National Lead Inspectors (NLI) and central interventions for waste management and recycling companies
SIM 03/2012/09
- Open Government Status
- Fully Open
- Author Unit/Section
- OPSTD, agriculture and waste sector, waste and recycling team
- Target Audience
- FOD inspectors covering manufacturing and services industries and specialist inspectors
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Summary
This guidance informs inspectors about the ongoing programme of interventions with national waste management and recycling companies. This programme of work started in 2009/10 and was targeted at nine significant companies. Central interventions have taken place to assess the safety management systems of these national companies. This work has been led by National Lead Inspectors (NLIs) and is still ongoing. This programme of work is being extended to a further six companies in 2012/13.
This guidance outlines how the assigned National Lead Inspectors (NLIs) should carry out this work with the newly added NLI companies and how interventions with the existing NLI companies should continue. It also provides guidance to inspectors who may have other work with these companies that is not related to the central interventions.
Introduction
Waste and recycling is defined as a high risk industry based on poor health and safety performance during recent years. The waste and recycling industry has an overall employee accident rate around 4.4 times greater than the UK average and a fatal accident rate around 16.8 times the average for all industries (based on 2010/2011 statistics.
The purpose of this ongoing initiative is to maintain relationships with existing NLI companies and to extend the central approach to six more companies to identify strengths and weaknesses in their safety management systems and to seek improvements in health and safety performance.
Delivering this programme of work will improve HSE’s intelligence of standards within the industry and improve inspector’s knowledge and competency in this high-risk industry. It should also lead to improved health and safety performance across the industry.
This initiative will be coordinated by a National Project Officer (NPO) from FOD, who will liaise with NLIs and report to the Waste and Recycling Sector and a briefing event will be held for all new NLIs in June 2012.
Action
Existing NLIs:
- Continue the central interventions at the nine existing NLI Companies. It is anticipated that this will comprise a mix of head office and site visits by the NLIs to maintain relationships and assess progress with Action Plans
- Report back to the National Project Officer (NPO) every quarter using the Table in Appendix 2 Part 2.
New NLIs:
- Attend NLI Briefing in June 2012
- Complete an Intervention Plan for the new NLI Company assigned to them (See Appendix 1 for template)
- Undertake the central intervention to review and assess the safety management systems. This will involve:
- head office visits and
- inspection of their operational activities
- The inspection of the company's activities should be carried out in at least two HSE areas (which may be in different Divisions)
- Report back to the NPO (using the Summary Report Form in Appendix 3) by end of 2012/13 work year
- Inspection of the NLI Company's activities should concentrate on waste collection activities (municipal and/or commercial) as these account for the largest proportion of accidents within this sector. However if collection activities are not a significant part of the company's business then Inspectors should use their judgement in choosing topic areas to inspect
- Topics and activities to sample are left to the discretion of the inspector but Sector suggestions are:
- Route risk assessment-format/suitability/availability/understanding
- Transport risk assessment (yard activities)
- Policy and use of reversing assistants
- Supervision of operatives
- Monitoring of operatives
- Competency of Supervisors /Team Leaders
- Director leadership
- Worker Involvement
- Adoption of safety management systems (e.g. HSG65, OSHAS 18001)
- Response to targets set by trade associations (e.g. ESA,BMRA) and WISH
back to the NPO (using the Summary Report Form in Appendix 3) by end of 2012/13 work year.
Other HSE Inspectors:
- Be aware of any of the NLI Companies listed in SIM 03/2012/10 (fully closed and not available externally as it contains confidential information) in their area.
- Refrain from carrying out proactive work with the NLI Companies unless it is associated with other Waste and Recycling Inspections i.e.
- Waste management and recycling: inspection intervention with local authorities (see SIM 03/2010/04)
- Hotspot Interventions 2012/13 (see SIM 03/201208)
- Carry out reactive work (i.e. complaints and accident investigation) as normal. However, the NLI should be informed of any significant outcomes.
- Notify (and consult in advance wherever possible) the NLI if proactive visits are required for training or any other purpose (e.g. specific projects)
Background
This programme of work started in 2009/10 and was targeted at nine significant companies. Central interventions have taken place to assess the safety management systems of these national companies.
The work, led by NLIs, is still ongoing in 2012/13 and is extended to a further six companies to ensure the initiative is balanced and targeted fairly across the significant companies operating in the waste and recycling sector.
Organisation
Resources
- New and existing NLIs are expected to be experienced Band 3 Inspectors with relevant safety management systems assessment training and experience. They will also have relevant experience of the waste and recycling industry standards and guidance.
Existing NLIs
- 2 days per existing NLI company has been assigned for 2012/13
New NLIs
- The central intervention will start in 2012/13 and is scheduled to continue for 3 years
- 8 days per NLI Company has been assigned for 2012/13
- It is anticipated that five contact days will be required to follow up the intervention in 2013/14 and two contact days in 2014/15 to maintain relationships
- The intervention is unlikely to be isolated to one HSE Area. The NLI should liaise with Head of Operations in other Areas and/or Divisions to agree the split of Inspector resources.
Work Recording
- A NLI case should be set up in COIN for each NLI company. The speciality type is “InterventPlan”
- The NLI should arrange for the National/Regional Intervention Plan button to be highlighted on the customer page (this will need someone with “orgadmin” rights)
- The following should be attached to the COIN case:
- The finalised Intervention Plan
- Audit Report
- Action Plan
Reporting
The NLI should:
- Liaise with the NPO regularly to discuss progress and plans. The Progress Report (Appendix 2) should be completed quarterly and sent to the NPO. This will allow further reporting to the Sector, Programme Board and HSE Board level
- Forward examples of enforcement notices, action plans, best practice and other noteworthy information to the NPO and Sector to help support and promote the initiative
- Complete a “Summary Report Form” (see Appendix 3) at the end of 2012/13 and send to the NPO
- Provide appropriate feedback to their NLI company
The NPO should:
- Liaise regularly with all the NLIs to provide advice where needed and to collate progress on the intervention
- Assist the NLIs with coordinating inspection across HSE Divisions
- Collate progress on delivery using progress reports received quarterly from NLIs
- Report on progress to the Sector
The Waste and Recycling Sector will:
- Collate the information provided by the NLIs with the NPO
- Communicate the general findings to the NLIs, HSE and to the industry.
Health & Safety
- Inspection of waste and recycling activities has potential to expose HSE staff to risks to their safety
- When undertaking site inspections, inspectors should observe working practices from a safe vantage point.
- Inspectors must wear high visibility clothing at all times
- Inspectors should also be aware of and comply with HSE’s policy on lone working.
Further References
OPSTD – Agriculture and Waste Sector - Waste Management and Recycling Team, HSE Cardiff
Appendices
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