Scramble your way to a coastal adventure

As promised in the last blog on tombstoning, we’d like to introduce coasteering: a popular and developing activity that involves traversing the intertidal zone – or, in everyday language, scrambling around the coastline having fun.

Those taking part in the activity use a combination of scrambling, walking, swimming and jumping to complete the

The idea is NOT to stay dry...

journey – if you set out with the intention of staying dry, you’re not coasteering!

In its early days, coasteering was a niche activity which began in Pembrokeshire, south Wales, where there are miles of wild, rocky coastline to explore. It was run by a small number of well-managed outdoor centres; but since then the activity has spread around the UK. This growth in the sport’s popularity has brought new activity providers onto the scene.

In the summer of 2007, primarily as a result of several incidents and near misses, members of the National Water Safety Forum (NWSF) began to think about the management and development of coasteering – and, in parallel, approaches to managing “tombstoning” incidents.

In response to these incidents, a joint project was launched with the Royal National Lifeboat Institution (RNLI), the Maritime and Coastguard Agency (MCA) and the Royal Life Saving Society (RLSS). Under the direction of the NWSF beach advisory group, an industry working group was established involving some 120 organisations and individuals providing commercial coasteering services to the public. The project aimed to reduce the number of accidents, and implement an industry standard for organisations offering coasteering activities.

How did we address the issue?

1. Developing an industry group. Bringing the providers, regulators and rescue organisations together has been the key activity over the last few years.

New and emerging sports often have local pockets of knowledge and excellent practice; sharing this and embedding good practice was the objective, along with helping the industry to formalise the knowledge that was sometimes locked away.

One of the early achievements was the development of a workable definition of coasteering:

Coasteering involves traversing along a stretch of intertidal zone, often as part of an organised group activity. Participants travel across rocks and through water, using a variety of techniques including climbing, swimming and jumping into water. Coasteering guides and participants wear appropriate clothing and equipment while undertaking coasteering activities.

2. Agreeing industry standards and common practice. This was no mean feat. Many of the providers had to sacrifice some of their hard-earned commercial experience and compromise.

The maxim of “not allowing excellence to be the enemy of good” proved true; many providers had first rate standards and operations, which were beyond the capability of smaller companies. The working group addressed this by developing a “safe as necessary” standard that was achievable by everyone in the industry. The group put together two documents outlining the agreed practice and information.

The guidance has proved to be influential and both documents have been adopted by the outdoor industry regulator, the Adventure Activities Licensing Authority (AALA).

3. Developing capacity. One of the issues identified early in the project was the number of organisations involved in developing the sport, who were doing a good job in terms of promoting good practice, but had little resource to scale this nationally.

The original industry group has now progressed from being a NWSF working group into the National Coasteering Charter (NCC), which now includes the majority of providers and training bodies. This group will take forward the sharing and embedding of good practice across the sport.

Adventure is beautiful

Did the project deliver everything we wanted?

No. Not all the training providers are currently involved, nor are some of the other wider industry groups. But, and this is an important “but”, the key providers are involved and they have a common vision of improving the safety and quality of the sector.

However, the wider impact of the project shouldn’t be underestimated.

The process itself and the fact that an industry group overcame its difficulties to work together through what were contentious issues and achieve a good number of excellent outcomes have been noted both in the UK and internationally.

The coasteering project was presented at the World Conference on Drowning Prevention in Vietnam (look out for a blog on this event soon!).

So, what next?

The NCC will take over governance of the key documents with RoSPA, the RNLI, the MCA and other members of the NWSF taking more of a watching brief. The NCC, if it grows as promised, looks to be the best forum for managing the issues associated with coasteering and as such it will have a formal reporting route through the NWSF and, we hope, through other groups.

For more information about coasteering:

• NWSF coasteering skills and competency framework
• NWSF safety and risk management guidance for coasteering
• AALA use of guidance.

Coasteering is great fun, and a unique way of experiencing our country’s beautiful coastline. Get out there and have a go!

David Walker, RoSPA’s information manager and NWSF member

This blog was based on an article in RoSPA’s Staying Alive journal. Take a look at RoSPA’s Flickr account for more coasteering photographs (all owned by John Paul Eatock and Keirron Tastagh).

Don’t jump into the unknown!

It’s that time of year again – the weather is (sometimes!) beautifully warm, people are on holidays, and perhaps a touch too much alcohol may have been consumed. Inhibitions are lowered, and somebody decides to jump off a pier or a bridge.

I can see the attraction of tombstoning, being a bit of an adrenaline junkie.

However, there is a really simple message for people to keep in their minds: don’t jump into the unknown!

Look before you leap

Last week’s newspapers wrote about a man in his 20s who jumped 30 feet off Brighton Pier into just three feet of water. Unsurprisingly, he suffered serious head and spinal injuries – hopefully he will make a full recovery, but others have not been so lucky.

Sadly, it’s not difficult to find many stories of deaths and serious injuries caused by tombstoning in recent years.

Tombstoning offers a high-risk, high-impact experience but it can have severe and life-threatening consequences. Some of these reasons may seem obvious, but they’re worth emphasising – as the accident stats show!

Injuries and deaths as a result of tombstoning are a growing problem. Over the five year period 2004-2008 – 139 incidents required a rescue or emergency response and 12 of them ended in a fatality.

We looked at 41 of the most serious cases in more detail, and the stats may surprise you.

• Most of those involved in the most serious cases were male (85%)
• Teenagers were involved in just over half the cases (55%), followed by those in their 20s (25% with the remainder of incidents involving people aged over 30 years
• All of the known alcohol-related incidents involved males aged over 40 (which accounted for three of the fatal incidents)
• Of the non-fatal incidents, spinal and limb injuries (both at 20%) were most commonly reported.

So, perhaps counter intuitively, it’s not just teenage boys who are the problem. And it’s not the teenagers who are putting their lives in danger after drinking – that is reserved for those who are old enough to know better.

Many of the non-fatal incidents have resulted in life-changing injuries and they required significant resources from the rescue services. As well as the costs to the authorities, these people are now going to require lifelong care from family and friends – it’s not just their own quality of life that has been reduced.

Young and older fathers were among the fatalities, along with at least three teenagers. The coastguard has produced a video clip highlighting the consequences.

So what’s RoSPA’s advice? You may be expecting me to wave my arms and say, “Don’t do it!” But this is the real world. People are going to do what they feel like doing – and most of the time, that’s fine. So all we are saying is that people should arm themselves with information, and know what they’re getting themselves into.

Taking a moment to think through what you’re about to do may save a lifetime of pain and regret – or it may simply save your life.

Don’t jump into the unknown. Consider the dangers before you take the plunge:

• Check for hazards in the water. Rocks or other objects may be submerged and difficult to see
• Check the depth of the water. Remember tides can rise and fall very quickly – as a rule of thumb, a jump of ten metres requires a water depth of at least five metres
• Never jump while under the influence of alcohol or drugs
• Check for access. Can you get out of the water once you’re in?
• Consider the risks to yourself and others. Conditions can change rapidly – young people could be watching and may attempt to mimic the activity. And, if you jump when you feel unsafe or pressured, you probably won’t enjoy the experience.

Jumping in is the easy part; getting out of the water is often more difficult than people realise, and don’t forget that strong currents can rapidly sweep people away – even strong swimmers cannot swim against the tide.

The best way to learn about the risks involved and have a good experience is to try coasteering – a mix of scrambling, climbing, traversing and cliff jumping around the coast with a professional guide.

Stay tuned to the blog next week for an article on coasteering!

Vicky Fraser, RoSPA’s press officer/web editor

Goldilocks had the right idea about health and safety

Among the questions posed in his call for evidence which ends on July 29, Professor Löfstedt asked: “To what extent does the concept of ‘reasonably practicable’ help manage the burden of health and safety regulation?”

“Reasonable practicability” as a concept causes much confusion, particularly when it comes to its practical application. However, it is a cornerstone of the UK’s approach to regulation of work-related risk, which has proportionality at its heart.

As is widely recognised, the principle was originally established in the now famous common law judgement of Edwards versus the National Coal Board in 1949. Lord Justice Asquith said at the time:

“Reasonably practicable is a narrower term than ‘physically possible’ and implies that a computation must be made… in which the quantum of risk is placed in one scale and the sacrifice involved in the measures necessary for averting the risk (whether in time, trouble or money) is placed in the other and that, if it be shown that there is a great disproportion between them – the risk being insignificant in relation to the sacrifice – the person upon whom the obligation is imposed discharges the onus which is upon him.”

In other words, for things to be considered safe so far as is reasonably practicable you have to go on trying to make them safer until you reach a point where it is not worth doing more (a point of diminishing safety returns) – AND the risks which still remain must not be too great.

Making such safety judgements with confidence is often quite difficult. If the efficacy of safety measures is uncertain in reducing the likelihood of failure, particularly when the consequences of failure are serious, the result is more likely to be a precautionary “belt and braces” approach.

Critics say the concept of reasonable practicability allows too much flexibility and leads to weak or inadequate precautions being taken. Evidence suggests that, properly applied, reasonable practicability guarantees a high standard of safety. Investigations tend to confirm that few accidents occur where reasonably practicable safety measures have been taken.

The real importance of the concept is that it allows proportionality of response to risk, taking account of different variables. The alternative to this might be a rising scale of specific solutions laid down in law, but this would be cumbersome and might lead to both “under-hitting” and “over-hitting”. Reasonable practicability allows for fine tuning.

Making sound judgements about such risk/cost optimisation can pose real challenges for those firms lacking the necessary skills or access to professional expertise, particularly where options must be chosen from a range of solutions. For example, to take a case related to public safety, reasonably practicable water edge treatments to prevent drowning can vary from little or no action, to shelving and/or planting edges and erecting signage, through to extensive physical barriers at the extreme.

Factors such as population density and foreseeable behaviours can influence the scale of control measures. Those not in the know sometimes find it difficult to understand why maximum measures have been taken in one setting but not in another.

What is useful about reasonable practicability is that it provides a constant reminder to risk creators, risk takers and regulators that safety is not an absolute but always a matter of judgement. At RoSPA we try to express this simply by saying that things need to be as safe as necessary, not necessarily as safe as possible.

On the other hand the concept can give rise to conflicting responses. Firms tend to welcome the flexibility it provides; but when faced with lack of clarity they can then demand official advice about exactly what would constitute a minimal standard of compliance.

There is also confusion about costs. The affordability of specific measures does not relate to the financial circumstances of the individual duty holder. You cannot plead poverty and get away with a lower standard of safety but you can factor in opportunity costs, for example, the longer-term costs of restricting a particular activity or of unintended consequences such as risk transfer.

The fundamental ideas in our health and safety law about risk/cost optimisation originated in the philosophy and practice of radiological protection developed from the 1940s onwards. Here, the core doctrine was “justification, optimisation, risk limits”. In other words:

1. If an exposure is tolerable, is it justified by sufficient benefits?
2. Has exposure been optimised? (I.e. has a point of diminishing returns been reached in terms of further dose reduction?)
3. Have upper bounds been set? (I.e. have suitable dose limits been established?)

This approach can be applied to all kinds of risk decision-making in health and safety.

In practice the workability of a reasonably practicable approach to safety depends on skill in undertaking suitable and sufficient risk assessments. Initially this means establishing if risks are trivial, moderate or high and, if they fall into the last two categories, deciding if control measures are adequate or if more needs to be done. Assessments also enable duty holders to prioritise risks for attention and they can be generic, specific and/or dynamic.

In many cases, those managing risk may carry out very little actual assessment. Much of what is called “risk assessment” is really little more than hazard identification and involves minimal exercise of judgement as to the probability or consequences of failure. If this simple approach enables standard but quite satisfactory solutions to be selected from the overall health and safety guidance lexicon then this does not necessarily matter, particularly if it leads to people adopting sufficiently safe systems of work. On the other hand, there is always a danger of “over-hitting” if the level of risk actually presented by the hazard is trivial and the standard solution selected is substantially more than is really required.

A simple approach to finding the right balance is what I have called “iterative triage” or “the Goldilocks Principle”. (In her search for beds and porridge Goldilocks found beds that were too hard or too soft, and porridge that was too cold or too hot – and this enabled her to find the ones that were “just right”.)

What all this demonstrates are two awkward truths:

1. There is probably no practical regulatory alternative to a goal-setting approach supported by reasonable practicability, especially in the complex risk environment of our contemporary world of work
2. If this approach is to be successful in practice, duty holders need to be suitably informed and competent or have access to suitably competent advice.

Those daunted by the challenges posed by this approach to work-related safety and health often demand regulatory simplification or a return to common sense. The reality is, though, that the risk profile of even apparently benign settings such as shops, office and schools can often be quite varied and complex; the devil is always in the detail and the right solutions are sometimes counter-intuitive.

An approach to regulating and managing risks based on what is reasonably practicable is undoubtedly a more mature approach than one based on prescription, but it only works in practice if the challenges are matched by necessary competence.

Getting health and safety judgements right is not always easy, but if they help to save lives, reduce injuries and safeguard health without wasting scarce resources, then the effort involved is surely worthwhile.

As ever, readers’ comments are invited below.

Roger Bibbings, RoSPA’s occupational safety adviser

Further thoughts on the Löfstedt Review

Following my previous blog post, it’s time to further develop some thoughts on the Löfstedt Review and the issues surrounding it.

What made the HSW Act and the post-Robens architecture different from the earlier Factories Act law was not just its goal setting nature, bounded by “reasonable practicability”, but its attempt to describe the essential ingredients for arriving at and sustaining safe systems of work in an organisational setting.

In other words, it was not just a long list of dos and don’ts related to particular hazards. In a suitably general way, it set out the people/policy/procedures needed to ensure that hazards were routinely identified, risks assessed, appropriate controls applied and refined – taking into account advances in knowledge and lessons from operational experience.

Thus, where earlier law had sought only to prescribe measures to be taken in various (actually quite limited) settings, the 1974 Act – later augmented by the Management of Health and Safety at Work (MHSW) Regulations – tried to indicate what employers needed to do to be able to work this out for themselves, using risk assessment and supported by competent people/advice, consultation with workers and so on.

In theory, regulations and guidance introduced later to regulate specific risks and activities were designed to support this underlying core. In reality, however, what we now have is architecture of law that is actually quite untidy, incomplete and is not easy to understand in detail without going on a training course and/or reading quite a lot of guidance! (This is just as true, of course, of law relating to other aspects of business such as employment, tax, planning, environment etc. Most business owners/managers do not read raw, undigested health and safety law but refer to guidance or seek professional advice.)

And, of course, law and guidance on their own provide only part of the answer since legally-required systems and risk control measures alone (even when supported by detailed requirements) are not enough to guarantee desired outcomes.

To ensure the “fine fit” between systems/standards and operational reality you also need an effective health and safety culture. We also need effective systems of promotion, education, training, advice, and support to enable smaller businesses particularly to respond effectively. And we also need enforcement to deal with the criminally non-compliant. Good law is clearly necessary but it is far from sufficient to deliver safe and healthy working conditions.

The challenge I believe Professor Löfstedt faces in conducting his review is not only to show how we can return to the essence of the Robens vision, stripping out a lot of the confusing duplication and overlap of duties in the different sets of regulations (without reducing essential protections), but how – in practical terms – we can deal with the challenges smaller firms in particular face in responding to goal-setting law.

For example, it is just as important that his team looks at other issues like the overall health and safety support system for SMEs in the UK and what can be done to make this more effective and coherent. He may also like to look at the role of third party semi-regulators such as clients, main contractors, insurers, assurers etc., and perhaps take a look at the case for some sort of rapid, independent appeal process to deal with any incidences of over-the-top requirements that they might impose.

The Government will insist, with justification, that any proposals pass what is called “the small firms test”. There is continuing debate about whether there really is some sort of size threshold in today’s business below which ideas about formal risk management have no meaning in practice. It is often said that small firms “run” their businesses, whereas large firms “manage” them – and small firms are not just large ones that haven’t got big yet!

What we and most other stakeholders in the health and safety system continue to argue is that it is the level of risk to workers (and others) and not the organisation’s size that must be the guiding principle. So Prof. Löfstedt and his advisers need to begin at the beginning and consider if we do indeed have a clear set of goal-setting risk duties in law which reflect the different elements in the risk management challenge, and which are applicable to all organisations. At present these are scattered across the top of the legal structure and do not flow logically downwards and outwards in other subsidiary law and guidance. Some, like risk assessment, are repeated at several levels. Other really important ones like investigation and organisational learning from incidents are not very clear at all.

So if they are to approach their commission professionally, what Professor Löfstedt and his colleagues will need to consider at the outset is whether current risk management duties in law are both understandable and truly “scalable” in different settings. If there are gaps, then these need to be identified, together with ideas as to how they might be filled in the most appropriate way.

Only then will it be meaningful to look at how to brigade more effectively the large amount of regulatory detail that has accumulated since 1974, and after 1992 in particular. Anything else, such as just trying to return to the letter of particular directives (often unworkable in a UK setting) runs the risk of just tinkering at the edges for political effect and creating even less clarity.

The same breadth of vision and depth of understanding are needed to deal with the final part of the review about the legal position of employers in cases where employees act in a grossly irresponsible manner. Nobody sets out to have an accident but on occasion some employees do, for various reasons, act with disregard for their own or others’ health and safety. Professor Löfstedt and his panel members will need to do their homework here too, avoiding crude behaviourist models of safety management which see accidents as being caused mainly by “unsafe workers” and immerse themselves in excellent HSE publications such as HSG48 Reducing error and influencing behaviour to help get causation factors in perspective.

I would urge all readers to watch this space and feed in their ideas to the review as it proceeds. Email: review.healthandsafety@dwp.gsi.gov.uk.

Roger Bibbings, RoSPA’s occupational safety adviser

Untangling the terms of the Löfstedt Review

Following on from my previous blog – Hazard and risk: understanding the difference – in which I talked about the Lord Young Review, the time is about right to look at what is happening next.

Chris Grayling, employment minister for the Department for Work and Pensions, has commissioned Professor Ragnar Löfstedt, director of the King’s Centre for Risk Management at King’s College London to chair a team of six people to consider the opportunities “for reducing the burden of health and safety legislation on UK businesses while maintaining the progress made in improving health and safety outcomes” and to report by this autumn. The team will comprise politicians, business people and employee representatives.

Professor Löfstedt’s review will be supported by a small team of DWP officials and will focus primarily on the approximately 200 statutory instruments and associated approved codes of practice rather than the Health and Safety at Work (HSW) Act itself or other primary legislation.

The professor has called for evidence from a range of stakeholders including government bodies; employers’ organisations; employees’ organisations; professional health and safety bodies; and academics. They will consider:

• The scope for consolidating, simplifying or abolishing regulations
• Whether the requirements of EU Directives are being unnecessarily enhanced (“gold-plated”) on translation into UK law
• If lessons can be learned from comparison with health and safety regimes in other countries
• Whether there is a clear link between regulation and positive health and safety outcomes
• If there is evidence of inappropriate litigation and compensation arising from health and safety legislation
• Whether changes to legislation are needed to clarify the legal position of employers in cases where employees act in an irresponsible manner.

RoSPA is feeding ideas into the review, but it is my opinion that the professor and his colleagues will need to commit to doing a lot of homework if they are to understand fully the background to what they have been asked to do. And if they do not co-ordinate closely with other “simplification” initiatives that are underway there is a real danger of confusion.

These initiatives include a wider project by the HSE looking at how it organises its overall range of guidance, including on health and safety management, as well as another Government initiative asking the public for ideas on how to cut so-called “red tape”, including in health and safety. Logically any attempt to revise and restructure the HSE guidance lexicon should perhaps await the outcome of the Löfstedt review.

Health and safety law is important. People’s lives and health depend on it. Any review needs to be undertaken professionally and carefully, without being rushed. It needs to be strategic, evidence-based and must carefully consider previous reviews of regulation and the results of consultation on particular regulations.

In particular Professor Löfstedt, members of his panel and DWP officials will need to go back and understand in some detail the history and evolution of our system of health and safety law and guidance, as the past and present are intimately connected. Core ideas in our law and guidance system about health and safety management go back a long way – to before the Robens Committee including, for example, the report of the Joint Industrial Council on Accident Prevention of 1956! Ideas about how to regulate and manage health and safety issues have an enduring DNA.

In theory there is supposed to be a logical flow from the general duties of care in the HSW Act, through the Management of Health and Safety at Work Regulations (MHSWR) to other specific hazard and sector related regulations. Guidance documents (which are what people actually read) then support all this. But, as everyone now admits, the elegance and logic that were envisioned in the 1972 Robens Report have been corrupted over time by adaptations to implement EC directives, and so on. Key duties like risk assessment, training and information are repeated at number of levels but others like monitoring and learning from incidents are weak if not missing altogether.

In terms of transparency and proportionality, health and safety law and supporting guidance needs to be focused on the “big” issues. In some hazard areas like chemicals and physical hazards, where the impact of an accident or incidence of ill health is immediate and visible, the law is well developed. However, in other areas such as those involving psychosocial risks (ergonomics, stress, violence etc. which affect millions of workers) it is still quite vague.

And, worryingly, huge areas of hazard like work-related road safety (more people are killed while at work on the road than in all other workplace accidents) are addressed only by the most generic guidance.

Arguably the balance between what is covered in regulation and what is addressed in guidance could be readjusted. On the other hand, options here have been limited. Much of the problem, in my view, has been due to our inability in the UK to use Approved Codes of Practice (ACoPs) to transpose EC directives. Robens had high hopes for ACoPs since they were intended to provide both authoritative advice and flexibility; but this vision was not shared.

On one side the TUC always thought ACoPs were too weak. The CBI on the other has always tended to view them as prescriptive regulation by the back door. And the European Commission refused to accept them as a vehicle for transposition of directives into national law anyway.

This whole debate ought to be revisited, and Professor Löfstedt’s review is the ideal time to do so.

This topic is too big and too important to squeeze into one short blog post – so stay tuned for part two. And don’t forget to join the debate – open and honest discourse on all sides is the best way to produce a national health and safety culture that the UK can be proud of.

Roger Bibbings, RoSPA’s occupational safety adviser

Hazard and risk: understanding the difference

In the wake of Lord Young’s Review, and DWP Minister Chris Grayling’s speech saying that from now on the HSE was going to concentrate on “high hazard” industries, it occurred to me that perhaps the minister might have conflated use of the terms “hazard” and “risk”; many people still don’t get the difference.

Hazards: All human activity exposes people to hazards. Hazards are activities or “things” with the potential to cause harm. They can physical, chemical, biological, or even psychological.

Risk: Risk can be understood as the chance that exposure to a hazard will result in harm at some specified level. Hazards with major potential for harm that are well controlled can actually present low levels of risk, because they are well managed and consequently the chances of harm occurring are low. But moderate hazards that are poorly controlled can present significant risks because of the high probability that being exposed to them will result in harm.

So levels of risk (high, medium, low or trivial) can be assessed by looking at the hazard and the probability that it will cause harm.

An example: a circular saw is a hazardous piece of machinery. However, in the hands of a properly-trained operative, the risk of harm would be low (making the activity high hazard but low risk). In the hands of an untrained person, the risk of harm could be very high (making the activity high hazard and high risk).

When allocating resources, decision makers have to consider small numbers of people exposed to high potential hazards and larger numbers of people exposed to lesser hazards – but which can actually result in a greater burden of injury.

In practice, political judgements tend to be skewed towards high hazards with the potential for activities to result in death or life-changing injury, rather than longer-term and more chronic forms of harm.

Lord Young’s Review

RoSPA has been keen to try and make some sense out of Lord Young’s ideas about managing health and safety in what he terms “low hazard” workplaces such as “offices, shops and schools”. They may not have the obvious kinds of harmful energies found in manufacturing, extractive, transport or construction settings but there are obviously still health and safety issues in these environments that need to be addressed.

For example, even small, service-based firms which might at first glance seem quite safe will certainly have significant issues such as fire, occupational road risk, etc. – not to mention issues such as slips, trips and falls, stress and the possibility manual handling injury as well as the potential for threats and violence.

On top of that, there are likely to be facilities management issues such as safe access and egress, safe cleaning, safe storage, safe vehicle parking, lifts, gas and electrical safety, and possibly asbestos and legionnaires’ disease problems. There may be building maintenance and construction, design and management activities too. All these issues need to be addressed and managed safely.

If health and safety is built into an organisation’s ethos, from the boardroom to the shop floor, this kind of safety management should come naturally, and will be relatively straightforward. There should be no burdensome red tape: health and safety is not synonymous with bureaucracy, contrary to the beliefs of the tabloid press.

When asked to define “non-hazardous” at a meeting of the CBI Health and Safety Panel, Lord Young accepted there was a need in schools, for example, to deal appropriately with safety in chemistry labs, workshops and other hazardous activities such as outdoor adventure activities. Obviously all these issues need to be addressed adequately but in a proportionate way.

The inescapable fact is that the distribution of the workforce has continued to change dramatically over the last three and a half decades since the Health and Safety at Work Act was introduced. More people than ever work in offices, call centres, shops and so on. There may be fewer fatal and major RIDDOR events in these settings but troublesome minor injury events still happen, and ill health and wellbeing issues have now become more important than accidents. Absence due to work-related ill health is now almost twice that due to accidental injury.

What we have got to help get across to ministers is that it is the risk profile of jobs and not necessarily the hazard profile of work environments that is critical. (After all, low hazard can still mean high risk and vice versa.)

For example, if you work in an office but suddenly have to do a lot of work-related driving your risk profile increases dramatically. Car and van drivers who cover 25,000 miles annually for work face the same risk of being killed at work as someone employed on a fishing trawler. If you are in a customer-facing role you are likely to face threats or even assault. If you work long hours in a call centre you may face stress and ergonomic problems such as musculoskeletal disorders. If you work next to poorly maintained air-conditioning equipment there is a danger of legionnaire’s disease and so on.

So it is not just a question of your proximity to the traditional forms of “high hazard” found in manufacturing, agricultural or construction settings. Many of the issues which cause accidents at work are in fact common to both industrial and non-industrial environments, particularly slips and trips, and manual handling injuries.

We need to be clear that health and safety management is not just relevant to traditional industries. Almost every kind of work has its issues and if they are not properly managed and regulated, people will be hurt and resources and business opportunities will be squandered.

Roger Bibbings

RoSPA’s Occupational Safety Adviser