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Wednesday, 1 December 2021, Abigail Miller MCIEH CEnvH, member of EHN’s editorial board and CIEH’s Health & Safety Advisory Group
‘Compliance’ is a scary word for some. In health and safety management it means upholding your legal duties, understanding how legislation affects you and ensuring everyone abides by the rules.
But it also translates as ‘doing the right thing’, which is what everyone responsible for health and safety should set out to do.
Compliance isn’t a single action, however, and many factors need to be considered and steps taken to achieve it.
The foundation of any safety management system is the risk assessment. If you get this first step right, nailing compliance will be (fairly) straightforward.
Risk assessment may also be a scary prospect, but contrary to popular belief, it doesn’t have to mean creating reams of paperwork and thousands of checklists. Keep it simple. You don’t need to have individual risk assessments for every task, but instead can create more generalised risk assessments to cover multiple elements of any operation.
To approach it, think carefully about all the foreseeable risks and consider all aspects of the work activity, considering all hazards and subsequent control measures that can be put in place. Begin by identifying the hazard – something that could cause harm, such as wires trailing across the floor, or considering COVID-19. Then, ask ‘what is the risk?’ and what makes that hazard more likely to cause an issue. For example, factors contributing to the risk of a trip on a wire could include who uses the area or whether the wires are secured. Whether employees get COVID-19 or not is more complex and involves external factors, potentially outside your control, but in order to be compliant you need to do everything in your power to reduce the risk on your premises.
Once a risk assessment has been carried out, we then have to determine and implement control measures. What will you do to ensure it is less of a risk or problem? It may mean re-routing wires so they are no longer trailing across a high traffic area, asking employees to take a lateral flow test twice a week or improving ventilation.
Consultation can provide a key supporting role here and involving the workforce in identifying hazards and controls is a highly effective way of understanding what your significant issues are and getting the risk assessment right. The risk assessment allows you to see where you may need to provide appropriate information, instruction, and training to your employees.
Providing information and instructions can be straightforward – measures can be as simple as creating a booklet, briefing people, or a sign saying ‘To be used by trained operatives only’. Training, however is a more complex area.
With safety, we talk about competence, but just because you’ve trained someone in a specific area it doesn’t mean they will yet be competent. A newly qualified driver, for example, may have passed their test with flying colours, but may not be confident enough to drive on the motorway or had any experience driving in bad weather.
At the same time, you can have experience and be competent but not necessarily have all the knowledge required to manage safety successfully. This is where training, both new, refresher and progressive, comes in.
Training is a tool to give people the knowledge and / or practical experiences to become competent in their role and, support compliance, so consideration must be given to this area if you’re going to take that holistic view.
Ensure training courses meet requirements, are accessible and are delivered by an accredited provider for the best experience. There are many aspects of safety where regular training should be considered within a risk assessment, so ensuring up-to-date training is being provided is also key in the journey towards compliance.
Be careful though, training on its own doesn’t guarantee competence. For one, someone who faints at the sight of blood is obviously not best appropriate to become a first aider, no matter how much training you give. Similarly, levels of engagement during training are critical to ensure that obtained knowledge genuinely translates when put into practice.
Refresher training, while being useful for many, will be useless if those undergoing it aren’t taking in what they have learnt and fail to understand how to put it into practice, so think about how best to engage them and mix it up to keep it fresh for the most effective, and ultimately, the safest outcomes.
Here at CIEH, we provide comprehensive training across various elements of environmental health, including first aid at work, food safety and allergen awareness, HACCP, health and safety and manual handling. For support on how you and your team can ensure compliance, explore our training opportunities.