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To: Health and Safety Enforcing Authorities and HSAOs

For the attention of: Local Authority Health and Safety Enforcement Managers, Health and Safety Regulators and others

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Operational interventions in 2007/08 to help deliver the falls from height and slips and trips programmes

In relation to organisations that procure and/or manage building and plant maintenance (in particular to facilities management) and their contractors

This instruction builds on the FOD Delivery Plan by providing more detail on the inspection and other activity to be delivered in 2007/08 in order to help achieve a 5% reduction in fatal and major injuries due to work related falls from height and slips and trips.  It sustains the inspection and campaign activities of 2005/06 and 2006/07. Inspectors should consider both falls from height and slips and trips issues on all visits described in this instruction.

Background

Falls from height

1. 2007/08 marks the last year of the current Falls from Height Programme. The accident statistics for 2005/06 show a 12% reduction in the fatal and major injury figures¹ for all sectors, and that we are on track to deliver our PSA Target.  Nevertheless, falls remain the most common kind of fatal injuries, and we need to sustain our effort over the next year in order to be sure of success.

2. The Work at Height Regulations 2005 (WAHR), the supporting guidance on our webpages hse.gov.uk/falls/guidance.htm and associated publicity and interventions have done much to raise awareness of the legal requirements and the risks of falls from height.

3. An independent evaluation of the WAHR has shown a high degree of awareness of the regulations and that around 60% of employers interviewed had changed the way they managed work at height.  This included the application of better work practices, demonstrated through increased demand for safer access equipment reported by manufacturers and suppliers.

4. We will be maintaining the promotional element of the Falls from Height Programme in 2007/08 through Ladders Week 2007, planned for June/July.  Since this will be the third year of intensive work on Falls from Height, particularly on ladders, there will be a stronger enforcement element to the work in 2007/08.  Inspectors will wish to note that the Section 7 Inspector Checklist of the Topic Inspection Pack now identifies where pre harm prosecutions may be appropriate. (see Para 12).

Slips and Trips

5. Slips and trips are themselves the biggest cause of major injuries to workers (36% in 2005/6), to members of the public entering workplaces (over 50%), and are often the initiators of other types of accidents such as falls from height.

6. Despite the increased awareness of slips and trips issues recently via publicity campaigns such as Watch Your Step and increased enforcement activity, accident statistics remain stubbornly high.

7. Facilities management companies (in particular) can play a major role in the control of slip and trip risks, for example with appropriate floor maintenance and cleaning regimes.

8. Much advice and guidance can be found on the slips and trips pages on the HSE website at hse.gov.uk/slips/index.htm

Action required by inspectors

9. In 2007/08 we are looking to sustain the operational interventions on falls from height delivered in 2006/07 and extend operational engagement with regard to slips and trips.

10. Specifically, we are asking inspectors to continue the programme of inspection visits, begun under the Height Aware Campaign to companies that manage and procure (minor) building and plant maintenance activities such as facility management companies and housing associations.  We are also asking inspectors to visit contractors who carry out the work e.g. those engaged in building maintenance and cleaning services, and to revisit particularly poor performers as part of Ladders Week 2007 see Para 16 below. FOD visits will need careful local coordination across Divisions, with LAs and with the Construction Programme.

11. The FOD Delivery Plan confirms the number of visits expected per division. We are looking for LA inspectors to consider a similar approach² to procurers not previously visited, spread throughout the planning year.

12. At each visit inspectors should:

• Assess compliance with the Work at Height Regulations in line with the January 2007 Falls from Height Topic Inspection Pack Section 7 of the pack includes a useful summary in the form of a checklist.
• Consider the dutyholders’ assessment of the risks to their own employees from work at height and from slips and trips, and the adequacy of the measures they have introduced to avoid, or minimise these risks.
• Assess the dutyholders’ policy for managing the risks arising from contracted work at height and for slips and trips issues. See the Falls from Height Topic Inspection Pack checklist (Section 7) for expectations regarding the control of contractors.
• Assess compliance on slips and trips issues in line with the Slips and Trips Topic Inspection Pack
• Pay particular attention to activities in connection with floor cleaning (both general cleaning, housekeeping and spillage procedures). See OM/2007/1: ‘Reducing slips and trips accidents caused by floor cleaning’.

13. We are also asking FOD inspectors to make follow-up visits to contractors e.g. building and plant maintenance contractors³ identified during previous visits to those who contract out building and maintenance work or through the accident follow-up work during 2006/07. Follow-up visits will be appropriate where the management of work at height or slips and trips observed at visits to clients’ premises raised concerns.

14. When visiting facility managers or their contractors, inspectors should obtain details of contractors who are used regularly to carry out tasks at height and those whose work activities may be influential in the control of slips and trips (e.g. cleaning contractors, those who maintain/replace flooring). This will help identify new dutyholders for future programme directed inspections (PDI).  Visits will need careful local coordination across FOD Divisions, with LAs and with the Construction Programme.

15. Many facilities management companies are LA enforced.  We are looking for LA inspectors to adopt the same approach as FOD inspectors. Given the range of companies potentially in the target group there is likely to be opportunities for joint LA/HSE visits. These can be coordinated through local HSE/LA health and safety planning arrangements and using existing networks HSE/LA coordination through Partnership  Managers, Partnership Teams and Enforcement Liaison Officers (ELOs).  The Construction Programme will also be targeting procurement companies and contractors and FOD Regions will want to liaise with local Construction Programme staff to ensure that interventions – including those relating to Ladders Week 2007 - are properly coordinated at regional level. 

16. Inspection element of Ladders Week 2007 will take place in July 2007⁴ immediately after the promotional element, - a nationwide “Ladders Exchange“ initiative.  The target audience is the same as for the through-year inspection activity, but during July the inspection activity should be intensified.  The FOD Delivery Plan confirms the number of visits expected per division to contractor companies not previously visited and to companies previously visited during Ladders Week 1 in November 2005 and defined as poor performers (see Para 20 below).

Action required by HSAOs

17. We are asking HSAOs based in FOD Division area offices to act as a central point of contact during “Ladders Exchange” to coordinate local publicity and media interest and to be familiar with the nature and timing of “Ladders Exchange” initiatives delivered through local HSS and Speedy Hire outlets and any complementary schemes run by local authorities with other retailers or builder’s merchants.  We are also looking to HSAOs to liaise regularly with Tony Almond, Falls from Height Programme (see Para 27). 

Targeting

18. According to DTI data there are around 12,000 facilities management companies in the UK.  However, we recognise that they proved difficult to find in 2006/07 and that Standard Industrial Classification (SIC) numbers are not very helpful in identifying them.  The Falls Programme Team has identified a number of company search services that can be used to identify the target companies.  These are listed at Annex A. It has also identified facilities management companies that operate nationwide.  These are listed at Annex B.  For each of these a national FOD lead should be appointed to carry out a visit to the company’s HQ, and to coordinate regional visits to these company’s contractors as appropriate.  

19. Essentially, targeting companies that procure maintenance work is to check what measures are in place to positively raise safety standards for those carrying out the work.  The ‘Height Aware’ Campaign Information Sheet 3: ‘Selecting competent contractors for work at height’ provides more information.  See hse.gov.uk/falls/campaign/materials.htm Ultimately these are the people we are seeking to influence through programme directed inspections, and through ‘campaign’/promotional initiatives. The targeting of procurement companies is intended to encourage them to raise standards through their own influence, by cascading positive health and safety messages. Organisations from the Public Sector that procure maintenance work should not be inspected, but like other procurement organisations they may prove a useful source of information about contractors.

20. The Falls from Height Programme Team will provide by 26 March 2007 a list to each FOD Division of poor performers they had identified during Ladders Week 1 in November 2005 from which to select follow-up visits.

Resource required

21. The FOD Delivery Plan confirms the resource allocation by division.

Recording

To be notified by FOD.

Start and completion dates

22. The programme of inspection visits to companies that manage and procure plant and minor building maintenance, and to their contractors should start in April 2007 and should be completed by 31 March 2008. 

23. Inspection visits in support of Ladders Week 2007 should start in Mid June to end July 2007.  HSAO activity will be required in June 2007 to coordinate the promotional element of Ladders Week 2007.  (Construction Programme inspection initiatives will conducted throughout June 2007).

Inspector competency or training

24. The nature and reasons for the inspection activity is described above at Para 12.  All inspections should be carried out in accordance with the ‘Falls from Height Inspection Topic Pack’ and the ‘Slips and Trips Topic Inspection Pack’.  It is for the inspector to decide when a follow up visit to a contractor is appropriate, and whether enforcement action is warranted.  Any formal enforcement action should be in accordance with the Enforcement Policy Statement and Enforcement Policy Model.

Health and Safety

25. The usual H&S guidance applies.  Inspectors are likely to encounter a wide range of work activities.  Many contractors will be working offsite. 

Programme contact

26. For further information please contact:

• John Holland, Falls from Height Programme, HSE, 8NW, Rose Court, 2 Southwark Bridge, London SE1 9HS. Tel: 020 7717 6991 (VPN 522 6991), (GTN 3053 6991) Email: john.holland@hse.gsi.gov.uk
• Tony Almond, Falls from Height Programme, HSE, 8NW, Rose Court, 2 Southwark Bridge, London SE1 9HS. Tel: 020 7717 6381 (VPN 522 6381), (GTN 3053 6381) Email: tony.almond@hse.gsi.gov.uk
• Mark Thomas or Helena Allum, Slips and Trips Programme, HSE, 8NW, Rose Court, 2 Southwark Bridge, London SE1 9HS. Tel: 020 7717 6686 (VPN 522 6686), (GTN 3053 6686) Email: mailto:mark.thomas@hse.gsi.gov.uk