Stakeholder simplification proposals
HSE welcomes simplification proposals from stakeholders, and although it may not be possible to accept all proposals, they are given serious consideration. Stakeholders have the opportunity to submit proposals through various tools, for example, using HSE Infoline, contact and stakeholder groups, directly to HSE officials, or via BRE’s simplification proposal website.
Since publishing the 2007 Plan, HSE has received four simplification proposals:
- One proposal concerned how hospitals report RIDDOR incidents to HSE and Local Authorities. The RIDDOR Regulations were reviewed in 2005 / 2006, and included exploring work in this area, but there was no consensus for radical changes to reporting. The proposal was not adopted, but any future reviews of RIDDOR may reconsider the issue raised.
- One was a suggestion to revisit the issue of linking radon with employer’s liability insurance, making it a condition of insurance that a radon assessment had been carried out. HSE has previously examined this area, but it was found that there was no clear incentive for insurers to take an interest. HSE has advised that the proposal will not be taken forward.
- After consideration, HSE did not take forward a proposal to have one single, statutory health and safety qualification. HSE sets out the core criteria required and is fully behind initiatives for greater mutual recognition between schemes but recognises that an across the board scheme could act as a barrier to SMEs.
- One was a misunderstanding of the law, and was not taken forward.
In addition, HSE also fed into three proposals received by other government departments.
Of the proposals outlined in the 2006 and 2007 Plans which were accepted, seven have now been completed – core-criteria for electrical contractors endorsed by HSE; a list of health and safety regulations published; consideration of the certification of gas installers; a review of accident reporting; and three on helping SMEs understand health and safety information.
One proposal required working in Europe to propose a simpler process for applying for exemptions under the Genetically Modified Organism (Contained Use) Regulation. HSE’s efforts towards simplification of this have involved several strands of work and is on-going:
- the exemption of safe organisms has been discussed at several meetings of Scientific Advisory Committee for Genetic Modification and will be included as a specified workstream for the Committee in 2008/09;
- discussions with the European Commission on the most up to date guidelines for the exemption process; and
- multilateral discussions with other Member States to ascertain their views and approach to the subject – preliminary discussions have indicated a similar approach.
Three other proposals concerned projects already underway as part of HSE’s simplification work – a review of the health and safety law poster; review of the form to register a business; and clarification of the requirements of LOLER and PUWER.
