequences. Lost product must be re-made, which incurs overtime or
additional labour costs.
Personnel who have been injured remain absent from the workplace; they are paid
full salary during their absence and at the same time the organisation has to employ
temporary labour to cover their work. In some instances this temporary labour solution
cannot be applied and then other workers in the workplace have to pick up the work of
their absent colleague. This leads to overworking, fatigue and stress which in turn leads
to an increase in human error and higher absenteeism.
While some of the costs highlighted above are quite apparent, some may be hidden to
the organisation; others are non-discoverable in nature. If industrial relations are severely
damaged by a workplace accident, that reflects in poor productivity, higher absence
rates and reduced efficiency. But how could that be exactly costed out? The answer is it
cannot be. If bad publicity were to result from a workplace accident, that might have a
direct effect on our customers’ willingness to do business with us. Again, this could be a
very significant cost that would be difficult to quantify and discover.
The above arguments relate to workplace accidents and ignore the cost implications
of work-related ill-health. Occupational ill-health often results from poor working
conditions and poor working environments. It almost invariably leads to workplace
absence and, in some instances, may be severe enough to warrant dismissal on medical
grounds. There are costs associated with the worker absence, the management of that
absence and the legal action that often results from such ill-health and dismissals, not to
mention the poor industrial relations and PR that can accompany such illnesses.
Studies which have analysed workplaces looking for the costs associated with workplace
accidents suggest that the uninsured losses to an organisation are greater than the
insured losses by a factor of 8× as a minimum. In other words, our insurance company
cannot be approached to fund the vast majority of losses that we incur when we injure
people at work or make them sick. We fund those losses ourselves
None of the above included any comment about the financial implications of legal
actions, which this report will now move on to consider.
The Legal Argument
There are legal standards that we must comply with and failure to comply can lead to
enforcement action being taken against us in the form of legally binding notices that
require us to carry out such improvements or to stop certain activities. This enforcement
action invariably carries with it the costs associated with carrying out the improvement
to the enforcement officer’s timescale, or stopping an activity that we find to be
financially beneficial. This is not to mention the bad IR and PR that is usually associated
with these enforcement notices. In other instances, failure to achieve legal compliance
may result in prosecution. Directors may also face personal liability for legal failing of
the organisation that they direct. Needless to say, all of the above legal actions carry
with them the risk of incurring huge legal fees in mounting a defence (and paying the
prosecution legal fees in the event of the case being lost).
In addition, injure a worker, or cause ill-health, and we may well be sued by the injured
party. These cases may result in the payment of compensation to injured victims.
Though this money may come from our insurers in the first instance, it invariably leads
to higher insurance premiums in the short- and long-term as those insurers attempt to
claw back their losses from us.
The Moral Argument
We have a clear policy obligation to our staff to ensure their ongoing health, safety and
welfare. That has been made clear in the statement of intent signed by our Managing
Director as the headline of our H&S policy. Aside from the legal and financial arguments
discussed above, we must also consider the huge personal impact of accidents and
ill-health that can and do occur as a result of our H&S standards. One worker may
be injured or made ill, but that one person has a family, friends and colleagues. The
impact of a serious accident or case of ill-health has wide-ranging implications. We
must reflect on our own personal values and decide whether we would wish to see the
unpleasant and sometimes tragic consequences of poor H&S standards occurring in our
organisation.
In conclusion, I would state that cutbacks cannot be made to the H&S budget, nor to
the capital project, on the basis of the three arguments described above. We owe it to
ourselves, to our workforce and to our shareholders to retain our H&S budgets so that
we are best able to avoid the losses that workplace accidents and ill-health might cause.
Element IA2: Regulating Health and Safety

Comparative Governmental and Socio-Legal Models
Role, Function and Limitations of Legislation
Organisations may not adopt good health and safety standards voluntarily therefore
legislation (statutes and other legal instruments enacted by the governing body)
provides a way of making sure minimum health and safety standards are met.
Limitations to the legislative approach include:
–– Little incentive for organisations to go beyond the minimum legal requirements
(they will comply with the letter of the law, but not with its spirit).
–– The need for enforcement and an effective court system (i.e. procedures for the
prosecution and punishment of organisations and individuals who fail to meet
the required standards).
Nature, Benefits and Limitations of ‘Goal-Setting’ and ‘Prescriptive’

Legal Models
Goal-Setting Legislation
–– Sets an objective but leaves it to the duty holder to decide on the best way of
achieving the defined goal.
–– Allows more flexibility in compliance because it is related to the actual risk
present in the individual workplace.
–– Is less likely to need frequent revision and can apply to a much wider range of
workplaces.
–– Is more difficult to enforce because what is “adequate” or “reasonably
practicable” are much more subjective, possibly requiring the intervention of a
court to provide a judicial interpretation.
–– Duty holders need a higher level of competence in order to interpret such
requirements.
Prescriptive Legislation
–– Defines the standard to be achieved in far more explicit terms.
–– Has clearly defined requirements which are more easily understood by the duty
holder and enforced by the regulator.
–– Does not need a higher level of expertise to understand what action is required.
–– Provides a uniform standard to be met by all duty holders.
–– Is inflexible and may lead to an excessively high or low standard.
–– Does not take account of the circumstances of the duty holder and may require
frequent revision to allow for advances in knowledge and technology.
Legal Hierarchy of State and Federal Laws

–– Federal law is created by a federal government (a group of states or provinces
that merge together surrendering their individual sovereignty to the central
government while retaining other limited power).
–– Federal systems aim to ensure uniform standards and regulation throughout the
country since if each state can set their own standards this will inevitably lead to
inconsistencies.
Loss Events in Terms of Failures in the Duty of Care to Protect

Individuals and the Compensatory Mechanisms that May be
Available
A work-related accident or disease may result in loss to the individual or dependants.
There are a number of mechanisms that allow individuals to seek restitution for
damages including:
–– No fault compensation schemes.
–– Employers’ schemes.
–– Social insurance schemes.
Fault compensation scheme:
–– Employer’s liability.
Damages may be classified as:
Economic - actual monetary loss.
Non-economic - pain, suffering, and loss of companionship or amenity.
Compensatory - to compensate the claimant.
Special damages - can be relatively easily quantified because they relate to known
expenditure up until the trial.
General damages - include future expenditure and issues which cannot be precisely
quantified.
Punitive - to punish the wrongdoer.
Purpose of Enforcement and Laws of Contract

Purpose of Enforcement
Enforcement ensures that duty holders:
Deal immediately with serious risks.
Comply with the law.
Are held to account if they fail in their responsibilities.
Principles of Enforcement with Reference to the UK HSE’s

‘Enforcement Policy Statement’ (HSE41)
Proportionality of enforcement - enforcement action should be in proportion to:
Any risks to health and safety.
The seriousness of any breach of law.
Consistency of approach - duty holders managing similar risks expect a consistent
approach regarding:
Advice given.
The use of enforcement notices.
Decisions on whether to prosecute.
The response to incidents.
Transparency - duty holders need:
To understand what is expected of them and what they should expect from the
enforcing authorities.
Clarity on what are statutory requirements that legally apply and what is simply
advice or guidance that is desirable but not compulsory.
Information to employees and their representatives on decisions made and actions
taken.
Targeting - ensures that resources are directed to:
Those whose activities give rise to the most serious risks.
Where the hazards are least well controlled.
Accountability - enforcing authorities should have:
Policies and standards in place against which they can be judged.
An effective and accessible procedure for dealing with comments and complaints.
Laws of Contract
Contract law has many implications in respect of occupational health and safety and
establishes the relationship between an employer and employee or contractors, and
those who manufacture articles or substances and those who buy them.
A contract of employment implies that:
–– The employer will take reasonable care to ensure the health and safety of the
employee.
–– The employee will carry out his or her work with reasonable care and skill.
When articles and substances are manufactured, contracts are established between
the producer (or manufacturer) and the consumer (or end user).
Role and Limitations of the International Labour

Organisation in a Global Health and Safety Setting
Role of the United Nations
ILO Role and International Labour Conference
The International Labour Organisation (ILO):
Is an agency of the United Nations (UN).
Is the global body responsible for drawing up and overseeing international labour
standards.
Has adopted more than 180 conventions and 190 recommendations covering all
aspects of the world of work, half of which are concerned with health and safety
matters.
Role and status of ratified international conventions, recommendations, codes of
practice in relation to health and safety:
The adoption of a convention by the International Labour Conference allows
governments to ratify it and for it to become a treaty in international law.
ILO Conventions are considered international labour standards.
ILO Recommendations are non-binding guidelines so are not ratified by member
countries and do not have the binding force of conventions.
ILO Codes of Practice are not legally binding instruments and are not intended to
replace the provisions of national laws or regulations but aim to serve as practical
guides.
Roles and Responsibilities of ‘National Governments’,

‘Enterprises’ and ‘Workers’: R164 Occupational Safety and Health
Recommendation, 1981
Occupational Safety and Health Recommendation 1981 (R164) sets out the roles
and responsibilities of:
–– Governments.
–– Enterprises.
–– Delegates and committees.
–– Workers.
Use of International Conventions as a Basis for Setting National

Systems of Health and Safety Legislation
International labour standards are legal instruments drawn up by the ILO’s constituents
(governments, employers and workers) that set out basic principles and rights at work.
They are either:
Conventions:
–– legally binding international treaties that may be ratified by member states, and
–– lay down the basic principles to be implemented by ratifying countries,
–– example: Occupational Safety and Health Convention (C155) 1981.
Recommendations:
–– serve as non-binding guidelines,
–– supplement the Convention by providing more detailed guidelines on how it
could be applied, and
–– can also be autonomous, i.e. not linked to any convention,
–– example: Occupational Safety and Health Recommendation (R164) 1981.
Role of Non-Governmental Bodies and Health and

Safety Standards
Relevant Influential Parties
The following influential parties have a key role in influencing health and safety
performance:
–– Employer bodies.
–– Trade associations.
–– Trade unions.
–– Professional groups.
–– Pressure groups.
–– Public.
Importance of Print, Broadcast and Social Media in a Global

Economy
The media play an important role in communicating health and safety issues through
print, broadcast and the Internet.
The media can change attitudes to health and safety by publicising enforcement
action, sanctions and also good health and safety performance.
Benefits of Schemes which Promote Co-operation on Health and

Safety Between Different Companies
There are benefits to be had in schemes which promote co-operation on health and
safety between different companies:
–– Good neighbour schemes encourage larger organisations to help smaller
businesses and contractors who do not have access to the same health and
safety expertise.
Adverse Effects on Business Reputation

Following any adverse health and safety incident there will be financial implications
for the organisation and indirect costs the effect of which cannot easily be
determined.
One such effect is on the stakeholders of an organisation who include:
–– Employees who rely on the organisation for employment.
–– Other businesses (suppliers and contractors) who trade with the organisation.
–– Businesses that benefit indirectly from the presence of an organisation (local
shops).
–– Shareholders who own the organisation and wish a satisfactory financial return.
An Organisation’s Moral Obligations to Raise Standards Within

their Supply Chains
Global brands are in a superior position to make a positive impact on health and safety
standards, both within their organisations and throughout their supply chain:
Competition between suppliers to deliver products at the lowest price impacts on
the resourcing of health and safety in supply organisations.
Global organisations should take responsibility to ensure that financial competition
between suppliers does not result in erosion of health and safety standards.
Meaning of ‘Self-Regulation’
Self-regulation is the process whereby an organisation monitors its own adherence
to health and safety standards, rather than having an outside agency, such as a
governmental body, monitoring and enforcing them.
Benefits are:
The organisation can set and maintain its own standards without external
interference.
If problems arise, the organisation can:
–– More easily keep its own internal affairs private.
–– Avoid the significant national expense of establishing an enforcement agency.
Disadvantages are:
Attempts to self-regulate may fail because individual organisations may believe there
is little advantage in establishing good standards if similar organisations choose to
ignore them.
Employees who work in a self-regulated organisation may experience poor standards
with an increased frequency of accidents and ill health.
Role and Function of Corporate Governance in a System of Self-Regulation

Corporate governance is the system by which organisations are directed and
controlled by their board of directors who make broad strategic decisions which
affect the direction of the organisation.
Their area of control should include occupational health and safety and to ensure
good health and safety performance the following matters should be addressed
within the organisation:
–– Demonstration of commitment by senior management.
–– Health and safety reviewed at board level.
–– Access to and provision of competent advice.
–– Training and competency in health and safety for all staff.
–– Consultation with the workforce and health and safety representatives with
concerns reaching the right level within the organisation.
–– Systems in place to assess risks and implement suitable control measures.
–– Awareness of activities taking place in the organisation, including those of
contractors.
–– Regular information received on accidents and ill health.
–– Targets set to allow the organisation to improve standards and to benchmark
performance.
–– Significant changes in working arrangements brought to the attention of the
board.
How Internal Rules and Procedures Regulate Health and Safety

Performance
For an organisation to effectively manage occupational health and safety it must
devise and implement rules and procedures that enable workers to adhere to safe
working practices.
For rules to be effective they must be monitored by supervisors and managers who
have the authority to enforce and impose sanctions.
Short Questions
1. An organisation has decided to adopt a self-regulatory model for its health and
safety management system.
Distinguish between:
(a) the benefits; and (6)
(b) the limitations (4)
of self-regulation in connection with the management of health and safety.
2. (a) Outline the benefits and limitations of prescriptive legislation. (5)
(b) Outline the benefits and limitations of goal-setting legislation. (5)
Give examples in both cases to illustrate your answers.
3. (a) Outline the meaning of the phrase ‘punitive damages’ in the context of a
compensation award, and clearly identify the purpose of these damages
and to whom they are paid. (5)
(b) (i) In the context of claims for compensation, outline the meaning of
the term ‘no fault liability’. (2)
(ii) In the context of claims for compensation, outline the meaning of
the term ‘breach of duty of care’. (3)
Long Questions
4. (a) In relation to the improvement of health and safety within companies,
describe what is meant by:
(i) corporate probation; (2)
(ii) adverse publicity orders; (2)
(iii) punitive damages. (3)
(b) Outline the mechanism by which the International Labour Organisation
can influence health and safety standards in different countries. (7)
(c) Explain the role of legislation in improving workplace health and safety.
(6)
5. Non-governmental bodies have an important role in influencing health and

safety standards.
Identify FIVE relevant influential parties and outline their role in influencing
health and safety performance. (20)
Model Answers
Short Questions
Question 1
Interpretation
This question simply asks you to explain the benefits of self-regulation; i.e. speed,
flexibility and ownership, versus the limitations arising from poorer compliance.
Plan
(a) Benefits: (b) Limitations:

Developed by those involved - All those involved may not
ownership. operate within the self-
regulatory rules.
Quicker to achieve than
statutory regulation. Danger of self-interest being
put ahead of employee or
Higher levels of compliance.
public interest.
Easily be adapted/updated.
Lower levels of compliance.
Cheaper/quicker means of
No independent auditing.
addressing issues.
May result in closer relationship
between industry and clients.
Suggested Answer
(a) One of the more important benefits of self-regulation is that it is developed

by those directly involved in the management of health and safety and this
can generate a sense of ownership. Other benefits include the fact that it
may be quicker to achieve than statutory regulation and can result in higher
levels of compliance. It can also be easily adapted or updated and may offer a
cheaper and quicker means of addressing issues. Finally, the application of self-
regulation may result in a closer relationship between industry and its clients.
(b) Key limitations of the model are that all those involved may not operate within
the self-regulatory rules and that there is a danger of self-interest being put
ahead of employee or public interest. Additionally, self-regulation can result
in lower levels of compliance because there is no third party or independent
auditing and it may not be valued highly by stakeholders.
Question 2
Interpretation
This question is clearly structured and simply requires a comparison of prescriptive and
goal-setting legislation in terms of benefits and limitations. Note that the benefits of
one type of legislation, i.e. “prescriptive legislation is not difficult to enforce”, is the
limitation of the other, i.e. “goal-setting legislation is more difficult to enforce”.
Plan
(a) Prescriptive Legislation

Benefits: Limitations:
Requirements clear and easy to Inflexible.
apply.
May require standards to be
Provides the same standard too high or too low.
for all.
Does not take account of
Not difficult to enforce. local risks.
Does not require a high level of May need frequent revision.
expertise.
(b) Goal-Setting Legislation

Benefits: Limitations:
More flexibility in the way Open to wide interpretation.
compliance may be achieved.
Duties and standards may be
Is related to actual risk. unclear until tested in courts.
Can apply to a wide variety of More difficult to enforce.
workplaces.
May require a higher level
Less likely to become out of of expertise to achieve
date. compliance.
Suggested Answer
(a) The benefits of prescriptive legislation are that its requirements are clear and
easy to apply and it provides the same standard for all. It is not difficult to
enforce and does not require a high level of expertise.
Its limitations are that it is inflexible and may be inappropriate in some
circumstances by setting standards too high or too low. It does not take
account of local risks and may need frequent revision to keep up with changes
in technology and knowledge.
(b) The benefits of goal-setting legislation are that it has more flexibility in the
way compliance may be achieved and it is related to actual risk. Also it can
apply to a wide variety of workplaces and it is less likely to become out of
date.
These benefits are countered by the fact that it may be open to wide
interpretation and the duties it lays down and the standards it requires may be
unclear until tested in courts of law. As a result it may become more difficult
to enforce and may require a higher level of expertise to achieve compliance.
Question 3
Interpretation
This, again, is a well signposted question and simply asks you to outline key concepts
relating to punitive damages, no fault liability and duty of care.
Plan
(a) Punitive damages:

Monetary award paid to a claimant.
Not awarded to compensate.
Awarded to reform or deter the defendant.
Both a punishment and a deterrent.
Amount of award determined by court - not linked to the loss.
(b) (i) No fault liability:
Independent of any wrongful intent/negligence.
Injury sufficient to confer liability.
Compensation paid by insurance or government.
(ii) Breach of duty of care:
Duty of care owed by an employer to employee.
Employer breached duty.
Breach led to the loss.
Suggested Answer
(a) “Punitive damages”, are a financial or monetary award which, while paid to
a claimant, are not awarded to compensate them, but in order to reform or
deter the defendant and similar persons from pursuing a course of action such
as that which damaged the claimant. As such they are both a punishment and a
deterrent. The amount of the award is determined by a court and is not linked
to the losses suffered by the claimant.
(b) (i) “No fault liability” is a liability which is independent of any wrongful
intent or negligence. As such, an injury alone is sufficient to confer
liability with compensation being paid either by an insurance company or
from a government fund.
(ii) There are three standard conditions that must be satisfied in order to
establish a breach of duty of care. These are that a duty of care was
owed by an employer to his employee; that the employer acted in
breach of that duty by not doing everything that was reasonable to
prevent foreseeable harm and lastly that the breach led directly to the
loss, damage or injury.
Long Questions
Question 4
Interpretation
This is another well signposted question, this time a long question. The first part simply
asks you to describe the concepts of corporate probation, adverse publicity orders, and,
again, punitive damages. If you are familiar with these concepts, then providing the
answer should not pose a problem. The second and third parts of the question require
a little more thought in order to indicate the way in which both the ILO, and national
legislation influence, in their own ways, health and safety standards in the workplace.
Plan
(a) (i) Corporate probation:

Supervision order.
Imposed by court on a company which committed a criminal
offence.
The court might:
–– Require company to review policy/procedures.
–– Initiate training programme (directors/senior management).
–– Reduce the number of accidents.
Aim is to instigate change in culture under the supervision of the
court.
(ii) Adverse publicity order:

Publicise the failings of an organisation.
Seek to change conduct through public perception.
Requires company to make public statement and change approach to
management of H&S.
(iii) Punitive damages:
Monetary award paid to a claimant.
Not awarded to compensate.
Awarded to reform or deter the defendant.
Both a punishment and a deterrent.
Amount of award determined by court - not linked to loss.
(b) Conventions/recommendations.
Ratification of conventions commits to national law.
Report to the ILO detailing compliance with conventions.
Complaint procedures for violation of ratified convention.
Technical assistance.
Apply pressure internationally on non-participating countries.
(c) Sets minimum standards.
Can be enforced by a regulator.
Allows punishment if standards are not achieved.
Kept up to date by government.
Applies to all workplaces ensuring consistent application.
May be prescriptive or goal-setting (ACoPs, guidance).
Suggested Answer
(a) (i) Corporate probation is a supervision order imposed by a court on a

company that has committed a criminal offence. When applied to
a health and safety offence, the court might require the company
to review its safety policy or health and safety procedures, initiate a
training programme for its directors and senior management or reduce
the number of its accidents. The aim is to instigate a change in the
organisation’s culture under the supervision of the court.
(ii) The intention of an adverse publicity order would be to publicise the

failings of an organisation and seek to change its conduct through public
perception. It requires the company to make a public statement and to
change its approach to the management of health and safety.
(iii) “Punitive damages” is a financial or monetary award which, while paid to
a claimant, is not awarded to compensate them, but in order to reform
or deter the defendant and similar persons from pursuing a course of
action such as that which damaged the claimant. As such it is both a
punishment and a deterrent. The amount of the award is determined by
a court and is not linked to the losses suffered by the claimant.
(b) The ILO develops international labour standards through conventions. These
are supplemented by recommendations containing additional or more detailed
provisions. Ratification of conventions by member states commits them to
apply the terms of the convention in national law. There is also a requirement
for member states to submit a report to the ILO detailing their compliance with
the requirements of the conventions that they have ratified. The ILO can also
initiate complaint procedures against countries for a violation of a convention
that they have ratified and also provide technical assistance to member states
where this is necessary. In addition ILO can also apply pressure internationally
on non-participating countries to adopt ILO standards.
(c) Legislation improves workplace health and safety by setting minimum standards
which can be enforced by a regulator and allowing punishment of the offender
if standards are not achieved. It is kept up to date by government and applies
to all workplaces ensuring consistent application. The legislation may be
prescriptive, or goal-setting, supported by approved codes of practice or
guidance to assist interpretation of standards required.
Question 5
Interpretation
The NEBOSH syllabus in IA2.4 ‘The Role of Non-Governmental Bodies and Health and
Safety Standards’ requires you to be able to give “Examples of relevant influential parties
(employer bodies; trade associations; trade unions; professional groups (e.g. IOSH, ASSE,
Board of Certified Safety Professionals); pressure groups, public, etc., and their role in
influencing health and safety performance”, consequently this question comes as no
surprise. The bodies referred to are already listed in the syllabus so all we need to do is to
expand on their individual roles in influencing health and safety performance.
Plan
Relevant influential parties:
Employer bodies
Represent interests of employer.
CBI in UK:
–– Main lobbying organisation for UK business.
–– Works with government, legislators, policy-makers to help UK businesses
compete more effectively.
Trade associations
Membership of companies who operate in a particular area of commerce.
Promote common interests/improvements in quality, health, safety, environmental
and technical standards:
–– Publication of guidelines, information notes, codes of practice, and regular
briefing notes on technical issues and regulatory developments.
–– Sharing of good practice.
–– Provision of news and events.
–– Meetings, workshops, seminars to enable networking/exchange of information/
ideas on technical and safety issues.
Trade unions
Organisation of workers.
Common goals in key areas wages/hours/working conditions.
Negotiates with the employer on behalf of its members:
–– Contracts.
–– Wages.
–– Work rules.
–– Complaint procedures.
–– Workplace safety and policies.
Agreements negotiated binding on rank and file members.
Unions may appoint safety representatives:
–– Investigate accidents.
–– Conduct inspections.
–– Sit on a safety committee.
Professional groups (e.g. IOSH)
Individuals who work in a particular profession.
Achieved a defined level of competence.
Members pay a subscription/receive benefits.
UK, Institution of Occupational Safety and Health (IOSH):

–– Largest body for health and safety professionals.
–– Chartered Safety and Health Practitioners.
–– Sets professional standards.
–– Supports and develops members.
–– Provides authoritative advice and guidance on health and safety issues.
Pressure groups
Organised group of people who have a common interest.
Seek to influence government policy or legislation.
Carry out research.
Lobby members of parliament.
Aim to influence public and government opinion.
UK - Centre for Corporate Accountability:
–– Promotion of worker and public safety.
–– Focus on role of state bodies in enforcing health and safety law/investigating
work-related deaths and injuries.
Suggested Answer
Employer Bodies
These represent the interests of employers. In the UK the main body is the
Confederation of British Industry (CBI). The CBI helps create and sustain the conditions
in which businesses in the United Kingdom can compete and prosper for the benefit
of all. The CBI is the main lobbying organisation for UK business on national and
international issues. It works with the UK government, international legislators and
policy-makers to help UK businesses compete more effectively.
Trade Associations
Trade associations are formed from a membership of companies who operate in a
particular area of commerce and exist for their benefit. They can promote common
interests and improvements in quality, health, safety, environmental and technical
standards. This can be through various appropriate means. For example, the publication
of guidelines, information notes, codes of practice and regular briefing notes on
technical issues and regulatory developments. Sharing of good practice can be facilitated
together with provision of news and events appropriate to their members’ areas of
activity.
There can also be meetings, workshops and seminars held, depending on an
association’s membership, both internationally and at a national/regional level, to
enable networking and the exchange of information and ideas, for example on technical
and safety issues.
Safety is of prime importance in any industry and there is usually a way of publicising and
circulating safety messages to the members on a regular basis.
Membership of a trade association is generally available to companies and organisations
active in the relevant industry.
Trade Unions
A trade union is an organisation of workers who have formed together to achieve
common goals in key areas such as wages, hours, and working conditions. The trade
union negotiates with the employer on behalf of its members and negotiates contracts
with employers. This may include the negotiation of wages, work rules, complaint
procedures, rules governing hiring, firing and promotion of workers, benefits, workplace
safety and policies. The agreements negotiated by the union leaders are binding
on the rank and file members and the employer and in some cases on other non-
member workers. In the UK, Unions may appoint safety representatives from amongst
the workers who may investigate accidents, conduct inspections and sit on a safety
committee.
Professional Groups
A professional group is an organisation of individuals who work in a particular
profession and have achieved a defined level of competence. Members typically pay a
subscription to join the group and receive a range of benefits. In the UK, the Institution
of Occupational Safety and Health (IOSH) is the largest body for health and safety
professionals. It is an independent, not-for-profit organisation that sets professional
standards, supports and develops members and provides authoritative advice and
guidance on health and safety issues.
Pressure Groups
A pressure group is an organised group of people who seek to influence government
policy or legislation. They can also be described as ‘interest groups’, ‘lobby groups’ or
‘protest groups’. They carry out research, lobby members of parliament and so aim
to influence public and ultimately government opinion. One example in the UK is the
Centre for Corporate Accountability. This is concerned with the promotion of worker
and public safety. Its focus is on the role of state bodies in enforcing health and safety
law and investigating work-related deaths and injuries.
Element IA3: Loss Causation and Incident

Investigation
Theories/Models and Use of Loss Causation
Techniques
Accident/Incident Ratio Studies
There is a relationship between the numbers of different types of accident as shown in
the following accident triangle:
Bird’s accident ratio triangle
There are certain limitations when applying such data:

Not every near-miss or minor incident involves risks which could actually have led to
a serious incident or fatality.
Be careful comparing:
–– Different triangles.
–– Different definitions, (e.g. lost-time accidents).
–– Different industries (with different types of risk).
Statistical significance - representative data is necessary for a meaningful comparison
between a workplace and the industry as a whole.
Domino and Multi-Causality Theories

Single Cause Domino Theory
Heinrich’s Accident Sequence:
–– Ancestry and social environment.
–– Fault of person.
–– Unsafe act and/or mechanical or physical hazard.

–– Accident.
–– Injury.
If this sequence is interrupted by the elimination of one of the factors, then the
injury cannot occur and the accident has been prevented.
Bird and Loftus Accident Sequence:
–– Lack of control by management.
–– Basic causes (i.e. personal and job factors).
–– Immediate causes (substandard practices, conditions or errors).
–– Direct causes.
–– Loss (negligible, minor, serious or catastrophic).
Multi-Causal Theories
There may be more than one cause of an accident, not only in sequence, but
occurring at the same time.
A major disaster normally has multiple causes, with chains of events, and
combinations of events.
The essential features of the multiple causation approach are shown in the following
diagram.
Features of the multiple causation approach
Immediate, Underlying and Root Causes

Definitions from the UK HSE guidance, Investigating Accidents and Incidents, HSG245
are:
Immediate cause refers to the direct cause of the accident, i.e. the actual agent of
injury or damage, such as the sharp blade of the machine.
Underlying causes are the less obvious reasons for the incident - the unsafe acts
and unsafe conditions, such as the guard being removed.
Root causes are the ultimate failings from which all other failings arise - typically
management and organisational failings such as failure to train people properly or
failure to assess risks.
Unsafe Acts and Unsafe Conditions
An unsafe act is human performance which is contrary to accepted safe practice and
which may lead to an accident.
Unsafe conditions are the physical condition of the workplace, work equipment,
the working environment, etc. which might be considered unsafe and could
foreseeably lead to an accident if not dealt with.
Latent and Active Failures - Reason’s Model of Accident Causation

James Reason (an occupational psychologist) has developed a model of accident
causation for organisational accidents, which are rare but often have disastrous
consequences (e.g. Piper Alpha, 1988).
Reason’s model shows that organisational accidents do not arise from a single cause but
from a combination of active and latent failures.
Adapted version of Reason’s model of accident causation
Defence barriers between the hazard and a major incident prevent the incident,
(e.g. containment of the hazard, safe operating procedures, etc.), provide warning of
danger, (e.g. an alarm) and mitigate the consequences, (e.g. means of escape).
However, the barriers are not perfect and can be defeated by:
–– Active failures - unsafe acts which have immediate effects on the integrity of
the system, usually committed by those directly involved in the task. The cause
of the failure will be due to an error (accidental) or a violation (deliberate).
–– Latent failures - at the strategic levels, both in the organisation and external
environment, which remain dormant until they interact with the local factors,
unsafe acts and work environments and increase the likelihood of an active
failure (e.g. lack of supervision, maintenance failure).
When the gaps created by active failures align with those created by the latent
conditions, the opportunity exists for a serious outcome.
Fault Tree Analysis (FTA)

Can be used in accident investigation and in a detailed risk assessment.
A logic diagram based on the principle of multi-causality, which traces all branches of
events which could contribute to an accident or failure.
The starting point is the undesired event (called the Top Event).
The immediate and necessary contributory fault conditions leading to that event are
added next.
These may each in turn be caused by other faults, etc.
Each branch of the tree is further developed until a primary failure (such as a root
cause) is identified.
Event Tree Analysis (ETA)

Concerned with identifying and evaluating the consequences following an event (the
Initiating Event).
Used to investigate the consequences of loss-making events in order to find ways of
mitigating, rather than preventing, losses.
Stages involved in carrying out ETA are:
–– Identify the Initiating Event of concern.
–– Identify the controls that are assigned to deal with the Initiating Event.
–– Construct the event tree beginning with the Initiating Event and proceeding
through the presence of conditions that may exacerbate or mitigate the
outcome.
–– Establish the resulting loss event sequences.
–– Identify the critical failures that need to be dealt with.
–– Quantify the tree if data is available to identify the likelihood or frequency of
each possible outcome.
Bowtie Model
FTA is concerned with analysing faults which might lead to an event.
ETA considers the possible consequences once an undesired event has taken place.
Both can be combined into a bow-tie diagram:
–– Faults (initiating events) lead to a critical event.
–– The critical event generates consequences.
–– These need to be mitigated through the use of barriers.
Swiss Cheese Model
An organisation’s defences against hazards are modelled as a series of barriers
(represented as slices of cheese).
The holes in the cheese slices:
–– represent weaknesses in individual parts of the system; and
–– are continually varying in size and position in all slices.
The system as a whole produces failures when:

–– holes in all of the slices momentarily align; and
–– a hazard passes through holes in all of the defences, leading to an accident.
Behavioural Root Cause Analysis

Works back through the causal chain of an accident to identify the most basic
preventable cause(s) that initiated the incident.
Aims to identify the behaviours that led to unsafe acts.
The simple method of asking ‘why’ as the causal chain is investigated back to source
will eventually come up with an unsafe act of behavioural origin.
Quantitative Analysis of Accident and Ill-Health Data

Calculating Loss Rates from Raw Data
Accident/Incident Frequency Rate
Number of work-related injuries × 100,000

Total number of man-hours worked
Accident Incidence Rate

Average number of persons employed
Accident Severity Rate
Total number of days lost × 1,000

Ill-Health Prevalence Rate
Total number of cases of ill health in the population × 100

Number of persons at risk
Presenting and Interpreting Loss Event Data

Histograms
Type of bar chart used to illustrate a frequency distribution.
Pie Charts
Circular diagram, where the pie is divided into ‘slices’ representing the fractions into
which the total of the variable is divided.
Line Graphs
Rather than using a bar chart or histogram, the information can be displayed as a series
of data points connected by straight lines.
Shows the relationship between two variables. Many graphs are needed to show all the
values in a table of data. It is possible to plot a number of sets of values on one graph if
one of the variables remains the same for each. The slope of the graph shows the rate of
change
Principles of Statistical Variability, Validity and the Use of

Distributions
Statistical variability refers to the spread or distribution of a particular variable in
the population under consideration.
Need to collect a sample of sufficient size so can say it is likely to be representative
of the whole population.
Normal distribution is used to calculate probabilities. Providing that the values
of the mean and standard deviation of a normal distribution are known, then it is
possible to make predictions with the aid of standardised normal tables.
Reporting and Recording of Loss Events (Injuries, Ill

Health, Dangerous Occurrences) and Near Misses
Reporting Requirements and Procedures
Requirements for reporting and recording certain loss events are set out in the
ILO Occupational Safety and Health Convention (C155) and the accompanying
Protocol (P155). Employers should:
–– Record and notify occupational accidents, suspected cases of occupational
disease, dangerous occurrences and commuting accidents.
–– Inform employees about the recording system and notifications.
–– Maintain records and use them to help prevent recurrence.
Notifiable diseases should at least include the prescribed diseases listed under ILO
Convention C121.
Internal Reporting and Recording

Accident investigation records:
–– Used to provide management with an objective tool for measuring and
evaluating safety performance.
–– Used as a tool to help control the accidents that are causing the injuries and
damage.
–– Should provide the following information:
–– The relative importance of the various injury and damage sources.
–– The conditions, processes, machines and activities that cause the injuries/
damage.
–– The extent of repetition of each type of injury or accident in each operation.
Loss and Near Miss Investigations

Implied Legal Requirements
Legal duty that employers may be subject to can only be effectively discharged if some
form of investigation takes place. These include duties associated with:
Risk assessment and review of health and safety arrangements.
Statutory reporting of accidents.
Industrial injuries benefit or compensation.
Common law duty of care.
The UK HSE have produced a useful guide entitled HSG245, Investigating Accidents and
Incidents.
Reasons for Carrying Out Investigations

Legal reasons.
Data gathering.
Establishing root, underlying and immediate causes.
Benefits of Carrying Out Investigations

Prevention of recurrence.
Improved employee morale.
The development of managerial skills.
Investigation Procedures and Methodologies

Accident/Incident Report Forms
Should collect the following information:
A summary of events.
Root cause/immediate causes.
Details of witnesses.
Information about injury, ill health or loss sustained.
Recommendations.
Steps to Take Following an Adverse Event

Initial actions:
Emergency response.
Initial report.
Initial assessment and investigation response.
The decision to investigate:
–– Minimal level investigation - supervisor looks into the circumstances.
–– Low level investigation- a short investigation by the line manager.
–– Medium level investigation - a more detailed investigation by the relevant
supervisor or line manager.
–– High level investigation - a team-based investigation, involving supervisors or line
managers, health and safety advisers and employee representatives.
The Investigation
If a full investigation is deemed necessary the following four steps set out a systematic
and structured approach.
1. Gathering of Relevant Information
Accident investigation should:
Take place as soon as possible after the event.
Include inspection of the scene of the accident to collect any information
relating to physical conditions of the plant, equipment and building.
Involve interviewing witnesses and any others likely to give information
concerning any unsafe acts or practices which may have contributed to the
accident.
Interviewing Witnesses
Types of Witness
–– The victim.
–– The eyewitness.
–– People who can offer corroborative statements.
Interviewing Technique
–– Put the person being questioned at ease.
–– Carry out interviews at the scene of the accident if possible.
–– The investigator should be looking for the witness’s version of the accident.
2. Analysis of Information
Examine all the facts, put them together to establish what actually happened and
determine why it happened. Discover the immediate, underlying and root causes by
systematically working through the event.
3. Identify Control Measures
Identify all possible control measures and select the ones which are most suitable
(taking account of reasonable practicability and the effectiveness of different control
types).
4. Plan and Implement
Report to management summarising all available evidence accurately and
recommend future action necessary to prevent a recurrence.
Plan what has to be done and do it, setting timescales (short-term versus long-
term), allocating specific actions to individuals and checking that the proposed
actions have actually been implemented.
Involvement in the Investigation Process

Managers
The objective of any analysis or investigative report is to provide management with
a means of deciding why their policies and procedures failed to prevent accidents,
injuries and ill health.
Supervisors
The immediate supervisor is likely to know most about the situation and so
best suited to carry out the enquiries necessary for the investigation to reach a
satisfactory conclusion.
Employees’ Representatives
Have the right to investigate both accident and ill-health incidents.
Safety Practitioner
In the case of serious accidents, the company safety practitioner should be in charge
of the investigation.
Communications Focusing on Remedial Actions and Lessons Learnt

Having investigated a loss event and identified immediate and root causes and remedial
actions, the relevant information must be communicated, using the most appropriate
techniques, to all those who need to know; may relate to changes in systems of work,
training, etc.
Short Question
1. Witnesses can often provide essential information for accident investigations.
Describe the various issues to think about during the interview process so that the
best quality of information relating to a workplace accident can be obtained from
witnesses. (10)
Long Questions
2. An accident has occurred where a forklift truck skidded on a patch of oil and
collided with an unaccompanied visitor, causing a crush injury to their leg.
(a) Outline, with justification, why the accident should be investigated. (4)
(b) Outline the actions necessary to collect evidence for the investigation of
the accident. Assume that the initial responses of reporting the accident and
securing the scene have taken place. (8)
(c) Describe the factors which should be taken into account when analysing the
information gathered as evidence. (8)
3. Accident investigations can vary in terms of duration, size and specialisms of the
investigation team and resources allocated.
(a) Explain why it is important for an organisation to investigate workplace
accidents. (10)
(b) Outline the factors that would influence the level of investigation required
following a workplace accident. (10)
Model Answers
Short Question
Question 1
Interpretation
This question simply requires you to describe the best way to carry out an accident
investigation interview in order to obtain the facts. If you have been involved in accident
investigations previously, then much of this answer will be familiar to you from past
experience.
Plan
Interview as soon as possible after the event - injury/shock make this difficult.
Suitable environment.
Put witness at ease.
Interview one witness at a time.
Establish good rapport.
Purpose - preventing recurrence, not to apportion blame.
Record the findings.
Establish facts.
Avoid leading questions/implied conclusions.
Sketches/photographs.
Listen to witness without interruption.
Give sufficient time to answer.
Issues summarised/agreed.
Suggested Answer
The first requirement is to interview as soon as possible after the event although injury
or shock may make this difficult. The interview should be carried out in a suitable
environment where the witness can be put at ease. Only one witness should be
interviewed at a time, with the interviewer taking time to establish good rapport. The
purpose of the interview should be explained, that of preventing a recurrence and not
to apportion blame, and also the need to record the findings. Questioning techniques
should establish facts and avoid leading questions or implied conclusions. Sketches
and photographs may help with the interview. Finally, the witness should be listened to
without interruption, given sufficient time to answer, and the issues discussed should be
summarised and agreed at the end of the interview.
Long Questions
Question 2
Interpretation
We have a simple scenario here and the answer must relate back to this scenario
wherever necessary. There are three parts to the question, so our answer must be in
three parts. Note the marks breakdown. Part (a) is simple enough. Part (b) is concerned
with the collection of evidence following the event. Part (c) is concerned with the
analysis of the investigation evidence; this is perhaps the part of the question most open
to misinterpretation. Factors to consider (things to think about) = organisational, job and
personal factors = HSG48.
Plan
Why investigate - causes, prevention, insurance, morale of staff, IR, PR.
Evidence collection:
–– From scene - photos, sketch, samples, text, CCTV.
–– From witnesses - interview; from records & documents - risk assessments,
maintenance logs, etc.
Factors:
–– Organisational - culture, peer group pressure, practices, etc.
–– Personal - drugs/alcohol, training, experience, attitude, etc.
–– Job - shift, comfort, environment, etc.
Suggested Answer
(a) The accident should be investigated for various reasons. First, investigation
allows for the identification of the immediate and underlying causes of the
accident and the various factors that may have contributed to it. This in turn
should allow for the identification of the corrective actions necessary to prevent
a recurrence of this event and others like it.
Second, any investigation gives the organisation a good opportunity to assess its
compliance with legal requirements and best practice.
Third, an investigation provides an opportunity for management to
demonstrate a clear commitment to health and safety and show that they are
interested. This has a direct impact on the safety culture of the organisation and
on employee morale. Indeed, employee morale would suffer badly if the event
were not investigated.
Fourth, the factual evidence collected during the investigation will be vital in
deciding liability issues should there be a civil claim for compensation based on
this accident.
(b) Assuming that first-aid assistance has been given to the injured visitor, and
that the scene has been secured, the first actions must be to collect evidence
from the scene itself before that evidence becomes contaminated. This would
be done by photographing the scene, or perhaps even videoing it, drawing
sketches and taking measurements to annotate that sketch. It would also be
appropriate to write a brief description of the scene including any additional
information that may be relevant but that is not apparent from photographs
or a sketch, (e.g. a loud tannoy, or high or low ambient temperatures in the
workplace). CCTV footage may be available and should be secured.
Factual information about the environment around the accident scene must
also be gathered, so the condition of the floor, light levels, markings on the
floor, the presence of pedestrian walkways and signage must all be recorded
in some way. The oil patch must be photographed in situ before clear up and
perhaps a sample taken as evidence.
The position of the forklift truck must be carefully recorded and any forensic
evidence that shows its route must also be noted (such as skid marks on
the floor, collision marks on surrounding structures such as racking, etc.).
The FLT must also be carefully examined to determine its condition and the
acceptability of its safety-related features. This examination should also take
into account the position of any load on the FLT and the capacity rating of the
FLT.
The oil spill on the floor will have to be investigated in more detail to determine
its source and the reasons for its presence on the floor.
Failures in the spill detection and clear-up procedures may be identified.
Following investigation of the physical evidence, the background documents
and records must be scrutinised and copies may have to be taken. Risk
assessments, safe systems of work, operating procedures, FLT maintenance and
inspection logs, training records and other company documentation will all
have to be examined.
Another vital source of information must also be addressed during the
investigation and that is, of course, the witnesses. The FLT driver should be
isolated from other people to prevent possible contamination of their evidence.
They should be interviewed about the event as soon as possible to prevent the
natural process of reviewing an event and then embellishing it. Other witnesses
would also be interviewed as soon after the event as possible, including the
injured party, although this may depend on their availability. Other personnel
who did not directly witness the scene, but who have information relevant to
the investigation, may also be interviewed and this would include reception
staff who greeted the visitor to site, and maintenance personnel who recently
carried out work on the FLT.
(c) The various factors that will have to be analysed in order to determine the
causes of this accident can be thought about in various ways, but one way that
might be useful is to consider organisational, job and personal factors.
Organisational factors that should be considered in the analysis would include:
The safety culture of the organisation, especially as perceived by the staff
and the FLT driver.
Peer group pressure and the influence of this on the behaviour of the driver
(he may have been speeding because to drive slowly is considered unmanly)
and the visitor (they may have been in a group of peers and behaving
recklessly).
Pay and reward schemes in operation. The FLT driver may have been
incentivised to drive fast due to the pay and reward system.
Personal factors that should be considered would include:
The basic personality traits of the driver, their attitude towards health and
safety in general and pedestrian safety in particular.
Their training in FLT driving, including basic skills training, job-specific
training and any induction training they may have had into the workplace.
The FLT driver’s experience and their general reliability and competence
level.
The intelligence level of the driver and their ability to understand
instructions.
The driver’s fitness as assessed against the fitness criteria that exist for FLT
drivers.
Factors that may have compromised the driver’s ability to function correctly,
such as fatigue, stress, drugs and alcohol.
Job factors would play an enormous part in the analysis and the following factors
would have to be considered:
Signage in the workplace, markings on the floor and the provision of barriers
to segregate pedestrians and vehicles.
The levels of supervision in the workplace.
Procedures and rules in place to govern the movement of visitors around the
site.
Procedures and rules relevant to the movement of FLTs within the
workplace.
Maintenance, testing and inspection regimes in place for the FLT.
Shift patterns, hours of work and workload allocation within the workplace.
Question 3
Interpretation
A two-part answer is required here. Part (a) requires an explanation, so depth and detail
are implied. The question itself is very direct. Part (b) requires an outline of factors, but
again is quite direct.
Plan
Identify causes (underlying and immediate), take corrective action, identify cost,
promote positive culture, and provide information for legal reporting and insurance
claims.
Seriousness or potential seriousness (severity, number involved), nature of accident
(complexity), use of permits, breach of legal requirements or may involve a civil
claim.
Suggested Answer
(a) There are many important reasons why an organisation should investigate
workplace accidents. These might be considered under the following areas:
Identification of causes. The true causes of an accident must be discovered
if any form of effective corrective action is to be taken. It is important that
the true underlying causes are identified as well as the immediate causes.
These principles are clearly identified in both the simple domino theory of
accident causation as well as the more complex multi-causality theory.
To take corrective action to prevent recurrence. Unless the true root
causes and underlying causes of accidents are known, then effective
corrective action to prevent recurrence cannot be identified and taken. The
prevention of accidents is a legal, moral and economic imperative for an
organisation.
Underlying deficiencies in safe systems, risk assessments, etc. must be

identified and corrected. Even though these deficiencies may not have
directly led to a particular event, they will contribute to future accidents in
the workplace. Deficiencies must be addressed in the interest of continuous
improvement.
Investigations can be used to determine cost (financial) to an organisation.
This may be important as a way of promoting good health and safety
internally, by highlighting the financial impact on the organisation of failure.
Good accident investigation is vital for worker morale and helps to promote
a positive culture by involving people in a practical way in health and safety
in the workplace. In the absence of visible investigation, workers will make
their own minds up about the organisation’s priorities and they may form
negative views.
Accident investigation may be a necessity in order to gather information for
legal requirements regarding accident reporting.
Finally, accident investigation is often mandatory under insurance policies for
the simple reason that an accident may result in a claim for compensation.
In such an event the insurance company must have good quality factual
information, gathered at the time of the accident, in order to make an
informed decision about liability; do they fight the claim or pay out?
(b) The various factors that might influence the level and complexity of an accident
investigation would include the following:
Seriousness of the event. Accidents that have minor outcomes may not
require detailed, complex investigations because they had minor outcomes.
No one was seriously hurt; there will not be a claim for compensation, so
why spend a lot of time and effort investigating? This argument can be
effectively applied to some accidents but not all (as we shall discuss next).
Potential seriousness. Accidents that result in minor injury, or minor
property damage and even near misses, can have the potential for very
serious outcome. That outcome was not realised in this instance, but the
possibility existed. Therefore, one factor that is crucial to examine is the
potential of an event to have serious outcomes in terms of severity of injury
caused and/or number of people involved. Where there is the potential
for high severity outcomes, then a more detailed and complex investigation
would be warranted. Where that potential does not exist, then a simpler,
quicker investigation will suffice.
Nature of accident. Many accidents are very simple in their causation. They
take little time to investigate and little time to analyse. A complex and in-
depth investigation is not going to reveal any hidden depths and therefore
is unwarranted. An organisation can learn all it needs to know with a simple,
quick investigation.
Permits-to-work. Any event involving permits-to-work (PTWs) will be,
by the very nature of PTWs, high-risk work and often complex high- risk
work. It is therefore often sensible to undertake a thorough and detailed
investigation to ensure that the permit system is working correctly. Any
accident occurring under permit control implies a failure of the permit
system itself and therefore must be taken seriously (if the permit system was
working well, then the accident would not have happened).
Any event that results in the necessity to report to the enforcing authorities
should be investigated in more depth and detail because of the reporting
requirements. This is not because a complex investigation is required to
discover the facts of the event. Often these events are relatively simple.
Instead, it is because of the potential involvement of the enforcer at some
stage after the event has been reported. Site visits, enforcement actions and
ultimately prosecution may result from the report and therefore it is in the
interest of the organisation to collect detailed factual information should the
need arise.
Similarly, any event which seems to indicate that there has been a breach of
legal requirements (and possible enforcement action that may follow) must
be investigated to a higher degree.
Finally, as was mentioned above, any event that appears to involve significant
injury or loss to a person, and therefore may result in a civil claim, should be
investigated in more depth and detail because of the liability issues that may rest
on having detailed factual evidence and analysis from the time of the event.
Element IA4: Measuring and Reviewing Health

and Safety Performance
Purpose and Use of Health and Safety Performance
Measurement
Meaning of Health and Safety Performance Measurement
To manage health and safety successfully there needs to be some measure of
performance.
Performance measurement is a critical part of the management system to:
Check that risks are being managed in an organisation.
Identify how things could be improved in the future.
Provide information on how the system operates in practice.
Identify areas where remedial action is required.
Provide a basis for continual improvement.
Provide feedback and motivation.
Need for Active and Reactive Measures

No single measure, by itself, will effectively measure the performance of the
organisation.
Active monitoring provides information on compliance with predetermined
standards and can be used as a predictor of future performance.
Reactive monitoring relies on past data on loss-causing events and therefore only
provides a historical picture of performance.
Meaning of Key Performance Indicators

Quantifiable measures that an organisation can use to assess the degree to which
strategic and operational goals have been met.
Focus on aspects of performance that are the most critical for the current and future
success of the organisation.
To be effective they:
–– need to be measured frequently;
–– should be easy to understand in terms of corrective action that needs to be
taken; and
–– should be of relevance to the senior management team.
Types of and Benefits of Leading and Lagging Indicators

Leading Indicators
Involve precursors that may lead to an accident, injury or disease.
Focus on improving health and safety performance and reducing the probability of
serious accidents.
Can be used:
–– To monitor the effectiveness of the health and safety management systems
before accidents, incidents and failures happen.
–– To prevent or control accidents, incidents and failures.
Measure activities carried out to prevent and control injury.
Lagging Indicators
Measure loss events that have already occurred.
Quantify an organisation’s safety performance in terms of past incident statistics.
Promote reactive rather than proactive management.
Assessment of the Health and Safety Objectives and Arrangements

Measuring Performance Against Objectives
To assess the effectiveness and appropriateness of health and safety objectives and
arrangements in terms of:
–– Hardware (plant, premises, substances).
–– Software (people, procedures, systems).
To measure and reward success (not to penalise failure).
To use the results as a basis for making recommendations for a review of current
management systems.
To maintain and improve health and safety performance.
Arrangements for Actioning Objectives

Such as:
Accident reporting.
Fire precautions.
Training.
Contractors and visitor arrangements.
Dealing with any hazards in the operation.
Safe methods of work, permit-to-work schemes.
Control Measures
Assessment of the effectiveness of control measures is an area of performance
measurement best achieved by systematic review:
Supervisor daily assessment.
Sectional manager monthly review.
Quarterly review of a department.
Annual review of total organisation.
Review of Current Management Systems

Every element of the management system should be examined in detail.
Review is combined with audit procedures.
Audit looks at all aspects of the system - Plan, Do, Check, Act.
The review should cover:
Assessment of degree of compliance with set standards.
Identification of areas where improvements are required.
Assessment of specific set objectives.
Analysis of accident and incident trends.
Safety committee and safety representatives, supervisors and management, should all be
involved in the review process.
Health and Safety Monitoring

Objectives of Monitoring
Active systems - monitor the achievement of objectives and the extent of
compliance with standards, e.g. safety of plant and equipment; safe behaviour by
employees.
Reactive systems - monitor accidents, ill health, incidents and other evidence of
deficient health and safety performance, such as hazard reports.
Limitations of Accident and Ill-Health Data as a Performance

Measure
Rare occurrences, therefore numbers may not be statistically significant.
Variations from year to year might be due to pure chance rather than any accident
reduction measures that have been introduced.
Accident statistics tend to reflect the results of actions taken some time previously,
so that there is not a rapid cause and effect situation.
Under-reporting of minor accidents.
Time off work does not correlate well with the severity of an injury.
Distinctions Between, and Applicability of, Performance Measures

Active/Reactive
Measuring safety performance by looking for things before they happen can never be
easy and means that the safety practitioner has to make speculative predictions.
However, this is what the law requires. Risk assessments are carried out to decide
what might happen and are followed by any necessary action. It is possible to measure
whether action has been taken in those areas where the risk assessment suggests it is
required. If an accident occurs then it can no longer be considered as improbable; it
needs to be included in the risk assessments.
Active Monitoring
The objective is to check that the health and safety plans have been implemented
and to monitor the extent of compliance with:
–– The organisation’s systems and procedures.
–– Legislation and technical standards.
By identifying non-compliances, steps can be taken to ensure that any weaknesses
are addressed, so maintaining the adequacy of the health and safety plans, and
helping to avoid any incidents. Active monitoring is planned and takes place
regularly.
Reactive Monitoring
This depends on a loss event occurring. The objective is to analyse data relating to:
–– Accidents.
–– Ill-health situations.
–– Other loss-causing events.
–– Any other factors which degrade the system.
Objective/Subjective
Objective measures - detached from personal judgment and often factual; not
always possible to use objective measures.
Subjective measures - based on someone’s opinion, judgment or bias; may get
different results from different people.
Qualitative/Quantitative
Qualitative measures are not represented numerically and use descriptors such as
“good” or “poor”.
Quantitative measures are numerical, e.g. number of accidents reported; can be
compared between periods.
Health and Safety Monitoring and Measurement

Techniques
Range of Measures Available to Evaluate an Organisation’s
Performance
Selecting the appropriate outcome indicator depends on the chosen objectives, but the
following are indicators relevant to a range of objectives.
Active Monitoring Data
The extent to which plans and objectives have been set and achieved, including:
–– Perceptions of management commitment.
–– Specialist staff.
–– Risk assessments.
–– Safety policy.
–– Extent of compliance.
–– Training.
–– Health and safety committee meetings.
Reactive Monitoring Data
–– Health surveillance reports.
–– Cases of occupational diseases.
–– Near misses.
–– Damage-only accidents.
–– Reportable dangerous occurrences.
–– Lost-time accidents.
–– Three-day, lost-time accidents.
–– Reportable major injuries.
–– Fatalities.
–– Sickness absences.
Active Monitoring Techniques

Health and Safety Audits
In-depth, systematic, critical investigations into all aspects of safety.
Types of safety audit include:
–– A detailed internal investigation of the safety systems and practices of the
organisation.
–– An external safety audit, carried out by an outside organisation.
Workplace Inspections
Walk the premises, looking for hazards or non-compliance with legislation, rules or
safe practice.
Other Methods
–– Safety tours.
–– Safety sampling.
–– Safety surveys.
–– Climate surveys.
–– Behavioural observations.
–– Benchmarking.
Collection and Use of Sickness, Absence and Ill-Health Data

The collection and analysis of information on which employees are off sick and why will
help to:
Identify patterns and high-level causes of short-/long-term sickness absence.
Identify work-related/other causes.
Plan cover for your absent employees.
Benchmark the organisation’s performance.
Role, Purpose and Key Elements of Measurement Techniques

Role and Purpose
The primary purpose of measuring health and safety performance is to provide
information on the systems used by an organisation to control risks to health and safety.
Measurement information supports the maintenance of the health and safety
management system by:
Providing information on how the system operates in practice.
Identifying areas where remedial action is required.
Providing a basis for continual improvement.
Providing feedback and motivation.
Workplace Inspections/Safety Tours/Safety Sampling

The advantage of workplace inspections is that the inspection can be far more frequent
than an audit. To be an effective measure, the workforce as well as management need to
be involved, as this gives them ‘ownership’ of the safety process. Management is able to
demonstrate commitment to safety and it is possible to get a clear picture of problem
areas and to take quick and effective action. A scoring system is required if comparisons
over time, or with other sections, are to be made. Such an inspection usually goes under
the name of safety sampling if it concentrates on a few specific points. A safety tour
follows a set route.
Safety Surveys
Make sure that aspects of safety are not overlooked in the general run of inspection.
Generally results in a formal report and an action plan to deal with any findings.
Safety Conversations
Provide the opportunity to respond to non-compliant behaviour in an effective but
non-confrontational manner.
Used to deliver feedback, describe a safer alternative, listen to the response and
close the conversation in a productive manner.
Behavioural Observations
Used in Behavioural Change Programmes with the ultimate aim of improving
individual behaviour.
The key principle is to positively reinforce the desired behaviour and deter or even
punish the undesired behaviour.
The In-house Health and Safety Practitioner’s Role in Audits Carried

Out by Third Parties
The practitioner is fully familiar with the organisation’s health and safety communication
and information systems and therefore is well placed to:
Ensure that suitable documentation is available for the external auditor.
Brief and organise interviews with appropriate responsible persons at all levels in the
organisation.
Advise on what observations are likely to be most productive in assessing control
systems.
Comparisons of Performance Data

Previous Performance
Compare present performance data with that obtained previously to show overall
trend.
Performance of Similar Organisations/Industry Sectors
Compare company performance with other companies (benchmark).
National Performance Data
Performance data produced by national enforcement agencies and also by
international organisations (such as the World Health Organisation). Can be useful
to compare standards with national figures.
Use of Benchmarking
Benchmarking is the process of comparing your own practices and performance
measures with organisations displaying excellence and whom you might wish to
emulate.
Reviewing Health and Safety Performance

Formal and Informal Reviews of Performance
Review should be a continuous process and both formal and informal at different levels
in the organisation.
A formal review is carried out periodically and may cover the whole of the
organisation.
An informal review may be instigated for a specific reason, e.g. a loss incident, and
may cover one small section of the production process.
Review Process
Inputs to a Review Process
A range of information is used as the basis of a review, including:
Internal performance data, e.g. audit, accident, ill-health and incident data, safety
climate data.
Achievement of specific objectives.
External standards and legislation.
Expectations of stakeholders.
Outputs from a Review Process

The review process leads to specific outputs which should lead to continuous
improvement:
Specific actions and improvement plans which meet the SMART (Specific,
Measurable, Achievable, Realistic, Timely) criteria.
New performance targets relating to both active and reactive measures, e.g. lost-
time accidents.
Reports to stakeholders, e.g. shareholders, employee groups, regulators.
Short Questions
1. (a) Using examples, explain the differences between active and reactive systems
for monitoring health and safety performance. (6)
(b) Outline FOUR limitations of using accident and ill-health data as a means of
measuring health and safety performance. (4)
2. A national campaign aimed at improving standards of health and safety in a

particular industry has been deemed a failure due to a significant increase in the
rate of reported accidents over the period of the campaign.
Explain why accident rates may have proved a poor measure of the campaign’s
effectiveness and identify other measures that might have been used. (10)
Long Question
3. As a health and safety practitioner advising at a large organisation, you have
decided to develop and implement an in-house auditing programme for the
organisation’s health and safety management system.
Describe the range of organisational and planning issues that would need to be
addressed in the development of the audit programme. Note that you do not need
to identify the specific factors to be audited. (20)
Model Answers
Short Questions
Question 1
Interpretation
Part (a) of this question asks for an explanation of differences, so some depth and detail
is required here. Part (b) requires an outline of four possible limitations.
Plan
(a) Active - forward looking, lead indicators, objectives achieved, inspections.

Reactive - backward looking, lagging indicators, accidents and ill health.
(b) Negative.
Historic.
Poor reporting.
Latency.
Suggested Answer
(a) Active systems measure the compliance with standards, whereas reactive
monitoring measures previous failures in performance, enabling an
organisation to learn from its mistakes. Active measures are often referred to
as leading indicators, since they measure achievement of objectives and targets
and therefore indicate the direction that the organisation is currently taking.
Reactive measures are often referred to as lagging indicators since they reflect
where the organisation has already been - its history, in effect. Completion of
safety inspections might be used as an active measure; number of accidents
during a time period might be used as a reactive measure.
(b) Reactive data, such as accident and ill-health statistics, can be seen as rather
limited because they measure failure, even though there might have been
successes in other areas. They are therefore inherently negative. This
data as a measure of performance provides only a prediction, rather than
a determinant, for the future. The data lags current performance; it does
not lead current performance. Health statistics can be very limited, simply
because occupational diseases have a long latency period, so current data
reflects workplace standards that existed years previously. One final limitation
of reactive data is that they are extremely reliant on good reporting systems.
Poor reporting leads to poor data quality and consequently poor meaning.
Question 2
Interpretation
This question is quite straightforward, but note that there are two parts to it hidden in
the last sentence. We are asked to explain the inherent weaknesses in using accident
rates as an indication of success and we are also asked for alternative measures that
might have been used instead.
Plan
Under-reporting and effect.
Auditing, inspections, sampling, surveys.
Suggested Answer
Accident rates may have been a poor measure to use to indicate the success of the
campaign because there may have been under-reporting of accidents prior to the launch
of the campaign. This under-reporting would have led to an artificially low accident rate.
The campaign would then have raised awareness of safety issues within the industry.
This draws people’s attention to safety and accident reporting. As a result, accident
reporting improves despite the fact that the underlying accident rate might not change
at all or might even go down. Consequently the apparent accident rate increases during
and after the campaign. This is a common occurrence as safety awareness improves
within industries and organisations.
Other techniques that might have been used as an alternative to accident rates to
measure the effectiveness of the campaign might have included:
Auditing workplaces before and after the campaign to get an in-depth view of safety
management systems and their effectiveness.
Safety inspections of sites to gather a snapshot of the standards within workplaces
and the standards of behaviour.
Safety sampling exercises where representative numbers of workplaces are visited
before and after the campaign to make reliable predictions about the industry as a
whole.
Attitude surveys given to workers before and after the campaign to see if there was
any change in workers’ opinions about safety.
Long Question
Question 3
Interpretation
Though this question is scenario-based, there is very little detail about the organisation
and therefore we have to express our answer in very general terms. Note the comment
about not considering specific factors to be audited. This question is concerned with
the planning and organisational arrangement issues that must be considered when
establishing an audit system.
Plan
Resources. Schedule.
Senior management support. Personnel.
Scope. Training.
Audit system. Feedback process.
Software. Launch.
Suggested Answer
The organisational and planning issues that would have to be addressed would include:
Correctly identifying and then gaining the resources required (money, time and
personnel) through careful planning and analysis.
Gaining the support of directors and senior managers so that:
–– Those resources are made available.
–– Access is authorised to all of the necessary information and personnel across the
organisation.
–– Access to the senior managers themselves during the audit process is agreed.
The scope of the auditing to be carried out must be decided upon; will the audit
stick to health and safety issues, or range across other areas as well? And which parts
of the organisation are to be audited? These will be particularly important questions
to answer with regards geographic locations to be audited and consequently the
legal standards that will apply.
The type of auditing will also need to be decided upon. Will a proprietary system
be purchased, or will one be developed from scratch internally, or a combination of
the two? The manager will have to decide on whether to use a scored audit system
or one more reliant on narrative judgments. A software system may need to be
purchased to run the audit system, and again, decisions will have to be taken as to
the type of software and resource requirements.
An audit schedule will have to be designed, taking into account the resources made
available for conducting audits, the size of the organisation and the frequency
required. The frequency of auditing may have to vary from one part of the
organisation to another, depending on the risk level presented by the different parts
of the organisation.
Some thought will have to be given to the personnel who will carry out the audits.
Their time will have to be secured as well as their personal commitment to the
process. Training and ongoing support will have to be made available and this may
have to be supplemented with background knowledge building as well. This will, of
course, require the co-operation of their managers.
The methods used to provide feedback on audit findings, the type of feedback given,
the methods used for resolving disagreement with feedback and the review process
will all have to be considered and finalised.
Consideration must be given to how the audit programme will be launched. This
might involve clear communication of the programme, its aims, methods and
processes through various media. A test pilot may have to be carried out to ensure
the efficient working of the system and the acceptability of the scheme to others.
Element IA5: The Assessment and Evaluation

of Risk
Sources of Information Used in Identifying Hazards
and Assessing Risk
Accident/Incident and Ill-Health Data and Rates
Incident data can be used to:
Support hazard identification and risk assessment.
Classify industries and occupations according to risk.
Consider accident trends.
Use “cause of injury” to determine hazards in a workplace.
Measure the effect of preventive/control measures.
Accident and Disease Ratios
In comparisons between various industries, or between work areas in the same factory,
commonly used accident and disease rates need to be considered.
Incidence Rate

Average number of persons employed
Frequency Rate

Severity Rate
Total number of days lost × 1,000

Prevalence Rate
Total number of cases of ill health in the population × 100

Total number of persons at risk
External Information Sources

National governmental enforcement agencies such as the UK’s HSE, USA’s OSHA
and Western Australia’s Worksafe.
International bodies such as the European Safety Agency, the International Labour
Organisation and the World Health Organisation.
Professional bodies such as IOSH and IIRSM.
Trade unions.
Insurance companies.
Trade associations.
Internal Information Sources

Injury data.
Ill-health data.
Property damage.
Near-miss information.
Maintenance records.
Absence records.
Uses and Limitations of Information Sources

External Sources
More data based on a larger sample.
Type of industry covered may be much wider than own situation.
Be careful when comparing accident data between organisations, for example:
The two organisations may use different definitions.
There may be no indication of injury severity.
The figures may be for employees only (misleading for an organisation that makes
wide use of contractors).
The figures may not be adjusted to take account of overtime/part-time.
Culture differences - “back to work” policies, etc.
Internal Information
Relevant to risk assessments.
Limited in quantity.
Hazard Identification Techniques

Hazard Detection Techniques
Observation
Observation of work being done.
Task Analysis
Identify and analyse the individual steps within a particular task.
Checklists
–– Cover the key issues to be monitored.
–– The “4 Ps” structure:
–– Premises.
–– Plant and substances.
–– Procedures.
–– People.
Incident Reports
Each company should maintain its own records of all accidents that have occurred.
Failure Tracing Techniques
–– e.g. HAZOP.
Importance of Worker Input

Involve employees with relevant experience and knowledge as they are likely to have
the best understanding of the hazards; involvement also increases ‘ownership’ of the
assessment and hopefully compliance with any control measures identified.
Assessment and Evaluation of Risk

Key Steps in a Risk Assessment
For the majority of work activities the five-step approach is recommended:
Step 1: Identify the hazards.
Step 2: Decide who might be harmed and how.
Step 3: Evaluate the risks and decide on precautions.
Step 4: Record your findings and implement them.
Step 5: Review your assessment and update if necessary.
Factors Affecting Probability and Severity of Risk

The magnitude of a risk associated with an incident is determined by two factors:
the likelihood or probability of the event occurring; and
the consequence or harm realised if the event takes place.
This is usually expressed as:
Risk = Likelihood (or Probability) x Consequence (or Harm)
Risk Estimation and Evaluation

Risk estimation is determining the size of the risk. This may range from being a
relatively crude estimation, e.g. high, medium or low, to a more accurate estimation
based on data. “Estimation” is used because risk deals with uncertainty and even the
most detailed risk assessments have to make a number of assumptions.
Risk evaluation is the decision-making process whereby it is decided, on the basis of the
risk estimated, as to whether it is acceptable or otherwise.
Risk Control Standards

Having evaluated the risk and established whether or not it is acceptable, it has to be
established that the controls meet minimum standards. Such standards may be defined
in legislation, codes of practice and relevant guidance.
Formulation and Prioritisation of Actions

When deciding on what action to take the hierarchy of controls should always be
followed:
Elimination - can the hazard be removed altogether? If not, can the risks be
controlled so that harm is unlikely?
Substitute the hazard - try a less risky option (e.g. switch to using a less hazardous
substance).
Contain the risk - prevent access to the hazard (e.g. by guarding).
Reduce exposure to the hazard - reduce the number of persons exposed to the
hazard and/or reduce the duration of exposure.
Personal protective equipment - provide protection for each individual at risk.
Skill/supervision - rely on the competence of the individual.
Welfare arrangements - provide washing facilities to remove contamination, and
first-aid facilities.
Requirements to Record Findings

The significant findings should include:
A record of the preventive and protective measures in place to control the risks.
What further action, if any, needs to be taken to reduce risk sufficiently.
Proof that a comprehensive assessment has been made.
Use and Limitations of Generic, Specific and Dynamic Risk

Assessments
Generic Risk Assessments
Apply to commonly identified hazards.
Set out the associated control measures and precautions for that particular hazard.
Don’t take into account the particular persons at risk or any special circumstances
associated with the work activity.
UK HSE guidance contains information on hazards and controls required for a
wide range of health and safety topics and can be used as the basis for generic risk
assessments.
In-house generic risk assessments can be used in workplaces where the particulars
of the individuals at risk are not relevant and the activity is one that is standard and
routine.
Specific Risk Assessments

Apply to a particular work activity and the persons associated with it.
Identify specific activities, processes or substances used that could injure persons or
harm their health and who might be harmed (including vulnerable persons).
Dynamic Risk Assessments

Needed when work activities involve changing environments and individual workers
need to make quick mental assessments to manage risks, (e.g. police, fire-fighters,
teachers and lone workers).
“The continuous assessment of risk in the rapidly changing circumstances of an
operational incident, in order to implement the control measures necessary to
ensure an acceptable level of safety”.
Five stages:
–– Evaluate the situation.
–– Select systems of work.
–– Assess the chosen systems of work, (are the risks proportional to the benefits?).
–– Introduce additional controls to reduce residual risks to an acceptable level.

–– Reassess systems of work and additional control measures:
–– If the benefits outweigh the risks, proceed with the task.
–– If the risks outweigh the benefits, do not proceed with the task, but consider
safe, viable alternatives.
Limitations of Risk Assessment Processes

Extrapolation from statistical and scientific data to obtain a value which people will
accept.
The public’s attitude to acceptance of risk.
Issues regarding the general accuracy of risk estimations.
Assessing risks involves uncertainties.
Temporary and Non-Routine Situations

The standard risk assessment aims to accurately identify all potential hazards, but it is
also important to take account of temporary and non-routine operations:
Maintenance may be routinely planned but it will be temporary so can be missed in
a workplace walkabout.
Emergency maintenance will be non-routine therefore needs to be assessed
specifically.
Cleaning operations may be routine but temporary or may result from emergency
releases that are non-routine.
Consideration of Long-Term Hazards to Health

Health hazards such as radiation, harmful substances and noise may not be readily
observed in the workplace and need special consideration in the risk assessment
process.
Accident and ill-health records are unlikely to assist in identifying these types of
hazard since the latency period before health effects are realised may be many years.
Observation of the workplace is ineffective since many health hazards are invisible
and need specialist equipment to detect them.
The hazard profile of the workplace should recognise and identify potential long-
term hazards to health.
Radiation, harmful substances and noise frequently have their own specific risk
assessment methodologies, detailed in appropriate legislation, which need to be
followed.
Types of Risk Assessment

Qualitative
A qualitative risk assessment is the comprehensive identification and description of
hazards from a specified activity, to people or the environment. The range of possible
events may be represented by broad categories, with classification of the likelihood and
consequences, to facilitate their comparison and the identification of priorities.
Semi-Quantitative
A semi-quantitative risk assessment involves the systematic identification and analysis
of hazards from a specified activity, and their representation by means of both qualitative
and quantitative descriptions of the frequency and extent of their consequences, to
people or the environment.
Semi-quantitative risk assessments may also use a simple matrix to combine estimates of
likelihood and consequence in order to place risks in rank order.
Quantitative
These assessments are sometimes referred to as Quantified Risk Assessment (QRA) or
Probabilistic Risk Analysis (PRA).
A quantitative risk assessment is the application of methodology to produce a
numerical representation of the frequency and extent of a specified level of exposure
or harm, to specified people or the environment, from a specified activity. It is used to
calculate probabilities or frequencies of specific event scenarios.
Organisational Arrangements for an Effective Risk Assessment

Programme
Plan
–– What you want to achieve.
–– Who will be responsible.
–– How you will achieve your aims.
–– How you will measure your success.
Do
–– Identify your risk profile.
–– Organise your activities to deliver your plan.
Check
–– Measure your performance.
–– Assess how well the risks are being controlled.
–– Investigate the causes of accidents, incidents or near misses.
Act
–– Review your performance.
–– Take action on lessons learned.
Acceptability/Tolerability of Risk
Risks may be classified into three categories:
Acceptable - no further action required; risks insignificant or trivial and adequately
controlled. They are of inherently low risk or can be readily controlled to a low level.
Unacceptable - certain risks that cannot be justified (except in extraordinary
circumstances) despite any benefits they might bring.
Tolerable - risks that fall between the acceptable and unacceptable. Tolerability
does not mean acceptable but means that society is prepared to endure such risks
because of the benefits they give and because further risk reduction is grossly out of
proportion in terms of time, cost, etc.
Increasing individual risk and societal concerns
Unacceptable
Tolerable
ALARP region
Acceptable
Tolerability of risk
Systems Failures and System Reliability

Systems comprise a collection of interrelated processes that all need to be managed as a
whole.
Principles of System Failure Analysis

Holistic approach - looks at the behaviour of the total system rather than the
workings of individual components.
Reductionist approach - divides the system into its components.
There is a range of failure tracing methods that are based on treating the fault, failure or
events systemically, including:
Hazard and Operability Studies (HAZOPS).
Failure Mode and Effects Analysis (FMEA).
Fault Tree Analysis (FTA).
Event Tree Analysis (ETA).
Using Calculations in the Assessment of Systems Reliability

Parallel, Series and Mixed Systems
The overall reliability of equipment depends on both the reliability of all components
and the way in which they are arranged:
If a single component has a reliability of R, putting two identical components in
parallel will increase the overall reliability.
If components are added in series, the reliability of the system is reduced.
Parallel systems: in a parallel system the failure of one component will not stop the
system functioning.
Parallel system
The reliability of the system is described mathematically as:
R(S) = 1 - [(1 – R(A))(1 – R(B))]

Series systems: in series, all components must function for the system to operate.
A B
Series system
To calculate reliability of a series system, the reliabilities are multiplied together:
R(s) = R(A) × R(B)
Mixed systems:
R(A) = 0.95 R(D) = 0.60
R(C) = 0.999 R(E) = 0.93
R(B) = 0.99 R(F) = 0.90
Mixed system
The basic principle is to break down the overall system into component series and
parallel systems and treat each separately.
Common Mode Failures

Failure of a number of items due to a common cause, e.g. loss of electricity supply.
Principles of Human Reliability Analysis

Hardware design can only go so far for improved reliability; there still exists the
human input into the operation.
Humans do not work in the same way as machines. They are not good at carrying
out repetitive tasks to a consistent standard. The reliability of a human being cannot
be determined to the same accuracy as a machine.
Action can be taken to make reasonable assessments of the type and frequency of
error so that positive action can be taken to minimise the effects.
Human Reliability Analysis/Assessment (HRA) is a structured way of estimating
the probability of human errors in specific tasks. It is used as part of certain risk
assessment processes, (e.g. QRA in the nuclear, offshore and chemical industries).
Methods of Improving System Reliability

Use of reliable components.
Use of a quality control system.
Parallel redundancy:
–– Additional components can be added in parallel series so that if one component
fails, the other one will keep the system going.
Standby systems:
–– Should part of the system or a component stop working, then an alternative
system automatically steps in to continue operation.
Minimising failures to danger:
–– Systems fail to safety.
Planned preventive maintenance:

–– Means of detecting and dealing with problems before a breakdown occurs.
Minimising human error:
–– Training and instruction.
–– Man-machine interface is ergonomically suitable.
–– Working environment is comfortable.
Failure Tracing Methodologies

A Guide to Basic Probability
To understand the advanced risk assessment techniques that involve quantified risk
assessment you need to understand the basic principles of probability.
Principles and Techniques of Failure Tracing Methods

Hazard and Operability Studies (HAZOPS)
Designed for dealing with complicated systems.
Studies are carried out by a multidisciplinary team who make a critical examination
of a process to discover any potential hazards and operability problems.
Process is fully described and then every part is questioned to discover all possible
deviations from the intended design which might occur, and what their causes and
consequences might be.
A number of ‘guide words’ are applied to the statement of intention, so that every
possible deviation from the required intention is considered, (e.g. NOT, MORE,
LESS, REVERSE).
Having identified each deviation, consider:
–– How and how soon the deviation has taken place.
–– Estimation of likelihood and consequences.
Fault Tree Analysis
A logic diagram based on the principle of multi-causality.
Uses sets of symbols used in logic diagrams (AND gate, OR gate).
Starts with a ‘top event’, such as a particular accident or other undesirable event.
The immediate and necessary events for the top event to occur are identified.
The tree is further developed from the top downwards to obtain all the possible
primary cause events.
Establish an (upside down) tree.
Event Tree Analysis

Starts with an initiating event and develops the tree from left to right.
Defines the events which flow from the primary event. Event trees are used to
investigate the consequences of loss-making events in order to find ways of reducing
losses.
Stages in carrying out event tree analysis:
–– Identify the initiating event.
–– Construct the event tree beginning with the initiating event and proceeding
through failures of the safety functions.
–– Establish the resulting accident sequences.
–– Identify the critical failures that need to be addressed.
Short Question
1. Outline the range of internal and external information sources that may be useful
in the identification of hazards and the assessment of risk. For each source, indicate
the type of information available and how it contributes to hazard identification or
risk assessment. (10)
Long Question
2. A complex manufacturing site situated close to a housing estate includes a storage
vessel containing liquefied petroleum gas (LPG). It has been calculated that a
major release of the LPG in the vessel could occur once every one hundred years
(frequency = 0.01/year). This LPG release, in combination with the presence of
an ignition source (probability, p = 0.1), would lead to a vapour cloud explosion
on the industrial site. However, if the wind is blowing from the prevailing direction
(p= 0.6) and the wind is slow and stable (p = 0.5), the LPG vapour cloud would
drift over the housing estate where it might be ignited (p = 0.9).
(a) Using the information contained in the description above, demonstrate

an event tree and calculate the level of risk of explosion BOTH on the
manufacturing site AND in the local housing estate. (10)
(b) Comment on the significance of these results. (4)
(c) Outline a hierarchy of control options that could be used to eliminate or
minimise the risks and give examples to illustrate your ideas. (6)
3. (a) Outline the potential uses and limitations of Fault Tree Analysis (FTA). (4)
(b) A power press operator has to reach between the tools of a hydraulic power
press between each operational stroke of the machine. It is possible that in
event of a machine fault the operator could be at risk of a crushing injury to
their hand. This crushing injury could be caused due to the press tool falling
by gravity (fault a). Alternatively, it could be caused by an unplanned powered
stroke of the press (fault b). The anticipated frequencies of the underlying
failures that would lead to either of these faults (a or b) are given below:
Failure type Frequency (per year) Effect

Flexible hose failure 0.2 a
Detachment of press tool 0.1 b
Electrical fault 0.1 c
Hydraulic valve failure 0.05 a or b
(i) If the press operator has their hands between the tools of the press for
20% of the time that the machine is operating, demonstrate a simple
fault tree of the situation described above, and use it to calculate the
expected frequency of the top event (a crushing injury to the worker’s
hand). (10)
(ii) If there are ten presses, all identical to the one described in this scenario,
in a workshop, discuss, with reasons, whether or not the level of risk
calculated would be acceptable. (4)
(iii) If the use of the hydraulic press cannot be avoided, explain how the fault
tree could be used in order to prioritise preventive measures. (2)
Model Answers
Short Questions
Question 1
Interpretation
There is a lot of structure in this question, even though it is not broken down into
specific parts. The question clearly asks us to outline internal and external information
sources. I think a 50:50 split between the two sources is sensible here (though this is not
clearly indicated). The question also asks for a range - this indicates that we must take
a step back and take in the wide view; focus too narrowly on one set of sources and you
will miss marks. For each source of information we are clearly told to indicate the type
of information available and how it is useful, and everything relates to risk assessment.
Plan
External:
–– Relevant governmental agencies (OSHA/UK HSE).
–– European Safety Agency.
–– ILO.
–– WHO.
–– Professional and trade bodies.
Internal:
–– Accident investigation reports, etc.
–– Inspection reports.
–– Audit results.
–– Maintenance logs.
Suggested Answer
External information sources that might prove useful during the risk assessment process
would include:
National governmental enforcement agencies such as the UK’s HSE, USA’s OSHA,
Western Australia’s Worksafe. These all produce legal and best practice guidance and
statistics.
International bodies such as the European Safety Agency; the International Labour
Organisation; the World Health Organisation.
There are various professional bodies that have an interest in occupational safety and
health and these bodies often issue guidance that can help in hazard identification
and risk assessment. In many instances specific advice can be obtained relevant to a
specific issue.
This guidance can often be augmented by further guidance available from trade
bodies and trade unions - these organisations can often give excellent practical
guidance based on their close working knowledge of the practical issues arising.
They are in a good position to indicate exactly what the principal hazards associated
with their kind of work are, and the consequent risks.
Finally, information can be obtained from manufacturers or suppliers which can
indicate the extent of a hazard and the relevant control options that might be
necessary. For example, safety data sheets from chemical suppliers provide essential
information on the chemical nature of a hazardous substance and necessary controls.
Similarly, the noise and vibration magnitude data from a machinery supplier can
give an insight into the potential noise or vibration exposure and the subsequent
exposure controls necessary.
Internal information sources might include:
Accident and near-miss reports and investigation reports. These are useful because
they will clearly identify hazards that either have or had the potential to cause injury.
They may also be useful during the risk assessment process because they help in the
evaluation of likelihood and severity of injury, and hence the degree of risk.
Inspection reports may be useful in identifying the easily observed hazardous
conditions in the workplace and also the common types of control failure. This
process not only helps the hazard identification process, but also influences risk
assessment; the effectiveness of various control options can be better estimated
based on current controls.
Audit reports may also be useful in a similar way by identifying hazards that have
been overlooked and the effectiveness of existing controls.
Maintenance logs may be useful in determining the effectiveness or otherwise of
particular controls in the workplace, such as automatic warning systems, guards and
PPE.
Long Questions
Question 2
Interpretation
This looks like a very intimidating question, but once you get into it, it’s not as bad as it
looks (honestly!). It’s a three-part question, so a three-part answer is required. Note the
marks for each part. Part (a) is the bit with the maths. This requires you to have a clear
vision of what event tree analysis is; start with the initiating event and deal with possible
consequences - use a simple binary decision-making logic diagram. Part (a) clearly
indicates that two calculations are required. Workings out must be shown for each. Part
(b) asks you to comment on the results. It is worth stating the obvious here. Part (c)
is concerned with a hierarchy of control options and is not concerned with the specific
technical control necessitated by bulk storage of LPG (a Unit IC topic).
Plan
I wouldn’t plan the answer here because the plan would need to be so well developed
you might as well just draw up the full answer, and part (b) can’t be answered until you
know the outcome of part (a).
Suggested Answer
(a) The event tree should look something like this:
(Remember that the probabilities on each yes/no branch point must add up to 1,
so having been given the probability of there being an ignition source on site as
0.1, the probability of there NOT being an on-site ignition source (and therefore
no on-site explosion) must be 1 - 0.1 = 0.9. This is a vital step to remember when
calculating the probability of an off-site explosion because the question itself does
not give you this vital number - you have to work it out for yourself.)
An explosion will only occur on site if the release encounters the on-site ignition
source. The frequency of such an occurrence on-site is 0.01 x 0.1 = 0.001/yr, which
is once every 1,000 years (i.e. 1/0.001).
An off-site ignition will only occur if: the vapour isn’t ignited on site AND the wind
is in a certain direction AND the wind speed is < 8 m/s AND the vapour finds an
ignition source in the housing estate. Thus, the expected frequency of off-site
explosion is 0.01/yr x 0.9 x 0.6 x 0.5 x 0.9 = 0.00243 per year. This result can be
alternatively expressed as approximately once in about 411 years (obtained by
taking the reciprocal of the previous figure, i.e. 1/0.00243).
(b) The results show that the risk to members of the public is greater than the risk to
employees on site. Figures allow comparison with benchmark data, e.g. the UK HSE
proposes an individual risk of death from workplace activities as one in a million per
annum. Here the greater risk to members of the public is clearly unacceptable and
given the fact that an explosion would be likely to cause multiple fatalities, both of
these expected frequencies would appear unacceptable.
(c) A standard hierarchical approach - elimination, substitution or minimisation
of quantity/use of LPG, reduce probability of release (protective systems,
maintenance, operation, ignition sources, emergency procedures, siting of tanks) -
will contribute to minimising the risk in this situation.
Question 3
Interpretation
This is another of those rather scary-looking questions that looks worse than it really
is. Note that there are four parts to the question and so you need four separate parts
to your answer. Part (a) is very straightforward. Part (b) (i) has the maths, but as long as
you have a clear idea of what FTA is about it should be OK. Remember to always show
your workings. Part (ii) is a continuation of part (i) and if your part (i) answer is wrong
then part (ii) can be difficult. Part (iii) is similarly linked to part (i), so a mistake in (i)
might mislead you. Note that a detailed technical understanding of power presses is not
required here; the question is about the practical application of FTA.
Plan
This is another question where a plan would be so detailed that you might as well just
get on with the answer.
Suggested Answer
(a) FTA is used for analysis of events which may have multiple causes. The probability/
frequency of the “top event” can be quantified provided there is sufficient data on
the probabilities/frequencies of the underlying events. It also helps identify critical
stages where intervention might be most effective (to reduce the probability of
the top event occurring). However, complex events require skill to work out and
of course the top event probability calculation is only as good as the data which is
input into the calculation.
(b) (i) CRUSHING INJURY
& f = 0.2 × 0.5 = 0.1/YR

or 1 in 10 years
P = 0.2 Tool comes down as

result of failure
Operator f = 0.15 + 0.35
exposed = 0.5/yr
Powered Gravity
stroke fall
f = 0.05 + 0.2 + 0.1
f = 0.05 + 0.1
= 0.35/yr
= 0.15/yr
Valve Electrical Valve Hose Detachment

failure fault failure failure of tool
f = 0.05/yr f = 0.1/yr f = 0.05/yr f = 0.2/yr f = 0.1/yr

(ii) If the frequency of a crush injury to an operator’s hand is once every
ten years and there are ten such presses, then across the entire
workshop the crush injury frequency will be (0.1/yr 10) = 1 per
year. Given the nature of the likely disabling injury, this frequency is
obviously far too high to be tolerable without some attempt to reduce
the risk.
(iii) Looking at the fault tree, priority should be given to those factors that
would give the greatest reduction in frequency of the top event. In the
diagram flexible hose failure makes the greatest contribution to the
frequency of the top event, followed by detachment of the tool and
electrical fault. Controls include: solid pipe instead of flexible hose;
more reliable components; maintenance and testing.
Element IA6: Risk Control

Common Risk Management Strategies
Concepts Within a Health and Safety Management System
The topic of risk control can be split into loss control and risk financing.
Loss control:
–– Risk avoidance: eliminate.
–– Risk reduction: control.
Risk financing:
–– Risk retention: finance from funds within the organisation.
–– Risk transfer: finance from funds outside the organisation.
Definitions of these methods (which can be used individually or in combination) are:
Avoidance or Elimination
–– Risk avoidance is avoiding completely the activities giving rise to risk.
–– Risk elimination usually has a wider meaning; it implies removal of a risk without
necessarily ceasing an activity completely.
Risk Reduction
Where risk is not avoided or eliminated entirely, but attempts are made to reduce
the frequency and/or severity of a potential loss by use of typical safety control
techniques such as engineering solutions to control risk at source, procedures and
behavioural measures (training, etc.).
Risk Retention
–– With knowledge: there has been a conscious decision to bear the burden of
losses.
–– Without knowledge: it is done without any consideration whether or not to
insure.
Risk Transfer
Involves transferring the risk to another party such as by insurance - the loss is
financed from funds which originate outside the organisation. Another way is to
engage a contractor who will take on the risks.
Insurance
Advantages of insurance are that the:
Loss will be dealt with smoothly.
Insurer can get hold of the funds quickly.
Insurer can provide advice.
Use of Specialist Contractors

Sometimes the best way of avoiding a hazard for employees.
Task is carried out professionally and in compliance with current legislation.
Risk Sharing
Involves financing risks that are manageable and transferring those that are not.
Methods include:
–– A deductible portion of excess.
–– Re-insurance.
–– Co-insurance
Circumstances when Each of the Previous Strategies would be

Appropriate
Risk Avoidance
Risks can’t be managed to an acceptable level.
The costs of achieving a project are too high due to necessary risk control.
Risk Retention
With knowledge - no further action planned to deal with it:
–– There aren’t any control options available.
–– The only options are unacceptable or can’t be implemented yet.
Without knowledge - ineffective risk assessment system.
Risk Transfer
Most commonly by insurance.
Tends to be used in conjunction with other risk management options.
Risk Reduction
Apply control measures, according to the hierarchy of risk control.
Most common way to manage risks.
Decreases the likelihood and/or severity of undesired consequences through
preventative measures and/or contingency plans.
Factors to be Considered in the Selection of an Optimum Solution

Based on Relevant Risk Data
Probability Severity Action
Definite High Eliminate
Medium Fund (cheaper than insurance)
Low No action - operating expense

High High Eliminate or reduce probability or severity
Medium Reduce severity
Low Retain as an operating expense

Medium High Reduce severity
Medium Reduce severity or transfer

Low High Fund or insure
Medium Fund

Remote Catastrophic Insure, or fold company
High Fund, insure, or fold company
Medium Fund or retain as an expense
Low No action
Relationship between probability and severity
Other important factors include:

Present state of technology.
Public expectancy.
Legal requirements.
Economic state of the company.
Levels of insurance premiums.

Confidence of the company in the benefits of risk management and in the

competence of the risk manager.
Human factors.
Principles and Benefits of Risk Management in a Global Perspective

All activities involve risk therefore organisations have to manage risk by:
–– identifying it;
–– analysing it; and
–– evaluating whether the risk needs to be controlled in order to satisfy their risk
criteria.
ISO 31000:2009 Risk Management - Principles and Guidelines sets out the principles
of effective risk management.
Link between Outcomes of Risk Assessments and Development of

Risk Controls
The outcome of the risk assessment process follows from risk evaluation and involves
making decisions about risk controls and the priority for their implementation.
Risk evaluation involves comparing the level of risk found during risk analysis (which
considers the causes and sources of risk, their consequences and the likelihood of
occurrence) with established risk criteria and informs the decision about the need
for controls.
Risk assessment may conclude:
–– the need to implement additional controls;
–– change existing controls; or
–– continue with no controls at all.
Factors to be Taken into Account when Selecting Risk

Controls
Preventive and Protective Measures
The following are well recognised principles of prevention:
Avoiding Risks
Not using the material or carrying out the activity.

Evaluating Risks
–– Evaluating the risks that cannot be avoided.
–– The level of risk is compared against agreed risk criteria to decide on the most
appropriate risk control options.
Combating Risks at Source
Control the risk as close to the point of generation as possible to prevent its escape
into the workplace.
Adapting Work
–– Adapting the work to the individual.
–– Consider ergonomic principles and design the work to suit the person.
Adapting to Technical Progress
Many risks disappear from the workplace as better processes and methods are
introduced.
Replacing
The dangerous with the non-dangerous or the less dangerous.
Developing Policy
–– Developing a coherent overall prevention policy.
–– Requires the employer to look at all aspects of the health and safety
management system rather than simply concentrating on basic workplace
precautions.
Prioritising Measures
Giving collective protective measures priority over individual protective measures.
Giving Appropriate Instructions
To employees.
Determine Technical/Procedural/Behavioural Control Measures

Categories of Control Measures
Technical
Engineering solution.
Procedural
A safe system of work.
Behavioural
–– Education and training.
–– Notices and signs.

General Hierarchy of Control Measures

Quoted in many different ways, but one such hierarchy of effectiveness is:
Elimination (technical)
–– Stop using the process, substance or equipment or use it in a different form.
Substitution (technical/procedural)
–– Substitute a chemical that is not dangerous or less dangerous for a toxic one.
–– Use less noisy pumps.
Engineered Controls (technical/behavioural)
–– Redesign of process or equipment to eliminate release of hazard so that
everyone is protected.
–– Enclosure or isolation of process or use of equipment to capture hazard at
source and release to a safe place, or dilution to minimise concentration of
hazard, e.g. acoustic enclosures, use of LEV.
Signage/Warnings and/or Administrative Controls (procedural/behavioural)
–– Design work procedures, work systems to limit exposure, e.g. limit work periods
in hot environments, develop good housekeeping procedures.
–– Use of signs, training in specific work methods and supervision.
PPE (as a last resort) (technical/behavioural)
–– RPE, gloves, etc. - only protects the individual.
Another example of a hierarchy is:
Total elimination or avoidance of the risk at its source.
Reduction of the risk at its source.
Contain the risk by enclosure of some kind.
Remove the employee from the risk.
Reduce the employee’s exposure to the risk.
Use personal protective equipment.
Train the employee in safe techniques.
Make safety rules, or issue instructions.
Tell the employee to be careful.
Factors Affecting Choice of Control Measures

Long/short term.
Applicability.
Practicability.

Cost.
Proportionality.
Effectiveness of control.
Legal requirements and associated standards.
Competence of personnel.
Relevant training needs.
Safe Systems of Work and Permit-to-Work Systems

Safe Systems of Work
This is where the work is organised in a logical and methodical manner so as to remove
the hazards or minimise the risks.
Legal and Practical Requirements
Article 10 of the ILO Occupational Safety and Health Recommendation (R164)
requires employers to:
“provide and maintain workplaces, machinery and equipment, and use work methods,
which are as safe and without risk to health as is reasonably practicable”.
Copyright © International Labour Organisation 1981
Components of a Safe System of Work

A safe system of work constitutes the bringing together of:
People.
Equipment.
Materials.
Environment.
Permit-to-Work Systems
A permit-to-work is a formal written document of authority to undertake a specific
procedure and is designed to protect personnel working in hazardous areas of activities.
Essential Features
Permits should:
Define the work to be done.
Say how to make the work area safe.
Identify any remaining hazards and the precautions to be taken.

Describe checks to be carried out before normal work can be resumed.

Name the person responsible for controlling the job.
Be regularly monitored.
General Application
Electrical equipment and supplies.
Machinery.
Overhead travelling cranes.
Chemical plant.
Radiation hazards.
Confined spaces.
Essential Elements of a Permit-to-Work Form

1. Permit title. 2. Permit number.
Reference to other relevant permits or isolation
certificates.
3 Job location.
4. Plant identification.
5. Description of work to be done and its limitations.
6. Hazard identification - including residual hazards and hazards introduced by the
work.
7. Precautions necessary. Person(s) who carries out precautions, e.g. isolations,
should sign that precautions have been taken.
8. Protective equipment.
9. Authorisation. Signature confirming that isolations have been made, and
precautions taken, except those which can only be taken during the work. Date
and time duration of the permit.
10. Acceptance. Signature confirming understanding of work to be done, hazards
involved and precautions required. Also confirming permit information has
been explained to all workers involved.
11. Extension/shift hand-over procedures. Signatures confirming checks made that
plant remains safe to be worked upon, and new acceptor/workers made fully
aware of hazards and precautions. New time expiry given.
12. Hand-back. Signed by acceptor certifying work completed. Signed by issuer
certifying work completed and plant ready for testing and recommissioning.
13. Cancellation. Certifying work tested and plant satisfactorily recommissioned.

Basic Principles of Operation

Hazard evaluation.
Precaution planning.
Instructing the supervisors.
Issuing the permit.
Monitoring the permit.
Use of Risk Assessment in the Development of Safe Systems of

Work and Safe Operating Procedures
Analysing the task - identifying the hazards and assessing the risks:
–– What is used.
–– Who does what.
–– Where the task is carried out.
–– How the task is done.
Introducing controls and formulating procedures:
–– Verbally.
–– Simple written procedure.
–– Formal permit-to-work scheme.
Instructing and training people in the operation of the system:
–– Communicated properly.
–– Understood by employees.
–– Applied correctly.
Monitoring and reviewing the system; check that:
–– The procedures laid down are being carried out and are effective.
–– Any changes that require alterations to the system of work are taken into
account.

Short Questions
1. Business risk management involves the following approaches:

(a) Risk avoidance. (2)
(b) Risk reduction. (3)
(c) Risk transfer. (3)
(d) Risk retention. (2)
Distinguish between each of these approaches and give a specific example of

each.
2. Production line workers in a textile plant are required to use knives routinely as part
of their work. Outline the factors to be considered when developing a system of
work designed to minimise the risk to these workers. (10)
Long Question
3. An investigation of a serious accident has concluded that maintenance operations
in a particular area of a factory should have been subject to a permit-to-work
system. Identify and explain the main factors that should be considered when
setting up such a system. (20)

Model Answers
Short Questions
Question 1
Interpretation
This question has a clear structure, so your answer should follow suit. Note that you are
asked for an example in each case; failure to provide one would imply that full marks
cannot be awarded even if your explanation is full.
Plan
Avoidance - don’t do it, e.g. get someone else to do it for you.
Reduction - control the risk; hierarchy, e.g. substitute chemical.
Transfer - insure the risk, e.g. liability insurance.
Retention - with or without knowledge.
Suggested Answer
(a) Risk avoidance: actively avoiding or eliminating the risk. This might be done by, for
example, discontinuing or avoiding a risky process or activity or by eliminating a
hazardous material. Closing down a butchery operation within a food factory (with
the hazards associated with that operation) and buying in ready-prepared meat
from a supplier is an example of risk avoidance.
(b) Risk reduction: reducing the level of residual risk. This might be done, for example,
by adopting a hierarchy of measures to control the risk, such as removing one
hazardous agent and introducing another less hazardous agent in its place, or
adopting an engineering control by guarding a piece of machinery, or adopting a
safe person strategy by training workers so that they are aware of a hazard and can
behave accordingly.
(c) Risk transfer: transfer of risk to a third party. This is often done by insurance. If
the risk is realised and a loss occurs then the insurance policy will pay for the loss,
so the financial risk has been transferred from the workplace on to the insurer (at
a cost). Alternatively risk might be transferred to a contractor. Here, a separate
organisation is retained to undertake an activity that the workplace does not want
to carry out directly. However, because of the complexity of health and safety (and
contract) law, it must be remembered that liability for losses may be laid at the
door of the workplace and not just the contractor.

(d) Risk retention: accepting a residual level of risk within the company. This is often
done with the knowledge of the workplace (i.e. knowingly) where the risk is
small and the costs of reducing the risk seem disproportionate to any benefit. If
a loss occurs, then the organisation will have to cover that loss from revenues.
Sometimes a risk may be retained without knowledge (i.e. unwittingly). This can
occur when a risk has not been recognised (and therefore goes uninsured) or when
a risk is recognised and insurance is put in place, but the insurance fails to cover
the loss. This might occur if the loss is greater than the amount of insurance cover
purchased, if there is a large excess, or if there are policy exclusions that mean the
insurer avoids payment.
Question 2
Interpretation
This question outlines a simple scenario. Implicit in the question is the fact that knives
have to be used, so elimination of knives is not an option. The question asks for factors
to consider or “things to think about” when developing the safe system of work. An
outline is required, so a brief explanation of a range of factors is necessary.
Plan
Task analysis, risk assessment, control of risk. Must consider elimination (automation,
process change), type of knife, environment (space constraints, lighting), individual
factors (age, attitude, skill), PPE, consultation with workforce, training.
Suggested Answer
The first factor to consider is the identification of the tasks requiring the use of knives
(by task analysis, for example). This might then be followed by risk assessment. The
people at risk, the hazards and various risk factors must be identified and recorded in
this risk assessment. The correct methods needed to control the risk must be designed
and implemented. During the risk assessment process the potential for risk elimination
by automation or process change should be considered (though it must be expected
that use of knives will remain). Consideration must be given to the type of knife
(safety features), safe storage of knives, safe carrying of knives and knife sharpening
arrangements. The environment must be considered (factors such as space constraints
and lighting), as must individual factors relevant to workers using knives (age, attitude,
skill). Suitable PPE must be selected and supplied. Worker training in much of the
above will be necessary.

Long Question
Question 3
Interpretation
Make sure that you have clearly identified the key words in the question. The whole
focus of the question is the set up of a permit-to-work (PTW) system. The only piece of
information of importance in the first part of the question is to pick up on the fact that
the PTW system is to address maintenance operations.
Plan
Factors to consider:
Defining what the permit system covers (tasks to be performed, legal requirements,
personnel responsibilities).
Selection, training and competence of personnel (assessment, records, certification).
What the permit itself prescribes (validity conditions, emergency procedures, the
tasks, hand-back conditions).
How the work should be co-ordinated and monitored.
Suggested Answer
Maintenance operations in a factory environment may involve various high-risk
types of work, such as work on large complex items of machinery, work on pressure
systems, work on high-voltage electrical systems, work in confined spaces, work on
plant containing hazardous chemicals, work at height and work on plant at extremes
of temperature, to name but a few. Often multiple hazards will exist at the same time
and generate high and complex risk. Consequently maintenance work may often be
designated as high risk and made subject to permit-to-work (PTW) control. In these
cases, a PTW system must be carefully designed and implemented to ensure safety at all
stages of the maintenance work.
Various factors must be considered when such a system is being designed, developed
and implemented:
In the first instance the system parameters must be clearly identified so that there
is a clear understanding of what the permit system covers. The system must define
which work is covered by the permit system and which work falls outside of permit
control. This may sometimes be subject to legal requirements. For example,
confined space entry should always be made subject to permit control as a matter
of course. In other instances the use of a permit system will be dependent on
perceived risk on site (e.g. hot work). The definition of permit parameters must
also identify the key site personnel and what their specific responsibilities and
authorities actually are with regards the permit system. Personnel with responsibility
for authorising work under the permit system must be clearly identified, as must
personnel who have responsibility delegated to them in the absence of key

personnel. Personnel responsible for undertaking specific activities, such as risk

assessment or atmospheric monitoring, should have their responsibilities clearly
allocated, as should staff responsible for monitoring the effective operation of the
permit system.
Another factor to consider is the effective selection, training and competence of
personnel. Competence is a key word here. All personnel associated with the PTW
system must have the necessary competence to undertake their specific roles or
task. This implies training, knowledge, experience and perhaps other qualities, such
as ability. Assessment of competence may be necessary. Training records, and in
some instances specific certification for key personnel, may have to be obtained and
records retained.
What the permit itself prescribes must be considered in the development of the
permit system. This will vary depending on the nature of the types of work that
fall within permit control. Generally, there would be arrangements designed into
the system for the formal specification of key safety requirements before the
commencement of work. These safety requirements would be communicated
to relevant personnel through use of the permit system and the actioning of key
controls would be verified. There would be some form of formal hand-over of
control from authorising manager to personnel undertaking the maintenance
work activities, as well as some specific restrictions placed on those workers as
to types of work permitted and types of work not permitted. The verification of
safety throughout the operation and the formal hand-back of plant/equipment
or areas would then follow. Formal acceptance of these areas would follow, with
the cancellation of the permit to prevent future work being carried out under old
permissions.
The PTW system must clearly identify how the work should be co-ordinated and
monitored. Personnel with key responsibilities must be identified here, as well as the
co-ordination and monitoring arrangements being described in the system.

Element IA7: Organisational Factors

Types of Safety Leadership and their Likely Impact on
Health and Safety Performance
Meaning of Safety Leadership
Successful safety leadership is based on visible, active commitment at board level
with effective downward communication systems through the management
structure.
The aim is to integrate good health and safety management with business decisions.
Effective leadership should involve the workforce in the promotion and achievement
of safe and healthy conditions and encourage upward communication to engage the
workforce.
Without the active involvement of directors, organisations will never achieve the
highest standards of health and safety management.
Types of Safety Leadership

Transformational
Based on the assumption that people will follow a person who inspires them.
The way to get things done is by generating enthusiasm and energy.
The aim is to engage and convert the workforce to the vision of the leader.
Transformational leaders are good at seeing the big picture, their vision, but sometimes
not the detail where the problems often arise.
Transactional
Based on the assumption that people are motivated by reward and punishment and
social systems work best with a clear chain of command.
The transactional leader creates clear structures setting out what is required and the
associated rewards or punishment.
The organisation and therefore the subordinate’s manager has authority over the
subordinate, and the Transactional Leader allocates work.
The main limitation is the assumption that individuals are simply motivated by reward
and exhibit predictable behaviour.
Servant
Based on the assumption that leaders have a responsibility towards society and those
who are disadvantaged.

The aim is to serve others and help them to achieve and improve.
Key principles include personal growth, environments that empower and encourage
service, trusting relationships to encourage collaboration and the creation of
environments where people can trust each other and work together.
It can be an appropriate model for the public sector or other large caring employers.
However, it may be seen as too soft for the private sector where the needs of
shareholders, customers and market competition are more important.
Situational and Contextual (Hersey and Blanchard)

Hersey and Blanchard recognise that tasks are different and each type of task requires a
different leadership approach. Leadership techniques can be optimised by matching the
leadership style to the maturity level of the group as follows:
Leadership style:
1. Telling - unidirectional flow of information from the leader to the group.
2. Selling - the leader attempts to convince the group.
3. Participating - the leader shares decision making with the group, making the
system more democratic.
4. Delegating - the leader still is in charge but monitors the ones delegated with
the tasks.
Maturity level of those being led:
1. Incompetence or unwillingness to do the task.
2. Inability to do the task but willing to do so.
3. Competent to do the task but not confident.
4. Competent and confident.
Behavioural Attributes of an Effective Leader

Leadership behaviours which are regarded as being effective and are respected by
followers include:
Integrity.
Appreciation of corporate responsibility (the need to make profit is balanced with
wider social and environmental responsibilities).
Being emotionally positive and detached.
Leading by example.
Supporting and backing people when they need it.
Treating everyone equally and on merit.
Being firm and clear in dealing with bad behaviour.

Listening to and understanding people (understanding is different from agreeing).

Always taking responsibility and blame for mistakes and giving people credit for
successes.
Being decisive and seen to make fair and balanced decisions.
Asking for views, but remaining neutral and objective.
Being honest but sensitive in delivering bad news or criticism.
Keeping promises.
Always accentuating the positive.
Involving people in thinking and especially in managing change.
Benefits of Effective Health and Safety Leadership

Leadership as a Core Element of Effective Health and Safety
Management
The core elements to effectively managing for health and safety rely on:
Leadership and management.
A trained and skilled workforce.
An environment where people are trusted and involved.
An understanding of the risk profile of the organisation.
Effective leadership involves:
Maintaining attention on the significant risks and implementation of adequate
controls.
Demonstrating commitment by actions and awareness of the key health and safety
issues.
Consulting with the workforce on health and safety.
Challenging unsafe behaviour in a timely way.
Setting health and safety priorities.
Understanding the need to maintain oversight.
Showing acceptance and compliance with the organisation’s standards and
procedures, (e.g. wearing the correct PPE on site).
Striving to engage employees in the health and safety programme.

Benefits of Effective Safety Leadership on Organisational Health

and Safety Culture and Performance
Achieving a positive health and safety culture in an organisation is fundamental to
managing health and safety effectively and leaders can influence this.
The tangible benefits of a positive health and safety culture are reflected in indicators of
good health and safety performance and include:
Reduced costs.
Reduced risks.
Lower employee absence and turnover rates.
Fewer accidents.
Lessened threat of legal action.
Improved standing among suppliers and partners.
Better reputation for corporate responsibility among investors, customers and
communities.
Increased productivity, because employees are healthier, happier and better
motivated.
Link between Effective Leadership and Employee Engagement

Employee consultation and involvement is an essential element of effective health
and safety management and therefore leadership plays an essential role in promoting
participation and engagement of the workforce.
Effective health and safety leadership will ensure that:
Instruction, information and training are provided to enable employees to work in a
safe and healthy manner.
Safety representatives carry out their full range of functions.
The workforce is consulted (either directly or through their representatives) in good
time on issues relating to their health and safety and the results of risk assessments.
Employees are clear who to go to if they have health and safety concerns.
Line managers regularly discuss how to use new equipment or how to do a job
safely.
Health and safety information is cascaded through the organisation through team
meetings, notice boards and other communication channels.

Encouraging Positive Leadership for a Safe and Healthy Workplace

Both the organisation and the health and safety practitioner have a role in encouraging
positive leadership and supporting the management team to exhibit visible leadership
commitment to a safe and healthy workplace.
The policy and planning process should serve to commit leaders to an effective health
and safety programme. Leaders should respond by demonstrating commitment and
leading by example.
The health and safety practitioner needs to motivate the board into action in order to:
Set the direction for effective health and safety management.
Establish a health and safety policy that is an integral part of the organisation’s
culture and values.
Take the lead in ensuring the communication of health and safety duties and
benefits throughout the organisation.
Respond quickly where difficulties arise or new risks are introduced.
Corporate Social Responsibility

This is the term used to describe the voluntary actions that business can take, over
and above compliance with minimum legal requirements, to address both its own
competitive interests and the interests of the wider society.
Businesses should take account of their economic, social and environmental impacts,
and act to address the key sustainable development challenges based on their core
competences wherever they operate – locally, regionally and internationally.
Internal and External Influences

Internal Influences on Health and Safety
Finance
A company’s financial position will affect its approach to the health and safety
budget.
Production Targets
The attainment of production goals can put operatives under intense pressure,
which can lead to stress and an increase in incidents and accidents in the workplace.
Trade Unions/Labour Unions
Trade union safety representatives may be involved as members of safety
committees and as such are active in improving health and safety in the workplace.

Organisation Goals and Culture

The goals and culture of an organisation strongly influence how people behave and
what is expected of them.
External Influences on Health and Safety within an Organisation

Insurance Companies
Enforcement Agencies
Contracts/Contractors/Clients
Courts/Tribunals
The Organisation
Legislation
Trade Unions
Public Opinion
External influences on the organisation
Legislation - pending changes and their effect on the company.

Enforcement Agencies - can influence health and safety within companies by:
–– Providing advice.
–– Serving enforcement notices.
–– Prosecution.
Tribunals/Courts - may have a direct effect on health and safety through their
decisions, such as dismissing an appeal against an enforcement notice.
Contracts/Contractors/Clients - the nature of contracts and relationships with
contractors may have profound effects on the health and safety of a particular
contract.
Trade Unions - active nationally in promoting standards of health and safety by:
–– Supporting their members’ legal actions and setting precedents and standards.
–– Acting through lobby and pressure groups to influence legislation.
–– Carrying out and sponsoring research.
–– Publicising health and safety matters and court decisions.
–– Providing courses on health and safety subjects.

Insurance Companies – can directly influence other companies where there is a

requirement for employers’ liability insurance.
Insurance companies may also affect companies by means of their policy towards
claims, i.e. because of the high cost of litigation, cases tend to be settled out of
court, rather than pursued in court.
Public Opinion - can have a powerful effect on legislators, which may result in
legislation being passed or prosecution taking place.
Types of Organisations
Concept of the Organisation as a System
A system is a regularly interacting or interdependent group of items forming a united
whole.
The organisation is viewed as an integrated complex of interdependent parts which
are capable of sensitive and accurate interaction among themselves and within their
environment.
Organisational Structures and Functions

Formal and Informal
–– Formal - represented by the company organisation chart, the distribution of
legitimate authority, written management rules and procedures, job descriptions,
etc.
–– Informal - represented by individual and group behaviour.
Large or Small
Most businesses are deemed to be small (up to 50 employees).
Organisation Charts
The pyramidal structures identify the formal levels of authority and responsibility
within the organisation or department, with authority or control running from top
to bottom.
Role of Management
Management will lead through issued instructions, policies and procedures, and
supervision to ensure that these are being adhered to.
There is normally a line of responsibility with different functions at each level.
Hierarchical Line Management Structures
–– Line management - direct line of authority (from the Works Director to the
Shop-Floor Operative).
–– Staff relationship - advisory relationship with managers and departments.

–– Functional relationship - certain members of staff have a company-wide remit

to carry out activities ‘across the board’.
Small Businesses and Flat Management Structures
These are organisations with up to 50 employees. A feature of such organisations
is the necessity (certainly in those with few employees) for the employees to adopt
several roles. Much of the work is done in teams where a team leader will facilitate
the work of the team, operating in a collaborative style rather than through a
hierarchical structure. This is a much flatter structure than the linear one and relies
on co-operation and joint decisions rather than instruction being passed down
through a management chain.
Organisational Goals and Those of the Individual: Potential Conflict

Both the organisation and individuals have their own separate and distinct goals.
For the organisation to achieve its goals, the employees need to have their own goals
and objectives to work towards the organisational goal. This can lead to conflict between
the employees’ personal goals and their organisational goals.
Integration of Goals of the Organisation with the Needs of the

Individual
Authority given to enable the individual to carry out tasks can result in an increase
in self-esteem and greater possibility of the tasks being performed well.
Responsibility for their work gives employees ownership of the task involved and
defines what they can and cannot do.
Accountability must be made clear to all individuals given health and safety
responsibilities.
Third Party Control

Identification of Third Parties
Contractors
Employers who engage contractors have health and safety responsibilities for the
contractors and also for anyone else that could be affected by their activities.
Contractors themselves have legal health and safety responsibilities as employers or
as employees.
Cooperation and coordination is important to make certain that everyone
understands the part they need to play to ensure health and safety.

Agency Workers
Businesses and self-employed people using temporary workers must provide the
same level of health and safety protection for them as they do for employees.
Providers of temporary workers and employers using them need to co-operate and
communicate clearly with each other to ensure risks to those workers are managed
effectively.
Before temporary workers start they need to be covered by risk assessments and
they need to know what measures have been taken to protect them.
Other Employers (Shared Premises)

Where employers share workplaces they need to co-operate with each other to
comply with their respective health and safety obligations.
–– This involves telling other employers about any risks their work activities could
present to their employees, both on- and off-site.
The main principle that applies is that employers will be responsible for
those activities and issues that are under their control, but co-operation and
communication with others will still be required.
–– The starting point for all parties is risk assessment which needs to consider the
risks to others sharing the building or site.
Reasons for Ensuring Third Parties are Covered by Health and

Safety Management Systems
There are legal, moral and economic reasons for ensuring that third parties are
covered by health and safety management systems.
Basic Duties Owed To and By Third Parties

Basic duties owed to and by third parties include those of:
–– Designers, manufacturers and suppliers to customers/users (usually in relation
to machinery and dangerous substances for use at work).
–– Occupiers of premises/land to visitors (to take reasonable care to see that the
visitor will be reasonably safe in using the premises for the purposes for which
they are invited or permitted by the occupier to be there).
–– Contractors to clients and vice versa (co-ordination/collaboration of activities
and exchange of essential information that might affect the health and safety of
respective employees).

Selection, Appointment and Control of Contractors

The Planning Stage
Define the task(s) that the contractor is required to carry out.
Identify foreseeable hazards and assess the risks from those hazards.
Introduce suitable control measures to eliminate or reduce those risks.
Lay down health and safety conditions specific to the tasks.
Involve the potential contractors in discussions concerning the health and safety
requirements.
Choosing a Contractor
Determine the technical and safety competence required by the contractor.
Ask the contractor to supply evidence of that competence.
Supply information regarding the job and the site, including site rules and emergency
procedures.
Ask the contractor to provide a safety method statement outlining how they will
carry out the job safely.
Contractors Working on Site

Introduce a signing in and out procedure.
Ensure the contractor provides a named site contact.
Carry out site induction training for all contractor employees.
Where necessary, control activities by using a permit-to-work system.
Checking on Performance
Are contractors working to agreed safety standards?
Have there been any incidents and were they reported?
Have there been any changes of circumstance, e.g. change of personnel?
Review
Regularly review the procedures to ensure currency and effectiveness.
Responsibilities for Control of Risk Associated with Contractors on

Site
There is a general duty to ensure that all reasonably practicable measures are taken
by clients (i.e. those who engage contractors) and people in charge of premises to
reduce the risk to contractors and vice versa.

Provision of Information Relating to Hazards/Risks to Third Parties

Contractors
The employer or client has a duty to provide sufficient information to the contractor
to ensure their safety.
Visitors
It is common practice to give visitors written information on emergency procedures.
General Public
Notices and warnings should appear on perimeter fences, gates, etc. Road works and
other activities that impact on the general public should be publicised.
At high-risk workplaces like refineries and chemical works, information on the
hazards arising from their activities and the action to take in the case of an incident
is necessary.
Review of Contractor Performance

Should include:
The outcomes and achievements of the contractor.
The adequacy of procedures in place during the work.
Consideration of any amendments or additions to the procedures that might be
needed.
Recording the overall performance of the contractor and rating it against established
criteria.
Assembling and providing feedback to the contractor.
Consultation with Workers

Role of Consultation within the Workplace
Successful health and safety management depends on a workforce that is committed to
health and safety and which co-operates with the employer.
The key benefits from consultation are:
Better employment relations between workers and employers.
Workers feel more involved and are more likely to co-operate with their employer.
It creates a safer and less stressful environment which contributes to a good safety
culture.

Formal Consultation
The obligations under ILO Occupational Safety and Health Convention 1981 (C155),
Article 20 can be fulfilled by the appointment of:
Workers’ safety delegates (often called “safety representatives”).
Workers’ safety and health committees and/or joint safety and health committees.
Representatives should have the following functions, rights and entitlements:

Be given adequate information on health and safety matters.
Consulted (when major health and safety measures or changes to work with health
and safety implications are planned).
Protection from dismissal/prejudicial treatment.
Be able to contribute to the health and safety decision-making process/
negotiations.
Access to all parts of the workplace, workers, labour inspectors and health and safety
specialists (as required).
Allowed reasonable time (paid) and given training to perform their functions.
Worker Representatives
The main role of representatives is to work proactively to prevent worker exposure to
occupational hazards and typical activities include:
Workplace observations and inspections.
Examination of records.
Listening to complaints.
Reading information.
Asking members represented what they think.
Health and Safety Committees

Union Committees
The role of the local union committee is to:
–– Respond to worker concerns.
–– Initiate action on the hazards it recognises.
–– Educate union members in health and safety.
–– Help represent workers’ health and safety grievances to management.
Typical activities include:
–– Regular meetings to discuss issues brought to its attention by members, suggest
possible solutions and progress reports on issues being tackled.

–– Developing health and safety training programmes.

–– Researching specific health and safety issues to aid negotiations with
management.
–– Accompanying government inspectors on workplace inspections.
Joint Labour-Management Committees
The role of the Joint Labour-Management Committee is to:
–– Involve management as well as workers.
–– Promote health and safety in the workplace (including providing training).
–– Monitor the workplace for hazards and legal compliance (including inspections).
–– Agree the health and safety policy and its implementation.
–– Work with management to resolve health and safety problems/complaints.
–– Be involved in planning proposed changes that may impact on health and safety.
–– Keep union members informed about planned actions.
Formal Consultation Directly with Workers
If the workplace does not have union representatives then there is still the need for
some form of formal consultation with the workforce. Employers can consult with
workers:
through worker representatives elected by a group of workers, or
directly.
Informal Consultation
Discussion Groups
These consist of a group of individuals coming together to discuss issues of mutual
interest. In the workplace, groups may be formed, often from volunteers, to deal
with a number of issues both work and non-work-related.
Safety Circles
Small groups of employees who meet informally to discuss safety problems in their
immediate working environment.
Departmental Meetings
Attended by shop-floor representatives, supervisory and management staff who
meet frequently, often once a week, to discuss general matters affecting their
department.
Worker Discussions
Formal or informal discussions by groups of employees.
E-mail and Web-based Forums
–– The intranet to access and seek information.
–– E-mails to clarify and engage in two-way communication on health and safety
issues.

–– Web-based forums for exchange of information, discussion and debate about

contentious issues.
Behavioural Aspects Associated with Consultation

Peer Group Pressures
–– The safety representative is a worker’s representative and not part of the
management team.
–– His role is primarily a policing one in which he monitors the safety performance
of management and, because of peer group pressure, he may see himself in a
conflicting, rather than co-operative, role.
Danger of Tokenism
Tokenism is an approach where management goes through the motion of
consultation but has no real intention of taking on board the views expressed by
employees. There is no strict obligation on the employer to implement suggestions
from employees arising from the consultation process (unless there is a specific
legal requirement), but the employer should respond positively to information
gained during the consultation process. If proposals are seen to be rejected without
justification, this is likely to generate general resentment and apathy towards the
process, and have a detrimental effect on the health and safety culture.
Potential Areas of Conflict
–– The safety representative can sometimes see himself as an expert on health and
safety matters, while management may take the view that their opinions are
correct simply because they are management and know better.
–– Consultation about problems where the views of all the participants are
considered should lead to a lessening of conflict and arrival at effective decisions.
Role of the Health and Safety Practitioner in the Consultative

Process
The health and safety practitioner has a substantial role to play in the consultative
process:
–– Often the first contact for the employer or employee on health and safety
matters.
–– May be involved in safety committees in a chairing role or simply in an advisory
capacity during committee deliberations.
Health and Safety Culture and Climate

Culture and Climate Definition
“A system of shared values and beliefs about the importance of health and safety in
the workplace.”

“An attitude to safety which pervades the whole organisation from top to bottom
and has become a norm of behaviour for every member of staff from the board of
directors down to the newest juniors.”
Influence of Health and Safety Culture on Behaviour and the Effect

of Peer Group Pressure and Norms
The safety culture of an organisation has a profound impact on the behaviour of those
who work within it. A poor safety culture will tolerate indifferent and even dangerous
behaviour which will inevitably become the norm so that even workers well aware of
unsafe practices will tolerate poor practices. One such influence is peer pressure from
work colleagues.
Group Formation
People join into groups with people with similar outlooks.
A lot of work situations involve group work or committees and discussion groups.
Group Reaction
The group tends to create rules, and arranges for division of labour.
In small groups, individuals can exert more influence.
Group Development
Groups develop ‘pecking orders’ in terms of the amount of speech and influence
permitted. Dominant individuals struggle for status and an order develops.
Group Control
A group will:
Establish standards of acceptable behaviour or group ‘norms’.
Detect deviations from this standard.
Have power to demand conformity.
Impact of Organisational Culture Factors on Individual Behaviour

We are all influenced to some degree by things that we see and hear, such as television
advertising and lifestyle programmes.
Influences on behaviour in the workplace may include:
Managers and supervisors.
Work colleagues.
Training.

Job design.
Work equipment.
The UK’s HSE publication HSG48, Reducing Error and Influencing Behaviour, associates
the following with good safety performance:
Effective communication.
Learning organisation.
Health and safety focus.
Committed resources.
Participation.
Management visibility.
Balance of productivity and safety.
High quality training.
Job satisfaction.
Workforce composition.
Indicators of Culture
These include:
Housekeeping.
The presence of warning notices throughout the premises.
The wearing of PPE.
Quality of risk assessments.
Good or bad staff relationships.
Accident/ill-health statistics.
Statements made by employees, e.g. “My manager does not care” (negative culture).
Some of these indicators can be easily noticed by a visitor and help to create an initial
impression of the company.
Correlation between Health and Safety Culture and Climate and

Health and Safety Performance
It is often possible to gauge the standard of safety performance of a company by an
initial walk-round and first impressions.
Culture - objective characteristics that can be observed or inferred by an outside
observer.

Climate - subjective assessment of the way people within the organisation perceive
its structures, roles, rules and authority.
Subjective and Objective Nature of Culture and Climate

Culture reflects deeper values and assumptions:
–– The behavioural aspects (i.e. ‘what people do’).
–– The situational aspects of the company (i.e. ‘what the organisation has’).
Climate refers to shared perceptions among a relatively homogeneous group.
–– Used to refer to psychological characteristics of employees (i.e. ‘how people
feel’), corresponding to the values, attitudes, and perceptions of employees with
regard to safety within an organisation.
Measurement of the Culture and Climate

Safety Climate Assessment Tools
The UK Health and Safety Laboratory (HSL) has published a safety climate tool
which uses eight key factors:
–– Organisational commitment.
–– Health and safety behaviours.
–– Health and safety trust.
–– Usability of procedures.
–– Engagement in health and safety.
–– Peer-group attitude.
–– Resources for health and safety.
–– Accidents and near-miss reporting.
Perception or Attitude Surveys
Survey questionnaires containing statements which require responses indicating
agreement or disagreement.
When carried out regularly, attitude surveys can identify trends and it is then
possible to quantify how attitudes are changing.
Findings of Accident/Incident Investigations
Where carelessness is found to be the widespread cause of accidents/incidents, this
may be an indicator of poor safety culture.
Effectiveness of Communication
Successful communication is measured by feedback which enables the sender to test
whether the receiver has fully understood the communicated message.
Evidence of Commitment by Personnel at All Levels
Evidence of commitment can be seen by management visibility.

If managers are not seen at the “sharp end of activity” then they are not interested
in the job or health and safety.
Factors Affecting Health and Safety Culture and

Climate
Promoting a Positive Health and Safety Culture
Management Commitment and Leadership
‘Lead by example’.
High Business Profile to Health and Safety
A positive health and safety culture can be promoted by including safety in all
business documents and meetings.
Provision of Information
About health and safety matters (posters, leaflets or in staff newsletters).
Involvement and Consultation
Involve staff members in:
–– Risk assessments.
–– Workplace inspections.
–– Accident investigations.
–– Safety committee meetings.
Consult with employees on:
–– The introduction of any measures which may substantially affect their health and
safety.
–– The arrangements for appointing or nominating competent persons.
–– Any health and safety information to be provided to employees.
–– The planning and organisation of any health and safety training.
–– The health and safety consequences of introducing new technology.
Training
To ensure that people have the right skills to carry out their job safely.
Promotion of Ownership
Involvement and consultation.
Setting and Meeting Targets
Setting targets:
–– Can have a positive effect on a safety culture.
–– Should encourage people to work together in order to achieve the target.

Factors that May Promote a Negative Health and Safety Culture or

Climate
Organisational Change
This can:
–– Leave individuals worrying about job security and their position in the
organisation.
–– Cause mistrust of management and suspicion of any alterations to role or
environment.
Lack of Confidence in Organisation’s Objectives and Methods
If productivity appears to take precedence over safety, the worker perception will
be that the company is untrustworthy, with little commitment to safety, leading to a
subsequent deterioration in the safety culture.
Uncertainty
Can lead to dissatisfaction, lack of interest in the job and generally poor attitudes
towards the company and colleagues.
Management Decisions that Prejudice Mutual Trust or Lead to ‘Mixed Signals’
Regarding Commitment
Can lead to unrest and distrust in an organisation.
Effecting Cultural or Climate Change

Planning and Communication
Start at the top of the organisation but encourage participation at all levels with clear
objectives as to what is to be achieved by the proposed change.
Strong Leadership
Managers at all levels need to demonstrate strong leadership and not give inconsistent
or mixed messages.
A Gradualist (Step-by-Step) Approach

Advantages - changes are phased in over a period of time, ensuring that there is time
for adaptation and modification and for the change to become part of the established
culture.
Disadvantage - the changes take a relatively long time to implement.
Action to Promote Change

Direct
Positive action is carried out with the sole objective of effecting change (a steering
group and a working party).

Indirect
This brings about change but is not necessarily the primary reason for carrying out
the action, e.g. risk assessments and training.
Strong Worker Engagement

Must be significant commitment from employees who must recognise the need for
change.
Ownership at All Levels

All individuals at all levels must be engaged in the process and committed to change.
Training and Performance Measurements

These are key elements in developing competence and encouraging employee
involvement.
Importance of Feedback
Crucial, to ensure that any changes implemented are working successfully.
Problems and Pitfalls Relating to Change

Changing Culture Too Rapidly
Employees may feel vulnerable, insecure, confused and angry.
Adopting Too Broad an Approach
It is important that everyone is clear about the changes that will occur.
Absence of Trust in Communications
Inconsistent management behaviour can bring about mistrust and uncertainty,
leading to a complete breakdown in relations between management and workforce.
Resistance to Change
Set patterns of thought and behaviour can be difficult to overcome when change
occurs.

Short Questions
1. (a) Explain briefly what is meant by the ‘health and safety culture’ of an
organisation. (2)
(b) Outline, using practical examples, the barriers to the development of a
positive health and safety culture within an organisation. (8)
2. (a) Explain the reasons why an organisation should establish mechanisms for
effective consultation with employees on health and safety matters. (4)
(b) Outline a range of both formal and informal consultation mechanisms that
could contribute to effective worker consultation. (6)
3. The senior management of an organisation wishes to introduce a number of new,
safer working procedures but has met with resistance from the workforce.
Outline the steps that managers could take to gain the support and commitment
of staff when introducing the changes. (10)
Long Questions
4. A manufacturing company is about to embark on a process of organisational

change that is intended to reduce costs and increase productivity. As planned,
the change will lead to a smaller workforce, a flatter management structure,
enlarged responsibilities for the remaining staff, outsourcing of most
maintenance tasks, increased use of automated processes and the need for some
employees to be multi-skilled.
Review the elements of a strategy designed to ensure that the company
maintains its current high standards of health and safety, and its positive health
and safety culture, both during and after the change. (20)

5. The refurbishment of an organisation’s offices will involve the services of several

different trades from a number of small local companies and is to be completed
while the building is occupied. An interior designer specialising in commercial
properties will manage the project.
(a) Outline the criteria that should be used when selecting contractors to
undertake their part of the project. (6)
(b) Outline the organisational measures that the project manager may need
to consider in order to ensure the health and safety of office personnel
during the work.
You are not required to consider the specific risks associated with the
work. (14)
6. (a) Describe the indicators and measures that could be used to assess the
health and safety culture of an organisation. (12)
(b) Describe the organisational factors that may influence the success of an
attempt to improve an organisation’s health and safety culture. (8)

Model Answers
Short Questions
Question 1
Interpretation
Part (a) is asking for a straightforward explanation of the phrase ‘health and safety
culture’. Note that only 2 marks are available here. Part (b) is asking for an outline of a
range of reasons why it might be difficult to improve the culture. Note that you must
give practical examples to illustrate your answer.
Plan
Beliefs, values, behaviour. Positive or negative.
Reorganisation, lack of confidence, poor leadership, no resources, no commitment,
poor communication.
Suggested Answer
(a) The health and safety culture of an organisation is the system of shared values
and beliefs about the importance of health and safety in that workplace. The
culture is how workers at all levels within the organisation think and feel about
health and safety, and about how this translates into their behaviour. The culture
may be positive or negative and will pervade the whole organisation from top to
bottom.
(b) There are many possible barriers to the development of a positive health and
safety culture within an organisation. These are not dissimilar to the factors that
promote a negative health and safety culture and include the following:
Company reorganisations - change is unsettling for all people in an
organisation and during times of change people may lose their belief in the
company and its aims and means. For example, a company downsizing and
making workers redundant will struggle to secure worker commitment to
a health and safety policy that states that “people are our most valuable
asset”.
Lack of confidence in management - if workers do not trust management
to make sound decisions about the direction of the organisation and
the methods used, then they will not engage in initiatives started by
management.

Lack of leadership - people in organisations need to see that people in

management positions are showing clear leadership with regards to health
and safety. If no managers are clearly showing leadership and indicating the
way forward, then workers will not be able to make their own way. Clear
leadership, demonstrated by clear decision making as to the way forward,
coupled with action will show others where to head.
Lack of resources - health and safety cost money. If safety is not adequately
resourced in terms of money and personnel then positive improvements
will be hard to achieve. An example would be a health and safety budget
being cut to achieve a short-term financial target, resulting in the loss of a
part-time safety officer.
Lack of management commitment - in the absence of senior management
commitment, resources and attention will not be paid to health and safety.
Priorities will lie elsewhere and others within the organisation will respond
accordingly. It is only with clear commitment from senior management
that organisations can hope to make positive improvements to their safety
culture. For example, if senior managers are heard to belittle and denigrate
health and safety in meetings, this will send a negative message to middle
and junior staff.
Poor communications - in the absence of clearly communicated policies
and decision making, people will not be subject to the positive influence of
their organisation. They will be left to make their own minds up about how
important health and safety is. If communications are clear, then they will
know what the organisation is thinking and what the organisation is doing to
improve health and safety. Examples would be notice boards, team briefings
and management meeting minutes which do not feature any health and
safety element.
Question 2
Interpretation
This is a straightforward question in two parts. The first part asks you to explain, in effect,
the advantages of having effective consultation arrangements in the workplace. The
second part then requires you to outline what those arrangements might be, ranging
from formal safety committees to informal day-to-day discussions.

Plan
(a) Reasons:
Ownership of safety measures by employees.
Improved perception of value of H&S.
Use of employee knowledge.
Encourage ideas from employees.
(b) Arrangements:
Safety committees.
Consultation with safety representatives.
Consultation at departmental meetings.
Informal consultation by leaders with employees.
Consultation during accident investigation or risk assessment.
Tool box talks.
Discussion at safety circles.
Staff appraisals.
Questionnaires/suggestion schemes.
Suggested Answer
(a) Reasons:
Effective consultation arrangements with employees can result in a number of
benefits relating to health and safety matters in the workplace. These include the
development of ownership of safety measures by employees and an improved
perception of the value and importance of health and safety. There is also the
opportunity for the input of employee knowledge to ensure more workable
improvements and solutions to health and safety problems. Finally, effective
consultation encourages the submission of improvement ideas by employees.
(b) A key formal consultation arrangement is the establishing of a health and
safety committee. Another essential arrangement is consultation with safety
representatives. These may be trade-union-appointed representatives or elected
representatives. Planned direct consultation can take place at departmental
meetings or team briefings. Less formal consultation can also take place during
risk assessments or accident investigations.
Other informal consultation arrangements include day-to-day meetings with
leaders and employees, tool box talks, safety circles or improvement groups, staff
appraisals and questionnaires or suggestion schemes.

Question 3
Interpretation
This question presents a simple case study that can be answered, in the main, from your
own experience. How would you overcome resistance to change to safer work methods?
Find out why, consult, explain, involve, train, review.
Plan
Reasons for resistance.
Consult with workforce (formal/informal).
Step-by-step approach.
Clear explanation to the workforce.
Involve workforce in proposals.
Demonstrate benefits of change.
Training incentives.
Senior management commitment.
Review.
Suggested Answer
The first step to gain support and commitment from the staff should be to find out
what the reasons for resistance are. Might there be fear of redundancy, de-skilling or
simply a general dislike of any type of change? The most important requirement is to
effectively consult with the workforce. This could be through formal means; such as the
safety committee, or more informally; through day-to-day meetings with leaders and
employees, tool box talks, safety circles or improvement groups. A steady, step-by-step
approach with trials and pilots of the proposed changes will ease the introduction, as will
clear explanations of any proposed changes and the reasons for those changes. It will be
important to actively involve the workforce in the proposals, take on board suggestions
and offer training in the new methods. It will also be valuable to demonstrate the
benefits of change, such as improved accident rates and production rates. A final part of
the process should be continuing demonstration of senior management commitment
and regular review of the changes to learn from any mistakes.

Long Questions
Question 4
Interpretation
This is another organisational change question, similar to short Question 3, but we are
given more details about the scenario which need to be included in the answer. So, we
need to think about how reducing costs, increasing productivity, reducing the workforce,
increasing responsibilities, automating processes and outsourcing maintenance tasks will
impact on health and safety and how these changes should be managed. Consequently,
consultation, staff involvement, communication, risk assessment, training and
monitoring of standards will be essential elements of the proposed strategy.
Plan
Clear policy.
Allocation of senior management responsibilities.
Set performance measures.
Amend plans where safety is compromised.
Consultation at all levels.
Involve employees.
Communicate.
New risk assessments with employee involvement.
Map job skills.
Assess training needs.
Capture/replace lost process knowledge/experience.
Procedures to manage risks in outsourced tasks.
Mitigate employee anxiety (communication/job replacement/redundancy).
Allocate time and resources.
Monitor safety performance.
Review change process and safety implications.
Suggested Answer
The strategy should commence with the organisation making a definite statement
of safety objectives as part of the change process so that the policy regarding health
and safety during the change is well understood. It should be clear that plans will be
amended if it is identified that the change process is adversely affecting health and
safety.

There should be senior managers identified with clear responsibilities for managing
safety during the change and performance measures identified and set, against which the
impact of the change can be measured. To maintain the health and safety culture there
should be regular consultation at all levels in the organisation and employees and their
representatives should be involved in working groups dealing with the change. In this
way the organisation can utilise employee experience and also encourage ownership of
the change process.
In addition, there should be regular communication of plans and progress. The planned
change will render current risk assessments invalid and therefore a programme of risk
assessment revision will need to be undertaken with full involvement of employees. The
new roles will require mapping of job skills and experience and also an assessment of
training needs.
Because the proposed change will result in a much smaller workforce, this will lead to
loss of informal knowledge and process experience which will need to be identified and
preserved before employees are made redundant.
The move to outsourcing will lead to increased use of third parties and contractors,
and therefore these new risks will need to be managed, and also consideration given to
contractor competence.
The proposed changes will be stressful for the workforce and therefore steps need to
be taken to mitigate employee anxiety by regular and honest communication, help with
job replacement and an open approach to redundancy. It will also be important not to
rush through the changes and to allow adequate time and resources for training and
implementation of the new structure.
Finally safety performance should be monitored during and after the change and there
should also be regular review of the process and its safety implications.
Question 5
Interpretation
This question fits right into the third party control section of Element IA7. The first part
is straightforward - how do you assess the suitability of a contractor? Note an outline is
required, not just a list of key words. Note the marks.
Part two is concerned with organisational factors, i.e. the management of the work. It is
not concerned with the practicalities of doing the work.
Plan
Experience, references, policy, competence, history, trade member, tests, risk
assessments and method statements.
Work schedules, inductions, security, accident reporting, accessibility/restrictions
(including emergencies), emergency procedures, hazards, waste, information.
.

Suggested Answer
(a) The criteria to be considered when selecting a competent building contractor are
fairly straightforward and would include:
Previous experience with this type of work.
Reputation with previous/current clients (obtained by taking up references).
Content and quality of health and safety policy document and risk
assessments.
Level of training and competence of staff.
Accident and enforcement history (accident statistics going back over 3-5
years; enforcement notices and prosecutions).
Membership of relevant professional bodies.
Equipment and statutory examination records.
Examples of risk assessment and method statements for work carried out.
(b) The organisational measures that may need to be considered to ensure safety of
office staff during the work:
Clear agreement on work schedules and timescales that are then clearly
communicated to all contractors and the office staff.
Induction issues for contractors - so that they understand the implications of
their work for office staff.
Security procedures such as signing in/out.
Accident reporting procedures - so that in the event of an incident involving
office staff, the project manager is informed immediately.
Clear communication and co-ordination on the means of escape that have to
be maintained to ensure office worker safety as the project progresses.
Procedures to be followed in the event of an emergency.
Information on hazards in the building (e.g. utilities and asbestos location/
presence) that not only present a hazard to contractors, but also present a
hazard (if disturbed) to office workers.
Arrangements for delivery and storage of materials - so as not to interfere
with office worker access and egress or emergency escape routes.
Removal of waste that may pose a hazard to office workers.
Information on parts of the building where access might be temporarily
restricted.

Question 6
Interpretation
The first part of this question is concerned with how health and safety culture might
be assessed. Two important words appear in the question; indicators and measures.
How might an external assessor discover and qualify an organisation’s health and
safety culture? Part two of the question is concerned with organisational factors, i.e.
characteristics of the organisation that might influence success.
Plan
(a) Attitudes, communication, business integration and decision making, committee,

adviser, enforcement action, policy documents.
(b) IR, confidence, management commitment, resource allocation.
Suggested Answer
(a) The indicators and measures that could be used to assess the health and safety
culture of an organisation would include:
Attitudes towards health and safety by workers/managers and the
acceptance of health and safety responsibilities. This might be assessed by
questionnaire or interview.
The extent of communication on health and safety within the organisation.
This might be assessed by viewing all of the various forms of communication
that are apparent.
The integration of health and safety into other management functions (e.g.
purchasing). This might be assessed by reference to policy and procedure
documentation and by interview.
The influence of health and safety on management decision-making. This
might be assessed by reviewing management meeting minutes and by
interview.
The effectiveness and composition of the safety committee. This could be
assessed by viewing meeting minutes and by interview.
The status of the Safety Adviser. This could be assessed by examining the
position of the safety adviser within the organisation and by reference to
salary.
The relationship with the enforcement agencies.
The quality of the health and safety policy and its effectiveness. This might be
assessed by reading policy documentation and by audit.

Reference to health and safety in the organisation’s annual report.

Other measures might include the standard reactive monitoring data, such
as lost time accidents, etc. though these are fairly limited in the context of
assessing safety culture.
(b) The factors that may influence the success of an attempt to improve an
organisation’s health and safety culture would include:
The industrial relations (IR) climate within the organisation. If this is good,
then achieving consensus and buy-in will be fairly easy. If IR is poor, then
certain groups of workers may not engage with attempts to improve the
culture and may even deliberately sabotage such attempts.
The confidence of the workforce in their management’s ability to control
risks. If management have the trust of the workforce in this respect
then workers are more likely to listen to and respond to improvement
programmes.
Management commitment to health and safety. If commitment is seen
to be demonstrated, then those workers who support any improvement
programmes have ammunition to win the argument. If management
commitment does not exist, or is not seen to exist, then those arguments will
be lost.
The resources and expertise devoted to health and safety. Lack of resource
handicaps any improvement programme. Good resourcing and the presence
of the right people in the right positions will allow the best chance of success.

Element IA8: Human Factors

Human Psychology, Sociology and Behaviour
Meaning of Terms
Psychology - study of the human personality.
Sociology - study of the history and nature of human society.
Influences on Human Behaviour

Personality
Integrated and dynamic organisation of the physical, mental, moral and social
qualities of the individual.
Attitude
View of the world and approach to the situation.
Aptitude
Talent or the appropriateness of actions.
Motivation
Tendency of an individual to take action to achieve a particular goal.
Key Theories of Human Motivation

Mayo (Hawthorne Experiments)
Working in a small, harmonious group can have a significant effect on productivity.
Having a chance to air grievances seems to be beneficial to working relationships.
Maslow (Hierarchy of Needs)
Self-Actualisation
Esteem
Task
needs Social
Safety or
Security
Biological
Maslow’s hierarchy of needs

If the earlier needs are not satisfied, the person may never get round to doing much
about the later ones.
Not all individuals achieve self-actualisation; many have unsatisfied needs and therefore
their achievements are merely compensations, and they are left frustrated and unhappy
Vroom (Expectancy Theory)
Vroom defined motivation as a process whereby the individual makes choices
between alternative forms of voluntary activities.
Employee effort leads to performance and performance leads to rewards.
The choices made by the individual are based on estimates of how well the expected
results of a given behaviour will lead to the desired results.
Motivation is based on three factors:
–– The expectancy that effort will lead to the intended performance.
–– The instrumentality of this performance in achieving a particular result.
–– The desirability of the result to the individual (valence).
If employees are going to be motivated then all three factors must be positive.
If any are not achieved, employees will not be motivated.
Blanchard
The key psychological needs of an individual are autonomy, relatedness, and
competence. If these are satisfied in a workplace employees will become highly
motivated and more engaged.
The Blanchard model identifies a spectrum with six Motivational Outlooks:
Disinterested – the person finds no value in the project or task and considers it a
waste of time.
External – the project or task only provides the person with an opportunity for
more money or other external gain.
Imposed – the person participates in the project or task only because they feel
pressured to do so.
Aligned – the person links participation to a significant value such as learning from
others or having others learn from them.
Integrated – the person participates in the project or task because they can link it to
a life or work purpose important to them.
Inherent – the person enjoys the activity and wants to participate.
Optimal motivation theory can help managers understand how individuals are motivated
and consequently how a leader’s role might activate such motivation in the workplace.

Factors Affecting Behaviour

Experience
With increasing experience we would expect an employee to become more
competent.
Social/Cultural Background
Factors we learn by association.
Education and Training
Training is used to motivate and change the behaviour of the people involved in
workplace activities to eliminate or reduce human failings which result in accident
behaviour.
Perception of Risk
Human Sensory Receptors
Sight.
Hearing.
Taste.
Smell.
Touch.
Sensory Defects and Basic Screening Techniques

Sensory defects increase with age and failing health.
Some people need spectacles and hearing aids, and you should have a general
idea of why this could be so. The safety practitioner probably needs to be more
concerned about those who don’t know that they have sensory defects or try to
forget about it.
Individuals have the ability to screen out things that they are not interested in.
Perception
Perception of Danger
Factors involved are:
Signals from the sensory receptors.
Expected information from the memory.
These two signals combine to give us a ‘picture’ of the situation of hazard, which is then
processed by the brain. The decision is then to take, or not to take, action.

Perceptual Set
Sometimes called a ‘mindset’; we perceive not only the problem, but also the answer
and set about solving the problem as we have perceived it.
Further evidence may become available which shows that our original perception
was faulty, but we fail to see alternative causes and solutions.
Perceptual Distortion
The perception of hazard is distorted (possibly due to work rates, physical effort, bonus
payments).
Errors in Perception Caused by Physical Stressors
Influences may be fatigue, overwork, overtime, stresses from the workplace, and stresses
from home and outside activities.
Perception and the Assessment of Risk

Problems in the perception of a situation will cause errors in perception of risk.
Perception and the Limitations of Human Performance

Limitations in knowledge, strength, physical and mental ability when trying to put a
solution into effect.
Filtering and Selectivity as Factors for Perception

A filter mechanism only allows vital elements to be passed on for processing in the
brain. We continuously screen out items that are not of immediate interest.
The filtering and selectivity process can present a danger by concentrating on a
particular familiar topic and missing a vital signal which should have warned of
danger.
Human Failure Classification

HSG48, Classification of Human Failure
Errors
Actions or decisions not intended and that involve a deviation from an accepted
standard.
Errors can be split into:
Skill-based errors:
–– Slips - failure in carrying out the actions of a task.
–– Lapses - forgetting to carry out an action.

Mistakes - do the wrong thing believing it to be right:

–– Rule-based.
–– Knowledge-based.
Violations
Deliberate deviation from a rule or procedure.
There are three types of violation:
Routine - normal way of working:
–– Cutting corners to save time and/or energy - may be due to, for example,
awkward working posture, etc.
–– Perception that rules are too restrictive or no longer apply.
–– Lack of enforcement of the rule.
–– New workers starting a job where routine violations are the norm and not
realising that this is not the correct way of working.
Situational - rules are broken due to pressures from the job.
Exceptional - rarely happens and only occurs when something has gone wrong.
Cognitive Processing
On-line processing - decisions which have to be made as a work process is in
operation.
Off-line processing - decisions which can be made after consideration of a number
of alternatives.
Knowledge-, Rule- and Skill-Based Behaviour (Rasmussen)

Skill-based behaviour - person is carrying out an operation in automatic
mode. Errors occur if there are any problems such as machine variation or any
environmental changes.
Rule-based behaviour - operator is multi-skilled and has available a wide selection
of well-tried routines which can be used to complete the task. Errors occur if the
wrong rule is applied.
Knowledge-based behaviour - person has to cope with unknown situations,
where there are no tried rules or routines. Errors occur when some condition is not
correctly considered or when the resulting effect was not expected.
Contribution of Human Error to Serious Incidents

Seveso (near Milan, Italy), 1976
No systematic hazard analysis.
Inadequate reaction/process control.

No emergency response plan.

No safety management system.
Three Mile Island (USA), 1979

Operators under stress.
Operator training was inadequate.
Confusing instrumentation.
Bhopal (India), 1984

Large inventory of the intermediate.
Plant was located next to a sizable population.
Protective systems were not kept in working order.
No systematic hazard analysis.
Instrumentation poorly maintained and unreliable.
Managers and operators at the plant had insufficient experience and knowledge.
Poor emergency planning.
Buncefield (UK), 2005

Instrumentation poorly maintained and unreliable.
Inadequate hazard analysis.
Poor emergency planning.
Piper Alpha Oil-Rig Explosion (North Sea), 1988

Failure in the permit-to-work system.
Design failure.
Inadequate emergency procedures.
Texas City (USA), 2005

Equipment failure.
Inadequate risk management.
Poor staff management.
Poor safety culture.
Lack of maintenance and inspection.
Lack of general health and safety assessments.

Improving Individual Human Reliability in the Workplace

Motivation and Reinforcement
Workplace Incentive Schemes
Encourage employees to work harder in order to receive a payment or benefit.
Reward Schemes
Reward given for improvement or a target reached.
Job Satisfaction
Factors which lead to job satisfaction are motivators.
Factors which lead to an absence of dissatisfaction are hygiene factors.
Appraisal Schemes
Way of finding out what problems exist within a workplace, and give the opportunity
for improving matters.
Provide a measure of the safety culture.
Allow the employee to comment on progress and to voice opinions.
Selection of Individuals
Matching Skill and Aptitudes
Competency-based interviewing - often used to try to identify whether the skills, talents
and abilities of the candidate match the requirements of the job.
Training and Competence Assessment
To get only those workers who will conform to safety standards.
On-the-Job Training
Provides trainees with experience which is a combination of work-based knowledge
and the development of skills.
Off-the-Job Training
–– Lectures.
–– Seminars.
–– Programmed instruction.
Fitness for Work
Some jobs, often called ‘safety critical’, involve activities that require a person’s
full, unimpaired control of their physical and mental capabilities, e.g. tower crane
operator.

Health Surveillance
Health surveillance involves implementing systematic, regular and appropriate
procedures to detect early signs of work-related ill health among employees exposed to
certain health risks, and then taking appropriate action. Examples include hearing tests,
lung function tests and blood tests for substances such as lead.
Support for Ill Health and Common Mental Health Problems

Providing support for workers suffering from ill health (including work-related mental ill
health) will be beneficial for both the worker and the employer.
Organisational Factors
Effect of Weaknesses in the Safety Management System on the
Probability of Human Failure
Inadequacies in Policy
–– Inefficient co-ordination of responsibilities.
–– Poor management of health and safety.
Setting of Standards
Failing to set standards may lead to inconsistencies in performance and behaviour.
Information
Should be accurate and timely.
Planning
A failure to plan will cause failings in all aspects of the safety management system,
e.g. inadequate or absent risk assessments.
Responsibilities
Everyone involved must understand what their role is and how this integrates into
the system.
Monitoring
A failure to monitor will mean that an organisation will not know whether it is
achieving minimum standards.
Influence of Formal and Informal Groups

Formal Groups
Formal organisations/groups are established to achieve set goals, aims and objectives.
They have clearly defined rules, structures and channels of communication.

Informal Groups
Within any organisation there is a ‘grapevine’. This is usually very effective in
communicating gossip and information. Since the source is difficult to trace, the
information might not be totally reliable. So superimposed on the formal organisational
structure is an informal structure of communication links and functional working groups.
These cross all the barriers of management status and can be based on:
Family relationships.
Out-of-work activities.
Experience or expertise.
Organisational Communication Mechanisms and their Impact on

Human Failure Probability
Modes of Communication
Communication can be one-way:
Sender identifies the message.
Sender transmits the message.
Receiver receives the message.
Receiver interprets the message.
There is no opportunity for feedback and the assumption is that the receiver has paid
adequate attention. Examples include: a tannoy message in a factory, a safety poster, etc.
Communication can also be two-way:
Opportunity for the receiver to transmit information or questions back to the
original sender and for the sender to respond such that a conversation takes place.
Likely to be more effective and reliable by placing the onus on both parties rather
than one.
Examples include: a one-to-one meeting, a tool box talk with the opportunity for
questions, etc., or a telephone call.
Shift Handover Communication

During shift handover relevant information has to be communicated to maintain the
continuity of the activities; if this fails there is the risk of serious consequences.
Organisational Communication Routes

Vertical communication:
–– Downwards.
–– Upwards.

Horizontal communication.
Inward and outward communication.
Job Factors
Effects of Job Factors on Probability of Human Error
Task Complexity
Can have a significant effect on the propensity for human error; tasks involving complex
calculations, decisions or diagnoses present more opportunity for such error and should
be broken down into simpler units to give greater clarity.
Patterns of Employment, Payment Systems and Shift Work

Short-term contracts may cause stress due to the lack of job security.
Permanent contracts may lead to complacency in the workforce.
Piecemeal workers are paid by performance and speed is of the essence, because the
faster they work the more they get paid.
Shift workers may experience negative effects on their health.
Application of Task Analysis

A means of breaking down a task into each individual step.
By such detailed analysis the cause of the injury may become apparent and it may
identify a better way of completing the task.
Role of Ergonomics in Job Design

Influence of Process and Equipment Design on Human Reliability
Grouping of displays.
Consistency in displays.
Relative positioning of control devices and displays.
Working space and environment.
Layout of controls, displays and seating for convenience of operation.

The Employee and the Workstation as a System
ENVIRONMENT
Fumes/Gases Heat/Cold Glare/Darkness Vibration Noise
MAN
MACHINE
Display Bells Switches
Dials Buzzers Knobs
Counters Hooters Levers
Gauges Lights Pedals
Ergonomic ‘fit’
Elementary Physiology and Anthropometry

Physiology - study of the functions of the human being. The person must not be
expected to do more than the human body is capable of.
Anthropometry - study of human measurements, such as shape, size, and range of
joint movements.
The machine must be designed for the person.
Degradation of Human Performance Resulting from Poorly Designed

Workstations
Unnatural posture.
Leaning forwards, causing neck and lower back problems.
Repetitive motions, requiring the operator to exert force or use some unnatural
motion, can lead to upper limb disorders.

Ergonomically-Designed Control Systems - Examples of

Applications
Production Process Control Panels
Operate the panel from a safe place.
Reach all the dials and switches easily.
Emergency controls clearly identifiable and easy to operate.
Operator able to see the production area.
Crane Cab Controls

Controls in the cab within easy reach and allow ease and delicacy of control.
Driver has a satisfactory view of operations below.
Driver protected from the external environment.
Aircraft Cockpit
Interface easily with all the controls.
Controls/displays fitted in a logical way.
Safety-critical switches cannot be inadvertently operated.
Emergency controls clearly identifiable, easy to use and situated in a suitable
location.
Pilot must be able to adjust position to obtain the best field of vision.
CNC Lathe
Operator can access the key pad or keyboard easily and use keys comfortably.
Operator can adjust operating position.
Relationship between Physical Stressors and Human Reliability

Physical stressors:
–– Extremes of heat, humidity, noise, vibration, poor lighting, restricted workspace.
They have a negative effect which means that errors are more likely to occur.
Effects of Under-stimulation,Fatigue and Stress on Human

Reliability
Under-stimulation can arise when jobs are monotonous and controlled.
Fatigue can lead to poorer performance on tasks requiring attention, decision-
making or high levels of skill.

Stress can affect performance and an individual’s ability to make decisions and work
effectively.
Behavioural Change Programmes

Principles of Behavioural Change Programmes
The key principle is to positively reinforce the desired behaviour and deter or even
punish the undesired behaviour.
The steps involved in a behavioural change programme:
Step 1: Identify the specific observable behaviour that needs changing.
Step 2: Measure the level of the desired behaviour by observation.
Step 3: Identify the cues (or triggers) that cause the behaviour and the consequences
(or pay-offs) (good and bad) that may result from the behaviour.
Step 4: Train workers to observe and record the safety-critical behaviour.
Step 5: Praise/reward safe behaviour and challenge unsafe behaviour.
Step 6: Feedback safe/unsafe behaviour levels regularly to workforce.
Organisational Conditions Needed for Success in Behavioural

Change Programmes
Good management of technical issues, e.g. machinery guarding.
An effective safety management system.
Adequate resources and commitment.
Example of Typical Behavioural Change Programme Contents

For each of two tasks a list of expected observable behaviours is identified. Observers
then regularly visit the workplace to observe the behaviour and record whether it was
safe or unsafe or not seen. Observers may include all workers and should not be just
those with management or supervisory roles. Example:

Task Expected behaviour Safe Unsafe Not Comment

seen
Loading Loader wears safety gloves 3 1
pallet
Loader wears safety shoes 3 2
Loader adopts safe lifting
procedure 2 0
Loader keeps environment tidy 1 1
Loader deals with spillages 0 0 1
Transporting Driver sounds horn when
pallet by FLT approaching exit doors 4 1
Driver keeps within speed limit 4 2
Driver keeps forks lowered 2 0
Driver is courteous 2 0
Total 21 7
% safe 75%

Short Questions
1. A useful definition of the word ‘perception’ is “the process by which people

interpret the information that they take in through their various senses”.
Outline a range of factors that could affect the way that people perceive hazards
in workplaces. (10)
2. Outline the organisational and behavioural factors that may lead new employees
to disregard instructions given during health and safety induction training. (10)
3. Outline measures to improve human reliability in the workplace. (10)
Long Questions
4. Describe what is meant by ‘skill-based’, ‘rule-based’ and ‘knowledge-based’
behaviour and explain how each of these operating levels can give rise to human
error and how, in each case, such error may be prevented. Illustrate your answer
with reference to practical examples and actual incidents. (20)
5. In relation to human error:
(a) Distinguish between routine, situational and exceptional violations. (6)
(b) Outline, with appropriate reference to actual major incidents, the factors
that might promote routine violations at work. (14)
6. Outline the design features of both controls and displays on the control panel of
complex process machinery that could reduce the likelihood of operator error.
(20)

Model Answers
Short Questions
Question 1
Interpretation
This is a relatively straightforward question. Perception is obviously a key word since it is
the whole focus of the question and has even been defined in the question. Note you
are asked for a range of factors; focus too narrowly on one or two ideas and you will miss
the bigger picture.
Plan
Fatigue, drugs and alcohol, training, experience, aptitude, IQ, environment, sensory
impairment.
Suggested Answer
The range of factors that might affect how people perceive hazards in the workplace
are mostly factors associated with the person themselves. These personal factors would
include issues such as:
The effects of fatigue. A tired person is less likely to take note of sensory
information that an alert person would detect early.
Drugs and alcohol. These have an obvious effect on mental processes and, in some
instances, will be psycho-active and therefore directly interfere with the processing
of sensory information.
Education and training. A trained person will know the meaning of various sensory
inputs, will recognise their importance and act accordingly. An untrained, poorly
educated person may not make the same associations between sensory input and
hazards.
Experience. Inexperienced workers often fail to recognise hazards for what they
are and underestimate the risk associated with hazards precisely because they lack
experience. More experienced workers do not fall into the same trap.
Aptitude. Some individuals will have an innate ability to respond to sensory stimuli
in an appropriate manner.
IQ. A worker with low IQ may struggle to correctly perceive the level of risk
associated with a particular hazard, particularly if the hazard is not visible in nature.
A person with high IQ may be better able to interpret sensory information and
translate that into hazard awareness.
Environmental factors may interfere with a worker’s ability to perceive hazards in the
workplace. Factors such as low light levels, dust, noise and extremes of temperature
can have an effect on hazard perception. This is not only due to direct interference
with the senses themselves, but also to the psychological influence of environmental
extremes.

Any form of sensory impairment will have an obvious impact on perception of

hazards. A partially sighted worker may not be able to see hazards to avoid them; a
colour-blind worker may mistake red and green indicator lights.
Question 2
Interpretation
This question is concerned with rule breaking, and with the reasons for rule breaking
(rather than the classification of rule breaking). Though the question is not subdivided,
there are two clear parts: organisational and behavioural reasons.
Plan
Organisational - recruitment, induction itself, peer group pressure, culture.
Behavioural - age, experience, culture, IQ, attitude, sensory perception.
Suggested Answer
Organisational factors that might lead new employees to disregard instructions given
during induction training might include:
The employee selection process, whereby poor recruitment and selection processes
allow employees with poor attitude, intelligence and behaviour patterns into the
workplace.
A poor induction process that fails to engage the employees, especially if the training
provided is not applicable to actual practice in the workplace.
The absence of refresher training.
A lack of awareness on the part of experienced workers for the safety of new
starters.
Peer group pressure coming to play on new starters forcing them to disregard
instructions so as to fit in with their newly acquired peer group.
Poor levels of supervision such that inappropriate behaviour is not detected or
challenged early.
Poor safety culture (including lack of management commitment) within the
organisation, which will be perceived by new starters early on.
The behavioural factors are those that relate specifically to the character of the
employee themselves, rather than relating to the organisation in which they find
themselves working. The behavioural factors that might lead to employees disregarding
instructions given during induction training might include:
A lack of familiarity with the working environment.
Poor risk perception as a result of young age and/ or a lack of workplace experience.

Issues associated with the cultural background of the individual and consequently
the beliefs and values that they bring into the workplace.
Language issues that might arise as a result of the nationality or cultural background
of the worker, their reading ability and any learning difficulties they may suffer from.
Sensory impairments such as deafness, impaired hearing, impaired sight.
Low IQ or poor mental capabilities leading to difficulties in understanding
instructions or the true nature of hazards and risks.
Question 3
Interpretation
This question is asking for an outline of measures. Be aware that improving human
reliability means in the context of improving safety-related behaviour (reducing the risk
of human error, violations, etc.). We are not concerned with improving time keeping,
quality or any other aspect of “reliability”.
Plan
Employee selection, training (induction, refresher, etc.) and supervision; management
commitment; incentive schemes; workplace/equipment ergonomic assessments of the
workplace; improving working environment; job rotation (monotony/boredom); rest
breaks (fatigue/attention span); communication and consultation.
Suggested Answer
There are many ways of improving human reliability in the context of safety-related
behaviour. If these measures are taken, then there is less likelihood that workers will
break safety rules or will be subject to human error.
Employee selection - recruiting the right worker for the job is an important measure.
For example, a worker with a high IQ working on a monotonous job is more likely to
bend and break the rules to relieve the monotony.
Training (induction, job-specific and refresher) - in the absence of proper, effective
training, workers will not know how to behave correctly and consequently will have to
do what they see as best.
Supervision - it is vital that workers are supervised to an adequate level in the workplace
so that non-compliance and errors are detected and corrected early. This prevents bad
habits from forming and sends a clear message to the worker: rule breaking will not be
tolerated.
Demonstrable management commitment - without strong leadership workers will not
feel motivated to behave correctly.

Incentive schemes - if workers see some form of reward for good behaviour then they
are more likely to comply with rules, etc. and they are also more likely to exercise care
when performing their duties because they have a personal reason for caring about
outcomes. Incentives can be financial in nature, but may have no financial value at all
(e.g. employee of the month schemes).
Workplace/equipment ergonomic assessments of the workplace - it is important
that the environment and the equipment and workstation of employees are designed
and laid out to be as comfortable as possible and to minimise the chances of error.
Job rotation is a good way of relieving monotony and boredom and maintaining some
form of interest.
Allowing for appropriate rest breaks - workers do not become so excessively fatigued
that decision making becomes poor (also to maximise attention span).
Good workforce communication and consultation - so that workers feel engaged
in the decision-making process in the workplace and therefore feel a greater level of
commitment to work.
Long Questions
Question 4
Interpretation
This is a complex question, but is set out in a very clear way. A description of
Rasmussen’s three behaviour models is required. These must be related back to the
main types of human error outlined in HSG48. You should also include an explanation
of how these types of human error can be avoided. Examples must be included for full
marks to be awarded.
Plan
Rasmussen - skill-, rule- and knowledge-based behaviour modes.
Errors - skill-based slips and lapses; rule-based mistakes; knowledge-based mistakes.
Error prevention - skill-based: minimise fatigue and distractions, cross-checks and
supervision.
Rule-based - training, supervision, background knowledge, drills for rare events.
Knowledge-based - competence, time, oversight, access to resources.
Suggested Answer
These three levels of behaviour (skill-, rule- and knowledge-based) are based on the
work of Rasmussen and they underlie the basic types of human error described in the
HSE guidance note HSG48: Reducing Error and Influencing Behaviour.

Skill-based behaviour occurs when a person is carrying out tasks that are routine and
familiar. They may be physical tasks such as pushing a button on a control panel or
mental tasks such as adding a column of figures in the head. The person is not using
any higher-level reasoning skills in performing the tasks - they are acting automatically.
In this mode of operation, two types of human error can occur: slips and lapses. A slip
occurs when the person performs an action incorrectly. For example, an experienced
crane operator attempts to lower a load slowly, but applies too much pressure to the
control lever resulting in a sudden violent lowering of the load. A lapse occurs when a
person omits a step in a process. For example, an experienced machine operator forgets
to remove the chuck key from a grinder, resulting in the key being ejected on start-up.
These types of human error, which occur when a person is behaving in skill-based mode,
can be avoided by ensuring that people are not fatigued; this might require attention
to shift patterns and hours of work, as well as ensuring that adequate breaks are taken.
Ensuring that individuals undertake a variety of tasks may help, by avoiding complacency
and reducing repetitiveness and boredom. Minimising distractions in the workplace can
reduce the likelihood of lapses. The Paddington rail crash, involving a signal passed at
danger, was probably caused (in part) by a skill-based error on the part of the driver who
omitted to correctly recognise the danger signal. Slips and lapses can also be minimised
by introducing double-checking systems into the work routine so that others check
that certain actions have been carried out correctly. Supervision to detect errors is also
useful.
Rule-based behaviour is more complex than skill-based behaviour. Here a person
is starting to use reasoning skills with some higher-level decision making. However,
because the person is familiar with the situation (or thinks they are) they have a set of
options that they can choose from in order to help them decide on appropriate action
to take. In short, a logical approach is made to a situation along the lines of “if A, then
B”, where B is the rule to apply if situation A occurs. In this mode of operation, one type
of human error can occur: rule-based mistakes.
A rule-based mistake occurs when a person incorrectly applies a rule to a situation. For
example, a security guard attempts to evacuate a building during a bomb-threat; they
know the rule for fire is “get out and stay out” and they incorrectly apply this rule to
the bomb threat situation. The correct procedure would be to stay in the building. The
security guard has applied a general rule incorrectly to a situation.

This type of human error can be prevented by providing clear guidelines to follow for
all foreseeable eventualities, by training people in correct diagnosis of problems and
the rules to apply, and by practice of the rules so that they become well known. Good
supervision and process design can also minimise this type of error. The Kegworth air
crash was caused, in part, by rule-based mistakes on the part of the pilot (shutting down
an engine that he thought was on fire, when in fact the other engine was on fire). Rule-
based mistakes can also be minimised by good background training (education) so that
workers are more able to recognise the risks inherent with applying simplistic, rule-based
solutions to problems, and by exposing workers to rare event situations so that they
become aware of times when standard rules do not apply (e.g. conducting emergency
drills).
Knowledge-based behaviour occurs when a person or group of people are trouble-
shooting and problem-solving. It involves higher cognitive skills, reasoning and decision
making. It occurs when an unusual situation arises and the people involved have to take
action and make decisions based on their knowledge and understanding of the situation
rather than relying on a ‘rule of thumb’.
The type of human error that occurs during this mode of operation is the knowledge-
based mistake. This occurs when a person makes a mistake because they do not fully
understand the situation or the system they are working on, or they lack background
knowledge. For example, an electrician electrocutes themselves while fault finding on a
complex electrical system because they lack the competence to correctly diagnose the
problem safely.
This type of human error can be minimised by ensuring that people have the right level
of competence for their roles, i.e. training, background knowledge and understanding. It
can also be minimised by allowing people time to think a problem through and correctly
diagnose problems and solutions. If time constraints are imposed, then knowledge-
based mistakes are far more likely to occur. The Chernobyl nuclear disaster was largely
caused due to knowledge-based mistakes - operators made incorrect decisions during a
simulation exercise because they did not have the background knowledge to correctly
interpret information being fed back to them by the reactor. Competent operators
would have made different decisions. Knowledge-based mistakes can also be minimised
by ensuring that workers are overseen by competent persons and that they have access
to sources of advice, either within or external to the organisation.
Question 5
Interpretation
This question is set in two parts so must be answered in the same way. Note the marks.
Part (a) is itself broken down into three topics, so each part will be relatively short. Part
(b) requires a much more in-depth description of factors. Note that part (b) is only
concerned with the promotion of routine violations (not situational or exceptional
ones); also note the comment about reference to actual major incidents. You do not
have to base your entire answer on actual major incidents, but clearly you should refer to
several as you give your answer.

Plan
(a) Routine - custom and practice.

Situational - not usual, but forced by pressure.
Exceptional - something is already wrong.
(b) Cut corners, save time - working posture, slow controls, noise levels, false
alarms, procedures, PPE, environments, reward/incentive scheme, work
overload, perception, enforcement, new starters.
Suggested Answer
(a) A routine violation is a violation (an example of rule-breaking behaviour) that

has become the normal way of working within the work group (e.g. speeding
when driving in a car); it has become custom and practice to break the rule in
this way.
Situational violations occur because the pressures of the job encourage the
rule to be broken; the procedures can’t be adhered to if the job is to be done,
e.g. no PPE available, so pressure to continue without it. Situational violations
are not the norm within the workplace and you would often expect workers
to do the job the right way, but then they will break the rule because of some
form of pressure (or perceived pressure) - if a deadline is approaching the rule
breaking starts (in order to meet the deadline). Once the deadline is passed,
the pressure is relieved and the proper application of the rule returns.
An exceptional violation occurs when things have gone wrong (typically
emergencies) and a rule is broken in an attempt to rectify the situation. As the
name suggests, exceptional violations only occur in exceptional circumstances.
These definitions do not have clearly defined edges and it is possible that
one type can merge into another type over time. For example, a situational
violation occurs, workers get away with the rule breaking (nothing bad
happens) and so they are encouraged to break the rule again. Over time,
standards slip and the situational violation becomes the normal way of
working - it has become a routine violation.

(b) Routine violations often occur due to cutting corners to save time/energy,
which is encouraged by: awkward, uncomfortable or painful working posture;
excessively awkward, tiring or slow controls or equipment; difficulty in
getting in or out of maintenance or operating position (posture); equipment
or software which seems unduly slow to respond; high noise levels which
prevent clear communication; frequent false alarms from instrumentation;
instrumentation perceived to be unreliable; procedures which are hard to
read or out of date; difficult to use or uncomfortable personal protective
equipment; unpleasant working environments (dust, fumes, extreme heat/
cold, etc.); inappropriate reward/incentive schemes; work overload/lack of
resources.
In addition, there are the following factors: perception that rules are too
restrictive/impractical/unnecessary (particularly true where there has been
lack of consultation in the drawing-up of rules); belief that the rules no longer
apply; lack of enforcement of the rules (e.g. through lack of supervision/
monitoring/management commitment - even sanctioned by management
“turning a blind eye” in order to get the job done); or new workers starting
a job where routine violations are the norm and not realising this is not the
correct way of working (may be due to culture/peer pressure or lack of
training). Examples could include Herald of Free Enterprise capsize (bow
doors left open), Piper Alpha (permit procedures).
Question 6
Interpretation
This whole question is focused on the idea of human error (or operator error), so
think slips, lapses and mistakes - not rule breaking. Note the key words - “controls
and displays”. Note that we are not given a specific panel or process, so we are free to
discuss general principles.
Plan
Controls: minimise number needed, easily operated (position), ordered logically
(follows process), require positive action - with feedback to indicate successfully
operated, stereotyping/conventions (switches up for off, down for on; knobs
clockwise for increase, etc.), position controls next to corresponding displays,
emergency controls (prominent, distinctive), etc.
Displays: visible, labelled, positioning of safety-critical displays, conventions/
stereotyping (colours on dials relating to danger and safe conditions, dials increase
the same way, etc.), analogue vs digital (appropriateness), glare avoidance.

Suggested Answer
It is important, during the design of control panels for industrial equipment, to consider
the possibility of human error. Equipment operators may be subject to human error,
they may commit skill-based errors (slips and lapses) and they may make mistakes (both
rule-based and knowledge-based). These errors might result in highly undesirable
consequences and therefore must be prevented. This can be done by careful design of
controls (those parts of the control panel that an operator has to interact with to make
changes to the operation of the equipment) and displays (those parts of the panel that
deliver information to the operator about the status of the equipment).
Desirable features of controls might include:
Minimise the number needed so as to avoid operator confusion.
Place controls in positions where they are easily operated.
Ensure that controls are ordered logically (e.g. in such a way that the operation of
the controls follows the logical order of the process being controlled).
Design controls so that they require positive action in order to be operated and
cannot be operated accidentally or knocked. For example, a hand brake of a car
cannot be released simply by pushing down on the lever.
Ensure that feedback is available to the operator to indicate successful operation of
the control.
Obey any stereotyping/conventions that might already exist for that type of control.
For example, switches up for off, down for on; knobs turn clockwise for increase, etc.
It may be possible and desirable to position controls next to corresponding displays.
For example, if a knob alters temperature it might be desirable to site the knob next
to the temperature readout.
Emergency controls should be prominent and distinctive so that they are easy to see
and activate. They might be positioned near to the operator’s position so that they
are within easy reach in the event of emergency.
Controls that have to be operated frequently might be positioned close to the
operator for ease of access, while those that are used infrequently might be
positioned further away.
Controls might be laid out in an arc around the operator so that they can all be
activated without the need to over-reach.
Controls that require force to operate should be power or servo assisted.
Controls must not be overly sensitive; minor changes to the control should not
result in excessive changes to the parameter being controlled.

Desirable features of displays might include the following:

Displays must be visible to the operator from their normal operating position. They
must also be large enough to be easily visible to the operator.
They must be appropriately labelled, so that the parameter they are displaying is
clear to the operator; this might require the use of pictograms (which might also
help overcome language barriers).
The positioning of safety-critical displays must be carefully selected so that they are
in the operator’s normal line of sight and in a commanding position.
Again, any conventions/stereotyping that exist should be recognised and used. For
example, colours on dials relating to danger and safe conditions would normally
use green for safe, red for danger. Dials should all increase the same way, normally
clockwise.
Careful selection of analogue vs digital displays should be made. There are times
when a digital readout is perfectly acceptable and desirable. There are other times
when analogue is preferred since the position of the needle on an analogue dial
can be determined by a quick glance that does not require the accurate reading of
numbers.
Displays must be carefully placed and lit so as to avoid glare.
Duplication of adjacent displays should be avoided in some instances where
accidentally reading the wrong display might end in disaster.

Element IA9: The Role of the Health and

Safety Practitioner
Role of the Health and Safety Practitioner
To minimise the risk of harm or injury at work by educating colleagues, setting
procedures and building a culture of safety in the workplace.
To work closely with managers, employees and sometimes trade unions.
To liaise with external contacts, such as contractors, clients and the enforcing
authorities.
To avoid potential conflicts by working impartially with employees, employers and
third parties.
Meaning of the Term ‘Competence’

In relation to a health and safety adviser, ‘competence’ is described in the UK legislation
Management of Health and Safety at Work Regulations 1999 as having:
“sufficient training and experience or knowledge and other qualities to enable him
properly to assist in undertaking the measures referred to…”.
An additional important requirement is the ability to recognise the limits of one’s own
competence.
Need for Health and Safety Practitioners to Evaluate and Develop

their Own Practice
Evaluating Own Practice
Performance Criteria
The practitioner should be able to:
Evaluate their own practice against set targets and goals.
Use a range of valid and reliable evidence to assess their own work, which includes
an assessment of behaviour and values by others.
Involve others in the interpretation of evidence.
Use evidence to reflect on their own practice and professional issues.
Accept criticism in a positive manner, and assess its validity and importance.
Revise goals and targets in the light of their reviewing evidence and performance.

Identifying Self-Development Needs

Performance Criteria
The practitioner should be able to:
Set and prioritise clear and realistic goals and targets for their own development.
Base goals and targets on the accurate assessment of all the relevant information
relating to their own work and achievement, including developments in professional
practice and related areas.
Devise a personal action plan and review it regularly.
Try out developments in their own practice in a way which does not cause problems
for others.
Evaluate developments in their own practice and ensure continued self-
development.
Health and Safety Practitioner – Mentoring and Supporting

Mentoring aims to enhance an individual’s skills, knowledge or work performance
through one-to-one discussions.
Health and safety practitioners can use their specialist knowledge and understanding
to support the development of others.
Increasingly, organisations are looking for practitioners who are collaborative,
supportive and helpful rather than purely advisory.
Supporting a manager to discover the best, most practicable solution to a health and
safety problem can involve mentoring.
Distinction between Leadership and Management

Management - the organisation and co-ordination of the activities of a business in
order to achieve defined objectives.
Leadership - establishing a clear vision, sharing that vision with others and providing
the information, knowledge and methods to realise that vision.
The health and safety practitioner can align with both the management and the
leadership models:
–– Look after the health and safety management system and advise on its effective
operation.
–– Act as a visionary to get board-level buy-in for culture change.

Need to Adopt Different Management Styles

The management style adopted needs to match the nature of the interaction and the
type of relationship with each party.
Management styles can broadly be categorised into the following three groups:
Autocratic.
Democratic.
Participative.
Role of the Health and Safety Practitioner in Safety Management

Systems
Health and safety practitioners need to have the status and competence to advise
management and employees or their representatives with authority and independence.
They are well placed to advise on:
Formulating and developing health and safety policies.
Promoting a positive health and safety culture and securing the effective
implementation of health and safety policy.
Planning for health and safety, deciding priorities and establishing adequate systems
and performance standards.
Day-to-day implementation and monitoring of policy and plans including accident
and incident investigation, reporting and analysis.
Meaning of the Term ‘Sensible Risk Management’

Sensible risk management aims to balance the growing “risk averse” attitude of
society toward innovation and development.
Risk management is not about:
–– Reducing protection.
–– Exaggerating risks.
–– Stopping activities where the risks are managed.
–– Creating a totally risk-free society.
–– Generating paperwork.
Enabling Work Activities as Part of Proportionate Risk

Management
The practitioner should check whether the decision or the chosen precautions are
proportionate by considering the actual risks.
Organisations should take ownership of their risks and take proportionate steps to
manage those risks.

Organisational Risk Profiling

The aim of risk profiling is to examine the nature and level of the threats faced by an
organisation and the likelihood of these adverse effects occurring (i.e. severity and
likelihood).
It establishes the likely level of disruption and cost associated with each type of
risk and enables the effectiveness of controls in place to manage those risks to be
assessed.
The outcome is that significant risks are identified and prioritised for action and
minor risks noted to be kept under review.
It informs decisions about what risk control measures are needed.
Risk profiling provides an organisation with a detailed picture of the:
Risks inherent in its operations.
Effectiveness of the controls in place to mitigate the risk.
Framework for monitoring its higher-risk priorities.
Contribution of the Health and Safety Practitioner in Achieving the

Objectives of an Organisation
Health and safety practitioners can contribute to the achievement of the objectives of an
organisation by:
Leading on health and safety issues.
Acting as advocates, persuading both managers and the workforce of the value of
their knowledge and expertise.
Involving the workforce and communicating so that everyone is clear on what is
needed.
Ethics and the Application of Ethical Principles

Ethics is concerned with moral issues, i.e. the judgments we make and our resulting
conduct.
Just because an action is legal does not necessarily mean it is ethical.
The Institution of Occupational Safety and Health (IOSH) and the International
Institute of Risk and Safety Management (IIRSM) have Codes of Conduct/Ethics
which all members are expected to follow.

Effective Communication and Negotiation Skills

Effective Communication
Two important health and safety messages that need to be communicated are:
Evidence of clear, visible leadership.
A common appreciation of how and why the organisation is trying to improve
performance.
The health and safety practitioner can facilitate the delivery of both.
The health and safety practitioner can play a key role in ensuring that information into
the organisation enables it to monitor:
Legal developments to ensure they can comply with the law.
Technical developments relevant to risk control.
Developments in health and safety management practice.
Need for Consultation and Negotiation

Two of the key organisational requirements for developing and maintaining a positive
health and safety culture are co-operation and communication and both of these involve
consultation.
The key benefits from consultation and negotiation are:
Better employment relations between workers and employers.
Workers feel more involved and are more likely to co-operate with their employer.
It creates a safer and less stressful environment which contributes to a good safety
culture.
Influencing Ownership of Health and Safety

At board level, responsibility and ownership of health and safety can be achieved by
ensuring that:
Health and safety arrangements are adequately resourced.
Competent health and safety advice is available.
Risk assessments are carried out.
Employees or their representatives are involved in decisions that affect their health
and safety.

The following activities can act as drivers to influence ownership:

Participation by employees - supports risk control by encouraging their ‘ownership’
health and safety policies.
Management accountability - managers are judged on how well or effectively they
carry out the duties they are responsible for.
Consultation - can occur at each stage of the health and safety management
system:
–– Plan - consult workers or their representatives during the planning and
organising of training.
–– Do - involve and consult workers and representatives throughout any
implementation.
–– Check - involve the workforce in setting and monitoring performance measures.
–– Act - discuss plans for review and review findings with workers or their
representatives.
Feedback on success and failure - essential for motivating employees to maintain
and improve performance.
Importance of Receiving and Acting on Feedback

Reviewing is the process of making judgments about the adequacy of health and
safety performance.
Organisations need to have feedback to see if the health and safety management
system is working effectively as designed.
Reviewing gives the opportunity to celebrate and promote health and safety
successes.
The main sources of information on health and safety performance feedback come
from measuring activities and from audits.
Different Methods of Communication

To communicate and effectively promote the health and safety message there are three
basic methods.
Verbal communication - using the spoken word, e.g. face-to-face conversations,
meetings, interviews, training sessions.
Written communication - using the written word, e.g. report, memo, e-mail, notice,
company handbook, policy document, operating instructions, risk assessment,
minutes of meetings.
Graphic communication - using pictures, symbols or pictograms.

Procedures for Resolving Conflict and Introducing Change

During periods of change, conflict can occur because of:
Personality clashes.
Poor communication.
Conflicting interests.
Lack of leadership and control.
There are two broad approaches to conflict:
Unitary Approach.
Pluralist Approach.
Generally, managers take the unitary approach to conflict and change, while trade unions
favour the pluralist approach.
Ensuring Roles and Responsibilities are Clear, Understood and

Implemented by Workers
Within the policy there should be details of everyone’s roles and responsibilities
including those with particular functions such as directors, managers, supervisors, safety
representatives, workers, fire wardens, first-aiders and the competent person.
To check the extent of implementation of responsibilities and to make necessary
adjustments if there is early evidence that requirements are not being met, managers
need to monitor performance.
Use of Financial Justification

Significance of Budgetary Responsibility
Employers with good health and safety management systems in place are likely to save
substantial sums on the costs of accidents that would otherwise have happened.
If the business’s income is more than its costs, the business has made a profit.
If the business’s costs are more than its income, the business has made a loss.
The payback period is the amount of time required for the return on an investment
to return the sum of the original investment.
The business case for a health and safety initiative needs to show that the profit
gained from the benefits of the investment will outweigh the loss from the capital
expenditure.

Recognising the Responsible Budget Holder

Health and safety initiatives have to be funded and this requires a responsible budget
holder to agree to authorise expenditure from their budget.
The general arguments used to justify health and safety initiatives need to be directed at
specific budget holders to influence them to make appropriate decisions.
Cost-Benefit Analysis
Analyses the costs associated with loss events and compares them with the costs
associated with preventing or otherwise reducing the risk.
Cost-benefit graph
Problems:
Not all costs and benefits can be assigned reasonably accurate financial value.
Benefits may not be seen immediately.
Some costs and benefits are one-off, others are recurring.
Cost areas could include:
Organisational
Costs of staff, and the time involved.
Design
Engineering aspects.
Planning
Safe methods of work.

Operational
Costs of running and maintaining safety systems.
Internal and External Sources of Information

The cost justification for health and safety initiatives is based on the benefits resulting
from incurring the cost and includes:
New personnel.
Disruption to normal working.
Purchase, fabrication and installation of safety devices.
Lost production and sales.
New safe methods of work and permit-to-work schemes.
New factory layouts.
Running and maintaining safety systems, maintaining guards.
Reduction in accidents, with associated savings.
Projected reduction in civil claims.
Projected reduction in insurance premiums.
Increased productivity.
The business data and information required for this exercise comes from multiple
sources, both external and internal.
Short- and Long-Term Budgetary Planning

Short-term financial plan:
–– Capital costs for plant and equipment.
–– Running costs.
Long-term financial plan:
–– Benefits, or cost savings from improved health and safety standards.
–– Projected savings from reduced accidents and incidents.

Unit IA Revision Guide: And Finally...
And Finally...
Hopefully, this Revision Guide has provided you with relevant practice questions as
well as some ideas for tackling them. It should also have shown that the questions are
straightforward, but that it is vital that you READ THE QUESTION and answer the
question that is written (not the one that you want it to be!).
In order to do well in the exams, it is really important to practise as many exam questions
as possible - the Examiner’s Reports for previous exams can be purchased from NEBOSH
(+44(0)116 263 4700) or online at www.nebosh.org.uk. These Examiner’s Reports do
not provide model answers, but nevertheless highlight important points that should have
been included in your answer.
Lastly, don’t panic about the exam, but do ensure that you are prepared - you want to
make sure that all your hard work will be rewarded.
Good luck!

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NEBOSH International Diploma

RRC Ref. NIDARG.3

ISBN for this volume: 978-1-911002-84-0

Welcome to your NEBOSH International Diploma Unit IA Revision

Element IA1: Principles of Health and Safety Management 13

Element IA2: Regulating Health and Safety 29

Element IA3: Loss Causation and Incident Investigation 46

Element IA4: Measuring and Reviewing Health and Safety

Element IA5: The Assessment and Evaluation of Risk 79

Element IA6: Risk Control 98

Element IA7: Organisational Factors 112

Element IA8: Human Factors 143

Welcome to your NEBOSH International

Overview of the Exam

NEBOSH Command Words

Compare and Contrast

Element IA1: Principles of Health and Safety

Societal Factors which Influence an Organisation’s

Uses of, and the Reasons for, Introducing a Health

Health and Safety Management Models

Application of the PDCA Cycle

The Reasons for the Introduction of Health and Safety

Principles and Content of Effective Health and Safety

 Express commitment to improving health and safety performance.

Communication of Health and Safety Information

General Principles and Objectives of a Health and Safety Policy Document

Practical objectives might include:

Key Elements of a Health and Safety Management System

Model Health and Safety Management System (ILO-OSH-2001)

ISO 45001 - Occupational Health and Safety Management Systems

The ISO 45001 Occupational Health and Safety Management System

Benefits and Limitations of Integration of Quality, Environmental,

2. A multi-site business has a quality management system compliant with ISO

(a) Integration - consistency of format, avoidance of duplication of procedures,

The benefits of integration

The benefits of retaining the existing system of separate management systems

Element IA2: Regulating Health and Safety

Nature, Benefits and Limitations of ‘Goal-Setting’ and ‘Prescriptive’

 Legal Hierarchy of State and Federal Laws

Loss Events in Terms of Failures in the Duty of Care to Protect

Purpose of Enforcement and Laws of Contract

Principles of Enforcement with Reference to the UK HSE’s

Role and Limitations of the International Labour

Roles and Responsibilities of ‘National Governments’,

Use of International Conventions as a Basis for Setting National

Role of Non-Governmental Bodies and Health and

Importance of Print, Broadcast and Social Media in a Global

Benefits of Schemes which Promote Co-operation on Health and

Adverse Effects on Business Reputation

An Organisation’s Moral Obligations to Raise Standards Within

Role and Function of Corporate Governance in a System of Self-Regulation

How Internal Rules and Procedures Regulate Health and Safety

5. Non-governmental bodies have an important role in influencing health and

(a) Benefits: (b) Limitations:

(a) One of the more important benefits of self-regulation is that it is developed

(a) Prescriptive Legislation

(b) Goal-Setting Legislation

(a) Punitive damages:

(a) (i) Corporate probation:

(ii) Adverse publicity order:

(a) (i) Corporate probation is a supervision order imposed by a court on a

(ii) The intention of an adverse publicity order would be to publicise the

 UK, Institution of Occupational Safety and Health (IOSH):

Express commitment to improving health and safety performance.

Legal Hierarchy of State and Federal Laws

UK, Institution of Occupational Safety and Health (IOSH):

The system as a whole produces failures when:

Underlying deficiencies in safe systems, risk assessments, etc. must be

Safe methods of work, permit-to-work schemes.

(a) Active - forward looking, lead indicators, objectives achieved, inspections.