HSE inspections of local authority waste collection services 2005-2007
Between 1 April 2005 and 31 March 2007, HSE inspectors visited LA)clients and the operators of municipal waste and recyclables collection activities throughout Great Britain, as part of a phased initiative within the industry.
Well over 60% of LAs were visited and both in-house and contracted-out services were inspected. Inspectors assessed the management and organisational arrangements in place, the monitoring and supervisory aspects of the activities, and the activities themselves. These were assessed against criteria within an inspection report form.
The results of the visits indicated that the standard of management of contracts and contractors was a matter of concern. In summary, key findings included the following:
Were collection options being risk assessed before being specified in the ‘invitation to tender’?
In around 45% of the LAs seen, the evidence suggested that there had not been a proper assessment of the various collection, transfer, treatment and processing systems available to ensure that the most appropriate system was chosen for the environment with proper consideration of factors such as recycling performance, value for money and health and safety.
Evidence that health and safety implications of the collection rounds were considered at an early stage was scant in 20% of LAs visited. Proper and early consideration of these issues had only taken place in 35% of the LAs seen.
Were health and safety considerations included in the tender evaluation process?
Over 25% of returns indicated that contract selection did not adequately cover health and safety arrangements. In 10% of LAs seen, the level of consideration actually achieved led the inspector to conclude that the LA clients were in breach of their duties under health and safety legislation.
Were the health and safety roles of the client and the contractor properly understood and clear?
Just over 30% of LAs seen were not fully aware of their obligations, under the Management of Health and Safety at Work Regulations 1999, to risk assess the process and they also had not recognised they had ongoing responsibilities throughout the life of the contract.
There was often a substantial lack of client involvement throughout the life of the contract and a lack of clearly defined roles and duties. Of the LAs seen, 9% were deemed to have limited or no compliance with their duties.
Was there effective monitoring of contractor performance by the client to ensure compliance with health and safety control measures?
The HSE inspectors assessed around 45% of LAs visited as requiring improvements in this area. In 19% of LAs seen the HSE inspectors considered that the LA was failing to properly and effectively monitor contractor performance and was not complying with the law.
Was there effective monitoring and supervision on the ground by the client and the contractor?
Of the LAs visited, 44% were assessed as having inadequate systems to monitor the effectiveness of the supervision of street collection crews. Monitoring of supervision by the client was often minimal, although the role of the supervisor was usually clearly defined.
More could be done to improve monitoring of the effectiveness of supervision by the client. If insufficient monitoring is carried out then there is little assurance that safe systems of work are followed.
Was there flexibility within the contract to change the operating details in response to emerging health and safety issues?
Inspectors reported that in almost 29% of LAs visited that the contracts were inflexible.