Executive summary

The Health and Safety Executive’s (HSE) Simplification Plan 2009 is the fourth in a series of annual plans to outline HSE’s progress in reducing the administrative burden of health and safety regulation, as well as showing how HSE, in partnership with local authorities as co-regulators, is delivering the Government’s better regulation agenda.

The HSE Strategy, "The Health and Safety of Great Britain\\ Be part of the solution" sets out the overall direction for the health and safety system as a whole, recognising the importance of the better regulation agenda.

The HSE Strategy accepts that Great Britain’s health and safety priorities cannot be delivered in isolation from other issues that impact on or overlap with them. Improving health and safety can help improve the performance of a business. However, unnecessary paperwork and bureaucracy can act as a deterrent to compliance.
Health and safety is just one part of overall business regulation and must be a benefit to those it seeks to protect, not a disproportionate burden on those who have to comply with it.

In 2005, a cross-government exercise measured the administrative burdens resulting from legislation across all departments (for more information, see Annex 2 for details).

In line with other government departments, HSE is committed to working towards reducing administrative burdens by 25% from the 2005 baseline level, without reducing levels of health and safety protection. The ABME calculated an indicative annual cost of £2.03 billion of administrative burdens stemming from health and safety legislation. To achieve a 25% reduction, HSE’s estimated reduction target was £508 million. This has been modified, mainly as a result of machinery of government changes, to a total cost of £2.022.5 billion and a £505.6 million reduction target.

Baseline	£m value	Net reduction target to be achieved (£ms) by May 2010
December 2005 baseline	£2,032m	£508m
2008 baseline adjustments	-£13.1m relating to Approved Code of Practice in Confined spaces
	+£5.2m relating to adventure licensing
December 2008 and 2009 baseline	£2,022.5m	£505.6m

Up to May 2009, HSE has reduced administrative burdens by an estimated £382 million on a net basis, equating to 75.6% of the reduction target, and by December 2009 will achieve an estimated £499.1 million reduction, or 99% of the target – but this figure includes estimated savings that have not been validated and which may be subject to change or revision.
Delivered and forecast delivery:

	May 2009	December 2009	May 2010
Gross savings	£403.6 million	£521.2 million	£548.9 million
Gross burdens	£21.6 million	£21.6 million	£21.6 million
Net reductions (£ms)	£382.0 million	£499.6 million	£527.3 million
% reduction	18.9%	24.7%	26.1%

HSE’s previous Simplification Plans set out initiatives to help to achieve the target. Progress and delivery of these projects is outlined below:

Initiative title and description	Target reduction from ABME data	Impact on business	Delivery of initiative / timings
Sensible Risk Management – example risk assessments - increasing compliance, and encouraging proportionate risk management – and addressing risk assessment costs in the Management of Health and Safety at Work Regulations	£235 million gross savings plus £18.4 million reduction in risk assessment costs from requirements in other legislation	34 Example Risk Assessments help small businesses think through some of the hazards in their business and identify the steps they need to take to control the risks.	Completed. 33 published by November 2008. 34th Example Risk Assessment delivered in September 2009.
Gas Safety (Installation and Use) Regulations – reviewing the requirement for a landlord to carry out a gas safety check	Up to £59 million gross savings	Landlords will be able to get appropriate gas safety guidance in a “one stop shop” on the HSE website.	Underway. New website to be implemented by May 2010.
Lifting Operations & Lifting Equipment Regulations – new guidance to clarify examination of equipment requirements	Up to £33 million gross savings	Businesses are clearer about when to examine lifting equipment and fork lift trucks.	Underway. New guidance on examination of lifting equipment was published in June 2008.
Control of Asbestos Regulations 2006 – consolidating three sets of regulations	£27.7 million gross savings	From November 2006, asbestos contractors no longer need to notify HSE when working with textured decorative coatings.	Completed in November 2006.
Manual Handling Operations Regulations – guidance on the labelling of loads	Up to £32.5 million gross savings	The new guidance published in May 2008 helps businesses decide when to label loads to avoid manual handling injuries to workers.	Completed. New guidance published in May 2008.
The written health and safety policy statement – an electronic template for the statement and Electronic risk assessment template – additional initiative linked to HSE’s work on Sensible Risk Management and to the written health and safety policy statement project	Up to £26.5 million gross savings Up to £27 million gross savings	From September 2009, businesses can now use one form to complete their risk assessment, health and safety policy and record of health and safety arrangements. This will help businesses get started on their risk assessments and will save them time.	Completed in September 2009 Integrated with the electronic risk assessment template. Evaluation to be carried out by May 2010
Forms project – including a separate project to amend legislation to remove 8 outdated forms.	£21.3 million gross savings	54% of HSE’s forms not required by law removed by April 2007 From 6 April 2009, most businesses will no longer have to notify HSE or local authorities when they start up or when they move.	Completed by April 2007. Completed in April 2009. 8 outdated business notification forms removed in April 2009.
Workplace (Health, Safety and Welfare) Regulations – guidance on labelling water	Up to £17 million gross savings	Following publication of the guidance in September 2007, businesses are clear that they only need to label water when the water should not be drunk.	Completed. New guidance published in September 2007.
RIDDOR project – reducing the time taken to report incidents at work	£16.5 million gross savings	From March 2007, businesses are encouraged by HSE to “ring and report”, saving time in reporting incidents at work.	Completed in March 2007.
Control of Substances Hazardous to Health Regulations – rationalising and improving guidance and reducing risk assessment costs	Up to £11.1 million gross savings	From Summer 2009, the new COSHH website, guidance and example risk assessments make it easier for businesses to understand what they have to do to control the risks from chemicals.	Completed in Summer 2009
Health and Safety Information for Employees Regulations – amending regulations on the health and safety law poster	£10.7 million gross savings	From April 2009, businesses no longer have to write the name and address of their enforcing authority, and the address of the local Employment Medical Advisory Service (EMAS) directly onto their poster. If they already have a poster, this does not have to be replaced for 5 years. The new poster is also simpler and clearer than the old one.	Completed in April 2009.
Business online project – making HSE’s forms available in an electronic and interactive format	Up to £10 million gross savings	Businesses will be able to use a range of electronic HSE licence application and notification forms. From June 2008, businesses can now notify HSE electronically about construction projects.	Underway but now being addressed by other, wider, customer support programme(s) on a longer timescale. F10 Construction Notification form launched in June 2008.
Offshore Installations (Safety Case) Regulations 2005 – revising the frequency for submitting a safety case from three years to five years	£3.8 million gross savings	From April 2006, offshore firm only have to submit a safety case every 5 years rather than every 3 years.	Completed in April 2006.
Construction (Design and Management) Regulations 2007 – clarifying and simplifying requirements for the notification of construction projects	£3.6 million gross savings	From April 2007, businesses have to complete less paperwork for construction projects.	Completed in April 2007.
ACoP on Zoos – ACoP no longer in existence	£544,000 gross savings	Removal of the ACoP meant removing the administrative burdens connected to ACoP requirements.	Completed in December 2006.
Good practice guidance on worker involvement – clarifying requirements on providing health and safety information to safety representatives	Up to £36.6 million gross savings	Businesses can find out more easily what they have to do to improve dialogue and cooperation between employers and workers without having to pay for external services	Completed. New guidance published in October 2008.
Docks form – removal of an outdated form	£3.6 million gross savings	Businesses will not have to certify the safety of a boat that takes dock workers to other ships in the harbour to load and unload the cargo.	Underway. This form is now expected to be removed by May 2010.
TOTAL GROSS SAVINGS (if all initiatives are delivered and savings validated)	£548.9 million gross savings

Since publication of the 2008 Plan, HSE has successfully delivered four simplification measures:

• Sensible Risk Management – example risk assessments - addressing risk assessment costs in the Management of Health and Safety at Work Regulations 1999 through example risk assessments ;
• Written health and safety policy statement and the electronic risk assessment template;
• Forms project - removing 8 outdated business premises notification forms and registers; and
• Health and Safety Information for Employees Regulations project - amending the health and safety law poster.

Good progress is being made on the remaining projects. Savings resulting from these projects add to those already achieved from initiatives delivered previously.

Three of HSE’s simplification measures were approved in June 2009 by an independent External Validation Panel, whose members include representatives from the Confederation of British Industry, Institute of Directors, British Chambers of Commerce, Federation of Small Businesses and Trades Union Congress. Approved projects were:

• Manual Handling Operations Regulations – guidance on the labelling of loads; £32.5m gross savings as at May 2009;
• Removal of 8 forms required by Factories Act and Offices, Shops and Railway Premises Act; £21m gross savings as at May 2009; and
• Health and Safety Information for Employees Regulations – amending regulations on the health and safety law poster. £10.7m gross savings as at May 2009.

HSE, in partnership with local authorities as co-regulators, is committed to wider better regulation work in line with the HSE Strategy in addition to the administrative burden reduction programme. In the past year, the following key strands of work have taken place:

• making the content of HSE’s priced publications containing advice, guidance and regulations, freely available; and
• continuing to improve policy development, information and guidance for small-and medium-sized enterprises (SMEs), in line with the Government’s “Think Small First” policy and drawing on advice from HSE’s own Small Business Trade Association Forum.

HSE and local authorities have continued to work closely with its stakeholders, such as representatives from businesses, trade unions, and trade associations, in the development of simplification projects as well as wider better regulation initiatives.

Over the next six months, HSE will continue to review its simplification initiatives, in the light of the Government’s Strengthening Regulatory Management proposals and the new HSE Strategy published this year. HSE will also carry out post-implementation reviews and evaluations, as appropriate, to determine whether projected savings have been delivered as well as examining their overall impact.

This report does not, however, include details of new HSE simplification initiatives being developed under the Government’s Strengthening Regulatory Management proposals.