6th June 2008
The health and safety framework heralds a new approach to environmental health competencies. Tony Lewis and David Newsum explain the thinking behind this new approach currently being piloted and set to go live early next year
What does the framework hope to achieve and when is it likely to go live?
One of the defining features for environmental health over the last 12 months has been the emergence of a competence framework for health and safety enforcement. The framework, currently being piloted within the HSE and selected local authorities, is set to "go live" in spring 2009 and will prescribe the knowledge, skills and competencies that a regulator needs to demonstrate if he/she is to be fully authorised to take enforcement action under the Health and Safety at Work etc Act.
The development work for the framework is being undertaken by a partnership that includes HSE, Lacors, CIEH and Rehis. Direction for the project is provided by a management board made up of representatives from all of the partners as well as experienced health and safety practitioners from local authorities and the HSE.
What is "competence" and why do we need a framework of competencies for health and safety?
The language of "competence" is quite complex and contains a myriad of definitions, but we think that a diagram (see right) by Lewis and Brennan in 2006, explains it quite succinctly.
Put simply, "competencies" are a range of applied knowledge and skills. A couple of good examples taken from the actual framework are: "Carry out topic based inspections to evaluate wider standards", and "assess the quality of hazard identification in regulated organisations".
Both of these competencies require the regulator to hold some specific knowledge and to have developed a range of key skills. Put simply, the health and safety competence framework is designed to match regulatory activity with practitioners whose overall "competence" is assessed against a defined benchmark.
The greatest advantage of such a system is to ensure that employers and their practitioners are not exposed to legal challenge by undertaking regulatory activity for which they cannot demonstrate their competence.
So, how will a practitioner and manager actually use the framework?
Having a framework of agreed competencies as a standard for the fully authorised regulator is just the start. A website takes the practitioner through the framework at his/her own pace and by posing a series of questions answered by clicking on one of three response boxes headed "agree", "unsure" or "disagree". At the conclusion of the process, the website generates an email to the practitioner that indicates the extent to which he/she meets the competence framework and where development needs lie. The site and its associated processes is known as the Development Need Assessment (DNA) tool.
The idea that professional development is a constant process is central to this tool and its effective use. Learning that is not regularly deployed will eventually fade, while the law, policy and science of health and safety are constantly developing. Therefore it is essential that inspectors review training and development needs regularly for areas in which they can benefit from additional development activities. It follows that the identification of development needs does not automatically lead to the revision of an inspector’s authorisation.
The framework is not a performance management tool. The relationship between an inspector’s training needs and that inspector’s level of authorisation is a management decision, taking account of the inspector's current role. Similarly, an individual’s pay is a management decision reflecting factors outside the scope of this framework.
Why do we need a competence framework and DNA tool for regulators when we have environmental health degrees?
It is important to understand the difference. The environmental health degree is a qualification that to some extent focuses on developing the knowledge and skills required to become an EHP – it does not confer competence, although it is the beginning of a journey that leads to competence. The competence framework captures the common competencies of a fully authorised health and safety inspector regardless of employer or background.
There is no doubt that the framework will be used by those developing academic qualifications in environmental health or other relevant areas; indeed, the 2007 curriculum for environmental health takes account of the framework. Further, the framework will also be used to guide future work-based experiential learning.
Is the project being applied equally to local authority and HSE staff?
Yes. The project management board has direct representation from some local authorities and is chaired by Lacors. It also represents CIEH, Rehis, the HSE’s Local Authority Unit and field operations directorate. The governance is supported by a board of senior managers representing HSE’s operational directorates and human resources division. The products being produced and approach being developed apply jointly and equally to local authority and HSE health and safety regulators.
Aren’t competency frameworks just another fad?
The Chartered Institute for Personnel and Development (CIPD) Learning and development: national annual survey report 2007 revealed that 60 per cent of respondents had a competence framework in place for their organisation and of those which did not, almost half (48 per cent) intended to introduce one. That still leaves some fifth of respondents planning to move forward without a competence framework.
However, 40 per cent of those are organisations employing 250 or less, mainly concentrated in the private sector. So, with the exception of a proportion of small private sector firms, competencies seem to be an accepted feature of a modern organisation. The framework helps ensure that both HSE and local authorities are seen as modern regulators, achieving consistency and partnership working.
Will the DNA tool be linked to other competence frameworks or development needs assessment tools for regulators such as food safety for example?
This is the intention of the organisations this project represents. Projects are already under way to develop similar frameworks for food safety, port health, health protection and housing. All of the teams are working together to try and ensure that each framework operates in the same way, has the same look and feel, and is based on common regulatory competencies to avoid duplication. Lacors, CIEH and Rehis are involved in all of these projects.
Will the use of the DNA tool create a greater resource burden for local authorities?
Depending on how thoroughly they do this currently it may well take managers longer to prepare for and carry out development reviews. But we believe the moderate additional investment will be well worthwhile because of the benefits this will bring.
Is the DNA tool a measure of how well a practitioner does his/her job?
It is not a measure; it provides a benchmark with indicators, and a structure that allows the assessment of development needs against that benchmark. It is not absolute and it needs to be read and interpreted in line with an individual’s role and aspirations. The approach is one that encourages us all to be self questioning, as this helps us to learn from experience and apply that learning more effectively. If it improves the way we identify development needs, meet them, and get more out of them, it should help us become more effective in our roles.
Who is going to check that appraisal using the DNA tool is done properly in local authorities and HSE?
The development of the tool is intended to support the new Section 18 guidance; so monitoring arrangements, although not yet determined, will be considered in line with S18 standard assessment and auditing. CIEH is currently lobbying strongly for inter-authority and inter-agency auditing to be a strong feature.
How can I find out more about the framework and the DNA tool?
Further information is currently available via the website:http://hse.mandogroup/competenceframework
It should, however, be remembered that this is not the final website and some changes may need to be made following completion and evaluation and before the project goes live.