Health and Safety (FEES) regulations: Charging for the approval and monitoring of offshore First - Aid and medic training providers regulatory impact assessment
1 These proposals arise out of a review in which the Health and Safety Commission (HSC) looked at the feasibility of introducing charges in statutory permissioning regimes for assessing safety cases, granting approvals, and associated regulatory activities. The review recommended that certain activities that fell within HSC/E charging policy guidelines, but for which no charge is currently made, should be further examined. One such activity is the approval and monitoring of offshore first-aid and medic training providers. First-aid at work training onshore is already subject to charging. Proposals for charging for onshore approval were agreed by HSC on 23 November 1999 for inclusion in the Health and Safety (Fees) Regulations 2000. These came into force on 10 October 2000.
2 These proposals do not address health and safety risks. The current standards applying to medics and offshore first-aiders will be maintained.
3 The proposals will enable HSE to put in place a fees regime to recover the costs of its activities with respect to considering applications for approval and ensuring the appropriate standards are met. As the feasibility study has noted, much of the work connected with the assessment of the suitability of persons for approval to train, examine and certify onshore first-aiders and post-approval monitoring work is carried out by the Training Approval Services Consortium (TASC). Should HSE move to a similar contractual arrangement for key aspects of the approval of persons to train, examine and certify offshore first-aiders the fees would, in all likelihood, mirror those for onshore approval. The principal costs incurred are those of staff time in HSE's First Aid Approvals and Monitoring Section, and also the work of HSE's contractor in undertaking assessment and monitoring. HSE carries out the assessment and monitoring of medic training providers in-house, and has no plans to change this arrangement in the short term. In the longer term, HSE plans to approach external bodies to invite them to tender for this work.
4 The Offshore Installations and Pipeline works (First-Aid) Regulations 1989 (OFAR) require persons in control of offshore installations to ensure adequate first-aid and basic health care provision for all personnel who are injured or become ill while on offshore installations or pipeline works. It is intended to use the Health and Safety (Fees) Regulations 2002 for the purpose of introducing charging. There are two broad methods of charging:
5 These two options were appraised by an HSE working group. The working group concluded that flat rate fees per approval and monitoring visit was the preferred charging option measured against the following criteria and compared to actuals charging:
6 Flat rate fees score positively against all of the above criteria, and are also the method of charging for onshore approvals work. Actuals charging was thought not to provide the degree of predictability industry seeks and is more complex to administer than flat rate fees.
7 In common with other recent charging proposals, these proposals represent a transfer of funds from the private to the public sector in the first instance. Since the organisations affected are commercial concerns, we might expect any additional costs to be passed through to the offshore organisations receiving the service. This is likely to increase economic efficiency, and the actual scale of the costs involved, estimated below, is extremely small compared to industry turnover.
8 The financial issues surrounding charging have been examined by HSE in a feasibility study. There are no other significant economic impacts.
9 The proposals will maintain the benefits of the current OFAR regime.
There may be efficiency gains in making charges explicit, where they were not before. For example, there may well be an extra incentive for training providers to ensure the training will be given approval in the first instance, without repeat visits from an assessor. Similarly, there may be additional incentives to ensure that standards are maintained, so that repeat visits are not deemed necessary during post approval monitoring.
10 There may be efficiency gains in making charges explicit, where they were not before. For example, there may well be an extra incentive for training providers to ensure the training will be given approval in the first instance, without repeat visits from an assessor. Similarly, there may be additional incentives to ensure that standards are maintained, so that repeat visits are not deemed necessary during post approval monitoring.
11 Any organisation or individual employer may seek approval to train, examine and certify offshore first-aiders and medics. Approval of training and/or qualifications depends upon the organisation or employer satisfying criteria set out in appendix 6 of the OFAR ACoP, and a recent revision of that ACoP allows for the fact that this training could take place offshore. There are, currently, 15 approved offshore first-aid training providers, they also provide onshore first-aid training - 4 also approve offshore medic trainers. This number is expected to grow to around 24 approved first aid training providers and 7 approved offshore medic trainers. Actual and planned volumes of work in connection with offshore first-aid and medic approvals are currently estimated as follows:
Year |
First-Aid: new |
First-Aid: renewals |
Medics: new |
Medics: new |
|---|---|---|---|---|
| 1998/99 (actual) |
0 | 2 | 0 | 0 |
| 1999/00 (actual) |
0 | 4 | 0 | 0 |
| 2000/01 (actual) |
0 | 5 | 0 | 3 |
| 2001/02 (forecast) |
3 | 2 | 2 | 0 |
| 2002/03 (forecast) |
3 | 1 | 2 | 0 |
12 All offshore businesses will be affected by these regulations, in that charges will be passed through to those organisations receiving the service.
13 The tables below provides the actual fees payable. The training of offshore medics is more comprehensive than that for first-aiders because it is designed to allow them to treat injured or ill persons sometimes in accordance with the directions of a registered medical practitioner. Training for first-aiders takes four days and training for offshore medics takes four weeks. The fee proposals for offshore medic approvals and associated monitoring are substantially higher than for first-aid given the need to engage more highly skilled medical staff to carry out the approval and monitoring function. Offshore approvals will come up for review every five years.
| Fee for an original approval |
Fee for an additional site-visit |
Fee for renewal of approval |
|
|---|---|---|---|
| First-Aid |
£890 | £320 | £62 |
| Medic |
£1,305 | £845 | £62 |
| Fee for an initial site-visit |
Fee for an additional site-visit |
|
|---|---|---|
First-Aid |
£355 | £320 |
Medic |
£845 | £845 |
14 The initial fees are designed to cover economic cost and include the original approval assessment visit and the original approval monitoring visit which is undertaken as soon as possible after an approval has been granted. After this, post approval monitoring visits take place at a frequency of approximately once every five years. The majority of organisations will not require an additional initial site visit, and the proportions requiring this cannot be predicted in advance. For the purposes of this assessment only, we take this proportion to be 20%. This would indicate expected revenue from new approvals of £5,670 in FY 2002-3, varying between £5,160 and £6,285 depending on the extent of additional visits. Revenue from renewals would be around £62, and revenue from post approval monitoring will be around £600. Total revenue in FY 2002-3 is therefore expected to be around £6,000.
15 Charges will be subject to refunds, reflecting economies where original approvals for more than one training element is applied for by the same applicant. Where an application for an original approval of either on or offshore first-aid training is made at the same or subsequently to each other, a further refund of £150 will be made. If an application for an approval of medic training is made subsequently to both these on or offshore first-aid training applications, a further refund of £50 will be made. If an application for either on or offshore first-aid training is made and at the same time or subsequently, a medic training application is made, a refund of £50 will be paid. If, after this, an application for the other type of first-aid training is made, a further refund of £150 will be made. When an application for medic training is made and at the same time, or subsequently, an offshore first-aid training application is made, a refund of £50 will be made. If after this, an onshore first-aid training application is made, a refund £150 will be made. Where all three types of application are made at the same time, a refund of £200 will be given.
16 Since the majority of current offshore trainers also cover onshore training, we assume that the refund will normally apply in the future, and we take a average figure of £100, representing the range of discounts available. This would indicate expected revenue from new approvals of £5,170 in FY 2002-03, varying between £4,660 and £5,785 depending on the extent of additional visits. Revenue from renewals would be around £60, and revenue from post approval monitoring will be around £600. Total revenue in FY 2002-03 is therefore expected to be around £5,500.
17 This figure is higher than the expected long-term average, due to an unusually high number of new applications. In the longer term, there are expected to be around two new applications each year (the majority for approval to provide offshore first-aid training).
18 New approvals are therefore expected to generate around £2,000 in any one year. Ongoing renewals will generate an additional £250. There are expected to be around three post approval initial site visits for first aid trainers and one for medic trainers each year, generating an additional £1,860. The need for pre and post approval additional site visits are expected to occur rarely. Income of some £4,100 per annum is therefore forecast in FYs 2003-4 and subsequently (these figures are in real terms, and may rise slightly).
19 These are as indicated in the above tables. Over a five year period, a newly approved first-aid training provider and medic training provider would each typically incur the following costs (to the nearest £100):
First aid: [£890 + 20%*£320] + £62 + [£355+ 20%*£320] = £1,435.
Medic: [£1,305 + 20%*£845] + £62 + [£845 + 20%*£845] = £2,550.
20 The above fees will be passed on to the offshore industry. Total compliance costs to industry are estimated at around £6,000 in FY 2002-3 and £4,000 each year thereafter. These costs are expressed in current values and will rise slightly in real terms in future years.
21 Since costs are expected to be passed on to those offshore companies receiving the benefit, the majority of whom are large enterprises, there is expected to be little impact on SMEs.
22 The costs to industry exclude certain costs, which will continue to be born by HSE. These include policy work undertaken by Health Directorate and Safety Policy Directorate, verification work undertaken by Health Directorate, and the work of granting the approvals, which is done by FAAMS. The vast majority of these costs have, and will continue, to relate to onshore approval, and the offshore element is extremely small.
23 There are no other costs associated with these proposals, except the costs of developing the proposals (including staff time spent on the feasibility study). These costs can now be considered as `sunk'.
24 There are no resource costs to society as a result of these proposals, which represent a transfer of funds from the private to the public sector.
25 There are no environmental impacts as a result of these proposals.
26 There are no resource costs or benefits to society as a whole.
27 Both numbers of new approvals and the scale of fees are provisional at present. There are no other uncertainties.
28 HSC/E will review this charging regime after an appropriate period of time. Because of the relatively small scale of receipts, this may not be a formal review.
