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LAC 67/2 (rev4.1) - Targeting local authority interventions

Annex C – Examples of Intervention Types

This Annex sets out the range of intervention types available for the Regulation of Health and Safety at Work with examples of their use. Further example case studies are also provided to help develop the principles of intervention use at Annex E. LAs are invited to share further examples on HELex.

Type Description Examples
Intervention types: Proactive interventions
Influencing and Engaging with Stakeholders, Others in Industry and Large Employers
Partnerships Strategic relationships between organisations or groups who are convinced that improving health and safety will help them achieve their own objectives. This may involve duty holders or trade unions, regulators, other Government departments, trade bodies, investors.

Developing new relationships between businesses and regulatory services to reduce the regulatory burden on businesses; promote two way communication between businesses and regulatory services; supporting regulators to find the right balance between encouragement, education and enforcement and offering support from regulatory services for businesses e.g. Local Enterprise Partnerships.

Working with a range of agencies e.g. work experience co-ordinators, secondary school students and other regulators/enforcement organisations from the coast guard to school wardens to raise awareness on sensible health and safety, tattooing, road and fire safety, and workplace safety use a variety of techniques e.g. supporting website and Facebook pages.

Estates Excellence type projects  use a range of organisations (e.g. LAs, Fire and Rescue Service, the Federation of Small Businesses, EEF, service providers, trade unions and local business groups) to set up/fulfil the need for advice and training for businesses and workers. Uses specially-trained staff to visit SMEs on targeted industrial estates to offer advice to managers and workers and provide free workshops, training, advice and guidance specifically targeted to a business' individual needs.
Motivating Senior Managers Encouraging the most senior managers to enlist their commitment to achieving continuous improvement in health and safety performance as part of good corporate governance, and to ensure that lessons learnt in one part of the organisation are applied throughout it (and beyond). Business engagement partnerships (e.g. Local Enterprise Partnerships) can link a range of local partners including representatives from the Federation of Small business and Chamber of Commerce to get manager buy-in on effective management of health and safety risks.
Supply Chain Encouraging those at the top of the supply chain (who are usually large organisations, often with relatively high standards) to use their influence to raise standards further down the chain, e.g. by inclusion of suitable conditions in purchasing contracts.

Given an LA’s local focus, national supply chain activity is often outside of their remit (although large Primary Authority Schemes may help develop this).

However, there can be opportunities for LAs to get local supply chains to improve health and safety e.g. office cleaning suppliers, builders merchants.

LAs can also be involved in helping to collect intelligence that feeds into supply chain monitoring e.g. linking in with trading standards or public health work on sunbeds, tattoo inks.

Design and Supply Working with those who can improve health and safety by improving the design of processes or products. Violence at Work/Retail Violence/Safe Bet Alliance schemes have been adopted by LAs. Engagement and education have led to outlets adopting a number of design and procedural changes to improve safety/stress of employees and the handling of incidents and their aftermath.
Sector and Industry-wide Initiatives “Gearing” achieved by stimulating a whole sector or an industry to sign up to an initiative to combat key risks, preferably taking ownership of improvement targets. Initiative to reduce workplace violence in takeaways – the LA working with the Police and local takeaways to pledge and commit to certain activities e.g. takeaways prohibiting customers possessing alcohol from entering the premises; the Police and the LA providing specific guidance, training, promotion and publicity.
Intermediaries Enhancing the work done with people and organisations that can influence duty holders. These may be trade bodies, their insurance companies, their investors or other parts of government who perhaps are providing money or training to duty holders Using local HABIA and training college contacts to influence hair dressers and managers to take up published materials and working practices.
Engaging with the Workforce
Working with Those At Risk Working with safety representatives, trade unions and other organisations that represent people put at risk by work activities to support them in their roles.

Migrant Workers - Using the local community structures and support groups to educate and communicate health and safety messages to vulnerable migrant workers.

Working with Other Regulators and Government Departments
Working with other regulators etc. Where appropriate work with other regulators (including HSE, other LA regulators, the Police etc.)  to clarify and set demarcation arrangements; promote cooperation; coordinate and undertake joint activities where proportionate and appropriate; share information and intelligence.

Working with relevant signatories of the Work-Related Death Protocol.

Working with the Care Quality Commission during the period of transition to aid handover and ensure continued protection of employees and non–employees.  

Creating Knowledge and Awareness of Health and Safety Risks and Encouraging Behaviour Change
Education and Awareness Seeking further ways of getting messages and advice across early to key target groups, particularly those who are difficult to reach, using channels such as small business groups, chambers of commerce etc. Promoting risk education as a curriculum item at all levels of the education system.

Using awareness days and targeted information to promote health and safety messages at take away establishments.

Working with educational establishments that operate work experience placements to raise safety awareness of students.

Gas safety in catering premises – having evaluated intelligence that highlighted local catering premises were not managing significant risks effectively including gas engineers working out of scope - food safety officers, health and safety officers and representatives from Gas Safe Register developed and organised a training day for the local businesses and enforcement officers.

Talks to local Technical College students e.g. to construction students on asbestos awareness, to student hospitality managers – on legionella control, to hair dressing students – on dermatitis.

Offering advice and support visits to new business start-ups.
Promoting Proportionate and Sensible Health and Safety
Encouraging Compliance Encouraging the development of examples with those organisations that are committed to performance and then using these examples to show others the practicality and value of improving their own standards. Promoting and sharing compliant practice through campaigns, local business forums, large business mentoring small businesses etc. to improve the management of health and safety risks.
Recognising Compliance   “Where proper management of risks can be assured, HSE and LAs will not intervene proactively. This means we will discourage HSE and LAs from putting resources into issues where the risks are of low significance, well understood and properly managed.”

Business Awards to give public recognition to workplaces that have taken positive action to improve employee’s health and wellbeing.
Recognising the use of third party inspections and audits for large events (formalised in license agreements) by LAs who then only need to oversee/check the process – thus freeing up LA resources for other purposes.

Directing regulatory resources away from compliant businesses and low risk activities, and a more direct focus on non-compliant businesses.
Inspection and Investigation
Inspection Alongside the National LA Enforcement Code (the Code), HSE has published a list of higher risk activities falling into specific LA enforced sectors. Under the Code, proactive inspection should only be used for the activities on this list and within the sectors or types of organisations listed, or where there is intelligence showing that risks are not being effectively managed. The list is not a list of national priorities but rather a list of specific activities in defined sectors to govern when proactive inspection can be used. However, if a business carries out an activity on this higher risk list, it does not mean that it must be proactively inspected: LAs still have discretion as to whether or not proactive inspection is the right intervention for businesses in these higher risk categories.

Proactive inspection of industrial retail/wholesale premises to ensure adequate control of work at height and work place transport.

Incident and Ill Health Investigation Making sure that the immediate and underlying causes are identified, taking the necessary enforcement action, learning and applying the lessons.

Using HSE Accident selection criteria and HSE’s risk based approach to complaints handling

When there is only limited information regarding the potential need for a more involved intervention it may be prudent to maintain an active ‘watching brief’ to see if there is cumulative evidence that identifies poor performance.
Dealing with Issues of Concern and Complaints Encouraging duty holders to be active and making sure that significant concerns and complaints from stakeholders are dealt with appropriately. Adoption of the HSE complaints handling procedures to ensure that resources are targeted on complaints that indicate the poor management of risk.
Enforcement
Enforcement Inspection and investigation provides the basis for enforcement action to prevent harm, to secure sustained improvement in the management of health and safety risks and to hold those who fail to meet their health and safety obligations to account. Enforcement also provides a strong deterrent against those businesses who fail to meet these obligations and thereby derive an unfair competitive advantage.

Ensuring that adequate arrangements are made for enforcement.

Taking proportionate enforcement action in line with HSE’s Enforcement Policy Statement (EPS) and Enforcement Management Model.

When taking enforcement action, making it clear to the dutyholder which matters are subject to enforcement, where compliance has not been achieved, what measures are needed to achieve compliance (including timescales) and their right to challenge/appeal.

Following up on enforcement action taken to check that the necessary improvements have been made.

Other interventions Other forms of proactive activity that are distinctly different to the other types of intervention outlined elsewhere on this list. Such interventions should be clearly described and named within your own recording systems to aid any future analysis and to prevent this classification being used as a ‘catch-all’. E.g. Test purchasing of services.
Updated 2015-06-11