Inspection Aide Memoire based on HSG65 POPMAR
Assessing management during inspection/investigation
After initial discussions plan what you can do in the time available. Aim to collect sufficient information about their management system during the course of the inspection (visit or accident investigation) to make a reasonably well informed judgement about their SMS performance. Below are suggested lists of areas to be covered.
Information/documents to seek
- Corporate health and safety policy
- Supporting policies or procedures
- RA’s/safe systems of work
- Existing action plans or internal investigation reports
- Accident/ill health information
- Management reviews
As well as assessing their adequacy, use the policies/procedures etc to direct questioning of anyone with specified responsibilities (e.g. so you’re responsible for doing X, did you know this was part of your role, is this role is best allocated to you, do you have adequate resources – information/money/time/training/experience/authority, how do you do it in practice, what are the barriers to doing it, who monitors your work, if you delegate tasks how do you monitor adequate completion etc ). Try not to be too judgemental at this stage in order to keep discussions moving forward.
People to meet
- Chief Executive Officer/Managing Director
- Board Director responsible for health and safety
- Health and safety advisor and/or other relevant specialist advisor e.g. OH, manual handling
- TU/employee reps
- A representative sample of employees at each level in the organisation (a vertical slice)
- Anyone else who has a key role or responsibilities defined in policy/procedure/RA documents
Ensure visit feedback (verbal and written) is addressed to CE/MD. Ask for an action plan indicating how they intend to tackle problems identified.
Safety (and Health) Management System
A typical system will be based on POPMAR (HSG65) i.e. Policy, Organising, Planning, Monitoring, Audit and Review.
Note: A contemporary approach, which is a variation of POPMAR is; Plan, Do, Check, Act, these terms reasonably translate into POPMAR headings.
The five POPMAR elements are: Policy, Organisation, Plan, Monitor, Audit and Review.
A general statement that there’s an intention to protect staff, comply with the law. It sets out the organisation’s commitment to high and improving standards of H&S and the aims and objective. The policy should be up to date, signed and dated by CEO/Director, communicated to all staff, understood and acted upon. It has a practical effect on the way things are done. It covers all the key risks/H&S matters or is supported by other policies/procedures which do. It does not conflict with other organisational policies. It sets out the strategy for health and safety management, risk assessments, risk control systems, etc. It provides a vision of leadership commitment.
The Organisation – setting out who does what. The specific H&S responsibilities of each role/position should be set out. All key H&S roles (e.g. completion of risk assessments, arranging training, investigating accidents, monitoring compliance etc.) should be allocated to someone competent to carry them out. People should understand, accept and act on their responsibilities.
The Arrangements – setting out rules, systems, procedures for H&S e.g. how risk assessments will be completed, implemented and reviewed, how training needs will be identified and met, employees consulted, performance monitored.
To secure a positive health and safety culture to get staff involved and committed, organisations need to manage 4Cs; Control, Cooperation, Communication, Competent workforce/advice
Risk assessment procedures are followed, up to date, relevant and reviewed. And apply to suppliers of goods and services. Roles/responsibilities and job descriptions contain relevant reference to health and safety. A board member is nominated as H&S ‘champion’ and is active in the role. Senior managers lead by example (e.g. complying with H&S rules at all times, attending H&S training, asking about H&S issues). H&S responsibilities are allocated to managers, with H&S specialists in support role. Managers accept responsibility for controlling risks in their area and have the resources (money, time, support, competence etc) to do it. Employees understand and accept their role in ensuring day to day H&S. Everyone knows how their performance will be measured and monitored and how they will be held accountable. Good performance is rewarded, poor performance is investigated and improvement supported. Written safe systems of work are in place for non-routine/infrequent activities.
Legal obligations for informing and consulting employees are met (see Worker Involvement topic pack). Staff and representatives are active participants in the H&S system. They are involved in developing policies, risk assessments, setting standards, monitoring, investigating through an effective H&S committee or equivalent forum. They should meet regularly be involved in determining priorities; it shouldn’t be bogged down in dealing with day to day matters and complaints etc which should be resolved through the management system which should have arrangements for employees to raise concerns and for managers to respond. Arrangements are in place for co-operation and co-ordination where different organisations share a workplace.
The organisation keeps up to date on H&S through external sources of information. Employees are given relevant information about policies, results of risk assessments, investigation findings etc. Employees are familiar with policies/procedures and know their responsibilities. Directors/managers signal commitment by actions e.g. chairing H&S committee, involvement in accident investigation. Board/Management/team briefings include H&S. All contracts include H&S requirements. Clear procedures exist for recording and reporting accidents/ill health/near misses and employee concerns.
All employees have adequate instruction and training in the skills, hazards, risks and risk controls relevant to their job. All managers have received H&S training relevant to their role. (At higher levels this may be in H&S management, further down it may be in supervising skills plus specific risk awareness). Staff with specific H&S responsibilities allocated by the policy (e.g. Risk assessment) have the skills needed to carry them out effectively. Refresher training is provided, especially for statutory appointees .e.g first aiders. H&S training needs arising from recruitment, promotion or changes to plant/processes/working practices are identified and met. Induction training includes H&S. Adequate training records are kept. Staff, especially those in high hazard roles, are assessed as competent.
Competent H&S advice
The organisation has identified the level of competent advice (health, safety, specific risks) it needs and has arranged it (e.g. by training existing staff, recruiting suitably qualified advisers, contracting with competent providers). The competent advisor has adequate status within the organisation and preferably reports directly to a director; advice is respected and acted on.
Planning and Implementing
The company can identify its biggest hazards and its biggest risks. There is a clear process for completing and reviewing risk assessments and identifying risk controls. Risk assessments result in action (or plans) to control risk, the necessary controls for h/s are in place. All actions cannot be achieved at once so they are suitably prioritised. It can identify and justify main areas (e.g. top 3) where additional controls are needed and have a plan for this. Annual and, where appropriate, longer term H&S plans are in place. Targets/objectives are set and agreed with managers. If appropriate, there are contingency/emergency plans in place and practiced. Processes require H&S to be automatically considered as part of change (new plant/premises/practices etc). Purchasing and supply policies take account of H&S requirements. The company has set clear and specific performance standards (the ‘state to be achieved’) so that everyone knows who does what, when, with what result and performance can be measured. (for example: not ‘All staff must be adequately trained’, but more specific e.g. ‘’Production manager to ensure that all production staff attend ½ day ‘Moving Stuff Safely’ training (book through ABC Training) within 2 weeks of employment and refresher training every 2 years’.
Implementation of the SMS is easier if clear objectives, procedures and risk control systems are properly documented.
Active monitoring– before things go wrong
Periodic proactive monitoring is done to confirm that key risks are controlled and performance standards met – that the policies/procedures/risk assessments are actually complied with in practice and if not why not. Such indicators can be checklist inspections, sampling, spot checks, health surveillance, follow up actions or surrogate measures such as attending safety training, meeting production targets, statutory equipment insurance reports. They should be converted from a qualitative to a quantitative measure e.g. % of inspections completed on time. Monitoring should be managed by someone, preferably line management, who has the competence to judge the quality of compliance, e.g. not just has a risk assessment been done, but does it reach justifiable conclusions and has the risk been reduced as low as possible. Where problems are identified, prioritised action plans for improvement are made and implemented. Directors/senior managers see and consider results of monitoring and give feedback.
Reactive monitoring– after things go wrong
Procedures are in place for investigating injuries, ill health, property damage, near misses. Investigations are proportionate to the event - those involving potential or actual significant harm are investigated in depth. The investigator has sufficient authority and training in investigation techniques. Employee/TU reps are involved. Immediate and underlying causes are identified and remedial action prioritised. Policies/procedures/risk assessments are reviewed and changed where necessary. Lessons learned are shared across the company. Directors/senior managers are informed of findings. Accident/ill health data is analysed for trends and the amount and causes of work related sickness absence is identified; directors receive and discuss reports. The company can identify costs/losses associated with accidents etc.
The organisation must learn from experience, improve performance and respond to change. The review should bring continuous improvement particularly to the management system. It should take place at all levels, to include judgements about for instance workplace controls and accident data is analysed to identify underlying causes and trends.
The structured periodical process of collecting information on the effectiveness of the total SMS and planning for improvement. Normally undertaken by external agents, but can be internal given that skilled staff are used and they’re independent of the subject section. Complements more frequent monitoring arrangements by checking occasionally to see if the health and safety management system is actually achieving the right results. For example checking that the risk control and workplace precautions are in place.
Importantly an action plan must arise (this will always be the case for continual improvement) and the actions are implemented.