Author unit / section:

   Construction Sector

Target audience:

   Construction Division Staff and Construction Inspectors

Introduction

1  This SIM replaces SIM02/2003/04 and provides guidance for Inspectors in FOD Construction Division on completing the revised IRF Construction (IRF C) on COIN. It should be read in conjunction with the Work Recording OM 2008/05. For detailed information on Divisional priorities, including those listed on the IRF C, please refer to the 'Construction in HSE' intranet site.

When to use the IRF C

2  The information gathered during proactive work is vital to the Division’s ability to assess standards and evaluate the effectiveness of its intervention strategy as a whole. The IRF C should be used to record ALL inspection work with the exception of that detailed in paragraph 3 below. This includes visits to head offices, dealings with CDM duty holders and other intervention visits. Inspection Cases can still be used where appropriate to link various visits to one another (e.g. as part of a National Lead Inspector intervention - NLI) but the details, time etc should be recorded on the IRF C. This is to avoid the need to create additional work recording timelines.

3  The only exceptions to this are:

• Asbestos Licence Assessment visits - specific guidance regarding recording work with asbestos is contained within SIM 02/2008/03.
• MEC - specific guidance relating to recording matters of evident or potential concern is contained within OC 18/12.
• Advice/ Education/ Promotion work such as SHAD’s, WWT, or partnership work with Local Authorities should be recorded as detailed in OM 2008/05.

How to use the IRF C

4  The information on the IRF C should be completed in line with existing COIN guidance on the intranet.  Further help is available in a new specific ‘How To’ guide in relation to the IRF C at this site.

5  The IRF/ Ratings page of the IRF C has been redesigned to better reflect the work of the Division as contained within its Business Group Delivery Plan (BGDP). Inspectors are no longer required to rate and record time against specific topic hazards (such as falls or transport). Instead details are recorded against individual elements of the BGDP work stream (such as homebuild).

Recording against the work stream

6  Work should be recorded against the most appropriate work stream – one that reflects the primary reason for the visit in relation to the duty holder against whom the IRF C is being recorded.

7  In deciding the most appropriate work stream to record against, Inspectors should take due regard of the descriptors below:

Hazard Topic	Recording Criteria
Refurb General	Record all property refurbishment activities with the exception of that relating to specific commercial clients in project 1B of the BGDP and work linked to the property developers campaign (see below)
Refurb Commercial Client	Record major commercial refurbishment work associated ONLY with projects related to specified clients – project 1B in the BGDP
Homebuild	Record all work associated with large, medium or small homebuilders and developers
Asbestos Licensing	ONLY used to record all work associated with asbestos licence duty holders (see SIM 02/2008/03 for further recording guidance)
Public Procurement	Record all interactions with public sector clients in line with project 5 of the BGDP – unless TTM specific
Roadworks/ TTM	Record work associated with roadworks / temporary traffic management by NOMINATED INSPECTORS ONLY
Property Developers	ONLY used to record work linked to the property developers campaign and associated work (project 2 in the BGDP)
Const Other	Used to record ALL work not otherwise defined by another work stream
Initiative 1	To be used ONLY with specified inspection initiative. N.B. No initiatives are specified currently

e.g. A refurbishment project also involving licensable asbestos work would be recorded against:

• Refurb General – where site risks / management of the project is discussed with a principal contractor / contractor (including discussion of the asbestos issues)
• Asbestos Licensing – when looking at removal work being undertaken by a licensed contractor on the site.

7  The only BGDP work stream to have been omitted from the IRF C is ‘Major Projects’. The reason for this is that many major projects or NLI schemes are also incorporated within other BGDP work streams. Major project work should be recorded against these work streams where appropriate.

8  Where no specific category is applicable (e.g. visit to a wind farm site) the ‘Const Other’ work stream should always be used to record relevant visit details.

Recording against REACH

9  Although work relating to the Registration, Evaluation, Authorisation and restriction of Chemicals Regulations (see REACH for more information) is not included in the BGDP, all FOD staff must record the time they spend discussing these regulations. This is in order that the required full reports can be made to the European Commission on enforcing authority activity under REACH. All FOD staff will record against this category on the IRF Other, the IRF C or on the timesheet, if appropriate.

Selecting a work stream

10  Because work is being recorded on the IRF C against BGDP work streams instead of FIT3 topics, there will be less need to record against more than one line on the IRF/ Ratings page. For this reason all of the work streams have been defaulted to ‘Not Discussed’. This is in order to minimise the need to close unused lines. The relevant category will therefore need to be actively selected by changing the ‘Not Discussed’ field to a blank space.

Rating a work stream

11  Where ratings are made against the work streams Refurb General, Refurb Commercial Client, Homebuild, Roadworks/TTM, or Initiative 1, Inspectors should rate the work stream using the new six-point scale. The Risk Control Indicator Guide (RCI) is attached at Appendix 1 and provides a description for each work stream as well as the assessment scale to be used.

12  Note that the remaining work streams are not required to be rated. This is because rating these work streams will provide no additional intelligence benefit to the Division. Consequently the N/A value should be selected in these instances.

Recording time

13  Inspectors should record the time spent with the particular duty holder against the relevant work stream category. Where more than one work stream is required to be completed (e.g. Refurbishment General and REACH) the time spent on site should be proportionally recorded against both. The total time recorded on the IRF C should therefore be the same as the total time spent with the duty holder during the visit.

14  As the vast majority of proactive work will be recorded against the IRF C it is anticipated that there will be little need to use any of the categories on the timesheet for inspection activity. Where possible the total inspection activity time on the timesheet should therefore be recorded as an aggregated block in line with OM 2008/05:

e.g. Inspection visits undertaken during one day to a Homebuild [2 hours], Refurbishment General [1 hour] and Const Other [3½ hours] sites would be recorded as an aggregated block of 6½ hours with the category field left blank.

Recording notices

15  The IRF C box ‘No. of Notices' should be completed with the number actually issued, not the number that may have been intended to be issued.

Inspection ratings

16  Except in accordance with paragraphs 17 and 18, there is no need to complete any Inspection Ratings Scores following general site visits.

17  However, Inspection Ratings Scores should be completed where an inspector has enough information to make an informed judgment about a duty holders overall health and safety performance as a company (i.e. not just site based). This would include circumstances such as:

• Head office visits to discuss poor site standards
• Other head office visits when the inspector considers enough information has been obtained; e.g. when clearing a notice or carrying out a post prosecution visit
• As part of a National or Local Lead Inspector Scheme

18  In these circumstances the ‘competence and attitude of management’ score should always be rated. Health, Safety and Welfare should be rated in addition where appropriate. The assessment scale to be used is attached at Appendix 2. Scores should be reviewed and changed as necessary at follow up visits to poor performers. 

19  NOTE: No work stream score or inspection rating on the IRF page should ever be edited or overwritten unless entered in error. New/ changed scores or ratings should be recorded as a new service order to 'build up' this ratings history.

Recording visit details

20  The visit details should be recorded on the Notes page of the IRF C in the summary and details fields.

21  The summary field is searchable so should contain useful information. However, the text field is restricted to 80 characters only. Any relevant keywords should be listed first. The only construction related keyword for use in 2008/09 is listed below:

Keyword	Use when?
migrant	For all work relating to vulnerable, including migrant or temporary, workers.

22  The rest of the summary field should be used to record information that is of use in identifying the visits undertaken. For visits to transient construction sites it is important to include the site address.

e.g. 29 March 2008 Visit to 12, High Street, London, SW1

23  The notes details field should contain the mandatory information outlined in OM 2008/05. This includes the date, purpose of the visit, persons seen (including employees and their representatives), what was seen and any action taken. Whenever an RCI in Appendix 1 is given a score of 5 or 6 the action taken and the reasons for taking that action must also be recorded.

24  In addition to this Inspectors should report selectively on examples of good or poor practice observed and any particular issues that have given rise to a poor assessment score.

25  Where it is considered useful to draw these to the attention of the sector, or where issues of wider importance are revealed, these messages should be raised directly with the sector or included as part of the Division's other BGDP reporting arrangements.

26  The sector would particularly welcome information on innovative solutions or challenges to achieving the standards set out in the project plans. These can be sent in any format and at any time and do not need to be linked to particular IRF C’s.

Attachments

27  Attachments should be added where relevant - Letters, SG reports & visit reports if lengthy.  Photographs should not be attached although these can be included selectively in a report. File names should be chosen to enable appropriate searching on TRIM in accordance with the guidance on COIN.

Appendix 1 – Risk control indicator guide

Risk Control Indicators – Assessment Scale: each risk control indicator should be assessed against the following 1-6 scale.
1	High standards with some aspects meeting best practice.
2	Good standards meeting minimum legal requirements
3	One or more minor shortcomings are present. As these shortcomings are not serious, they can be dealt with informally with oral advice.
4	Standards are patchy. It is necessary to address one or more shortcomings by giving formal instructions for remedial action to be taken. Formal instructions may be implemented by, eg, obtaining a verbal undertaking from the company to take specific action, sending a letter, or physical removal/ disposal of items.
5	Standards generally unsatisfactory. Typically, at least one contravention that gives rise to a discernible risk gap.
6	Standards unacceptable. Unless application of the EMM identifies duty holder factors that provide strong mitigation, the issuing of a notice and/or prosecution is likely to be appropriate.

Refurb General

Record: All property refurbishment except that relating to commercial clients below

Visits to concentrate on topics that give rise to largest number of accidents and cases of ill-health

• Competence - inc. training of managers and operatives
• Falls - adequacy of arrangements
• Good order - site organisation and housekeeping
• Fire - both process safety and general fire precautions 
• Structural stability - competent structural engineering advice obtained relative to the scale and complexity of the work
• OH risks - Identification & effective management inc. Asbestos
• Welfare provisions

Refurb Commercial Client

Record: Major commercial refurbishment associated with specified clients ONLY

General: Consider standards on:

• Provision of information - client has provided early and complete information about risks
• Time and resources - client has allowed sufficient time and resources for project to be completed and has built in adequate contingencies against project overruns.
• Design changes – designs fixed at early stage and proper procedures in place to manage late changes
• Competence  - inc. training of managers and operatives
• Falls - adequacy of arrangements
• Good order - site organisation and housekeeping
• Electrical safety, 
• OH risks - Identification & effective management inc. Asbestos
• Welfare provisions
• Workforce consultation

Client: Purpose of project to obtain clear evidence from contractors on how specified commercial clients perform their duties under CDM (good and bad) in a way that does not compromise contractor’s position. Visit Aid Memoir located in BGDP documents.

Homebuild

Record: All work associated with large, medium, small homebuilders / developers

General: Consider standards on:

• Competence  - inc. training of managers and operatives
• Falls - adequacy of arrangements
• Good order - site organisation and housekeeping
• Transport – planning & management of vehicle risk
• Excavations – appropriate protection
• OH risks - Identification and effective management
• Fire – management and precautions
• Cranes – planning, training, pre-use & maintenance checks
• Electrical safety
• Welfare provisions

Timber frame: As well as the above consider: build sequence to enable effective falls prevention, support panels, safe access and egress including fire emergency, controls on potential sources of ignition, control of manual handling issues.

Roadworks / TTM

Record: Roadworks / TTM work by NOMINATED INSPECTORS ONLY

Contractors: Consider standards on:

• Knowledge - Ch8/NRSWA etc standards & risk management
• Competence - sector scheme training
• OH risks - Identification and effective management, especially noise, vibration, MH

Clients:

• Contractor procurement - contractor pre-qualification & performance monitoring
• Knowledge - Ch8/NRSWA etc standards & risk management
• Design - capture and prioritise re better workforce protection
• Fitness for work – evidence of assessing
• Safe systems of work
• Traffic signs & barriers - maintenance arrangements
• Monitoring - risk control measures
• Client feedback - problem areas – design issues
• Near miss - systems for reporting and investigating
• Near miss - systems for reporting and investigating
• Unqualified operatives - policy and practice towards
• Enforcing authority - arrangements for enforcing acceptable standards under Highways legislation

Initiative 1

Record: ONLY work associated with a specified inspection initiative

Evaluation guidance to be provided in association with each initiative where this category is used.

The issues below are not rated.

You should select the N/A value & complete the time box & No. of notices issued (if appropriate)

• Asbestos Licensing

  ONLY used to record work associated with asbestos licence duty holders

• Property Developers

  ONLY used to record work linked to the property developers campaign

• Public Procurement

  Record all interactions with public sector clients – unless TTM specific

• Const. Other

  Used to record ALL work not otherwise defined by another hazard topic

• REACH

  Record any work undertaken linked to the REACH regulations

 Appendix 2 – Inspection rating scale

When rating the competence and attitude of management, overall health and safety performance, or the welfare compliance gap, use the tables below.  

Competence and attitude of management
Rating	Descriptor
1	Management know the relevant health and safety standards, have put them into effect and check they are applied correctly. There is clear evidence of effective self-regulation with standards being monitored and refined. Full compliance with the approach in HS(G) 65.
2	Management generally enthusiastic and competent with either (i) effective systems in place for other business processes (eg quality assurance), but have knowledge gaps of health and safety requirements, or (ii) good health and safety knowledge with systems requiring improvement. There is potential for good performance and reasonable compliance with the HS(G)65 approach.
3	Management are knowledgeable about relevant health and safety standards but there has been little effort to adopt a proactive approach to health and safety management. However, senior managers volunteer their thoughts as the inspection progresses and appear to be committed to adopting a more proactive approach. There is general confidence that the recommendations resulting from the inspection will be put into place.
4	Management have only a patchy knowledge of relevant standards and there is little or no evidence that a proactive approach to health and safety management has been adopted. However, senior managers recognise the need to satisfy explicit statutory requirements and there is some prospect that a more proactive approach may be adopted.
5	Management show significant shortcomings in their knowledge of relevant standards; they do not appear to be willing to instigate a proactive approach and have not recognised that health and safety is an issue where they need to be personally involved. There is uncertainty as to how they will respond to the findings from the inspection.
6	There is a negative approach to accepting legal duties and management dispute the relevance or validity of recognised benchmark standards. Totally ineffective in the management of health and safety.  The findings from the inspection are likely to be ignored.

Health and Safety Assessment Scale
Rating	State of compliance	Descriptor
1	High Standards	High standards. Some aspects meet best practice.
2	Good Standards	Good standards. Meet minimum legal requirements.
3	Minor shortcomings	One or more minor shortcomings are present. As these shortcomings are not serious, they can be dealt with informally with oral advice.
4	Standards Patchy	Standards are patchy. It is necessary to address one or more shortcomings by giving formal instructions for remedial action to be taken. Formal instructions may be implemented by, eg, obtaining a verbal undertaking from the company to take specific action, sending a letter, or physical removal/ disposal of items.
5	Standards Unsatisfactory	Standards generally unsatisfactory. Typically, at least one contravention that gives rise to a discernible risk gap.
6	Standards Unacceptable	Standards unacceptable. Unless application of the EMM identifies duty holder factors that provide strong mitigation, the issuing of a notice and/or prosecution is likely to be appropriate.

Welfare compliance gap
Rating	State of compliance	Descriptor
1	Compliance	Good, clean provision. Would be content to use it yourself.
2	Minor non-compliance	Welfare facilities need cleaning, temporary absence of consumables such as soap or towels.
3	Inadequate provision	No heated water, or very dirty welfare facilities, or too few toilets.
4	Major non-compliance	No toilet or washing facilities, or welfare facilities so poor as to be unfit for use.