Crr 412/2002

HSE Health & Safety Executive

A survey of UK approaches to sharing good practice in health and safety risk management

Prepared by Risk Solutions for the Health and Safety Executive

CONTRACT RESEARCH REPORT 412/2002 HSE Health & Safety Executive

A survey of UK approaches to sharing good practice in health and safety risk management

E Baker Risk Solutions 1st floor, Central House 14 Upper Woburn Place London, WC1H 0JN United Kingdom

The concept of good practice is central to HSE’s approach to regulation of health and safety management. There must therefore be a common understanding of what good practice is and where it can be found. A survey was conducted to explore how industry actually identifies good practice in health and safety management, decides how to adopt it, and how this is communicated with others. The findings are based primarily on a segmentation of the survey results by organisation size, due to homogeneity of the returns along other axes of analysis. A key finding is that there is no common understanding of the term good practice or how this is distinguished from best practice. Regulatory interpretation of good practice is perceived to be inconsistent. Three models were identified: A) Large organisations, primarily in privatised industries, have effective Trade Associations where good practice is developed and guidance disseminated industry-wide. B) Large and medium-sized organisations in competitive industries have ineffective trade associations. They develop good practices in-house and may only share these with their competitors when forced to do so. C) Small organisations have little contact with their competitors. They look to the HSE to provide guidance on good practice in an accessible form. This report and the work it describes were funded by the Health and Safety Executive. Its contents, mcludmig any opimons and/or conclusions expressed, are those of the authors and do not necessarily reflect HSE policy.

First published 2002

ISBN 0 7176 2273 8

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without the prior written permission of the copyright owner.

ii CONTENTS

EXECUTIVE SUMMARY V 1 INTRODUCTION 1 1.1 Background to the Survey 1 1.2 Study Objectives 1 1.3 Design of the Questionnaire 2 1.4 Survey Sample 2 1.5 Structure of this Report 5 2 UNDERSTANDING OF GOOD PRACTICE 6 2.1 Is the concept of ‘good practice’ understood? 6 2.2 To what extent is good practice used in industry? 7 2.3 How is cost-benefit analysis used to determine what is good practice? 9 2.4 A Practical Test for Good Practice? 10 3 ROLE OF THE HSE 11 3.1 How is HSE’s role perceived in the formulation and dissemination of good practice? 11 3.2 Is HSE’s intervention sought and valued? 15 4 SAFETY DECISION MAKING 16 4.1 Who are the decision-makers who determine whether or not to adopt good practice? 16 4.2 Are there industrial sector leaders and followers in adoption of good practice? 18 5 MODELS OF GOOD PRACTICE SHARING 19 5.1 Model A – Pan-industry Forum with Endorsement by HSE 19 5.2 Model B – Emergent Practice from Work Experience and Collaboration 20 5.3 Model C – Reliance on Compliance 21 6 CONCLUSIONS AND RECOMMENDATIONS 23 6.1 Conclusions 23 6.2 Recommendations for the HSE 24 6.3 Recommendations for organisations seeking to adopt good practice 25 6.4 Recommended further research 25 APPENDIX 1: QUESTIONNAIRE 27 APPENDIX 2: NON-SEGMENTED RESPONSES TO QUESTIONS, SECTIONS 2-7 39 Questionnaire Section 2: Structure of the Organisation and responsibility for Health & Safety Management 39 Questionnaire Section 3: Tools/ Methods Used for Health & Safety Risk Assessment 41 Questionnaire Section 4: Sources of Good Practice 43 Questionnaire Section 5: Organisation’s Approach to Decision-Making with Regard to Health & Safety Management 46 Questionnaire Section 6: Recent Changes to Health & Safety Practices in the Organisation 48 Questionnaire Section 7: Organisation’s Expectations with respect to the Role of the HSE 49 APPENDIX 3: STUDY CONTRIBUTORS 50 Survey Respondents Whose Responses Were Included in the Analysis 50 Case Study Participants 53 Workshop Participants 53

iii

iv EXECUTIVE SUMMARY

The concept of good practice is a central tenet of the HSE’s approach to regulation of health and safety management. It is therefore important that there is a common understanding of what good practice is and where it can be found. The HSE commissioned Risk Solutions to explore how industry actually identifies good practice in health and safety management, decides how to adopt it, and how this is communicated with other organisations. A questionnaire was issued to 1,270 organisations predominantly in the transport, construction, chemical process, engineering/manufacturing and health services sectors. 278 replies were received and analysed. Following the survey we explored specific case studies in more detail with a number of the respondents. Finally the preliminary results were validated in a series of workshops. The survey returns were analysed to explore possible trends. The returns were homogeneous against many possible segmentations of the sample, with the exception of organisation size. Consequently our findings are based primarily on a segmentation of the survey results by organisation size.

MAIN SURVEY FINDINGS

The survey drew the following key conclusions: 1. The concept of good practice is not consistently understood by industry. 2. People report that they base decisions to change health and safety practices on the requirement to adopt good practice, although our findings show many other drivers are at least as important. 3. A minority of companies make use of cost-benefit analysis to determine what is good practice. 4. The HSE is seen as the most important formulator of, and the first port of call for the dissemination of, good practice. Small companies are most reliant on the HSE. 5. The HSE’s dual role as both advisor on good practice and regulator of whether approaches are appropriate may prevent companies proactively seeking advice from them. 6. Key health and safety decision-makers within companies differ according to the size of the company. 7. There are no real sector leaders who set the benchmark in health and safety practices for others to follow.

KEY RECOMMENDATIONS FOR THE HSE

A. The HSE should publish guidance on how good practice can be defined, sought out and identified. B. The HSE should ensure that its advice on good practice is clearly communicated to all those it wishes to reach. C. The HSE should ensure that guidance and approved codes of practice are published in a timely manner to coincide with changes in regulations. D. The HSE should improve training for its own inspectors to ensure consistency of approach in regulating against good practice requirements. E. The HSE should consider how best to reconcile its dual role as regulator and provider of independent advice on good health and safety practices.

v KEY RECOMMENDATIONS FOR ORGANISATIONS SEEKING TO ADOPT GOOD PRACTICE

We identified three models used by industry for sharing and disseminating authoritative good practice health and safety management. They depend on the size of the organisation and the level of competitive rivalry within its sector. Organisations should consider where they fit within the models to decide what actions they can take: Model A - Pan-industry forum with endorsement by HSE Organisation Characteristics S Typically large (e.g. former nationalised industries) S Strong and representative Trade Association or similar body. S Particular health and safety management topics are explored by the Trade Association, which then issues guidance to all its members. Potential Actions Organisations should aim to become more involved with their Trade Association, if they are not already. Model B - Emergent practice from work experience and collaboration Organisation Characteristics S Typically large and medium-sized companies S Industry highly competitive and good health and safety practices may be seen to give a competitive edge. S Sharing of good practices often not achieved voluntarily but may be forced through collaboration on projects. Potential Actions Organisations should lobby the HSE to help them develop a neutral forum for agreeing industry- wide good health and safety practices. Model C - Reliance on compliance Organisation Characteristics S Typically small companies S Limited or no contact with industrial competitors, and no strong trade or other association. S Strong reliance on compliance and hence on guidance from the regulator. Potential Actions Look for simple and easy to obtain advice from the HSE, for example through its web-site. Consider getting advice from larger client companies. RECOMMENDED FURTHER RESEARCH S A follow-up survey should be considered, in a year’s time, to identify any changes that have taken place as a result of the HSE following these recommendations. S HSE should consider commissioning a piece of research to specifically investigate the role of the supply chain in disseminating good health and safety practices.

1 INTRODUCTION

1.1 BACKGROUND TO THE SURVEY

‘Good practice’ plays a central role in the Health & Safety Executive’s (HSE’s) approach to risk regulation, and this has recently been explicitly articulated in the HSE publication ‘Reducing Risks, Protecting People’ (R2P2)1. HSE expects duty-holders, as a minimum, to apply relevant standards of authoritative good practice and then reduce remaining risk as low as reasonably practicable (ALARP). In order for this approach to be effective, HSE and its stakeholders need to share an understanding of what constitutes good practice. Due to the centrality of the good practice concept, HSE also wants to understand how its stakeholders identify, communicate, apply, monitor and evaluate good practice. HSE selected a survey of UK industry as a tool to help it understand these issues. Risk Solutions undertook to explore these issues for HSE, through a questionnaire-based survey, face-to-face case study discussions and workshops involving survey respondents. Following discussions with the HSE we concentrated on the following sectors: S Transport S Construction S Chemical process S Engineering / manufacturing S Health services S Education We also aimed to include both large organisations and SMEs in the survey.

1.2 STUDY OBJECTIVES

There were a number of study objectives outlined in the study brief. These were: 1. Establish whether or not the concept of good practice is understood by industry and how this is distinguished from best practice. 2. Establish to what extent good practice is used in industry (as opposed to other approaches such as first principle ALARP or ‘custom and practice’). 3. Identify how cost-benefit analysis or other criteria are used to determine what good practice is, and how this is used to distinguish between good and best practice. 4. Understand how industry perceives HSE’s role in the formulation and dissemination of good practice, e.g. whether HSE’s intervention is sought, whether HSE’s intervention is valued, and what is the understanding of HSE’s role (as set out in R2P2), 5. Identify cases or examples where good practice has been adopted and implemented. 6. Identify the decision-makers within organisations who determine whether or not to adopt good practice.

1 New edition, published 13th December 2001, available from HSE Books, ISBN 0-7176-2151-0.

7. Determine whether or not there are industrial sector leaders (who introduce or develop good practice) and followers (who adopt the leader’s practice).. 8. Establish how good practice, with respect to health and safety management, is identified, shared and adopted in different industrial sectors, and how this is kept under review 9. Develop a generic model for identifying, monitoring, evaluating and communicating good practice. The primary purpose of the study is to provide the HSE with an informed picture of the variability in approach both within and across industrial sectors. HSE hopes to use the findings either to spur the production of further guidance to industry or perhaps to inform a need for HSE to change its own approach.

1.3 DESIGN OF THE QUESTIONNAIRE

A copy of the questionnaire is presented in Appendix 1. The questionnaire was designed to directly test a number of the issues the HSE are interested in. In addition we asked a range of questions designed to help us segment the sample to allow us to analyse and test a number of potential theories and models of how good practice is used in the real world. In analysing the responses we discovered considerable homogeneity of Appendix 2.response, and for this reason we have not reported against a number of the potential segmenting questions in the main body of the report. A full breakdown of the answers given is provided in Appendix 2.

1.4 SURVEY SAMPLE

The purpose of the survey was not to provide a statistically representative sample of all companies in the UK, but to ensure that the sample of responses contained a selection of companies from each of the targeted sectors as well as a range of company sizes. In this way we hoped to identify the range of different approaches across and within industrial sectors and organisation structures. 1270 questionnaires were issued. Companies were targeted as follows: S A selection of companies from the FTSE 100 and FTSE 250 within the target industrial sectors. S A sample of companies in the target sectors obtained through the Chambers of Commerce. S A selection of organisations in the health, engineering and education sectors identified through Yellow Pages from various sources around the country. All the organisations to whom questionnaires were sent were prequalified with a phone call to ensure the questionnaire was addressed to the appropriate individual with responsibility for health & safety. 278 questionnaires were returned by the cut-off date for receipt (22% response rate), and the sample breakdown in terms of company size, age and sector is illustrated in the figures below.

The five sectors of particular interest made up 74% of the sample. The actual numbers of responses in each of those sectorsOil&Gas were: Transport1% 26 Health Services Pharmaceuticals 4% 3% Telecoms Education Engineering/ 2% 3% manufacturing Transport Media 23% 9% 1% Printing 4% Publishing 1% Retail 3% Other 20% Support services 1% Ut ilit ies Textiles 4% 1% Waste Management 1% Other Chemical Process 4% 5% Construction 32%

Figure 1: Sector Breakdown of 278 Questionnaire Responses

Construction 88 Chemical Process 15 Engineering/ manufacturing 65 Health services 12

90 Size cut-off for Medium 80 Size cut-off 77 73 for Small 70

27 30 24 21 21 20

Number of Responses of Number 14 11 10 10

0 Question <£2m £2m- £4.4m- £10m- £24.6m- £100m- £500m- >£1,000m not £4.3m £10m £24.5m £100m £500m £1,000m answered Turnover

Figure 2: Size of Company by Turnover

We have based our assessment of whether a company is small, medium or large on the EU definitions2. However these are based on a combination of three criteria: employees, turnover and balance sheet. During our piloting of the questionnaire we discovered that respondents found it difficult to answer a question about their company’s balance sheet, so we have had to use only the turnover and employees to define company size. Figure 2 shows the breakdown of the sample according to company turnover. By this criterion we have 21 small companies, 94 medium companies and 142 large companies. 21 respondents did not answer this question.

140 Size cut-off for Medium Figure 3 shows the size breakdown 117 of companies according to number 120 Size cut-off for Small of employees. Here again 21 100 companies are classified as small,

80 129 as medium with 122 classified as large. Six respondents did not 56 60 answer this question. Responses 42 40 24 20 10 12 6 8 3 0 Question 1-10 11-25 26-49 50-100 101-249 250-1,000 1,001- >10,000 not 10,000 answered No. of Employees

Figure 3: Size of Company by No. of Employees

100 90 86 Figure 4 illustrates the range of 81 80 company structures within the 70 questionnaire responses. Although 60 53 the majority of the sample were 50 40 either full Plcs, or companies

30 21 limited by share or guarantee, the 20 11 10 full range of potential organisation

Number of Responses of Number 8 10 5 3 structures was contained within the 0 ) s jv e d y) er ed / re e c sample. 21 respondents did not e c (AIM ha ante rad r limit gen t Plc (full) y s n a e nswer llian Plc b U / a a t sol t f d / o Lt answer this question. n no t ar P Ltd by gua ership Govt (dep uestio rtn Q Pa Company Structure

Figure 4: Sample Breakdown by Company Structure

2 Small companies have up to 49 employees and up to 7 million euro (£4.3 million) turnover. Medium companies have between 50 and 249 employees and up to 40 million euro (£24.3 million) turnover.

100 98 Figure 5 shows that there was a

90 comprehensive spread of ages

80 amongst the companies in the 70 sample. A relatively large proportion 60 of organisations, 35%, were formed 50 45 41 before 1946. There were also 16 40 31 organisations formed within the last 30 20 five years. 9 people did not respond 20 18 16 Number of Responses of Number to this question. 9 10

0 Question Pre 1946 1946-1955 1956-1965 1966-1975 1976-1985 1986-1995 Since 1996 not answered Year Organisation Founded

Figure 5: Sample Breakdown by Year of Foundation

Figures 1-5 show the distribution of organisations by industrial sector, size and year of formation. We believe that the figures demonstrate that the 278 organisations that form our sample represent a broad range of industrial sectors and variety of environments. Consequently we are confident that the findings from our work capture the full range of approaches to managing health and safety in the workplace.

1.5 STRUCTURE OF THIS REPORT

The rest of this report is divided into five main sections: Section 2: Understanding of Good Practice. This deals with how the concept of good practice is understood and used by industry to inform health & safety risk management decisions. It also includes some discussion of other tools, the way decisions are made and who makes them. The findings presented in this section relate to study objectives 1, 2 and 3. Section 3: Role of the HSE. This deals with how HSE’s role is viewed by industry and whether more guidance or regulation is sought. The findings presented here relate to study objective 4. Section 4: Safety Decision Making. This section presents the survey findings on who makes decisions on health and safety management policy and practice, and relates to study objectives 6 and 7. Section 5: Models of Good Practice Sharing. This section outlines the three models that appear to exist within industry, and includes some discussion of how HSE could support these existing activities to make them more effective. This section relates to study objectives 8 and 9. Section 6: Conclusions. This section covers our conclusions and recommendations. Findings related to study objective 5, identification of case study examples, are presented in sections 2 and 5.

2 UNDERSTANDING OF GOOD PRACTICE

2.1 IS THE CONCEPT OF ‘GOOD PRACTICE’ UNDERSTOOD?

The questionnaire posed an open question: “How would you define good practice as used in health and safety management”. We received 205 answers to the question, implying that 73 respondents (a quarter of the sample) were unable to provide a definition. Of those that did respond a selection of their answers is provided below: “Being practical.” “What a reasonable employer would adopt” “The provisions of any code of practice or practice which is reasonable in all circumstances” “A pragmatic, practical approach to risk reduction” “Clearly defined guidelines and instructions” “Compliance with legal requirements” “Having a system and procedures in place that meet legislative requirements and benefit all staff” “That which reduces accidents” “An approach that gives equal weight to procedural and cultural (behavioural) factors” “The way to do something” “Following the relevant ACOP or common sense” “Above and beyond the legal requirements” “Fit for purpose” “Carry out a safe working process where it is reasonably practicable” “Following minimum/ less than minimum requirements”

Whilst there are certain themes that permeate the responses, there is certainly no definitive or consistently held definition. 38 of the responses (14%) indicated that good practice to them means complying with legislation and regulation and following ACOPs. A number made reference to exceeding legislative standards. Several made reference to industry standards or to exceeding industry norms. A few referred to the ALARP principle. While there may be some organisations that come close, in their interpretation, to the meaning implied by HSE, it appears from this sample that the concept of good practice may not be a particularly useful one in terms of guiding behaviour. During our two workshops we also explored what the participants understood by the term ‘good practice’. This provoked considerable discussion at both workshops. Concern was expressed over whether ‘good practice’ was a way for HSE to ratchet up safety standards without recourse to providing regulation, or “legislation by the back door”, particularly if

good practice is seen to embody a higher level of safety than the minimum required under existing regulations. Participants also noted that interpretation by HSE inspectors has often been inconsistent with regard to good practice. This makes decision-making, on the basis of a subjective definition of good practice, extremely difficult. Many of the workshop participants failed to recognise any distinction between good and best practice, which accorded with the findings of the survey where only 27% of respondents claimed to distinguish between the two. The end result of these discussions was that participants supported our first conclusion:

Conclusion 1: The concept of Good Practice is not well understood by industry

2.2 TO WHAT EXTENT IS GOOD PRACTICE USED IN INDUSTRY?

Despite our conclusion that the concept of good practice is not well understood, many of the respondents in the survey considered that they were changing their health and safety practices on the basis of good practice, as well as for a number of other reasons. 85% of respondents agreed that the HSE had made the role of good practice clear – they know that good practice is supposed to underpin what they do, even when they disagree on what good practice actually is. Three-quarters of the sample claimed that adoption of good practice was one of the drivers for a change to their health and safety practices during the last five years.

250 208 200 160 160 150 133 122

100 88 85 82 48 50 32 27 20

Number of Companies of Number 0

e t n s e r g w n ity rt i .. c e ce tice n e v o tio . i h n c a vie d ti p s lys s v t e a h e i c e a r d O t r r cc a g n l a is P c a it re g a o a s d ry isk / w d d n g o r t e u su n tio e r in o to c n N A e a L G la i e e i e u d d y tre c m g o ci lo so to e ri n p rd s s R e co a u p m C n fic i E re e ci d w e ty O p fe tra S a S m fro s n tio a d n e m m Drivers for Change co e R

Figure 6: Drivers for Recent Change in Health and Safety Management Practice Cited by Survey Respondents

Figure 6 shows the reasons cited by respondents to the survey for implementing a recent change in health and safety practice. Good practice is the most commonly cited reason, but the answers to this question may well be skewed by the survey’s own focus on good practice. In the face-to-face interviews we found it much more difficult to pin down specific examples where the main reason for a change was to adopt a good practice identified from elsewhere. In many of the cases, changes were driven by regulatory change, or by anticipation of regulatory change (“to keep a step ahead of the competition”, or “we’re going to have to implement this next year anyway”).

Box 1: Three Case Study Examples

Behavioural Based Feedback System One construction company was made to use this behavioural observation system by the project manager on a major infrastructure project and later decided to adopt it as good practice. The system is voluntary, and requires one person in a team of, for example, scaffolders, to spend an hour observing their colleagues performing their everyday tasks. The observer notes down any behaviours they spot that have the potential to be dangerous, and after the hour is over they immediately feed back their findings to their colleagues. The system works through the fact that co-workers rather than supervisors are involved in the observation, and staff are able to visualise what might have happened to them.

Improved Manual Handling Training Following the introduction of new manual handling legislation, a small manufacturing company looked to a larger local company in a different sector to help it with training. Staff were trained in risk assessment techniques, and then applied these techniques within their own company. The manufacturing company was able to modify the shop floor to introduce conveyor belts drawing supplies of raw materials from silos rather than lifting heavy bags, and to train staff on the correct manual handling techniques using videos.

Reduced Chlorine Storage A water company reviewed its practice of storing large quantities of chlorine on site and decided to stop storing it. Chlorine is now delivered in smaller quantities as and when it is required. The reasons for the change were firstly to reduce the risk of accidents and potential harm to the local area, which included homes and schools, and secondly to reduce their requirements to conform with stringent and costly COSHH regulations.

Other key spurs for companies were their own regular risk review or trend analysis and specific incidents or accidents that pointed to inadequate controls. Respondents were able to tick as many or as few of the options as they wished. 20 respondents ticked ‘Customer insistence’ and over half of these were in the Construction industry. We were surprised to see that so few of the respondents to our survey appeared to be driven by their customers to adopt good practice. At one of the workshops this issue was discussed specifically, and it was suggested that approaching the topic from the opposite direction, through asking companies whether they require their suppliers to adopt certain health and safety practices, may show a different picture. We consider that this may be an area worthy of exploration by a future research project. During the two workshops we explored the use of good practice as a driver for change in more detail. We uncovered several examples where the desire to identify and adopt good practice did appear to be the main driver for a change in practice (Box 1). However, the companies involved were without exception larger companies, with good links to others

within their own industry with whom they could share ideas. This finding reinforces our conclusions with regard to models for good practice sharing, described in Section 4. From the survey we found that only half of companies claimed to understand and rigorously use the ALARP principle, with only a third of small companies claiming to do this. This must be of concern to the HSE, as ALARP is the fundamental cornerstone of its entire approach to health and safety decision-making. HSE considers that after a company has adopted good practice it must then seek to ensure any remaining risks are reduced ALARP. Companies that are adopting good practice may not understand that this is not necessarily sufficient to demonstrate that they have met the HSE’s expectations in terms of reducing risks to their workforce. HSE therefore needs to make this aspect much clearer. From the survey findings and our discussions with health and safety practitioners in face-to- face interviews and in workshops we identified an enthusiastic aspiration amongst these professional to adopt good practices. However the lack of a consistent understanding of what actually constitutes good practice lead us to our second conclusion:

Conclusion 2: People report that they base decisions to change health and safety practices on the requirement to adopt good practice, but given the inconsistency in interpretation of the term itself, we doubt that it is currently a useful driver of behavioural change.

2.3 HOW IS COST-BENEFIT ANALYSIS USED TO DETERMINE WHAT IS GOOD PRACTICE?

The questionnaire directly asked respondents whether they use cost-benefit analysis (CBA) to decide whether a proposed change to health and safety practices would be good practice. Only 44% of respondents claimed to do so, and only 9% of companies stated that they use a threshold for deciding whether a health and safety practice is too expensive. The HSE considers that the use of good practice relieves the duty-holder of the need to explicitly weigh costs against benefits to reach a decision. This finding therefore accords with HSE’s aspiration for the use of CBA in health and safety decision making. Nine out of ten respondents said they use their own criteria for determining whether something is good practice for their organisation. We explored this issue in more depth at the workshops, to understand what people mean by their own criteria. Individuals cited “gut feel”, “cultural fit” and “whether something fitted with wider business objectives” as criteria they would consider when reviewing a change in health and safety practices, as well as whether regulation mandated a change. Formal CBA may only be used for major capital investment decisions, or where practitioners need more detailed support for a concept to persuade senior management to adopt it. Workshop delegates also commented that mandatory regulations did not always appear to meet cost-benefit criteria themselves, being disproportionately expensive and not necessarily

dealing with the highest priority issues in terms of greatest risk to the workforce or the general public. During the survey one in seven respondents stated that despite having identified something as a good practice for their business it would not always be implemented. Although the survey did not explore the reasons for this, workshop delegates speculated that this might be true if budgets were simply too limited, or where support for changing practices was not obtained either from senior management or from staff who may resist changes in working practices.

Conclusion 3: A minority of companies make use of cost-benefit analysis, but certainly not for every decision over a change in practice. Explicit thresholds are seldom used but they are implicit in ‘gut feel’ decisions.

2.4 A PRACTICAL TEST FOR GOOD PRACTICE?

During the course of our work we were able to develop a practical tool or checklist that could help others in deciding how to identify and adopt good practice. This is presented for information in Box 2.

Box 2: A Practical Interpretation of Good Practice

A simple checklist to help companies to identify good practices could be:

1. Is there already authoritative guidance on this issue? Guidance can be that provided by HSE or by another authoritative body. If there is authoritative, up-to-date guidance then this should embody good practice.

2. If not, what do other people do/ what approaches are out there? Need to look outside the organisation to understand the options available.

3. Is it appropriate? Would any of those approaches be technically feasible for the organisation to adopt?

4. Can we apply it? Does the organisation have the capability to apply the approach themselves?

5. Will it work for us? Would it fit into the existing organisational culture – would people be prepared to adopt it?

3 ROLE OF THE HSE

One of the objectives of this study was to gain some understanding of how HSE’s role is perceived by industry. A series of questions was asked in Section 7 of the questionnaire directly exploring the role of HSE. In addition there were other parts of the questionnaire that touched on the role of the HSE more indirectly.

3.1 HOW IS HSE’S ROLE PERCEIVED IN THE FORMULATION AND DISSEMINATION OF GOOD PRACTICE?

The survey directly asked respondents whether HSE should play an important role in formulating good practice, and also whether the HSE does play that role.

0% 20% 40% 60% 80% 100%

HSE should play an important role in formulating good practice

HSE does play an important role in Strongly Agree formulating good practice Agree Disagree HSE should play an important role in making sure good practice is shared Strongly Disagree

HSE does play an important role in making sure good practice is shared

Figure 7: Survey Responses on Role of the HSE

Respondents agreed strongly that HSE should play an important role in both formulating and disseminating good practice. However they did not agree as strongly that HSE was adequately fulfilling this role. HSE needs to consider how it can improve this aspect of its own performance. The survey asked organisations what sources of information they looked to for communicating and disseminating good practice. A wide variety of possible sources was provided, together with the opportunity to add those not included on the list, and respondents were able to tick as many or as few as they wished. Figure 8 illustrates the range of responses to this question. The figure shows clearly that the UK regulatory bodies, which for most respondents means the HSE, are viewed as the primary source for the communication and dissemination of good practice, with 95% of respondents citing them. Interestingly in-house management and employees are the second most commonly cited source of good practice information, followed by trade associations, trade journals and conferences. The many sources cited indicate that there are companies out there that are casting their nets very widely in seeking out good practice. During our workshop discussions it was noted that several of the organisations that responded to our survey are regulated primarily by local authorities. There was some discussion of the differences between the way local authority inspectors and those from the

HSE interpret regulations, and it was suggested that consistency would be improved if HSE provided training for local authority inspectors to ensure consistency of approach between the different inspection bodies. We have looked in more detail at the sources used by different types of companies. We segmented the sample in terms of company size and by industrial sector. Figures 9 and 10 illustrate the differences within the sample according to these segmentations.

100 90 80 70 60 50 40 30 20

% Companies Citing Source Citing Companies % 10 0 ) t l r I E n es ls ns es rs rs ia rs rs ns a e rs K B ce rs S e e na io c lie o d e to o b th e U C r to H m y r t n p is e m di ni lo O y s e c ( e lo u ia re p dv M to u U G w ie m re s ag p Jo c fe u a s A s La tr m i ie n m so n S l u e ie s o D d a E de s o a /C ad tr du C of o M a A C eg ts r s n of B r e L n T u r I te ry se T d e d e rs tu o u ra li In h e ti t o T C r t b s la H he O m In gu In t ha e O C R K U

Figure 8: Range of Sources Cited as Communicating and Disseminating Good Practice

Figure 9 shows the differences between organisations according to size. The responses have been ordered according to those given by the large companies. The fact that the lines denoting responses from medium and small companies are below the one for large companies indicates that on average each medium and small company uses fewer sources of information, with small companies relying on the fewest sources. For all sizes of company, UK regulatory bodies, particularly HSE, are the primary source of information. Medium companies are more reliant on trade associations and less reliant of their own in-house expertise than are large companies. Small companies rely more on trade journals, rather than trade associations. This may be a matter of resources, or it may be that they are specialist companies in fields for which there is no trade association but for which trade journals do exist.

100 90 80 70 60 Large 50 Medium 40 Small 30 20 10 0 l ) s s s a a s rs I E r di B S ent iers sors er ob on C H i l e s UK ye erce ppl v om dito G M e w Other m ployee u ad s Uni irectors ferencesS st Au e stri La m ies ( al ie d u D Em g a Con e ustr Tr of Co Trade Journals L nts/Cu r Ind te of nd e e I tu Trade Associations Cli r bers Oth nsti gulatory Bod the I e In House Managem O Cham UK R

Figure 9: Sources Cited by Companies Segmented According to Company Size

Figure 10 indicates which sources of information the five industrial sectors targeted by HSE use. The order of the sources has been fixed according to those used by the construction industry, as the largest sector represented in the sample. Again all industries rely on the HSE as a primary source.

100

60 Construction Engineering 50 Health Services Transport 40 Chemical Process

) ls s s s s e r a nt r r r ns BI rs c SE e ie e o C so r rn pl nces it o m ni e the (H u m p e Global Media m O e r ud U irectors Jo ociations Su e A Lawyersm ies s de o D Employee a C f od As r o B Manag Conf T Legal advi Trade te se itu ou Clients/Custo atory Trade Other Industriesst UK ul H In n hambers of eg I Other Industries C R K U

Figure 10: Sources Cited by Companies Segmented According to Industrial Sector

There are clearly differences between the sectors. The construction industry relies on in-house management, employees, trade associations, trade journals and conferences as its most commonly cited sources, as does the engineering sector, albeit in a slightly different order or priority, with employees less often cited than in-house management or trade associations. Health services hardly use trade associations at all, and are more likely to cite in-house management, trade journals, the media and trade unions. The transport sector also hardly uses trade associations, and is more likely to rely on in-house management, conferences, clients/ customers and auditors to provide information on good practice. The chemical process industry most commonly uses trade journals, followed by trade associations, in-house management and suppliers to provide them with information. The different emphasis put on different information sources by these different industrial sectors points to the need to target communication channels for disseminating good practice to those sectors. In all cases, however, the HSE or other UK regulatory bodies are seen as the primary information source.

100

e e n s s e n e s r c c o d d c o c d e n ti ti r r n ti n r th a c la a a a la a a O id a u d d id u id d u r g n n u g u n P e ta ta e ta G f /r S S G /r G S E o n y n n nt l s o k tr io o e a S e ti U s t ti n H d la u ra la tm io o s d e s r t C i n i a a g I d g p rn d le e le e e e F D t v ve e ve t In ro ti d ti n p p a p e p i r ri cr T c m A s s rn re re ve p l p o K a G n U o K ti U a r rn he te t In O Figure 11: Forms of Information Used to Help in Developing Good Practice

Figure 11 shows the various forms of information used by organisations in developing good practice. Again respondents were provided with a range of possible options and were invited to tick as many or as few as they wished. HSE guidance is again cited as the primary source of information. Segmenting the sample according to organisation size again showed small organisations typically relying on far fewer forms of information, being almost entirely reliant on HSE guidance, ACOPs and prescriptive legislation.

Conclusion 4: The HSE is seen as important formulator of, and the first port of call for the dissemination of, good practice. Small companies are most reliant on the HSE.

3.2 IS HSE’S INTERVENTION SOUGHT AND VALUED?

Again there were specific questions dealing with how well the HSE is viewed at regulating and providing guidance to industry. Figure 12 shows that the majority of respondents consider that HSE provides adequate guidelines, although almost 40% would actually like to see more regulation of their industry.

0% 20% 40% 60% 80% 100%

HSE provides adequate guidelines on how to interpret regulations Strongly Agree Agree Disagree HSE does not do Strongly Disagree enough to regulate health & safety in our industry

Figure 12: Survey Responses on the Role of HSE During the workshops delegates noted that the guidance and ACOPs produced by the HSE are very good and are welcomed when they are published. However they also referred to the timelag between the introduction of legislation or regulation and the production of the complementary guidance, which can be up to two years. They would therefore like to see more timely publication of HSE guidance to help them with implementing legislative changes. In addition to this, delegates were keen to discuss their experiences of inspection and the inconsistencies in attitude and approach of different inspectors. The point was made that many companies, particularly smaller ones, would be loath to approach the HSE for advice or guidance for fear of generating an unwanted inspection. The dual role of HSE as both provider of independent advice and policeman is seen as creating tension, reducing HSE’s ability to help companies understand how they can improve their practices. Further evidence for this was derived through the case study interviews, where interviewees from smaller companies commented that they were only inspected once an incident had occurred, but had they received advice earlier then the incident might have been prevented. The limited resources of the HSE are clearly an issue here.

Conclusion 5: The HSE’s role as both advisor and regulator is seen as a barrier to companies in proactively seeking help from the HSE. Limited HSE resources may constrain the value of inspections.

4 SAFETY DECISION MAKING

4.1 WHO ARE THE DECISION-MAKERS WHO DETERMINE WHETHER OR NOT TO ADOPT GOOD PRACTICE?

The questionnaire asked respondents to state who in their organisation is responsible for setting health and safety policy, for implementing that policy and for deciding what constitutes good practice for them. The field was left blank to enable all possible titles to be used. During analysis we then grouped the responses between the most senior management (Board, Director or Group 100 level), middle 90 management (Senior or 80 70 specialist HSE managers) 60 and others (which covered Large 50 responses such as ‘all 40 Medium 30 Small employees’, ‘line 20 management’ and 10 ‘external consultants’). 0 Board/ Director/ Senior/ HSE Other The findings are Group Management illustrated in figures 13- 16. Again we did not find any significant differences Figure 13: Responsibility for Setting H&S Policy in approach when we analysed the results by industrial sector. Figure 13 shows that the smaller the company the more likely it is that health and safety policy will be set at the most senior level. Perhaps surprisingly, only half of all large companies set health and safety policy at the most 100 senior level. Discussions at 90 the workshops indicated 80 that this picture may be a 70 shifting one – delegates felt 60 50 Large that these responsibilities 40 Medium were now more likely to be 30 Small assumed at Board level 20 than they have been in the 10 past. The drivers cited for 0 Board/ Director/ Senior/ HSE Other this were increasing Group Management awareness of the implications of corporate governance requirements Figure 14: Responsibility for Translating Policy into and the potential for facing Practice corporate manslaughter charges. However the point was also made that even when a policy is endorsed by the Board it is likely to have been developed by a less senior health and safety professional. Very large companies usually have teams of people devoted to health and safety matters. By contrast,

small companies are unlikely to have dedicated health and safety staff, and the responsibility for setting policy is much more likely to be held by the managing director or another director within the company. Figure 14 shows that once it comes to implementation, the Board is even less likely to be involved in larger companies. In small companies, implementation is still often the responsibility of the top team, perhaps because the organisation is so small there simply is no- one else to do the job. Clearly where the top people are involved in key decisions and in the day-to-day running of the business there will be limited resources in terms of time and effort to devote specifically to health and safety issues.

Figure 15 shows that decisions about what 100 90 constitutes good practice 80 are slightly more likely to be 70 made at Board level than 60 are other implementation 50 Large issues. Again in small 40 Medium companies decision-making 30 Small 20 is heavily loaded on the top 10 team, whereas in large and 0 medium-sized companies Board/ Director/ Senior/ HSE Other Group Management middle managers assume responsibility for this aspect, as the professional staff with Figure 15: Responsibility for Deciding What Constitutes Good Practice the expertise in the area. The implications of these figures are that where HSE seeks to get key messages about health and safety to the decision- makers within companies, it will need to target these messages to the people who are actually involved in making the decisions. In large and medium companies this often means the health and safety practitioner, but in small companies it may mean the most senior staff, already overloaded with the day-to-day running of their business.

Conclusion 6: Key health and safety decision-makers within companies differ according to the size of the company. In large companies decisions may be delegated down, while small companies are heavily dependent on the top team or individual.

4.2 ARE THERE INDUSTRIAL SECTOR LEADERS AND FOLLOWERS IN ADOPTION OF GOOD PRACTICE?

We asked respondents to the questionnaire whether their own company set the benchmark for health and safety practice in their industry, and if not whether they could tell us who did. A surprisingly high proportion of respondents, 42%, claimed to set the benchmark themselves. Only 10% of the sample gave the name of another company or organisation as the setter of the health and safety benchmark for their sector. Of those cited, only Dupont and BP were names given by more than one organisation. Several of the benchmark-setters cited were trade associations. Despite their confidence, none of the organisations who considered they set the benchmark themselves were named by any other survey respondent. Discussions in the workshops confirmed that there is no single company within a sector that is typically seen to set the benchmark. Well-connected practitioners often know which company in their sector is good at a particular aspect of health and safety risk management, but it was generally agreed that sector leaders as such do not really exist.

Conclusion 7: There are no real sector leaders who set the benchmark in health and safety practices for others to follow. This is therefore not a practical route to disseminating new thinking in health and safety good practice.

5 MODELS OF GOOD PRACTICE SHARING

Through our case study interviews with 12 organisations (listed in Appendix 3) we developed an initial view on the way in which organisations in the real world are able to identify, share and adopt good practice. We took our initial ideas to the two workshops that were held for survey respondents to test them against the delegates’ understanding of how these processes worked. Through this iterative approach we have developed three generic pictures of the ways that organisations are able to seek out and develop good practice. From the questionnaire we identified that company size was important in determining the ability of companies to look further afield for good practice. We also discovered during our interviews that industry structure is also a key to the way in which good practice evolves and is shared. In the three sections below we describe the three generic models, together with illustrative examples for each one. The value in these models will come from helping the HSE to understand where it can best target its limited resources to support the development and sharing of good practice in those industries and for those companies that do not currently have well-developed networks of their own.

5.1 MODEL A – PAN-INDUSTRY FORUM WITH ENDORSEMENT BY HSE

Model A primarily applies to large companies with well-developed and well-supported Trade Associations although other pan-industry fora may also work well. The key attributes of this model are: Most of the industry, often a relatively small number of large players, belongs to the association. Ideas can be taken forward and championed by individual organisations on behalf of the association. Members understand that they only get out as much as they put in – these associations are only effective with an active membership who drive them forward, and must remain dynamic to avoid becoming dinosaurs. Once the association has developed guidance in a particular area it is issued to the whole industry, and receives endorsement in some form from the HSE. Trade associations with the characteristics described above typically exist within privatised industries, such as the utilities, where the former nationalised companies have been split up but still retain strong links via the association. Other industries with strong trade associations include the chemical and retail industries. Case study examples of good practices that have been identified and shared in this way are: Example A1: Working at Height in the Electricity Industry The electricity industry identified a particular need to develop a safe way to work at height, appropriate for working on transmission towers. One organisation led an initiative to review what other people did, looking both within the UK and abroad, and even reviewing how circuses operated. They evaluated how appropriate the various approaches were for the industry and how feasible they were to apply, both technically and culturally. The findings were published by the trade association as guidance.

Example A2: Rollover Sheeting for Heavy Goods Vehicles A member of the road haulage industry identified a risk to drivers when manually covering heavy goods vehicles with sheeting, following an accident. The initiative to find a good practice solution was led by the company, who worked together with the Freight Transport Association, the Road Haulage Association and eventually with the HSE National Interest Group (NIG) to bring the rest of the industry to discuss the issue. The example of the quarry industry, which was already addressing the issue and converting its vehicles to ‘easy-sheeted’ vehicles, was used. A way forward was identified and agreed collectively and guidance issued throughout the industry, allowing an eighteen month period for the industry to move over to the safer vehicles. Example A3: Safety Passport in the Food Industry Members of the food industry, not normally part of an active trade association, were brought together by one of the members to develop a system to ensure subcontractors within the industry were competent to work safely. The initiative, a ‘safety passport’ recognised by all the large players in the industry, will be launched in November 2001 with the endorsement of the HSE.

5.2 MODEL B – EMERGENT PRACTICE FROM WORK EXPERIENCE AND COLLABORATION

Model B primarily applies to large and medium-sized companies within highly competitive industries where there is no single, widely-recognised and supported forum. The key attributes of this model are: Good health and safety practices may be seen to give a competitive edge, so benchmarking and other information is not voluntarily shared. Good practices are developed ‘in-house’ or emerge from work experience. Sharing of health and safety practices with others may be forced through collaboration on projects (e.g. major construction projects) and this can lead to adoption of good practices developed elsewhere. Examples of such industries are the construction industry and the food manufacturing industry. Case study examples of good practices that have been developed and shared in this way are: Example B1: Reduction in Storage Height of Boxes at Warehouse A member of the retail industry identified a risk at one of its warehouses where large containers were being stored three high and were liable to be dislodged by high winds. After reviewing the available space and the rest of the warehousing practices within the group it was decided to limit the height of stacks to two high. This is now regarded within the group as good practice, however there is no knowledge outside the company of whether other retailers face the same risks or whether there are other ways they could have controlled the risks.

Example B2: Reduction of Workplace Noise Levels A medium-sized member of the pharmaceuticals industry identified that its workforce was exposed to a level of noise within the limits of health and safety regulation but that caused the workforce a level of discomfort. After a review of options the machinery generating the noise was modified, reducing noise levels from 80dB to 74dB. These limits are lower than required by existing regulation, so this modification should properly be described as ‘best’ practice, although the company in question considered it good practice. This highlights once again the lack of distinction made by companies between the terms ‘good’ and ‘best’ practice. This approach has not, to date, been shared with other members of the industry. Example B3: Thermal Comfort Standards in the Chilled Food Industry A member of the chilled food industry recently introduced warm clothing for employees working in low temperature conditions. The regulations on this matter are currently considered by the company to be unclear, and they did not feel that HSE has provided any real guidance on what is required of an employer. The company therefore took it upon itself to decide that it would be good practice to provide the clothing. Other members of the industry take a different view. A key feature of this model is that good practice is being developed, often in isolation, by large number of companies. Trust and fora for sharing these practices are difficult to achieve. The HSE may have a role here in facilitating the types of fora necessary for Model A to operate in those industries that are currently reliant on Model B.

5.3 MODEL C – RELIANCE ON COMPLIANCE

Model C primarily applies to smaller companies. The key attributes of this model are: Limited or no contact with industrial competitors No strong trade or other association Limited resources for own research and development Strong reliance on compliance and hence on guidance from the regulator Authoritative guidance sought from HSE Examples of industries where this model is the norm is in engineering, particularly the numerous small workshops typical of the industry, and at the small company end of the construction industry, where health and safety practices may be driven by the major contractor for subcontractors, but much day-to-day work is on small jobs.

Case study examples of good practices adopted via this path are: Example C1: Working at Height Procedure in the Construction Industry Following a serious incident a member of the construction industry totally revised its working at height procedures. The new procedures were taken from construction industry guidance provided by the HSE. Example C2: Manual Handling Manual handling guidance and training is obtained by many small companies via videos and literature made available by the HSE.

Conclusion 8: Three generic models for the identification, sharing and adoption of good practice have been developed. These hold challenges for HSE in facilitating the sharing and adoption of good practice, particularly for those small companies that are so heavily reliant on its guidance.

6 CONCLUSIONS AND RECOMMENDATIONS

6.1 CONCLUSIONS

The key conclusions of this research are: 1. The concept of good practice is not well understood by industry, and this should be of concern to HSE in view of the increased emphasis on good practice within R2P2. 2. People report that they base decisions to change health and safety practices on the requirement to adopt good practice, but given the inconsistency in interpretation of the term itself, we doubt that it is currently a useful driver of behavioural change. 3. A minority of companies make use of cost-benefit analysis to determine what is good practice, but certainly not for every decision over a change in health and safety practice. Explicit thresholds are seldom used but may be implicit in ‘gut feel’ decisions 4. The HSE is seen as the most important formulator of, and the first port of call for the dissemination of, good practice. Small companies are most reliant on the HSE. 5. The HSE’s dual role as both advisor on good practice and regulator of whether approaches are appropriate is seen as a barrier to companies in proactively seeking help from the HSE on this issue. Limited HSE resources may constrain the value of inspections. 6. Key health and safety decision-makers within companies differ according to the size of the company. In large companies decisions may be delegated down, while small companies are heavily dependent on the top team or individual. 7. There are no real sector leaders who set the benchmark in health and safety practices for others to follow. This is therefore not a practical route to disseminating new thinking in health and safety good practice. 8. Three generic models for the identification, sharing and adoption of good practice have been developed. These hold differing challenges for the HSE in facilitating the sharing and adoption of good practice, particularly for those small companies that are so heavily reliant on its guidance. HSE views good practice as the first port of call’ for companies. Where something is established as good practice, a company should adopt it as a matter of course, and only then is there a need to go on and review whether risks have thereby been reduced ALARP. In effect, good practice is a valuable short cut which avoids the need for companies to make a detailed evaluation of different health and safety practices. However for companies to find such a shortcut of value, they need to understand whether a particular practice can genuinely be considered as good practice or not, without spending a great deal of time and effort in the process. Given the conclusions outlined above, we consider that the HSE needs to carefully review the way it has presented the concept of good practice. Clarifying the definition of good practice would greatly help those practitioners in industry who are genuinely attempting to follow HSE guidance and advice in order to improve the safety of their working practices. There is real confusion between compliance with legislation and regulation, use of ACOPs,

good and best practice. Most practitioners do not distinguish between the terms good and best practice, yet it appears to us that HSE views these concepts as fundamentally different. Without clarification and improved guidance in this area from HSE, practitioners are unable to evaluate whether what they are doing is appropriate and is ‘good practice’. From discussions with a number of companies we received the impression that HSE inspectors may be inconsistent in their own use and enforcement of the concept of good practice, further adding to the uncertainty of health and safety practitioners in industry.

6.2 RECOMMENDATIONS FOR THE HSE

Based on our research, industry expects the HSE to provide a lead role in identification and dissemination of good practice. We therefore recommend that HSE takes the following actions: A. The HSE should publish guidance on how good practice can be defined, sought out and identified. In publishing this guidance, the HSE should make clear: S Where an organisation has adopted good practice that this may not necessarily be sufficient to reduce risks to ALARP and that they are still obligated to do this. S The difference HSE understands between ‘good’ and ‘best’ practice. S The role, if any, that HSE expects CBA to play in assessing good practice. B. The HSE should ensure that its advice on good practice is clearly communicated to all those it wishes to reach. The communication of advice from the HSE needs to be tailored to the audience, and channelled via media that the audience is most likely to use as an information source. As a first step, HSE should consider the different methods of communicating with groups that fall into the three models identified in Section 5: S For Model A the HSE should be seen to be supportive and provide input into representative Trade Associations and their ilk. The HSE should visibly participate in the Trade Associations and provide their endorsement to guidance where this is deemed appropriate. S For Model B the HSE needs to be aware of the good health and safety management practices that emerge from collaborative projects. Indeed there may be a role for them to act as a catalyst in such environments, bringing together organisations that would not ordinarily have close contact, in order to address a particular topic. In this model the HSE should be more proactive. S In Model C the HSE’s role is much more passive in that they need to provide advice and information in a readily digestible way so that small organisations can easily and cheaply navigate through the enormous wealth of health and safety risk management information and guidance that exists. In this role HSE should provide small organisations with a route map (perhaps via their internet site) to the appropriate sources of information. HSE should develop clear and simple guidance targeted at small companies, and consider how this can best be communicated (e.g. through the HSE website,

television advertising campaigns, storylines on soap operas, citizen’s advice bureaux or banks where companies may go to look for advice or loans). C. The HSE should ensure that guidance and approved codes of practice are published in a timely manner to coincide with changes in regulations, rather than lagging behind them. D. The HSE should improve training for its own inspectors to ensure consistency of approach in regulating against good practice requirements. In reviewing its training practices, the HSE should also consider providing training to local authority inspectors, on a voluntary basis, to assist with developing a nation-wide consistency in approach to regulating good practice. E. The HSE should consider how best to reconcile its dual role as regulator and provider of independent advice on good health and safety practices.

6.3 RECOMMENDATIONS FOR ORGANISATIONS SEEKING TO ADOPT GOOD PRACTICE

The organisations that participated in our survey could be broadly classified according the three models described in Section 5. To get more value from the concept of good practice, organisations should consider where they themselves fit within these models: Model A Organisations that identify themselves with Model A should aim to become more involved with their Trade Association or equivalent body, if they are not already. Organisations of this type were clear that there were benefits to be obtained through involvement, including the ability to set the agenda to some extent as well as benefiting from the collective resources available. Model B Organisations that identify themselves with Model B should lobby the HSE to help them develop a neutral forum for the exchange of good health and safety practices with other members of their industry. These organisations should look for opportunities to share practices without losing competitive advantage – an industry-wide approach to a particular issue can help to ensure that competitive edge is not lost through increasing ones own costs while others cut corners. Model C Organisations that identify themselves with Model C should consider consulting the HSE for advice, without fear that they will incur an unwanted inspection – the HSE web-site could be a useful source. They should also consider the wide range of information sources available to them and focus on those most likely to provide them with a simple answer. Seeking advice from large client organisations may also be practical.

6.4 RECOMMENDED FURTHER RESEARCH

We recommend following up this study through a further survey in, say, one year’s time. This would enable the HSE to gauge how effective it had been in adopting the

recommendations set out here. It would be of particular value to identify whether the concept of good practice had been clarified and was being used more consistently. Another area, touched on briefly in this study and worthy of further research, is the impact of the supply chain on adoption of good practice. Anecdotally, large companies reported requiring their suppliers to adopt particular health and safety practices. A wide-ranging survey such as the one reported here is not a suitable tool to investigate this aspect, as one would need to recruit into the study a series of companies that have a supply chain relationship with one another. Such an in-depth study would lead to important lessons about how to communicate best practice using the supply chain as a mechanism.

APPENDIX 1: QUESTIONNAIRE

SECTION 1 INFORMATION ABOUT MY BUSINESS

Q1 My organisation’s name is: Q2 My name is

Q3 My job title is

Q4 My email address is

Q5 Date of response

Q6 My organisation was Pre 1946 1946-1955 1956-1965 1966-1975 originally formed in: [If your organisation has been subject to a recent change of 1976-1985 1986-1995 Since 1996 ownership, please indicate approximately how long it has been in business altogether] Q7 My organisation has the Part of an Plc (full) Plc (AIM) Ltd. by following structure alliance/jv / shares Ltd. partnership Ltd. by Unlimited Govt. Partnership guarantee (dept/ / sole trader agency) Q8 My organisation works Transport Construction Chemical Process in the following sector (tick Engineering/ Health Services Other (please all that apply) manufacturing Oil & gas specify) Pharmaceuticals Telecoms ……………………… Q9 The main nature of my (eg machine shop, chemical processing, healthcare etc) business activity (ies) are

Q10 My organisation has 1-10 101-249 the following number of 11-25 250-1,000 employees 26-49 1,001-10,000 50-100 > 10,000

Q11 The annual turnover <£2m £24.6m-£100m of my organisation is (*) £2m-£4.3m £100m-£500m £4.4m-£10m £500m-£1,000m £10m-£24.5m >£1,000m

(*) – Sub-divisions reflect EC definitions of Small and Medium Enterprises (SMEs)

Other comments

SECTION 2 STRUCTURE OF MY ORGANISATION AND RESPONSIBILITY FOR HEALTH & SAFETY MANAGEMENT

agree Agree disagree Strongly Strongly Disagree Q1 My organisation’s safety risk management policy is clearly defined and endorsed by the Board Q2 My organisation has clear and appropriate safety risk management objectives in support of that policy. Q3 Responsibility and accountability for safety risk management is clearly defined and understood throughout my organisation. Q4 People who have explicit CEO / managing Co secretary / Finance director responsibility for safety risk director legal advisor. management in my Internal audit Risk manager Insurance manager organisation (check all those Line / project SHE managers All employees that apply). managers Others (please specify) Q5 My organisation spends money externally on research YES NO into health & safety practices.

(If the answer to this question is NO please go to Q7) Q6 The health & safety less than between £100k between £1m more than research budget of my £100k and £1m and £10m £10m organisation is: Q7 My organisation regularly publishes: a) its safety performance YES NO record b) comparisons between its YES NO own safety performance record and sector averages c) comparisons between its YES NO own safety performance and national averages Q8 If you answered NO to all parts of Q7, does your YES NO organisation measure or monitor performance even though it does not publish the findings? Other comments

SECTION 3 TOOLS/METHODS THAT YOU USE FOR HEALTH & SAFETY RISK ASSESSMENT

Q1 Does your organisation use any health & safety risk YES NO assessment tools? If answer is NO go to Q3. Q2 My organisation uses the Checklists HazID/Hazop Qualitative risk following health & safety risk assessment assessment tools / methods: Brainstorms / Fault tree Quantitative risk workshops analysis / event assessment (please check any that apply). tree analysis Failure Modes Business Impact Other (please and Effects Analysis (BIA) specify) Analysis (FMEA) Q3 My organisation explicitly Works premises Works premises Other premises (e.g. identifies health & safety risks (workshops) (offices) client or supplier) in the following areas: Construction/ Office Heavy equipment site operations equipment (manufacturing / (check all that apply). Chemicals Travel during tools) storage and use working hours Handling of Travel to/from Other (please hazardous work specify) materials ………………………… Q4 Of the risks you checked in Q3, which does your organisation regard as the biggest?

agree Agree disagree Strongly Strongly Disagree Q5 My organisation regularly identifies the key health and safety risks, introduced by its activities, to: a) its employees / subcontractors b) members of the public on site/company premises c) members of the public off- site/ outside company premises

agree Agree disagree Strongly Strongly Disagree Q6 As activities change, my organisation evaluates changes to the key safety risks to: d) its employees /subcontractors e) members of the public on company premises f) members of the public off- site/ away from company premises

Other comments

SECTION 4 SOURCES OF GOOD PRACTICE

Q1 How would you define good practice as used in health and safety management? Q2 Does your organisation distinguish between good YES NO practice and best practice in health and safety management?

(If answer is YES, please provide an illustrative example) Q3 Do you believe your organisation sets the benchmark YES NO in its sector for good practice in health & safety management?

(If answer is NO, please specify who does) Q4 I know where to go to get Strongly Agree Disagree Strongly advice on good practice in health agree disagree and safety risk management

Q5 My organisation looks to the UK regulatory bodies (e.g. Employees following sources for HSE) CBI communicating and Other industries (global) Institute of Directors disseminating good practice with Other industries (UK) Chambers of Commerce respect to health & safety risk Trade associations Clients / customers management Trade unions/employee Suppliers associations Trade journals (please check all that apply). Lawyers Conferences Legal advisors Media Auditors Others (please specify) In-house Management …………………………

Q6 My organisation uses the International prescriptive Other UK Government following forms of information legislation/ regulations Department Guidance when developing health & safety UK prescriptive legislation/ International Standards risk management practices: regulations UK Standards Approved Codes of Practice Industry Standards (please check all that apply). HSE Guidance Trade Federation Guidance Other (please specify) …………………………… Q7 Which of the sources checked in Q5 does your organisation regard as the most important?

Q8 Who do you think should be the most important source of information with respect to good practice H&S management

Strongly agree Agree Disagree Strongly disagree Q9 My organisation relies on the following for ensuring health and safety risks are properly managed: g) custom and practice h) common sense and engineering judgement i) industry practice j) written codes and standards k) compliance with legislation

Q10 My organisation uses risk assessment as the basis for decisions about how to ensure good health and safety risk management. Q11 My organisation is constantly seeking to improve its health & safety performance. Q12 My organisation benchmarks its health & safety performance: l) against its own industry norms m) against international norms Q13 My organisation’s health & safety record has measurably improved over the last five years. Other comments

SECTION 5 MY ORGANISATION’S APPROACH TO DECISION-MAKING WITH REGARDS TO HEALTH & SAFETY MANAGEMENT

Q1 Who is responsible for setting health & safety policy in your organisation?

Q2 Who is responsible for translating the policy into operational practice?

Q3 Who is responsible for deciding what approaches constitute good practice for your organisation?

agree Agree disagree Strongly Strongly Disagree

Q3 My organisation changes its health & safety practices on an ad hoc basis.

Q4 My organisation has a regular process of review to ensure our health & safety practices are right for us.

Q5 My organisation encourages employees to make suggestions to improve health & safety.

Q6 Managers in my organisation are fully aware of the key health & safety risks when making day-to- day decisions on working methods.

Q7 My organisation regularly compares its health & safety practices with those: n) of other organisations in the YES NO same sector o) of organisations in other YES NO sectors.

(If your answer to either part of this question was ‘YES’ please indicate how you achieve this.)

agree Agree disagree Strongly Strongly Disagree

Q8 My organisation assesses and prioritises its health & safety risks in terms of severity and likelihood of occurrence. Q9 My organisation understands and rigorously applies the ALARP principle when assessing health and safety risks. Q10 My organisation applies quantitative criteria when it determines whether or not a safety risk is broadly acceptable/ tolerable / unacceptable. Q11 My organisation adopts any new health and safety practice it considers constitutes good practice. Q12 My organisation uses its own criteria to determine whether a practice from elsewhere would be good practice for us. Q13 My organisation applies cost-benefit analysis to help determine whether a proposed change to our health and safety practices would be good practice. Q14 If your organisation uses cost-benefit analysis to establish whether to adopt a specific YES NO practice, does it apply a threshold above which it is considered too expensive?

(If the answer is YES, how is this applied and can you provide an illustrative example)

Other comments

SECTION 6 RECENT CHANGES TO HEALTH & SAFETY PRACTICES IN MY ORGANISATION

Q1 Has your organisation made any changes to health & safety practice during the last YES NO five years?

(If answer is NO, please go to next section)

Q2 If your organisation has Regulatory changes (please Other reasons (please specify) made changes, were these specify)…………………… ………………………………….. driven by regulatory changes New activities or for other reasons? Adoption of good practice

Q3 If your organisation made Very Good Adequate Poor No changes for regulatory reasons, good advice how clear was the advice you given received from the regulator?

Q4 If you made changes for Specific incident/accident Customer insistence other reasons, what prompted Safety record trend analysis Own periodic risk review you to change? Employee suggestion Recommendation from Trade Legal advice Association or similar body Audit report Other (please specify) ………………………………

Other comments

SECTION 7 MY ORGANISATION’S EXPECTATIONS WITH RESPECT TO THE ROLE OF THE HSE IN DEFINING/ADVISING ON GOOD PRACTICE

agree Agree disagree Strongly Strongly Disagree

Q1 My organisation fully understands its responsibilities under the Health & Safety at Work etc Act 1974. Q2 My organisation fully understands what we need to do to comply with all other health & safety legislation Q3 The HSE has made clear the role of good practice in selecting health & safety approaches. Q4 The HSE should play an important role in making sure good practice is shared amongst organisations. Q5 The HSE has played an important role in making sure good practice is shared amongst organisations. Q6 The HSE provides adequate guidelines on how to interpret regulations for our industry. Q7 The HSE should play an important role in formulating good practice. Q8 The HSE does play an important role in formulating good practice. Q9 The HSE does not do enough to regulate health & safety in our industry Other comments

SUPPLEMENT

We hope to carry out a more in-depth look at a series of case studies. Would you be willing YES NO to discuss any recent changes you have made in more detail with one of our analysts?

Once the survey findings have been analysed, we plan to hold a seminar/ workshop to YES NO discuss the findings. Would you be interested in taking part (at no cost to yourself other than travel costs) ?

APPENDIX 2: NON-SEGMENTED RESPONSES TO QUESTIONS, SECTIONS 2-7

QUESTIONNAIRE SECTION 2: STRUCTURE OF THE ORGANISATION AND RESPONSIBILITY FOR HEALTH & SAFETY MANAGEMENT

0% 20% 40% 60% 80% 100%

Q1: My organisation's safety risk management policy is clearly defined and endorsed by the Board

Strongly agree Q2: My organisation has clear and appropriate Agree safety risk management objectives in support of Disagree that policy Strongly Disagree

Q3: Responsibility and accountability for safety risk ma na ge ment is cle arly de f ined and understood throughout my organisation

Q4: People who have explicit responsibility for safety risk management in my organisation (more than one response accepted)

250

200

150

100

r s r r r r e e e e g / MD y cto a lo Othe e n p anage Dir a CEO m m m ct manag ce ce e HE n n All e S Internal0% auditRisk manager 20%any secretary 40% 60%a 80%a 100% roj p in r p F u / e Ins n Com Li

Q5: My organisation spends money externally on research into health & Yes safety practices No

Q6: The health and safety budget of my organisation is (for those responding to Q5 with 'Yes')

80 70 60 50 40 30 20 10 0 less than £100k between £100k and between £1m and more than £10m £1m £10m

0% 20% 40% 60% 80% 100%

Q7a: My organisation regularly publishes its safety performance record

Q7b: My organisation regularly publishes comparisons between its own safety performance record and sector Yes averages No Q7c: My organisation regularly publishes comparisons between its own safety performance and national averages

Q8: My organisation measures or monitors performance

QUESTIONNAIRE SECTION 3: TOOLS/ METHODS USED FOR HEALTH & SAFETY RISK ASSESSMENT

0% 20% 40% 60% 80% 100%

Q1: Does your organisation use any health & Yes safety risk assessment tools? No

Q2: My organisation uses the following health & safety risk assessment tools/ methods (select as many as apply)

250

200

150

100

Q3: My organisation explicitly identifies health & safety risks in the following areas (select as many as apply)

300

250

200

150

100

Q4: Of the risks identified in Q3 my organisation regards this as the biggest (one answer only)

90 80 70 60 50 40 30 20 10 0

0% 20% 40% 60% 80% 100%

Q5a: My organisation regularly identifies the key health and safety risks introduced by its activities to its employees/ subcontractors

Q5b: My organisation regularly identifies the key health and safety risks introduced by its activities to member of the public on site/ company premises Strongly agree Q5c: My organisation regularly identifies the Agree key health and safety risks introduced by its Disagree activities to member of the public off-site/ company premises Strongly Disagree Q6a: As activities change my organisation evaluates changes to the key safety risks to its employees/ subcontractors

Q6b: As activities change my organisation evaluates changes to the key safety risks to it s me mbe r of t he public on company premises

Q6c: As activities change my organisation evaluates changes to the key safety risks to member of t he public a way f rom compa ny premises

QUESTIONNAIRE SECTION 4: SOURCES OF GOOD PRACTICE

Q1: How would you define good practice as used in health and safety risk management – 205 individual responses received, see discussion in Section 2 of the main body of the report.

0% 20% 40% 60% 80% 100%

Q2: Does your organisation distinguish between good practice and best practice in health and safety manageme nt ? Yes No

Q3: Do you believe your organisation sets the benchmark in its sector for good practice in health and safety manageme nt ?

0% 20% 40% 60% 80% 100% Q4: I know where to go to get advice on good practice in health and safety risk management Strongly Agree Agree Disagree Strongly Disagree

Q5: My organisation looks to the following sources for communicating and disseminating good practice with respect to health and safety risk management - see Figure 8 in Section 3 of main report.

Q6: My organisation uses the following forms of information when developing health and safety risk management practices – see Figure 11 in Section 3 of main report.

Q7:Which of the sources checked in Q5 does your organisation regard as the most important?

120

100

20 0

Q8:Who do you think should be the most important source of information with respect to good practice in health and safety management?

180

160

140

120

100

0% 50% 100%

Q9a: My organisation relies on custom and practice to ensure health and safety risks are properly managed

Q9b: My organisation relies on common sense and engineering judgement to ensure health and safety risks are properly d Q9c: My organisation relies on industry practice to ensure health and safety risks are properly managed

Q9d: My organisation relies on written codes and standards to ensure health and safety risks are properly managed Strongly Agree Agree Q9e: My organisation relies on compliance Disagree with legislation to ensure health and safety Strongly Disagree risks are properly managed

Q10: My organisation uses risk assessment as the basis for decisions about how to ensure good health and safety risk management

Q11: My organisation is constantly seeking to improve its health and safety performance

Q12a: My organisation benchmarks its health and safety performance against its own industry norms

Q12b: My organisation benchmarks its health and safety performance against international norms

Q13: My organisation's health and safety record has measurably improved over the last five years.

QUESTIONNAIRE SECTION 5: ORGANISATION’S APPROACH TO DECISION- MAKING WITH REGARD TO HEALTH & SAFETY MANAGEMENT

Q1: Who is responsible for setting health and safety policy in your organisation? See Figure 13 in Section 4 of the main report for responses.

Q2: Who is responsible for translating the policy into operational practice? ? See Figure 14 in Section 4 of the main report for responses.

Q3*: Who is responsible for deciding what approaches constitute good practice for your organisation? ? See Figure 15 in Section 4 of the main report for responses.

0% 20% 40% 60% 80% 100%

Q3: My organisation changes its health and safety practices on an ad hoc basis

Q4: My organisation has a regular process of Strongly Agree review to ensure our health and safety Agree practices are right for us Disagree Strongly Disagree Q5: My organisation encourages employees to make suggestions to improve health and safety

Q6: Managers in my organisation are fully aware of the key health and safety risks when making day-to-day decisions on working met hods 0% 20% 40% 60% 80% 100%

Q7a: My organisation regularly compares its health and safety practices with those of other organisations in the same sector Yes No

Q7b: My organisation regularly compares its health and safety practices with those of organisations in other sectors

*Note that due to an error on the questionnaire, section 5 had two questions numbered ‘3’.

0% 20% 40% 60% 80% 100%

Q8: My organisation assesses and prioritises health & safety risks in terms of severity and

likelihood

Q9: My organisation understands and rigorously applies the ALARP principle

Strongly Agree Q10: My organisation applies quantitative Agree criteria when it determines the tolerability of a Disagree risk Strongly Disagree

Q11: My organisation adopts any new health and safety practice it considers constitutes good practice

Q12: My organisation uses its own criteria to determine whether a practice from elsewhere would be good practice for us

Q13: My organisation applies cost-benefit analysis to help determine whether a proposed change would be good practice

Q14: If your organisation uses cost-benefit 0% 20% 40% 60% 80% 100% analysis does it apply a threshold above which a specific practice would be considered too expensive? Yes No

QUESTIONNAIRE SECTION 6: RECENT CHANGES TO HEALTH & SAFETY PRACTICES IN THE ORGANISATION

0% 20% 40% 60% 80% 100% Q1: Has your organisation made any changes

to health and safety practice during the last 5 Yes years? No

Q2: If your organisation has made changes, were these driven by regulatory changes or for other reasons? See Figure 6 in Section 2 of the main report for graph and Section 2.2 for related discussion.

0% 20% 40% 60% 80% 100% Q3: If your organisation made changes for Very good regulatory reasons how clear was the advice Good your received from the regulator? Adequate Poor No advice given No response

Q4: If you made changes for other reasons, what prompted you to change? See Figure 6 in Section 2 of the main report for graph and Section 2.2 for related discussion.

QUESTIONNAIRE SECTION 7: ORGANISATION’S EXPECTATIONS WITH RESPECT TO THE ROLE OF THE HSE

0% 50% 100%

Q1: My organisation fully understands its responsibilities under the Health & Safety at Work

Act 1974

Q2: My organisation fully understands what we need to do to comply with all other health and safety legislation

Q3: The HSE has made clear the role of good practice in selecting health and safety approaches

Strongly Agree Q4: The HSE should play an important role in Agree making sure good practice is shared amongst Disagree organisations Strongly Disagree

Q5: The HSE has played an important role in making sure good practice is shared amongst organisations

Q6: The HSE provides adequate guidelines on how to interpret regulations for our industry

Q7: The HSE should play an important role in formulating good practice

Q8: The HSE does play an important role in formulating good practice

Q9: The HSE does not do enough to regulate health and safety in our industry

APPENDIX 3: STUDY CONTRIBUTORS

SURVEY RESPONDENTS WHOSE RESPONSES WERE INCLUDED IN THE ANALYSIS

A & R Carton (UK) Ltd Central Trains Aberdeen Asset Management Plc Century Newspapers Ltd Adonis Construction Limited Challenge Fencing Ltd AEP (Chippenham) Ltd Charles Turner & Co Ltd Aggreko UK Ltd Chauvin Pharmaceuticals Airscrew Ltd Chelsfield Plc Akcros Chemicals Limited Chemence Ltd Alcoa Extrusions (UK) Ltd Chemson Ltd Allenbuild Turner Chrysalis Group plc Ambersil ltd Clachan Construction Co. Ltd Anglia Railways Train Services Ltd Clark Contracts ltd Antony Rowe Ltd Cleghorn Waring & Co (Pumps) Ltd Anwyl Construction Co. Ltd Colway Tyres Ltd Apollo London Limited Computacenter Apple Web Offset Ltd Conoco (UK) Ltd Applied Optical Technologies Coolchain ltd Arriva Plc Coolkeeragh Power Ltd AWG Coppice Alupack Ltd Barnes & Elliott CRL Bath Press Ltd Cumbrian Industries Limited Baxall Construction Ltd D J Construction Ltd BBA Group PLC D S Machining Services Ltd Belway Homes ltd D.A. Green and Sons Ltd Bethell Group Plc Dean & Dyball Construction Ltd Bethell White Building Services Debenhams Retail plc Beva Construction Decorative Panels Ltd Billington Structures Ltd Dental Practice Board Blackbourne M&E Services DEW Pitchmastic plc Bodycote International Plc Diamond Build plc Bombardier Transportation UK LTD Dolphin Telecommunications Ltd Bonar Yarns and Fabrics Ltd Dow Agro Sciences Ltd Bousfield Ltd Dupont Powder Coatings UK Ltd Briggs & Forrester (Mechanical Services) Ltd Dura Automotive Bristol Contributory Welfare Association Ltd E J Taylor & Sons British Nuclear Fuels Plc Eastman Chemical (UK) Limited Broadway Edison Mission Energy First Hydro Co. Brockway Carpets Ltd Electricity Association Services Ltd Bullock Construction Ltd Electro Furnace Products Ltd Bupa Hospital (Clare Park) Eraba Ltd Bymacks Limited Eric Wright Group C & B Group Evans Vanodine International plc C Spencer Ltd Evotec OAI Canute Haulage Plc F Sherwood & Sons Transport Ltd Caparo Merchant Bar Plc Fairfield PNEU School Carillion Plc Farrington Guerney Primary School Cavalier Carpets G F Holding Contractors Central Building Contractors G. Durham

G.F Tomlinson Building Ltd Kingsway Engineering Ltd Galliford Try plc Lancaster Synthesis Ltd Galliford Try Plc Leslie Wilks Associates Gamble Trackline Service Ltd Liverpool John Moores University Garnett Dickinson Group Loweth Limited Geest Plc M J Allen National Autoparts Ltd Geoffrey Osborne ltd Macfarlan Smith Ltd George & Harding Ltd Macfarlane Transport George Abbot School Marshalls Plc George Wilkinson (Burnley) Ltd McCarthy Surfacing Ltd George Wimpey UK Ltd McPhillips (Wellington) Ltd Gordon's School Memco Limited Grant Rail Ltd Metal Contract Management Ltd Grasmere Press Ltd MFI (UK) Ltd (part of MFI Furniture Grp Grocontinental Plc) GTRM Ltd Miba Tyzack Ltd Halton General Hospital Midas Homes Ltd HBG Construction Ltd Mitie Group PLC Henry Boot Plc Mivan LTD Herbert Baggaley Construction Ltd Mortons of Horncastle Ltd Hinkins & Frewin Multibuild Ltd Hobbs The Printers Ltd Nacam Uk Ltd Hochtief (UK) Construction Limited Napp pharmaceuticals Ltd Hollingsworth & Vose National Express Group Plc Holly Lodge Primary School National Grid Company Howard Hunt (City) Ltd Natta Buildings Co ltd Iceland Foods Naylor Chemicals Ltd IDG Communications Newfield Construction Ltd IMI plc Newtek Glazing Systems Ltd Industrial Services Group Ltd Next Retail ltd Informa Group Plc NGF Europe ltd Initial City Link Norbert Dentressangle UK Ltd Wales & Innogy Holdings Plc West Interflex Tullis Neill Nordam Europe Ltd Interoute Telecommunications North Bristol NHS Trust Interserve Plc Northern Foods Plc IVO Energy Limited Northern Ireland Electricity Plc J & H Bunn ltd Northern Pump Suppliers J & S Seddon (Building) LTD Ofquest Ltd J. Murphy & Sons Ltd Ogihara Europe Limited J.S Chinn & Company Ltd Ove Arup Partnership Jarvis Plc Parkside Flexibles Ltd JN Bentley ltd Partek Cargotec (UK) ltd Government John Crowley (Maidstone) Ltd Business Ops John Dickie Group Penman Engineering Ltd John L Brierley Ltd Persimmon Plc Johnson Matthey Pickerings Europe Limited Kappa SSK Ltd Pochin (Contractors) Ltd Kelsey Roofing Industries Ltd Powderject Pharmaceutical Plc Ken Biggs Contracts Ltd R&T Swann ltd Kidde Graviner Ltd Rail Link Engineering (Bechtel) Kier Group Rank Gaming Division King George V College Redrow Group Plc Kingston Communications REGUS

Relyon Group Plc The Erith Group Renishaw Plc The Heart Hospital RG Carter Construction ltd Thyssen (GB) Ltd Rhodia Organique Fine Limited Tomkins Plc Richard Roberts Fabrics Trident Alloys Limited Richardson Projects Ltd TTP Communications Richardsons (Nyewood) ltd Tullis Russell Coaters Ltd Ringway Group Ltd United Utilities Rok Build Ltd Universal Vehicles Group Ltd Rotary North West UPS Logistics Group (UK) Ltd Rotunda Community college W.H.Brown Construction (Dundee) Ltd Royal Liverpool and Broadgreen University Walgrave Contracting Services Ltd Hospital Warings Contractors Ltd Rygor Group Ltd Waste Recycling Group PLC S Harrison Construction Ltd Westbury Tubular Struotures LTD S.C. Engineering Weston Area Health NHS Trust Scottish Media Group WH Smith Plc Scottish Power Wheatley Construction lyd Seafield Holdings Ltd William Clowes Ltd SECO Aluminium ltd Wiltshire Bristol Ltd Serco Group Plc Wincanton Serco Metrolink ltd Wolsteholme International Ltd Seymour (Civil Engineering Contractors) Ltd Shanks Group Plc Shell UK Exploration & Production SIAC Construction (UK) ltd Signet Group plc Sindall Ltd Smith & Nephew plc Snape Roberts Ltd Sol Construction Ltd Solvay Interox South Bucks NHS South West Water ltd Southern Print (WEBB) Spectrum Flair Group Ltd SSL International Stannah Lifts Limited Stephens & George Ltd Stephenson Group Ltd Stepnell Ltd Story Construction Ltd Sulzer Pumps (UK) Ltd Supersine Duramark Ltd Surrey Hampshire Borders NHS Trust Swift Horsman Ltd Taylor Barnard Ltd Taylor Woodrow TBI Plc Teich Flexibles (UK) Ltd Telia UK Ltd Thames Trains The Berkeley Group Plc The Bristol Nuffield Hospital

CASE STUDY PARTICIPANTS

Alcoa Extrusions UK Bonnar Yarns Carillion Plc Hochtief Construction Innogy Kappa S S K Ltd Napp Pharmaceuticals Ltd National Express Group Plc National Grid Co. Plc Scottish Power Solvay Interox Ltd United Utilities

WORKSHOP PARTICIPANTS

Appleweb Offset Ltd Bousfield Ltd Chauvin Pharmaceuticals Ltd Crispin & Borst Group Services Ltd Geest Plc Geoffrey Osborne Ltd George Harding Ltd Jarvis Plc MFI UK Ltd Ove Arup Partnership Ltd Serco Group Plc SIAC Construction (UK) Ltd The Electricity Association United Utilities WHSmith

53 Printed and published by the Health and Safety Executive C30 1/98 Printed and published by the Health and Safety Executive C1.25 02/02 ISBN 0-7176-2273-8

CRR 412 £15.00 9 780717 622733