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. HSE BOOKS © Crown copyright 2002 Applications for reproduction should be made in writing to: Copyright Unit, Her Majesty’s Stationery Office, St Clements House, 2-16 Colegate, Norwich NR3 1BQ 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. vi 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.