Title: Safe maintenance: protecting your people and avoiding prosecution?
Good morning and thank you for inviting me to give today’s keynote speech.
As you would expect, I plan to use part of this opportunity to update you on recent developments within HSE, but primarily I want to talk about some of the safety issues associated with carrying out Maintenance work.
Any of you who have taken the trouble to read my personal history will know that most of my career has been spent in Manufacturing. Very recently I have joined the board of the High Value Manufacturing Catapult as a non-Executive Director. Manufacturing is part of my DNA just as much as health and safety. I believe that a strong manufacturing industry is vital to our national economy and that good health and safety are fundamental to achieving that strength and to building excellence.
But what is actually going on in the manufacturing industry today? If I were to ask people which are the most dangerous sectors of the economy in which to work – the majority would put Construction, Agriculture and Waste and Recycling at the top of the list – and they would be right to do so. Manufacturing is a diverse sector covering a whole range of industries with an estimated 2.8 million workers. Over the past 5 years, in Manufacturing, an average of 31 workers have died every year in workplace accidents, there have been an average of more than 4500 reports of major injuries and about 20,000 reports of injuries that keep people away from work for 3 days or more. Many manufacturing workers also suffer ill health from workplace exposures Maintenance-related accidents are a serious cause of concern. HSE’s data indicates that 25-30% of manufacturing industry fatalities in Great Britain were related to maintenance activity.
I was interested to note that one of the motivators on your website for attending this conference is “staying on the right side of the Law” and you have asked me to speak about protecting people and avoiding prosecution. I applaud your motivation in coming together here today to discuss how to improve safety in Maintenance, but I do hope that some of this subtext doesn’t mean that you may be missing the point?
No one would disagree that far too many maintenance engineers and technicians are being seriously injured and killed as they carry out their work. Many, if not all of these injuries and fatalities are preventable but the prize for doing so is about much more than avoiding prosecution.
I mentioned a few moments ago that Construction was one of the most dangerous sectors in which to work. It would be more accurate to say that it is one of the most hazardous – but recognising the difference and doing something about it is key – and huge leaps in performance can be achieved when people recognise that “it doesn’t have to be like that”. Over the last 10-15 years HSE has seen huge improvements in safety performance in construction – particularly on large-scale Construction activities, of which of course, the Olympic big build project continues to stand out as an exemplar.
Making the commitment to a different approach to safety delivers enormous benefits – for the business. Safe operation leads to higher staff morale, higher productivity, and higher profits. One of the greatest myths of our time is that doing health and safety well is a cost or “burden on business”. It isn’t – it goes hand in hand with being successful and growing the business .
Nowhere is this mindset change more important than in relation to carrying out Maintenance. It goes without saying that people who work in manufacturing are at their happiest when the plant is up and running and product is being churned out. But where does that place Maintenance? Where are you on the reactive to preventive scale? Do you love your machines and see it as vital to the business to look after them? Are the people who maintain your equipment as important and well cared for as those who produce the product? Do you contract out maintenance work and if so, has that somehow reduced your level of ownership of the tasks and the people who do it? Are your health and safety specialists actively involved in reviewing how maintenance work is carried out? Do they have the right skills and competences to review highly technical procedures on complex machines?
A couple of weeks ago in an interview for Works Management magazine with Brian (Tinham) I suggested that the high proportion of serious injuries and fatalities which occur during Maintenance are, “because maintenance operations are non-routine." But that is a culture – not a statement of fact.
Whether maintenance work is routine and planned or unplanned, it needs to be done – it’s an integral part of building in safety and reliability. Safety will depend on maintenance teams not being put under pressure to fix machinery and get the factory working again, quickly. Reliability will also come from the job being done properly and well – not in a rush. Maintenance doesn’t stop production, it is an integral part of building and retaining asset and production integrity
Anyone who has heard me speak before will know that I have a deep concern about the extent to which high hazard industries have allowed themselves to focus on the easy stuff rather than addressing the real risks in their businesses.
I’d like to call on you all to critically examine whether you are focussed on the true priorities in your business. In particular to consider your approach to all engineering and maintenance activities. Spotting slip or trip hazards is commonplace in most factories and gets a lot of attention – I would guess that for many this will be a source of many near miss reports. But there is a real need to focus and consider the risks that come from maintenance work, if we don’t the results can easily be serious life changing injuries, loss of life, major cost to the business and of course, the possibility of prosecution.
The most important opportunity to focus on the real risks is at the design stage. Equipment and machinery which is designed and installed with maintenance in mind ( as well as production efficiency) will be inherently safer to maintain. Consideration will have been given to safe access, and effective lock-out systems as well as considering the right frequency for preventive maintenance to be carried out.
But for many of you that is a privilege that comes along infrequently. You may be operating equipment that was designed and installed many years ago. Opportunities to make the plant safer to operate and to maintain still present themselves, but it is at this point where you have to decide whether the cost of implementing these changes is a “burden” caused by safety or an investment in improved efficiency and reliability.
I suspect that many of you have Behavioural safety programmes in your organisations – but where is the focus of these programmes? Does it consider the attitudes and behaviours of everyone in the organisation – including those who set the culture? I mean the leaders of the organisation – the ones who determine where Maintenance sits in the company hierarchy and priorities. A change in performance in safety will come about when you as leaders see maintenance as an integral and fundamentally important part of your business – not as something which places you at risk of prosecution.
I will leave the subject of Maintenance there with some food for thought but I am happy to debate it further if you wish.
Let me now quickly move on to give you an update on some of HSE’s recent work and the direction that our health and safety regulatory system is taking.
The last few years seem to have been all about reviews and change. We’re still awaiting the Government’s official response to last year’s Triennial Review of HSE, the publication date is imminent.
Findings and recommendations from all of the reviews have shaped an ambitious and challenging programme of work for HSE, but it is important to remember that the fundamental principles which shape our world class health and safety system remain unchanged. We are making excellent progress with delivering the reform and updating process:
We continue to hold to account those who expose their employees and others to unnecessary risk but we also continue to offer support to employers who want to do the right thing to ensure there is effective management of health and safety at the heart of their business.
The reviews recognised that Health and Safety is misused as an easy excuse to hide behind in order to prevent activities from taking place. This is an important issue for workplace health and safety because of the impact the constant ridiculing has on the mindset of the workforce and employers as well as politicians, the media and the public. Our system cannot function effectively if the importance and value of our work is undermined, seen as a joke or simply about paperwork and bureaucracy.
HSE’s Myth Busters Challenge Panel was set up in spring 2012 to enable people to challenge decisions when they think health and safety is being used wrongly. The work of the Panel has resonated with many. We have been really surprised by how many people have used it – and amazed by the cases they have sent us!
Full details are on HSE’s website, but I can confirm that among the many stories we’ve looked at we uncovered one case of receptionists at a manufacturing company being told to wear safety footwear - steel/plastic capped work shoes to work on reception. Despite their duties being: answering phones, posting letters and computer use! What was I saying earlier about focusing on the wrong priorities??
The Red Tape Challenge invited views from the public on which laws should be abolished or changed. Whilst there were a lot of comments posted on the RTC website about Health and safety legislation, many were actually supportive of the law as it stands and there were few suggestions for wholesale removal of legislative requirements. However, many felt we could do more to simplify and make clearer what the law actually requires of businesses and others.
We have therefore reviewed all 200 odd sets of health and safety regulations and Acts on the statute book to identify out of date, superseded, duplicatory requirements. And we have set about revoking them.
We are not making substantive changes in legal requirements; but simply tidying up and removing complexity. This will make it easier for dutyholders to understand what they have to do. The goal is to improve levels of compliance; not to remove controls or reduce standards.
Several reviews identified that HSE needed to improve and simplify its guidance and Approved Codes of Practice – to make it easier for people to find information that contains the appropriate level of detail and technicality.
We have reviewed nearly all of our guidance. We have overhauled our website and conducted a comprehensive review of all Approved Codes of Practice.
We are simplifying wherever we can - for example, for smaller, low risk businesses, we have revamped our basic health and safety guidance – and re-launched it as a web based tool. Health and safety made simple, has already been accessed over one million times.
The old Essentials of Health and Safety publication has also had a make over. It is now the Health and safety toolbox – providing clear consistent guidance in web accessible as well as hard copy format.
It is the next level of guidance up from Health and safety made simple and is aimed at those who need some more detail on specific hazards and issues.
Many of you will be familiar with our guidance on successful health and safety management – commonly referred to as HSG65. Following consultation this has been re-written. We believe it is now more relevant and accessible to those managing health and safety in workplaces today.
Its basic mantra is PLAN DO CHECK ACT – and the guidance comes as three parts – offering increasingly sophisticated levels of advice to meet the reader’s needs.
So that’s a whistle-stop tour of the reviews and our key actions on their recommendations to date. We have, also taken steps to focus inspections and interventions on higher risk premises and activities and on poor performers. Our USP is as a regulator with real enforcement powers. It is vital that we direct our resources at those most in need of our attention. But we also recognise that those who want to do the right thing value HSE’s input and advice and part of our response to the triennial review will be to look at how we might be able to respond to that need , both here in Great Britain and further afield.
We introduced Fee for Intervention in 2012 – which enables HSE to recover its costs when and where we encounter material breaches which require time and effort to help put the matter right. An independent review of the operation of FFI is currently underway.
Overall, we continue to have a world-class health and safety system in Great Britain – the last set of health and safety statistics continue to demonstrate that. But we have not conquered the problem of workplace ill health. So, we are focusing more than ever on occupational diseases – and looking to engage others to help us raise awareness and bring about behaviour change to reduce exposures and improve control measures in the workplace.
We still have a problem in relation to media coverage of health and safety. However, the press don’t invent these myths about health and safety. The stories arise because in every case someone in the organisation involved has told a customer, a client or even in some cases their own employees that the trivial matters we expose with our Myth Busters challenge panel are about health and safety.
HSE needs to tackle the cause of these stories – and that means encouraging everyone to think about whether they and/or their organisation contributes to the problem with unnecessary rules, over-reaction to very minor risks, or simply playing the “health and safety“ card to justify something.
Just as HSE is doing, there is a need for you to take time to ensure that you are focussing on the real priorities – the real hazards that could cause serious injury or damage people’s health – especially in high hazard non-routine activities like Maintenance.
Focus on the real hazards that could cause serious injury or damage people’s health and take the necessary measures, time and use the right expertise to get the get job done properly. Remember this is about improving safety, productivity and profitability not avoiding prosecution!.