PART 2- HOW YOU ORGANISE FOR HEALTH AND SAFETY

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• The policy statement should identify key safety posts and the responsibilities associated with them including the preventative/proactive and mitigatory/reactive safety management functions e.g. persons responsible for the policy and its maintenance, the SMS and the emergency (serious or imminent danger) response element of the SMS.

• There should be evidence (possibly in the form of an organogram/management tree) of the way safety functions are organised, showing key safety related posts and their links.

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a. Some responsibilities will naturally be a part of other jobs. Safety representatives will be decided by trade unions where recognition exists.

b. See leaflet on "Directors responsibilities for health and safety."

c. Formally appointing someone may assist in clarifying roles and responsibilities.

d. Is there a chain of command for safety related posts and how do posts inter-relate.

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• It is important that managers understand what is expected of them in relation to health and safety in the same way that they would for production or finance.

• Safety should be an integral part of a manager's job and should be planned in, not simply another task assigned to an already overloaded post.
• HS(G)65 recommends that Performance Standards should be set to assist in managing the risks associated with operations. Performance standards should:
- set out clearly what people need to do to contribute to an environment which is free of injuries, ill health and loss,
- help identify the competences which individuals need to fulfil their responsibilities
- form the basis for measuring individual, group and organisational performance.
• The performance standards should explain what is to be done and how. Examples might be checking contractors' health and safety performance before awarding contracts, providing training, periodic monitoring of performance/auditing, weekly "tool-box talks" by supervisors etc.

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• Organisations need to produce a climate, which promotes staff commitment to health and safety, and emphasise that deviation from safety goals, at whatever level, is not acceptable. Producing such a climate requires clear visible management commitment to safety from the most senior levels in the organisation. This commitment should not be just the formal statement but be evident in the day to day activities of the enterprise so that it is readily known and understood by employees.

• The attitude of a strong personality at a senior level within the organisation may have a beneficial or adverse effect on the safety climate. Inevitably junior employees will be influenced by that person's example.

• Operators confronted by abnormal situations will be guided not just by instructions but by the attitudes of supervisors or managers. In this, nothing is so pervasive or damaging, particularly if a complex or unusual situation arises, as a culture in which a 'macho' attitude to safety has been implicitly encouraged, or if departures from safe practice are 'winked at'.

• Most people wish to 'get on with it'. Few wish to appear timid, or to refer to the possibilities of danger that are not clear and visible. If these natural attitudes are not to dominate, positive steps must be taken to encourage an attitude of 'stop and think'. This must be an inherent part of training objectives, and of what management say or do.

References

1. Young people at work: a guide for employers, HSG165, HSE 1997, ISBN 0 7176 1285 6

• Certain aspects of the job may have special hazards such as working at height, working alone, dust, noise, fumes etc.

• Certain physical qualities or skills may be required, as well as a sense of responsibility. The latter is especially important in supervisory and management positions.

• Eyesight may be important where lack of good visual judgement may lead to accidents such as in forklift driving. Hearing ability may be important where audible warning systems are in use in noisy situations such as fire alarms where there is machinery. Audiometric testing may be used, supervised by occupational health staff. Colour vision may be important where colour safety signals are used, such as red for stop button. The latter is usually mushroom shaped to overcome this problem. Colour vision tests can be carried out by an occupational health nurse, or alternatively HSE's Guidance Note MS7 Colour Vision gives general guidance for managers who need to use them.

• Skin and respiratory disorders are of special concern in relation to dyes, in particular reactive dyes. Lung function tests, supervised by occupational health staff may be necessary.

• Respiratory health and smoking habits may be relevant wherever there are dusts or fumes present. Work involving exposure to textile dust will necessitate health surveillance and pre-employment assessment

• For those with safety responsibilities, basic questions on their working knowledge of health and safety law, Codes of Practice, can also be asked.

• Recruiters should understand the physical and mental limitations of young persons imposed by lack of maturity, experience or awareness. Similarly, the limitations of young or expectant mothers imposed by their physical condition should be understood. This should be included in training and guidelines provided for recruiters in assessing the job specification.

• An understanding of the Disability Discrimination Act will be required by those doing recruitment.

References

1. Management of Health and Safety at Work Regulations, Approved Code of Practice and Guidance, L21, HSE 1999, ISBN 0 7176 2488 9
2. Education and Training, KDL3, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608).

• Regulation 13 of the MHSW Regulations. requires that every employer provides adequate health and safety training to his employees on their being recruited or their being exposed to new or increased risks because of:

(i) Being transferred, or having a change of responsibilities;
(ii) Introduction of new or changed work equipment;
(iii) Introduction of new technology; and
(iv) Introduction of new or changed system of work.

References

1. Health and safety training - what you need to know, INDG345, HSE 2001
2. Effective health and safety training - a trainers' resource pack, HSG 222, HSE 2001
3.Education and Training, KDL3, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608).

• Provision of adequate health and safety training is a requirement of the MHSW Regulations. This covers recruitment, transfer and the introduction of new equipment, technology, systems of work or changes to any of these.

• Training needs to be given in a structured, manner preferably by trained training instructors using written down training schemes, this is particularly important where the employer needs to be certain that specific points have been conveyed and understood.

• Hazardous Work Permits can be prepared for jobs that carry an unavoidable high level of risk. These are usually issued by authorised persons to specific persons trained in the task to be undertaken. They specify the precautions that must be taken.

• Even if job-training schemes are not written down, those elements of certain jobs which carry a high level of risk should have a safe system of work or safe operating procedure set out in writing.

• All levels of management require training; and specific maintenance tasks should not be overlooked.

• Safety is a part of every employee's job, whether or not job descriptions and specifications are used. Where they are used, and it is preferable that they are, they must include health and safety criteria.

References

1. Safety Representatives and Safety Committees:(The Brown Book) Approved Code of Practice and Guidance, L87, HSE1996, ISBN 0 7176 1220 1.
2. A guide to the Health and Safety (Consultation with Employees) Regulations 1996, L95, HSE 1996, ISBN 0 7176 1234 1.
3. Briefing Paper No.6: Safety Representatives and Safety Committees, April 1994, Briefing Paper available from BCIA Ltd. (Tel: 0171 636 7788) or from GMB Clothing and Textile Section (Tel: 0181 947 3131).
4. Consultation, KDL2, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608).

• Employers have a duty to consult employees on matters relating to their health and safety, either under Section 2(6) of the Health and Safety at Work Act in the case of union appointed safety reps or under the Health and Safety (Consultation with Employees) Regulations.

• Consultation with employees is as effective and essential on safety matters as consultation is on other matters such as terms and conditions of employment etc. It assists problem solving and gains commitment.

• Consultation can be on a day to day basis with employees or their representatives, through the usual management structure. However it can also be on a more formally constituted basis, through the use of a properly constituted safety committee.

• If you recognise a trade union, which has appointed safety representatives, the latter may call for the setting up of a safety committee. How this takes place is set out in a booklet 'Safety Representatives and Safety Committees', published by HSE.

• Any employees not in groups covered by trade unions must be consulted by their employees under Ref2. This can be done directly or through elected representatives

References

1. Health and Safety (Safety Signs and Signals) Regulations 1996, L64, HSE 1997, ISBN 0 7176 0870 0.
2. Safety Representatives and Safety Committees:(The Brown Book) Approved Code of Practice and Guidance, L87, HSE1996, ISBN 0 7176 1220 1.
3. A guide to the Health and Safety (Consultation with Employees) Regulations 1996, L95, HSE 1996, ISBN 0 7176 12341.
4. Young People at Work: A guide for employers, HS(G)165, HSE 1997, ISBN 0 7176 1285 6
5. Five Steps to Information, Instruction and Training, INDG213, HSE 1996, ISBN 0 7176 1235 X
6. A Guide to Information, Instruction and Training: Common provisions in health and safety law, INDG235, HSE 1996, ISBN 0 7176 1286 4
7. An Introduction to Health and Safety: What you should know, where to get information, INDG259, HSE 1997
8. Briefing Paper No.6: Safety Representatives and Safety Committees, April 1994, Briefing Paper available from BCIA Ltd. (Tel: 0171 636 7788) or from GMB Clothing and Textile Section (Tel: 0181 947 3131)
9. Communication and Information, KDL1, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608).
10. Safety Systems at Work, KDL8, available from KDLI Publications (Tel: 0161 624 9749) or from the Knitting Industries Federation Ltd. (Tel: 0116 254 1608)

• Every employer must provide adequate information to his employees (HASWA) and specifically, inform employees of the risks to health and safety, protective and preventative measures, the identity of competent persons and the procedures for serious and imminent danger (MHSW Regs.).
• Every employer must provide information to his employees on health and safety law (The Health and Safety Information for Employees Regulations 1989). This will take the form of a prescribed poster or leaflet issue and can be referred to in the Policy, together with the location of any other sources of legal information, which it is intended to make available to employees.
• Information is provided to employees in the Policy statement, through training, use of safety signs etc. However, the Health and Safety Information for Employees Regulations 1989 makes the posting of a prescribed poster (or the issuing of a leaflet) mandatory. The information contained is headed "Health and Safety Law - what you should know". The Health and Safety Executive publish a wide range of free leaflets, as well as guidance on Regulations and technical matters much of which is of a general informative nature, or written specifically for employees.
• Where there are hazards that cannot be obviated, safety signs can be used. This includes signs indicating ear defence zones, fragile roofs, no smoking areas etc. All signs erected or placed must conform to the Health and Safety (Safety Signs and Signals) Regulations, 1996.
• The disciplinary procedures which apply to breaches of safety should be clear and set out in the same way as the disciplinary procedures which apply to other breaches of works' rules.
• Protective and preventative measures can be made known to employees by safety signs where appropriate, in addition to any training that may be given.
• It should be clear to each employee what to do if he has a problem relating to safety. This would normally involve discussion with an immediate supervisor, followed if necessary by invoking the grievance procedure, informing the safety representative etc.
• Where arrangements exist, employees should be informed of the membership of the Committee, and who is covered by it; and should be kept informed of its proceedings, perhaps by posting up minutes of meetings.
• The Safety Representatives and Safety Committees Regulations 1977 provide that a recognised trade union may appoint safety representatives from amongst employees. Once the Union has appointed safety representatives, it must provide written confirmation. Managers concerned with union appointed safety representatives should be aware of their safety representatives' rights to time off with pay, the carrying out of inspections and their rights to information. All this is set out in a booklet "Safety Representatives and Safety Committees" published by HSE.
• Extensive information on a large range of topics is published by the HSE. Much is obtainable in free leaflet form from HSE Books (Tel: 01787 881165).
• Approved Codes of Practice and guidance booklets are obtainable from HSE. A catalogue of HSE publications is published twice a year and is also available via the internet. Industry specific information is also published by the HSE.
• Trade Associations and the HSE take regular telephone calls on safety matters, and Training Groups will provide additional services to member companies.
• All managers should be aware of the above sources of information, and have copies of relevant information in their possession and accessible to supervisors and others.
• Upon receipt of such information, there should be a system in place for managers to promulgate relevant information to those who will need it, e.g. in the form of tool box talks, progress meetings (with safety as an item on the agenda), safety information sheets/bulletins etc.
• An interchange of ideas between organisations assists in ensuring that controls are identified which represent industry-wide best practice.

Safety Signs

• A requirement of the Health and Safety (Safety Signs and Signals) Regulations 1996. After the application of risk reduction measures, both engineered and procedural, all significant residual risks must be communicated to employees.

• For minimum requirements for signs and signals, refer to Health and Safety (Safety Signs and Signals) Regulations 1996 Guidance. A sign may take the form of a signboard, safety colour, illuminated sign, acoustic signal, verbal communication or hand signal. There are two types of sign, permanent and occasional.

• Permanent signs (signboards) must be used for signs relating to prohibitions, warnings and mandatory requirements and the location and identification of emergency escape routes and first aid facilities. Signboards and/or a safety colour must be used to mark permanently the location and identification of fire-fighting equipment.

• Meaning or purpose of safety colours: Red (prohibition, danger alarm, fire-fighting equipment), Yellow/amber (Warning sign), Blue (mandatory sign) and Green (emergency escape, first aid sign, no danger condition).

• Occasional signs e.g. Illuminated signs and acoustic signals must be used where the occasion requires, taking into account the possibilities for interchanging and combining signs, to signal danger, to call persons to take a specific course of action and for the emergency evacuation of persons.

• For minimum requirements for signboards and specific locations, refer to Health and Safety (Safety Signs and Signals) Regulations 1996 Guidance.