RR 174

HSE
Health & Safety

Executive
Costs of compliance with health and safety
regulations in SMEs
P re p are d b y Entec UK Limited fo r th e
H e alth an d S afe ty E xe cu ti ve 2003
RESEARCH REPORT 174
HSE
Health & Safety
Executive
Costs of compliance with health and safety
regulations in SMEs
Rebecca Lancaster, Rachel Ward,
Paul Talbot and Andrew Brazier
E n te c U K L i m i te d
D o h e rty I n n o vati o n C e n tre
P e n tlan d s S ci e n ce P ark
B u sh L o an
P e n i cu i k
M i d lo th i an
E H 26 0P Z
The following report details the findings of a study carried out by Entec UK Ltd on behalf of the Health
and Safety Executive to assess whether the costs of compliance with health and safety regulations are
disproportionate across different sizes of organisations, what the nature of expenditure is and how
effective the activities have been in improving health and safety performance. A postal survey of
organisations in Agriculture / Forestry, Construction, Health, Manufacturing and Transport sectors was
conducted, followed by indepth interviews with a sample of employers across these sectors (site visits).
As well as general health and safety expenditure and activity, the review focused on the Management
of Health and Safety at Work Regulations, COSHH Regulations, Control of Pesticides Regulations,
Manual Handling Operations Regulations and Noise at Work Regulations. The study identified that the
costs of compliance are disproportionate across different sizes of organisation, although the size at
which these costs became disproportionate varied across the different pieces of legislation. The
findings from the site visits largely supported those from the postal survey. Recommendations are
made regarding the nature of advice required by different sizes of organisations, and how they might
be more effectively targeted in the future.
This report and the work it describes were funded by the Health and Safety Executive (HSE). Its
contents, including any opinions and/or conclusions expressed, are those of the authors alone and do
not necessarily reflect HSE policy.
HSE BOOKS
Crown copyright 2003
First published 2003
ISBN 0 7176 2782 9
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, mechanical,
photocopying, recording or otherwise) without the prior
written permission of the copyright owner.
Applications for reproduction should be made in writing to:
Licensing Division, Her Majesty's Stationery Office,
St Clements House, 2-16 Colegate, Norwich NR3 1BQ
or by e-mail to hmsolicensing@cabinet-office.x.gsi.gov.uk
ii
CONTENTS
EXECUTIVE SUMMARY v
1. INTRODUCTION 1
1.1 Background 1
1.2 Aims and Objectives 2
2. METHODS 3
2.1 Summary of the Approach 3
2.2 Task One Postal Survey of Organisations 3
2.3 Task Two Site Visits 4
3. FINDINGS POSTAL SURVEY 5
3.1 Make up of Responses 5
3.2 Hazards of Particular Concern 5
3.3 Formal Health and Safety Management Systems 6
3.4 Recording Work-related Accidents and Ill-health 14
3.5 Reported levels of Accidents and Ill-health 15
3.6 Compliance Costs 16
3.7 Benefits of Compliance 31
3.8 Sources of Advice and Information 33
4. FINDINGS SITE VISITS 37
4.1 Validation of Information 37
4.2 Summary of validation section 37
4.3 Costs of Compliance 38
4.4 Factors Motivating Health and Safety 41
4.5 Other Findings 43
5. GENERAL DISCUSSION AND RECOMMENDATIONS 45
5.1 Discussion 45
5.2 Recommendations 48
6. REFERENCES 51
iii
APPENDICES
Appendix A Postal Survey Questionnaire
Appendix B Postal Survey: Pilot questionnaire evaluation form
Appendix C Postal Survey: Detailed sample structure and response rate
Appendix D Postal Survey: General findings
Appendix E Postal Survey: Findings by size
Appendix F Postal Survey: Findings by sector
Appendix G Postal Survey: Specific regulations
Appendix H Site Visits: Supporting information
Appendix I Site Visit Summaries
iv
EXECUTIVE SUMMARY
BACKGROUND
An initiative in 1999, conducted by the Better Regulation Task Force (BRTF), considered the
regulatory barriers to start-up, success and growth of small businesses and found that smaller
companies are often at a competitive disadvantage compared with larger organisations because
of the cost and time involved in regulatory compliance. This has been supported, in the case of
health and safety regulations, in a recent evaluation of the Manual Handling Operations
Regulations commissioned by HSE (Lancaster et al, 2001). That study revealed that the cost
per employee in organisations taking action to manage manual handing risks was 341 per
employee for small organisations and 37 per employee for large organisations.
AIMS AND METHODS
The study aimed to assess whether the costs of compliance were indeed disproportionate across
a wider range of regulations, what the nature of expenditure was and how effective the action
taken had been.
This project had three specific objectives:
Investigate to what extent the costs of compliance with health and safety regulations were
disproportionate across different sizes of organisation;
Highlight the circumstances underlying the development of health and safety systems in
Small and Medium-sized Enterprises (SMEs);
Identify recommendations regarding the nature of guidance required by SMEs and how they
can be targeted.
A combination of postal survey and follow-up visits was conducted across a range of sizes of
organisations and sectors including Agriculture / Forestry, Construction, Health services,
Manufacturing and Transport. As well as general health and safety expenditure, five pieces of
regulation were chosen to be included in the study. These were Management of Health and
Safety at Work Regulations, Control of Pesticides Regulations, COSHH Regulations, Manual
Handling Operations Regulations and Noise at Work Regulations.
Care should be taken in interpreting the information across sectors as the proportion of SMEs
and large organisations varied across these sector samples. For example the Agriculture group
has a much greater proportion of SMEs than all other sector groups.
MAIN FINDINGS
The results from the site visits and postal survey were mainly consistent. The findings from the
survey included:
Large organisations with greater than 5000 employees report considerably less expenditure
per employee for all regulations compared with organisations of fewer than 5000 employees
(see discussion that follows for examples).
Medium and large organisations report training as their greatest expenditure, small
organisations report training and provision of Personal Protective Equipment (PPE) as their
greatest expenditure, however it was discovered during the site visits that not all
organisations included the costs of employing health and safety personnel.
v
Larger organisations were more likely to think that the benefits outweighed the costs.
Reported benefits were broadly similar across all organisations. Construction companies
perceive an added benefit of ensuring acceptance onto tender lists and success in gaining
contracts.
The main motivators underlying the development of health and safety systems were legal
obligation (particularly in larger organisations), health and safety publicity (particularly in
SMEs) and requirements from other existing internal systems and procedures.
Larger organisations preferred Internet based sources of information, compared with a
preference for paper based information among SMEs.
The main frustrations, when establishing health and safety systems, for newly established
organisations were reported as time restrictions, cost, lack of knowledge / skill and lack of
information and guidance. Encouragingly, a third reported no frustrations when setting up
health and safety systems.
ADDITIONAL FINDINGS
Over two thirds of organisations had formal health and safety systems in place. This
proportion is greater for large organisations than SMEs. Reasons for not having systems
included lack of knowledge, too small, low priority, and time restrictions.
A large proportion of those with formal systems had a health and safety policy, documented
risk assessments, accident reporting and a designated health and safety person / role. Much
fewer organisations, particularly SMEs, had performance measurement and performance
targets.
Organisations that have been operating for longer had more comprehensive systems,
particularly the inclusion of performance targets and performance measures.
Manual handling was the most reported hazard of concern by Construction, Manufacturing
and Health; vehicle transportation hazards for Transport and moving machinery by
Agriculture/Forestry.
The majority of organisations record accidents, fewer record ill-health. Larger
organisations are more likely to record accidents and ill-health than SMEs.
Medium-sized organisations report more accidents per employee than small and large
organisations. However, in the site visits, there were more accidents in small organisations
than medium and large organisations.
DISCUSSION AND RECOMMENDATIONS
Are costs of action greater for SMEs compared with large organisations?
firms are often at a competitive disadvantage compared with larger firms because of the cost
and time involved in regulatory compliance. This was highlighted by some of the participants
in the current HSE study, who stated a concern that there was a danger of them being at a
competitive disadvantage, due to the compliance costs incurred.
However, in this current HSE study, the overall reported spend on health and safety increased
slightly with size of the organisation. This is confounded by the fact that some organisations
failed to include some expenditure in this calculation, particularly the cost of employing health
and safety personnel within the organisation. For this reason the reported costs for particular
vi
pieces of regulation are considered to be more accurate, in terms of actual spend. The most
noticeable trend was that very large organisations of 5000+ employees spent considerably less
per employee than those with 5000 employees or less. For example small firms spent 7 times
more per employee and organisations with between 1000 4999 employees spend 15 times
more per employee than very large firms (+5000 employees) on the Management of Health and
Safety at Work Regulations. Therefore, it appears to be true that the costs of compliance are
disproportionate for very large organisations than for smaller organisations. Whilst this is true
of all 5 regulations investigated, there is considerable variation across regulations in terms of at
what size of organisation this disproportionate effect occurs.
Costs of compliance were clearly disproportionate for small firms when implementing the
Manual Handling Regulations and the Noise at Work Regulations. This may be influenced by:
the economies of scale when purchasing PPE, equipment, and training; the ability of larger
organisations to adopt generic risk assessment processes, where appropriate; and, the increased
likelihood that larger organisations will have an in-house specialist that can provide training on
these issues.
What is the nature of expenditure?
SMEs were less likely to have formal health and safety systems in place. All organisations were
more likely to have a written health and safety policy (92%), an accident reporting system
(94%), a designated health and safety role/person (90%) and documented risk assessments
(88%) than performance targets and measures (34% and 39% respectively). However, those
that had been in operation for longer were more likely to have targets and measures in place,
perhaps suggesting that it is not until systems have been in place for some time that
organisations look to set performance targets and measure their health and safety performance.
The majority of small and large organisations managed their health and safety in-house.
However, large organisations were more likely to involve employees in the form of health and
safety committees or groups etc. Medium sized organisations were much more likely to use
external consultants to assist them in meeting their requirements.
Has the action taken been effective?
Respondents were asked what effect the action they had taken to comply had had, selected from
a specific range of potential outcomes (e.g. performance / productivity, staff morale, sickness
absence, time lost through accidents, etc.). When reporting on these potential outcomes, over
half of all organisations reported that their actions had not led to any effect (i.e. neither
positively nor negatively).
Large organisations were more likely to report that the benefits outweigh the costs. This may be
due to the fact that SMEs are less likely to have experienced an accident and therefore do not
realise the costs associated with not taking action. SMEs were also less likely to have
performance measures and targets in place and therefore may be relying on their perception of
the benefits and costs rather than a more calculated objective view.
Construction and manufacturing were most likely to report specific benefits but were also more
likely to have performance measures and targets in place to make this judgement. However,
construction also reported additional benefits compared with other sectors. Construction
companies reported that health and safety systems are crucial in the commissioning of work and
therefore the benefits to this sector may be far greater than for others.
Effectiveness of guidance
It was identified that many organisations had considered implementing health and safety
systems within the first five years of operation. It was also identified that SMEs are motivated
vii
to take action by publicity about health and safety and therefore failure to establish systems may
be associated with lack of awareness rather than lack of willingness to comply.
It was identified that very few organisations actually measure the impact of their activities and
therefore have very little information on which to base an assessment of the costs and benefits
of this activity.
Recommendations
The main recommendations were therefore that:
Thought should be given to the provision of awareness, and possibly training, through business
start-up and local enterprise initiatives. Organisations may also be targeted via BSI, ISO,
Investors in People, Inland Revenue as organisations have been found to introduce health and
safety systems as part of a review of other systems and procedures they are required to
implement.
HSE inspectors were found to be a useful source of advice. However, this varied greatly across
sectors and regions. Therefore further work is required to ensure a more consistent message /
service.
Further guidance and advice is required, for all organisations but especially SMEs, on new
regulations that are relevant to them, setting performance targets for health and safety, and
evaluating the effectiveness of specific activities and their impact on these targets.
Additional guidance, regarding measurement of health and safety performance, is required by
all organisations to allow them to demonstrate the benefit of compliance with regulation. This
should allow performance to be determined without the necessity for the occurrence of
accidents.
viii
1. INTRODUCTION
1.1 BACKGROUND
In 2000, the University of Manchester (Chittenden, Kauser & Poutziouris) conducted a literature
review of the regulatory burdens of small business. The purpose of the study was to review the
academic literature and a variety of reports on the impact of government regulations on small
firms in the U.S.A., the U.K., the European Union, Australia and New Zealand. In all the
countries studied small firms were concerned about the level of compliance costs that they
incurred, and, in all countries reviewed, the government had accepted that the burden of
regulation has a disproportionate impact on small firms.
The review stated that, small businesses are more severely affected by red tape than large
companies because small firms are less proficient in dealing with the complexities of regulation
and are unable to spread the costs of compliance across large scale operations. Beale and Lin
(1998) found that compliance costs were disproportionately higher for small firms. The
Occupational Safety and Health Agency estimated that the compliance costs of regulations on
lead exposure in construction to be greater than for small firms compared to larger firms.
The review also observed substantial variability in perceived regulatory burdens across
industries and regions, which was stated as being unsurprising due to the diverse nature of the
small business sector. The impact on different business sectors was considered in a survey in
2000 conducted by the SBRT
1
for NatWest. Construction, agriculture and business service
sectors were observed as spending more time per person on compliance with government
regulations. It was argued that although these results may be partially caused by the relatively
small number of employees per firm in agriculture and business services, construction and
agricultural firms also have to deal with many health and safety, and environmental regulations.
Overall findings of Chittenden, Kauser, and Poutziouris 2000 review showed that:
It was recognised in all countries in the study that small firms bear a relatively higher
burden of costs than larger businesses.
It was not possible to provide a rule of thumb that could be used to estimate the extent to
which compliance costs borne by small firms are greater than those for large firms. Where
it was possible to quantify differential impact on small businesses it appeared that the
burden faced by businesses with up to 20 employees is at least 35% higher than for the
largest size of firm (i.e. firms with more than 500 staff, e.g. ENSR, 1995). It was stated that
this figure should be seen as an absolute minimum.
It was recognised that, in the majority of cases, the costs borne by small firms were
relatively much higher: it is common for firms with less than 20 employees to incur
compliance costs that are several times greater than the costs incurred by large businesses
(e.g. Inland Revenue, 1998).
The costs associated with compliance with health and safety legislation are cited as a major
barrier to compliance, particularly if the benefits are not realised (Wright et al, 1999). Due to
the number of people employed by each organisation, they may go for some time without
1
SBRT surveys are conducted quarterly for NatWest and are mailed to small firms who are members of
the SBRT volunteer group.
1
experiencing an accident. In addition, it is reasonable to suggest that the costs of compliance
with health and safety legislation are greater per employee for smaller organisations than for
large ones. It is also reasonable to assume that SMEs will not necessarily have the health and
safety expertise in house that is afforded by larger organisations. Consequently SMEs may be
slower to realise the costs of accidents and the benefits of health and safety interventions.
The recently conducted Evaluation of the Manual Handling Operations Regulations
commissioned by HSE (Lancaster et al, 2001) highlighted the disproportionate costs of
compliance across difference sizes of organisations. The study revealed that the cost per
employee in organisations taking action to manage manual handing risks was 341 per
employee for small organisations and 37 per employee for large organisations. Clearly cost of
compliance for small organisations is disproportionate to that for large organisations.
Provision of appropriate guidance and support for SMEs is key to improving health and safety
compliance and performance. Revitalising Health and Safety (Government and HSC, 2000)
makes particular reference to small firms and the fact they have difficulty accessing information
relevant to them. A greater understanding of these costs, how effectively they are allocated and
the circumstances and the factors that motivate SMEs to tackle health and safety would allow
more appropriate and more suitably targeted guidance to be provided for SMEs.
1.2 AIMS AND OBJECTIVES
This project has three objectives:
Investigate to what extent the costs of compliance with health and safety regulations are
disproportionate across different sizes of organisation;
Highlight the circumstances underlying the development of health and safety systems in
SMEs;
Identify recommendations regarding the nature of guidance required by SMEs and how they
can be targeted.
This report first details the methodology employed to tackle the above aims and objectives, with
the findings separated into two sections, i.e. postal survey findings and site visit findings. The
postal survey section pays particular attention to what formal health and safety management
systems organisations have in place and the main reasons that prompted the development of
these systems; and, compliance costs and benefits, including average spend per employee and
nature of expenditure by size, sector, and regulation. The site visits section summarises the
findings of the 30 site visits, again focusing on costs of compliance, main expenditure, benefits
of compliance, and factors motivating the development of formal health and safety systems. A
general discussion and recommendations follow this.
Additional results can be found in the appendices for those readers wishing to have more
detailed findings. Relevant sections of the appendices are therefore referred to at appropriate
points throughout the report.
2
2. METHODS
2.1 SUMMARY OF THE APPROACH
The project involved three tasks:
A postal survey of organisations, investigating costs of compliance, accident and incident
history, and approach to health and safety management;
Site visits to 30 of the organisations involved in the postal survey. Of the 30 organisations,
20 were SMEs and 10 were large organisations. The main focus of the visits was to:
- Validate the data from the postal questionnaires;
- Allow more detailed cost benefit assessment of regulations;
- Further expand on any links in the development of health and safety systems,
compliance with health and safety legislation, and other non-health and safety
system development /compliance;
- Document particularly cost effective systems that have been shown to have a
significant impact on reduced incidents / health and safety performance.
Reporting for each of the above phases.
2.2 TASK ONE POSTAL SURVEY OF ORGANISATIONS
2.2.1 Sample
Five sectors were agreed as the focus for this study, which mainly reflect the priority areas for
HSE. An equal number of organisations were selected for each of the 5 sectors, within these the
sampling reflected the true proportion of organisations in each of the size categories (based on
Dun and Bradstreet database records).
Table 1
Sample structure
Sector (SIC codes) Large
250+
Medium
50 - 249
Small
0 - 49
Total
Agriculture / Forestry (01, 02, 09) 42 252 2106 2400
Construction (15, 16, 17) 425 1175 800 2400
Manufacturing (20-39 inc) 800 800 800 2400
Transport (41, 42, 75) 261 1243 896 2400
Health (80) 232 1153 1015 2400
3
2.2.2 Questionnaire design
Five pieces of regulation were agreed for investigation. It was established that little had been
done to review the Management of Health and Safety at Work Regulations, particularly costs of
compliance. Manual Handling Operations Regulations, COSHH and the Noise at Work
Regulations were selected, as they would provide a comparison across sectors, and as they are
likely to be applicable to all sectors. The Pesticides Regulations were selected as being
particularly relevant to the Agriculture sector. The questionnaire was printed in two-colour
print to encourage response. See Appendix A.
2.2.3 Questionnaire piloting
The questionnaire was piloted in 10 organisations, one large and one SME in each of the 5
sectors. Each pilot organisation was sent a copy of the questionnaire and asked to complete it
and provide feedback using a pilot evaluation form (see Appendix B). This feedback was used
to update the questionnaire, the majority of comments centred around:
Lack of historical information available regarding the costs of compliance;
Questionnaire seemed more appropriate for large firms than a small business.
The questionnaire was redrafted based on this feedback, in particular:
Questions allowed organisations to provide general information if detailed information was
not available (therefore ensuring a certain level of information to work with).
The wording was reviewed to ensure that small organisations would feel it was relevant /
appropriate for them.
2.2.4 Data analysis
The results are presented, categorised by organisation size and by sector.
Mostly the results are presented as a percentage of the total respondents or respondents that
answered a particular question.
The costs relating to size are presented as mean costs and costs per employee.
Caution should be given to interpreting the costs per sector as some sectors have a greater
proportion of small organisations than others. The results are therefore discussed more in terms
of the variations in the nature of the expenditure across sectors rather than actual expenditure.
2.3 TASK TWO SITE VISITS
2.3.1 Sample
30 site visits were conducted. A cross sample was taken from the responses from the original
postal survey. The sample structure is detailed in Appendix D.
2.3.2 Pro forma development
The pro forma was developed to reflect the aims of the visits, these being to validate the
information from the postal survey as well as expand on the information gained regarding costs
of compliance and the nature of expenditure in relation to the 5 pieces of regulation being
investigated.
4
3. FINDINGS POSTAL SURVEY
3.1 MAKE UP OF RESPONSES
Whilst the initial sample was structured to mirror the true make-up of the sectors, the variations
in response rates from 10% to 24% has resulted in a sample that does not mirror the true sector
structure as closely as was hoped. Care should therefore be taken in making comparisons across
sectors.
Further details of the make up of the responses, including a number from sub-groupings by
sector, are presented in Appendix C.
3.2 HAZARDS OF PARTICULAR CONCERN
Employers were asked which of a range of given hazards were of particular concern in their
organisation. Multi-site organisations were asked to respond for their own site only.
The hazards of greatest concern varied per sector, as shown in chart 1. Whilst manual handling
was the primary concern in the construction (88%), manufacturing (86%) and health (65%)
sectors, vehicles / transportation hazards were dominant in the transport sector (83%), and
moving machinery in the agricultural / forestry sector (70%).
Chart 1
Main hazards per sector
0
10
20
30
40
50
60
70
80
90
100
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Slipping/tripping hazards
Chemicals
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Main Hazards
Respondents from the construction and manufacturing sectors seemed to have the greater
number of potential hazards (average 9 hazards & 8 hazards per respondent) than any other,
whilst the fewest hazards were stated in the health sector (average 4.5 per respondent).
5
Businesses which had been in operation for less than 5 years reported less potential hazards than
longer established businesses (e.g. 70% new businesses vs at least 77% for older businesses
reported manual handling hazards).
Smaller businesses also reported less potential hazards than larger businesses (e.g. 72% small
businesses vs. 90%+ larger businesses reported manual handling hazards).
Organisations that record work related accidents / ill health reported more potential hazards than
those that do not (3% none of them vs. 42% none of them respectively). The same is true for
organisations which have formal health and safety systems in place (3% none of them vs.
30% none of them respectively).
The other hazards most likely to be offered included:
Infection / cross-contamination / bodily fluids (13 mentions);
Animals / handling animals (9 mentions);
Violence / aggression / attacks (9 mentions);
Sharp objects / needles (8 mentions);
Radiation / X-rays (9 mentions);
Asbestos (5 mentions).
3.3 FORMAL HEALTH AND SAFETY MANAGEMENT SYSTEMS
3.3.1 What systems do organisations have in place?
84% of organisations had formal health and safety management systems in place (at the site at
which they were interviewed) and 16% did not. In implementing these systems many of the
organisations had a designated health and safety role, risk assessments, an accident reporting
system and written health and safety policy. However, considerably fewer had specified health
and safety performance measures and / or targets, as shown in chart 2.
6
Chart 2
Formal health and safety systems
90
94
88
39
34
92
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10
20
30
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A designated An accident Documented risk Performance Performance Written health and
health and safety reporting system assessments measurements targets/objectives safety policy
person/role
Businesses that did not have formal health and safety management systems in place were asked
why they had not implemented such systems.
Almost a third (30%) lacked the necessary knowledge. Whilst, the small number of
organisations reporting they did not have formal health and safety management systems in
place means statistical comparisons cannot be made, it is felt significant that this reason was
most often cited within the manufacturing sector (47%).
A quarter gave no reason (24%).
A fifth felt they had no employees or that their company was too small for it to matter
(21%), particularly the case in the construction sector (39%).
A further fifth felt it was a low priority (20%), less so in the construction sector (9%).
A further fifth cited time restrictions (19%), particularly in manufacturing (33%).
7
3.3.2 Do larger organisations have more comprehensive systems than SMEs?
Significantly fewer small businesses had formal health and safety systems in place (71% for
small companies compared with 84% for large). Also, the systems in place at smaller
companies were often less comprehensive than those within larger organisations (e.g. only 17%
of small companies include performance measurements compared with 71% of large
companies).
Chart 3
Formal health and safety systems by size
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8
3.3.3 Do some sectors have more comprehensive systems than other sectors?
Fewer organisations in the agriculture / forestry sector had formal systems in place, compared to
the other sectors, and the systems were generally less comprehensive. This finding is however
confounded by the sample within the agriculture / forestry sector containing a greater proportion
of SMEs. The results for the other sectors were broadly similar.
Interestingly, a quarter of organisations that claimed they did not record work related accidents
did report that their management systems included an accident reporting system (23%),
suggesting that they may in fact record accidents.
Chart 4
Formal health and safety systems per sector
0
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60
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Health Services
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9
3.3.4 When were formal systems first considered?
Respondents were asked when their organisation had first considered implementing formal
health and safety systems. 61% had first considered formal systems since 1990, 18% between
1980-89 and 11% before 1980. Not surprisingly, due to the introduction of the six pack of
regulations, there was a peak in activity around 1990. See chart 5.
Chart 5
When formal health and safety systems were first considered
12
10
8
6
4
2
0
Percent
1815 1948 1960 1969 1975 1981 1987 1993 1999
1932 1953 1966 1972 1978 1984 1990 1996 2002
In what year did you first consider implementing h&s
This pattern was similar across all sectors. However, it was clear that the transport sector had
lagged behind the others, demonstrating a peak of activity around 1999. See chart 6.
Whilst charts 5 and 6 suggest a drop in activity in 2002, caution should be taken when
interpreting this data, as organisations may have under-reported activity for 2002 as the survey
was issued part way through that year.
10
Chart 6
When formal health and safety systems were first considered by sector
16
14
12
Percent
10
8
6
4
2
0
Sector of Activity
Construction
Health Services
Manufacturing
Transport
1815 1948 1960 1969 1975 1981 1987 1993 1999
1932 1953 1966 1972 1978 1984 1990 1996 2002
In what year did you first consider implementing h&s systems?
The businesses that had first considered their formal health and safety systems longer ago
appear to be more likely to include performance measurements and targets than those which
considered them more recently. This may indicate that systems become more sophisticated over
time. For example, 51% of businesses that considered formal systems before 1980 include
performance measurements, compared to only 37% of those who considered systems since
2000.
Respondents with formal health and safety systems in place were asked how long their business
had existed before such systems were considered.
A quarter of respondents did not know how long their business had been in operation before
formal health and safety systems were implemented (25%).
A quarter had considered formal systems between 0 5 years after their inception (26%).
12% after 6 10 years.
10% after 50 years.
11
Businesses in the agricultural / forestry sector were most likely to have existed for longer before
implementing formal health and safety systems only 10% had implemented them within the
first 5 years of existence. This is likely to be related to the length of time the companies had
been in operation, as it may be assumed that many were family run businesses that had been in
operation for generations. Health sector organisations were the most likely to have
implemented systems within their first 5 years of existence (35%).
3.3.5 What prompts organisations to comply with health and safety regulations?
Respondents within businesses that had formal health and safety systems at their site were asked
for the three main reasons that prompted the development of formal health and safety systems.
The main reason was legal obligation (68%), followed by health and safety publicity (52%).
For 39% it had been part of other systems that were being developed in the organisation, for
example new quality systems. A quarter was prompted by insurance costs (27%) and
experience of accidents within the organisation (24%). This is shown in chart 7.
Chart 7
Reasons for implementing formal health and safety systems
0
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The main other reasons included:
Concern for staff / client / patient welfare (15 mentions);
Moral / social duty (12 mentions);
Legal / NHS / registration requirements (9 mentions);
Good business practice / responsible employers (7 mentions);
Change management or ownership (6 mentions);
12
Company policy / philosophy (6 mentions);
Common sense (5 mentions).
Smaller organisations appeared to be more likely to respond to publicity (65%), whereas large
organisations were more likely to respond to the introduction of other systems (42%), overall
system reviews (23%), experience of accidents (47%).
Whilst the primary reasons were common across sectors, it appeared that:
Health and safety publicity had less effect in the manufacturing sector (40% vs minimum
52% in the other sectors).
Visits by HSE / Local Authority inspectors had more effect in the agricultural/forestry
sector (22%, vs 8% or less in the other sectors).
Supplier / customer / client pressure has more effect in the construction sector (25% vs
maximum 10% in the other sectors).
Insurance costs have been a more important prompt in the manufacturing (37%) and
transport (33%) sectors compared to the other sectors (maximum 23%).
Accidents have been a more important prompt in the manufacturing sector (34% vs
maximum 25% in the other sectors).
Please see Appendix F, chart F1, which provides further detail on reasons for implementing
health and safety systems across sector.
13
3.4 RECORDING WORK-RELATED ACCIDENTS AND ILL-HEALTH
The vast majority of organisations reported that they record work-related accidents and ill-
health (88%). Organisations that record accidents and / or ill health were asked how accurate
they felt the records were.
Almost all of them felt their records were very (67%) or quite (32%) accurate for recording
work-related accidents. Only 1% thought that their records were not accurate.
Whilst the vast majority of organisations felt they kept accurate records of ill-health, it was
significantly lower than the proportion which kept accurate records of work-related accidents.
In total, 41% kept very accurate records of ill-health and a further 48% kept quite accurate
records. 9% thought them not very accurate and 2% not at all accurate.
3.4.1 Are large organisations more likely to record accidents and ill-health?
Only 79% of businesses employing under 50 staff reported that they record accidents, compared
to 99%+ of larger businesses. Only 48% of businesses employing under 50 staff recorded ill-
health, compared to 76%+ larger businesses.
Chart 8
Recording work-related accidents by business size
Large (250+
employees)
Medium (50-249
employees)
Small (1-49
employees)
l i ?
l i
Do you record work re ated acc dents Yes
Do you record work re ated acc dents? No
0% 20% 40% 60% 80% 100%
14
Chart 9
Recording work-related ill-health by business size
Large (250+
employees)
Medium (50-249
employees)
ill
ill
Do you record -health? Yes
Do you record -health? No
0% 20% 40% 60% 80% 100%
3.4.2 Are some sectors more likely to record accidents and ill-health?
Those involved in agriculture / forestry were significantly less likely to record accidents or ill-
health than all the other sectors (62% agriculture vs. 93%+ of those in the other sectors
recording accidents; 37% agriculture vs. 67%+ of those in the other sectors recording ill-health).
The perceived accuracy of recording work related accidents was greatest in the health and
manufacturing sectors (73% & 70% very accurate respectively) and lowest in the agriculture /
forestry sector (57%). The perceived accuracy of recording ill health was greatest in the health
and manufacturing sector (53% very accurate) and lowest in the construction sector (28%). For
charts providing further details of recording work-related accidents and ill-health, by sector,
please refer to Appendix F, charts F2 and F3.
3.5 REPORTED LEVELS OF ACCIDENTS AND ILL-HEALTH
3.5.1 How many accidents are reported by organisations?
All respondents were asked how many of a range of accidents and ill-health instances their
organisation had encountered within 2001, and in the previous 5 years.
It appears that there were more accidents in the manufacturing, transport and construction
sectors than in agriculture / forestry or health sectors in 2001, with a very similar trend shown in
the data for the previous five years. The detailed results for 2001 can be seen in Appendices E
and F, tables E1 and F1 respectively.
15
3.5.2 Are accident rates different in larger organisations when compared to
SMEs?
In order to establish whether accident rates vary according to the size of an organisation the
percentage chance of reporting an accident per size category is presented in Appendix E, table
E2. It would appear that those organisations with less than 5000 employees (i.e. the small,
medium and large-sized organisations) report more accidents per employee than the very large
organisations with 5000 or more employees. This is true for 2001 and the previous 5 years.
3.6 COMPLIANCE COSTS
3.6.1 How much do organisations spend on health and safety?
All respondents were asked to estimate how much they spent on health and safety in the
previous 12 months (March 2001 March 2002). 27% had spent less than 1,000, 17% had
spent between 1001 - 5,000, 11% between 5,001 - 10,000, 21% between 10,001 -
50,000, and 12% over 50,000.
3.6.2 Do SMEs spend more than large organisations?
As expected, smaller companies spent less than larger organisations on health and safety in the
last year, averaging just over 4,000, compared to over 27,000 for medium sized companies,
almost 420,000 for large organisations, and almost 630,000 for very large organisations (see
table 2 for further detail).
Table 2
Average spend on health and safety by size
Average Mean
Spend
Minimum Mean
Spend
Maximum Mean
Spend
Mean N Mean N Mean N
Small (0-49) 4,136 654 2,077 654 5,651 654
Medium (50-249) 27,345 648 17,288 648 33,787 648
Large (250-4999) 419,691 219 411,731 219 427,663 219
Very Large (5000+) 628,926 127 619,450 127 631,107 127
Not Known 28,784 128 23,241 128 32,359 128
Total 110,301 1776 103,620 1776 114,606 1776
16
Table 3
Average spend per employee by size of organisation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
5000+
M3 - Management of H&S at work 111.59 176.75 20.89 15.99
P3 - Pesticides 50.50 25.74 2.90 0.58
C3 - COSHH 54.40 27.45 9.75 11.06
MH3 - Manual Handling 571.61 46.75 8.60 5.01
N3 Noise at Work 164.39 140.96 6.38 5.18
A16a - Total Spend on H&S 149.38 166.38 20.58 19.54
When calculated per employee, the most noticeable finding when looking at costs of compliance
by size of organisation is the relatively small amount spent per employee for large and very
large organisations when compared with small and medium-sized organisations. The spend is
very similar across large and very large organisations. For organisations with less than 250
employees the spend is also broadly similar. There are however some variations in relation to
specific regulations. For example, SMEs spent considerably more per employee than larger
organisations on the Noise at Work Regulations, Management of Health and Safety at Work
Regulations, and on the Manual Handling Regulations.
Table 3 shows that Manual Handling is clearly the largest disproportionate cost overall for small
organisations, one potential explanation for this is that the capital costs of procuring equipment
to comply with these regulations are easier to recall than the costs of the amount of time
invested. Costs per employee for complying with the Pesticides Regulations may be skewed in
the organisations with less than 50 employees, due to the high number of farmers in this
category. Costs per employee for specific regulations are discussed in more detail in section
3.6.5.
3.6.3 Do some sectors spend more than other sectors?
Those in the agriculture / forestry sector appear to have spent the least in the previous year.
However, this may not be surprising given that the majority of this sample was small companies
and they have a narrower range of health and safety activities compared with other sectors. The
manufacturing and construction sectors, which spent more than the other sectors in the previous
year, shared a very similar pattern of expenditure (see chart 10), although average
manufacturing expenditure was skewed upwards by several businesses spending very large
amounts (see Appendix F, table F2, for further details).
17
Chart 10
Cost of compliance per sector
%

100
90
80
70
60
50
40
30
20
10
0
Estimated H&S spend
Don't know
More than 50000
10001-50000
5001-10000
1001-5000
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101-500
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3.6.4 What is the nature of health and safety expenditure?
Respondents were asked to report their 3 main health and safety expenditures.
Provision of Personal Protective Equipment (PPE) was reported as being the main expenditure
across small organisations within the agricultural / forestry, construction, and manufacturing
sectors. Training was the main expenditure amongst small organisations in the health sector.
Provision of PPE and training were therefore amongst the main expenditures across the majority
of sectors for small organisations. Provision of PPE was the second main expenditure for the
transport sector (the majority of respondents in the transport sector did not know what their
main expenditure was).
Training provision was the main expenditure for all five sectors across the medium-sized
organisations. Provision of PPE was the second largest expenditure for the construction,
manufacturing, and transport sectors, whilst moving and handling was the second greatest
expenditure for the health services sector (25%). Comparison with the small organisations
showed that health and safety consultants were more likely to be employed by the medium-sized
organisations across most of the sectors
Training provision was also the main expenditure for all five sectors across the large
organisations. Salary for health and safety personnel was the second largest expenditure for the
construction sector, possibly due to the requirements under the CDM Regulations. Larger
construction organisations are likely to act as principal contractors and therefore require more
health and safety input under CDM than smaller construction companies. Manual handling was
the second largest expenditure for the health services sector, likely to be in relation to
purchasing of equipment. Like the medium-sized organisations, provision of PPE was the
18
second greatest expenditure across the construction, manufacturing, and transport sectors.
Within the agricultural /forestry sector, an equal proportion of respondents reported that they did
not know what their main health and safety expenditure was, as did those that reported training
as their main expenditure.
Across all three sizes of organisation, provision of training and PPE appeared to be the most
commonly reported main two expenditures by the respondents in the postal survey. For further
details of the nature of 3 main health and safety expenditures, by size of organisation, please
refer to Table E3 in Appendix E.
3.6.5 Expenditure on actions taken and costs per employee Specific
Regulations
This section of the report covers the expenditures incurred and the costs per employee, when
taking action in relation to each of the 5 specific regulations. Please refer to Appendix G for
further detail regarding the specific regulations, in particular information regarding response to
each of the regulations, in addition to details regarding the actions and activities implemented.
Management of Health and Safety at Work Regulations
The amount of expenditure per activity relating to the Management of Health and Safety at
Work Regulations varied (as shown in chart 11 and Table 4). The greatest expenditure by far
was on implementing control measures, followed by providing health and safety assistance.
The least was spent on making other special arrangements for temporary staff, young people etc.
and co-operation with employers with whom the respondent organisation shared the workplace.
Chart 11
Expenditure on actions to meet Management of Health and Safety at Work Regulations
100%
80%
60%
40%
20%
0%
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Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
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Taking the given costs and the low, midpoint and high point per cost category where no actual
cost was given, the calculated mean expenditure per activity was as shown in Table 4. The
mean estimated spend per activity ranged from just under 3,000 for other arrangements in
connection with temporary workers, expectant and new mothers and young people to over
125,000 for implementing control measures.
Table 4
Average costs of actions to meet Management of Health and Safety at Work Regulations
Actions Calculated Valid Number of Mean, Valid Number Mean low point
mean responses (for based on of responses mean high point
the calculated
mean)
actual
costs given
(for the actual
costs mean)
Range
(calculated mean
respective ranges)
Risk assessments 7,549 N=1215 7,544 N=671 6,266 8,833
H&S arrangements 9,293 N=961 9,929 N=519 7,883 10,702
Implementing control measures 125,572 N=556 200,783 N=318 122,973 128,172
Health surveillance 9,583 N=523 9,338 N=304 8,149 11,017
H&S assistance 22,400 N=897 25,708 N=516 19,517 25,285
Serious and imminent danger 6,755 N=581 7,209 N=310 5,520 7,989
Information and training for staff 13,011 N=1002 14,161 N=551 11,432 14,591
Co-operation with employers with whom 5,825 N=313 12,284 N=157 4,810 6,840
share the workplace
Other special arrangements for 2,897 N=383 1,478 N=198 2,015 3,779
temporary staff, young people etc.
The Calculated mean is based on taking the midpoint of each cost band, reflecting those respondents who provided a cost band as
their response. The Mean based on actual costs given is based on averaging the actual cost figures given by those respondents
who quoted actual figures. Therefore, the valid number of responses are fewer for the actual costs mean, as the majority of
respondents provided cost bands rather than actual figures.
20
Table 5
Average spend per employee for action taken in relation to the Management of Health
and Safety at Work Regulations
Regulation: Management of Health &
Safety at Work Regulation
Average spend per employee per Regulation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
1. Risk Assessments 87.01 34.03 14.07 15.00
2. Health & Safety arrangements 98.51 46.63 14.36 16.91
3. Implementing control measures 278.31 133.48 54.79 41.19
4. Health surveillance 63.92 30.15 16.04 11.42
5. Health & Safety assistance 177.28 93.07 41.47 24.74
6. Serious & imminent danger procedures 38.75 27.98 9.71 6.04
7. Information & training 109.80 57.16 26.21 15.92
8. Co-operation with other employers 84.40 17.28 10.13 4.46
9. Special arrangements for temp workers 58.82 8.33 4.21 1.91
M3 TOTAL 111.59 176.75 20.89 15.99
The significant finding here is that spend per employee for the Management of Health and
Safety at Work Regulations is less for organisations with greater than 250 employees. The
costs, in every category of compliance, are greatest for small organisations, i.e. those with less
than 50 employees.
21
Control of Pesticides Regulations
The amount of expenditure per activity relating to pesticide control varied (see chart 12). The
greatest expenditure items were related to controlling and confining application of pesticides
and the least was application notifications and restrictions.
Chart 12
Expenditure on actions taken to Control of Pesticides
%

t
a
k
i
n
g

a
c
t
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n

100%
80%
60%
40%
20%
0%
Don't know
More than 50000
Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
Less than 100
Information to Measures Getting Storage - cost Application - Notifications
employees - taken to certificates - category? cost and
cost protect - cost cost category category? restrictions -
category? category? cost
category?
cost was given, the calculated mean expenditure per activity was as shown in table 6. The mean
estimated spend per activity ranged from 710 for notification of aerial application and
observing restrictions to just under 5,000 for controlling application.
22
Table 6
Average costs of actions to meet Control of Pesticides Regulations
Actions Calculated
mean
Valid Number of
responses (for
Mean,
based on
Valid Number
of responses
Mean low point
mean high point
the calculated actual (for the actual Range (calculated
mean) costs given

costs mean) mean respective
ranges)
Information, instruction, training & 1458 N=174 1412 N=97 1078 1839
guidance
Protect health 3134 N=150 2734 N=82 2593 3675
Certificates of competence 1543 N=132 1416 N=76 1153 1934
Storage 2219 N=179 2667 N=105 1836 2602
Application controlled/ confined 4973 N=84 6486 N=50 4737 5209
Notification of aerial application & 710 N=26 8169 N=6 517 904
restrictions observed
Table 7
Cost per employee for action taken in relation to Control of Pesticides Regulations
Regulation: Pesticides Average spend per employee per Regulation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
1. Information, instruction, training.. 28.15 15.97 2.83 0.37
2. Protecting humans, creatures, plants.. 63.07 29.51 3.56 0.72
3. Certificates of competence 25.14 17.08 3.15 0.71
4. Storage 41.98 36.86 1.63 0.48
5. Controlled application 140.97 34.81 5.64 1.06
6. Notification of restrictions 15.44 13.11 0.79 0.09
P3 TOTAL 50.50 25.74 2.90 0.58
For all activities, small organisations spend more per employee than any other size category.
Large and very large organisations spend significantly less than small and medium-sized
organisations. It should be noted that there were only 13 large agricultural companies in total.
23
COSHH Regulations
The amount of expenditure per activity relating to the managing COSHH regulations varied (as
shown in chart 13 and table 8). As may be expected, the greatest expenditure was on control
measures, and the least on the time spent deciding what to do.
Chart 13
Expenditure on actions to meet COSHH Regulations
100%
80%
60%
40%
20%
0%
More than 50000
Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
Less than 100
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24
Table 8
Average expenditure on activities to meet COSHH Regulations
Actions Calculated
mean
Valid Number of
responses (for
Mean,
based on
Valid Number
of responses
Mean low point
mean high point
the calculated
mean)
actual
costs given

(for the actual
costs mean)
Range
(calculated mean
respective ranges)
Risk assessments - COSHH 5333 N=1147 6020 N=612 4387 6279
Time spent deciding 3633 N=748 3458 N=367 2825 4441
Costs of control measures 12945 N=810 15294 N=427 11182 14709
Maintenance/ examination & testing 6660 N=549 6538 N=282 5336 7984
Monitoring exposure 4742 N=505 4133 N=498 3610 5876
Health surveillance 5256 N=858 8201 N=215 3852 6648
Information, instruction & training 6238 N=807 4760 N=410 5180 - 4429
Table 9
Costs per employee of actions taken in relation to COSHH Regulations
Regulation: COSHH Average spend per employee per Regulation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
1. Risk assessments 34.47 23.82 9.88 12.42
2. Time spent implementing 34.78 17.47 6.71 3.65
3. Cost of control measures 131.70 54.70 19.80 30.72
4. Maintenance & examination 39.71 33.53 9.01 6.01
5. Monitoring of exposure 56.48 17.85 6.00 8.06
6. Health surveillance procedures 51.60 17.58 9.81 9.91
7. Information instruction & training 51.22 23.99 8.24 8.12
C3 TOTAL 54.40 27.45 9.75 11.06
The costs per employee of actions taken for small-sized organisations were greater than for
medium organisations in respect of all activities undertaken. The spend per employee is
significantly less for organisations with more than 250 employees. The costs for the large and
very large organisations were greater than SMEs in respect of all activities.
25
Manual Handling Regulations
The amount of expenditure per activity relating to the manual handling regulations varied (see
chart 14). As may be expected, the greatest expenditure was on changing work practices and
new equipment. The least expenditure was on risk assessments and reviewing assessments.
Chart 14
Expenditure on actions to meet Manual Handling Regulations
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
%

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Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
Less than 100
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26
cost was given, the mean expenditure per activity was calculated (see table 10).
Table 10
Average expenditure on activities to meet Manual Handling Regulations
Actions Calculated
mean
Valid Number of
responses (for
the calculated
mean)
Mean, based
on actual
costs given
Valid
Number of
responses
(for the
Mean low point
mean high point
Range (calculated
mean respective
actual costs ranges)
mean)
Employment/training a specialist 6002 N=539 4925 N=296 4566 7438
Risk assessments - Manual handling 3416 N=875 3190 N=428 2526 4305
Work practice changes 42338 N=552 86320 N=241 40545 44131
Work environment changes 13016 N=291 16649 N=126 11116 14916
Load changes 5060 N=251 4637 N=96 3807 6312
New equipment 29751 N=566 43960 N=280 27265 32238
PPE 6017 N=556 5720 N=276 4820 7213
Training & information 5709 N=800 5782 N=393 4409 7008
Reviewing assessments 3603 N=475 3063 N=212 2682 4524
Occupational health 9145 N=200 9126 N=95 7662 - 10629
27
Table 11
Costs of action in relation to Manual Handling Regulations: per employee
Regulation: Manual Handling Average spend per employee per Regulation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
1. Employment/training of a specialist 288.86 37.91 3.06 5.04
3. Work practices/processes 2,855.05 57.66 41.85 5.99
4. Work environment 594.44 71.86 8.22 5.77
5. Changes to the load 222.10 33.56 3.24 0.03
6. New equipment 745.18 118.32 11.31 17.53
7. Provision of PPE 302.89 31.67 4.13 1.80
8. Training and information 194.76 37.25 3.04 5.96
9. Reviewing assessments 145.86 21.46 3.39 0.59
10. Provision of occupational health 400.98 51.48 6.18 6.75
MH3 TOTAL 571.61 46.75 8.60 5.01
The costs of action taken in relation to the Manual Handling Regulations were much greater per
employee for small organisations, again this is confounded by a few organisations who have
spent a significantly greater amount on controls or equipment. For example, some reported
spending between 20, 000 and 30, 000 on lifting equipment. With less than 50 employees
these are significant amounts per employee. The work environment, work processes and new
equipment categories should be treated with caution as respondents have reported provision of
new equipment under each of these headings.
Costs of action taken, per employee, in relation to the Manual Handling Regulations were
broadly similar across large and very large organisations.
28
Noise at Work Regulations
The amount of expenditure per activity relating to the noise at work regulations varied (see chart
15). The greatest expenditure was on reducing noise and other actions. These other actions
primarily included audiometry tests, noise assessment tests and getting new, quieter equipment.
The least expenditure was on maintenance and review.
Chart 15
Expenditure on actions to meet Noise at Work Regulations
%

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s
p
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100%
80%
60%
40%
20%
0%
Assessments Reduction of Provision of Hearing zones Maintenance Information to Other actions -
of risks - cost noise - cost PPE - cost - cost category and review - employees - cost category
category category category cost category cost category
More than 50000
Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
Less than 100
cost was given, the calculated mean expenditure per activity was as shown in table 12.
29
Table 12
Average expenditure on activities to meet the Noise at Work Regulations
Actions Calculated
mean
Valid Number of
responses (for
Mean,
based on
Valid Number
of responses
Mean low point
mean high point
the calculated actual (for the actual Range (calculated
mean) costs given

costs mean) mean respective
ranges)
Risk assessments - noise 3226 N=666 2682 N=345 2374 4079
Reduction of exposure 46671 N=433 84964 N=212 45074 48268
PPE 3161 N=653 2214 N=340 2172 4152
Creating hearing protection zones 3487 N=236 4138 N=109 2699 4275
Maintenance and review 2858 N=315 1828 N=157 1829 3887
Information to staff 3512 N=447 3796 N=218 2672 4352
Other actions - noise 52272 N=54 84246 N=31 51099 53445
Table 13
Costs per employee for action taken regarding Noise at Work Regulations
Regulation: Noise at Work Average spend per employee per Regulation
Small Medium Large Very Large
(0-49) (50-249) (250-4999) (5000+)
2. Reduction of noise exposure 357.12 681.34 8.69 21.62
3. Provision of PPE 128.68 21.71 1.86 0.61
4. Creation of hearing protection
zones
158.78 17.56 3.07 12.91
5. Maintenance and review of
control measures
103.18 21.31 1.96 0.25
6. Provision of information 109.74 30.99 2.21 0.59
7. Other actions 368.71 600.90 25.71 0.00
N3 TOTAL 164.39 140.96 6.38 5.18
30
SMEs spent significantly more per employee than large and very large organisations. However,
this is confounded by a small number of organisations that have spent significant amounts on
particular controls. For example an SME organisation employing 43 staff has spent 75,000 on
replacement of equipment and sound reduction. Another organisation with 550 employees
spent 1.5 million on noise prevention engineering and reduction. Many of the reported noise
controls are described as plant renewals and therefore, whilst having health and safety benefits,
these changes may well have been installed irrespective of the noise implications.
3.7 BENEFITS OF COMPLIANCE
3.7.1 Do the benefits outweigh the costs?
On balance, the costs of implementing the health and safety systems were believed to have been
outweighed by the benefits by 31% of respondents. 14% thought the costs had outweighed the
benefits, and 14% thought they had broken even. A quarter did not know (26%) and 16%
thought it was too early to say.
Organisations that have experienced a change in staffing levels were more likely to think the
benefits outweighed the costs of implementing health and safety systems (40% increased staff,
37% decreased staff compared to 27% for the same staffing levels).
Large employers were also more likely to think the benefits outweighed the costs (47%,
compared to 34% for medium and 22% for small organisations). There was a tendency for
businesses that have greater numbers of days lost through illness and accidents to be more
positive about the benefits of implementation. 26% organisations with under 5 lost days citing
benefits outweigh costs, rising to 55% of those that lost 250 or more days through illness /
accidents.
Chart 16
Cost-benefits of compliance
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
10
19
12
13
46
17
39
15
11
19
15
28
15
14
28
14
36
15
23
13
18
29
12
21
19
14
31
14
16
26
l
i
i its
Don't know
Too ear y to say
Costs and benefits broken even
Benefits outwe ghed the costs
Costs outwe ghed the benef
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31
i
The construction and manufacturing sectors were the most likely to think the benefits
outweighed the costs (39% & 36% respectively, compared to a maximum of 29% in the other
sectors).
3.7.2 What impact does this action to achieve compliance have?
a list of potential outcomes.
More than half of the organisations felt that their actions had not led to any improvements, with
the exception of staff morale (37% recorded no effect) and time lost through accidents (41%).
The outcomes more likely to have been positively effected included:
Performance / productivity (20% increase, 8% decrease);
Staff morale (33% increase, 4% decrease);
Damage and waste (17% decrease, 3% increase);
Sickness (16% decrease, 5% increase);
Time lost through accidents (27% decrease, 2% increase).
Insurance premiums were more likely to have increased than decreased (15% increase, vs 8%
decrease), as was the number of staff employed (12% increase vs 4% decrease). For further
details of effects of compliance, see Appendix D, chart D1 and table D1.
For differences in effects of compliance by sector, please refer to Appendix F, table F3.
32
3.8 SOURCES OF ADVICE AND INFORMATION
Respondents were asked from where they got their information about health and safety
currently.
44% relied on health and safety consultants, 38% on the HSE central resource, 31% on Croner,
26% on the HSE Inspector and 20% from IOSH (Institution of Occupational Safety & Health).
Fewer than 15% used any other source (see chart 17). The relevant trade and professional
associations, e.g. CITB (Construction Industry Training Body), largely dominated the other
sources of information.
Chart 17
Current sources of information
50
45
40
35
%

r
e
s
p
o
n
d
e
n
t
s

30
25
20
15
10
5
0
Health and HSE Central Croner Other, HSE IOSH Internet, at RoSPA Local Local Federation of None of them
safety Resource specified Inspector sites other Authority Enterprise Small
consultants than those Inspector Businesses
relating
above
33
3.8.1 Preferred information type
Respondents claimed to prefer paper-based information (75%), followed by the Internet (46%),
attending conferences (33%), personal visits (34%) and videos (24%), as shown in chart 18.
Chart 18
Preferred information type
0
10
20
30
40
50
60
70
80
%

r
e
s
p
o
n
d
e
n
t
s

Paper-based Internet Attending Personal visit Videos Telephone Don't know Audiotapes
conferences
People using Trade Associations, RoSPA and IOSH were more likely to prefer internet-based
information sources (74%+). People who were using their local enterprise agency, the HSE
central resource and the FSB were more likely to prefer paper-based information (85%, 82% &
85% respectively). People using IOSH and RoSPA appeared more likely to use conferences
(58% & 53%) & videos (40% & 42%) than others. A similar pattern can be seen for newly
established firms, see chart D2 in Appendix D.
Large organisations preferred Internet-based information, compared to smaller organisations
(80% vs 28% small organisations).
Across all the sectors the results were broadly similar, although those in the agriculture /
forestry sectors appeared less likely to wish to gain information through the Internet whilst both
agriculture / forestry and transport were less likely to attend conferences (see Appendix F, chart
F5.
3.8.2 Newly-established Firms
Businesses that were established less than five years ago were asked where they first went to
seek information about health and safety. They were most likely to go to health and safety
consultants (34%) and the HSE (32%), followed by Croner (20%), as shown in chart D2,
Appendix D.
The primary frustrations and barriers encountered when respondents first considered
implementing health and safety systems were the time required (36%), costs (30%), lack of
34
knowledge / skills in the organisation (27%) and lack of information / guidance (25%). A third
reported no frustrations.
Table 14
Initial frustrations and barriers
Col
Cases Response %
Frustrations Time required 52 36.4%
None 46 32.2%
Costs 43 30.1%
Lack of knowledge/skills in your organisation 39 27.3%
Lack of information/guidance 37 25.9%
Other, please specify: 10 7.0%
Lack of support from HSE/Local Authority Inspector 7 4.9%
Total 143 163.6%
The other frustrations and barriers included culture, inability to employ additional staff,
competitors non-compliance, unaware of new regulations, existing systems and the language
used.
Respondents in businesses that were established less than five years ago were asked what
additional advice / information would have been useful in these early stages. Their responses
were wide-ranging:
A named local area contact;
Central sources of information;
Clarity of what exactly is required (i.e. the core information and not the opinion of someone
with a vested interest);
Copies of generic safe systems of work when working with machinery / dust / electricity
etc.;
General information;
Health and safety updates;
HSE / Local Authority to issue health and safety information to all companies on what is
required;
Information on First Aid courses;
Information on landlord responsibilities;
Knowing where to go for information and helpful advice;
Legal responsibilities - an easy guide;
More detailed structure, better implementation of BSI 8500;
More visits from HSE to advise;
None - there was plenty of good advice and information available;
Paper or on-line annotated checklists of generic actions for new business premises or
specialist industries or functions;
35
Personal visit & information booklet;
Practical applications for small companies (less than 5 employees);
Templates for the implementation of management systems and controls;
Use of health and safety mentor;
Videos, advice from local companies such as ourselves who have already implemented
changes.
36
4. FINDINGS SITE VISITS
4.1 VALIDATION OF INFORMATION
The first objective of the site visits was to validate the information collected during the postal
survey. On the whole it was found that the information reported in the postal questionnaires
was accurate. As is to be expected, some circumstances had changed in the period of time
between completion of the questionnaire and when the site visit took place. These changes
included increases / decreases in the number of staff employed, an increase in turnover, changes
in outcomes of health and safety effects, changes in the organisations main hazards, increases
in costs incurred, etc. The site visits also allowed for the collation of further information and
clarification of the information reported in the questionnaire.
4.2 SUMMARY OF VALIDATION SECTION
The validation of information provided in the postal survey, through analysis of the site visits, is
summarised as follows:
The postal survey is considered to be a reasonably accurate reflection of the costs of
compliance and associated actions.
Yearly expenditure may be underestimated due to failure of some organisations to include
costs of health and safety personnel.
There were some inaccuracies in reporting the size of the organisation, although it was
believed that this would even out.
Cost comparisons are reported as cost per employee meaning that incorrectly reported
size would not have an effect on the findings.
The postal survey is considered to be an accurate reflection of the health and safety systems
in place, as well as in relation to what these systems comprise.
Motivating factors reported in the postal survey were found to be an accurate reflection.
Opinions regarding whether or not costs and benefits had outweighed one another also
appeared to largely reflect information provided in the postal survey.
It was felt that the postal survey was an accurate reflection of accident numbers, as those
site visits that omitted to include accident numbers were those that classified them
differently and this was the minority.
The postal survey is considered to be a reasonably accurate reflection of the actions taken
on each of the specific regulations.
37
4.3 COSTS OF COMPLIANCE
For those 30 organisations visited, the costs provided were generally in agreement to those
given in the questionnaire. The majority of the organisations visited stated that the larger
proportion of their spend on health and safety was incurred proactively, in order to prevent
accidents / incidents. Only a small proportion stated that the majority of their yearly health and
safety expenditure was spent reactively, as a consequence of accidents having occurred. The
costs of compliance for the organisations visited are described according to size.
4.3.1 Cost Ranges and Main Expenditures
Cost Ranges
In considering the organisational annual estimates of health and safety spend, costs per
employee ranged from 21 to 550 for the small organisations. Overall reported yearly costs, as
a total for the whole organisation, ranged from 500 to 5,500. The estimations of annual
health and safety spend, as provided by the medium organisations visited, ranged from
approximately 10 to 625 per employee. Overall reported annual health and safety costs, at a
total for the whole organisation, ranged from 1,000 to 60,000. The estimations of annual
health and safety spend, as provided by the large organisations visited, ranged from 20 to 300
per employee. Overall reported annual health and safety costs, as a total for the organisation,
ranged from 10,000 to 1.1 million.
Main Expenditures
The main expenditures across the small organisations generally comprised costs of employee
time, training of personnel, procurement of equipment, health and safety consultant fees, and
provision of PPE. Across the medium organisations visited, the main expenditures generally
comprised of training, equipment, employee / management time, the cost of employing a
designated health and safety person and provision of PPE. Within the large organisations
visited, main expenditures mainly comprised of training, procurement of equipment, employee /
management time, the cost of employing a designated health and safety person, implementing
control measures, and the cost of health and safety software packages.
Main expenditures were therefore quite similar across categories of size. The main differences
were that the medium and large organisations included the cost of employing a designated
health and safety person as a main expenditure, whereas the small organisations did not. Large
organisations also included implementing control measures and procurement of health and
safety software packages as main expenditures, whereas the small and medium organisations
visited did not.
38
Overall
Organisations were asked to list their 3 main health and safety expenditures. Table 15 shows
the main expenditures of the 30 organisations visited.
Table 15
Main aspects of health and safety expenditure across the 30 organisations visited
Training Equipment Employee /
management
time
Internal H&S
persons
salary
H&S
consultant
fees
Provision
of PPE
Implementing
control
measures
Staffing H&S
software /
packages
Site
upgrades
Small 5* 3 5 0 2 2 0 0 0 0
Medium 13 7 6 5 3 3 0 1 0 1
Large 4 3 2 2 1 0 2 1 2 0
Totals 22 13 13 7 6 5 2 2 2 1
*E.g. 5 of the 30 organisations visited listed training as one of their 3 main health and safety expenditures.
In response to the question regarding the three aspects of health and safety that organisations
spent the most on in 2001, the results of the postal survey showed that the aspects raised most
often, across all sectors, included:
Training;
Personal protective clothing and equipment (PPE);
Safety equipment, including modifications to machinery;
Consultancy.
On comparison, the main expenditures reported during the site visits across the 3 sizes of
organisations were training, equipment and employee time. The designated health and safety
persons wage, consultant fees and provision of PPE were also frequently reported. The
findings of the site visits therefore, again, largely validate the findings of the postal survey.
4.3.2 Costs vs. Benefits
Of the 30 organisations visited, 60% reported that the benefits of implementing health and
safety systems had outweighed the costs. 24% reported that the costs and benefits had broken
even and 10% of organisations said that it was too early to say. Just 3% stated that the costs
outweighed the benefits and another 3% said they did not know. The postal survey also
observed that the majority of organisations believed that the costs of implementing health and
safety systems were outweighed by the benefits.
The majority of organisations, within each category of size, reported that the benefits of
implementing health and safety systems had outweighed the costs. However, the small and
large organisations were more likely to report this (72% and 75%, respectively) than were the
medium organisations (47%). The postal survey also found that large organisations were more
likely to think the benefits outweighed the costs, than were the small and medium organisations.
However, the survey differed from the site visits in that the percentage of employers who felt
that the benefits had outweighed the costs was larger amongst the medium organisations than it
was amongst the small organisations.
39
Small
72% of small organisations visited reported that the benefits outweighed the costs of
implementing health and safety systems.
14% of small organisations visited said they did not know if the costs had outweighed the
benefits (or vice versa).
14% stated that they thought the costs and benefits had broken even.
One small organisation reported that the performance / productivity of employees had decreased
as a result of extra safety measures that need to be taken and heeded.
Medium
47% of medium organisations visited stated that the benefits of implementing the health and
safety systems had outweighed the costs.
The medium organisations visited were more likely to say that the costs and benefits had broken
even (40%) than were the large or small organisations.
13% stated that they thought it was too early to say.
Large
75% of large organisations visited stated that the benefits of implementing health and safety
systems had outweighed the costs.
Conversely, 12.5% of large organisations visited stated the costs of implementing the health and
safety systems had outweighed the benefits, and another 12.5% stated that they thought it was
too early to say.
The large organisation that perceived the costs to have outweighed the benefits stated that this
was largely because it thought it impossible to calculate the reputational risk associated with a
poor health and safety record.
4.3.3 Benefits
The most common benefits reported were similar across the 3 sizes of organisation and the 5
sectors. Only the construction sector displayed a benefit that was slightly more sector specific
and this was in relation to enhanced company profile / reputation. Although other sectors
reported the benefit of enhanced company profile, the organisations in the construction sector
reported that health and safety systems, up to a certain standard, ensure that the company can
compete in the market place, enabling them to secure contracts and new clients. This was
particularly linked to the requirements under the CDM Regulations, whereby they will not be
included on tender lists if they do not have a minimal health and safety standard / performance
and cannot commence work until they have produced / contributed to the project health and
safety plan.
The most commonly reported benefits across all sizes and sectors for those organisations
visited, starting with the most frequently reported benefit, included:
Increased staff morale through raised health and safety awareness and a better
understanding of the risks;
Enhanced company reputation;
Safer working environment;
Increased performance / productivity;
40
Reduced sickness absence;
Decrease in the time lost through accidents;
Decrease in the number of reportable accidents;
Managements peace of mind, in terms of being compliant and up to date with the
regulations;
Improved working practices and procedures;
Protection for the organisation against litigation;
Reduced insurance premiums.
The main benefits reported during the site visits again largely supported those observed by the
postal survey, which found that increased staff morale, a decrease in the time lost through
accidents, increased performance / productivity, decreased damage and waste, and reduced
sickness absence, were the most commonly reported benefits.
4.4 FACTORS MOTIVATING HEALTH AND SAFETY
The postal survey found that the three main reasons, prompting the development of formal
health and safety systems, were legal obligation (68%), followed by health and safety publicity
(52%) and as part of other systems that were being developed in the organisation, such as new
quality systems (39%). A quarter was prompted by insurance costs (27%) and experience of
accidents within the organisation (24%).
4.4.1 Size
Small
For the site visits, of the 6 small organisations that had formal health and safety management
systems in place, the main reasons, prompting this development, were legal obligation (67%)
and health and safety publicity (67%), followed by insurance costs (50%) and as part of other
systems that were being developed in the organisation, such as a quality system (50%). 33%
also gave supplier / customer / client pressure and one of their three main reasons and visits by a
HSE / LA inspector was another reason gave by 33% of these small organisations. Other
mentions included the organisation having reached a particular size, accident prevention, trade
groups / federations, to improve the working environment.
The site visits therefore supported the postal surveys findings that small organisations appeared
more likely to respond to publicity (65%).
Medium
Of the 15 medium organisations visited, the main reason given for prompting the development
of health and safety systems was legal obligation (87%). This was followed by the system
being developed as part of other systems being developed in the organisation, such as a quality
system (53%), supplier / customer / client pressure (47%), and insurance costs (40%). A review
of organisational structure / systems was a reason given by 33% of medium organisations
visited, with other reasons being the organisation reached a particular size (27%), experience of
previous accidents within the organisation (27%), and health and safety publicity (27%).
Other prompts reported included growing litigation concerns and the publicity surrounding this;
to demonstrated management commitment and placate a disruptive workforce; to improve the
documentation of the systems already in place; and for the safety of employees and enhanced
company profile.
41
Large
Of the 8 large organisations visited, 100% of organisations reported one of their main reasons
for introducing health and safety systems was due to a legal obligation. 50% reported
experience of accidents within the organisation as a reason, with the next most reported reasons
being the organisation having reached a particular size (33%), supplier / customer / client
pressure (33%), and insurance costs (33%). A review of organisational structure / systems was
reported by 25% of large organisations, as was a visit by a HSE / LA inspector (25%). Other
prompts included union pressure and trade groups / federation.
The large organisations visited also reported other prompts, which included:
Union pressure;
Trade groups / federations;
Change in culture of the organisation, due to a change in client i.e. a procurement issue;
Removal of Crown Immunity, i.e. the organisation had to comply just as any organisation
would;
Specific incident e.g. a fire assessment conducted by external authorities;
Risk Management Corporate Governance as a result of the organisation formerly being
one division of a larger organisation, but then becoming a separate organisation.
The postal survey observed that large organisations were more likely to respond to the
introduction of other systems (42%), overall system reviews (23%), and experience of accidents
(47%). The sites visited did not report the introduction of other systems as one of their 3 main
prompts, rather legal obligation was stated by all as being one of the main reasons. Experience
of accidents was the second most frequently reported reason given by the large organisation and
was reported more by the large organisations than the small organisations, which supports the
findings of the postal survey.
4.4.2 Sector
Whilst the postal survey observed that the primary reasons, for developing health and safety
systems were common across sectors, a few observations across sector were made. One of
these observations, that appears to have been supported by the site visits, was that supplier /
customer / client pressure had more effect in the construction sector (25% vs. maximum 10% in
the other sectors).
The organisations visited within the construction sector all reported pressure from their
contractors / clients / industry to have certain health and safety standards in place to be able to
procure and carry out the work. For example, employees may have to be trained in a particular
set of qualifications to be able to do the work, or the organisation may need to meet a certain set
of standards. One organisation also specified that compliance was needed with the CDM
regulations, otherwise the organisation cannot commence work on a project until the health and
safety plan is in place.
Support for the other primary reasons made by the postal survey, across sectors, was not noted
across the site visits.
On summarising the primary reasons given by the organisations visited, it was also noted that
the organisations within the Health Services sector also have to adhere to the Care Standards
Act, which requires healthcare organisations to be up to a certain standard with health and
safety.
42
4.5 OTHER FINDINGS
The results from the site visits largely reflect those from the postal survey, any differences are
highlighted below:
The postal survey is considered to be a reasonably accurate reflection of the costs of compliance
and associated actions. However, costs reported for specific regulations are thought to be more
accurate than general health and safety expenditure due to the failure of some organisations to
include the cost of employing health and safety personnel.
Small organisations were more likely to have had accidents (in terms of accidents per employee)
than medium and large organisations. The postal survey found a greater rate of accidents in the
medium size organisations.
Costs per employee were comparable but the upper ranges for small and medium-sized
organisations were almost double that of those for the large organisations.
A greater proportion of organisations in the site visits reported that the benefits outweighed the
costs compared with the postal survey. The percentage of organisations reporting that benefits
outweighed the costs was lowest in medium sized organisations.
The factors motivating health and safety activity were largely the same as the postal survey
although fewer large organisations reported introducing health and safety systems as part of a
review of other systems within the organisation.
For newly-established organisations, when asked what advice they would give to other new
organisations they suggested: implementing health and safety systems as soon as possible and
developing these with the business; joining local organisations and networks; and, seeking to
gain advice and guidance as much as possible.
For further details of the postal survey validation and supporting information regarding the site
visits, please refer to Appendix H. Appendix H provides more detailed information on the site
visits regarding health and safety management systems; accidents; specific regulations; future
costs; sources of advice and information; and newly established firms. Full versions of the case
studies from each of the 30 organisations visited can also be viewed in Appendix I.
43
44
5. GENERAL DISCUSSION AND RECOMMENDATIONS
5.1 DISCUSSION
5.1.1 What motivates organisations to take action?
The main motivators to take action were legal obligation, health and safety publicity and in
response to reviews of existing systems. Smaller organisations were more likely to be
motivated by publicity (65%) suggesting that they may have taken action earlier if they had
been aware of the issues. The publicity that they have been exposed to has therefore been
effective in promoting action, further publicity may be required to prompt other SMEs to take
similar action. When newly established organisations were asked what frustrations they faced
when setting up systems, other than time and costs, many reported lack of knowledge (27%) and
information (26%). When asked what information would have been useful, the general themes
were around practical information / tools to identify what is required to set up systems,
indicating the kinds of publicity that might be most appropriate for SMEs / newly established
businesses.
Larger organisations were more likely to be motivated by legal obligations and experience of
accidents. Therefore, promotion of the benefits of a more proactive approach may be required
for larger organisations. This may also suggest that larger organisations are more concerned
about the threat of legal action than SMEs.
A significant proportion of organisations reported a review of other systems as a prompt to
establish health and safety systems. There maybe some scope for working more closely with
other authorities (e.g. BSI, ISO, Environment Agency) in order to encourage organisations to
consider health and safety when they are reviewing their existing systems, and advice on how
systems can be integrated to minimise the effort required.
There were also some themes specific to particular sectors. For example, the construction sector
was more likely to be prompted by suppliers / clients. This may be as a result of the
requirements of all parties under the CDM Regulations. Similarly, the site visits identified that
requirements for health and safety under the Care Standards Act were a motivating factor for
organisations in the health sector. It appears that the agriculture sector was concerned about
visits from inspectors and this may be related to the increased emphasis placed on this sector in
Revitalising Health and Safety (Government and HSC, 2000). Insurance costs were an
incentive for the transport and manufacturing sectors.
5.1.2 What are the major activities that organisations undertake to comply?
All organisations were more likely to have a written health and safety policy (92%), an accident
reporting system (94%), a designated health and safety role/person (90%) and documented risk
assessments (88%) than performance targets and measures (34% and 39% respectively).
However, those that had been in operation for longer were more likely to have targets and
measures in place, perhaps suggesting that it is not until systems have been in place for some
time that organisations look to set performance targets and measure their health and safety
performance. It may be argued that there is relatively less information and advice available on
monitoring and review, than on implementation.
SMEs were less likely to have formal health and safety systems in place, as were those in the
agriculture sector (who make up over a third of all small organisations who responded). Also,
45
for SMEs and Agriculture / Forestry, those that had systems in place reported less
comprehensive systems.
The majority of small and large organisations managed their health and safety in-house.
However, large organisations were more likely to involve employees in the form of health and
safety committees or groups etc. Medium sized organisations were much more likely to use
external consultants to assist them in meeting their requirements.
5.1.3 Do SMEs have more accidents than large organisations?
It appears that medium sized organisations experienced more less than one day injuries than
small or large organisations. Large organisations of greater than 1000 employees had
significantly fewer (one quarter) less than one day injuries than organisations with less than
1000 employees. The proportion of 1 to 3 day injuries decreased slightly with the size of
organisation, as did 4 or more day injuries. Non fatal major injuries were more evenly spread
across different sizes of organisations.
5.1.4 Are costs of action greater for SMEs compared with large organisations?
firms are often at a competitive disadvantage compared with larger firms because of the cost
and time involved in regulatory compliance. This was a factor that was particularly pointed out
by four of the organisations visited in this project (H F Electrical, OPEX, Peal Engineering, and
Magees). They were all medium-sized organisations (2 construction, 1 manufacturing, and 1
agriculture) who stated a concern that there was a danger of them being at a competitive
disadvantage, due to the compliance costs incurred.
However, in this study, the overall reported spend on health and safety increased slightly with
size of the organisation. This is confounded by the fact that some organisations failed to include
some expenditure in this calculation, particularly the cost of employing health and safety
personnel within the organisation. For this reason the reported costs for particular pieces of
regulation are considered to be more accurate, in terms of actual spend. The most noticeable
trend was that very large organisations of 5000+ employees spent considerably less per
employee than those with 5000 employees or less. For example small firms spend 7 times more
per employee and organisations with between 1000 4999 employees spend 15 times more per
employee than very large firms (+5000 employees) on the Management of Health and Safety at
Work Regulations. Therefore, it appears to be true that the costs of compliance are
disproportionate for very large organisations than for smaller organisations. Whilst this is true
of all 5 regulations investigated, there is considerable variation across regulations in terms of at
what size of organisation this disproportionate effect occured.
For the Management of Health and Safety at Work Regulations the actual spend per employee
was comparable across organisations with between 1 and 1000 employees, and almost double
for organisations with between 1000 and 4999 employees. Small organisations spend the most
per employee on the Control of Pesticides Regulations (1986).
For the COSHH Regulations, organisations with between 1000 and 4999 employees spent the
most per employee, almost double that of organisations with less than 1000 employees and
almost 10 times more than organisations with 5000+ employees.
The greatest impact on smaller organisations can be seen in the Manual Handling Regulations.
Although there are a few organisations that have reported significantly high expenditure in
particular categories, even for the other categories the figures are greater for small firms. For
example, small firms spent significantly more per employee on training / employment of
46
specialists, risk assessment, work environment, new equipment, training and information, and
provision of occupational health. Costs of compliance were also disproportionate for small
organisations when implementing the Noise at Work Regulations. Smaller organisations spent
considerably more per employee on provision of PPE, creation of hearing protection zones, risk
assessment and maintenance and review of controls.
Costs of compliance were clearly disproportionate for small firms when implementing the
Manual Handling Regulations and the Noise at Work Regulations. This will be influenced by:
the economies of scale when purchasing PPE, equipment, and training; the ability of larger
organisations to adopt generic risk assessment processes, where appropriate; and, the increased
likelihood that larger organisations will have an in-house specialist that can provide training on
these issues.
5.1.5 Are costs of action greater for some sectors compared with others?
Whilst it is difficult to compare the costs of compliance across sectors, due to the variation in
sample sizes and proportions of sizes of organisations in each sector, the following conclusions
can be drawn.
Those in the agriculture sector had the least expenditure, mainly because the majority are SMEs
who generally reported having less comprehensive health and safety systems in place. The
manufacturing and construction sectors had the greatest expenditure. Manufacturing, in
particular, had a much higher expenditure for control measures, with some reports of individual
companies spending significant amounts on plant renewal, process changes etc. The health
services sector and the transport sector had similar levels of expenditure. Almost one fifth of
transport organisations did not know what their expenditure was, which suggests that their
reported total expenditure may be somewhat inaccurate.
Agriculture and the health services spent considerably less than the other sectors on the COSHH
Regulations, although the health services sector spent the most on health surveillance in relation
to this regulation.
With regard to the Manual Handling Operations Regulations, health and construction spent a
considerable amount more on changing work practices. For example, introducing new
procedures for manual handling and procurement of materials.
5.1.6 Are the benefits of action greater for large organisations than SMEs?
The main benefits reported during the site visits again largely supported those observed by the
postal survey including: increased staff morale, a decrease in the time lost through accidents,
increased performance / productivity, decreased damage and waste, and reduced sickness
absence. The most common benefits reported were similar across the three sizes of organisation.
5.1.7 Are the benefits different across sectors?
Only the construction sector displayed a benefit that was slightly more sector specific and this
was in relation to enhanced company profile / reputation, particularly relevant in tendering for
work to demonstrate capability to meet requirements under the CDM Regulations.
5.1.8 Do the benefits of implementing health and safety regulations outweigh
the costs?
a specific range of potential outcomes (e.g. performance / productivity, staff morale, sickness
absence, time lost through accidents, etc.). When reporting on these potential outcomes, over
half of all organisations reported that their actions had not led to any effect (i.e. neither
positively nor negatively).
47
Large organisations were more likely to report that the benefits outweigh the costs. This may be
due to the fact that SMEs are less likely to have experienced an accident and therefore do not
realise the costs associated with not taking action. SMEs were also less likely to have
performance measures and targets in place and therefore may be relying on their perception of
the benefits and costs rather than a more calculated objective view. In the site visits, a
comparable number of small and large organisations reported that the benefits outweigh the
costs. This was greater than for medium sized organisations. Medium sized organisations had
however taken more action than small organisations and therefore may have greater expenditure
for limited additional benefit (in terms of experience and therefore impact on accidents).
Construction and manufacturing were most likely to report specific benefits but were also more
likely to have performance measures and targets in place to make this judgement. However,
construction also reported additional benefits compared with other sectors. Construction
companies reported that health and safety systems are crucial in the commissioning of work and
therefore the benefits to this sector may be far greater than for others.
5.2 RECOMMENDATIONS
5.2.1 Targeting organisations
Large organisations were much more likely to be motivated by legal obligation. The site visits
confirmed that this was in terms of claims from individual employees rather than from action
taken by a visiting inspector. Those organisations in the Agriculture sector were however, more
likely to be motivated by threat of a visit from an inspector, irrespective of the size of the
organisation.
Many organisations, particularly Medium and Large sized organisations reported implementing
health and safety systems as part of an overall review / formalisation of existing systems. There
may therefore be some scope to target organisations with information through other professional
bodies / authorities. For example through BSI, ISO, Investors in People.
Generally, SMEs were more likely to be motivated by publicity, suggesting that lack of action is
a result of lack of awareness.
One of the recommendations from the site visits (see Appendix D) was that more advanced
information regarding changes in legislation / regulations would be helpful / useful. It was
reported in Chittenden, Kauser and Poutziouris (2000) that a survey by the Forum of Private
Business (FPB, 2000) indicated that the majority of small firms were concerned about the
timing of new regulations. This indicated that SMEs are less aware of up and coming
regulations, despite HSEs efforts to provide advanced warning of new regulations.
A quarter of all organisations reported that they had considered implementing formal systems
within the first five years of operation. This figure is however likely to be conservative as the
overall levels of activity have increased since 1990 and this finding refers to all organisations,
including those established many years before this. It is likely that many new businesses will be
linked to a regional business start-up scheme and will retain contact with this scheme over the
first few years. Therefore it is recommended that provision of information / training through
these schemes be investigated as a means of targeting SMEs / newly established firms and
keeping them informed of planned new regulations.
It appears, from the site visits, that there are still considerable differences, across regions,
regarding the way in which HSE inspectors are perceived and their role. The relationship
between employers and inspectors appears to work more effectively when the inspector is
perceived as a provider of advice and support rather than a policing body.
48
Consistent with previous studies (e.g. Lancaster et al, 2001), SMEs preferred paper-based
format for sources of information. Larger organisations preferred the Internet and conferences /
training courses.
5.2.2 Nature of advice
As consistent with previous studies (e.g. Lancaster et al, 2001), SMEs appear to be confused as
to what regulations were relevant to them. Medium sized organisations relied heavily on
external consultants to point them in the right direction.
The fact that relatively few organisations have performance targets or performance measures
means that this survey has relied heavily on the respondents perception of whether the benefits
of compliance outweigh the costs. It is therefore reasonable to assume that organisations fail to
evaluate many of the activities that they carryout and therefore could be spending significant
sums on activities that are of little benefit in terms of improving health and safety performance.
For example, many organisations spend a considerable sum on training and provision of PPE.
Whilst alternative awareness provision and controls are available to organisations, a lack of
evaluation of the impact of these activities means that they may be unknowingly inappropriate /
ineffective.
It is observed by the researchers that little of the advice provided to employers gives details of
how to establish performance criteria or measure performance. This is also the case for methods
of evaluating the impact of specific interventions and assessing their contribution to improved
performance. It is therefore recommended that more specific advice and guidance be developed
to raise awareness of the importance of target setting and evaluation in relation to health and
safety management.
49
50
6. REFERENCES
Beale, H.B.R. & Lin, K. (1998). Impacts of Federal Regulations, Paperwork, and Tax
Requirements on Small Business. A Report prepared for the U.S. SBA Microeconomic
Applications Inc. Washington D.C. September.
BRTF. (2000). The Better Regulation Guide and Regulatory Impact Assessment. The Cabinet
Office, London.
Chittenden, Francis, Prof.; Kauser, Saleema, Dr.; & Poutziouris, Panikkos, Dr. Manchester
Business School, The University of Manchester. (2000). Regulatory Burdens of Small
Business: A Literature Review. A research project funded by the Small Business Service and
supported by the Leverhulme Trust.
ENSR. (1995). Administrative Burdens in the European Observatory for SMEs Third Annual
Report.
FPB. (2000). 58
th
Quarterly Survey of Private Business. The Forum of Private Business
Quarterly 2.
Inland Revenue. (1998). The Tax Compliance Costs for Employers of PAYE and National
Insurance in 1995-96. The Centre for Fiscal studies, University of Bath.
Lancaster, Rebecca; Jacobsen Maher, Catherine; & Alder, Andrew. (2001). Second Evaluation
of the Manual Handling Operations Regulations (1992) and Guidance. HSE Contract Research
Report 346 / 2001. HSE Books, Sudbury.
Revitalising Health and Safety: Strategy Statement (2000). Government and Health and Safety
Commission. Department of the Environment, Transport and the Regions: Free Literature
Service, P O Box 236, Wetherby.
Small Business Research Trust. (2000). NatWest SBRT Quarterly Survey of Small Businesses
in Britain. Vol. 16, No. 3, SBRT.
Wright, Michael; Lancaster, Rebecca; Jacobsen Maher, Catherine; Talwalkar, Medha; &
Woolmington, Tony. (1999) Evaluation of the Good Health is Good Business Campaign. HSE
Contract Research Report 272 / 2000. HSE Books, Sudbury
51
Appendices
52
Appendix A
Postal Survey Questionnaire
53
COSTS OF COMPLIANCE WITH HEALTH AND SAFETY REGULATIONS
Background
Entec is one of the UKs largest health, safety and environmental consultancies. We
have been commissioned by the Health and Safety Executive (HSE) to conduct an
investigation into the costs of compliance with health and safety regulations.
Woodholmes.ksa is managing the survey on behalf of Entec. The HSE is interested
in establishing:
The costs of compliance, whether this varies proportionally between sectors by
size of organisation
Also, the circumstances surrounding the original implementation of health and
safety systems, the problems faced, etc.
In order to conduct this independent survey, we are asking organisations of different
types and sizes to provide information. Your details have been selected at random
from a company register. Any information that you provide will be treated with the
strictest confidence, only summary information across this large number of
organisations will be reported to HSE.
This is your opportunity to provide real information to HSE on costs of
compliance and present any problems you have faced.
Instructions
We would be grateful if you could complete the following questionnaire, your
response is equally valuable to us if you have taken action in relation to health and
safety or not.
If you are an organisation with several independent sites, you are asked to complete
this for one of these sites. However, if your sites are managed as one organisation
and it is easier to respond for your whole organisation, then you may do so. In this
case, please be consistent in you response.
Complete the questionnaire by ticking the appropriate boxes for each question, e.g.:
Yes
4
No
Next to some responses you will see this symbol: +, if your response is followed by
this symbol, move forward to the question indicated.
The questionnaire is divided into 2 sections:
Section A asks for general information about the nature of your business, hazards,
and general action taken.
Section B asks about any action you have taken in relation to specific regulations.
Please return this questionnaire in the reply-paid envelope provided or post to:
Woodholmes KSA, 15 Lansdowne Terrace, Newcastle-upon-Tyne, NE3 1HN
54
SECTION A
GENERAL INFORMATION
What is your main sector of activity? Please tick one only.
1
Go to question A1.1
Construction
2
Go to question A1.2
Health Services
3
Go to question A1.3
Manufacturing
4
Go to question A1.4
Transport
5
Go to question A1.5
BACKGROUND
A1.1 What area of the agriculture and forestry sector does your organisation operate
in? Tick one box only.
Agriculture production
crops
1
Agriculture
livestock
specialities
production
and animal

2
Forestry
3 Other, please specify: 4
Now please go to Question A2
A1.2 What area of the construction sector does your organisation operate in? Tick
one box only.
Building construction and
operative builders
general contractors
5
Heavy construction other than
building construction
contractors
6
Construction special
trade contractors
55
A1.3 What area of the health services sector does your organisation operate in? Tick
one box only.
Offices of health
practitioners
9
Nursing homes
10
Hospitals
11
Medical and dental laboratories
12
Other, please specify: 13
A1.4 What area of the manufacturing sector does your organisation operate in? Tick
one box only.
Food and kindred
products
14
Tobacco products
15
Textile mill products
16
Apparel and other finished
products made from fabric and
similar materials
17
Lumber and wood
products
18
Furniture and fixtures
19
Paper and allied products
20
Printing, publishing, and allied
products
21
Chemicals and allied
products
22
Petroleum refining and related
industries
23
Rubber and
miscellaneous plastic
products
24
Leather and leather products
25
Transportation equipment
26
Primary metal industries
27
Electronic and other
electrical equipment and
components, except
computer equipment
28
Measuring, analysing and
controlling instruments;
photographic med and optical
goods
29
Fabricated metal
products, except
machinery and
transportation equipment
30
Industrial and commercial
machinery and computer
equipment
31
Stone, clay, glass, and
concrete product
32
Miscellaneous manufacturing
industries
33
56
A1.5 What area of the transport and vehicle repair sector does your organisation
operate in? Tick one box only.
Local and
transit and
highway
transportation
suburban
interurban
passenger
35
Motor freight transportation and
warehousing
36
Vehicle repair
Now please go to Question A2 below.
A2 Approximately how many employees are there in your organisation / and at your
site, if different? Please write in the total figure and then a breakdown for full
time and part time employees, if applicable:
Organisation Site
Total
Full time
Part time
A3 Has this number changed significantly, at your site, in the last 3 years
(more or less than 10%)? Please write in the % change, or 0 for no change.
No, still the same
Increased by
%
Decreased by
%
A4 Approximately how long has your site been in operation? Please write in:
years
A5 What was your organisations approximate annual turnover for the last full
financial year? Please provide a response for your site if this is a multi-site
operation.
57
NATURE OF HAZARDS
A6 Which of the following hazards are of particular concern in your organisation?
Please provide a response for your site if this is a multi-site operation. Tick all the
boxes relevant to your organisation below.
Chemicals
1
Confined spaces
2
Display Screen equipment
3
Dust
4
Ejection of material
5
Electricity
6
Extreme temperatures
7
Falling temperatures
8
Fire
9
Fumes
10
Manual handling
11
Moving parts of machinery
12
Noise
13
Poor Lighting
14
Pressure systems
15
Psychosocial hazards
16
Slipping/ tripping hazards
17
Work at height
18
Vehicles / Transportation
19
Hand / Arm Vibration
20
Whole Body Vibration
21
Other, please specify:
22
A7 Do you record work related accidents and / or ill-health?
Accidents
1
Ill health
2
If you do NOT record this data please go to question A9
A8 How accurate do you feel these records are?
accidents ill health
Very accurate
1 5
Quite accurate
2 6
Not very accurate
3 7
Not at all accurate
4 8
58
INTRODUCING HEALTH AND SAFETY
A9 Are formal health and safety management systems in place at your site? Please
tick the appropriate box:
Yes
+ if yes go to
A11
No
+ if no go to
A10
A10 We are interested to know why formal health and safety management systems
have NOT been implemented in your organisation. Please tick all boxes that apply
in the table below:
Cost implications
1
Lack of knowledge / information
2
Not priority
3
Time restrictions
4
Now please proceed to Question A15 (unless you answered yes to question A9, in
which case you should continue completing the remainder of Section A.)
A11 We are interested to know what your health and safety systems include. Please
tick all boxes that apply in the table below:
A designated health and safety person / role
1
An Accident Reporting system
2
Documented risk assessments
3
Performance measurement
4
Performance targets / objectives
5
Written Health and Safety policy
6
A12 In what year did you first look at / consider implementing health and safety
systems? Please write in:
A13 How long had your organisation been operating before you made the decision to
implement these systems? Please write in to the nearest year/month:
59
A14 What were the three main reasons for developing your health and safety
management systems? Please tick all boxes that apply.
Experience of accidents within the organisation
1
Health and Safety publicity
2
In conjunction with other systems that were being developed in the
3
organisation e.g. new quality system etc.
Insurance costs
4
Legal obligation
5
Supplier / customer / client pressure
6
There was a review of organisational structure / systems
7
Trade groups / federations
8
Union pressure
9
You were visited by a HSE Local Authority Inspector
10
Your organisation reached a particular size
11
60
ACCIDENTS AND ILL HEALTH
A15 We are interested to know how many accidents have occurred both in 2001
and also as a total in the last 5 years. Please provide a response for your site if this
is a multi-site operation. Please complete the table below:
Severity of injury
Number of accidents
In 2001 In the last
5 years
Less than 1 day off work
1 to 3 days off work
4 or more days off work. Including, strains, sprains,
lacerations etc resulting in 4 or more days off work
(excluding major injuries)
Non fatal major injuries; including any fractures
(excluding fingers, toes or thumbs), dislocation of
knee hip or spine, any amputation, unconsciousness,
any injury requiring resuscitation, loss of sight, and
any injury requiring admittance to hospital for over 24
hours.
Fatal injuries
61
COMPLIANCE COSTS AND BENEFITS
A16 (a) Please estimate how much you spent on health and safety in the last 12
months (March 2001 March 2002). Please tick the box that applies to your
organisation, providing a response for your site if this is a multi-site operation.
When considering costs you should include consultancy or training fees,
employee time involved, capital and equipment costs, etc.:
Cost
Less than 100
1
101 - 500
2
501 - 1000
3
1001 - 5000
4
5001 - 10 000
5
10 000 50 000
6
More than 50 000
Please specify..
7
Dont Know
8
A16 (b) What three aspects of health and safety did you spend the most on in 2001?
Please write in:
1
2
3
A17 In your opinion, has the action taken affected any of the following in your
organisation / site, if it is a multi-site operation. Please tick one box for each
outcome that applies:
Increased No affect Decreased Too early to
Say
Dont
know
A Compensation claims
1 2 3 5 6
B Insurance premiums
7 8 9 10 11
C No. of staff employed
12 13 14 15 16
D Product damage / waste
17 18 19 20 21
e Performance / Productivity
of employees
22 23 24 25 26
F Sickness absence
27 28 29 30 31
g Staff morale
32 33 34 35 36
h Staff turnover
37 38 39 40 41
i Time lost through accidents
42 43 44 45 46
j Other, please specify

47 48 49 50 51
62
1
2
3
4
5
6
7
A18 On balance, in your organisation, have the: Please tick the box that applies:
Costs of implementing health and safety systems
1
outweighed the benefits
Benefits outweighed the costs
2
Costs and benefits broken even
3
Too early to say
4
Dont know
5
SOURCES OF ADVICE AND INFORMATION
A19 From what sources do you currently get your health and safety advice /
information? Please tick all boxes that apply in the table below:
Health and Safety consultants
1
Local Enterprise
2
RoSPA
3
Croner
4
IOSH
5
HSE central resource
6
HSE inspector
7
Local Authority inspector
8
Federation of Small Businesses
9
Internet, at sites other than those relating to
above. Please specify:
.
10
A20 What form of information / advice is most suitable for you? Please tick the
boxes that apply to your organisation. Please provide a response for your site
if this is a multi-site operation:
Internet

Paper-based

Attending conferences / seminars

Videos

Audiotapes

Telephone

Personal visit

63
A21 What additional advice / information would you find useful? Please write in
NEWLY-ESTABLISHED BUSINESSES
Please complete this section if your organisation has been established in the
last 5 years. If your organisation has been running for longer than 5 years,
please go straight to Section B.
A22 Where did you first seek advice and information on health and safety? Please
tick all boxes that apply in the table below:
HSE
1
Croner
2
IOSH
3
RoSPA
4
Health and Safety consultants
5
Local Enterprise
6
Federation of Small Businesses
7
Internet, at sites other than those relating to
above. Please specify:
.
8
A23 Were there any frustrations / barriers that you faced when you first considered
implementing health and safety systems? Please tick all boxes that apply in the
table below:
Lack of information / guidance
1
Lack of support from HSE inspector
2
Lack of knowledge / skills in
organisation
your
3
Time required
4
Costs
5
6
64
A24 What additional advice / information would have been useful in these early
stages: Please write in
Section B
Specific Regulations
Instructions
This section asks about action taken in response to particular regulations and the
costs associated with this. A selection of regulations have been chosen, some of
which may not apply to your organisation. The Provision and Use of Work
Equipment Regulations (PUWER) are not included as these are being evaluated
separately as part of another research project.
Please work through the section, if you have not taken any action in response to a
particular regulation you will be directed through the questionnaire to the next
appropriate question.
MANAGEMENT OF HEALTH AND SAFETY AT WORK
The management of Health and Safety at Work Regulations, require employers to
take general action to identify, assess, control and manage risks to health and safety
of employees and others and outline the responsibilities of employees in this
process. In addition, the revised regulations include specific requirements in relation
to new and expectant mothers, young persons and fire precaution.
M1 Have you taken any action in relation to the Management of Health and Safety at
Work Regulations?
Yes
1
No + if no go to P1
2
M2 Please specify the year that you began addressing these regulations.
65
M3 What did this action concern and what were the cost implications? Indicate the
cost using the categories below and provide an actual cost if you can. When
considering costs you should include consultancy or training fees, employee
time involved, capital and equipment costs etc.
1 Less than 100 5 Between 5001 10,000
2 Between 101 - 500 6 Between 10,001 50,000
3 Between 501 - 1000 7 More than 50,000
4 Between 1001 and 5000
Tick if
action
taken
What action taken / description Cost
category
(1 7)
Estimated
actual
cost
General risk assessments of risks to
health and safety of yourself (if a self
employed person), employees and / or
others in connection with your work.
1
Health and safety arrangements for
effective planning, organisation,
monitoring and reviewing preventive and
protective measures
2
Implementing control measures e.g. costs
of interventions such as capital costs
3
Health surveillance procedures
4
Health and safety assistance,
appointment of competent person(s) to
assist in meeting statutory requirements
for health and safety
5
Procedures for serious and imminent
danger and danger areas
Establishing appropriate contacts with
external services e.g. first aid,
emergency services and rescue work
6
Information and training for employees
on health and safety risks, controls,
arrangements and procedures,
responsibilities etc.
Information for others affected by your
undertaking.
7
Co-operation and co-ordination with other
employers with whom you share a
workplace
8
Other special arrangements in connection
with temporary workers, expectant and
new mothers and/or young persons
9
66
PESTICIDES
As you may be aware the Control of Pesticides Regulations require employers to take
general action to control and manage risks to health and safety of employees and others,
presented by the storage / selling / supply / use / aerial application of pesticides.
P1 Have you taken any action in relation to the Control of Pesticides Regulations?
Not
applicable
1
Yes
2
No
3
+if not applicable go to C1
+if no go to C1
P2 Please specify the year that you began addressing these regulations?
P3 What did this action concern and what were the cost implications? Indicate the cost on
the table below using the categories below and provide an actual cost if you can.
When considering costs you should include consultancy or training fees, employee
time involved, capital and equipment costs etc.
2 Between 101 - 500 6 Between 10,001 50,000
Tick
if
actio
n
taken
categor
y (1-7)
Estimate
d actual
cost
Information, instruction,
training and guidance to
employees
1
Measures taken to protect:
health of humans, creatures,
plants, environment, water .
2
Gaining certificates of
competence
3
Storage
4
Application controlled and
confined to intended target
5
Notifications of aerial
application and restrictions
observed
6
67
COSHH
As you may be aware the Control of Substances Hazardous to Health Regulations, require
employers to take general action to identify, assess, control and manage risks to health and
safety of employees and others, presented by substances, and outline the responsibilities of
employees in this process.
C1 Have you taken any action in relation to the COSHH Regulations?
Not
applicable
1
Yes
2
No
3
+if not applicable go to MH1
+if no go to MH1
C2 Please specify the year that you began addressing these regulations?
C3 What did this action concern and what were the cost implications? Indicate the cost
using the categories below and provide an actual cost if you can. When considering
costs you should include consultancy or training fees, employee time involved,
capital and equipment costs etc.
2 Between 101 - 500 6 Between 10,001 50,000
Tick if
action
taken
category
(1 7)
Estimated
actual cost

Assessments of risks created by work involving
substances hazardous to health of yourself (if a self
employed person), employees and / or others in
connection with your work.
1
Time spent deciding and implementing controls
2
Costs of control measures ( including engineering
measures / PPE / etc)
3
Maintenance / examination and test of control
measures
4
Monitoring of exposure to employees at the
workplace
5
Health surveillance procedures / requirements
6
Information instruction and training for persons
who may be exposed to substances, on health and
safety risks, controls, arrangements and procedures,
responsibilities etc.
7
68
MANUAL HANDLING
As you may be aware the Manual Handling Operations Regulations require employers to
review their manual handling tasks. Common manual handling tasks include, handling
patients, carrying bricks, carrying paper, filling supermarket shelves, pushing or pulling
trolleys etc.
MH1Have you taken any act
Not
applicable
1
Yes
2
No
3
ion to manage manual handling risks in your organisation?
+ if not applicable got to N1
+ if no go to N1
MH2 What year did you first start to implement these regulations?
MH3 What did this action concern and what were the cost implications? Indicate the cost
2 Between 101 - 500 6 Between 10,001 50,000
Tick if
action
taken
What action taken /
description
Cost
category
(1 7)
Estimated
actual cost

Employment / training of a specialist
1
Conducting risk assessments of manual handling tasks
2
Changes in work practices / processes
3
Changes to the work environment
4
Changes to the load, either that you produce or in
discussion with suppliers
5
New equipment or changes to existing equipment
6
Provision of personal protective equipment (PPE)
7
Training and information for employees
8
Reviewing assessments and monitoring controls
9
Provision of occupational health services / physios / etc
(Please estimate the proportion of the costs if this service is
provided for a wider application).
10
69
NOISE
As you may be aware the Noise at Work Regulations (NAWR) require employers to take
general action to identify, assess, control and manage risks to health and safety of
employees and others, presented by noise, and outline the responsibilities of employees in
this process.
N1 Have you taken any act
Not
applicable
1
Yes
2
No
3
ion in relation to the Noise at Work Regulations?
+ if not applicable go to end page
+ if no go to end page
N2 Please specify the year that you began addressing these regulations?
N3 What did this action concern and what were the cost implications? Indicate the cost
2 Between 101 - 500 6 Between 10,001 50,000
Tick if
action
taken
category
(1 7)
Estimated
actual
cost
Assessments of risks of work involving exposure to
noise
1
Reduction of noise exposure (control measures at
source) excludes provision of PPE such as hearing
defenders
2
Provision of PPE i.e. hearing defenders other PPE to
ensure compatibility with hearing defenders
3
Creation of hearing protection zones
4
Maintenance and review of control measures
5
Provision of information to employees who may be
exposed to noise
6
Other actions
7
70
We may wish to discuss some of the issues raised further. If you would be happy to do so, we
would be grateful if you could provide your contact details below (or attach your business card).
All responses will be treated with the strictest confidence.
Name:Job title:.
Organisation:Address:
.
.
Telephone Number:.. Post code:.
Thank you for providing this information
Please return this questionnaire in the reply-paid envelope provided or post to:
Woodholmes KSA, 15 Lansdowne Terrace, Newcastle-upon-Tyne, NE3 1HN
71
72
Appendix B
Postal Survey: pilot questionnaire evaluation form
73
COSTS OF COMPLIANCE WITH HEALTH AND SAFETY REGULATIONS
PILOT QUESTIONNAIRE EVALUATION
We would be grateful if you could provide us with your thoughts on our pilot
questionnaire:
1. Approximately how long did it take you to complete the questionnaire?
2. Were the instructions easy to follow? (*Please delete as appropriate) YES/NO*. If
not, could you please make a note of where any confusion.
arose:

3. Did you think the language used was appropriate to the respondents being
targeted? (*Please delete as appropriate) YES/NO*. We would welcome any
comments:.

4. Did you find that the response options were appropriate? (*Please delete as
appropriate). YES/NO*. If not, could you please point out where this wasnt
appropriate, and why?

5. Were there any problems with the routing of the questions? (*Please delete as
appropriate) YES/NO*. If so, could you please point out where any confusion
arose:

6. Any other comments?:

We would appreciate it if you could provide us with the following information:
Name:
Organisation:..
Job Role / Title:..
Telephone number:
74
Thank you for your assistance
Please return the questionnaire and evaluation form, in the reply-paid envelope
provided, or post to Rebecca Lancaster, ENTEC UK Ltd., Doherty Innovations Centre,
Pentlands Science Park, Bush Loan, Penicuik, Midlothian, EH26 0PZ.
75
76
Appendix C
Postal Survey: detailed sample structure and response rate
77
Sample structure Size by Sector
Table C1
244 131 185 86 88 8 742
72.8% 26.5% 48.2% 18.9% 31.4% 12.1% 36.8%
30 250 119 167 119 9 694
9.0% 50.5% 31.0% 36.7% 42.5% 13.6% 34.4%
13 102 40 160 55 4 374
3.9% 20.6% 10.4% 35.2% 19.6% 6.1% 18.6%
48 12 40 42 18 45 205
14.3% 2.4% 10.4% 9.2% 6.4% 68.2% 10.2%
335 495 384 455 280 66 2015
100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%
Count
Col %
l (1-49
Count
Col %
Count
Col %
Large (250+
Count
Col %
Count
Col %
i
e/Forestry Not stated
Sector of Activity
Smal
employees)
Medium (50-249
employees)
employees)
Not known
Size of
organisation
Group Total
Agr cultur
Construction
Health
Services Manufacturing Transport Group Total
Detailed Sample Structure by Sector
Agriculture
Table C2
108 32.2%
184 54.9%
3 .9%
40 11.9%
335 100.0%
Agriculture production - crops
animal specialities
l
%
organisation operates
in?
Agriculture production - livestock and
Forestry
Other - please specify:
Tota
Count
What area of agr/forest
sector your
Construction
Table C3
219 44.2%
24 4.8%
155 31.3%
97 19.6%
495 100.0%
%
construction sector
operates in?
Count
What area of
your orgnisation
Building construction and operative
builders - general contractors
Heavy construction other than
building construction - contractors
Construction - special trade
contractors
Other - please specify:
Total
78
50 10.9
Health Services
Table C4
92 24.0%
127 33.1%
27 7.0%
6 1.6%
132 34.4%
384 100.0%
ls
l
%
organistn operates in?
Offices of health practitioners
Nursing homes
Hospita
Medical and dental laboratories
Tota
Count
What areas of health
service sector your
Manufacturing
Table C5
11 2.4
5 1.1
16 3.5
17 3.7
15 3.3
24 5.3
20 4.4
4 .9
27 5.9
2 .4
10 2.2
5 1.1
40 8.8
5 1.1
57 12.5
11 2.4
15 3.3
37 8.1
86 18.8
457 100.0
l
ing and allied
i
ion
l
i
good
l l
%
Food and kindred
Textile mil
Apparel and other finished products made from fabric
Lumber and wood
Furniture and
Paper and allied
Printing, publish
Chemicals and allied
Petroleum refin ng and related
Rubber and miscellaneous plastic
Leather and leather
Transportat
Primary metal
Electronic & other e ect equip & components, except
Measuring, analys s & control instruments: photog
Fabricated metal prods, except machinery and
Industria & commercia machinery and
Stone, clay, glass and concrete
Miscellaneous manufacturing
Other, please
Tota
Coun
What area
manufacturing
your
operates
79
Transport
Table C6
57 20.1%
126 44.4%
54 19.0%
47 16.2%
284 100.0%
%
operates in?
Count
What area of transport
and vehcle repair
sector your org
Local and suburban trans &
interurban hghwy passngr transptn
Motor freight transportation and
warehousing
Vehicle repair
Total
Make up of Responses
Table C7
Response rate
No. of returns (% response)
Large Medium Small Total*
Agriculture / Forestry 13 (31%) 30 (12%) 244 (12%) 335 (14%)
Construction 102 (24%) 250 (21%) 131 (16%) 495 (21%)
Manufacturing 160 (20%) 167 (21%) 86 (11%) 455 (19%)
Transport 55 (21%) 119 (10%) 88 (10%) 280 (12%)
Health 40 (17%) 119 (10%) 185 (18%) 384 (16%)
Total 374 (21%) 694 (15%) 742 (13%) 2015
(17%)
There were a number of responses that were not classified by size, these are included in the total figure and therefore the sum of the
size columns does not always equal the total
80
Appendix D
Postal Survey: general findings
81
Benefits of Compliance
Chart D1
Effects of compliance
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Don't know
Increased
No affect
Decreased
Too early to say
g
?

r
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?
.
.

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H
Table D1
Effects of compliance
Too early
to say Decreased No affect Increased Don't know Total
Has the action affected
compensation claims in ur org?
Count
%
239
11.9
198
9.8
899
44.6
170 509
8.4 25.3
2015
100
Has the action affected insurance
premiums in ur org?
Count
%
138
6.8
165
8.2
917
45.5
294 501
14.6 24.9
2015
100
Has the action affected no. of
staff employed in ur org?
Count
%
46
2.3
72
3.6
1247
61.9
232 418
11.5 20.7
2015
100
Has the action affected product
damage/waste in ur org?
Count
%
97
4.8
336
16.7
971
48.2
62 549
3.1 27.2
2015
100
Has the action affected
performance/productivity of
Count
%
119
5.9
155
7.7
864
42.9
409 468
20.3 23.2
2015
100
Has the action affected sickness
absence of ur org?
Count
%
110
5.5
316
15.7
1033
51.3
99 457
4.9 22.7
2015
100
Hast the action affected staff
morale in ur org?
Count
%
77
3.8
86
4.3
758
37.6
663 431
32.9 21.4
2015
100
Has the action affected Staff
turnover in ur org?
Count
%
63
3.1
138
6.8
1311
65.1
60 443
3.0 22.0
2015
100
Has the action affectd time lost
through accidents in ur orf
Count
%
125
6.2
549
27.2
834
41.4
49 458
2.4 22.7
2015
100
82
c
i
Sources of advice and information newly-established firms
Chart D2
Initial sources of information: percentage of respondents preferring a specified source of
information
0
5
10
15
20
25
30
35
40
%

r
e
s
p
o
n
d
e
n
t
s

Health and HSE Inspector Other, please Croner Don't know/No Local RoSPA Federation of Internet, at IOSH
safety specify response Enterprise Small sites other than
consultants Businesses those relating
to above
83
84
Appendix E
Postal Survey: findings by size
85
Reported levels of Accidents and Ill-health
The mean number of accidents, per organisation, by size are shown below.
Table E1
Mean accidents in 2001, by site size
Size of company at site
Table
Total
Small (1-49
employees)
Medium (50-249
employees)
Large (250+
employees)
/Not
applicable
How many accidents in 2001, Mean 7.4 20.1 77.1 16.4 19.5
less than 1 day off work Valid N N=400 N=350 N=139 N=1126 N=2015
How many accidents in 2001, 1 Mean 1.9 4.8 15.0 4.0 4.4
to 3 days off work Valid N N=400 N=350 N=139 N=1126 N=2015
How many accidents in 2001, 4 Mean 1.4 3.7 9.1 2.2 2.8
or more days off work Valid N N=400 N=350 N=139 N=1126 N=2015
How many accidents in 2001, Mean 0.19 1.47 1.60 0.47 0.67
non fatal major injuries? Valid N N=400 N=350 N=139 N=1126 N=2015
How many accidents in 2001,
fatal injuries?
Mean
Valid N
0.010
N=400
0.009
N=350
0.014
N=139
0.007
N=1126
0.008
N=2015
Table E2
Percentage chance of reporting an accident, by size of organisation
% chance of employee being affected per accident type
Accident type Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
In 2001
Less than 1 day
off work
4.88% 7.89% 7.06% 2.32%
1 to 3 days off
work
1.68% 1.58% 1.71% 0.64%
4 or more days
off
0.96% 0.87% 0.93% 0.63%
Non fatal major
injuries
0.16% 0.21% 0.18% 0.26%
Fatal injuries 0.00% 0.01% 0.00% 0.00%
In last five years
Less than 1 day
off work
19.00% 23.19% 10.58% 2.28%
1 to 3 days off
work
5.04% 4.39% 3.23% 0.64%
4 or more days
off
3.24% 2.43% 2.85% 0.80%
Non fatal major
injuries
0.52% 0.52% 0.66% 0.12%
Fatal injuries 0.00% 0.01% 0.01% 0.00%
86
Compliance Costs and Benefits
Table E3
Nature of the 3 main health and safety expenditures by size of organisation
% Agriculture /
Forestry
Construction Health Service Manufacturing Transport
S M L S M L S M L S M L S M L
Training 8 27 31 22 72 86 25 37 48 20 44 58 - 51 71
PPE 16 - - 27 38 38 - - - 33 32 26 15 27 47
Consultants - - - 9 22 - - - - 10 - - - 22 15
Equipment - - - - - - - 13 - - 20 11 - - -
Dont know - - 31 - - - 19 - 23 - - - 18 - -
Dust extraction /
dust masks
6 - - - - - - - - - - - - - -
Safety / warning
signs
- 10 - - - - - - - - - - - - -
Fire prevention - - - - - - 11 - - - - - - - -
Lifting / manual
handling / hoists &
associated
equipment
- - - - - - - 35 25 - - 11 - - -
Staff time - 13 - - - - - - - - - - - - -
Salary for H&S
personnel
- - - - - 41 - - - - - - - - -
First Aid - - - - - - - - - - - - 14 - -
S=Small, M=Medium, L=Large. Table E3 details the 3 main expenditures per size for each of the 5 sectors. Figures
are given as a percentage of respondents that reported each aspect as one of their 3 main expenditures. RED = 1
st
main expenditure; GREEN = 2
nd
main expenditure; BLUE = 3
rd
main expenditure.
87
Appendix F
Postal Survey: findings by sector
88
Formal Health and Safety Management Systems
Chart F1
Reasons for implementing health and safety systems across sector
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
/ i
Visi / l i i
l
i l i
lier/ li
i i l
/
i i
i
l ici
l li
Union pressure
Don't know
Trade groups federat ons
ted by a HSE Loca Author ty nspector
Other, p ease specify
Organisation reached a part cu ar s ze
Supp customer/ c ent pressure
There was a rev ew of organ sationa
structure systems
Exper ence of accidents w thin the
organisation
Insurance costs
In conjunction w th other systems that
were being developed
Hea th and safety publ ty
Lega ob gation
%

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89
Recording Work-Related Accidents and Ill-health
Chart F2
Recording work-related accidents by sector
A / y
i
l i
l i
griculture Forestr
Construction
Health Services
Manufactur ng
Transport
Do you record work re ated acc dents? Yes
Do you record work re ated acc dents? No
0% 20% 40% 60% 80% 100%
90
Chart F3
Recording ill-health by sector
0%
l
i
ill
ill
10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Agricu ture/Forestry
Construction
Health Services
Manufactur ng
Transport
Do you record -health? Yes
Do you record -health? No
Reported levels of Accidents and Ill-health
The mean number of accidents, per organisation, by sector are shown in table F1.
Table F1
Mean accidents in 2001, by sector
Sector of Activity
Table
Total
Agriculture/
Forestry Construction
Health
Services
Manufactu
ring Transport Not stated
How many accidents in 2001, Mean 3.3 17.5 13.4 42.2 17.2 4.1 19.5
less than 1 day off work Valid N N=335 N=495 N=384 N=455 N=280 N=66 N=2015
How many accidents in 2001, 1 Mean 0.5 5.4 5.4 4.3 7.3 0.5 4.4
to 3 days off work Valid N N=335 N=495 N=384 N=455 N=280 N=66 N=2015
How many accidents in 2001, 4 Mean 0.4 3.6 1.0 3.8 5.7 0.6 2.8
or more days off work Valid N N=335 N=495 N=384 N=455 N=280 N=66 N=2015
How many accidents in 2001, Mean 0.09 1.03 0.07 0.52 1.92 0.05 0.67
non fatal major injuries? Valid N N=335 N=495 N=384 N=455 N=280 N=66 N=2015
How many accidents in 2001,
fatal injuries?
Mean
Valid N
0.003
N=335
0.010
N=495
0.003
N=384
0.007
N=455
0.025
N=280
0.000
N=66
0.008
N=2015
91
Compliance Costs and Benefits
Table F2
Average spend on health and safety by sector
Average Mean Minimum Mean Maximum Mean
Sector of Activity
Spend Spend Spend
Agriculture/Forestry Mean
N
13,382
279
11,435
279
14,732
279
Construction Mean 83,010 73,736 88,860
N 462 462 462
Health Services Mean 16,546 12,986 19,019
N 327 327 327
Manufacturing Mean
N
335,463
427
326,124
427
341,353
427
Transport Mean
N
18,353
263
11,697
263
22,757
263
Total Mean 110,301 103,620 114,606
N 1776 1776 1776
Effects of Compliance
Table F3
Effects of compliance by Sector
Outcome Agriculture/
forestry
Construction Health Manufact-
uring
Transport
Compensation
claims
Dont know Decreased Average Average Average
Insurance
premiums
Dont know Increased No effect Increased No effect
Staff employed No effect/
dont know
Increased Average No effect Average
Product
damage/waste
No effect/
dont know
Decreased No effect Decreased Decreased
Performance/
productivity
Dont know Increased No effect Increased No effect
Sickness absence Dont know No effect No effect Decreased No effect
Staff morale Dont know Increased No effect Increased Increased
Staff turnover Dont know/
no effect
Decreased Average Average Average
Time lost through
accidents
Dont know Decreased No effect Decreased Average
The sections of the table that state Average refer to the companies that showed no particular movement in any
direction, as opposed to actually stating no effect.
92
Inf ormation Type
Sources of Advice and Information
Chart F4
Sources of information per sector
0
10
20
30
40
50
60
70
l
i
%

p
e
r

s
e
c
t
o
r
Health and safety consultants
HSE centra resource
Croner
Other, please spec fy:
HSE inspector
IOSH
None of them
r
y

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Chart F5
Information preference by sector
a a lt
u e
H
r
ic
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g
0
10
20
30
40
50
60
70
80
90
i
isit
Vi
l
%

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r

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r

Paper-based
Internet
Attend ng conf erences
Personal v
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Audiotapes
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93
94
Appendix G
Postal Survey: specific regulations
95
RESPONSE TO SPECIFIC REGULATIONS
Respondents were asked to indicate which specific health and safety regulations they had taken
action against.
78% had taken action in response to Management of Health and Safety at Work
Regulations.
15% had taken action in response to the Control of Pesticides Regulations, although this
question was not relevant to 67% of respondents.
78% had taken action in response to COSHH Regulations.
71% had taken action in response to Manual Handling Operations Regulations.
50% had taken action in response to Noise at Work Regulations.
Chart G1
Actions taken in response to specific regulations
A
l
l

r
e
s
p
o
n
d
e
n
t
s
100%
90%
80%
70%
60%
No
50% Yes
Not applicable
40%
30%
20%
10%
0%
Managing H&S at Control of COSHH Manual handling Noise at Work reg?
work regs? Pesticides regs? regulations? risks?
96
There was a peak in activity between 1990 and 2000 for every regulation mentioned (see chart
G2). A few farmers indicated that they have been handling the issues covered by the
regulations since the date that their farm originally started going back as far as 1815!
Chart G2
Year started to take action
250
200
150
100
50
0
-50
i i
i l of
i
regul
i
li
ing i
reg
1950 1960 1970 1980 1990 2000 2010
Year began address ng Manag ng H&S
at work regs
Year began address ng Contro
Pesticides regs
Year began address ng COSHH
ations?
Year began address ng Manual
hand ng regs?
Year began address No se at Work
Year
Whilst chart G2 suggests a drop in activity in 2002, caution should be taken when interpreting
this data, as organisations may have under-reported activity for 2002 as the survey was issued
part way through that year.
N
u
m
b
e
r

o
f

r
e
s
p
o
n
d
e
n
t
s
97
Management of Health and Safety at Work
78% of respondents had taken action in response to Management of Health and Safety at Work
Regulations. Large businesses appeared more likely to take action in response to the regulations
(99% vs 60% for small organisations). There was higher participation in the construction
(90%), manufacturing (94%) and transport (84%) than in the agriculture / forestry (48%) or
health (74%) sectors.
Chart G3
No
100
80
60
40
20
0
Yes
Percent
Sector of Activity
Construction
Health Services
Manufacturing
Transport
Not stated
Have you taken any action in relation to Managing health and safety at work Regulations?
98
The actions taken were split by key activity areas, such as implementing control measures. The
actions most likely to have been taken included risk assessments (91%), information and
training (78%), health and safety arrangements (75%) and health and safety assistance (69%).
See chart G4.
Chart G4
Management of Health and Safety at Work Regulations activities
0
10
20
30
40
50
60
70
80
90
100
%

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99
Larger organisations were also more likely to take up each of the possible actions in support of
the managing health and safety at work regulations (as shown in chart G5).
Chart G5
Managing Health and Safety at Work Regulations activities by size
%

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80
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S m al l ( 1 -4 9 e m p l oy ee s )
M ed i u m ( 50 -24 9 em pl es )
La rge (25 e m p l oyees)
o y e
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100
Agricultural / forestry businesses seemed less likely to include any of the specific activities
except risk assessments in response to the regulations about managing health and safety at work.
The construction and manufacturing sectors appeared more likely to have encompassed a wide
range of relevant activities (see chart G6).
Chart G6
Management of Health and Safety at Work Regulations activities by sector
%

b
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100
90
80
70
60
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40
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0
l / Fo re
C ons tr uc ti on
H eal S i
Man uf ac ing
Tr ans por t
A g ri c u t u r e s t ry
t h e r v c e s
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101
Work Regulations varied (as shown in chart G7 and table G1). The greatest expenditure by far
was on implementing control measures, followed by providing health and safety assistance.
The least was spent on making other special arrangements for temporary staff, young people etc.
and co-operation with employers with whom the respondent organisation shared the workplace.
Chart G7
Expenditure on actions to meet Management of Health and Safety at Work Regulations
100%
80%
60%
40%
20%
0%
Do n ' t kn o w
Mo re tha n 5 00 00
B e tw ee n 1 00 01 -5 00 00
B e tw ee n 5 00 1- 10 00 0
B e tw ee n 1 00 1- 50 00
B e tw ee n 5 01 -1 00 0
B e tw ee n 1 01 -5 00
Le s s th an 1 00
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102
cost was given, the calculated mean expenditure per activity was as shown in table G1. The
mean estimated spend per activity ranged from just under 3,000 for other arrangements in
connection with temporary workers, expectant and new mothers and young people to over
125,000 for implementing control measures.
Table G1
Average costs of actions to meet Management of Health and Safety at Work Regulations
Actions Calculated Valid Number of Mean, Valid Number Mean low point
mean responses (for based on of responses mean high point
the calculated
mean)
actual
costs given
(for the actual
costs mean)
Range
(calculated mean
respective ranges)
Risk assessments 7,549 N=1215 7,544 N=671 6,266 8,833
H&S arrangements 9,293 N=961 9,929 N=519 7,883 10,702
Implementing control measures 125,572 N=556 200,783 N=318 122,973 128,172
Health surveillance 9,583 N=523 9,338 N=304 8,149 11,017
H&S assistance 22,400 N=897 25,708 N=516 19,517 25,285
Serious and imminent danger 6,755 N=581 7,209 N=310 5,520 7,989
Information and training for staff 13,011 N=1002 14,161 N=551 11,432 14,591
Co-operation with employers with whom 5,825 N=313 12,284 N=157 4,810 6,840
share the workplace
Other special arrangements for 2,897 N=383 1,478 N=198 2,015 3,779
temporary staff, young people etc.
103
Larger organisations also tended to invest more heavily than smaller organisations on all actions
to meet the Managing Health and Safety at Work Regulations, with a particular emphasis on
implementing control measures (see chart G8 and table G2).
Chart G8
Average expenditure on actions to meet Management of Health and Safety at Work
Regulations by size
Size of organisation
80000
70000
60000
50000
40000
30000
20000
10000
0

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l
m
e
a
s
s
s
e
i
l
l
s
i
s
h

e
m
p
l
t
r
s
k

a
s
s
e
t
h

s
u
r
v
n
I
n
f
o
r
m
a
t
i
o
n

a
n
d
H
&
S

a
s
n
e
m
i

w
t
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e
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l
m a
l
R
i
o
n i
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r

s
p
e
c
i
H H
o
u
s
a
n
d
p
e
r
a
t
i
o
C
o
-
O
t
e
r
i
S
Activities
Table G2
Regulations by size
Small (1-49 Medium (50-249 Large (250+
employees) employees) employees)
Risk assessment 2175 5105 17393
H&S arrangements 2463 6995 18703
Implementing control measures 6958 20022 69374
Health surveillance 1598 4522 18135
H&S assistance 4432 13960 46593
Serious and imminent danger 969 4197 10476
Information and training 2745 8574 28858
Co-operation with employers 2110 2592 11491
Other special arrangements 1471 1249 4866
104
Table G3
Average spend per employee for action taken in relation to the Management of Health
and Safety at Work Regulations
Regulation: Management of Health &
Safety at Work Regulation
Average spend per employee per Regulation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
1. Risk Assessments 87.01 34.03 14.07 15.00
2. Health & Safety arrangements 98.51 46.63 14.36 16.91
3. Implementing control measures 278.31 133.48 54.79 41.19
4. Health surveillance 63.92 30.15 16.04 11.42
5. Health & Safety assistance 177.28 93.07 41.47 24.74
6. Serious & imminent danger procedures 38.75 27.98 9.71 6.04
7. Information & training 109.80 57.16 26.21 15.92
8. Co-operation with other employers 84.40 17.28 10.13 4.46
9. Special arrangements for temp workers 58.82 8.33 4.21 1.91
M3 TOTAL 111.59 176.75 20.89 15.99
The significant finding here is that spend per employee for the Management of Health and
Safety at Work Regulations is less for organisations with greater than 250 employees. The
costs, in every category of compliance, are greatest for small organisations, i.e. those with less
than 50 employees.
105
The construction and manufacturing sectors appeared to spend more than the others on the
majority of categories. Agriculture / forestry and construction companies were more likely to
invest on health and safety advice than other sectors, whilst manufacturing, health services and
construction companies were more likely to invest in implementing control measures, as shown
in chart G9 and table G4.
Chart G9
Regulations by sector
50000
45000
40000
Sec t o r
35000
A g ricult u r e/For est r y
30000
Constructio n
25000 Heal t h Ser vices
20000
Manuf a c t uring
Tra nspor t
15000
10000
5000
0

e
x
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n
d
i
t
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r
e

m
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r

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l

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r
r
Activities
106
Table G4
Regulations by sector
Agriculture/
Forestry
Construction Health
Services
Manufacturing Transport
Risk assessment 3288 8924 4568 9442 7384
H&S arrangements 3410 13712 6637 8874 5354
Health surveillance 3137 10312 9240 10706 7797
H&S assistance 27906 30757 14899 20525 12191
Serious and imminent danger 1343 9075 2843 6215 9278
Information and training 3630 20235 12257 11495 6084
Co-operation with employers 6684 8074 1718 4572 3145
Other special arrangements 2623 4092 1374 2990 1757
Implementing control measures 8486 37450 41303 47166 20911
107
15% had taken action in response to the Control of Pesticides Regulations (referred to as
Pesticides Regulations), however this question was not relevant to 67% of respondents. 63% of
those involved in the agriculture / forestry sector had taken action, compared to 12% who had
not and 24% who thought it irrelevant. See chart G10.
Chart G10
100%
80%
60%
No
Yes
Not applicable
40%
20%
0%
%

o
f

r
e
s
p
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/
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lt
t C
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l
M
H ic
r
g
A
The actions taken were split by key activity areas, such as storage. The actions most likely to
have been taken included storage (79%), informing employees (72%) and measures taken to
protect (68%).
108
Chart G11
%

o
f

t
h
o
s
e

t
a
k
i
n
g

a
n
y

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e
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t
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s

Control of Pesticides Regulations activities
90
80
70
60
50
40
30
20
10
0
Information to Measures taken to Getting certificates - Storage - action Application - action Notifications and
employees - action protect - action action taken or not? taken or not? taken or not? restrictions - action
taken or not? taken or not? taken or not?
The amount of expenditure per activity relating to pesticide control varied (see chart G12). The
greatest expenditure items were related to controlling and confining application of pesticides
and the least was application notifications and restrictions.
109
Chart G12
Expenditure on actions taken to Control Pesticides
%

t
a
k
i
n
g

a
c
t
i
o
n

100%
80%
60%
40%
20%
0%
Don't know
More than 50000
Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
Less than 100
Information to Measures Getting Storage - cost Application - Notifications
employees - taken to certificates - category? cost and
cost protect - cost cost category category? restrictions -
category? category? cost
category?
cost was given, the calculated mean expenditure per activity was as shown in table G5. The
mean estimated spend per activity ranged from 710 for notification of aerial application and
observing restrictions to just under 5,000 for controlling application.
Table G5
Average costs of actions to meet Control of Pesticides Regulations
Actions Calculated
mean
Valid Number of
responses (for
the calculated
Mean,
based on
actual
Valid Number
of responses
(for the actual
Mean low point
mean high point
Range (calculated
mean) costs given costs mean) mean respective
ranges)
Information, instruction, training & 1458 N=174 1412 N=97 1078 1839
guidance
Protect health 3134 N=150 2734 N=82 2593 3675
Certificates of competence 1543 N=132 1416 N=76 1153 1934
Storage 2219 N=179 2667 N=105 1836 2602
Application controlled/ confined 4973 N=84 6486 N=50 4737 5209
Notification of aerial application & 710 N=26 8169 N=6 517 904
restrictions observed
110
The larger organisations appeared to spend more than the smaller ones on the majority of
categories, particularly in the case of controlling / confining application to the intended target

e
x
p
e
n
d
i
t
u
r
e

(see chart G13 and table G6). Medium-sized organisations were more likely to have spent on
storage facilities. Please note that too few non-agricultural / forestry businesses responded to
this section to compare results meaningfully.
Chart G13
Average expenditure on meeting Control of Pesticides Regulations by size
14000
12000
10000
8000
6000
4000
2000
0
Information, Protect health Certficates of Storage Application Notification of
instruction, competence controlled/ aerial
training & confined appplication
guidance & restrictoins
observed
ll l )
i )
)
Sma (1-49 emp oyees
Med um (50-249 employees
Large (250+ employees
Table G6
Average expenditure on meeting Control of Pesticides Regulations by size
Small (1-49 Medium (50- Large (250+
employees) 249 employees)
employees)
Information, instruction, training & guidance 704 2395 3314
Protect health 1577 4427 7495
Certificates of competence 629 2561 4165
Storage 1049 5529 3559
Application controlled/ confined 3524 5222 12719
Notification of aerial application & restrictions 386 1967 1413
observed
111
Table G7
Cost per employee for action taken in relation to Control of Pesticides Regulations
Regulation: Pesticides Average spend per employee per Regulation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
1. Information, instruction, training.. 28.15 15.97 2.83 0.37
2. Protecting humans, creatures, plants.. 63.07 29.51 3.56 0.72
3. Certificates of competence 25.14 17.08 3.15 0.71
4. Storage 41.98 36.86 1.63 0.48
5. Controlled application 140.97 34.81 5.64 1.06
6. Notification of restrictions 15.44 13.11 0.79 0.09
P3 TOTAL 50.50 25.74 2.90 0.58
For all activities, small organisations spend more per employee than any other size category.
Large and very large organisations spend significantly less than small and medium-sized
organisations. It should be noted that there were only 13 large agricultural companies in total.
COSHH Regulations
76% of respondents had taken action in response to managing COSHH regulations. 18% felt it
was irrelevant and 6% had not taken any action. Large businesses appeared more likely to take
action in response to the regulations (93% vs 62% for small organisations). There was higher
participation in the construction (87%), manufacturing (89%) than in the health (70%), transport
(68%) or agriculture / forestry (58%) sectors. See charts G14 and G15.
112
Chart G14
Taken action in response to COSHH by size
29
12
6
62
85
93
10
3
1
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
No
i
%

r
e
s
p
o
n
d
e
n
t
s

Yes
Not appl cable
Small (1-49 employees) Medium (50-249 Large (250+ employees)
employees)
Size of organisation
Chart G15
Taken action in response to COSHH by sector
30
9
24
10
25
58
87
69
89
68
11
4
6
2
7
0%
No
i le
20%
40%
60%
80%
100%
r
e
s
p
o
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t
s
Yes
Not appl cab
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y

e
s

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i
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g
r
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113
i
c
The specific types of actions that could have been taken to meet COSHH were grouped under a
series of headings. The actions most likely to have been taken included risk assessments (95%),
providing information / instructions (74%), time spent deciding (67%) and costs of control
measures (66%).
Chart G16
Specific actions taken in response to COSHH
0
10
20
30
40
50
60
70
80
90
100
%

Assessments of Time spent Costs of control Maintenance of Monitoring Health Information
risk - action deciding - action measures - control employees - surveillance - instruction -
taken or not? taken or not? action taken or measures - action taken or action taken or action taken or
not? action taken or not? not? not?
not?
114
Larger organisations are also more likely to take up each of the possible actions in support of
COSHH (see chart G17).
Chart G17
Specific actions taken in response to COSHH by size
%

b
u
s
i
n
e
s
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e
s

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e

b
a
n
d
100
90
80
70
60
50
40
30
20
10
0
S m al l ( 1 -4 9 e m p l oy ee s )
M ed i u m ( 50 -24 9 em pl o y e es )
La rge (25 0 + e m p l oyees)
A
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115
The agriculture / forestry sector appeared less likely to have undertaken any of the specific
activity types in response to the regulations about COSHH, with the exception of risk
assessments. Manufacturing businesses appeared more likely to have encompassed a wide
range of relevant activities. See chart G18.
Chart G18
Specific actions taken in response to COSHH by sector
100
90
80
70
60
50
40
30
20
10
0
Assessments Time spent Costs of Maintenance Monitoring Health Information
of risk - deciding - control of control employees - surveillance - instruction -
action taken action taken measures - measures - action taken action taken action taken
or not? or not? action taken action taken or not? or not? or not?
or not? or not?
l
l
i
%

p
e
r

s
e
c
t
o
r

t
a
k
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n
g

a
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t
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n

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n

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l
a
t
i
o
n

t
o

C
O
S
H
H

Agricu ture/Forestry
Construction
Hea th Services
Manufactur ng
Transport
116
The amount of expenditure per activity relating to the managing COSHH regulations varied (as
shown in chart G19 and table G8). As may be expected, the greatest expenditure was on control
measures, and the least on the time spent deciding what to do.
Chart G19
Expenditure on actions to meet COSHH Regulations
100%
80%
60%
40%
20%
0%
More than 50000
Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
Less than 100
g
o
r
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e
g
o
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c c
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117
Table G8
Average expenditure on activities to meet COSHH Regulations
Actions Calculated
mean
Valid Number of
responses (for
Mean,
based on
Valid Number
of responses
Mean low point
mean high point
the calculated
mean)
actual
costs given

(for the actual
costs mean)
Range
(calculated mean
respective ranges)
Risk assessments - COSHH 5333 N=1147 6020 N=612 4387 6279
Time spent deciding 3633 N=748 3458 N=367 2825 4441
Costs of control measures 12945 N=810 15294 N=427 11182 14709
Maintenance/ examination & testing 6660 N=549 6538 N=282 5336 7984
Monitoring exposure 4742 N=505 4133 N=498 3610 5876
Health surveillance 5256 N=858 8201 N=215 3852 6648
Information, instruction & training 6238 N=807 4760 N=410 5180 - 4429
118
Larger companies spent, on average, substantially more than smaller organisations (see chart
G20 and table G9).
Chart G20
Average expenditure on activities to meet COSHH Regulations by size
30000
25000
20000
15000
10000
5000
0

e
x
p
e
n
d
i
t
u
r
e

a
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e H

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i I
Table G9
Costs per employee of actions taken in relation to COSHH Regulations
Regulation: COSHH Average spend per employee per Regulation
(0-49) (50-249) (250-4999) (5000+)
2. Time spent implementing 34.78 17.47 6.71 3.65
3. Cost of control measures 131.70 54.70 19.80 30.72
4. Maintenance & examination 39.71 33.53 9.01 6.01
5. Monitoring of exposure 56.48 17.85 6.00 8.06
6. Health surveillance procedures 51.60 17.58 9.81 9.91
7. Information instruction & training 51.22 23.99 8.24 8.12
C3 TOTAL 54.40 27.45 9.75 11.06
The costs per employee of actions taken for small-sized organisations were greater than for
medium organisations in respect of all activities undertaken. The spend per employee is
119
significantly less for organisations with more than 250 employees. The costs for the large and
very large organisations were greater than SMEs in respect of all activities.
Chart G21
Average expenditure on actions to meet COSHH Regulations by sector
0
5000
10000
15000
20000
25000

e
x
p
e
n
d
i
t
u
r
e
Construction
Health Services
Manufacturing
Transport
r
e

a
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I
M
a
The construction and manufacturing sectors appeared to spend more than the others on the
majority of categories. Manufacturing has particularly invested heavily in control measures (see
chart G21 and table G10).
Table G10
Average expenditure on activities to meet COSHH Regulations by sector
Agriculture/
Forestry
Construction Health
Services
Risk assessments - COSHH
Time spent deciding
Control measures
Maintenance/ examination &
testing
Monitoring exposure
Health surveillance
Information, instruction & training
1880
1131
3810
1301
1833
1175
1570
6153
5106
13538
8180
4847
5591
7739
2289
1556
6186
4206
2400
5742
1462
8429
4428
19091
8320
5769
6923
5838
3323
2948
8812
4553
4999
3026
3758
120
71% of respondents had taken action in response to Manual Handling Operations Regulations.
18% felt it was irrelevant and 11% had not taken any action. There was no significant
difference in the propensity to take action according to sector or size of organisation.
The specific types of actions that could have been taken to meet the Manual Handling
Regulations were grouped under a series of headings. The actions most likely to have been
taken included risk assessments (86%), giving training and information (81%) and changes in
work practices (62%), as shown in chart G22.
There were no significant differences in the specific actions taken by different sectors or sizes of
organisations.
Chart G22
Specific actions taken in response to Manual Handling Regulations
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
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The amount of expenditure per activity relating to the manual handling regulations varied (see
chart G23). As may be expected, the greatest expenditure was on changing work practices and
new equipment. The least expenditure was on risk assessments and reviewing assessments.
121
Chart G23
Expenditure on actions to meet Manual Handling Regulations
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
%

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Between 1001-5000
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122
cost was given, the mean expenditure per activity was calculated (see table G11).
Table G11
Average expenditure on activities to meet Manual Handling Regulations
Actions Calculated
mean
Valid Number of
responses (for
the calculated
mean)
Mean, based
on actual
costs given
Valid
Number of
responses
(for the
Mean low point
mean high point
Range (calculated
mean respective
actual costs ranges)
mean)
Employment/training a specialist 6002 N=539 4925 N=296 4566 7438
Risk assessments - Manual handling 3416 N=875 3190 N=428 2526 4305
Work practice changes 42338 N=552 86320 N=241 40545 44131
Work environment changes 13016 N=291 16649 N=126 11116 14916
Load changes 5060 N=251 4637 N=96 3807 6312
New equipment 29751 N=566 43960 N=280 27265 32238
PPE 6017 N=556 5720 N=276 4820 7213
Training & information 5709 N=800 5782 N=393 4409 7008
Reviewing assessments 3603 N=475 3063 N=212 2682 4524
Occupational health 9145 N=200 9126 N=95 7662 - 10629
123
Small organisations appear to have spent more, on average, on meeting the Manual Handling
Regulations than larger organisations, although small and large organisations seem to have
spent about the same, on average, on changing work practices. This is shown in chart G24 and
table G12. This is however, confounded by one or two organisations that reported having spent
a particularly large sum. For example, one small organisation reported spending 200, 000 on
moving to new premises. It is not clear from the questionnaire whether this is the total cost of
the new premises or the difference between the new and the existing premises. Whilst it may be
argued that in order to implement the regulations, some premises may not be suitable to
accommodate hoists etc, the total cost of new premises it not a true reflection of the costs of
compliance with the regulations.
Chart G24
Average expenditure on activities to meet Manual Handling Regulations by size
0
10000
20000
30000
40000
50000
60000
70000
80000

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124
Table G12
Average expenditure on activities to meet Manual Handling Regulations by size
Employment/training a specialist 7221 5686 5172
Risk assessments - Manual handling 3268 3496 3777
Work practice changes 71376 8649 70797
Work environment changes 14861 10779 9517
Load changes 5552 5033 4272
New equipment 18630 17749 17142
PPE 7572 4750 5774
Training & information 4869 5588 5299
Reviewing assessments 3647 3219 4902
Occupational health 10025 7722 9958
Table G13
Costs of action in relation to Manual Handling Regulations: per employee
Regulation: Manual Handling Average spend per employee per Regulation
Small
(0-49)
Medium
(50-249)
Large
(250-4999)
Very Large
(5000+)
1. Employment/training of a specialist 288.86 37.91 3.06 5.04
3. Work practices/processes 2,855.05 57.66 41.85 5.99
4. Work environment 594.44 71.86 8.22 5.77
5. Changes to the load 222.10 33.56 3.24 0.03
6. New equipment 745.18 118.32 11.31 17.53
7. Provision of PPE 302.89 31.67 4.13 1.80
8. Training and information 194.76 37.25 3.04 5.96
9. Reviewing assessments 145.86 21.46 3.39 0.59
10. Provision of occupational health 400.98 51.48 6.18 6.75
MH3 TOTAL 571.61 46.75 8.60 5.01
The costs of action taken in relation to the Manual Handling Regulations were much greater per
employee for small organisations, again this is confounded by a few organisations who have
spent a significantly greater amount on controls or equipment. For example, some reported
spending between 20, 000 and 30, 000 on lifting equipment. With less than 50 employees
these are significant amounts per employee. The work environment, work processes and new
125
equipment categories should be treated with caution as respondents have reported provision of
new equipment under each of these headings.
Costs of action taken, per employee, in relation to the Manual Handling Regulations were
broadly similar across large and very large organisations.
Chart G25
Average expenditure on activities to meet Manual Handling Regulations by sector
140000
120000
100000
80000
60000
40000
20000
0
Construction
Health Services
Manufacturing
Transport

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The health sector appeared to spend significantly more than the others on introducing changes to
working practices, followed by the construction sector (see chart G25 and table G14).
126
Table G14
Average expenditure on activities to meet Manual Handling Regulations by sector
Agriculture/ Construction Health Manufacturing Transport
Forestry
Mean
Services
Mean Mean
Mean Mean
Employment/training a specialist 4766 7638 6909 5999 3731
Risk assessments - Manual 3467 4089 3346 3428 2457
handling
Work practice changes 8309 56586 132255 8623 4274
Work environment changes 13484 11019 20733 12713 8241
Load changes 6405 4940 4315 5249 5662
New equipment 17390 18849 20220 23622 15674
PPE 7148 4315 6046 7768 5171
Training & information 4877 7249 4527 7581 3157
Reviewing assessments 4547 3732 4209 4041 1375
Occupational health 8428 8597 7283 13276 7929
127
38% of respondents had taken action in response to Noise at Work Regulations. 50% felt it was
irrelevant and 13% had not taken any action. There were no significant differences in the
propensity to take action in response to the Noise at Work Regulations according to business
size or sector.
Those who had taken action in response to the noise at work regulations were most likely to
assess the risks and provide personal protective equipment and least likely to create hearing
protection zones.
Chart G26
Specific actions taken in response to Noise at Work Regulations
%

r
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s
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80%
70%
60%
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50%
Taken action
40%
30%
20%
10%
0%
Assessments Reduction of Provision of Hearing Maintenance Information to Other actions
of risks noise PPE zones and review employees
The amount of expenditure per activity relating to the noise at work regulations varied (see chart
G27). The greatest expenditure was on reducing noise and other actions. These other
actions primarily included audiometry tests, noise assessment tests and getting new, quieter
equipment. The least expenditure was on maintenance and review.
128
Chart G27
Expenditure on actions to meet Noise at Work Regulations
%

r
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s
p
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80%
60%
40%
20%
0%
Assessments Reduction of Provision of Hearing zones Maintenance Information to Other actions -
of risks - cost noise - cost PPE - cost - cost category and review - employees - cost category
category category category cost category cost category
More than 50000
Between 10001-50000
Between 5001-10000
Between 1001-5000
Between 501-1000
Between 101-500
Less than 100
cost was given, the calculated mean expenditure per activity was as shown in table G15.
Table G15
Average expenditure on activities to meet the Noise at Work Regulations
Actions Calculated
mean
Valid Number of
responses (for
the calculated
Mean,
based on
actual
Valid Number
of responses
(for the actual
Mean low point
mean high point
Range (calculated
mean) costs given costs mean) mean respective
ranges)
Risk assessments - noise 3226 N=666 2682 N=345 2374 4079
Reduction of exposure 46671 N=433 84964 N=212 45074 48268
PPE 3161 N=653 2214 N=340 2172 4152
Creating hearing protection zones 3487 N=236 4138 N=109 2699 4275
Maintenance and review 2858 N=315 1828 N=157 1829 3887
Information to staff 3512 N=447 3796 N=218 2672 4352
Other actions - noise 52272 N=54 84246 N=31 51099 53445
129
Medium-sized organisations appeared more likely to spend significantly more than large or
small organisations on reducing exposure to noise and other activities (see chart G28 and table
G16).
Chart G28
Average expenditure on activities to meet Noise at Work Regulations by size
120000
100000
80000
60000
40000
20000
0
l ( l )
i ( )
( )
Smal 1-49 emp oyees
Med um 50-249 employees
Large 250+ employees

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r
Table G16
Average expenditure on activities to meet Noise at Work Regulations by size
Risk assessments - noise 3088 3104 3571
Reduction of exposure 8928 102201 15069
PPE 3217 3257 2907
Creating hearing protection zones 3969 2634 6396
Maintenance and review 2580 3196 3022
Information to staff 2743 4648 3388
Other actions - noise 9218 90135 23600
130
Table G17
Costs per employee for action taken regarding Noise at Work Regulations
Regulation: Noise at Work Average spend per employee per Regulation
(0-49) (50-249) (250-4999) (5000+)
2. Reduction of noise exposure 357.12 681.34 8.69 21.62
3. Provision of PPE 128.68 21.71 1.86 0.61
4. Creation of hearing protection
zones
158.78 17.56 3.07 12.91
5. Maintenance and review of
control measures
103.18 21.31 1.96 0.25
6. Provision of information 109.74 30.99 2.21 0.59
7. Other actions 368.71 600.90 25.71 0.00
N3 TOTAL 164.39 140.96 6.38 5.18
SMEs spent significantly more per employee than large and very large organisations. However,
this is confounded by a small number of organisations that have spent significant amounts on
particular controls. For example an SME organisation employing 43 staff has spent 75,000 on
replacement of equipment and sound reduction. Another organisation with 550 employees
spent 1.5 million on noise prevention engineering and reduction. Many of the reported noise
controls are described as plant renewals and therefore, whilst having health and safety benefits,
these changes may well have been installed irrespective of the noise implications.
131
250000
The heath sector appeared to spend far more than the others on reducing exposure to noise,
whilst the construction sector was spending far more than the other sectors on other actions.
See chart G29 and table G18.
Chart G29
Average expenditure on activities to meet Noise at Work Regulations by sector
0
50000
100000
150000
200000

e
x
p
e
n
d
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t
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Construction
Health Services
Manufacturing
Transport
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C
Table G18
Average expenditure on activities to meet Noise at Work Regulations by sector
Agriculture/
Forestry
Construction Health
Services
Risk assessments - noise 3659 3110 3212 3604 2107
Reduction of exposure 8452 17476 192837 14424 5849
PPE 3503 3548 2680 3405 2039
Creating hearing protection zones 4194 2915 4205 4264 1595
Maintenance and review 3409 2976 2615 2862 2507
Information to staff 2983 5310 3363 2534 2897
Other actions - noise 11392 173450 4120 53505 3150
132
Appendix H
Site Visits: supporting information
133
Validation of information:
Estimations of yearly health and safety spend
In discussing expenditure on health and safety during the site visits it was found that 6 (20%) of
the organisations visited had not included the designated health and safety persons wage in the
overall estimate of yearly spend in the original questionnaire. (Health Large; Flavourfresh;
AC Whyte; HF Electrical; Thames Valley Hospice; Thistleton Lodge; i.e. 3 from the health
sector, 2 from the construction sector, and 1 from the agricultural sector). Half of these 6
organisations were from the health sector, but they varied in size category, i.e. 1 small, 1
medium, and 1 large, so there was no effect of size observed. In addition, 2 of these 6
organisations did not include employee time, e.g. when they are attending training, in their
estimations of cost. (Health Large; Thames Valley Hospice). These 2 organisations were both
from the health sector but were not in the same size category. Costs of health and safety
consultants, however, were included across the 30 organisations yearly estimations of spend on
health and safety.
On discussing the costs during the visits it was found that there was a tendency for the
interviewee to discuss other costs not reported in the questionnaire and therefore, if anything,
the costs provided during the postal survey were an underestimate of the actual costs that
organisations incurred (Transport Large, Health Medium, Thistleton Lodge).
It was reported that spend can vary widely from one year to the next. For example, one
organisation (Thistleton Lodge) stated that yearly spend could sometimes be 3 times as much
as that reported in the questionnaire, if certain equipment needs to be bought / replaced.
Based on the revised figures given by these 8 organisations discussed, we can calculate the
approximate increase in estimates for these organisations. Increases, from the original
questionnaire and after discussions around costs during the site visits, mostly ranged from 2.5
times to 4 times as much as the original quote, going on annual costs per employee. This was
the approximate increase for 75 % of the 8 organisations discussed. There were just 2
organisations whose increases were approximately 18 times as much as originally reported,
which was due to these 2 organisations having low overall costs of health and safety
expenditure, before the addition of the health and safety persons wage.
Clarification of organisation size
There were some inaccuracies observed in relation to the number of employees reported in the
questionnaire and those clarified during the site visits. One organisation, which had been
classified as large prior to the visit, was actually medium in size (OPEX). The numbers had
been exaggerated because the organisation was responsible for the safety of various
subcontractors. 2 organisations were classified as small, instead of medium, prior to the site
visit, due to inaccurate numbers originally reported in the questionnaire. (AC Whyte and
Transport Medium). This had an effect on the sample of organisations visited, i.e. there were
3 medium sized organisations in place of 1 large and 2 small. In addition, another organisation
(Morecambe Bay Hospital) reported accurate total numbers of employees for the organisation,
but omitted the figures broken down as to how many worked on the site (it was a multi-site
operation). One small organisation also omitted the companys 2 Directors from the total
number of employees but this did not affect the organisations size category. (Securitais).
Whilst this may have some effect on the survey results, there appears to be inaccuracies in
reporting across the sizes so overall implications may even themselves out. Regardless of this,
the most important results, in terms of cost comparisons, are reported as cost per employee and
therefore incorrectly reported size will not have an effect on the findings.
134
Health and safety systems
The majority of the details reported in the questionnaires, in relation to what the health and
safety systems include, were validated as accurate during the site visits. Only two discrepancies
were observed. One organisation (Site Electrical) had reported in the questionnaire that they
had performance measurement in place but during the visit reported there was no formal
method. The farm had reported that there was a health and safety policy in place, although this
turned out to not be the case.
2 of the 30 organisations (Grayston and Thistleton Lodge) included accident prevention as an
additional motivating factor to implement health and safety systems, although this reason was
not reported in the questionnaire.
Only a small proportion of organisations (two) changed their opinion, since completion of the
questionnaire, about the balance between the costs and benefits of implementing health and
safety systems. The organisations in question changed to costs and benefits broken even from
dont know, and from benefits outweighed costs to costs and benefits broken even.
(Grayston; Thistleton Lodge). It is not clear whether this was due to further information
gained since the postal questionnaire or whether this had been incorrectly reported initially.
Accidents
2 of the 30 organisations did not provide accident statistics within all of the categories within
the table in the questionnaire. During the site visits it was confirmed that the reason for this was
that the organisations classify accidents differently to those categories provided in the
questionnaire (Morecambe Bay Hospital; Hunter Wilson).
With regard to the specific regulations, the information provided was again largely accurate. 3
of the 30 organisations (Health Medium; Thistleton Lodge; JBT) reported, in the
questionnaire, that no action had been taken in relation to a certain regulation, when actually it
should have been completed as not applicable. A small proportion of organisations visited
also reported that action had been taken in categories that had not originally been included in the
questionnaire, e.g. provision of PPE and issues surrounding changes in load under the Manual
Handling regulations.
A couple of the issues within the Noise at Work regulations were beyond the control of one
organisation visited, as that particular company is contracted to work on airports and it is the
airports that have control over the noise exposure levels and hearing protection zones.
(Securitais). It was therefore not simply the case that no action had been taken, guidelines are
followed but the organisations client controls some of the specific regulation issues.
On a few occasions some of the same costs incurred were reported under more than one of the
regulations, although this was not a common occurrence and not likely to have an impact on the
overall results of the postal survey. However, in the case of a the farm visited it was concluded
that the general costs, rather than the costs reported under the specific regulations, were a better
reflection of the total costs incurred.
One-off inaccuracies
In addition, there were a number of one-off inaccuracies, between questionnaire and site visit,
amongst the 30 organisations visited. As these are one-off inaccuracies it was felt that they had
not had an impact on the accuracy of the postal survey as a whole, and therefore are not detailed
in this report.
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Health and Safety Management Systems
The nature of systems
Table H1
The nature of the health and safety systems amongst the 30 organisations visited
Designated Accident Documented Written H & S Performance Performance
H& S person reporting Risk Policy measurement targets /
system Assessments objectives
Small
4 4 4
4 4 4 4
Medium
Agriculture
4 4 4 4 4
4 4 4 4 4 4
Large
4 4 4 4
Small
4 4 4 4 4
4 4 4 4
Construction Medium
4 4 4 4 4
4 4 4 4 4
4 4 4 4 4 4
Large
4 4 4 4
Small
4 4 4 4 4 4
4 4 4 4
Health Medium
Services
4 4 4 4
4 4 4 4 4 4
Large
4 4 4 4 4 4
4 4 4 4
Small
4 4 4 4
4 4 4 4 4 4
4 4 4 4 4 4
Medium
Manufacturing
4 4 4 4
4 4 4 4 4
Large
4 4 4 4 4 4
4 4 4 4
Small
4 4 4 4
4 4 4 4
Transport Medium
4 4 4 4 4 4
4 4 4 4 4 4
Large
4 4 4 4 4
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84% of the organisations within the postal survey had formal health and safety management
systems in place (at the site at which they were interviewed). Of the 30 organisations visited,
only 1 organisation did not have formal health and safety management systems in place. The
reason given by this small agricultural business was that there were no formal regulations for
that line of business.
Within the postal survey, businesses that had formal health and safety systems in place were
asked what they comprised. Almost all had an accident reporting system (94%), a written
health and safety policy (92%), a designated health and safety person / role (90%) and
documented risk assessments (88%). Only 39% of the postal survey had performance
measurement and performance targets / objectives.
The postal survey observed that businesses within the agricultural sector were less likely to have
the various elements of the formal health and safety systems in place. For example, 67% of the
agricultural sector in the postal survey had a written health and safety policy, compared to the
other 4 sectors that were all above 90% for having a written health and safety policy in place.
Only 2 of the 30 organisations visited did not have a health and safety policy (see table 33).
These 2 organisations were both small firms from the agricultural sector. Aside from this, no
particular effect of sector was found on what an organisations health and safety systems
comprise.
97% of sites visited had a designated health and safety person, an accident reporting system, and
documented risk assessments and 93% had all these plus a written health and safety policy.
47% of sites visited had performance measurement and 40% had performance targets /
objectives. None of the 7 small organisations visited had either performance measurement or
performance targets / objectives in place. All of the 8 large organisations visited had
performance measurement and 75% had both performance measurement and performance
targets / objectives. Only 2 of the large organisations visited did not have performance targets /
objectives in place. Of the 15 medium organisations visited, 13% had performance
measurement, another 13% had performance targets / objectives, 27% had both performance
measurement and performance targets / objectives, and 46% had neither in place.
These findings therefore back-up the general findings of the postal survey, which stated that
smaller companies were less likely to have as comprehensive systems as those used within
larger organisations (e.g. within the postal survey 17% of small companies included
performance measurement vs. 71% of large companies).
How health and safety is managed
Small:
The majority of the small organisations visited had a health and safety officer or other manager
in place, who had responsibility for managing the health and safety systems in close
consultation with the Managing Director. One small organisation shared health and safety
responsibility among a few Project Managers, but again this was in consultation with the
Managing Director or equivalent. In some cases, the health and safety of the small businesses
tended to be implemented and managed by the owner of the business. The majority of the small
organisations visited had developed their systems in-house, although a small proportion had
bought in assistance from health and safety consultants.
Medium:
The majority of the medium organisations visited managed their health and safety systems via a
structure whereby a local manager (with various different role titles, e.g. Health and Safety
Manager, Quality Manager, Production Director etc.) had responsibility for day-to-day
137
management of health and safety. This designated health and safety person would then report
directly to another Director or Manager, with the systems ultimately being overseen by senior
management. In some cases, the designated health and safety person reported directly to the
Managing Director, or Board of Directors. 53% of the medium organisations employed external
health and safety consultants for varying degrees of advice. Some of the organisations had
worked with health and safety consultants on a regular basis, whilst others only used consultants
for training provision. 13% of the medium organisations visited mostly developed systems in-
house, only using consultants for occasional advice; whilst 33% did not use external consultants
at all.
Large:
The large organisations mainly managed their health and safety via a local health and safety
manager who drove health and safety on a day-to-day basis, with the health and safety systems
being approved, reviewed and overseen by an overarching Board at senior management level.
The health and safety policies, risk assessments, etc, were generally then disseminated to the
various sites within the organisation. Large organisations also tended to have the majority of
health and safety expertise in-house, meaning that they were less likely to need to seek
assistance from external health and safety consultants. However, a small proportion of those
large organisations visited employed external consultants in specialist areas.
Accidents
All of the 30 organisations visited recorded work-related accidents. Accident statistics provided
in the questionnaire were largely accurate when compared to those given during the site visits,
and documented evidence was generally provided to support this.
Small
Across the 7 small organisations visited the number of accidents that occurred in 2001 ranged
from zero accidents to 2.5 accidents per employee. The majority of these organisations reported
that the number of accidents that had occurred was generally the same year on year, without any
particular increases or decreases. The main reason for this was that those accidents that still
occurred were unpredictable ones, such as being related to handling unpredictable horses, or,
e.g. in a healthcare setting, accidents involving patients falling. One of the small organisations
reported a general decrease in accident numbers, which was perceived to be as a consequence of
greater health and safety awareness within the organisation.
Medium
Of the 15 medium organisations visited, the number of accidents that occurred in 2001 ranged
from 0.02 to 0.5 accidents per employee across the organisations. A third of the medium
organisations reported that accident numbers had remained the same over the past few years,
another third reported an increase in accident numbers and the remaining third reported a
decrease in accident numbers.
With regards to the organisations that reported increases in accident numbers, the overwhelming
perception was that the increase was as a result of raised health and safety awareness resulting
in increased reporting, rather than as a result of an actual increase in the number of incidents
occurring. In addition, one organisation perceived the increase in accidents to be as a result of
the increased claim culture across society, rather than an increase in actual accidents. Another
observation was that, although in some cases accidents may appear to have increased, this was
actually as a result of an increased workforce and that accident numbers, per employee, had
remained the same, once this was compensated for.
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Organisations did look for trends and had, for example, seen trends in relation to specific
injuries such as a high incidence of cut-hand injuries or slipping and tripping accidents. The
organisations that reported these trends had put control measures in place. The medium
organisations that reported a decrease in the number of accidents occurring largely attributed
this decrease to increased awareness and a better understanding of health and safety within their
organisation.
Large
Of the 8 large organisations visited, the number of accidents that occurred in 2001 ranged from
0.01 to 0.29 per employee across the organisations. 3 of these organisations reported that
accident numbers had remained the same over the past few years, 4 reported an observed
decrease in accidents, and 1 noted an increase. However, this increase was again perceived to
be due to an increase in reporting as a consequence of increased health and safety awareness,
rather than an actual increase in incidents occurring. A proportion of the large organisations
that had reported a decrease in the number of accidents also stated that there had been an initial
increase in reporting, following implementation of the accident reporting system and the
resulting increased health and safety awareness. One large organisation, that had reported
accident numbers having stayed the same in recent years, did however state that there had been
a marked improvement since the health and safety systems were initially implemented. The
large organisations did look for trends amongst the accidents, with particular trends including
the occurrence of slips, trips, cuts, and back injuries in one transport organisation.
In terms of the approaches taken by the organisations, with respect to implementing the
regulations, it was found that the majority of the organisations visited tended to use the
Management of Health and Safety at Work Regulations as an overall regulation, overarching the
other regulations. Most organisations implemented general health and safety aspects under this
regulation, implementing the more specific risk assessments etc under those regulations relating
to more specific hazards e.g. COSHH assessments, moving and handling training, noise risk
assessments. A small proportion of the organisations visited implemented the regulations in a
less integrated way, with this approach seeming more common amongst the small organisations.
97% of the 30 organisations visited had taken action in response to the Management of Health
and Safety at Work Regulations. Only 3% said it was not applicable.
Of those organisations that had taken action in response to these regulations, the actions most
likely to have been taken included risk assessments (100%), information and training (87%),
health and safety arrangements (86%), and health and safety assistance (83%). These were also
the top four actions taken in response to these regulations, as found by the postal survey, and in
the same order of precedence. On balance the large organisations were more likely to take
action across some of the activities, than were the small and medium organisations.
Cost Ranges:
Overall reported costs for the small organisations visited ranged from 30 to 9,150. Reported
yearly costs incurred therefore ranged from 63 pence to 915, per employee, across the small
organisations.
For the medium organisations visited, overall reported costs ranged from 2,051 to 123,000.
Reported yearly costs incurred ranged from 19 to 898, per employee, across the medium
organisations.
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Of the large organisations visited, overall reported costs ranged from in excess of 50,000 to
384,000. Reported yearly costs incurred ranged from more than 20 to 429, per employee,
across the large organisations.
Main Expenditures:
Work Regulations varied, but the small and medium sized organisations both incurred their
greatest expenditures on implementing control measures. This was the small organisations
greatest expenditure by far, with one small organisation having reported costs in excess of
100,000. One medium organisation reported implementing control measures having amounted
to costs of 50,000. This was also the activity reported as the main expenditure for these
regulations in the postal survey.
The greatest expenditure for the large organisations was incurred on health and safety
arrangements and health and safety assistance (one large organisation reported an expenditure of
135,000 across these two activities). The postal survey reported the greatest expenditure by far
was incurred on implementing control measures, followed by health and safety assistance.
Pesticides Regulations
23% of the 30 organisations visited had taken action in response to the Pesticides Regulations.
As expected, 77% of organisations said it was not applicable to them. Of the 23% organisations
that had taken action, 71% was from the agricultural sector (small, medium and large), 14% was
from the construction sector (medium), and 14% was from the manufacturing sector (large).
The number of organisations that had taken action in response to these regulations ranged quite
equally across size categories, i.e. 29% of small organisations, 20% of medium organisations,
and 25% of large organisations.
Of those organisations that had taken action in response to these regulations, the actions most
likely to have been taken included informing / training employees (100%), measures taken to
protect health (100%), gaining certificates of competence (67%), storage (67%), application
(50%). There were no differences across size of organisation in the actions most likely to have
been taken. The most common action observed in the postal survey was storage, followed by
informing and training employees, and then measures taken to protect health.
Of those visited, just 6 organisations had taken action in response to these regulations, with 2
from each of the three size categories. Overall costs for these 6 organisations ranged from a
minimum of 200 to a maximum of 5,000 per year. The minimum and maximum spend, per
employee each year, ranged from 2 to 180 across the organisations.
The amount of expenditure per activity relating to the Pesticides Regulations varied, with the
greatest expenditure incurred by providing information, instruction, training and guidance to
employees, controlling and confining application, and gaining certificates of competence
(costing the large organisations between 5,000 to 10,000 each). The postal survey found that
the greatest expenditure was incurred on controlling and confining application.
COSHH Regulations
93% of the 30 organisations visited had taken action in response to the COSHH Regulations.
7% said it was not applicable.
Of those organisations that had taken action in response to the COSHH Regulations, the actions
most likely to have been taken included assessments of risk (93%), costs of control measures
(83%), information, instruction and training (73%), and time spent deciding and implementing
(73%). These were also the four most common actions taken, as observed by the postal survey,
140
which also found risk assessments to be the most common action taken, although the other three
actions were in a slightly different order of precedence. On balance, the large organisations
were more likely to take action across some of the activities than were the small and medium
organisations.
Cost Ranges:
Overall reported costs for the small organisations visited ranged from 150 to 11,000.
Reported yearly costs incurred ranged from 6 to 324, per employee, across the small
organisations.
For the medium organisations visited, overall reported costs ranged from 650 to 35,000.
Reported yearly costs incurred ranged from 7 to 410, per employee, across the medium
organisations.
Overall reported costs for the large organisations visited ranged from 3,000 to 256,000.
Reported yearly costs incurred therefore ranged from 8 to 1,000, per employee, across the
large organisations.
Main Expenditures:
The amount of expenditure per activity relating to the COSHH Regulations varied, but the
greatest expenditure was the same across the three size categories and was incurred on
implementing control measures. The maximum spent on this activity varied according to the
size category, i.e. 7,850 by a small organisation, 16,000 by a medium organisation, and
100,000 by a large organisation. This was also the activity reported as the main expenditure
for these regulations in the postal survey.
97% of the 30 organisations visited had taken action in response to the Manual Handling
Regulations. 3% had not yet taken action, but none of the organisations visited said that it was
not applicable.
Of those organisations that have taken action in response to the Manual Handling Regulations,
the actions most likely to have been taken included risk assessments (83%), providing training
and information (70%), and changes in work practices (63%). In comparison, the postal survey
also observed the same three actions as being the most likely to have been taken, in the same
order of precedence. On balance, the small and medium sized organisations were less likely to
take action on some of the activities than were the large organisations visited.
Cost Ranges:
yearly costs incurred ranged from 6 to 325, per employee, across the small organisations.
Reported yearly costs incurred therefore ranged from 91 pence to 1,733, per employee, across
the medium organisations.
Overall reported costs for the large organisations visited ranged from 1,300 to 6.7 million.
Reported yearly costs incurred therefore ranged from 3 to 6,000, per employee, across the
Main Expenditures:
The amount of expenditure per activity relating to the Manual Handling Regulations varied,
with the greatest expenditure incurred on changes in work practices / processes (with the
141
maximum reported spend of 3,285). The medium and large organisation size categories both
reported that new equipment was their main expenditure (the maximum reported spend was
120,000 by the medium organisations and 125,000 by the large organisations). In
comparison, the postal survey reported that changes in work practices and new equipment were
the main expenditures, so the findings of the site visits again validate the survey.
70% of the 30 organisations visited had taken action in response to the Noise at Work
Regulations. 23% said it was not applicable to their organisation and 7% said it was applicable
but that action had not yet been taken.
Of those organisations that had taken action in response to the Noise at Work Regulations, the
actions most likely to have been taken included risk assessments (87%), provision of PPE
(83%), and provision of information to employees (78%). The organisations visited were least
likely to create hearing protection zones (43%). These observations are in agreement with the
postal surveys findings. Again, on balance, the small and medium sized organisations were
less likely to take action on some of the activities, than were the large organisations visited.
Cost Ranges:
yearly costs incurred therefore ranged from 25 to 114, per employee, across the small
organisations.
Reported yearly costs incurred therefore ranged from 62 pence to 150, per employee, across
the medium organisations.
Overall reported costs for the large organisations visited ranged from 350 to 125,000.
Reported yearly costs incurred therefore ranged from 92 pence to 34, per employee, across the
Main Expenditures:
The amount of expenditure per activity relating to the Noise at Work Regulations varied, but the
greatest expenditure was the same across the three size categories and was incurred on reducing
noise exposure. The maximum spent on this activity varied according to the size category, i.e.
more than 2,000 by a small organisation, between 1,000 to 5,000 by a medium organisation
and more than 50,000 by a large organisation. This was also the activity reported as the main
expenditure for these regulations in the postal survey. The medium organisations had three joint
main expenditures, which included reducing noise exposure (at a cost of 1,000 to 5,000),
provision of PPE (4,500), and provision of information to employees (at a cost of 1,000 to
5,000).
Future Costs
Organisations were asked whether or not their insurance premiums had increased / decreased
and whether or not they perceived that health and safety affected these premiums. 67% of
organisations reported an increase in their insurance premiums over recent years, with reported
increases ranging from a 20% to 30% increase, per annum, up to a five-fold increase, over the
last few years. The majority of organisations perceived this to be as a result of general increases
across the insurance market, as a result of the increasing claim culture. However, 16% of
organisations reported a decrease in their insurance premiums since the previous year, one of
which reported a 5% decrease and another stated that although overall insurance premiums had
increased, the premium pertaining to personal accident had decreased. Another organisation
142
also stated that there had been reduced price increases in insurance premiums, which were
regarded as being significant. This leaves 17% of organisations that did not state an increase or
a decrease / did not know. However, employer liability insurance was not applicable to 1 of the
organisations within this 17%.
53% of the organisations visited perceived that the health and safety systems did have an affect,
either directly or indirectly, on the level of their insurance premiums. 27% perceived that the
health and safety systems in place do not affect the organisations insurance premiums. 20%
either did not know whether there was a link and this was again not applicable to one of the
organisations within this 20%.
With regards to the future costs, organisations were asked whether or not they were aware of
any future costs, in relation to health and safety, which would dramatically impact on the costs
currently incurred. 63% reported that they were not currently aware of any such future costs.
Organisations stated that there would be the ongoing costs of training and maintaining the
current systems. 37% (i.e. 11 organisations), however, reported a number of potential future
costs, as follows:
New legislation in reducing noise exposure levels further (4 mentions).
Potential of changes to the Working Time Directive (2 mentions, both of which were
organisations from the transport sector).
The following future costs all received one mention each:
Increased client requirements resulting in extra man-hours, training etc.
Legislation changes in relation to the age of retirement would have an impact on adapting
workplace for the older workers including more safety measures for physically demanding
jobs that would not be necessary for younger workers. Another affect may be an increase in
the incidence of strains and injuries in the older worker and thus in time lost as a result.
Further documentation to provide an audit trail.
Further moving and handling training;
Extra activities to be taken on by the organisation resulting in an impact on the health and
safety costs incurred.
Cost of compliance with COSHH expected to increase.
Possible future changes in legislation around the policies for decking on vehicle
transporters.
Further action in relation to hygiene.
Protecting sites from terrorist attacks.
Investing in prevention of violence and aggression towards staff i.e. training and provision
of personal alarms.
Investing in reducing the hand-arm vibration hazard.
Future costs therefore included anticipation of possible legislative changes, changes in the
organisations activities impacting health and safety costs, increased compliance costs,
increased costs as a result of client requirements, and costs incurred as a result of increased
issues around a particular hazard.
143
Sources of Advice
Current sources of information
The organisations were asked from where they currently got their information about health and
safety. 63% of those organisations visited rely on getting information from HSEs central
resource, 43% rely on Croner, 37% on health and safety consultants, 30% on HSE inspectors,
and 27% on the Internet. The majority of the postal survey organisations relied on health and
safety consultants, followed by HSEs central resource, followed by Croner and then HSE
inspectors.
Recommendations
The 30 organisations visited were all asked whether there was any additional advice /
information that their organisation would find useful, to assist them in the development and
implementation of health and safety systems. The suggestions made are detailed as follows (in
no particular order):
More accident reports published by the HSE, i.e. examples of minor and major accidents
that have occurred and which are industry and activity specific (requested by organisations
in the agricultural and health sectors).
Written advice, from the HSE, of new regulations.
Seminars / discussion groups held for senior managers, offering free attendance would also
encourage more proactive health and safety spending. To promote a working partnership
between HSE and industry.
Clearer guidance on when and where to carry out manual handling risk assessments.
Online facility for manual handling risk assessments, e.g. in line with the COSHH
Essentials toolkit.
Improvements to the search facility on the HSE web site.
Development of a HSE recognised standardised training certifying body to ensure standards
of training and reduce costs to sub-contractors (suggested by organisations in the
construction and transport sector).
More guidance from HSE on the exhibition industry and its associated trade bodies, e.g.
extend the CDM regulations to include the exhibition industry.
HSE should work with the British Horse Society to enforce better and more consistent
levels of health and safety in the equine industry.
More advanced information on the employers legal obligation, i.e. sending out changes in
legislation or at least making them more accessible rather than only in journals, which can
be expensive. Bulletin-type information would be useful.
More information about HSEs future plans and new legislation (this suggestion was stated
by various organisations, particularly from the health and transport sectors).
Development of an overall document outlining the regulations in the form of a simple check
sheet to identify relevant ones and pointers for what to do next.
More openness and education from the HSE, so that the HSE are not perceived as a police
force. A better working relationship between HSE and industry (stated by organisations in
the transport sector).
144
A web site where an organisation could get sector-specific information tailored to the needs
and issues of that sector (health sector).
Good practice examples, i.e. how the HSE sees the new legislation working.
If guidance leaflets on the HSE web site were in downloadable format, it would be helpful.
Newly-established Firms
Of the 30 organisations visited, just 4 were newly established (i.e. established in the last 5
years). These included a small organisation from the agricultural sector, a medium organisation
from the health sector, a medium organisation from the manufacturing sector, and a large
organisation from the transport sector.
Initial source of advice and information
Initially, the newly established organisations reported having sought advice and information via:
The HSE;
The Internet;
Designated health and safety persons previous experience.
Advice from health and safety professionals sought (on an informal basis, initially).
The National Farmers Union.
Trade Associations / Societies, e.g. the British Horse Society.
Industry specific magazines.
The postal survey found that the majority of those organisations that had been established in the
last 5 years reported that they first sought information about health and safety from health and
safety consultants, followed by the HSE and then Croner.
Initial frustrations / barriers
The newly established organisations were asked if they had faced any particular frustrations /
barriers when they had first considered implementing health and safety systems. These
frustrations / barriers included:
Costs of implementation and matching the costs against operational requirements when
trying to get a business up and running. Initial setting-up costs can be high although the
ongoing costs have not been particularly significant.
Cultural issues (as the owners were from the United States and therefore not familiar with
UK requirements).
Lack of knowledge in certain areas e.g. fire safety.
Lack of experience.
The postal survey found that the primary frustrations and barriers encountered, when newly
established organisations had first considered implementing health and safety systems, were the
time required, followed by costs, lack of knowledge / skills in the organisation, and lack of
information guidance.
145
What would have been useful?
The newly established organisations were asked what would have been useful to them, when
they were initially setting up their health and safety systems. Suggestions included:
A pamphlet covering the basics of what a company needs to have in place, in order to
satisfy requirements.
More guidance at the early stage from HSE, on what was expected in terms of risk
assessments e.g. that the higher risk activities should be addressed first, instead of trying to
do everything at once.
Advice for other newly-established organisations
The newly established organisations were asked what advice they would give to other newly
established organisations that were considering implementing health and safety systems. The
advice given included:
Implement health and safety systems as soon as is practical, developing it as an integrated
part of the business.
Join local organisations for information and advice, e.g. local occupational health and safety
groups.
Seek to gain as much advice and guidance as possible, from various sources, accessing the HSE
web site initially and then in person, where necessary.
146
Appendix I
Site Visit Summaries
147
Sample Structure Table I1
Sector Activity Size Newly Established?
Agriculture Farm Small No
Agriculture Livery yard - stables Small Yes
Agriculture Horticulture: tomato growing Medium No
Agriculture Horticulture Medium No
Agriculture Animals and livestock Large No
Construction Telecommunications cabling and system Small No
Construction Electrical Engineering Company Medium No
Construction Water & Sewage pumping Medium No
Construction Exhibition Services Medium No
Construction External refurbishment Medium No
Construction Facilities Services & Management Large No
Health Services Nursing Home Small No
Health Services Hospice Medium No
Health Services Domiciliary Care Medium Site New
Health Services Nursing Home Medium No
Health Services Hospital Large No
Health Services Blood Transfusion Service Large No
Manufacturing Lumber & wood products Small No
Manufacturing Abrasive products Small No
Manufacturing Repair & overhaul of aircraft components Medium Yes
Manufacturing Industrial & commercial machinery & computer
equipment
Medium No
Manufacturing Manufacture of animal feed sold to agricultural
sector
Medium No
Manufacturing Rubber & misc. products Large No
Manufacturing Printing, publishing and allied products Large No
Transport Transportation Company Small No
Transport Aircraft fuelling Medium No
Transport Motor freight transportation and vehicle repair Medium No
Transport Transportation company Medium No
Transport Bus Company Large No
Transport Motor freight transportation & warehousing Large Yes
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List of 30 organisations visited:
Small
1. Archers Stables (Agriculture)
2. Palace Farm (Agriculture)
3. Securitais Communications Ltd. (Construction)
4. Thisleton Lodge (Health Services)
5. Hunter Wilson & Partners Ltd. (Manufacturing)
6. Manufacturing Small (Anonymous)
7. Transport Small (Anonymous)
Medium
1. Magees Nurseries Ltd.
2. Flavourfresh Salads Ltd.
3. Site Electrical (PH) Ltd. (Construction)
4. A. C. Whyte (Construction)
5. H F Electrical (Construction)
6. Opex Exhibition Services Ltd. (Construction)
7. Carewatch (Grampian) (Health Services)
8. Thames Valley Hospice (Health Services)
9. Health Services Medium (Anonymous)
10. Manufacturing Medium (Anonymous)
11. Rohr Aero Services (Manufacturing)
12. Peal Engineering Ltd. (Manufacturing)
13. Grayston Automotive Ltd. (Transport)
14. Jim Brackenridge Transport Ltd. (Transport)
15. Aviation Fuel Services (Transport)
Large
1. Agriculture Large (Anonymous)
2. Construction Large (Anonymous)
3. Health Services Large (Anonymous)
149
4. Morecambe Bay Hospitals NHS Trust (Health Services)
5. Manufacturing Large (Anonymous)
6. News International Newspapers Ltd. (Manufacturing)
7. Transport Large (Anonymous)
8. Logicom (Transport)
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Name of Organisation
Archer Farm Stables
Sector
Agriculture
Size
Small: 2 personnel (1 full time, 1 part time)
Validation of Information
A full verbal and paper validation of the information was performed. The only change, since
the questionnaire was completed, was an increase in the cost of pesticides / treatment of
weeds, which has increased by 200% to 300. The pesticides are not stored at the site and no
formal system is in place to address the Pesticides regulations specifically.
Health and Safety Systems and how they were established
The operation has only existed since October 2000 and consists of just two people working at
the site, which is run as a livery yard. There are no formal safety management systems in
place, neither are there any plans to implement any. The owner of the yard is present for up
to 7 days a week and is well experienced in the handling of horses.
Information and guidelines have been provided by the British Horse Society (BHS) and the
National Farmers Union (NFU) in relation to the requirements upon the yard owner to attain
a decent standard of operation. The guidelines are mainly aimed at the welfare of the horses,
however there is some guidance on the operators obligations for ensuring the health and
safety of the workforce and visitors. The yard owner is also working towards inclusion into
the Approved Livery Yard Scheme, this is a BHS administered scheme and is issued once
the yard owner has satisfactorily fulfilled several criteria including health and safety.
This is a very small operation where the main hazards are handling unpredictable horses and
dust. There is little benefit in implementing a formal management system, as there are only
two personnel that work at the site. The health and safety of staff and visitors is ensured by
the very close regulation by the livery yard owner and her own responsible approach. The
high levels of safety that are recommended by the BHS in treating horses and in PPE are
followed at the site. However, it is very easy for other establishments to set themselves up in
the equine industry without implementing the same levels of control.
Newly Established organisations (set up in the last 5 years)
On setting up the business, the main source of information, regarding health and safety, was
the NFU (who provided the insurance cover for the yard), in addition to the Pony Club (who
provided specific instructions and forms for accident reporting), and the BHS (who provided
guidance on the minimum standards of H&S). However, the owner and staff are very
experienced in the handling of horses and the operations of a livery yard / stables and were
already very aware of the health and safety requirements (and probably would have set up the
same systems without the advice). The BHS provide regular updates on advancements in
standards for PPE etc., and any further advice can be gleaned from Horse & Hound
magazine.
The area in which the owner had no expertise was in relation to the requirements for fire
safety and how to fight fires. The owner has not set up formal health and safety systems and
so could not give advice on setting one up, but would advise someone setting up in the equine
industry to gain a lot of experience beforehand and consult with the BHS. The costs of health
151
and safety are a minor issue, although the insurance (particularly liability insurance) is a
financial burden.
Accidents and costs of compliance
The accident statistics show that there have been a total of 5 accidents in 2001 (all of which
resulted in 1 to 3 days off work). This gives a statistic of 2.5 accidents per employee in 2001.
Statistics showed that there had been 4 accidents during 2000 (i.e. 3 resulting in less than 1
day off work and 1 accident resulting in a non-fatal major injury). The total numbers of
accidents have therefore remained approximately the same each year. All accidents are
recorded using a formal accident reporting system for staff and visitors alike. The frequency
of accidents is very high (per member of staff), although there have been no significant
incidents involving visitors. There is very little that the staff and management are able to do
to prevent accidents any further as, despite precautions being taken, the accidents have all
resulted from horses behaving erratically and unpredictably.
It was estimated that the organisation spends approximately 500 to 1,000 per year on health
and safety, providing a figure of 250 to 500 per employee per year. These health and safety
costs are not major and the benefits are perceived to outweigh them. Benefits have included
safe operation of the yard, reducing the likelihood of injuries and accidents. However, there
has been a significant increase in the premium for liability insurance (about 25% in a year),
which has come about as a result of the foot and mouth crisis and a generally hardening
insurance market. It was perceived that insurance costs are not affected by health and safety
performance. The bulk of other costs have been the training of staff and the less tangible
time costs associated with that.
Future costs and considerations
The yard owner was not aware of any specific future compliance costs that would
dramatically impact the costs currently incurred by the organisation.
Management of Health and Safety at Work Regulations: Not applicable
Pesticides Regulations: Nothing formal is carried out to comply with these regulations. The
site does not actually store or administer pesticides, but employs a 3
rd
party to treat the 10
acres of land, at a cost of approximately 360, on an annual basis. Benefits of these
regulations were considered to outweigh the costs, with benefits including making an area
usable (via killing the weeds), and the hard feed bill being reduced.
COSHH Regulations: Not applicable
Manual Handling Regulations: There are a lot of manual handling operations carried out at
the stables, especially during mucking out which is carried out daily. The owner has been
trained in the correct methods for manual handling within the environment. This has been
passed on to the other member of staff. Additionally, new pitch forks and shovels etc. are
bought (almost on an annual basis) as they rapidly become worn. The cost of these
regulations was estimated to be approximately 650 per year (i.e. 250 for the new
equipment, as detailed; and 400 for employee time). Benefits were again considered to
outweigh the costs and include an increase in staff morale and prevention of accidents.
Noise at Work Regulations: Not applicable
Information and advice
Whilst the accident statistics within the industry are not known whilst compiling this
summary, the anecdotal evidence provided by the owner and the relatively high number of
152
accidents that occur at the yard (which appears well run) do suggest that this is a relatively
high risk industry. Whilst the HSE would not be expected to influence the industry at grass
roots level (the awareness of the HSE is probably not extensive within the equine industry and
the HSE probably do not have the expertise in this area), by working with the BHS, better and
more consistent levels of health and safety could be enforced. It should be noted that there
are no minimum health and safety requirements placed upon such small operations by the
BHS and that their guidance does not have to be followed.
153
Name of organisation
Palace Farm
Sector
Agriculture
Size
Small
Background
The Farm was established over 50 years ago and the original owners son now runs the
working farm, which employs one other person on a full time basis. The 400 acres arable
farm grows Spring barley, Oilseed rape and Winter wheat. In addition, the farm currently has
50 head of beef cattle. The main hazards are chemicals for treating the crops, electricity, noise
from the wheat bruiser and manual handling. Additional hazards include dust and fumes.
Validation of information
Information supplied was largely accurate at the time of the visit and the farmers time had
been included in estimating costs of compliance. However, costs of conducting COSHH risk
assessments were reported under the Management regulations, COSHH regulations and
Pesticide regulations and therefore the costs associated with these are recorded three times in
the questionnaire. The general costs are therefore a better reflection than the costs reported
under specific regulations. In addition, the owner had reported that a health and safety policy
was in place but there wasnt a policy as such, but a risk assessment. Risk assessments
therefore were in place as reported.
Health and safety systems and how they were established
The farmer is responsible for the health and safety of himself and his employee and he shows
a high level of understanding of hazards, risks and controls required to manage these. An
accident book is held and reporting of accidents would be done through the HSE accident
reporting phone line. Risk assessments are carried out for particular hazards, particularly
those required under the COSHH Regulations. Additional assessments are in place for the
fork lift truck and noise expelled by the bruising machine. Controls are in place in each of
these cases. A training course to assist in conducting these assessments had been attended by
the farmer through the Agriculture Training Board (ATB) and the local college.
The main motivators are seen to be improved working environment for self and employee,
and legal obligations. Information on new regulations is received from the local collage and
information or questions regarding health and safety management obtained from the police,
college and ATB.
There had been very few accidents and none in recent years (last 3 years).
It was reported that between 101 and 500 is spent per annum on managing health and
safety. These costs are mainly related to insurance costs, equipment (including PPE), and
monitoring. The latter end of this range is probably more accurate when calculating the
Farmers time for assessing, monitoring and controlling risks. He estimated that he probably
spends about 20 hours per year managing health and safety. Therefore the organisation
spends approximately 250 per employee per annum on health and safety.
154
Although no affect was reported in terms of impact on specific indicators such as reduced
accidents, sickness absence, morale etc, the benefits are seen to outweigh the costs. This is
not due to any first hand experience of the costs of not taking action (prior to 1990) as there
have been very few accidents. Rather, the benefits are seen to outweigh the costs through a
realisation of what might happen if action is not taken, showing a clear understanding of the
risks. The business relies solely on the farmer being healthy enough to run the business and
the employee has been working for the farmer for a great number of years and therefore also
forms a significant asset to the business.
There has been a significant increase in liability insurance premiums in recent years and this
is not affected by the health and safety compliance or performance. This is thought to place a
significant burden on small firms of this size.
The farmer was not aware of any other significant developments that would impact on the
costs associated with health and safety management. He was confident that he would be
informed of any new developments through links with the local college.
An informal general risk assessment has been completed, yet not documented.
Pesticides Regulations
As well as an assessment of the substances used, a training course has been attended to certify
the use of pesticides. The employee is informed of the risks inherent in the use of these
substances.
COSHH Regulations
A specific risk assessment has been conducted for chemicals and pesticides used on the farm.
A course has been attended at the local college to assist in conducting such assessments. The
headings for the assessment are as follows:
Area and material (general area/activity and substance being assessed)
Where used (location)
Harmful affects (potential outcome of contact)
Advice/action (PPE to be worn, caution to be taken, safe working practice etc, safety
data sheet to follow etc)
Comments (a statement of the pathway to harm, e.g. inhalation, skin contact etc)
Emergency contacts and numbers
This assessment and associated controls form the greatest proportion of the expenditure on
health and safety. Controls are mainly in the form of PPE and provision of safety data sheets
and other safe working procedures.
Manual Handling
Risks were considered to be in relation to mechanical handling and as such an assessment of
the forklift truck has been carried out. The costs associated with this were minimal. It was
commented that the amount of handling across the industry has significantly reduced in recent
years due to introduction and wider use of big bales (moved mechanically), bulk feeds etc.
155
A risk assessment had not been conducted for manually handled load (although these are
likely to be significant).
Noise at Work Regulations:
Ear defenders are used for all noisy operations such as use of mobile bruise and mowing
grass. The costs associated with this are minimal.
Information and Advice
Currently advice and information is sought through the local college and ATB. The police
provided useful advice regarding safe us of machinery on public roads. It was thought that
better links could be established with the local HSE inspector. It was suggested that a
representative from HSE could perhaps present on health and safety courses at the local
college.
156
Securitais Communications Ltd.
Sector
Construction
Size
Small
Background
Securitais Communications Ltd. was established 10 years ago. The organisations main
activities are telecommunications cabling and systems. Securitais employs 10 people (8 full-
time and 2 part-time) in addition to employing further subcontractors when work is busy. The
staff numbers have increased by 20% since April 2002, when the organisation took on extra
work at Gatwick airport.
The details provided were largely accurate although the breakdown of full-time / part-time
employees was reported as being 6 full-time in the questionnaire, but there are also 2 Directors
who would be classified as full-time. In addition, although it was stated in the questionnaire
that time lost through accidents had decreased, this should actually have been completed as no
affect, as no accidents have occurred in the last 5 years. The only other observation was in
relation to action taken on the Noise at Work regulations. It was reported in the questionnaire
that no action had been taken with respect to reduction of noise exposure or creation of
hearing protection zones, when in fact these issues were beyond the control of Securitais. The
noise exposure and zones are under the control of the airports upon which Securitais are
contracted to work, although the organisations employees adhere to airport guidelines and
safety procedures in addition to their own.
The organisations main hazards are work at height, working on building sites, slipping and
tripping, manual handling, and vehicles / transportation. Health and safety systems include a
designated health and safety person, an accident reporting system, documented risk assessments,
and a written health and safety policy. A risk assessment is completed every time a new site is
visited. Part of an employees induction is to become familiar with a new site. The survey
officer completes the method statement and risk assessment for a new work site, generally at the
quotation stage. Employees read and review the method statement and risk assessment before
starting work at the new site to check for any changes, which may affect safety and the
information contained. If changes have taken place the employees report back for instructions
from the survey officer.
Accidents are recorded in the accident book, which is completed by any of the staff present in
the office at the time. In addition, the organisation keeps a serious reportable accidents book,
but they have not needed to use this yet. Accidents also need to be reported on the building sites
that the organisation is working on at the time of the accident. The culture of the organisation is
one that encourages the reporting of accidents.
The organisation has to adhere to site standards, and so all employees are trained to a
heightened awareness of health and safety. Employees are trained in the Construction Skills
Certificate Scheme (CSCS) in addition to the Airport Construction Training Alliance (ACTA).
PPE checks are completed annually, as is the Portable Appliance Check, in order to make sure
that all the electrical devices are safe. The health and safety policy is written internally and is
reviewed annually. All health and safety systems have been developed, and are maintained,
internally.
157
Health and safety systems were initially implemented in 1996, approximately 3 years after the
organisation began operating. Health and safety systems were introduced in conjunction with
the development of the quality system and in order to be up to standard with BAA (their main
employer), who have high quality and safety standards. Securitais were encouraged, by BAAs
lead, to consider health and safety. The safety and quality systems are inter-linked, e.g.
equipment checks form part of the quality system as well as the safety system.
The Project Manager stated that although insurance costs have escalated dramatically for airside
cover (the main area in which Securitais is contracted to work), Securitais safety performance
is good and so this industry increase has not added to the organisations insurance costs.
Securitais has, thus far, experienced zero accidents in the past 5 years, meaning that there have
been no accidents to improve on.
It was estimated that the organisation spends approximately 5,500 annually. This gives an
estimate of 550 per employee per year spent on health and safety. In addition to this figure,
extra staff have been taken on at Gatwick, for safety reasons, which would add a further
20,000 onto this figure (yet this is offset by the extra fees Securitais consequently charge
Gatwick for the work carried out).
All costs incurred have been as a result of compliance with health and safety, so have been
proactive. There have been no accidents occurring to drive reactive spend on health and safety.
Overall, it was stated that the benefits outweighed the costs. Morale has been raised, as
employees are aware that their safety is being considered. The organisation, as a whole, is more
favourably viewed as a result of the safety training the staff has undergone. In addition, BAA
has recommended Securitais to other organisations for other work, as a result of them having
quality and safety systems in place.
The organisations health and safety spend has increased significantly due to increased
requirements by BAA at Gatwick and Heathrow. This has taken the form of extra man-hours in
extended inductions on all new sites even for the very small installations. This is needed as
employees work on-site but it is often disproportionately costly. Extra costs are incurred in
relation to training for ACTA passes and CSCS registration, which can overlap in terms of
health and safety. Either or both can be required to gain access to the site, depending on the site
manager. Additional training courses are also required, for all technicians, in order to gain
access to electrical plant rooms.
Specific regulations
Management of Health and Safety at Work Regulations: risk assessments and method
statements have been developed for most tasks that are undertaken. Risk assessments are
carried out for all new sites and generally take about 4 hours to complete, depending on their
complexity (this includes the site survey, working out the assessment and the documentation).
Staff have been issued with instructions on PPE, safety equipment etc.; and site observations,
equipment safety checks, and PPE checks are carried out. Staff attend site inductions,
information is circulated to staff, and a supervisor is responsible for the team. In terms of
procedures for serious and imminent danger, hazards are identified in risk assessments and
method surveys, and contacts are entered into the methods for each site. Difficulties in
implementing these regulations arose with respect to finding the time to develop the systems
and gaining the information with help from Croner. The cost of these regulations was estimated
to be 915 per employee. The benefits have outweighed the costs in that staff are safer on sites
and more contracts have been won due to the organisation being safety competent.
Pesticides Regulations: N/A
158
COSHH Regulations: company use of substances was examined and COSHH assessments have
been written. All staff have been issued with a copy of the COSHH assessment and the
associated instructions. Overall, however, COSHH is not a significant risk for this organisation,
as the employees do not work with chemicals, only use of alcohol, which is low risk. The cost
of these regulations was estimated to be 28 per employee.
Manual Handling Regulations: staff have been instructed in appropriate lifting techniques and
existing practices have been reinforced. Gloves and safety footwear have been issued to staff.
On-site rules / practices are also adhered to, in addition to their own company guidelines. The
cost of these regulations was estimated to be 161 per employee. Benefits are viewed to
outweigh the costs, although the benefits are not tangible. There have been no injuries, which is
assumed to be as a result of training people how to lift properly and, in addition, PPE has made
provision for employee safety.
Noise at Work Regulations: the organisation carries out a lot of work at airports and BAA
guidance bulletins are adhered to. Employees have been issued with information regarding
exposure to noise and have been provided with ear defenders. The induction also covers
information re: noise levels. Reduction of noise exposure at source is beyond the control of the
organisation, as employees are contracted to work on airport sites. Creation of hearing
protection zones are controlled by the airport and adhered to by Securitais employees. The cost
of these regulations was estimated to be 60 per employee. Benefits again outweigh the costs as
hearing is being protected, and the organisation is viewed more favourably, for being safety
conscious.
Currently, advice and information is sought via health and safety consultants, Croner, and
HSEs central resource. Securitais receive regular advice from Croner already, which issues
them with bulletins regarding all the latest changes to the law etc. Croner also has a help desk,
which they have found useful. The organisation has not had any problems thus far in terms of a
lack of information.
159
Thistleton Lodge
Sector
Health Services
Size
Small: 48 staff (37 full-time and 11 part-time)
Background
Thistleton Lodge was established 16 years ago and is a nursing home that currently provides
general care for 60 elderly clients.
The details provided were largely accurate, although accident prevention was added as a
further motivating factor behind deciding to implement health and safety systems. Discussion
surrounding the estimated spend on health and safety in the last full financial year revealed
that some years spend could be 3 times as much as that reported in the questionnaire, if
certain equipment, such as hoists, needed to be bought. With respect to the costing of spend,
both in relation to general health and safety systems and specific regulations, it was found that
costs of employee time involved in developing and monitoring health and safety were not
included in the estimations. The cost of the designated health and safety persons wage was
also not included. Other inaccuracies were noted in relation to the organisations outcomes.
As reported in the questionnaire, compensation claims had not decreased, they were about the
same; insurance had increased five-fold rather than remaining the same; and sickness absence
was constant rather than showing a decrease. It was reported in the questionnaire that the
benefits outweighed the costs, yet it was stated in the visit that the costs and benefits were
more likely to have broken even. The only other inaccuracy in reporting was concerned with
the Pesticides regulations. It was stated in the questionnaire that no action had been taken,
when actually these regulations are not applicable to this organisation.
The organisations main hazards are manual handling and fire risk. The health and safety
systems include a designated health and safety person, an accident reporting system,
documented risk assessments and a written health and safety policy. The Health and Safety
Officer formulated the original health and safety policy in conjunction with assistance from
senior management. All health and safety systems were developed in-house.
The accident reporting system consists of documentation of accidents in an accident book
(there are two accident books: one for the staff and another for the residents). Any severe
accidents would be reported to HSE. Near accidents are also documented, especially those in
relation to moving and handling, so that the organisation can build preventative measures. It
is part of all the employees responsibility to make sure that they report all accidents. The
Health and Safety Officer monitors the accident records every 3 months.
The organisation has documented risk assessments in place and these include a risk
assessment for every client (in relation to moving and handling), in addition to an
environmental risk assessment for every room. The moving and handling risk assessments
have been in place for about 3 to 4 years, whereas the environmental risk assessments have
been in place for over 2 years. Both types of risk assessment take approximately 15 minutes
to complete.
160
The health and safety systems are updated yearly by the Health and Safety Officer. Health
and safety systems have been in place for 16 years, since the organisation began operating.
The motivating factors behind the organisations decision to implement health and safety
were largely as a result of legal obligation, although supplier / customer / client pressure was
also a factor (the organisations governing body stated that the Lodge must have health and
safety and risk assessments in place). In addition, Thistleton Lodge also undergoes a biannual
inspection of their policies, in order to make sure that they are being implemented, which also
provides them with accreditation from RDB. Further motivating factors consisted of accident
prevention, health and safety publicity, HSE / Local Authority Inspector visits, and insurance
costs. The organisation has found that their insurance costs have increased five-fold in the
last few years (they have not experienced any reductions as a result of having health and
safety systems in place).
The accident statistics show that there have been a total of 24 accidents in 2001, all of which
resulted in less than 1 day off work. There were no occurrences of accidents resulting in a
period of 1 day or more off work. This gives a statistic of 0.5 accidents per employee in the
organisation, in 2001. The Health and Safety Officer did not have immediate access to the
previous 5 years accident statistics, although it was felt that accident numbers had remained
approximately the same, with no major increase or decrease overall. The majority of
accidents are client falls and these are not predictable.
It was estimated that the organisation spends approximately 1,000 a year on health and
safety. This estimate provides a figure of 20.83 per employee per year. However, it was
also stated that hoists cost 1,500 to 2,000 each, meaning that the costs of health and safety
can range from 1,000 to 5,000 some years. Costs also include staff courses (such as
manual handling training, basic health and safety training, fire safety training) and provision
of warning signs, etc. The majority of the health and safety costs are considered to be
proactively spent on compliance, although there are some costs associated with time spent
observing and monitoring the frequency of accidents / measuring trends, resulting in some
implementation on a reactive basis.
It was considered that the costs and benefits had broken even. Benefits included a reduced
risk of accidents, increased staff morale through raised health and safety awareness, and
providing legal cover for the employer.
The Health and Safety Officer was not aware of any future compliance costs that would have
an impact on the current costs incurred.
Management of Health and Safety at Work Regulations: the organisation has environmental
risk assessments and individual manual handling risk assessments, which each take
approximately 15 minutes to complete. Accident books are in place and are monitored every
3 months. There are policies in place covering procedures for serious and imminent danger.
Training is provided externally by Lancashire Care Association, but everything else is
developed and managed internally. Health and safety topics are also discussed during an
employees induction. Difficulties have only arisen in relation to finding the time to develop
the systems, e.g. the environmental risk assessments took the Health and Safety Officer a
weeks worth of work to develop. The cost of these regulations was estimated to be 30 in
total, which is just the cost of the accident books each year (a cost of 63p per employee each
year). However, this estimation did not include the costs of employee time, such as
developing the policies, developing and conducting the risk assessments, employee time spent
161
on training and the yearly wage of the Health and Safety Officer. Costs and benefits were
considered to have broken even, with the main benefits being that the organisation is covered
legally and organisational reputation is enhanced.
COSHH Regulations: COSHH assessments have been completed, there is a COSHH policy in
place, instructions are issued to all new staff on induction, and gloves and aprons are
provided. The Health and Safety Officer formulated the policy but the housekeeper oversees
it, as she is the only employee who deals with hazardous substances. The rest of the staff do
not have to deal with hazardous substances, so COSHH is not applicable to most staff. The
cost of these regulations was estimated to be 300, which is the yearly cost of providing the
gloves and aprons and gives a statistic of 6.25 per employee per year. Employee time was
again not included in the overall estimations of cost. Costs and benefits were again
considered to have broken even and benefits included safety and health benefits for the
housekeeper, and implementation providing legal cover for the organisation.
Manual Handling Regulations: there are manual handling risk assessments in place, and 3
key movers have been employed by the organisation. Changes in work place practices,
changes to the work environment and changes to the load are all ongoing procedures.
Equipment is maintained every 6 months by FISC, and assessments and controls are reviewed
and monitored as an ongoing procedure. Training is carried out internally on induction, in
addition to further training that is externally provided, consisting of a 3 day key moving and
handling training course for some staff, who then go on to train the other staff in the
organisation. Problems in implementing these regulations have arisen in relation to making
sure staff adhere to the policy, i.e. properly moving and handling is more time consuming and
when staff want to get it done more quickly they are not doing it properly, thereby increasing
the risk of injury. The cost of these regulations is estimated to be 300, which is the yearly
cost of providing the gloves and aprons, giving a statistic of 6.25 per employee per year.
This is, however, the same 300 as that quoted for the COSHH regulations, so it is an overall
cost for all gloves and aprons across both regulations. Once again, the cost of employee time
was not included in the estimations of spend. Benefits were seen to outweigh the costs and
included: health benefits, when the policy is implemented properly through reduced injuries;
increased staff morale; and, reducing the risk of legal comeback on the organisation.
Improvements have been directly observed via a reduction in the frequency of manual
handling injuries since the moving and handling training has been in place.
Noise at Work Regulations: N/A
Currently such advice is sought through HSE and Local Authority inspectors.
The Health and Safety Officer would like more advanced information on an employers legal
obligation. The organisation would find it helpful if information, in relation to changes in
legislation specific to the health industry, could be sent out or could be made more accessible.
Although updates in legislation might be found in various publications, SMEs may not have
access to these and so may be continuing to follow old guidance without being aware that
they have changed.
162
Hunter Wilson & Partners Ltd.
Sector
Manufacturing
Size
Small
Background
Hunter Wilson & Partners Ltd. was established in 1971, and has been based on its current site
for the last 12.5 years, operating in lumber and wood products. The organisation is a timber-
rounding mill, one of only 3 in the UK, also carrying out contract timber treatment. There are
13 members of staff, which includes the 2 owners, 9 full-time employees, 1 part-time
employees, plus a further part-time employee who comes into the organisation just once a
week for 2 or 3 hours at a time.
The details provided were largely accurate, although the organisation had been operating for
just over 30 years, which had not been reported in the questionnaire. Accident statistics had
not been provided in the questionnaire, but estimations of these were provided on the visit.
Some of the costs provided for the specific regulations sections were yearly and some were
one-off, and so the site visit enabled identification of this classification of costs. In terms of
the Manual Handling regulations, PPE had been provided to employees, although this had not
been reported in the questionnaire. Likewise, in relation to the Noise at Work regulations,
some control measures relating to reduction of noise exposure, in addition to creation of a
hearing protection zone had been implemented but had not been reported in the questionnaire.
The organisations main hazards are vehicles / transportation, manual handling, and chemicals
(timber treatment). The health and safety systems include a designated health and safety
person, an accident reporting system, documented risk assessments and a written health and
safety policy. The designated health and safety person comes into the organisation once a
week and spends 2 or 3 hours managing the health and safety data, reporting to the Managing
Director who has ultimate responsibility.
The Managing Director enters accidents into the accident book once the foreman has reported
it to the office. There have been no accidents for the past 6 months, so accidents have not
been reviewed for a while. There have only been a total of 12 entries in the accident book
thus far, and these usually consist of cut hand injuries. The foreman has completed a first aid
course and all employees know to report accidents to the foreman and / or office.
The organisation has document risk assessments in place, which were developed by the
Managing Director and are carried out annually in October. It takes 3 employees (the
foreman, the health and safety person, and a workshop employee) approximately 1 day to
complete the whole risk assessment operation. The risk assessments are also reviewed
annually by the Managing Director and the health and safety person.
The Managing Director developed the health and safety policy, which is only updated if any
major changes take place, e.g. a change in work processes, or a site change. Every employee
has a copy of the health and safety policy.
The health and safety systems were first introduced in 1997, with motivating factors behind
the decision to implement these systems including health and safety publicity, legal
163
obligation, and trade / groups federations. The Managing Director attended a seminar run by
the Forest Products Association (FPA), where he met HSE representatives and discussed the
organisations operations. As a result of this, the MD found out the controls that needed to be
in place and invested a lot of time and effort during the following year developing the health
and safety systems. All systems were developed internally, although a health and safety audit
is carried out annually by a health and safety consultant, providing recommendations for
action.
Insurance premiums have increased substantially over the last few years, increasing by 20%
each year. The Managing Director asserts that the organisations insurance premiums are not
affected by the health and safety systems in place.
There have been no accidents in the last 6 months and there are only 12 entries in the accident
book altogether. The Managing Director estimated that there had been two incidents resulting
in 1 to 3 days off in the last 5 years, plus one chemical contamination about 2 years ago,
which resulted in long-term sick leave. The organisation has not had any incidents resulting
in less than 1 day off work. This total of 3 accidents gives an approximate statistic of 0.23
accidents per employee in the last 5 years. There have been no fractures or serious injuries in
the last 5 years. It was felt that accidents had decreased overall, due to all employees now
being much more aware of health and safety.
It was estimated that the organisation spends approximately 3,000 to 4,000 a year on health
and safety. This includes employee time, electrician costs (electric inspections are at least
200 a year), putting extra guarding on machines, and the annual health and safety audit
carried out by a consultant. This estimate gives an approximate figure of 230.77 to 307.69
per employee per year. The majority of the organisations spend was reported as being
proactive, complying to meet the requirements of inspections and regulations.
The Managing Director did not know whether or not the benefits of implementing health and
safety had outweighed the costs (or vice versa). Performance / productivity of employees has
decreased as a result of the extra safety measures that need to be taken and heeded. However,
benefits include a raised awareness amongst employees, in addition to managements mind
being at ease due to being up to date with the regulations.
The organisation was not aware of any future compliance costs that would have a dramatic
impact on the current costs incurred. The regulations in relation to fork lift seat belts have
increased costs for the organisation, in that the fork lift operators are in and out of their trucks
all the time, meaning that complying to these regulations reduces productivity by 50% in
some cases.
Management of Health and Safety at Work Regulations: the organisations risk assessments
are carried out over 1 day per year; employees are trained, and one person is employed part-
time to keep all the health and safety records. With respect to health surveillance, employee
exposure to chemicals is monitored and 2 employees are trained in first aid. Implementation
of control measures is an ongoing management operation. Difficulties in implementing these
regulations have only arisen in relation to finding the time needed to develop and manage the
systems. The cost of these regulations was estimated to be 2,500 a year, which is
approximately 192.31 per employee per year. In addition to these yearly ongoing costs of
complying / management time, there have also been one-off costs, which have included 650
for training 2 employees in first aid. Benefits were considered to have outweighed the costs
and include a raised awareness of health and safety across the organisation, in addition to a
164
much more open culture, as employees are not afraid of coming forward with any issues
relating to health and safety.
COSHH Regulations: COSHH assessments are in place and employee exposure is monitored
via quarterly tests. Training courses are provided to employees who are required to deal with
such substances, with minor training updates provided every 3 years. When implementing the
COSHH regulations, the organisation had access to technical back up, provided by its larger
client companies. The cost of these regulations was estimated to be 1,000 a year, which is
approximately 76.92 per employee per year. This includes the assessment of risk,
management time, and the quarterly tests. The organisation has also experienced one-off
costs, which include the capital cost of extra storage and bunding (7,850), and training for 2
employees. Benefits were again considered to outweigh the costs, with the organisation
having improved generally, being much tidier and safer. Further chemicals will be substituted
within the next 18 months, due to new EC legislation within the timber industry.
Manual Handling Regulations: the organisation has risk assessments in place and has
provided PPE to all employees (gloves and safety boots). Changes in work place practices
have been implemented, through installation of extra lifting and packing equipment. Loads
are now rolled instead of being lifted, which was one of the risk assessment actions. The cost
of these regulations was estimated to be 1,190 per year, which is approximately 91.54 per
employee per year. The installation of extra lifting and packing equipment was an additional
one-off cost of 3,285. Benefits were considered to outweigh costs as there have been no
strains or injuries due to an improved environment and improved practices.
Noise at Work Regulations: a noise assessment has been undertaken by an external consultant
and the organisation have reduced noise exposure by providing silencers etc. Hearing
protection zones have been created, and such zones have been designated with signs.
Employees have also been supplied with hearing defenders and are aware of noise issues via
verbal discussion. The cost of these regulations was estimated to be 852 per year, which is
approximately 65.54 per employee per year. The reduction of noise control measures (250)
and the noise assessment (625) were additional one-off costs. The noise assessments only
have to be done once every 3 years. Benefits were again considered as outweighing the costs,
although these benefits are not tangible, being more a generation of piece of mind through
knowing noise exposure has been taken into consideration and acted upon.
Currently, advice and information is sought via Health and Safety consultants and Local
Authority inspectors.
The Managing Director reported that an overall document outlining all the regulations would
be helpful. It was suggested that this take the form of a simple check sheet (one or two sides
of A4) that organisations can work through and identify which regulations are relevant to
their particular operations. It could also include pointers / places to go for further information
re each regulation e.g. a reference, web-site address or phone number. This would enable
organisations to quickly identify which regulations they needed to take action on. The
Managing Director has found information to be very piecemeal in the past.
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Anonymous
Sector
Manufacturing
Size
Small
Background
The organisation is a family-owned company that was established in 1976 and currently
employs 34 personnel (i.e. 24 full-time and 10 part-time). The organisation operates on two
sites: one in the town centre and the other in a purpose built unit on an industrial park. Pressure
to meet regulatory expectations has resulted in the company gradually moving production
activity to the industrial park. Over the last four years this development has resulted in
significant ongoing costs, including the moving of equipment and personnel between the two
sites.
A follow up interview was arranged with the Company Secretary, although the H&S
responsibility has recently been passed to a General Manager. The interview covered all the
responses in the original questionnaire and although it was not possible to evaluate the system
documentation, we were able to gain a comprehensive insight into H&S costs and benefits.
The organisations main hazards are fire (from packaging), fumes (extraction systems are in
place), small-scale chemical storage, man-machine hazards (semi automated processes in place),
and dust. The health and safety systems include a designated health and safety person, an
accident reporting system, documented risk assessments, and a written health and safety policy.
The General Manager has recently taken over responsibility for health and safety, reporting
directly to the owner of the business, who oversees the policy.
The management system was devised and implemented in 1998/99 and has been effectively
introduced on both sites. The business was established in the 1970s and so for many years the
company has been operating without a health and safety management system. There was some
initial concern that the commitment would not be sustainable although there is now more
confidence that the system is effective and works well. The main motivating factors, behind the
decision to implement health and safety systems, were the legal obligation, as a result of
pressure from regulatory inspection, health and safety publicity, in addition to the development
of the quality management system at the same time.
There have only been a small number of accidents over the five-year monitoring period and
most of these incidents have resulted in minor first aid. The cost implications overall have been
significant and they have been seen by the company as the primary reason for falling
profitability over the last few years. Most of the capital expenditure has been on working
environment improvements such as better air quality and, hence, improved occupational health.
There have been a small number of more significant accidents resulting in more than four days
off work. The ongoing costs have been of the order of 5,000 each year, with training and
specialist advice incurring the greatest cost. This provides an estimate of approximately 147
per employee, spent on health and safety, each year.
The main benefits have been difficult to quantify in monetary terms but more effective H&S
management and reduced price increases in insurance premiums were regarded as significant.
166
Better work planning and improved working practices and procedures were regarded as
secondary benefits but again it was difficult to put an exact value on these contributions.
The General Manager was not aware of any future compliance costs that would dramatically
impact the health and safety costs currently incurred aside from the ongoing costs of the gradual
movement of production activity from the town centre site to the industrial park.
Management of Health & Safety at Work Regulations: Initial commitment was found to be
onerous with the risk assessments taking up a considerable amount of management time. In
1999 the Local Authority and HSE threatened the company with possible closure, due to the
quantities of solvent emitted in an uncontrolled way from company operations. On moving and
establishing manufacturing activity in a purpose built unit away from the town centre it was
assumed by the company that regulatory pressure would reduce. The general feeling however,
is that the pressure has increased even further. The pressure has been relentless with a relatively
poor relationship between the company management and the HSE inspector in particular. Risk
assessment procedures are now well established and training (at a cost of 800 per year) has
been provided where appropriate. The initial design and build of compliant systems cost in the
region of 100,000. An additional 30,000 was incurred in relation to implementing a plan of
existing systems with regard to fire and explosion risks. Risk assessments were developed with
the aid of consultants, at a cost of 4,000. No major benefits have been identified as of yet.
Pesticides Regulations: Not applicable.
COSHH Regulations: Foam and production chemicals are stored on site but only small
inventories are involved. Foam is bought in bulk and stored both inside and outside the main
production building. Small quantities of chemicals are stored on site in a lockable storage area.
The General Manager is responsible for maintaining the COSHH procedures. It was estimated
that the total cost of implementing these regulations had been approximately 11,000, although
some of these costs incurred overlap with those for the Management of Health and Safety at
Work Regulations. The majority of these costs were incurred through the assessment of
chemicals used, elimination of certain chemicals, and testing for alternatives. Employee health
is monitored via occupational health monitoring once a year (at a cost of 800 per year).
Manual Handling Regulations: Bulk materials are palletised. Forklifts are used where possible
to minimise the amount of manual intervention. Production processes are now heavily
automated and so the level of manual intervention has again been minimised. Ongoing training
requirements and risk assessments are the main costs. Benefits have included a reduction in
time lost through accidents due to back injuries, in addition to an improved sick leave
performance associated with a reduced incidence of back pain etc.
Noise at Work Regulations: Noise levels are generally not a problem although there are a small
number of production processes that require PPE. Generally the staff observe the PPE
requirement but some of the younger, less experienced, staff need reminding. The cost of
implementing these regulations was estimated to be 2,450, with the largest estimated
expenditure being drawing up plans to create a room for the vibrating coating machine
(approx. 2,000), although this has not been created as of yet.
Advice and information is currently sought via HSEs central resource and Local Authority
inspectors.
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Name of Organisation
Anonymous
Sector
Transport: Transportation of beer in kegs throughout the UK and palletised transportation
throughout Europe.
Size
Small: 24 personnel
Validation of Information
A full verbal and paper validation of the information was performed and all responses in the
postal survey were reviewed and confirmed as correct.
Health and Safety Systems and how they were established
The organisation has been in operation since 1980 and moved to its current location in 1998
during an expansion of the business. It was shortly after this that the company was taken to a
tribunal by an employee, for unfair dismissal following gross misconduct. There were no
health and safety implications of the tribunal and the company were found to have been
justified to have taken the steps they had, but it highlighted to management that they did not
have as rigorous a system in place as they should have. Additionally, the ethos of the
company was changing, as the operations were becoming much bigger and more widespread.
The H&S management role is taken by one of the Transport Managers, although the
Managing Director has a very active role in H&S and the two have been trained to a basic
IOSH standard. The company also became ISO 9001 registered at the same time as setting up
the formal H&S management systems, although these were not integrated in any way. There
was no perceived common ground between the two systems.
The organisations insurance premiums have increased by 30% in the last year and the
Managing Director assumes that the companys health and safety performance affect these
premiums.
All accidents and incidents of ill health are recorded, the former being very accurate, although
due to the imprecise descriptions of illnesses, those records are not considered to be wholly
accurate. The time and costs associated with the recording are considered very small due to
the small number of staff and the low frequency of accidents and illnesses.
Likewise, the cost of implementing the H&S systems is not perceived as major, the systems
were set up in a very efficient manner with assistance from the trade body (Road Hauliers
Association) and an external consultant, although the spend on the latter was minimal. The
management time spent in implementing the systems was very small (no more than a day
each). The hazards associated with their activities are well known and not huge when
compared to other industries. The management now feel that the benefits they gain for
implementing the systems outweigh the costs due to general peace of mind and the fact that
the amount of sickies being thrown seems to have decreased.
The Managing Director was not aware of any future compliance costs that would have a
dramatic impact on the costs currently incurred. Changes in the Working Time Directive may
affect costs in the future, but it was perceived that this would not be significant.
168
Management of Health and Safety at Work Regulations: After qualification in basic H&S
management (obtaining their IOSH certification) the management realised that they had to
take action on these regs and did so internally; the HSE website was a very useful additional
source of information. Most of the expenditure as a result of the actions taken was in
hidden time costs and there was very little specific capital outlay. The costs of maintaining
the systems are not seen as significant.
Pesticide Regulations: Not applicable
COSHH Regulations: Not applicable
Manual Handling Regulations: Upon completion of the IOSH training course, the MD &
Transport / H&S Manager implemented the systems to comply with these regulations. At the
same time, the company won a major new contract with a local brewery to deliver their kegs
to local pubs, which would entail a high amount of manual handling - much more than other
employees would normally be exposed to. The first action taken to comply with these
regulations was to ensure that the drivers and delivery men received manual handling training
which was provided by the clients own physiotherapist. The managers observed the training
and also spent a few days with the men to gain experience of the issues that their employees
faced.
As a result of these actions, the absence rate from manual handling injuries is much lower
than management had anticipated before the new contract started. The benefits of the training
and the measures taken by management are definitely proportionate to the expenditure and
management believes that the number of accidents is much lower than if the training had not
been conducted. One concern is cultural however, as PPE and instruction is provided to
personnel, but once off site and away from management, there are no guarantees that the
workers use the PPE or training correctly.
Noise at Work Regulations: Not applicable
The organisation looked to implement more systematic approaches to health and safety
following a tribunal hearing. This particular company grew from a very small operation to
having 24 employees and the responsibilities upon management to comply with regulations
were not properly understood. There had been various mail shots and correspondence from
H&S consultants, but these were largely considered to not be relevant. There was very little
information from the HSE, although the company was in regular contact with the trade
association.
The company is now well aware of the HSE, but feels that there is a fear of the organisation
within companies, as they are reticent to raise any concerns / ask for advice as the HSE are
perceived to cause more problems than they would solve (i.e. the HSE may take a keener
interest in the company than if it had not notified them of its presence). A bit more openness
and education from the HSE as opposed to being perceived as a police force would be
welcomed.
169
Magees Nurseries Ltd
Sector
Agriculture
Size
Medium: 50 personnel
A detailed interview took place at Magees site to confirm the questionnaire responses. All
responses were consistent as far as could be assessed. There was not much scope for the
examination of paper records.
The organisations main hazards are pesticides (for specified requirements, as the mushroom
growing is primarily organic), moving machinery, and electrical hazards in the pack house.
Manual handling is not a problem anymore, due to automation.
The main motivating factors, behind the organisations decision to implement health and safety
systems, were in order to minimise insurance costs, as a result of commercial pressure from the
supermarket supply chain, and also due to publicity in terms of concern over growing litigation
issues in general.
Although the current operation has been in business for approximately 40 years, formal health
and safety systems have only been in place since 1990. During this period there have been
considerable increases in compliance and supply chain pressure. More recently, the supply
chain expectations have tended to dominate even more. Magees are dependent on a small
number of large contracts to keep them in business. They have moved from tomato wholesale
into mushroom growing for supermarkets. Initially, as a niche product, there was a reasonable
margin on the product but now mushrooms are considered to be a commodity and there is
considerable financial pressure on the business. The supermarkets have become increasingly
demanding in all areas of the business and not just product quality. Health and safety
performance is an area the supermarkets are showing an increasing interest in, together with the
growing and process efficiencies in the pack house.
Gradually the health and safety system has become more extensive as the demands on the
business have been felt. It has been a case of incremental development over about ten years.
The business manager has overall responsibility for health and safety performance.
There is a well-established accident reporting system in place but no regular records of ill health
are kept, except for basic absence records. Depression and bad backs however, were perceived
to be the most frequent reasons for taking sick leave.
The accident statistics show that there were a total of 3 accidents in 2001 (i.e. 2 that resulted in
less than 1 day off work, and 1 that resulted in 1 to 3 days off work). This provides a
statistic of 0.06 accidents per employee in 2001. Statistics also show that there has been a total
of 10 accidents in the last 5 years (i.e. 5 that resulted in less than 1 day off work and 5 that
resulted in 1 to 3 days off work).
There have been no major accidents on the site. Most of the incidents that have arisen have
resulted in minor first aid, with superficial cuts or bruising. There has been some concern
expressed recently regarding the new pallet and tray storage systems that the supermarkets are
now using. They appear to be more difficult to handle manually and there is a tendency to stack
170
them higher than the previous handling arrangement. There is a feeling at the site that this has
compromised an inherently safer approach.
The costs incurred for safety improvements have been gradually mounting and there is a general
feeling in the business that this is putting them at a competitive disadvantage with their
European competitors. Training costs have been the most significant level of health and safety
investment, with an overall health and safety spend estimated to be approximately 5,000 across
the business, per year. This works out to be approximately 100 per employee, per year, spent
on health and safety. Benefits have been difficult to quantify, displayed via a gradual
improvement in health and safety awareness and better working practices across the
organisation.
The organisations Director was not aware of any future costs that would dramatically impact on
the health and safety costs currently incurred.
Management of Health & Safety at Work Regulations: Compliance with these regulations
probably incurs the greatest cost, but it is perceived that the benefits do outweigh the costs. The
initial risk assessments took some time to complete, although the ongoing requirements are
more modest. The cost of implementing these regulations has been estimated to be 6,100 per
year (i.e. approximately 122 per employee), although there will be increases in this
commitment as more staff need to be put through training. The induction training for new staff
also involves a significant cost. The only difficulty in implementing these regulations was a
lack of time to commit to the regulations initially. The benefits perceived are primarily
associated with better and safer working methods and it is difficult to quantify the exact
amounts.
Pesticides Regulations: Only applicable to a small number of jobs and it is not a routine
operation. Mushroom production is essentially an organic process and so pesticide applications
are only used occasionally. Costs incurred have mainly been for awareness training and
pesticide storage facilities, totalling in the region of 3,800 (i.e. approximately 76 per
employee). Benefits are perceived, rather than a value put on these. Better occupational health
is the primary benefit.
COSHH Regulations: Initial costs to set up were quite high, but now that the system is in place
the ongoing costs are minimal. A chemical store is on site and a small number of staff maintain
the COSHH records. Initial costs were considered to be around 5,000 in manpower and
system costs. Ongoing costs are estimated to be 650 per year (i.e. 13 per employee). Main
benefits are now associated with better risk control and a safer working environment, although it
is difficult to put a value on this.
Manual Handling Regulations: Not considered to be relevant.
Noise at Work Regulations: Not considered to be relevant.
The main concern at Magees is the relentless external pressure regarding compliance
particularly from the supermarkets. It is acknowledged that a safe working environment is also
a productive working environment, but the price competition in the market is putting
considerable commercial pressure on the business. The advice and support from HSE has been
useful but European competition does not seem to have to incur these costs.
Advice is currently sought via HSEs central resource and via the Federation of Small
Businesses.
171
Flavourfresh Salads Ltd.
Sector
Agriculture / Forestry: Horticulture
Size
Medium: 110 employees working all year-round in a full-time position (plus a further 190 part-
time staff working seasonally during the summer months only).
Background
Flavourfresh Salads Ltd. is a horticultural organisation, whose main activity is growing
tomatoes. The number of staff working for the organisation therefore increases during the
summer months, when tomato picking takes place. The site has been operating for 30 years,
although it has only been operating as Flavourfresh Salads Ltd for the last 5 years.
The details provided were largely accurate although, in considering the effects of health and
safety action taken it was identified that, whereas in the questionnaire no affect had been
stated with regard to performance / productivity of employees, productivity had actually
increased. It was also noted that, in the organisations estimation of the yearly spend on general
health and safety, the costs of the designated health and safety persons wage was not included
in their estimate. The other inaccuracy identified was in relation to the organisations annual
turnover which, in discussion during the site visit, was reported as being 25% more than the
figure reported in the questionnaire data.
The organisations main hazards are employees cutting their fingers with knives, slipping /
tripping, chemicals, and working at height. The health and safety systems include a designated
health and safety person, an accident reporting system, documented risk assessments, a written
health and safety policy, and performance targets / objectives. The health and safety systems
were first introduced 5 years ago, when the organisation employed the health and safety
manager, who had previous experience of health and safety implementation. The health and
safety manager writes the health and safety policy, although the Board of Directors has ultimate
responsibility for the policy.
The accident reporting system consists of an accident book which is kept on site and completed
when an accident occurs, either by the person involved in the accident, or by their manager.
Accidents are monitored yearly, unless an accident resulting in more than 3 days off work
occurs, in which case an immediate accident investigation is carried out. Employees are
encouraged to report all accidents, although the health and safety manager cannot be certain that
all accidents are reported. 85% of accidents in the organisation are caused by a lack of care on
the part of the individual. The performance objective is to achieve a status of no accidents
occurring within the organisation.
The organisation has a number of documented risk assessments, such as those completed for
crop spraying, acid handling and tomato picking. It is estimated that it takes about a day to
complete and fully document one of these risk assessments.
The health and safety systems were introduced 5 years ago due to a combination of factors: a
designated health and safety person was employed, who had previous experience of accidents in
the rail industry, and wanted to transfer knowledge and reduce accidents in this organisation.
The other instigating factors were: as a legal obligation, and as a result of insurance costs.
Insurance costs have increased in line with all other insurance costs, but it is believed that the
insurance costs are lower than they would be, if they didnt have any health and safety systems
172
in place at all. The systems were all developed internally, by the designated health and safety
person, and are updated yearly, or when equipment or methods are changed.
The accident statistics show that there have been a total of 55 accidents in 2001 (i.e. 50 with less
than 1 day off work; 3 accidents resulting in 1 to 3 days off work; and 2 accidents resulting in 4
or more days off work). There were no occurrences of non-fatal major injuries of fatal injuries.
This gives a statistic of 0.5 accidents per employee, in 2001 (working on the full-time employee
figure, which is the total number of staff for most of the year). Statistics for total accidents
having occurred in the last 5 years were estimated as being 309 (i.e. 280 with less than 1 day off
work; 15 resulting in 1 to 3 days off work; 12 resulting in 4 or more days off work; and 2
resulting in non-fatal major injuries). There were no fatal injuries in the last 5 years. Overall,
accidents appear to have decreased, they have also decreased in severity which is due to the
organisation being more conscious of health and safety, becoming more proactive rather than
reactive. There was an initial increase in the number of less than 1 day off work accidents, but
this was seen to be as a result of employees being more aware of health and safety, reporting
more accidents than they used to, once the health and safety systems were introduced.
It was estimated that the site has spent around 5000 on health and safety over the last 5 years
(including: equipment, signs, posters, training, costs incurred due to an accident etc.), spending
approximately 1000 a year. This estimate provides a figure of 9.09 per employee spent on
health and safety in the last year. The average accident costs the organisation at least 3000.
It was considered that the benefits had outweighed the costs of health and safety
implementation. Productivity has seen an increase and time lost through accidents has
decreased. There are fewer people off work due to a reduction in accidents and employees are
safer and suffer less as a result of this.
It is anticipated that changes in legislation in relation to the age of retirement could increase the
organisations spend on health and safety. If a regulation comes into place whereby
organisations can no longer enforce retirement, then costs will increase as a result of having to
change work practices for older workers (such as providing extra handrails on ladders etc.,
providing more safety measures for physically demanding jobs, that would not be necessary for
younger workers). There may also be an increase in the incidence of strains and injuries,
therefore a greater cost in terms of time lost through these injuries etc.
Management of Health and Safety at Work Regulations: Risk assessments are developed by the
Health and Safety Manager and are re-assessed every year, as are the health and safety
arrangements as a whole. Each risk assessment takes about 1 day to complete. The Health and
Safety manager attended a course on advance health and safety (CIE4). Information and
training for employees has also been provided. Special arrangements for temporary workers,
including basic health and safety, are covered at the interview stage. The other sections of these
regulations not taken action on were seen as being a low priority for this organisation. The risk
assessments were developed first, in order to assess what health and safety systems were
needed. There was some difficulty encountered in trying to change the culture of some of the
older members of staff who had been doing the job that way for years. The cost of these
regulations was 18.64 per employee (working on the full-time employee figure). Benefits of
an overall reduction in accidents, and an increase in awareness of what can go wrong, were seen
to outweigh the costs.
Pesticides Regulations: Training in using the new sprayers has been provided, new signs have
been put in place and certificates of competence have been gained. The training in spraying was
introduced by the agriculture industry, along with an update in the regulations. The other
sections of these regulations not taken action on were seen as being a low priority for this
173
organisation. The main difficulty with adhering to these regulations is in keeping track of who
produces what pesticides. Again, there was a cultural problem in trying to change the working
practices of the older members of staff. Aside from the external training run by the Pesticides
Control Board (part of DEFRA), these regulations were dealt with internally within the
organisation. The cost of these regulations was 30.55 per employee (working on the full-time
employee figure). Benefits of an increased awareness and a reduction in the use of chemicals
were seen to outweigh the costs.
COSHH Regulations: The COSHH assessments were developed by the Health and Safety
Manager and take approximately 3 to 4 hours to complete. Data sheets are issued and new
assessments are carried out every time the organisation buys in a new chemical. The COSHH
assessments were carried out first in order to assess the substances and prioritise the actions to
be taken. Again, there was a cultural problem in trying to change the working practices of the
older members of staff. The cost of these regulations was 7.27 per employee (working on the
full-time employee figure). Benefits of a reduction in the usage of chemicals and an increased
awareness were seen to outweigh the costs.
Manual Handling Regulations: Employees have been trained, as necessary, in manual handling
(including new starts and summer temps, as required). The Health and Safety Manager has
encountered problems in trying to get people to lift a smaller load, and has also experienced the
same cultural problem, with the older members of staff, as with the introduction of the other
above regulations. The cost of these regulations was 91 pence per employee (working on the
full-time employee figure). Benefits of less time off work and a reduction in strains (they are
not reported very often) were seen to outweigh the costs. Overall manual handling is a low
priority for this organisation.
Noise at Work Regulations: No action has been taken in relation to these regulations.
Currently, such advice is sought through HSE inspectors. The Safety Manager would like to see
more accident reports published by the HSE, i.e. examples of accidents that have happened
which are relevant to their industry and activities, so that the organisation can relate to the
accidents as possible examples of what could potentially happen within their organisation. The
accident reports should include examples of minor accidents as well as major accidents, as small
accidents need to be prevented too and can also be learned from.
Written advice, from HSE, of new regulations was also requested.
It was felt that HSE could improve their standing by holding seminars or discussion groups for
senior managers / directors on health and safety issues (as it was considered to be quite difficult
to get management to spend on health and safety until an accident actually occurs). Offering
free attendance to such events could encourage more proactive health and safety spending.
174
Site Electrical (PH) Ltd.
Sector
Construction
Size
Medium: 130 employees (i.e. 125 full-time and 5 part-time)
Background
Site Electrical was established in 1980 as an organisation of mechanical and electrical
engineers. The organisation is part of the water and sewage pumping industry, maintaining 500
pumping stations on a contract basis. Main activities include: mechanical and electrical design,
providing complete pumping station packages, electrical contracting, mobile maintenance
teams, fabrication and control panel workshops.
The details provided were largely accurate although there was no formal method of performance
measurement as reported in the questionnaire.
The organisations main hazards are confined spaces, manual handling, slipping and tripping,
electricity, fumes, pressure systems, working at height, and vehicles / transportation. Health and
safety systems include a designated Health and Safety officer, an accident reporting system,
documented risk assessments, performance targets / objectives and a written health and safety
policy. The Safety Officer is responsible for the day to day application of the health and safety
policy, under the immediate direction of the Contracts Director, and with the full co-operation
of all other managers and supervisors, who take an active responsibility for health and safety in
their particular sphere of influence. The performance targets / objectives are reviewed on a
monthly basis and analysis reports are provided by the organisation to their main clients.
Accidents are documented and reported via accident report forms and the Safety Officer then
investigates all accidents. The accident reporting system is reviewed and monitored bi-
annually. The organisation has various risk assessments in place in addition to a number of
listed risk assessments that are in the development stages. Weekly toolbox talks are also held,
run by the various site supervisors, they consist of 10-minute discussions to raise safety
awareness.
The health and safety systems were first introduced 11 years ago due to a combination of factors
as follows: as a result of client requirements; as a legal obligation; in conjunction with other
systems being developed in the organisation; and because the organisation reached a particular
size (the organisation had increased from 1 to 90 employees in 15 years). The organisation
experienced pressure from their main contractor clients to have health and safety systems in
place and an experienced Contracts Manager was employed who introduced the necessary
quality and health and safety procedures. Another new employee was then taken on to continue
development and implementation of the health and safety systems.
The systems are all developed internally by Safety Personnel, using external training providers
and advisors when necessary. All systems are reviewed annually, or as and when they are
needed.
The accident statistics show that there have been a total of 31 accidents in 2001 (i.e. a total of 27
accidents covering the less than 1 day off work and the 1 to 3 days off work categories; and
4 accidents resulting in 4 or more days off work). There were no occurrences of either non-fatal
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major injuries or of fatal injuries in 2001. This gives a statistic of 0.24 accidents per employee,
in 2001. Statistics for accidents having occurred in the last 5 years (including the 2001
statistics) were 120 accidents in total (i.e. a total of 104 accidents covering the less than 1 day
off work and the 1 to 3 days off work categories; and 16 accidents resulting in 4 or more days
off work). There were no occurrences of either non-fatal major injuries or of fatal injuries in the
last 5 years. Overall, there has been a general decrease in accidents when considering the
reportable accidents. Recently there has been an increase in reporting, as employees now have a
greater inclination to fill in the accident book due to raised health and safety awareness, so that
the first aid injuries look artificially worse on paper.
It was estimated that the site spent around 60,000 on health and safety in the last full financial
year. This costing includes the Safety Officers wages, expenses, confined spaces training
(600 per employee, which is valid for 3 years), buying gas detectors (800 each) which have to
be calibrated every six months (at an average cost of 140 each), safety equipment and the
testing and maintenance of this, insurance and related costs. This estimate provides a figure of
461.54 per employee spent on health and safety in the last year. The major costs to the
organisation are spending proactively, although insurance costs have also increased as a result
of claims made.
Insurance costs have increased by two or three hundred per cent and the Safety Officer believes
that the organisation is not currently benefiting from any reduction in insurance costs as a result
of having health and safety systems in place.
It was considered that the benefits outweighed the costs as the organisation has the philosophy
that health should be put before wealth. The organisation cannot be seen not to be paying
close attention to health and safety, if they want to be seen as a reputable company and therefore
win more work as a result. Further benefits, other than an enhanced company reputation, have
been a general decrease in reportable accidents and an increased awareness of safety.
Future costs of compliance are anticipated as being incurred as a result of the necessity to keep
extensive records, which is a heavy burden on employee time (it is simple clerical work). The
Safety Officer believes that this is not proactive compliance, it is simply providing an audit trail
for the regulators.
Management of Health and Safety at Work: the organisation has about 70 generic risk
assessments in place, plus some site specific risk assessments. Each risk assessment takes about
2 hours to complete. The organisation has provided specialist safety equipment, inspections,
tests and calibration etc. Some new contracts were secured where pre-qualification procedures
included health and safety audits by client. This led to heightened awareness within Site
Electrical. As a result, a Safety Officer was appointed and the organisation has links with
external training providers. The actions taken on the regulations were developed and are
managed by safety personnel. The organisations main issue is the danger of confined spaces,
and this is very well organised for the safety of the employees. Equally there is a need to
comply with clients established health and safety policies and procedures. Benefits of an
enhanced company reputation, increased awareness, and reduced accidents, are seen to
outweigh the costs.
COSHH Regulations: generally the company has little contact with substances, contact mainly
consists of sewage in confined spaces. Employees are provided with a data sheet to improve
their understanding, as they do not generally understand COSHH assessments, which therefore
need to be covered in toolbox talks. Each COSSH assessment generally takes 3 hours for the
Safety Officer to complete, over a period of 3 days. PPE control measures are also in place.
Benefits are believed to outweigh the costs, yet the benefits of preventing accidents with
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substances are non-tangible, as the organisation had no previous encounters with accidents
involving substances as a comparison.
Manual Handling Regulations: manual handling is the organisations second biggest hazard
after confined spaces, yet a need has been recognised to improve procedures tackling manual
handling issues. The organisation has manual handling risk assessments in place in addition to
ongoing improvements to lifting and carrying equipment. Provision of PPE, and training and
information for employees, as identified for particular items or conditions, are also in place.
Difficulties can arise in assessing abnormal manual loads (i.e. in weight or bulk). The Safety
Officer suggested the practical solution of providing staff with general manual handling
awareness training. No tangible benefits have been observed as a result of action taken in
relation to these regulations, although the organisation has a lot of manual handling equipment
in place and incidents may have occurred had this equipment not been in place.
Noise at Work Regulations: the organisation has bought suitable equipment, i.e. that which
produces the lowest noise; has carried out risk assessments; has raised awareness (incorporated
in the toolbox talks); provided PPE; and has controlled the use of those tools creating noise.
Suppliers are asked for information regarding noise when new equipment is bought. Problems
have arisen with respect to the effect the environment has on noise, i.e. noise is affected by its
environment, and this can be difficult to measure. Again, no real benefits have been observed,
but there have been no reported aural problems, and this may therefore be viewed as a benefit.
Currently, advice and information is sought via health and safety consultants, Local Enterprise,
Croner, HSEs central resource, the Internet and GEE publishing / Tolley etc.
The Safety Officer does not find the HSE web site to be very user-friendly, as it takes him a lot
of searching to find the information required. Overall, he finds the web site to be quite good,
but he is always looking for specifics and it takes too much time to locate the information.
Clearer guidance on when and where to carry out manual handling risk assessments would be
appreciated.
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AC Whyte
Sector
Construction
Size
Medium
Background
AC Whyte was established in 1973 and employs 82 staff, 12 in the head office and 70
tradesmen who work on project sites. The work undertaken is all external refurbishment of
social housing including roof and window replacement and insulated rendering. The clients
are mostly local authorities. The organisation used to be involved mainly as a subcontractor
but this is changing and more and more of the work is now as a principal contractor. This has
had a large impact on the health and safety requirements and responsibilities for the
organisation.
The details provided were largely accurate although the total numbers of employees for the
organisation is 82, 12 at the head quarters (largely office based) and 70 tradesmen working at
project site(s). In the questionnaire it was reported that there were 12 in the organisation and
70 at the site. Therefore the organisation has been classified as a small organisation when, in
fact, it is a medium sized organisation. The only other accuracy in reporting was concerned
with costing the spend on general health and safety. For overall reporting of costs, the cost of
the time of the health and safety person had not been included in the calculations. The cost of
the health and safety consultant had however been included.
The main hazards are manual handling, working from height, noise, slips trips and falls,
chemicals and dust from cement. The organisation has a health and safety policy with an
underlying two-tier risk management process. Generic risk assessments are conducted in line
with specific regulations e.g. COSHH and Manual Handling, these are then fed into a project
specific risk assessment and method statements as required by the CDM Regulations (health
and safety plan).
Monitoring is carried out through audit and in-house accident reporting and review.
Risk assessments are carried out under the specific regulations and the organisation started
conducting these in 1994 following the introduction of the six pack of regulations. The CDM
Regulations (1994) followed and resulted in the requirement for project specific health and
safety plans. The organisation has increased the extent to which it acts as a principal
contractor on projects and this has resulted in more comprehensive and thorough assessment
of the overall risks to health and safety of employees to meet the requirements of the CDM
Regulations.
The organisation pays an annual subscription of 85 per employee to the Ayrshire
construction health and safety group. These consultants conduct generic risk assessments and
monthly on-site audit. In addition, the service provides on-going advice regarding health and
safety regulations / good practice and training courses.
The company estimator has additional responsibility for health and safety and
develops/updates the health and safety plans as required for each project under the CDM
Regulations. He also has responsibility for general health and safety management including
updating the health and safety policy and liasing with the consultant.
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Each site supervisor holds a copy of the health and safety plan and, as well as ensuring that
this is implemented on site, is also responsible for arranging health and safety meetings and
weekly toolbox talks with employees on site.
Employees are encouraged to meet their responsibilities under the various regulations as
stated in the policy. The toolbox talks provide an opportunity to raise awareness of health and
safety issues and employees responsibilities.
The main motivators to development and implementation of health and safety systems are
compliance with the regulations. This is particularly pertinent with the CDM Regulations
under which work cannot commence on a project until the health and safety plan is in place.
Also important are maintaining insurance premiums and meeting and maintaining the quality
system, which incorporates health and safety. Effective compliance with the CDM
Regulations and certification under ISO 9000 put the organisation at a competitive advantage.
There has been a general reduction in the frequency and severity of accidents since the
systems were introduced in 1994. In 2001 there were 7 accidents. The accidents that do
occur seem not to be relating to any trend or hazard. Generally they are considered to be as a
result of not carrying out the safe systems of work that are prescribed. Toolbox talks are
thought to help in continually raising awareness of health and safety issues and reinforcing
the need to implement the safe systems of work.
The improved health and safety record has ensured that insurance premiums stay at a
minimum. However, there has been a general increase in insurance premiums in recent years,
irrespective of health and safety performance. For example, there has been a general increase
in liability insurance premiums coupled with a requirement for increased levels of cover, due
to the increasing claims culture.
The organisation spends between 30, 000 and 50, 000 per year on health and safety,
approximately 350 - 600 per employee. A large proportion of this is for the time of the
estimator (20% of his total time per annum) who has general responsibility for management
of health and safety. In particular, developing and updating health and safety plans required
by CDM Regulations and updating the general health and safety policy and procedures.
Other significant costs include the fee to the consultants, which is around 6, 000 per annum.
The consultants conduct all generic risk assessments as well as monthly audits and ongoing
advice and training. Additional costs include controls (such as PPE and equipment), as well
as the time of supervisors and employees.
The benefits of compliance are seen to outweigh the costs for a number of reasons. Health
and safety systems have had a clear impact on the number and severity of accidents, although
these cost savings have not been quantified. Compliance also ensures that the company can
compete in the market place. Existing clients require compliance with health and safety
regulations and the quality certification and health and safety management systems are
thought to contribute to success in securing new clients.
For the specific regulations covered in the questionnaire, the organisation has carried out the
following steps in relation to these regulations.
Management of Health and Safety at Work Regulations:
The organisation carries out a general risk assessment prior to starting a contract and this
forms the basis of the health and safety plan. This is conducted by the in-house health and
safety role. The consultants then conduct regular (monthly) health and safety audits to ensure
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the safe working practices are being implemented and identify any new risks. Weekly tool
box talks are held covering a tropic for consideration. Training is provided as and when
required (often by the consultants). Subcontractors are assessed quarterly to ensure that they
are meeting their responsibilities. It is difficult to separate the costs of compliance with these
umbrella regulations from the requirements of specific regulations, particularly the CDM
Regulations as they look at general health and safety management at a project level.
Pesticide Regulations
Not applicable
Manual Handling Operations Regulations
Generic risk assessments are conducted, by consultants, for all handling tasks. The
organisation has put a limit on the weight that people can lift using the guidance in the
regulations. Therefore anything over 25kg must be mechanically handled or involve two
people. Reduced weight of packs of materials were requested from suppliers to bring these
down from 40kg to 25kg. Employees are trained in safe manual handling. Inspections are
conducted by the site supervisors and include observation of safe handling practices.
Training and equipment are the greatest costs of compliance.
COSHH Regulations
The generic risk assessments are conducted by the Consultants. Any new products that
require assessment are identified during the project risk assessment prior to commencing the
work and a new risk assessment generated. These new products are introduced rarely.
Controls are largely through provision of PPE for employees and this amounts to the greatest
cost of compliance. Inspections of safe working practices are conducted by the site
supervisors.
Generic risk assessments are carried out by the consultants. Controls have included fitting
silencers on machines and provision of PPE. The silencers posed the greatest cost initially.
New risks are limited and therefore generic risk assessments and controls are usually
adequate.
The organisation is not aware of any future regulations or requirements that will have a
significant impact on the way it manages health and safety or the costs incurred.
Currently such advice is sought through the health and safety consultant and this is regarded
as a good way of keeping up to date with current issues and new legislation.
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HF Electrical
Sector
Construction
Size
Medium
Background
HF Electrical is an electrical contractor and electrical engineering company. They conduct a
range of jobs of varying size from simple electrical repairs to larger refurbishment jobs. The
organisation employs approximately 150 employees, although this can fluctuate depending on
the workload. The company was originally a family run business, established over 20 years
ago in 1981.
The information provided in the questionnaire was largely confirmed as being accurate during
the visit. However, when discussing the costs of compliance in more detail it was evident that
the time of the health and safety manager had not been included in the original estimate.
Therefore the true costs of compliance are more likely to be in the 50, 000 + bracket rather
than 10 000 50, 000.
The main hazards are electrical, as would be expected, plus dust, manual handling, noise, fire
/ fumes, working from height and transport related.
There is a full time Health and Safety manager who co-ordinates the health and safety
systems. A consultant provides periodical advice and guidance. The policy is reviewed
annually and there is an accident reporting system and risk assessment procedure. Generic
risk assessments are conducted and this system has recently been reviewed as it was
considered that the risk assessment procedure was relying too heavily on generic risk
assessments. As a consequence the risk assessment forms have been re-drafted to involve
employees / operators in the assessment of risks when embarking on a new job.
Ill health is not monitored. The health and safety manager was confident that the accident
reporting was largely accurate as even very minor incidents are reported. The health and
safety system is specifically linked to the quality system for which they are ISO 900/01
certified.
The health and safety manager conducts inspections and audits. The policy and risk
assessment procedures are reviewed annually.
The main motivators to improve health and safety are increasing accidents, legal obligation
and pressure from principal contractors. There is a heavy requirement from contractors
requesting that employees be trained in particular qualifications. The training required varies
widely from one contractor to another, yet the training they receive from these various
schemes is very similar. It is thought that training costs could be significantly reduced if there
was a standard, authorised and widely accepted training scheme for this kind of work.
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There has been a steady fall in accidents and a further reduction in the accident / incident rate
between 1999 and 2000 from 8 to 5 over this period. However, there was a significant
increase in 2001 back up to 12. As a result, a newsletter was distributed to all employees to
encourage them to be vigilant and take steps to reduce the risks. Awareness was also
encouraged through regular toolbox talks, the subject of which was produced by the health
and safety manager and presented by local supervisors.
The most significant costs are associated with employing the health and safety manager,
training provision, equipment and PPE and production of health and safety documents,
material for tool box talks etc. The estimated costs of compliance with health and safety
regulations are, including the salary of the health and safety advisor, approximately 330 per
employee per annum (with overall health and safety spend being in excess of 50,000 per
year).
The benefits are considered to outweigh the costs. Morale increases momentarily following
provision of training and it is therefore hoped that the introduction of regular toolbox talks
will assist in maintaining this. In addition, the organisation considers that there can be no
price put on the loss of human life and therefore any health and safety effort that protects the
health and safety of its employees is valued.
The Health and Safety Manager was not aware of any particular future costs of compliance
that would dramatically impact the current health and safety costs incurred by the
organisation.
Management of Health & Safety at Work Regulations: The organisation implements specific
and generic risk assessments and a health and safety manual is in place and implemented. In
terms of control measures, PPE has been purchased and equipment is tested. Young persons
are closely supervised and are not allowed to operate the plant etc., except during training
exercises. These regulations are managed by the supervisors and by the operatives.
Information and advice was sought from RoSPA and health and safety consultants when
initially implementing these regulations. The overall cost of implementing these regulations
is approximately 69,000. This figure includes the initial capital costs as well as the ongoing
yearly costs and provides a statistic of 460 per employee. The benefits of implementing
these regulations were considered to outweigh the costs, with benefits including increased
morale and reduced lost time through accidents. The Management of Health and Safety at
Work regulations have had the biggest impact on the organisation, resulting in the most
involvement and having incurred the largest spend, in comparison to the other regulations
implemented.
Pesticides Regulations: Not applicable
COSHH Regulations: Assessments of risk are carried out, although the organisation uses very
few hazardous substances, e.g. occasional use of paint. Gloves and masks have been issued
and information is conveyed to employees via supervisors and the health and safety manual.
The estimated costs of these regulations amounted to 1,200, which is approximately 8 per
employee. Benefits were again considered to outweigh the costs, although employees have
little interaction with hazardous substances.
Manual Handling Regulations: Supervisors are trained in instructing other employees in
manual handling techniques by attending courses run by RoSPA. Employees then receive
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manual handling training from these supervisors. A few risk assessments are conducted, but
not many, as there are few heavy loads. New loads are also assessed. The cost of
implementing these regulations was 8,000, which is approximately 53 per employee.
Overall benefits, as described earlier, were considered to outweigh the costs.
Noise at Work Regulations: PPE has been provided via the issue of hearing defenders and
earplugs. The employees very rarely work in noisy conditions, but employees are advised of
precautions where required. Advice is also given within the health and safety manual. The
cost of implementing these regulations was 600, which is 4 per employee. Overall benefits,
as described earlier, were considered to outweigh the costs.
Sources of information
The organisation currently seeks advice and information via RoSPA, IOSH, HSE inspectors
and S.E.L.E.C.T.
The national HSE accident-reporting line is not considered to be as approachable and user
friendly as the previous local service, as the person on the other end of the phone is not
familiar with the local geography etc.
Other
As discussed, contractors can request a range of training qualifications and these different
training bodies can all provide similar training but, in order to remain competitive, the
organisation must qualify to all. It is considered that there should be a HSE recognised
standardised training certifying body to ensure standards of training and reduce costs to sub-
contractors.
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OPEX
Sector
Exhibition Construction: i.e. contractors undertaking the construction of exhibition stands etc.
Size
Medium: 160 personnel across all sites, but 40 based at Olympia
A comprehensive paper and verbal validation of the information was performed. The details
provided were largely accurate, although the number of personnel at the site had increased
slightly since the original questionnaire was completed. In addition, it was reported in the
questionnaire that the site-staff totalled 500 people and for this reason the organisation had been
classified as large. However, the site visit revealed that the organisation is medium in size, as
the 500 staff includes carpenters, electricians, plumbers, etc., who are all employed on a
contract basis. The Health and Safety Manager was partly responsible for the safety of these
subcontractors, hence the exaggerated numbers fell under his guardianship. The core team of
personnel includes show managers, project managers, graphic staff and admin staff. There was
the scope to undertake a detailed examination of their records and procedures, which were
freely provided.
The organisation was born out of the management buyout of P&O Exhibition Services 3 years
ago - the original company was established over 100 years ago and has been in operation at this
site for many years. Prior to the buyout and for the first eighteen months afterwards there was
not a rigorous approach to health and safety. Commercial reasons were cited as the main
incentives for creating a full time health and safety (H&S) role as the clients (the venues where
OPEX organise events) exerted a lot of pressure for OPEX to proactively manage H&S (this
was following the HSE prosecuting the clients following two fatal accidents).
The H&S manager has been in his role for over a year now and he reports directly to the MD,
but also works very closely with the FD. Since his arrival, there has been a large change in the
safety culture of the company with many changes to the safety management systems to make
them more relevant and simpler to the workforce and to increase involvement in H&S
throughout the organisation.
There is a comprehensive accident recording and ill health system in place, this was created
prior to the management buyout and the records and performance are regularly maintained and
communicated at all levels of the organisation. Since the H&S managers arrival, the overall
accident frequency has decreased only slightly, but the number of serious incidents has
dramatically fallen. The reason for this has been the increased awareness of H&S issues
amongst the workforce, a better understanding of the risks involved with the tasks (there has
been a dramatic change in the safety culture at the company since the H&S managers arrival),
better project management and the revised H&S management structure.
The H&S managers influence and the competitive edge he has given the company has been
seen by senior management as a positive measure in ensuring the attractiveness of the company
to the venues. Although systems might have been in place before his arrival, they were not
being effectively implemented, and are much more rigorously enforced now.
The main costs have been associated with training of personnel (mainly the project managers
who are now IOSH qualified) and the expense of a full time H&S managers wages. The
project managers are made responsible for ensuring the good H&S performance on the shop
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floor with overall guidance from the H&S manager. H&S reps (referred to as Champions of
Safety by OPEX) have also been allocated and are actively involved in all aspects of H&S at
the sites. The higher priority of H&S, the involvement of personnel at all levels, and the clearer
lines of communication for H&S issues, has helped to bridge the gap between management and
staff and allowed much better communication on many more issues.
Insurance premiums have increased by 30% in recent years, which was perceived to be as a
result of widespread increase in insurance costs across the market.
The H&S Manager was not aware of any future compliance costs that would have a dramatic
impact on the costs currently incurred. Training is now done in-house which has reduced costs.
Management of Health and Safety at Work Regulations: The H&S manager has gone to
considerable lengths to ensure that the company H&S performance is considered a key issue at
all levels and sees these regs as a core tool in achieving that. On his arrival at the company, he
conducted a company-wide survey to assess the H&S awareness throughout the organisation.
This allowed him to prioritise where action was required to ensure compliance with these regs.
The various procedures in place have also been made simpler and more available / usable for the
workforce. Generic risk assessments have been adopted for regular operations and specific risk
assessments conducted for one-off and infrequent tasks. The provision of training, manual
handling equipment and PPE has increased over the past year and there is more assistance from
other sites in the organisation and consultancies as appropriate for training and auditing. The
biggest impacts are the involvement of the workforce at all levels (much improved culture) and
the fact that OPEX are beginning to gain a reputation for treating H&S issues very seriously
commercially, this is very important for the company.
Pesticide Regulations: Not applicable.
COSHH Regulations: COSHH does not have a significant impact upon OPEXs operations as
there are very few hazardous materials handled on site.
Manual Handling Regulations: Mechanical handling equipment has been provided wherever
possible to reduce the reliance upon manual handling. All staff have received training in
manual handling and risk assessments for all handling activities have been completed. The
storage practices have also been reviewed and changed to improve access and arrangements for
the storage / lifting of heavy and bulky items. Despite the very manual nature of a lot of the
work that OPEX carry out, there has not been a history of injuries as a result of poor manual
handling practice at any site.
Noise at Work Regulations: Not applicable.
Other:
OPEX have vastly improved their approach to H&S in recent years and are beginning to realise
the benefits of this change by being considered as less of a risk by the venues themselves.
OPEX see themselves as being fairly unique in their approach to H&S within their industry.
They see the exhibition industry as being very much akin to the construction industry, albeit on
a smaller scale and with much shorter project schedules - exhibitions involve a short planning
period, rapid construction to a very tight deadline and then rapid striking of the exhibition to
make way for the next one; this involves a high diversity of operations including electricians,
plumbers/gas fitters and carpenter/joiners, all sharing a relatively congested, busy and rapidly
changing environment. There is little guidance (and power) for organisations such as OPEX to
ensure that adequate safety management systems are in place at the venues - the contractors
used are dominated by self-employed tradesman with little or no interest in H&S issues, which
are seen as a cost burden. It is very hard for OPEX to influence these people and improve the
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safety culture at that level - the apparent lack of interest and guidance from the HSE for the
exhibition industry and its associated trade bodies is weak.
Whilst OPEX see their good H&S approach as being a unique selling point, there is a very fine
line to tread as any increase in costs would make them less competitive. Therefore, more
guidance and regulation from the HSE would improve overall industry performance and create a
level playing field. By the inclusion of a set of regulations (such as an extension of the CDM
regs to include the exhibition industry), H&S within the industry would gain a better focus.
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Carewatch (Grampian)
Sector
Health Services
Size
Medium
Background
The Carewatch (Grampian) site was established in 1997, although Carewatch itself was
launched in 1993 and later franchised in mid 1995. Since December 2001, Carewatch has
been part of the Nestor Healthcare Group plc, whose companies have been providing
healthcare staff for more than 50 years. Carewatch (Grampian) employs a total of 164
employees, who provide domiciliary care to the elderly within Aberdeen City. The number of
staff has increased by approximately 50% over recent years, simply due to natural growth.
The details provided were largely accurate, although discussions during the site visit made the
Managing Director realise that the yearly spend on health and safety was in a higher cost
category then originally reported in the questionnaire. The site visit enabled clarification of
the Carewatch organisation itself, in terms of it being a franchise that has been in operation
since 1993 and part of Nestor Healthcare since 2001. The only other difference was an
increase in the total number of staff at the Grampian site, from 130 to 164 employees, since
completion of the questionnaire.
The main hazards are manual handling, slipping / tripping hazards and confined spaces.
Health and safety systems include a designated health and safety person, an accident reporting
system, documented risk assessments, performance measurement, performance targets /
objectives, and a written health and safety policy. The Operations Director, who reports
directly to the Managing Director, is responsible for health and safety at the Grampian site.
The health and safety policy is written centrally by Carewatch, and copies are held at each
site.
Accidents are reported directly to the Managing Director at Grampian, who then completes
the accident form directly over the Internet. The site has not experienced many accidents,
only 3 in total since the site was set up, so it has been easy for the Operations Director and
Managing Director to keep track of the accidents and therefore there has been no formal
monitoring of accidents, as such. Employees are encouraged on induction to report accidents
to their Supervisors. It is stressed that accidents should be reported, by explaining that any
injury experienced, as a result of an accident, may become worse over time and that it is
therefore better to report the accident when it happens.
Carewatch (Grampian) has a number of documented risk assessments in place, which are
completed for the elderly clients homes, whenever a new client is taken on, or if changes
take place in the clients home. If the hazards are too high the client is not taken on until
remedial action has been taken. The risk assessments are completed by the Field Care
Supervisor, who then ensures that the carer (s) are aware of the risks. A logbook is also left in
the clients home. The length of time it takes to complete a risk assessment depends on the
individual circumstances in the clients home, but may take half an hour on average, if the
home does not present many hazards. Risk assessments are reviewed as an ongoing process,
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with the majority of information to be updated originating from Carewatchs head office in
Brighton.
Performance measurement and performance targets / objectives are monitored as part of the
sites monthly reviews of both client and carer. Health and safety systems were first set-up at
the Grampian site, when the site began operating in 1997. Most of the information for these
health and safety systems originated from Carewatchs head office, and this was then
amended according to the local environment. The health and safety systems were all
developed internally, no external consultants were used. There was a combination of factors
contributing to the organisations decision to implement health and safety systems and these
included experience of accidents (via the Managing Directors previous jobs); health and
safety publicity; legal obligation; and a review of the organisations structure and systems.
The health and safety systems were developed in conjunction with the quality system: it is
also a requirement of the industry, in terms of the Care standards throughout the UK, to have
health and safety and quality systems up to a certain standard.
In addition, insurance costs were one of the motivating factors behind the decision to
implement health and safety. Insurance costs have doubled in the past year, but this is
perceived to be as a result of the general market increase across insurance. Insurance is
negotiated by Carewatchs head office, so the level of detail asked for, in terms of health and
safety, is not known by Grampians Managing Director, although he believes that insurance
costs are affected by the standard of health and safety systems an organisation has in place.
Newly established firms (those established in the last 5 years)
Although the Grampian site was set up in 1997, Carewatch itself has been running since 1995
and so most of the information needed for developing and implementing the health and safety
systems in Aberdeen was provided from the head office. All systems were developed in-
house, although the Managing Director at Grampian did seek professional health and safety
advice from previously known contacts, on an informal basis, which he found to be useful.
The Managing Director advised that an organisation that is newly established, and
considering implementing a health and safety system, should seek to gain as much advice and
guidance as possible, from various sources, accessing the HSE web site initially and then in
person, where necessary.
The Grampian site experienced 2 accidents in 2001, with just a total of 3 accidents over the
last 5 years as a whole (all three resulted in 4 or more days off work). This gives a statistic
of 0.02 accidents per employee, over the last 5-year period. There have been no particular
trends observed, although accidents are perceived to have increased slightly, simply as a
result of the increased workforce.
It was estimated that the site spends approximately 5,000 to 10,000 a year on health and
safety (which includes employee time, training, quality assurance etc.). Included in this
yearly figure is the cost of 2,700 for the moving and handling training, and 4,500 for
clinical risk assessment training courses (for 9 employees). This estimate provides a figure of
approximately 30.49 - 60.98 per employee, per year. The majority of the sites health and
safety spend is incurred via compliance costs, in order to meet the requirements of regulations
in order to prevent accidents, rather than being incurred reactively.
It was considered that the benefits had definitely outweighed the costs, with such benefits
including an increase in staff morale and awareness, in addition to providing protection for
the sites staff and clients. The Managing Director also benefits from being able to have
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confidence in the health and safety systems, and from the knowledge that the organisation is
compliant.
The Managing Director anticipated future costs in the areas of further moving and manual
handling training and in relation to the reissuing of all current documents. In addition, costs
will be impacted, in the near future, as the site is going to take on further activities that it is
not currently involved in.
Management of Health and Safety at Work Regulations: Risk assessments are in place,
generally taking approximately half an hour each to complete, depending on the hazards
present. Health and safety arrangements are continuously assessed and information and
training for employees is provided via induction and risk assessment training. No particular
difficulties were encountered when implementing these regulations, with help having been
provided from the Local Authority. The cost of these regulations is included within the
yearly 5,000 - 10,000 health and safety costs, as detailed earlier. Benefits were considered
to outweigh the costs and included increased staff morale and awareness, better protection for
staff and clients, and the MDs increased confidence in the standards of health and safety,
with regards to being compliant.
COSSH Regulations: The Field Care Supervisor, who is appropriately trained, manages these
regulations, identifying any hazards when carrying out the COSHH assessments. The only
substances used are household chemicals and the majority of employees are therefore not
exposed to these. Monitoring of exposure to employees is included as part of the general
monthly assessments / reviews. PPE is provided to the carers (including aprons, gloves, and
uniform, where necessary). The onus is placed on the carers to advise management of any
changes that will need to be dealt with (and this is applicable across all areas of health and
safety). The cost of these regulations is again included within the yearly health and safety
spend of 5,000 - 10,000, with the assessments of risk, employee time, and documentation
costing between 1,000 and 5,000, in addition to the costs of PPE which also cost in the
region of 1,000 to 5,000. Benefits were again perceived to outweigh the costs, although
they were not quantifiable, as few chemicals are used and it has not been necessary to
substitute any substances. Increased awareness and confidence in the systems were again
apparent as benefits.
Manual Handling Regulations: The site has 3 trained trainers and risk assessments are
routinely conducted. Supervisors complete a moving and handling plan and the client
reviews this. Each plan is completed yearly, as a minimum, or when there have been any
changes to the clients environment, if the client has been in hospital etc.: it is an ongoing and
interactive system. Changes to equipment have included the provision of hoists for the
clients home. Employees are all trained, in moving and handling, on induction and this is
updated as and when needed. Difficulties, in implementing these regulations, have only
arisen with respect to arranging retraining for the carers. It can be difficult, logistically, to
bring the carers into the office for training. In addition, some carers do not see the need to
retrain as they are already moving and handling on a daily basis. The cost of training the 3
trained trainers in moving and handling was 2,700. The other costs for these regulations
have also been absorbed within the sites yearly 5,000 to 10,000 yearly spend on health and
safety. Benefits were again perceived to outweigh the costs and included managements
increased confidence in the staff, to carry out the work, in addition to increased confidence
displayed by the staff themselves.
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Currently advice and information is sought via Croner, HSEs central resource, the Federation
of Small Businesses, a Corporate HSE Advisor and via the Internet. As the Grampian site
also more or less gained all their health and safety information from their head office, adding
to this via the Managing Directors previous experience, the MD did not find there was a lack
of guidance in any particular area.
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Thames Valley Hospice
Sector
Health Services: Hospice
Size
Medium
Background
Thames Valley Hospice was established in 1987 as a voluntary and independent health care
organisation. The hospice is registered under the National Care Standards Commission and
provides palliative care to patients with non-curable disease (mainly cancer). There are 81
employees in total (consisting of 34 full-time and 47 part-time, plus voluntary staff and bank
staff on top of this figure). The staff numbers increased by 11% over the last 18 months, due to
the development of the larger building and services. It is a non-profit organisation.
The details provided were largely accurate, although it was noted that the spend on health and
safety in the last 12 months would be nearer to the higher end of the cost range reported in the
questionnaire, should the salary of the in-house health and safety person and the ongoing
training costs both be included alongside the cost of the resources needed and the external
consultant. The cost of employee time, when they are attending the training courses, were also
not included in the estimations of yearly spend. The only other observation was with respect to
the questionnaire reporting that no action had been taken in relation to changes to the load on
the manual handling regulations. Employees have been informed with regards to inanimate
loads, i.e. moving smaller boxes and across shorter distances. However, the hospice obviously
cannot change patient size, so this load just has to be managed better.
The hospices main hazards are manual handling, psychosocial hazards, vehicles / transportation
(the hospice transports its own patients), and display screen equipment. Health and Safety
systems include a designated health and safety person, an accident reporting system, and a
written health and safety policy (currently being revised). Documented risk assessments are
currently being developed in all areas, although the organisation already implements VDU risk
assessments. The accident reporting system was developed by the Head of Quality, Safety and
Training, in half a day, and includes a form for patient-related accidents and another for staff-
related accidents. Employees are trained in the accident reporting system on induction and then
considered at annual training thereafter. Near misses are also recorded.
Initial attempts to implement health and safety systems were made in 1987 (health and safety
policy and manual handling training in place), although there was a major review and new thrust
during 2000 to develop the systems more fully. Health and Safety systems were introduced due
to a combination of factors: in conjunction with other systems being developed in the
organisation (i.e. the quality system); as a legal obligation; as part of a review of the
organisational systems / structure; and because the organisation reached a particular size. The
health and safety systems were developed in conjunction with the development of their quality
system, as they are very much inter-linked, and a designated health and safety role was created.
The designated health and safety person works in conjunction with an external health and safety
consultant, who carried out an initial audit of the organisation, so that the organisation was
aware of what needed to be done. Furthermore, the organisation also had a massive rebuild and
now has a much larger building and wider services to offer, so health and safety systems have
been updated in response to this change and increase in employees.
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The organisation holds annual reviews of the health and safety systems and the systems are
maintained by the designated health and safety person, in conjunction with advice from the
external consultant.
The Head of Quality, Safety and Training was unaware of health and safety having any impact
on the organisations insurance premiums.
The accident statistics show that there have been a total of 31 accidents in 2001 (i.e. all resulting
in less than 1 day off work). There were no occurrences of accidents resulting in 1 to 3 days off
work, 4 or more days off work, non-fatal major injuries, or fatal injuries. This gives a statistic
of 0.38 accidents per employee in 2001.
The current accident reporting system was only introduced in 2002, so the organisation does not
have records to compare current accident figures with. Accidents were previously written in a
book, but were not documented properly, the designated health and safety person is currently
developing a database to record accidents on the new system for future comparisons. However,
the health and safety person stated that they have a similar number of accidents from year to
year there does not appear to be any peaks and troughs in the accidents that occur. In addition
the health and safety person feels that there are less people off work due to backaches and
strains, due to the manual handling training which is ongoing. The majority of accidents are
related to patient care.
It was estimated that the organisation spends approximately 10,000 a year on health and safety
resources, plus 2,500 on the health and safety consultant (although they are spending an
additional 5,000 on the consultant this year, on running training). Overall this gives a statistic
of 216.05 per employee for this year. However, the costs that the organisation record do not
include the salary of the designated health and safety person, nor do they include the ongoing
training costs, or the cost of peoples time when they attend the training courses. The
organisation does not have an actual health and safety budget to stick to, training is just
considered to be a running cost and health and safety related funding is supported by
management, as long as there will be a specific benefit. The costs of health and safety are spent
in anticipation of incidents, rather than as a consequence of an accident / incident.
Costs and benefits were considered to have broken even. Health and safety has become part of
the organisations culture, and has become automatic. The administration department have a
much better environment as a result of health and safety (previously their office was cramped
and messy, but they now have a big office and their environment is now on a par with the
clinical side of the organisation).
The Head of Quality, Safety and Training was unaware of any future compliance costs that
would significantly affect the health and safety costs incurred. Future costs are likely to be
continued maintenance costs and ongoing training costs.
Management of Health and Safety at Work Regulations: new equipment is in place (e.g. beds),
occupational health is employed as a subcontractor, fire training and fire risk assessments are in
place, as is manual handling training. Risk assessments vary but the standard HSE display
screen equipment risk assessment generally takes the health and safety person half a day to
facilitate and employees 30 minutes to complete. An external consultant is used in an advisory
capacity, working in conjunction with the company health and safety person. An emergency
plan with private ambulance service and local private hospital is in place. The cost of these
regulations was estimated to be 464.20 per employee. There has been a large initial outlay of
costs, but this has been to develop and put the systems in place, meaning that these costs are not
the norm and future costs will be significantly less. Future costs are likely to be maintenance
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costs and ongoing training costs. Benefits have been seen in updating the administration
department and in areas of manual handling.
COSHH Regulations: data sheets are available to all staff; some who have read them have
learned from them already, considering what safer substances can be bought to replace
substances that are currently used. Appropriate PPE have been provided and occupational
health provides Hepatitis B and Tetanus Vaccinations. The cost of these regulations was
estimated to be 123.46 per employee. The organisations main expenditure is infection control
training. There have been difficulties with these regulations in terms of understanding what is
needed. COSHH is the companys weaker area and is currently being developed by the health
and safety person, in conjunction with the external consultant. As this area is currently being
developed, it is too early to make a judgement on the cost-benefit situation, however,
housekeeping staff are already more aware, and have been using more or less of certain
substances accordingly.
Manual Handling Regulations: the clinical staff conduct risk assessments on all patients, as part
of their daily role. These risk assessments take approximately 20 minutes on admission and
then 2 to 10 minutes daily. Staff receive manual handling training on induction and annually,
new equipment (e.g. beds) has been purchased, and changes have been made to working
practices. There have been no difficulties with these regulations, as employees understand the
purpose, with appropriate manual handling being automatic and part of the employees daily
routine. There are 4 manual handling trainers at the hospice and there will be 5 next year. The
training for trainers costs 200 per trainer each year. It was the manual handling training for
trainers that made the health and safety person realise that their beds were compromising patient
health, so the beds were consequently all replaced at a cost of 40,000. The cost of these
regulations was estimated to be 287.04 per employee. The benefits have definitely outweighed
the costs in that there have been fewer complaints re: aches and strains and the patients have
benefited by being made more comfortable as a result. People are less stressed by manual
handling, they think more about what they are doing, and why, and apply it to many different
tasks. The organisation is now concentrating on providing training in moving inanimate
objects, and developing risk assessments in this area.
Noise at Work Regulations: noise appeared to be an issue in the stress survey carried out
recently, however, as there is no significant machinery noise in the work place this has been
concluded to be as a result of people. The hospice is therefore trying to make people more
aware of the impact of loud discussions etc. in the workplace. Overall, however, the noise
regulations are not applicable to this organisation.
Currently advice and information is sought via health and safety consultants, IOSH, HSEs
central resource, Local Authority inspectors, and the Internet.
It was suggested that some form of system be set up, that organisations can sign up to, to
receive information on new legislation and on the expectation of employers in relation to
meeting change etc. Bulletin type information on a regular basis would be useful, especially if
the information could be specific to their sector. The organisation stated that the information
always seems to be about the construction sector, where as this particular organisation would
want more specific information, such as patient care updates, and VDU changes in legislation.
A website where an organisation could type in their specific needs and get information back
would be useful. The organisation would be willing to pay HSE to get updates regarding
specific issues. Journals are fine, but they can be expensive and are often full of issues that are
not relevant to their organisation.
In addition, the organisation feels that they would benefit from good practice examples, i.e.
realistic examples of how new legislation will impact on the workplace / how HSE sees the new
legislation working
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Anonymous
Sector
Health Services
Size
Medium
Background
The organisation is a nursing home that was established in 1987. The nursing home currently
employs 89 staff (32 full-time and 57 part-time) who provide general care for 66 elderly
patients. The number of staff employed has increased by 5% in the last few years, due to an
increase in the number of patients residing in the nursing home.
The details provided were largely accurate, although staff levels had increased rather than
decreased. It was reported in the questionnaire that health and safety systems were first
implemented in 1998, although they were actually first implemented 6 months to a year after
the organisation began operating. Further information was supplied in relation to the
outcomes of health and safety, i.e. there had been no effect on product damage / waste;
performance / productivity of employees had increased; sickness absence had slightly
decreased; and, there had been no effect on staff turnover. The General Manager did not
know whether or not health and safety had affected staff morale. With regards to the specific
regulations, the Pesticides regulations were not applicable to the organisation, rather than no
action having been taken, as reported in the questionnaire. The issue of procedures for
serious and imminent danger in the Management of Health and Safety at Work Regulations
had actually been implemented, although this had not been reported in the questionnaire.
Likewise, PPE had been provided to employees, under the Manual Handling Regulations.
The organisations main hazards are manual handling and psychosocial hazards. The health
and safety systems include a designated health and safety person, an accident reporting
system, documented risk assessments and a written health and safety policy.
The accident reporting system consists of the employee, who was involved in the accident,
reporting it to the nurse in charge to assist in entering the accident into the accident book.
The General Manager monitors accidents monthly, to look for any trends / common
denominators, e.g. a particular patient or particular piece of equipment. On average, the
General Manager spends approximately half a day a month monitoring accidents. Each
accident is considered, by going through the paperwork and speaking to the employee
involved, to identify whether or not anything can be done to avoid a similar future accident;
or whether the accident was unpredictable. Employees are provided with a health and safety
information sheet and encouraged to report accidents on their induction.
The nursing home has documented risk assessments in place and these include a fire risk
assessment, a falls risk assessment, a room risk assessment and a nutritional risk assessment.
The General Manager developed the risk assessments over a period of 3 months, taking a total
of 2 weeks to develop in real time. Each risk assessment takes approximately 10 to 15
minutes to complete, depending on what is being assessed.
The General Manager manages the health and safety systems and developed the health and
safety policy when she joined the organisation approximately a year after it began. There
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were no health and safety systems in place prior to this. The motivating factors behind the
organisations decision to implement health and safety included legal obligation, insurance
costs, health and safety publicity, and a review of the organisational structure / systems. In
addition, the systems were also developed in conjunction with other systems that were being
developed in the organisation, i.e. the Care Standard Act requires such organisations to be
mindful of health and safety. The organisations insurance premiums have increased
substantially in the last few years and it is believed that the nursing homes health and safety
systems have no affect upon these insurance costs.
The health and safety systems are reviewed annually, although there is an ongoing review of
risk assessments and accidents are monitored monthly. All health and safety systems are
developed and delivered in-house, except for the externally provided fire lectures.
The accident statistics show that there have been a total of 3 accidents in 2001 (i.e. 2 resulting
in less than 1 day off work and 1 resulting in 1 to 3 days off work). This gives a statistic of
0.03 accidents per employee in the organisation, in 2001. Accident statistics also showed that
there had been a total of 6 accidents in the last 5 years (i.e. 4 resulting in less than 1 day off
work, and 2 resulting in 1 to 3 days off work). The General Manager reported that accidents
have increased, believing it to be as a result of a suing culture, whereby accidents have not
necessarily increased, per se, rather people are more aware of being able to make
compensation claims.
It was estimated that the organisation spends approximately 10,000 a year on health and
safety. This estimate gives a figure of 112.36 per employee per year. This yearly spend
includes costs of employee time, teacher time, equipment (e.g. hoists, special mattresses), and
training. Training is the biggest health and safety cost for the nursing home, costing 20 per
hour, per person, in a one-on-one training situation, which lasts for a minimum of 4 hours.
All staff are trained on commencement of employment and then via an annual update. The
majority of health and safety costs are spent proactively, to meet the requirements of
regulations to prevent accidents.
It was considered that the costs and benefits had broken even, with the benefits including that
all staff are trained and, as a result, employees are confident in their work and the employers
have confidence in them. In addition, time lost through accidents has decreased and the
performance / productivity of employees has increased. Sickness absence has also decreased
slightly.
The General Manager was not aware of any future compliance costs that would have a
dramatic impact on the costs currently incurred.
Management of Health and Safety at Work Regulations: the nursing home has risk
assessments in place for all tasks, each of which were developed by the General Manager and
take approximately 10 to 15 minutes to complete. New equipment has been purchased, fire
plans are in place, and there is a new medical questionnaire for health surveillance purposes.
The General Manager has completed a health and safety course and employees received
regular training. All systems were developed internally, except for the fire lecture, which is
externally provided. Difficulties with implementing these regulations only arose with respect
to finding the time needed to develop the systems etc. The cost of these regulations was
estimated to be approximately 143.82 per employee per year. Benefits were considered to
have outweighed the costs, even if the circumstances arose whereby only one employee
experienced health benefits.
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COSHH Regulations: COSHH assessments have been undertaken and these also take
approximately 10 to 15 minutes to complete. PPE has been provided, medical questionnaires
are used to monitor employee health, and training has been provided to employees. The
housekeeping department manages COSHH, being the only department exposed to such
substances. There have been no difficulties in implementing these regulations. The cost of
these regulations was estimated to be approximately 56.18 per employee per year. Benefits
were again considered to outweigh the costs, although there have been no tangible benefits, as
the organisation had not previously experienced any accidents to improve on. Some products
have been substituted for less hazardous materials.
Manual Handling Regulations: the nursing home has two trained trainers and all residents are
risk assessed, with each assessment taking approximately 10 to 15 minutes to complete. The
risk assessments on all patients include the person, equipment and environment. New
procedure documents have been produced in relation to changes in work place practices.
New hoists and PPE have been provided, and all employees attend manual handling training.
Changes to the load have not been made in this environment due to the fact that one cannot
alter the load of a patient! There have been no difficulties in implementing these regulations.
The cost of the regulations was estimated to be approximately 230.34 per employee per year.
Benefits were considered to outweigh the costs, with benefits including raised confidence
levels when carrying out daily duties. There had been no particular incidence of strains /
injuries in the past to improve on.
Currently, information and advice is sought via Croner, Local Enterprise, and HSEs central
resource.
The General Manager found advice and information from HSE to be very helpful, having
been sent guidance in relation to health and safety and risk assessments. The HSE also
funded the General Manager to complete her Advanced Certificate in Health and Safety. A
financial contribution from HSE towards training would be extremely helpful.
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Anonymous
Sector
Questionnaire stated Agriculture. However, the site is used for the manufacture of animal feeds
(mixing, flaking and pelletising) which are sold to the agricultural sector.
Size
Medium: 70 personnel in total (including delivery drivers and sales reps), 56 on site full time
A comprehensive paper and verbal validation of the information was performed. All responses
in the postal survey were reviewed and confirmed as more or less correct, the sector (above)
could be questioned however. There were no inconsistencies identified and there was the scope
to undertake a detailed examination of their records and procedures.
The organisation was born out of the management buyout in 1999, prior to that, the head office
of the parent company was responsible for the health and safety (H&S) systems at the site.
Very shortly after the management buy out, the H&S systems were reviewed and improved, e.g.
accident reporting systems. The directors at the time were made responsible for H&S in light of
the management buy out and in view of this responsibility and their desire to placate the
disruptive workforce by showing the management commitment, the H&S systems were
developed.
The existing systems were used as the basis for the new systems and priorities were set as to
which systems should be developed first, an external consultant was called upon to assist in
setting those priorities. The first step was to designate the H&S responsibilities and roles and
for them to implement / develop the systems as and when required. Initially, the H&S team
(which was made up of managers from various areas of the business) had other business and
could devote some of their time to health and safety.
The Operations Director has ultimate responsibility for H&S, he reports directly to the board
and cascades certain responsibilities to the production and engineering managers. The H&S
team are responsible for the management of all the H&S systems on site.
Newly established organisations (set up in last 5 years)
Not applicable. Although the company was set up less than 5 years ago, they were not starting
from scratch, but merely developed existing systems.
There is a comprehensive accident recording and ill health system in place, this was created
after the management buyout and the records and performance are regularly maintained and
communicated at all levels of the organisation.
The accident frequency has more or less stayed the same at about 0.05 accidents per employee
per annum. It is still considered too early for the management to say whether or not the benefits
have outweighed the costs (or vice versa), although the H&S manager has much increased peace
of mind. Additionally, the accidents that have been prevented, as a result of the management
systems, will always be unknown, which makes the benefits even more difficult to quantify.
The general costs of the compliance (~38k) were mainly to meet the requirements of
regulations to prevent accidents as opposed to reactive after a specific incident.
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The Operations Director was not aware of any future compliance costs that would have a
dramatic impact on the costs currently incurred.
Management of Health and Safety at Work Regulations: The management set the target of
compliance with these regulations by 2002. The main priority was to ensure that the fire
protection was adequate and this made up the largest proportion of the 33k that has been spent
as a result of these regulations (the spend has been since 2000). As a result of these measures,
the insurance company has looked very favourably upon the company and they believe that the
premium has been affected (positively) as a result, although the total premium has still risen by
65% in 3 years. The company feels that, as a result of this and the less tangible factors, the
benefits warrant the expenditure.
COSHH Regulations: COSHH was first reviewed and revised in 2002 and was completed
within a year. The first step was the training of personnel before the rolling out of the COSHH
assessments. Before the management buy out (MBO), the COSHH assessments had been
conducted by a representative of the parent company and these were still used for the first years
after the MBO.
There are very few cost / benefits as a result of the regulations, although the costs are not seen
as disproportionate to the general benefits such as better control over materials on site and
aiding compliance with other regulations associated with their operations.
Manual handling Regulations: This was one of the higher priority areas after the MBO due to
the nature of the operations. The management foresaw that there could be a number of potential
employer liability claims against the company as a result of the amount of lifting operations.
Therefore risk assessments were carried out and then recommendations made to remove the
most hazardous manual-handling element. The solution was to invest 120,000 in palletising
machinery, which was initially seen as a significant outlay. However, the company has seen so
many benefits, as the new system has reduced manpower costs (the machine is able to do the
work of 4 people), and the quality management has improved significantly. The return on
investment was achieved within 2 years of installing the machine and management are now in
the process of purchasing a second machine. There is no doubt that the benefits of the
regulations outweigh the costs. The regs are not considered as particularly onerous and the main
problems encountered were engineering issues during the installation of the machinery.
Noise at Work Regulations: These have not had a significant effect upon the company and the
financial outlay is relatively low. Actions were taken fairly soon after the MBO as they were
seen as fairly uncomplicated and had the potential to protect the workforce (and the companys
liability especially) in the longer term. The first step was to carry out an assessment and create
a noise map and take precautions where necessary. The reduction in noise levels has been
achieved very cheaply and PPE is provided wherever this is not practical or possible. The
largest hurdle to overcome is the culture of employees who are apathetic about wearing ear
protection in certain areas, although with time and regular education, they are improving.
As a result of systems set up prior to the MBO, the organisation already had a (management)
culture that was responsible towards H&S requirements. A lot of investment was made shortly
after the MBO and a prudent approach was taken, with advice from external consultants where
necessary, to ensure that the systems were tailored to the new organisations needs. The
impression was that the biggest barrier was the lack of time and experience of the team with
setting up H&S management systems, but that the external consultant gave some invaluable
advice and assistance in formulating a plan for the site to become compliant as efficiently as
possible. The management have seen a marked improvement in their relationship with the
198
workforce since the MBO and attribute much of this to the fact that the workforce feels more
valued.
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Rohr Aero Services
Sector
Manufacturing
Size
Medium
Background
Rohr Aero Services was originally set up in December 1996, by 5 employees from the
corporate headquarters in the USA. The business became operational in January 1997. The
organisations main activities are the repair and overhaul of aircraft components. Although
Rohr Aero Services is currently only running one site at Prestwick, the organisation has
recently bought 9 other sites throughout the UK. There are 137 employees based at Rohr
Aero Servicess Prestwick site. The number of employees has increased by 6% in the last 3
years, simply due to natural growth as this area of the aircraft industry is currently doing well.
The details provided were largely accurate, although the site now had a total of 137 personnel
on the Prestwick site, which is less than the 146 originally reported in the questionnaire.
There were no further inconsistencies in the data provided, although circumstances had
altered in various other areas. Annual turnover had increased, by 75%, since completion of
the questionnaire. It was also reported, in the questionnaire, that product damage / waste had
decreased since the implementation of health and safety systems, but this effect was now
perceived to be nearer to no affect, since completion of the questionnaire. The cost of
COSHH health surveillance has increased to the next cost range, as a result of carrying out
more regular checks and employing more people in that area. In addition, both Manual
Handling and Noise at Work have become more significant issues in the past year.
The organisations main hazards are noise, manual handling, and use of chemicals. Health
and safety systems include a designated health and safety person, an accident reporting
system, documented risk assessments, a written health and safety policy, performance
measurement and performance targets / objectives. The Environment, Health & Safety
Facilitator is responsible for health and safety, and he reports to the Human Resources
Manager. The management team oversees the health and safety policy, reviewing health and
safety, as a whole, every Monday. The policy itself is reviewed at 6 monthly intervals, or
when changes occur. The health and safety policy and the environmental policy are
integrated.
The accident reporting system consists of accidents being reported directly to the employees
Team Leader, who then completes an accident form (which are located in strategic places and
online). The Team Leader then sends the completed form to the EH & S Facilitator who
enters the accident into an Excel spreadsheet. Accidents are then monitored across the site
(and the site is split geographically into sections). It was estimated that about 5 to 10% of
company time is spent on recording and monitoring work-related accidents. Employees are
encouraged by their Team Leaders / Managers to report accidents. Improvements made, in
relation to reducing accidents, are included in discussions with staff, in addition to the
accident statistics.
The organisations documented risk assessments are currently under review as the system is
being updated to adopt best practice. Training in risk assessments is currently being rolled
out. This training is currently aimed at the Operations Department, as this is where the most
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hazards are present. It was estimated that a risk assessment would take approximately 4 to 5
hours to complete and document.
Rohr Aero Services has a rigorous system of performance targets / objectives and
performance measurement in place. The Corporate targets are to reduce reportable accidents
by 50% in the next year, whilst reducing general accidents by 20%. The organisation has a
Policy Deployment system in place that sets the targets to achieve and measures how each
team is doing against their targets. Teams have weekly meetings to monitor these metrics,
which are displayed on boards around the Operations Department. There are 17 boards, one
per team. The management team reviews each of these boards every Friday, spending 15
minutes per board. The boards are also reviewed for 45 minutes at 6-weekly intervals. In
addition, the EH & S Facilitator has a board which details the overall performance of the site,
split geographically across the site. This shows performance against the overall targets and is
also reviewed by the management team.
External health and safety consultants have been used for air monitoring, and some training.
Risk assessments also used to be developed and conducted by external consultants, but these
are all done in-house now.
Implementation of the organisations health and safety systems was initially considered in
1997, 6 months after the business was set up. The main motivating factors behind the
decision to implement health and safety included the development of the quality and
environmental systems at the same time, the legal obligation, and the organisation having
reached a particular size. The company began with 19 mechanics in December 1996 and
quickly grew to 50 employees within 6 months, which instigated health and safety
considerations. Employee numbers continued to grow quite rapidly shortly after this.
Newly established firms (those established in last 5 years)
The EH & S Facilitator was the organisations first employee and he had experience of health
and safety from the organisation that he previously worked for, where he was a Union
representative and an emergency response team member. Advice and information was also
sought via the Internet and from HSE early on. Initial frustrations / barriers that the
organisation faced, when considering implementing health and safety systems, included the
cost of implementation and matching the cost against operational requirements when trying to
get a business up and running. In addition, there were cultural issues (as the owners were
from the States and therefore not familiar with UK requirements).
When first implementing health and safety, the EH & S Facilitator would have found it useful
to have had access to a pamphlet that covered the basics of what a company needs to have in
place, in order to satisfy requirements. A brief summary, such as this, would prevent an
organisation having to trawl through reams of information to find out what is required.
The EH & S Facilitator advised that an organisation that is newly established, and considering
implementing health and safety systems, should implement the systems as soon as is practical,
developing it as an integrated part of the business. It is also helpful to join local organisations
for information and advice (such as the Ayrshire Occupational Health and Safety Group, of
which Rohr Aero Services is a member).
The accident statistics show that there have been a total of 3 accidents in 2001 and 7 accidents
over the last 5 years. All these accidents resulted in 4 or more days off work. This gives a
statistic of approximately 0.02 accidents per employee in 2001. The EH & S Facilitator stated
that accidents have decreased over the last few years, perceiving this to be as a result of
increased employee awareness and measures that are now in place as a result from learning
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from previous accidents. For example, there used to be a high incidence of cut-hand injuries
and, as a result, the company now issues anti-cut gloves to all shop-floor employees.
It was estimated that the site spends approximately 5,000 a year on health and safety (this
includes employee time, tooling, training, and air monitoring). Employee time is probably the
biggest expenditure. This estimate provides a figure of approximately 36.50 per employee,
spent on health and safety per year, at the Prestwick site. It was stated that approximately
60% of the sites spend is incurred reactively, as a consequence of a health and safety
incidents, leaving 40% for proactive spend, meeting the requirements of regulations in order
to prevent accidents.
It was considered too early to say whether the benefits outweighed the costs, although it is
perceived that benefits will outweigh the costs in the long-term. Current benefits include
increased performance / productivity of employees, decreased sickness absence, increased
staff morale through raised awareness, and a decrease in the time lost through accidents. Staff
turnover is also very low, at 2%. Insurance costs have not increased significantly in recent
years.
The EH & S Facilitator stated that costs were expected to increase in the near future, as a
result of a new directive in relation to the reduction of vibrations and noise. Some of the
organisations pieces of equipment generate a significant amount of noise. New legislation,
in relation to reducing noise exposure further, will therefore have cost implications for Rohr
Aero Services.
In addition, the organisation is also moving the Prestwick site to a new site, local to the
current one, and this will incur significant costs. It was also perceived that compliance with
the COSHH regulations would become more expensive for organisations in the future.
Management of Health and Safety at Work Regulations: The site has risk assessments in
place, compliant equipment, and health screening has been introduced for painters and
welders. The training provided to employees includes training in risk assessments, general
awareness training, and training in emergency response. Refresher training also takes place
annually or sooner, if any changes come into effect. With respect to other employers with
whom the site shares a workplace, a permit to work system has been created for contractors.
The cost of these regulations was estimated to be between 208 and 898 per employee as a
total each year across the regulations, on the Prestwick site. Again, it was perceived to be too
early to say whether the benefits outweighed the costs, but benefits included those detailed
earlier, in addition to an increased awareness, within the management team, of health and
safety and their responsibilities.
COSHH Regulations: COSHH assessments are done in-house and COSHH training (initial
and refresher) is given to affected employees. Control measures include PPE, storage
facilities, and spill control measures. The management team spends time reviewing the
COSHH controls. Regular 6-month air monitoring and LEV testing takes place and the health
of painters and welders is surveyed via skin vitality and lung-function checks. Health
surveillance costs have recently increased in this area, due to carrying out more regular
checks and employing more people in this area of work. The cost of these regulations was
estimated to be between 73 and 255 per employee as a total per year across the regulations,
for the Prestwick site. It was stated to be too early to say whether the benefits outweighed the
costs, but it was perceived that these regulations would become more expensive to comply
with in the future. Benefits of COSHH included supporting the EH & S Facilitator to raise
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awareness of the safety needed when handling chemicals i.e. the provision of regulatory
backing.
Manual Handling Regulations: Manual handling risk assessments and training are conducted
and work practices / processes have been changed through changes in layout. Back supports
have been provided for Logistics personnel. The site is currently looking to procure new
equipment to aid manual handling. Assessments and controls are reviewed regularly at 2-year
intervals. Manual handling, as an issue, has increased significantly in the past year, with an
incidence of 3 strains, 2 of which were in an area that the review and development of risk
assessments is currently focusing on. 1 of these 3 strains was RIDDOR reportable. The cost
of these regulations was estimated to be between 52 and 128 per employee as a total per
year across the regulations, for the Prestwick site. Again, it was stated that it was too early to
say whether the benefits would outweigh the costs in this area.
Noise at Work Regulations: Noise monitoring is conducted by an external assessor.
Reduction of exposure has been targeted via procurement of quieter equipment. Employees
receive regular training in relation to noise exposure, and ear testing is included as part of an
employees medical. Noise, as a hazard, is increasing in significance for the Prestwick site: a
new component, that is very noisy to assemble and disassemble, has recently been brought in
and this will need to be dealt with. Costs will be increasing, due to improvements such as
more regular screening of employees hearing, procurement of acoustic booths, and acoustic
screening. Difficulties can arise in the implementation of these regulations, as employees
may not see the immediate risk to their hearing, due to the effects often taking a while to
surface. It will also take a while to become familiar with the interpretation of the New
Directive coming into place. The cost of these regulations was estimated to be between
25.55 and 117 per employee as a total per year across the regulations, for the Prestwick
site. No real benefits have been observed as of yet, as it was again perceived to be too early
to say.
Advice and information is currently sought via Croner, IOSH, and HSEs central resource.
The EH & S Facilitator did not feel there was a lack of guidance in any particular area, as the
organisation subscribes to Croner and IOSH and the HSE web site has been improved. Rohr
Aero Services is also a member of local organisations, and the networking within these
groups has greatly improved.
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Peal Engineering Ltd
Sector
Manufacturing
Size
Medium
Background
Peal Engineering manufactures vegetable harvesting and grading equipment for both the
domestic and export trade. The organisation has been in operation for approximately 20 years
and has a total of 52 full-time employees.
A comprehensive validation of the information was performed. All responses in the postal
survey were reviewed. There were no inconsistencies identified and the site interview provided
further supporting information.
The organisations main hazards are manual handling, noise, and electrical / machinery hazards.
The health and safety systems include a designated health and safety person, an accident
reporting system, documented risk assessments, and a written health and safety policy.
The current system was developed during a restructuring that took place in 1996. Other
motivating factors behind the organisations decision to implement health and safety included
the legal implications and the organisations insurance premiums (so that these do not increase
as fast). The health and safety systems were also developed in conjunction with the
organisations quality assurance, to ensure more effective compliance and efficient business
processes. The business was already well established before the management system was
installed and the Production Director took on the responsibility for full implementation,
reporting directly to the organisations Board. The health and safety policy is reviewed
annually and approved by the Board. External resources were also bought in, from health and
safety consultants, to assist where appropriate.
The accident statistics show that there have been a total of 17 accidents in 2001 (i.e. 15 that
resulted in less than 1 day off work; 1 that resulted in 1 to 3 days off work; and, 1 that
resulted in 4 or more days off work). This gives a statistic of approximately 0.33 accidents per
employee, in 2001. There have been a total of 74 accidents over the last 5 years, with 68 of
these having resulted in less than 1 day off work. The number of accidents is skewed towards
accidents resulting in minor first aid required. However, there are a small number of cases,
typically one each year, which results in an injury to incur more than 4 days off work.
Typically the costs in any one-year are around 5,000, with this expenditure primarily being
taken up with external consultancy (3,000 per year), training fees (1,000 per year), and
management time / equipment (1,000 per year). This gives an estimate of approximately 96
per employee, per year, spent on health and safety. There has been no appreciable increase or
decrease in the frequency of accidents, although there has been a trend towards a slight increase
in recent years. The benefits have been intangible and are primarily related to more effective
working practices and work planning.
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The Production Director was not aware of any particular future compliance costs that would
dramatically impact on the costs currently incurred.
Management of Health & Safety at Work Regulations: Risk assessment procedures are now well
established and consultancy support is used where appropriate. Three visits, including site
inspection, are undertaken each year, with the possibility that this might be reduced to two visits
in the near future. Advisory leaflets have been produced, guiding staff on the hazards in the
workplace and regular refresher training is provided when required. Difficulties, in
implementing these regulations, only arose in relation to the time it took for staff to adjust to
new expectations. The cost of the consultants carrying out the full site survey and quarterly
review is 4,500 a year (although this yearly cost should be reduced now that the system itself is
set up). Fork lift training, working at heights training, and manual handling training cost
approximately 3,000 a year. Benefits and costs were perceived to have broken even, with
benefits being largely intangible via improvements in work planning and scheduling production.
Pesticides Regulations: Employees are not exposed to pesticides, except in rare circumstances
where equipment is being tested in the field. Some stored crops are also surface treated with
pesticide and this product is handled through the machinery that is built by Peal Engineering.
COSHH Regulations: Small quantities of chemicals are stored on site in a lockable storage area.
The Production Director is responsible for the safe use of chemicals on site, which are primarily
associated with cleaning and surface treatment chemicals. Limited amounts of paint are also
stored on site and used during the manufacturing process. A small number of staff are trained in
the use of COSHH. The cost of these regulations includes 1,500 for equipment; 950 for
annual testing, e.g. L.E.V. tests, monitoring of exposure to employees; and, 300 for continual
updating of information instruction and training. As COSHH itself is not a significant issue for
the organisation, there have been no real benefits identified.
Manual Handling Regulations: Heavy lifting gear and forklifts are used on site. Guidance is
given to personnel whilst working off site in relation to what they can and cannot do.
Manufacturing activity involves the construction of large metal structures supporting vegetable
harvesting and grading equipment. Smaller items are palletised, but inevitable significant lifting
tasks are required when moving and transporting machinery. All this work is undertaken in a
carefully planned way with a significant proportion of the manufacturing being packed in crates
for the export market. Only a small number of these operations involve any manual
intervention. Training is provided on the manual handling of small loads in compliance with the
regulations, at an approximate cost of 1,000 per year. Costs and benefits were perceived to
have broken even, but no tangible benefits were identified.
Noise at Work Regulations: Noise levels in the manufacturing environment are limited to hand
tools and a small number of metal turning and shaping / press items. Training is provided on
PPE and precautions are taken about the site. Off site, staff are rarely exposed to significant
noise levels. Hearing defenders and ear plugs are supplied at a cost of 400 per year, the
creation of a hearing protection zone cost 80, and leaflets and poster campaigns have cost
approximately 200. There have been no real health benefits observed as of yet.
Information, advice and other considerations
The recent downturn in profitability within UK agriculture has meant that Peal Engineering has
become increasingly dependent upon export. They are finding it difficult to compete in a highly
competitive marketplace where the UK requirement is to comply with so many regulations.
Advice and information are currently sought via health and safety consultants, HSEs central
resource and inspectors, and via the Federation of Small Businesses.
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Grayston Automotive Ltd.
Sector
Transport
Size
Medium
Background
Grayston Automotive is a nationwide vehicle distribution organisation that was established 12
years ago by Andrew Grayston. The organisation began with just one transporter and now
runs 74. It increased by 50% 2 years ago on account of a major contract awarded to supply
35 lorries to an auction group. There are 125 staff in total (120 full-time and 5 part-time),
50+ of which are based on the site at Nateby. Nateby is the organisations only site, all other
staff work on lorries out-based, using registered parking areas and having contact every day
with the office for instructions and feedback. In addition, phone contact in the evenings is
covered by a duty mobile.
The details provided were largely accurate, although accident prevention was reported as an
additional motivating factor behind the decision to implement health and safety systems.
Another observation was in terms of costs and benefits, where discussion revealed that these
had broken even, when dont know had originally been reported in the questionnaire.
The organisations main hazards are vehicles / transportation, slipping and tripping and poor
lighting (i.e. loading in poor lighting on sites not owned by the organisation). The health and
safety systems include a designated health and safety person, an accident reporting system,
documented risk assessments, and a written health and safety policy. The health and safety
systems are written and managed by the Quality Manager and overseen by senior
management. The Quality Manager reports to the Operations Director who has ultimate
responsibility.
Accidents are reported via calls made to the traffic office, which then deals with the accident.
If the accident is serious, the Operations Manager is contacted and the Quality Manager is
notified, if necessary. If an employee has slipped or an injury has occurred, this is entered
into the accident book and a form is completed, a copy of which is also sent to the Quality
Manager. The Quality Manager monitors the accident book once a week for entries. Serious
accidents are followed up within 12 hours and staff are monitored if they have been in
hospital or if they have had any time off, as a result of the accident. 4 weeks after the
accident has occurred, the employee is contacted to make sure that any measures put in place
are working. The Quality Manager is also notified, by phone, of any near misses that occur.
Staff are generally very cautious and are taken through the process of recording accidents in
the accident book, on their induction. The organisation has control measures in place and a
policy of sensible operation. Drivers are given a safe system at work update whenever they
arrive on the Nateby site.
There are approximately 6 types of documented risk assessments (e.g. for display screen
equipment, the workshops, the traffic office, washroom / canteen, the vehicles), but most of
the risk assessments are for various aspects of the transporters. These include risk
assessments for the ramps, lorries, trailers, operation of the decks etc., in addition to a general
risk assessment for driving the lorries and a risk assessment for each vehicle. Grayston
Automotive has 20 factors affecting driving that all have to have a level of risk ranking
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attributed to them. The risk assessments generally take half an hour, per 5 minutes of
operation, to complete, although this time is extended if the risk assessment needs further
discussion. It would be discussed with the Operations Director and then at a Health and
Safety Committee if further conferring was needed, but risk assessments are generally signed
off by the person responsible for the area being assessed.
Health and safety systems have been in place, on some level, since the organisation began
operating, although it was decided that a role needed to be dedicated to health and safety,
once the organisations activities increased. The Quality Manager took on this role 2 years
ago, improving and developing the formal documentation of the policies and procedures. The
written health and safety policy took an ongoing period of 6 weeks to develop (although the
Quality Manager did not work solidly on it every day during this period). The systems are
generally updated yearly, although the policy was last updated in November 2002 and the
accident books are monitored weekly. Aside from the improved documentation of facts, the
other motivating factors behind the organisations decision to implement health and safety
systems were the legal obligation and prevention of accidents.
The Quality Manager reported that insurance costs against personal accident had actually
reduced.
The accident statistics show that there have been a total of 36 accidents in 2001 (i.e. 25 with
less than 1 day off work; 6 accidents resulting in 1 to 3 days off work; and 5 accidents
resulting in 4 or more days off work). There have been no non-fatal major injuries or fatal
injuries. This gives a statistic of 0.27 accidents per employee, within the organisation, during
2001. Accident records for the last 5 years were kept in a different format to that used
currently and so these statistics were not available for comparison. There are more accidents
being reported now, due to the increase in staff, but no particular increase in accidents has
been observed, once staff numbers are compensated for. Accidents are monitored for any
trends and it is the younger drivers who tend to have the most accidents as, although the
young drivers are all trained, they still lack the experience. There is also a trend of slipping
and tripping accidents and so control measures have been put in place in an attempt to reduce
these (e.g. all drivers are being supplied with anti slip boots).
It was estimated that the organisation spends between 10,000 and 50,000 a year on health
and safety, yet this figure was reported to be closer to the higher end of the range as it
includes the wages of the Quality Manager and all the associated ongoing time costs of
completing risk assessments etc. This therefore gives an approximate figure of 74.07 -
370.37 per employee per year. The cost of having 2 first-aiders covering night shifts is also
included in this yearly spend. The Quality Manager estimated that 85% of their spend was
proactive, whilst 15% was reactively spent in terms of the time involved in investigating and
acting upon any accidents that occur.
It was considered that the costs and benefits had probably broken even. Aside from the legal
factor, benefits included reduced risk-taking, an enhanced company reputation, less drivers
off work (but not significantly so), and increased staff morale through positive reactions to the
health and safety awareness.
No major future costs are currently anticipated, although the organisation is considering
conducting fire safety training and this might affect building specifications. There may also
be incurred costs on the transporters in 3 years time, via possible changes to the policies
surrounding the decking, if testing is stipulated.
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Management of Health and Safety at Work Regulations: the organisation has documented risk
assessments in place, as detailed earlier; all employees have induction and safety awareness
training; and control measures have been implemented (i.e. storage containers have been
built, workshop electrics changed to 110V, faulty machinery replaced, and electrical testing
carried out). The regulations are managed internally by the Quality Manager and there have
been no real difficulties with implementing these regulations. The cost of these regulations
was estimated to be approximately 125.93 per employee per year, although some of these
costs are as a proportion of the designated health and safety persons wage. Costs and
benefits were considered to have broken even, with the same general health and safety
benefits as detailed earlier.
COSHH Regulations: there is a continual review and assessment of the substances used and
specific items of clothing have been bought and hired for protection. The first action when
implementing these regulations was listing and removing substances via a general visual
assessment. The chemicals used by the organisation are mostly those that can be bought over
the counter. These regulations are also managed in-house. Difficulties have only arisen in
relation to gaining information re latex gloves i.e. the supplier has thus far been unable to get
the required information from the manufacturer. The cost of these regulations was estimated
to be 81.48 per employee per year. Costs and benefits were again considered to have broken
even, with 3 chemicals being removed so that they are no longer used. However, there had
been no previous accidents involving chemicals, except for an incident whereby an employee
was allergic to a certain soap, and this soap has since been substituted.
Manual Handling Regulations: there is no specific manual handling training within the
organisation as of yet, although it is one of the items for development on the agenda due to a
number of twisting injuries. The Quality Manager does not want to issue training before it
has been properly developed. A safe system of work is, however, explained to all staff. In
addition, there is a list of risk assessments, in relation to manual handling, which are also
being developed.
Noise at Work Regulations: assessments of working areas and time exposed to noise have
been carried out and hearing defenders have been provided to all affected staff. These
regulations are not a high priority for the organisation, as exposure only occurs within the
workshops and this itself is not a high risk. Exposure limits are well within the specifications
and ear defenders are provided for any short bursts of noise in the workshops. There are no
noise issues on the lorry side of the business. There have been no difficulties in the
implementation of these regulations, which are again managed in-house. The cost of these
regulations was estimated to be 7.96 per employee per year. However, the employee time
invested, which is included in this cost, is again a percentage of the designated health and
safety persons wage. Costs and benefits were again considered to have broken even, with
benefits being that employees do not suffer from hearing problems, although they had had no
problems in the past.
Currently, advice and information is sought via Croner, HSE inspectors, and the Road
Haulage Association.
It was stated that notification, from HSE, of new guidance / policy that supersedes previous
information would be very useful. Although the Quality Manager noted that HSE might state
that this information is available on their web site, he has found that the update page is often
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12 months old. The organisation wants to know more about HSEs future action plans. It
was suggested that a system on HSEs web site that was easier to access and scroll through,
and in a downloadable format, would be much more useful.
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Jim Brackenridge Transport Ltd. (JBT)
Sector
Transport
Size
Medium
Background
JBT was established almost 10 years ago, with the Altens site having operated for 6 years. It
is a motor freight transportation and vehicle repair organisation, with maintenance workshops
based in Cumbernauld. There is a total of 106 employees within the organisation (103 full-
time and 3 part-time), 32 of whom are full-time employees based on the Altens site. JBT has
experienced a natural growth in staff of 10% per annum, although this increase is likely to
stop for a few years now. The organisation consists of 5 sites in total.
The details provided were largely accurate, although extreme temperatures was added as an
extra hazard of concern to the organisation. With respect to the Management of Health and
Safety at Work regulations, health surveillance, as an issue, had also been acted upon,
although this has not been reported in the questionnaire. Likewise, in relation to the Manual
Handling regulations, changes to the work environment, and training and information were
also being implemented but were not originally reported in the questionnaire. Costs of spend
given for the COSHH and Manual Handling regulations were organisation-wide figures,
whereas the Management of Health and Safety at work costs were site-wide figures. The only
other observation was made in relation to the Noise at Work regulations, in that it was
reported in the questionnaire that action had not been taken, yet during the visit these
regulations were stated as not being applicable to JBT, as forklifts produce very little noise.
JBTs main hazards are vehicles / transportation, manual handling, dust, extreme
temperatures, and poor lighting (although lighting is less of a hazard on the Altens site). The
health and safety systems include a designated health and safety person, an accident reporting
system, documented risk assessments and a written health and safety policy. The Depot
Manager carries out the health and safety audits and manages the health and safety systems
for the site, in conjunction with the Health and Safety Advisor. An external consultant is also
paid an annual fee to assist in developing the organisations health and safety systems.
The accident reporting system consists of recording accidents in a book, according to the
RIDDOR system. It is not reviewed on a frequent basis but there have been no major
accidents. Accidents have been recorded since the organisation was established.
The documented risk assessments include those for operating forklift trucks, transporting
hazardous material, safe movement of people and machines within the JBT premises, use of
display screen equipment, and, loading the road tanker with flammable liquid. There are
plans to develop further risk assessments. The Depot Manager conducts the risk assessments
and these take approximately 1 hour to complete.
The Health and Safety Advisor manages the health and safety policy for the whole
organisation. This policy and its statements were reviewed at the end of last year, as were the
above documented risk assessments. There is no formal monitoring system in place, as such,
although the site has previously brought in an advisor every 6 months.
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Documentation of health and safety was implemented in 1999, although the methods were in
place prior to this. There were a combination of motivating factors behind the organisations
decision to implement health and safety systems and these included: legal obligation, health
and safety publicity, a review of organisational structure / systems, and the organisation
reaching a particular size. The growth of the organisation was quite significant last year, with
depots having opened up in Shetland and Orkney, resulting in the addition of another 30
employees. Another motivating factor was that the health and safety systems were developed
in conjunction with the organisations quality system, which was being developed in line with
haulage industry standards. The safety of employees is another motivating factor, as well as
enhanced company profile when the organisation is seen to be acting with health and safety in
mind.
No accidents occurred in 2001 and there were only 2 accidents in total in the last 5 years (i.e.
1 resulting in 1 to 3 days off work and 1 non-fatal major injury). These figures are for JBTs
Altens site. This gives a statistic of 0.06 accidents per employee on the Altens site, over the
last 5 years. The organisation has not really had a problem with accidents, thus far, and
therefore no significant increases, decreases, or trends have been observed.
It was estimated that the site spends approximately 20,000 a year on health and safety, which
includes site upgrades, training (driver training, first aid training for office staff, NEBOSH,
basic health and safety courses), and provision of PPE. This gives an estimate of 625 per
employee spent on health and safety on the Altens site each year. Training costs the site
approximately 5,000 a year, PPE approximately 3,500 to 4,000 a year and the site
upgrades have cost 40,000 in total over the last few years, in addition to future costs,
although these further upgrade costs will not be as large as this initial outlay. Almost all the
health and safety spend is as a result of proactive compliance, as there have been very few
accidents to initiate reactive spend.
It was considered that the benefits of health and safety had outweighed the costs, with
benefits including raised awareness amongst staff, and a raised company profile through
meeting health and safety standards. Insurance premiums have also decreased overall, as a
result of the driver training conducted. Product damage / waste has also decreased as a result
of both the site upgrades and the forklift training / manual handling training. In addition, time
lost through accidents has decreased, as a whole, over the years.
The Depot Manager was not aware of any future compliance costs that would significantly
affect the health and safety costs incurred. There will be the continued costs, such as training
(e.g. an awareness course in relation to dangerous goods), but no significant new costs.
Management of Health and Safety at Work Regulations: every employee receives a risk
assessment manual, there are specified traffic routes, and a fire plan and notices are in place.
A safety committee is currently being organised and workforce training is documented,
providing information to all employees. In terms of health surveillance, dust used to be a
major concern, but this hazard has since been removed from the workplace. Internally, all
sites have appointed full first aiders, and there is an employee trained to NEBOSH standard
on the Altens site. Further health and safety assistance is gained via external consultation.
This third party inspects sites quarterly, although this role will be taken over by the Depot
Manager in the future. There are plans to develop all areas of these regulations further in the
near future. The cost of these regulations was estimated to be 406.25 per employee per year,
as a figure for the Altens site. Benefits were considered to have outweighed the costs, with
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benefits being a lack of accidents, improved safety of employees, and increased productivity,
via an improved work environment.
COSHH Regulations: an external consultant was employed in order to implement and manage
these regulations. The consultant had direct contact with the Operations Director within the
organisation. Most of the substances handled by JBT are in relation to shipping (relevant to
the Shetland and Orkney sites). Difficulties in implementing these regulations have only
occurred in relation to the Cumbernauld site, with improvements having been put on hold, as
the site is being moved. All issues within COSHH will be taken action on eventually. The
cost of these regulations was estimated to be 5,000 a year across the 5 sites within the
organisation (this is the yearly cost of employing the third party). This gives an estimate of
47.17 per employee per year for the whole organisation. Benefits were considered to
outweigh the costs, and include increased awareness, with most benefits mainly being seen on
the workplace side of the organisation.
Manual Handling Regulations: the site has a manual handling risk assessment and training in
moving and handling and correct use of forklifts. With respect to changes in work practices,
electrical / non-electrical pallet trucks are being introduced. All employees are issued with
full PPE. Implementation, in relation to changes in the work environment, includes the
upgrading of sites, such as changing the loading bays on the Cumbernauld site. These
regulations have been managed in-house, with no major difficulties. The cost of these
regulations was estimated to be 169.81 per employee per year, across the whole
organisation. Benefits were again considered to outweigh the costs, with benefits including a
lack of aches and pains amongst staff and general increased awareness.
Noise at Work Regulations: N/A. The forklifts produce very little noise.
Currently, advice and information is sought via Croner, HSEs central resource, and the
Internet.
It was stated that more information regarding changes in legislation would be helpful in the
form of a flyer or an email. In addition, more industry-specific information, i.e. geared
towards the haulage industry would be useful. More information re forklifts, again via either
an email or a flyer would also be beneficial.
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Aviation Fuel Services (AFS)
Sector
Transport Sector: Aircraft fuelling
Size
Medium
All the information from the questionnaire was reviewed and confirmed correct, although the
number of employees has reduced slightly to 60 in total (due to natural wastage) since the postal
survey was first completed. The total number of employees was reported as being 46 (and
therefore small) in the questionnaire, whereas the organisation was clarified as being
medium in size, during the site visit.
The company is responsible for most of the aircraft refuelling at Heathrow Airport and is
heavily influenced by BP, Q8, Chevron and TFE (formerly Total). BP has an especially keen
interest in the H&S at AFS and gives guidance on the systems as well as conducting audits at
regular intervals. Many of the systems have been in place for many years (approx 20 years) and
were implemented in response to the HASAWA in 1974 and revised in light of experience and
new legislation ever since. The Technical Services Director is responsible for implementing the
H&S systems, although the General Manager is ultimately responsible, the General Manager is
a role that is held by a representative of one of the 4 companies for a period of 3 years at a time.
Due to the unique parent company approach, there is almost a blank cheque for health and
safety issues.
All accidents (however minor) are recorded, investigated and actions taken depending upon the
nature of the incident. The accident rate has actually increased in recent years, but the H&S
manager believes that this is as a result of better reporting than down to a less safe workplace -
this is indicated by the nature of the accidents / incidents that are reported. The manager
believes that the costs of the compliance are outweighed by the benefits that the measures bring
to the company. This is due to the positive effects it has had on other aspects of the operation.
The workforce feel particularly valued, and initiatives taken by the company that benefit the
employees in their personal lives as well as in their jobs further reinforces this, e.g. defensive
driving courses.
The Technical Services Manager was not aware of any future compliance costs that would have
a dramatic impact on the costs currently incurred.
Management of Health and Safety at Work Regulations: The annual spend in relation to these
regulations is approximately 21,200, which equates to 350 per employee. All elements of the
regulations, with the exception of procedures for serious and imminent danger, have been
satisfied. The main areas of concern for the site are noise and manual handling. The H&S
manager manages the regulations. There have been no major problems encountered with
respect to these regulations. BP have given a lot of support and guidance and the training of the
H&S manager has meant that there were no real surprises and the systems could be
implemented internally. As regards the benefits of these regulations, the H&S manager feels it
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is not easy to say, but he assumes that they prevent accidents from occurring and therefore can
only conclude that the benefits outweigh the costs.
COSHH Regulations: There was already a procedure and controls in place prior to the COSHH
regulations coming into force. As a result the only action required was to formalise the process
in a way to satisfy COSHH regulations. The annual spend is approximately 24,500, much of
which is spent on PPE and machinery to protect the personnel. The H&S manager is
responsible for all the assessments and conducts an annual review of the systems and material
safety data sheets (MSDS) etc to ensue the site is compliant. There werent many problems
encountered initially and Mobil (now BP) were very helpful in assisting in the process, although
sometimes it was difficult to obtain the MSDS from manufacturers and the culture of the
mechanics to order materials without requesting the MSDS has been an issue. The first step
taken was to obtain an inventory of substances held on site so that the management knew what
they were dealing with. All of this was carried out internally. Unlike the other regulations, the
management do not feel that the benefits outweigh the costs as there is a very limited number of
chemicals held on site.
Manual Handling Regulations: There is a very high amount of manual handling associated with
the operations at the site and there is a continuous effort by the company to minimise the risks to
the employees. As a result, approximately 50k is spent each year to aid the employees, the
bulk of which is the modification to the vehicles that are used to transfer the kerosene from the
distribution mains to the aeroplanes. This equates to approximately 830 per employee per year
on manual handling issues, although there is a significant cost saving in that the operations now
only require one man, as opposed to two men. An additional bonus is that there has been no
incident of a worker injuring himself as a result of manual handling operations. 3
rd
party
trainers are employed to train the workforce, indeed this was the first step taken to satisfy the
regulations. There have not been any major challenges in satisfying the regulations, although
changes to aeroplane design has resulted in some issues (the work involves the operators raising
their arms above their heads, some aircraft now have higher wings!) There arent any other
aspects that they feel they are lacking, although there will be a big initiative on the issue of falls
from heights and they are trying to remove the need for dipping the tankers.
Noise at Work Regulations: Again, due to the nature of the industry, precautions against noise
were already an integral part of their working practices. Therefore the company has not felt
many benefits of the introduction of the regulations, although it does not question the benefits of
the measures that they have taken to protect the workforce. The hazard of noise has actually
decreased over the decades, as aircraft engines have improved technologically i.e. are a lot less
noisy! The H&S manager is responsible for managing the systems in place and ensures that the
employees are trained and provided with the PPE as well as maintaining records and testing of
their hearing. Chevron also conducts an audit of the workplace noise on a 3 yearly basis.
Despite the companys size, it does have a wealth of advice and information at its fingertips by
virtue of the multinational companies that have a direct interest in AFSs operations. In addition
to this, HAL (Heathrow Airport Limited) also has its own standards and expectations for
companies that operate within the apron. The company is very proactive in its approach to
H&S, which is very much driven from the management downwards, through the organisation.
On a local level, the company has a very good relationship with the HSE local inspector and
finds that (on a personal level) they are always able to receive guidance and assistance on most
matters.
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Anonymous
Sector
Agriculture
Size
Large
Background
The organisation breeds pedigree livestock and has been in operation for over 40 years.
There are a number of farms, a veterinary laboratory, 4 hatcheries and head office. There are
500 employees, approximately 400 full-time and 100 part-time. There are a range of hazards
particularly at outstations (farms), including chemicals, fire, dust, manual handling, LPG,
working with animals, electricity, working from height and vehicles. There is also an added
danger associated with needlestick injuries (that was not reported in the questionnaire but
discussed during the visit).
The information reported was largely accurate. Supporting evidence was presented to the
researcher during the visit including health and safety policy, procedures, risk assessments
and accident statistics.
There is a health and safety steering group, with representatives from all aspects of the
companys activities, chaired by an Associate Director nominated by the Board of Directors.
The groups driver is the Safety and Security Co-ordinator. Procedures and policies are
reviewed and updated, agreed by the Group, endorsed by the Board of Directors and
disseminated to line management level. For example the health and safety policy is reviewed
each year. The latest review includes the addition of occupational road safety as this had been
recognised as a significant health and safety risk that had not been previously considered.
Generic assessments are conducted by the Safety and Security co-ordinator. These are
supported by specific assessments at a local level. Accidents are monitored and a briefing
generated annually, giving statistics for the year and any actions resulting from the
information. Audits of all sites are conducted by the Safety and Security co-ordinator. It is
recognised that there are difficulties associated with managing the risks at contracted farm
sites i.e. non company sites where floor space is rented, technical advice is provided and the
company collects the eggs.
Accidents are recorded and any resulting in more than one day lost are subject to a review by
the local manager, the Safety and Security Co-ordinator. Ultimately, the health and safety
steering group, where the learning outcome for other similar sites is reviewed, review the
post-accident risk assessment.
Accidents are thought to be more accurately recorded and monitored than ill-health. It is
considered that ill-health is harder to discriminate as being caused by work or non-work
activities. There have been 42 accidents in the last 5 years, and 5 in the last twelve months
(2001). There has been a steady reduction in accidents, particularly manual handling related
accidents. The organisation has provided train the trainer sessions for local managers to
assist in raising awareness of manual handling risks and safe working procedures. It is
thought that this reduction in lost time may also be influenced by the changing
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recommendations by GPs, who now advocate that those suffering from back pain stay at
work, where possible.
The costs were reported as being between 10k and 50k in 2001/02. However, on further
discussion, it was agreed that the more accurate estimate was at the latter end of this range
due to the salary costs of the Safety and Security co-ordinator coupled with time of steering
group and control measures. Therefore, the costs of compliance with health and safety
regulations are estimated at 100 per employee per annum. The costs are considered to
outweigh the benefits, largely because it is thought to be impossible to calculate the
reputational risk associated with a poor health and safety record.
The main reason for introducing a security manager was as a result of threat to the security of
employees and property from animal welfare activists. Whilst there had been some
consideration of health and safety as part of this role, the introduction of the six pack
regulations in 1992 lead to much more formal and comprehensive systems and the
recruitment of a Safety and Security Co-ordinator qualified in health and safety management.
The subtle change in title emphasis, to endorse safety first, is an acknowledgement of how far
the company has progressed in safety terms. The main motivators for implementation of
health and safety systems are experience of accidents (and associated claims), and legal
obligation. A previous accident, 12 years ago, resulted in the only prosecution (no history of
any enforcement notice). All subsequent visits from any local HSE inspector are always
prefaced at some stage with the recall of that accident, even although the Rehabilitation of
Offenders Act acknowledges the conviction referred to as a spent conviction. The Safety and
Security Co-ordinator feels that this does not send a good message to the company and that it
might be targeted as a result of this previous history.
The Safety and Security Co-ordinator is also responsible for the Environmental policy and
environmental auditing on sites and as such these systems are integrated as far as possible.
The organisation was not aware of any specific costs associated with health and safety
compliance in the future, other than maintaining existing systems and continuous
improvement.
Management of Health and Safety at Work Regulations:
The health and safety policy details 41 safe operating procedures for managing health and
safety. The Safety and Security Co-ordinator conducts generic risk assessments and specific
assessments, although the specific risk assessments are conducted in conjunction with local
managers. The Safety and Security Co-ordinator conducts annual audits at each location to
ensure that the policy is implemented and to identify any remedial action and training needs.
Health surveillance procedures are carried out and any risk and cluster areas identified are
dealt with. The protection of the animals from disease also aids in ensuring the immediate
health of employees and stool samples are taken from each production employee each week
and these are tested at the company laboratory.
Compliance with these regulations poses a significant cost to the organisation, estimated at
80% of their total health and safety expenditure.
Pesticides Regulations:
There are significant links with the Environmental Policy in the control of use of pesticides.
The costs are minimal, estimated at less than 2500. Training of farm staff is undertaken.
216
COSHH Regulations:
CPSHH was the first of these Regulations to be addressed. There was a significant
investment in a SHE system to formalise risk assessments and safety data sheets. Due to the
sheer numbers of chemicals used, 600 in total, compliance with these Regulations is the
second most costly to the organisation, estimated at approximately 14, 000.
Manual Handling Regulations:
Local managers identify handling activities and assess the risks. Local trainers have received
training to assist in assessment as well as raising awareness of the risks among employees.
There have been some significant investments in eliminating handling. For example, piping
in gas to avoid use, and therefore handling, of gas canisters. The cost of these interventions is
minimal. However, the total cost to the organisation is considered to be higher than reported
in the questionnaire, costs of employees time associated with in-house training (not
calculated in the estimated costs). As previously mentioned there has been some significant
reduction in the number of manual handling related incidents.
Noise at Work Regulations:
Steps have been taken to identify, measure and reduce noise levels where required. The costs
associated with this activity are minimal (< 2000).
Information and Advice
Whilst it is acknowledged that the HSE has positive associations with the trade association, it
is felt that there could be more done to build positive relationships with individual companies.
The previous incident involving HSE is considered to have damaged relationships and as such
the current relationship between the local HSE and the organisation could be much improved
if a more advisor approach was adopted by HSE.
217
Anonymous
Sector
Construction
Size
Large: 2500 personnel
All responses in the postal survey were reviewed. Generally the responses were found to be
accurate and much of the information was either confirmed verbally or records were reviewed.
The site interview concentrated on confirming further detail to back up the responses.
The organisations main hazards are electricity, confined spaces, and boiler plant pressure
systems. The main motivating factors behind the organisations decision to implement health
and safety systems included: a change in culture of the organisation (due to a change of client,
as a procurement issue); a legal obligation to secure consistency with compliance; and, an
increase in the size of the organisation (i.e. easier to manage through employment of an
integrated system).
Much of the current health and safety systems were established in 1994 when the organisation
was substantially restructured. The company has a fully developed integrated management
system in place that covers H&S, Quality and Environmental performance. The system is
certified to ISO9002 and ISO14001 and the structure of the H&S components follows the
guidance in OHSAS18001 / HSG65. At the last certification audit there were no substantial
compliance or non conformance issues.
The systems are maintained by a centralised H&S resource with the individual businesses
providing inputs to the system as appropriate. A centralised database is used to track actions
and conformance issues and the H&S resource report through the Technical Director to the
Main Board.
resulted in less than 1 day off work; 16 that resulted in 1 to 3 days off work; 40 that resulted
in 4 or more days off work; and, 8 non fatal major injuries). There have been zero fatal
injuries. This gives a statistic of approximately 0.1 accidents per employee in 2001. Statistics
also showed that there had been a total of 897 accidents over the last 5 years. The number of
accidents has been relatively constant with no appreciable increase or decrease in frequency.
It was estimated that the organisation spends in excess of 50,000 per year on health and safety,
although it was difficult to determine the exact figure, as the Business Unit Directors are
responsible for the spend. This estimate provides a figure of 20 per employee spent on health
and safety, per year.
It has been very difficult to confirm exact costs and benefits and the Company Accountant has
been consulted to confirm estimates. H&S costs are not clearly identified on the balance sheet
and the estimates could not be formally confirmed. The accident profile has been monitored
over six years and the nature of the accidents have not changed with no obvious trend in the
nature of the accidents. Benefits, however, are likely to outweigh the costs and have included
an effective market position, good responses in relation to competitive procurement, and
meeting blue chip expectations.
218
The H, S & E Manager was not aware of any particular future costs that would dramatically
impact on the health and safety costs currently incurred.
Management of Health and Safety at Work Regulations: Substantial effort has been invested in
developing an approach to consistent risk assessment procedures. The individual business now
undertakes its own risk assessments, with guidance from Head Office where appropriate. It has
been estimated that around >50K is spent on this activity and the benefits against this
expenditure are associated with better work planning and safer working practices.
Pesticides Regulations: Specialist advice is sought where services provided require pesticide
applications. Only a small number of personnel in the company are familiar with the
requirements of the regulations. Cost implications are minimal, in many cases, <5K but there
are no perceived benefits except for improved occupational health, which was regarded as
intangible and difficult to put a value on.
COSHH Regulations: Only small chemical inventories are stored on any one site. Chemicals
are stored, external to the building in locked cabinets. Only nominated personnel have access to
the cabinets. Cost implications have been quite significant due to the ongoing effort to maintain
the database and keeping track of deliveries and the chemicals in use. The training requirement
has cost >50K to implement.
Manual Handling Regulations: This is an ongoing requirement with most costs in the 10K to
50K categories. Training and specialist support are, again, the major costs. Prevalence of back
injuries / complaints have not substantially changed. Benefits are difficult to quantify, but the
perception is that less sick leave is being taken as a result.
Noise at Work Regulations: Noise exposure can be acute, undertaking specific site based
activities. Cost implications are typically <1000, reflecting the specialist nature of the
requirement and the fact that remedial action has not been particularly expensive to implement.
Again, it is difficult to identify any tangible benefits. Greater staff turnover in recent years and
the age cohort becoming younger tends to reduce or mitigate against hearing loss being picked
up.
There are clear concerns in the UK, that H&S regulations are strictly implemented and adhered
to; yet amongst our European partners there does not appear to be the same level of
commitment.
Currently, advice and information is sought via a variety of sources, including RoSPA, Croner,
IOSH, HSEs central resource and inspectors, the Internet (DEFRA), and the Technical Index.
219
Anonymous
Sector
Health Services
Size
Large
Background
The organisation was established over 60 years ago, although the site visited has been
operating for 27 years. There are 300 staff (280 full-time and 20 part-time) on site. The
organisation consists of 1300 employees overall (1150 full-time and 150 part-time). The
main activities undertaken, by this research organisation, are blood transfusion, blood product
preparation, tissue banks, collecting blood, and supplying blood products.
The details provided were largely accurate. However, discussion surrounding the estimated
spend on health and safety, in the last full financial year, revealed that the anticipated spend
could be 3 times as much as the figure originally reported in the questionnaire, should the
National Safety Adviser receive a larger budget in order to roll-out an improved training plan
for the organisation. The only other inaccuracy in reporting was also with respect to costing
the spend on health and safety generally. For overall reporting of costs, the cost of the
designated health and safety persons wage was not included in the overall yearly estimate.
Furthermore, the cost of the on-site occupational health nurses time was also not included in
the costing. With respect to the costing for spend on each of the regulations, it was noted that
those given for the Management of Health and Safety at Work, COSHH, and Manual
Handling were organisational figures over a 2 year period, whereas the Noise at Work costing
consisted of annual costs for the site.
The main hazards are chemicals, biological agents, sharps / needlesticks and manual handling.
The health and safety systems include a designated health and safety person, an accident
reporting system, documented risk assessments, a written health and safety policy,
performance measurement, and performance targets / objectives. All sites have a local health
and safety adviser and a health and safety committee, whilst the site visited also has a
National Safety Adviser. The National Safety Advisers Group oversee the health and safety
policies and actions. The health and safety systems were first considered in 1974, when the
Health and Safety at Work Act was passed, although health and safety was generally not
taken very seriously until the 1990s, when a National Safety Adviser was appointed.
The accident reporting system consists of an accident / incident form which is completed
immediately after the accident / incident has taken place (unless the accident involves sharps,
in which case this must be treated prior to completing the form). The form is then sent to the
National Safety Adviser to record, who spends approximately 5 to 10 hours a month
recording accidents, depending on the number of accidents that have occurred. The records
are examined for any patterns / trends, e.g. a number of glass tube breakages were picked up
and so the organisation changed to using plastic tubes. The National Safety Adviser
developed the accident reporting system, in conjunction with the occupational health nurse,
and based it on classification within a HSE report. Employees are encouraged to report all
accidents and incidents, only being blamed for not reporting.
The health and safety policies consist of a general statement in addition to a number of
specific policies dealing with issues such as waste control, radiation, PPE etc. There are
approximately 32 different policy elements both in terms of health and safety and
220
occupational health. The system is managed by the National Safety Adviser, who proposes a
policy, writes it up and then sends it to the National Safety Advisers Committee for review.
The policy is then edited and considered again until it is accepted, when it is presented to the
Partnership Forum. After acceptance in the Forum, the policy is entered into the
organisations health and safety directory, where it is accepted as a local policy.
The site has approximately 40 to 50 documented risk assessments, with approximately 500
risk assessments across the whole organisation. The organisation has a number of general
risk assessments and a multiple of specific ones. The site has spent around 6,500, over the
last 2 years, on training Risk Assessors.
The health and safety systems are updated yearly unless changes in legislation prompt an
earlier update. An audit survey is conducted annually by two health and safety advisers from
other units within the organisation, in order to document and measure the sites health and
safety performance. The organisations performance targets consist of elements classified
according to ratings of 1 to 4, with respect to the order of priority in which the elements need
to be eliminated.
The health and safety systems were developed due to a combination of factors consisting of:
experience of accidents within the organisation, legal obligation, a review of the
organisational structure / systems, in addition to the organisation reaching a particular size.
The organisation has increased a lot, at a steady rate, over the years and appropriate structures
were needed, providing an overall central control of systems. Any issues relating to employer
liability insurance are not applicable to this organisation, as the government does not insure
this type of organisation.
The accident statistics show that there have been a total of 74 accidents in 2001 (i.e. 72 with
less than 1 day off work; 1 accident resulting in 4 or more days off work; and 1 accident
resulting in a non-fatal major injury). There were no fatal injuries. This gives a statistic of
0.25 accidents per employee on site, in 2001. Statistics for accidents having occurred in the
last 5 years were estimated as being a total of 265 accidents overall (i.e. 258 resulting in less
than one day off work; 5 accidents resulting in 1 to 3 days off work; and 2 accidents resulting
in 4 or more days off work). There have been no fatal major injuries in the last 5 years.
Although the statistics over the past 5 years are not as accurate as the current system, and
even though more forms have been completed, due to raised awareness surrounding health
and safety, it is perceived that there have been less accidents overall.
It was estimated that the site spends approximately 10,000 a year on health and safety.
However, the National Safety Adviser has a budget of 22,000 a year, approximately 75% of
which is spent on training (bought in from external providers), 20% on equipment and 5% on
software. A further 30,000 has been requested in order to improve the organisations level
of training. 95% of the health and safety spend is considered to be proactively spent, i.e.
compliance costs on identifying and preventing accidents before they happen. In considering
the 10,000 a year quote, the site spent approximately 33.33 per employee on health and
safety in the last year.
It was considered that the benefits of health and safety had outweighed the costs. There have
been no serious accidents, general health and safety awareness has increased, and staff are
more motivated and happy, since their health and safety has been given greater consideration.
Productivity of employees has generally increased and sickness absence has decreased.
It is anticipated that future costs may be incurred as a result of a site survey investigating
noise control measures, particularly as the sites standards will be slightly stricter than the
221
European recommendations. Further costs may also be generated via problems with hygiene
in the manufacturing establishment (pharmaceutical); reducing radioactive isotope use; and, a
possible future organisational cost of 100,000 for protecting sites from terrorist attacks.
Management of Health and Safety at Work Regulations: the organisations risk assessments
are always being updated and a risk assessment itself can take anything from an hour up to a
week to complete, depending on the detail involved in that particular risk assessment. Fire
risk assessments take longer than some others due to the travel time incurred being a
significant factor. The policy documents state the management responsibilities and these are
reviewed yearly by the audit team. The organisation has an occupational health nurse on site
4 days a week, there is a variety of training for staff including: training of risk assessors,
health and safety training, procedures for serious and imminent danger, etc. Assessments are
carried out for special arrangements relating to temporary workers / new and expectant
mothers / and young persons. Problems, when implementing the regulations, are issues
around finding the time and resources, which can at times create conflict with the
organisations core activity of providing a service to their patients. The cost of these
regulations was estimated to be 70.77 per employee, across the whole organisation, over the
last two years. Benefits of improved staff morale, and risk assessments having set standards
to reduce injury, were seen to outweigh the costs.
COSHH Regulations: the organisation manages COSHH nationally, which provides an
overall view, although each site has its own COSHH assessments. The training of assessors is
an ongoing 3 year rolling programme, after which there will be another 3 year programme,
and so on. PPE checks are in place, monitors are provided (which also incurs recalibration
costs), as are L.E.V. tests / checks. The organisations health surveillance procedures include
respiratory sensitisers, animal-handling procedures, and post immunisation, Hepatitis B. The
organisation also has a computerised database covering information, instruction and training
for persons who may be exposed to substances, health and safety risks, etc. Specialist advice
on Legionella has been sought via an external consultant (although this cost came out of the
engineering budget). In addition external radiological protection advisors were also
consulted. The cost of these regulations was estimated to be 22.54 per employee, across the
whole organisation, over the last two years. The benefits were seen to outweigh the costs and
include a reduced likelihood of employees contracting occupational asthma and dermatitis,
i.e. there are definite health benefits for the organisation.
Manual Handling Regulations: Risk assessments and assessor training are in place; there is an
occupational health nurse on site who carries out the manual handling training and provides
advice; hoists / lifts, PPE (gloves), and ergonomics training are also provided. Aids have
been provided for changes to work practices, layouts in the work environment have also been
changed and suppliers have been informed re changes to the load in the goods supplied.
Although the organisation can control their internal environment quite well, they do have
problems with respect to the venues that they visit to collect blood etc., i.e. such venues are
beyond the organisations control and yet they may be problematic in terms of manual
handling and ergonomics issues. The cost of these regulations was estimated to be 13 per
employee, across the whole organisation, over the last two years. Benefits that include
reduced injuries to staff were seen to outweigh the costs.
Noise at Work Regulations: The organisation has specified low noise equipment and has
provided ear defenders, signage for hearing protection zones, training videos / leaflets and
audiometry. The audiometry is carried out internally by the occupational health nurse yet the
cost of this is difficult to quantify, as it would include the cost of pulling staff out of
manufacturing. An external specialist carried out the site-wide acoustic survey. Problems
222
with respect to these regulations consist of convincing staff that they need to use ear
protection even when they are only going into the affected area for 5 minutes, the managerial
factor is therefore being targeted in order to make sure staff are encouraged more in this area.
The cost of these regulations is estimated to be 12.33 per employee, per year, across the site
visited only. Benefits are again seen to outweigh the costs, and they include: the health
benefit, i.e. staff do not suffer from hearing problems as a result of noise at work; the staff are
more comfortable as the work environment is less stressful; and, staff morale has increased as
a result of the action taken.
Currently such advice is sought through RoSPA, Croner, IOSH, HSEs central resource and
inspectors, plus the Internet, such as the Home Office web site and web sites detailing
Material Safety Data Sheets (MSDS) which provide information on chemicals and COSHH.
The National Safety Adviser would like HSE to improve their flow of information, to give
organisations an idea of what areas the HSE might be tackling in the future, e.g. on their web
site, where it would be helpful to provide more guidance and to keep organisations more
informed of current and future issues.
223
Morecambe Bay Hospitals NHS Trust
Sector
Health Services
Size
Large
Background
Morecambe Bay Hospitals NHS Trust was established 4 years ago, although the individual
hospitals making up the Trust have been operating individually for many years prior to the
Trust merger 4 years ago. There are 5 hospitals within the Trust, which employs a total of
4500 staff (3500 full-time and 1000 part-time). Of these 4500 staff, approximately 800 are
based at the Kendal site. The hospital in Kendal is the headquarters for the Trust, and also
includes some Primary Care Trust facilities, e.g. mental health, dental units, etc.
The details provided were largely accurate although the number of employees on the Kendal
site was 800 to 1000 employees within the Trust total, and this had not been reported in the
questionnaire. The approximate annual turnover and the estimate of spend on health and
safety in the last 12 months, provided in the questionnaire, were both figures for the whole
Trust rather than for the hospital at Kendal. Accident statistics were not provided in the
questionnaire as the Trust classifies them differently. In terms of the outcomes of health and
safety, the reported decrease in product damage / waste and increase in performance /
productivity of employees were stated to be more as a result of quality issues rather than
health and safety. In addition it was stated that compensation claims had substantially
increased in the last 2.5 to 3 years, although the questionnaire had reported that it was too
early to say.
The Trusts main hazards include manual handling, psychosocial hazards (particularly stress),
violence, slipping and tripping, chemicals, and ionising radiation. The health and safety
systems include a designated health and safety person, an accident reporting system,
documented risk assessments, performance measurement, performance targets / objectives,
and a written health and safety policy. The Head of the Health and Safety Department writes
the policy, which then goes out for consultation to 80 safety representatives over a 2 to 3
month timescale. Modifications of the policy are then submitted to the Trust Board, or one of
its sub-groups, for approval.
The Head of Health and Safety manages the accident reporting system. When an accident
occurs, an official internal accident report is completed, a copy of which is retained by the
department, another by occupational health, and another is sent to health and safety.
Accidents are currently reviewed on a monthly basis, although reviewing would normally be
done annually. It was estimated that the health and safety department spends approximately
5.5 hours, on a daily basis, to record and monitor the accidents. In the last 2 years, near
misses and dangerous occurrences have also been reported and recorded. Employees are
encouraged to report accidents in the induction training programme, and by further training
courses for managers and staff, which are run approximately 8 times a year and are accredited
by IOSH.
The organisation has thousands of documented risk assessments that were developed by each
of the individual heads of department. Risk assessments are completed by trained staff and so
even the more detailed risk assessments take typically less than an hour to complete.
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Health and safety systems were first introduced and developed at the Kendal site in 1997,
which was when the health and safety department was established. Health and safety had
been piecemeal prior to 1997. The motivating factors behind the decision to introduce health
and safety systems included legal obligation, visits from HSE / Local Authority inspectors,
and removal of Crown Immunity in 1989 which meant that the organisation had to comply
with health and safety legislation just as any other organisation would.
All systems are developed and managed internally and accreditation is achieved. External
guidance is only sought with regards to consulting radiation protection advisors. Health and
safety performance is measured through the number of employers liability claims, the
accident and incident frequency rate and the RIDDOR system is used to benchmark systems.
Audits are carried out yearly and these lead to the setting of performance targets and
objectives each year. All health and safety systems are reviewed annually.
The organisation has heavily invested in health and safety and compensation claims have
increased substantially in the last 2 to 3 year period. However, the health and safety systems
in place have allowed the organisation to defend itself more confidently, resulting in claims
being not as expensive as anticipated. The Trust has also seen an increase in their insurance
premiums and these premiums are indirectly affected by the Trusts health and safety
performance.
The accident statistics show that there have been a total of 49 accidents in 2001 (all were non-
fatal major injuries of 4 or more days off work). There were no fatal injuries in 2001. This
gives a statistic of approximately 0.01 accidents per employee, within the Trust, during 2001.
Accident records, as a total for the last 5 years, show that there have been 131 accidents that
resulted in non-fatal major injuries of 4 or more days off work. Monitoring of accident
records have shown an increase, but this is viewed to be as a result of a more robust reporting
system in addition to a more stressful working environment (e.g. introduction of new
technology, management of change, etc.) rather than a simple increase in the incidence of
accidents.
It was estimated that the Trust spends approximately 250,000 per year on health and safety.
This estimate provides a figure of 55.56 per employee per year. This yearly spend increases
each year and, amongst other resources, this figure includes implementation of engineering
risk control measures / systems (e.g. it cost the Trust 30,000 to 40,000 to introduce safety
barriers around the building), health and safety training / instruction, and staffing.
Approximately 80% of this spend is considered to be reactive, i.e. incurred as a consequence
of health and safety incidents, leaving 20% of this spend attributed to proactive compliance.
The yearly spend figure does not include the additional revenue investment the Trust makes
for statutory maintenance, provision of personal protective equipment, etc.
It was considered that the benefits of health and safety implementation had outweighed the
costs. Benefits included a marginal increase in staff morale, and better publicity from an
NHS perspective. In addition, litigation costs are honing peoples attentions to implement
control measures and the health and safety systems allow the organisation to defend claims
more confidently, thereby reducing the expense of claims.
Future compliance costs include investment in the prevention of violence and aggression for
all staff. This would take the form of extensive training and would cost the organisation at
least 40,000 to 50,000. Further additional costs include updating policies and the purchase
of personal alarms for staff.
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Management of Health and Safety at Work Regulations: the organisation has numerous risk
assessments and control measures in place in addition to a fire procedure emergency plan and
joint fire safety and first-aid policies in co-operation with other employers who share the
same workplace. Health surveillance procedures include monitoring lung function,
dermatology investigation and counselling. Training courses are provided for staff and
managers and the organisation has policies in place relating to temporary, expectant and new
mothers and young persons. These actions were developed internally by the Head of Health
and Safety Department who was brought in reactively to comply with the legal obligation.
Difficulties in implementation included arguing the case for the regulations in terms of
needing more definitive guidance in relation to the ratios that need to be covered, i.e. the
amount of time / resources which would be expected to be invested per number of employees
within an organisation. It is believed that such guidance would be particularly helpful to
SMEs and thereby also helpful to large organisations too, e.g. an organisation of a certain
size would generally be expected to require a health and safety advisor one day a week. The
cost of these regulations was estimated to be approximately 85.32 per employee within the
Trust, over a period of 4 years. Benefits were considered to outweigh the costs and include a
generation of confidence and reassurance that health and safety systems are in place, in
addition to the provision of the ability to identify any short falls and develop action plans to
deal with them.
COSHH Regulations: the organisation has developed a risk assessment pro forma and
collated Material Safety Data Sheets (MSDS). COSHH assessments usually take longer to
complete (about an hour) than general risk assessments (which take about 20 to 30 minutes).
A master database of COSHH assessments and general risk assessments is currently being
developed. LEV has been installed and PPE purchased. Engineering LEV Control measures
are given 14-monthly examinations and employee health is monitored via occupational
hygiene. Employees have also been provided with training. COSHH has been quite difficult
to implement as it is much more scientific and technical, so managers tend to find it is more
difficult to understand. These regulations were also costly to implement, disproportionately
so considering the amount of chemicals used, although they are very valuable to the
organisation. The Pathology Department has a high level of compliance with COSHH. The
cost of these regulations was estimated to be 43.80 per employee within the Trust, over a
period of 4 years. The benefits were again considered to outweigh the costs, with benefits
including substitution of substances with safer materials, and a safer health history with health
surveillance monitoring showing that the number of people being harmed has decreased. In
addition, atmospheric workplace pollution has also decreased.
Manual Handling Regulations: the organisation provides training and information on
induction in addition to refresher training, which each take half a day to complete. Key
trainers are also being trained in a wide range of techniques, which takes 1 to 1.5 days. There
have been changes to the work place practices, environment and load. Hoists have been
purchased and the organisation is currently investing in developing risk assessments further,
and purchasing more equipment such as hoists and banana boards, so that mechanisation is
improved prior to investing more in training. PPE (footwear and gloves) and occupational
health services are also provided. These regulations have been quite difficult to implement in
that the risk measures reduce the likelihood of injuries, but employees may still have an
accident. A high level of discipline is needed by staff to carry out moving and handling
correctly; meaning a drop in standards could be made quite easily. In addition, difficulties
can arise as elderly patients generally expect to be lifted rather then being helped to move.
The cost of these regulations was estimated to be 50.69 per employee within the Trust, over
a period of 4 years. The benefits were again considered to outweigh the costs, although the
benefits are less tangible in that the number of accidents is static (there is a lot of under-
226
reporting) and many people see manual handling as part of their job. Occupational health
records are confidential, although the Head of Health and Safety would expect that there has
been an increase, (but only around 10 to 15%) for injuries related to manual handling.
However, claims for manual handling injuries have not increased dramatically. In addition,
the majority of costs in relation to implementing changes in work place practices, result in
savings.
Noise at Work Regulations: noise surveys are carried out in-house by qualified staff and new
equipment has been purchased to reduce the noise exposure at source. Information and PPE
has been provided to employees and hearing protection zones have been created. The style of
working has also been changed to reduce the noise. Difficulties in implementing these
regulations have arisen in that it has been a bigger issue than managers anticipated, meaning
that resources were limited, and the regulations are quite specialised and technical, although
internal qualified staff were available to deal with the technical side. The Trust probably
needs about 20 to 30 noise surveys a year, and only about 15 are currently carried out, due to
time restrictions. The cost of these regulations was estimated to be 5.31 per employee
within the Trust, over a period of 4 years. Benefits were again considered to outweigh the
costs and include less anxiety and stress among employees, health benefits for employees, and
less opportunity for staff to submit claims (meaning that the Trust does not have to pay out for
claims). Benefits for these regulations are more tangible than those for manual handling, i.e.
suppress the noise and gain immediate health benefits; but harm can still occur, c.f. with
manual handling, even though engineering controls and training are all in place.
Currently information and advice is sought via Croner, Barbour Index, IOSH, HSEs central
resource, in-house professionally qualified health and safety personnel, and the Internet (e.g.
the Freight Transport Association web-site, HSE and European health and safety sites).
The Head of Health and Safety Department would find case study examples specific to the
health service very useful. It is advantageous to read about anonymous organisations
mistakes. If these could be reported in the form of a newsletter relevant to each HSE
enforcement sector, such as HID, construction, health services etc., that would be beneficial.
The organisation subscribes to various health and safety indices. However, contract reports
and guidance leaflets are all in black and white. If these were on the HSE web site, in a
downloadable format, they could be e-mailed and put on the organisations Intranet, etc., for
broader dissemination.
227
Anonymous
Sector
Manufacturing
Size
Large: 1000 personnel
A comprehensive paper and verbal validation of the information was performed. All responses
in the postal survey were reviewed and confirmed as correct. There were no inconsistencies
identified and there was the scope to undertake a detailed examination of their records.
The organisations main hazards are manual handling, slipping / tripping hazards, moving parts
of machinery, and display screen equipment. The main motivating factors, behind the
organisations decision to implement health and safety systems, were the legal obligation,
supply / chain pressure, and specific incidents (e.g. a fire assessment that was conducted by
external authorities).
The current operation was subject to a management buyout from another organisation
approximately 4 years ago. The company is well established and has been operating on the
Colchester, Wrexham and Salford sites for many years. For the first two years after the
management buyout, the previous organisations system was relied upon. However, increasing
problems with compliance led the management to undertake a complete overhaul of the system
in place. The current health and safety system has been in place for about two years. The
Health and Safety Manager reports through a Director, to the Main Board, and the current
system is deemed to be more appropriate for the organisations current needs. They have never
intended to integrate the management systems and prefer to keep the management of health and
safety separate.
resulted in less than 1 day off work; 4 that resulted in 1 to 3 days off work; 9 that resulted in
4 or more days off work and 1 non fatal major injury). This gives a figure of approximately
0.07 accidents per employee, in 2001.
There is a comprehensive accident recording and ill health system in place. An occupational
health nurse has also just been recruited for the Colchester site. The Wrexham site is due to
close shortly and production will be consolidated at Colchester, primarily. Wrexham had initial
problems with health and safety performance and this was picked up by the HSE. There has
been a collaborative programme of system development that has turned performance around,
but health and safety was one of the factors considered when strategic decisions were being
made regarding the manufacturing base of the company. As a result, overall accident rates have
been improving slowly and the safety culture in the organisation is much improved.
It was estimated that the organisation spends in excess of 50,000 per year on health and safety,
which provides a figure of approximately 50 per employee, per year. The main costs have
been associated with capital investment, primarily around automation to enhance productivity,
but an additional benefit has been the reduced manual intervention in the production processes,
which has led to an inherently safer working environment. Consolidation of production on the
one main Colchester site has also resulted in considerable economies of scale and higher
degrees of automation. However, in the clean rooms there are still a large number of production
operatives working. This is where most of the accidents now occur.
228
Training costs are also a significant item, typically up to 50K per annum, and it reflects the
level of commitment the company now has to enhancing safety awareness across the workforce.
Benefits are therefore perceived to have outweighed the costs.
The Health and Safety Manager was not aware of any particular costs, in the near future, that
would have a dramatic impact on the costs currently incurred.
Management of Health & Safety at Work Regulations: Considerable effort has gone into
implementing the system and procedures to support compliance with these regulations. A
comprehensive set of guidance material and procedures are now in place to undertake risk
assessment and there is a well defined route to the reporting of incidents and near misses.
Internal and cross audits between sites are undertaken to ensure conformance. Difficulties, in
relation to implementing these regulations, have only arisen with respect to workload. The cost
of these regulations has been one of the major parts of health and safety expenditure. The
annual spend on these regulations is in the region of 56,000, which provides an estimate of 56
per employee per year. There is also an aspiration to be more proactive in terms of preventive
health, and recent recruitment decisions will enhance this position. Benefits are perceived to
outweigh the costs, with one tangible example seen in the organisations insurance premiums,
which are affected by the health and safety systems in place.
COSHH Regulations: Considerable effort has gone into establishing COSHH records and
several staff have been trained in the requirements of the regulations. Initial costs were quite
high in getting the system established and the training in place (20K initially). Ongoing
commitments and staff time are relatively modest. The cost of implementing these regulations
is estimated to be 23,000, per year, which is an approximate spending of 23 per employee per
year. An extensive range of chemicals are stored on site and the benefits are mainly associated
with better control over the management of chemicals and the inventory at each site and reduced
occupational exposure. It is, however, still quite difficult to put tangible values on these
benefits.
Manual Handling Regulations: Specialist guidance and awareness training has been provided
across key staff. The situation on all sites has gradually improved with the introduction of bulk
handling facilities, particularly associated with polymer handling and storage. The company
anticipates that the move from Wrexham to Colchester may expose staff to greater risks for a
short while but this should improve again in 2003. The cost of these regulations was estimated
to be approximately 82,000 (i.e. approximately 82 per employee, per year). Benefits are
again perceived to outweigh the costs, in specific areas, through use of mechanical aids and
appropriate training.
Noise at Work Regulations: Noise levels in the clean rooms have been surveyed and PPE is
provided, where appropriate. This is particularly relevant to staff working on equipment that
exposes them to intermittent high frequencies, rather than overall noise levels. The cost of these
regulations was estimated to be 11,000 (i.e. approximately 11 per employee per year).
Generally the benefits are considered to outweigh the costs but are difficult to quantify.
The organisation has invested considerably in health and safety since the management buyout
and this is evident in the systems that are now in place to monitor and improve on health and
safety performance. The company has welcomed the interaction with the HSE and although
difficult at first, they have been able to benefit considerably from the help and advice that has
been available.
229
Advice is currently sought from a variety of sources, including health and safety consultants,
RoSPA, Croner, HSEs central resource and inspectors, and via a subscription to the Barbour
Index.
230
News International Newspapers Ltd.
Sector
Manufacturing sector: Printing, publishing and allied products
Size
Large. Approximately 2,220 personnel on site (3,650 in the whole organisation).
A thorough paper and verbal validation of the information was performed. All responses in the
postal survey were reviewed and there were no inconsistencies identified.
News International appears to have a very proactive approach to H&S, in both the identification
and prevention of issues and the extent to which they protect the workforce. The organisation
has invested heavily in H&S systems in the past 13 years. There is a full time H&S team made
up of a Director and two full time H&S Managers (Production and Editorial), each with their
own assistant. This was set up in response to the high number of accidents that were occurring
within the company and the legal and insurance consequences of those accidents. The H&S
team were then responsible for establishing the other systems now in place, which include an
accident reporting system, documented risk assessments, a full H&S policy and performance
measurement.
The organisations main hazards include working with display screen equipment, noise, and
manual handling.
The accident statistics show that there have been a total of 323 accidents in 2001 (i.e. 289
resulting in less than 1 day off work; 3 resulting in 1 to 3 days off work; 30 resulting in 4 or
more days off work; and, 1 non-fatal major injury). This gives a statistic of 0.15 accidents
per employee on the London site, in 2001. Total accident statistics for the previous 5 years
were 1614 (i.e. 1445 resulting in less than 1 day off work; 15 resulting in 1 to 3 days off
work; 150 resulting in 4 or more days off work, and 4 non-fatal major injuries), although
these statistics were reported as being less accurate than those reported for 2001. There is a
comprehensive accident recording and ill health system in place, with full incident investigation
and reporting. The accident rate has more or less remained the same with very few major
accidents in recent years. This is a marked improvement to the early 1990s when the systems
were first set up.
Most of the 1.1 m annual spend on general health and safety is in relation to compliance with
regulations, although they believe their standards go beyond regulatory requirements. Less than
5% would be as a result of a specific incident or accident on site. The bulk of this spend is on
the improvement of machinery - due to the number of newspapers that are produced each day,
there is a heavy reliance upon large-scale fast printing machinery.
The company appears to put a very high price and emphasis on safety and strongly believes that
heavy investment in safer systems is of great benefit to the company. This is evident in the
increase in productivity and staff morale as well as the decrease in product damage and sickness
absence. There has also been a reduction in the insurance premium by 5%, after a H&S audit by
the companys insurance company - there was no proof presented to support this and it could be
questioned whether other factors may be attributable, or whether the terms of the insurance have
changed.
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It was anticipated that future costs would be increasing, in particular with respect to plans to
take further in relation to the Noise at Work Regulations.
Management of Health & Safety at Work Regulations: Annual spend in relation to these regs is
in the order of 240k. The first steps were taken over 10 years ago and started with the training
of personnel in all areas - this lasted for approximately 2 years. As well as the legal obligation,
the company wanted to be more pro-active in its approach to health and safety and saw this as
the ideal vehicle for that change in company ethos. Following some HSE investigations, the
company had previously made a lot of retrospective modifications to the working environment
without adequate planning. The culture of reacting to events resulted in the organisation not
solving the problems first time round.
COSHH Regulations: Following a high incidence of dermatitis amongst operators at the site, in
addition to legislation, the company decided to take measures with respect to these regs. The
first step taken was to conduct risk assessments and review the inventory of materials held on
site and then put controls in place or remove / replace the unnecessary substances. The largest
obstacle initially was to identify exactly what chemicals were held on site; there were a lot of
unlabelled containers of varying sizes, which were simply disposed of. Zurich Engineering and
the HSE gave advice and assistance in relation to these regs. The company has definitely seen a
benefit in implementing the measures to comply with these regs, although it was stated that it is
difficult to quantify. The main benefits have been the reduction in dermatitis amongst the
workforce and a less wasteful approach to the purchasing of chemicals. The annual spend is
estimated at 256k, which equates to approximately 1k per employee affected by chemicals.
Manual Handling Regulations: This is the area where the company has spent the most amount
of money, resulting in the replacement of large printing lines over a 2 year period. This equates
to 6.7 m per annum and approx. 6k per employee affected by the new equipment. The first
steps were the conducting of risk assessments and the purchasing of manual handling equipment
- the history of the printing industry meant that there were some very unsafe practices taking
place and there was an apathy amongst workers to change, which was the major obstacle
initially. The benefits are that the whole environment is much safer and the risks have been
sufficiently reduced. The management believe that the benefits have outweighed the costs,
despite the massive investment.
Noise at Work Regulations: The actions taken in relation to these regs were all implemented
internally as a result of identifying that there could be some long term effects upon the
workforce, and due to the risk of potential litigation against the company. The first steps taken
to satisfy these regs were to conduct audio assessments followed by noise mapping / surveying
of the site. The overall cost of the measures taken is approximately 125k per annum. For
those effected, the average spend is approximately 175 per employee. Again, the largest
obstacle in implementing the measures was the general apathy of the personnel to use PPE,
although they are more educated these days, perhaps as some personnel have suffered long-term
effects. The likely benefits are that the number of claims, as a result of hearing damage, is
likely to reduce, but the real benefits will probably not be realised for another 10 years.
Currently, information and advice is sought via a variety of sources, including health and safety
consultants, RoSPA, Croner, IOSH, HSEs central resource, and HSE inspectors.
The company has some specific concerns relating to workplace transport (inside the wire) as the
site is in operation 24 hours a day and involves a constant flow of traffic. The H&S team have
identified that musculo-skeletal problems will be the next area that they would like to address.
232
Anonymous
Sector
Transport
Size
Large: 280 full-time employees on the York site (with 5,200 full-time employees within the
Yorkshire Division).
Background
The organisation is a large bus company providing passenger transportation, with 13
engineering sites for conducting bus repair / refurbishment. The organisation has been in
operation for 10 years. The York site has been operating since 1995, but only as the current
organisation for the last 5 years (it was previously part of another company).
The details provided were largely accurate, however, when considering the overall health and
safety spend in the last 12 months further consideration, as a result of discussion with a
colleague, elevated the estimate to the higher end of the range stated in the questionnaire. Slight
inaccuracies were identified when going over the figures quoted regarding the spend on each
issue of the specific regulations, although these were a consequence of missing a nought off one
of the figures rather than not including a significant spend. No further inaccuracies were
identified.
The main hazards are vehicles / transportation (ten tonne vehicles moving round a confined area
in addition to high mileage), assaults on drivers by the public, and trips / slips and falls. Hand-
arm vibration is also a problem across Yorkshire, although not on the York site. Health and
safety systems include a designated health and safety person, an accident reporting system,
documented risk assessments, performance measurement, performance targets / objectives and a
written health and safety policy. The Divisional Safety Manager advises on health and safety
issues, and the team leaders are responsible for the day-to-day running of safety. In addition,
the organisation has a health and safety person responsible for the site. There is a certain
amount of local autonomy in managing health and safety, although systems are being
standardised at the group level of the organisation.
The accident reporting system consists of a health and safety incident report form that is
completed and then given to the sites accident investigators (ex-police). The accident
investigators investigate and document vehicle accidents and are currently being trained to
investigate personal injury as well. The accident investigator records accidents on the
organisations computer (fig-tree) system, and this is done throughout the organisation. Near
misses are also recorded, although it is difficult to know how accurately near misses are
reported.
The health and safety policy was developed internally and the Yorkshire Divisional policy is
disseminated down to each site, being reviewed at the group level. Documented risk
assessments have been in existence since 1998, with there currently being 82 risk assessments in
place across the various activities in the organisation. The organisation also measures
performance across a range of indicators and these are measured against costs at the group level,
as are the performance targets / objectives.
All health and safety systems are reviewed and monitored monthly at 3 levels in the company
(i.e. the site monthly health and safety committee meeting; the Divisional Board meeting, which
233
reviews accidents and health and safety in general at the divisional level; and, health and safety
is also reviewed monthly, at the country level, across the organisation).
The health and safety systems were first developed 6 years ago due to a combination of factors,
as follows: supplier / customer / client pressure; insurance costs, union pressure, the
organisation reached a particular size, and legal obligation. If market perceptions are that the
organisations employees are not properly provided for, with respect to health and safety
systems, then share prices drop. The organisation is therefore under pressure from its
shareholders to have appropriate health and safety systems in place. Health and safety systems
were also needed when the site increased in size and the company was taken over by the current
organisation. Insurance costs are huge, and increase year on year, with the perception being that
organisations probably have reduced premiums once they have health and safety systems in
place.
In addition, a staff survey carried out approximately 3 years ago, revealed that the number one
concern for employees was health and safety, which is another reason for keeping health and
safety high on the company agenda.
The accident statistics show that there have been a total of 82 accidents in 2001 (i.e. 68 with less
than 1 day off work; 9 accidents resulting in 1 to 3 days off work; and 5 accidents resulting in 4
or more days off work). There were no occurrences of non-fatal major injuries or fatal injuries.
This gives a statistic of 0.29 accidents per employee on the York site, in 2001. Statistics for the
previous 5 years were not available as, although there have always been accident books in place,
these were not recorded properly in the past. The new system will provide comparisons for
future years.
The Yorkshire Division Reportable Injuries graph for 2001/2 and 2002/3 shows that accidents
have been decreasing this year for Periods 3 to 7, compared to the same months in 2001/2,
except for a small increase recently. Last year, when the health and safety systems were being
promoted, reportable injuries increased. This trend is, however, perceived to have been as a
result of employees being more aware of health and safety, and of the procedure for reporting
accidents, rather than due to a sudden increase in the number of accidents.
It was estimated that the site spends approximately 50,000 a year on health and safety
(including: training, staff time, building the training room, plant maintenance, health and safety
packages, consultancy fees etc.). This estimate provides a figure of 178.57 per employee
spent on health and safety per year, for the York site of the organisation.
It was considered to be too early to say whether benefits had outweighed the costs. Training is
still in its early stages and the site has currently spent more than they have got back at this point,
but it is felt that there will be benefits in the long-term. However, the site has benefited from an
increase in awareness as well as in morale, as staff appreciate the effort going into the
development of the health and safety systems. In addition, there has been a decrease in
reportable injuries.
It is anticipated that, if the hand / arm vibration hazard escalates, there will be huge costs
associated with this although the organisation is currently striving to reduce this hazard. Any
changes in legislation to health and safety on the public road would have an impact on costs,
likewise would changes to the Working Time Directive. A reduction in the amount of hours
drivers are allowed to work would have an impact in terms of losing current employees, also
causing problems when recruiting further drivers, as a result of reduced hours on a job that is
already not well paid. Future costs may also be incurred if legislation changes and the noise at
work levels are reduced.
234
Management of Health and Safety at Work Regulations: 82 different risk assessments in place,
each of which take approximately 4 hours to complete (including carrying them out, typing
them up, disseminating them etc.) The site also carries out numerous tool box talk sessions
and many training courses. The organisation holds safety audits, behavioural audits, safety
tours, and meetings, and provides annual health surveillance for engineering staff. Each site has
an emergency plan in place. The risk assessments were developed first, in order to enable
prioritisation of what action should be taken. The cost of these regulations was estimated to be
428.57 per employee, as a total over a 4-year period, for the York site. Again there was an
initial outlay of costs and ongoing costs from training, but it is perceived that further benefits
will be apparent in the long-term. Benefits are an increase in staff morale, reduced reportable
injuries and a general increase in site safety for both visitors and employees.
COSSH Regulations: Risk assessments were initially attempted, and then a COSHH assessment
package was purchased from a consultant. The site sends the information to the consultant who
then carries out the COSSH assessments. These are reviewed and updated every 3 months.
Aside from the original cost of the package and the consultant fees, the biggest cost is employee
time in updating the assessments every 3 months. Maintenance of equipment, provision of PPE,
measurement of airborne vapours and annual health surveillance are all carried out. Training
sessions for engineering staff are also provided. The cost of these regulations was estimated to
be 127.86 per employee, as a total over a 4-year period, for the York site. Benefits are
perceived to have outweighed the costs and are again shown to be an increase in staff morale
and awareness and a decrease in reportable injuries. Again, it is perceived that there will be
further benefits in the long-term.
Manual Handling Regulations: These regulations are not seen to be as high a priority in
comparison to the other regulations and the general health and safety systems on this site.
Manual handling risk assessments are in place and are estimated to take approximately half a
day to carry out and document completely. The 10 main hazardous activities have been
assessed and some activities have been altered to a two-man task. Trolleys and sack trucks have
been purchased. The cost of these regulations was estimated to be 12.50 per employee,
estimated over a one-year period, for the York site. Again the benefits are seen to outweigh the
costs, being the same as those for health and safety in general, no specific benefits were stated
as a result of actions taken in relation to the manual handling regulations.
Noise at Work Regulations: Noise assessments have been carried out by an external consultant
(at a cost of 600 per site). However, as long as nothing changes with respect to the noise
exposure, the noise assessments will only have to be reviewed and updated approximately every
3 years. PPE and signage has been provided and a tool box talk was carried out in relation to
noise at work. The cost of these regulations was estimated to be 7.86 per employee, as an
initial outlay cost for the York site. Costs were again an initial outlay with benefits being more
of a long-term measurement, yet the ongoing costs are not high with renewal being approx.
every 3 years. Benefits were again stated as being the same as the general health and safety
benefits, with benefits outweighing the costs (albeit non-tangibly). Future costs may be
incurred if legislation changes and the noise at work levels are reduced.
Currently advice and information is sought via health and safety consultants, Croner, IOSH, and
HSEs central resource.
The Safety Manager would prefer advice that came straight from the HSE inspectors, being able
to ring them when a problem arises is something he does occasionally and benefits from. It was
suggested that a better working relationship was needed between the inspector and industry.
One idea was if the inspector held a seminar-type event, giving a presentation and providing the
235
opportunity for industry to meet their inspectors. Working partnerships should be more actively
encouraged and supported by the HSE.
In terms of advice for how the HSE should target SMEs, it was again suggested that a seminar
be held to provide information and advice, supporting a partnership situation where the HSE
could host regular seminars on a series of topics, also enabling the HSE to meet with the SMEs.
236
LOGICOM
Sector
Transport: Motor freight transportation & warehousing
Size
Large: with a total of 380 employees
All the information from the questionnaire was reviewed and confirmed correct, although the
number of employees has risen slightly from 349 to 380 since the survey was completed.
LOGICOM is an IT parts logistics company that operates throughout Europe with 6 premises,
including an HQ, technical centre, Paris office and warehouses.
LOGICOM was a division of ICL until it was divested in 2000. As part of the divestment
process, the in-house H&S expertise that was available as a division was removed and the
company had to provide their own. The dedicated H&S manager was previously a warehouse
manager, but received extensive IOSH accredited training in H&S legislation and the
companys obligations regarding H&S. He then took actions needed for an H&S system to be
put into place - although much of this was based upon the ICL models that the company had
been using previously.
Newly established organisations (set up in last 5 years)
The company had the advantage of experience in H&S systems when it was part of ICL,
therefore there were no major surprises for the company. The largest problem was the H&S
managers lack of experience, although the company had made the positive step of retaining the
services of ICL HS cover and arranging training prior to the divestment, and he was able to
begin setting up the systems, before the company moved to its new premises. More guidance at
the early stage from the HSE, on what is expected in terms of risk assessments, would have
been useful - the higher risk activities should be addressed first, but the manager initially tried to
do too much at once. The systems are still developing at the site and will not be complete for a
few more years yet i.e. fulfilling HSG 65. The initial setting up costs of these systems was very
high, but the ongoing costs are not seen as particularly significant.
All accidents (however minor) are recorded and the accident rate over the two years has
remained about the same (0.13 per employee per year) - most accidents are slips, trips, cuts and
back injuries. The general cost of the compliance is approximately 140 per person, which the
company see as a good level of investment for the benefits they gain - although due to the nature
of the business, the number of accidents / fatalities etc. that they believe the systems prevent are
not significant. One of the less tangible benefits is the fact that the employees feel that
managers are taking responsibility for H&S and hence increases the overall morale. The
company believes that their claims history and H&S system does not affect the insurance
premium adversely and that the increase in premium is purely due to the market conditions.
The Safety and Security Manager was not aware of any future compliance costs that would have
a dramatic impact on the costs currently incurred.
237
Management of Health and Safety at Work Regulations: The bulk of the costs associated with
these regs is the cost of employing a full time H&S professional and the training that is provided
to the employees. The latter is likely to decrease however as systems become bedded in. The
first actions taken were the identification of the major risks and then the setting up and training
of employees and managers for the H&S steering group. Departmental managers are
responsible for ensuring the safety of all employees and the H&S manager provides advice.
There was no integration with other systems, however there are plans to converge the system
with ISO 9001 at the next certification. The cost of these regs equates to approximately 280
per person, which from a health and safety point of view is seen as good value.
COSHH Regulations: the costs and actions associated with COSHH are minimal and only
applicable to cleaning materials held on site.
Manual handling Regulations: The first step taken, with respect to these regs, was the training
of personnel in manual handling assessments which was carried out by an external consultant.
All training / assessing is now done in house. The H&S manager is responsible for all training
and assessing and maintains the records accordingly. The main problem encountered was that
the information provided by the HSE is not specific enough for the manual handling assessment.
There is a lot of irrelevant information provided, making it a lot more difficult for companies to
identify exactly what they should be considering and doing. The company is now looking at
ways of assessing manual handling operations in a more objective manner. The cost per
employee of these regs is approximately 50 (for all employees) although only half of these
employees will actually be involved in any significant manual handling operations.
A lot of time and money is spent in training new employees, however, many of the employees
(many of whom are only on temporary contracts) have received manual handling training from
previous employers. It would be easier if there was a minimum standard to which people are
trained to, and for which they could produce certification. Therefore, when a company has a
manual handling issue specific to its operations, employees would only need to be trained in that
specific area. This would save on the re-training of many individuals, in which the employees
might have a low level of interest.
Noise at Work Regulations: The sprinkler pump room is the only area where there is any
significant noise on site. This area is run and managed by a contractor, therefore LOGICOM
does not consider it as a significant regulation for their organisation.
The H&S manager thinks that HSE websites and guidance documents are generally very
helpful. One possible improvement could be the provision of quite basic, generic PowerPoint
presentations that could be downloaded by companies for training / education purposes. This
would save small companies a lot of time and money in putting these together themselves and
would ensure a good and consistent standard.
Additionally an on-line facility for manual handling / DSE assessments and risk assessments in
general would be useful, in line with the COSHH Essentials toolkit http://www.coshh-
essentials.org.uk.
The HSE could use its influence to promote and encourage small firms within relatively close
proximity to share knowledge and the costs for courses. The setting up of accredited trainers /
consultants for their use would also be a great benefit to the smaller businesses to ensure they
are receiving correct and relevant information. The company feels that the HSE should be more
proactive at grass roots level and help small businesses.
238
Printed and published by the Health and Safety Executive
C30 1/98
Printed and published by the Health and Safety Executive
C1.10 11/03
ISBN 0-7176-2782-9
RR 174
78071 7 627820
35.00
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