How to pass your NEBOSH National Certificate exam – RoSPA’s top 10 tips!

Watch the video at the bottom of this blog to hear recent RoSPA NEBOSH Certificate candidate Roxanne share her tips for success. For more Workplace Safety related posts visit our dedicated blog at www.rospaworkplacesafety.com.

The NEBOSH National Certificate is the UK’s most widely held health and safety qualification, currently held by 150,000 successful candidates. So, if you’re currently studying for your exams then these top tips, assembled from my team of RoSPA trainers, who also have experience marking NEBOSH exams, are for you.

Offering top 10 tips on how to pass your NEBOSH National Certificate exam is Rob Burgon, RoSPA’s workplace safety manager.

1)    Keep your eye on the prize

Yes, it’s a lot of work, and yes, it’s usually on top of all your work work, but the reality is that these days, and in this economic climate, the right qualifications are more important than ever.

In our latest poll, 88 per cent of RoSPA Members agreed that a nationally recognised health and safety qualification helps career progression, and you only need to spend a few minutes scouring the Institution of Occupational Safety and Health’s (IOSH) jobs pages to be reassured that a NEBOSH qualification really will help open doors.

With this in mind, focus on the task in hand and prioritise accordingly. It is far better to pass first time, than to waste time re-sitting.

2)    Know what you’re getting yourself in to

The National General Certificate is divided into three units, the first two of which, NGC1 and NGC2 are assessed by written exam. In order to maximise your point earning potential you need to understand how scores are generated. Remember:

• Each exam lasts two hours
• Each consists of 10 short answer questions and one long answer question
• The short answer questions are each worth eight marks, and the long answer question is worth 20 marks
• Time wise, this means that you should give yourself eight to 10 minutes for the short answer questions and 20 minutes for the long answer question. Our delegates tell us they find it useful to take their own watch into the exam and have it visible on their desk to help keep track of time
• All questions are compulsory.
  

  These top tips certainly helped recent RoSPA candidate Roxanne Woodiwiss, who passed with distinction in March 2012!

3)    Remember that the examiner is looking to give you points

The NEBOSH Certificate exam is positively marked, with points awarded for the correct application of knowledge, rather than deducted for incorrect answers. Therefore, if in doubt, have a go! You really don’t have anything to lose.

This means that it’s your job to make it as easy as possible for the examiner to find places to award you marks. Keep writing legible, with clearly numbered answers (if a question consists of different sub-sections make sure you number each sub section and address it separately within your answer e.g. 1a, b and c) and provide an answer for every question (although you may want to “warm up” by starting with those that you feel most confident about, rather than working chronologically through the paper).

4)    Attend a NEBOSH Certificate revision course

If at all possible we strongly recommend candidates attend a revision course. By putting yourself in an environment where you’re face to face with both an expert tutor and your peers, a revision course allows you to practice exam questions, get feedback on your performance and ask any outstanding questions. Tutors expect there to be things that you’re still unsure of, so if in doubt, just ask. Many organisations, including RoSPA, will accept candidates on their NEBOSH Certificate revision courses even if they studied elsewhere and, for the reasons outlined below, attendance is something that we can’t emphasise enough.

5)    Answer the question that has been set, not a question that you’d like to answer

A quick look through NEBOSH’s Examiners’ Reports reveals that it is not uncommon for candidates to miss marks simply by failing to answer the question as set. Comments such as: “Some candidates fail to answer the question set and instead provide information that may be relevant to the topic but is irrelevant to the question and cannot therefore be awarded marks”, regularly feature in the common pitfalls section. A good revision course will again help you with this, as indeed will a few deep breaths to calm yourself before reading each question – twice.

6)    Apply the command words

Another common pitfall is failing to apply the command words, or action verbs, when answering a question. Taken from RoSPA’s National Certificate Revision Course, the following guide to NEBOSH National Certificate command words should help you steer clear of this:

• Define: Provide a generally accepted definition
• Describe: Give a detailed word picture
• Explain: Give a clear account of, or reasons for
• Give: Provide without explanation (normally used with the instruction to give an example, or examples of)
• Identify: Select and name
• Outline: Give the most important features (less depth than either “explain” or “describe” but more depth than “list”)
• State: A less demanding form of ‘define’ or where there is no generally accepted definition.
  

  Look at past papers in preparation for your exam. Practice answers and submit them to your tutor. You could also sit a mock exam.

7)    Condense your notes as the date approaches

Days immediately prior to the exam are not the time for reading through reams of notes with a highlighter in hand. As the date approaches you should concentrate on condensed excerpts that you can actually commit to memory. Use your own revision cards to create these, or purchase revision cards to augment with your course notes. Remember, minutes of concentrated learning will prove more valuable than hours of reading that you can’t later recall.

8)    Revise the subjects that you like least

Although it’s tempting to delve further into the topics that you enjoy and understand, when it comes to revision it’s the areas that you don’t like, or even understand, that really deserve your attention.

9)    Always be prepared

Take the pressure off yourself by alleviating the potential for niggling anxieties. Make sure you’re equipped with pens and a watch and that you’ve double checked the exam date, time and location and are fully briefed with travel arrangements. Do this thoroughly, and then put it out of your mind, so that you can better concentrate on the        substance of the exam.

10)  Use past papers to practice your exam technique

You will look at past papers as part of RoSPA’s NEBOSH Certificate course. These are obviously the best way to assess the type of questions that you will face. Moreover, by practicing answers and submitting them to your tutor you’ll be able to gauge the depth of response required. We also recommend that you take the opportunity to sit a mock exam in its entirety prior to the actual exam as this will help you understand how much time you have per question, as well as allowing you to practice writing for a significant length of time.

And finally,  try to keep abreast of developments within the safety community, as doing so will mean you can stand out from the crowd by including topical examples and pertinent issues into your exam answers. Free news e-bulletins, such as HSW (the free weekly e-newsletter of the popular Health and Safety at Work journal) are useful for this.

Thank you for taking the time to read our top tips. I wish you the best of luck in your NEBOSH exams and for your continued journey as a safety professional. If at any point myself, or a member of my training team can be of assistance, please don’t hesitate to get it touch.

Rob Burgon, RoSPA’s workplace safety manager

Tel: 0121 248 2233
Email: enquiries@rospa.com

Further reading:

How to craft killer questions for NEBOSH exams

NVQ v NEBOSH Diploma – Which is right for you?

Shopping for safety with RoSPA and dbda

RoSPA’s partner in safety, dbda, has launched a shiny new website to showcase our range of products. Visit www.rospashop.com to take a look at what’s on offer.

Resources cover a vast range of topics and safety areas, from workplace safety to safety at home, on the road, in and around water, and at leisure.

Also on offer is an exceptional variety of safety education materials aimed at teachers and schools, as well as posters, books and activities for parents and governors. In fact, we’ve just released a new set of resources aimed at teachers – if you want to build safety into your lessons, your first stop should be RoSPA.

Posters, books and videos are a great way of supplementing and illustrating safety messages, helping to bring safety to life. Go and visit, and take a look around: there’s something for everyone and plenty of ideas to inspire a safer way of life.

Turning obstacles into opportunities

When one door closes, another opens – or so says the old proverb. Finding a way to turn obstacles into opportunities when it comes to health and safety at work is vital in difficult economic times.

Scottish businesses will find help is at hand, however, at RoSPA’s Scotland Safety and Health Forum, entitled Finding opportunity amidst cuts and changes. Firms will have a chance to explore current and future safety and health issues, not just by sitting and listening, but by getting involved.

In difficult economic times you may need some help to make the business case for health and safety to your directors. This event, held at the Hilton Glasgow on September 21, will help you to do just that.

Although, thankfully, in the UK notifiable fatal and serious injuries in the workplace are reducing, there are still more than one million injuries to workers annually and more than two million cases of ill health caused or exacerbated by work. Many thousands are still dying prematurely as a result of conditions such as occupational cancer. The annual cost to the economy is in the region of £30billion.

Despite this scale of tragedy and loss, companies that are hard pressed, especially during tough economic conditions, may ask quite understandably why they should devote precious money – and even more precious time – to upgrading their health and safety management regimes.

Here’s one very good reason to keep on top of health and safety: the Health and Safety Executive (HSE) has estimated that the ratio between insured and uninsured costs arising from accidents lies in the range of 1:8 to 1:36. That means that in the worst case, for every £100 recovered from the insurer, the business loses about £3,600 – yet very few businesses investigate accidents and incidents, to see what lessons can be learned.

And an accident in which the insurance covers, say, £3,000 could end up costing more than £100,000.

In the case of a very severe accident, such as a fire or loss of a key worker in a small firm, such an event could spell the end of the business altogether.

But perhaps the most important reason to maintain good standards of health and safety is the human factor. Accidents are expensive in financial terms, but the cost to families, friends and communities is incalculable. Grief, stress and the financial hardship that often follow an accident can tear families apart.

No business wants its people to be injured or wishes to be prosecuted or served with enforcement notices by inspectors. With an increasing focus on corporate social responsibility, every conscientious business owner or senior manager wants to know that they have done everything they reasonably can to ensure safe and healthy working. No one wants an accident or work-related health issue on their watch.

Built around interactive sessions such as workshops, discussion groups, and panel interviews, the Scotland Safety and Health Forum will provide opportunities to share and receive advice. Case studies, top tips and practical advice will be given by prominent health and safety professionals from the region, covering key topics such as: the real cost of accidents, communicating the safety business case to senior managers, and important changes to Scotland’s safety landscape. Good safety leadership and teamwork are also vital for excellent health and safety cultures.

We’ve made fantastic progress in the past few years, with serious accidents falling throughout the UK. But we can’t become complacent; and some sectors are beginning to fall behind – notably the agricultural and construction industries. People should be able to come home from work safe and sound, no matter what they do for a living – and there is plenty of help for those who want to make sure they do so.

Sign up now for our Scottish safety forum – if you do so before August 10, you’ll receive a 20 per cent discount.

What price the safety and good health of Scottish workers?

Roger Bibbings, RoSPA’s occupational safety adviser

An Olympic effort for health and safety at work

The Big Build is the first Olympic project of its kind in the world to have been completed without an accident-related fatality.

With one year to go until London 2012, we at RoSPA are delighted to congratulate all those who have worked on the Olympic Park and Village “Big Build” construction project for their outstanding health and safety performance.

With 12,500 workers on the Olympic Park and Athletes’ Village, and more than 60million hours worked, their safety record is particularly impressive.

Of those working hours, 24million of them have been “RIDDOR reportable accident-free”, meaning that no serious accidents, incidents or near-misses occurred.

The accident frequency rate achieved has been 0.17 accidents per million hours worked, which is lower than for the construction sector as a whole and more in line with the average across all UK employment sectors. Near-miss reporting has been equivalent to 100 reports for every RIDDOR event, giving confidence that reporting levels are very good.

RoSPA was particularly impressed with how the ODA, from its inception, declared that its aim was to be a leader in safety and health, integrating these objectives into planning, design and construction operations and enhancing workforce wellbeing. Among the features of the safety and health programme, there have been detailed inductions and further training for workers, plus leadership and communication training for supervisors.

The challenge now will be to maintain this excellent record during the next phases of the Olympics project, running up to and through “Games Time” and beyond. However, what has been achieved thus far is a highly commendable British achievement that is well worth celebrating, particularly in an international context.

Given the prestige and profile of the Big Build and the level of performance achieved, the lessons the project has generated for health and safety form an important part of the overall Olympic legacy – with enormous potential to influence health and safety in the UK as well as globally and to demonstrate further the contribution which high standards in this area make to overall business success.

The ODA and CLM have achieved an internationally-recognised certification of their health and safety management systems (OHSAS 18001) and the Olympic construction project’s occupational health function has won two awards, including the RoSPA Astor Trophy.

RoSPA is delighted that the Big Build project will be submitting an entry to the RoSPA Occupational Health and Safety Awards in 2012, through which its health and safety management systems and performance will be considered by an independent judging panel.

Tom Mullarkey, RoSPA’s chief executive

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

Winning Awards at the Home of Health and Safety

Safety & Health Expo

On May 17-19, the annual Safety and Health Expo took place at Birmingham’s NEC – and as usual, RoSPA was present with a superb stand (even if we do say so ourselves!). This year, our theme was, “RoSPA: The Home of Health and Safety”, and the stand was modelled on our new headquarters in Edgbaston, Birmingham.

As well as meeting, greeting and talking to the many people

RoSPA's Expo stand: the home of health and safety

who came by to say hello, we also hosted Stocksigns, our safety signs partner, and DBDA, the new home of RoSPA’s products.

Visitors to the stand were invited to enter a prize draw to win a place on the prestigious NEBOSH National Diploma in Occupational Health and Safety, or an MORR Review for their organisation.

Additionally – and extremely successfully – we had a cyclone game on-stand. Participants had 30 seconds to catch as many red balls as they could and put them in a box, with the winner taking home an iPad2. Sounds easy enough, doesn’t it? I have it on good authority that it was much more difficult than it looks or sounds!

Tom Mullarkey scrabbles around in our on-stand cyclone game

The winner put away 11 red balls – while RoSPA’s deputy chief executive Errol Taylor, and Andreas Nicoli, one of our stand hosts, managed to put away 13 red balls while squashed into the box together – but as it was a joint venture, they were jointly disqualified!

Tom Mullarkey, RoSPA’s chief executive, said: “RoSPA was once again proud to be a part of this year’s Safety and Health Expo success story. The RoSPA stand was a real triumph, with the cyclone game attracting a huge number of willing participants all keen to enter our competition.

“Expo is always a great opportunity to meet our colleagues and fellow professionals, and hear about the good work they’re doing on the ground. This year was no exception; we were able to meet and talk to a great many people – old friends and new. Our stand saw an excellent level of footfall, and we established plenty of new relationships with event-goers.

“The calibre of stands and exhibitions was extremely high, and everyone involved can be very proud of their contributions to an excellent event.”

As far as other stands went, the favourite of this intrepid Expo explorer was The Explosion Stand – otherwise known as Denios. They demonstrated what could happen when reactive substances come together in an unplanned manner – with extremely loud results. It was all great fun – and had a serious message at its heart, which was communicated to the audience impressively.

The explosions could be heard from the other end of the NEC – and the NEC is a BIG place!

The RoSPA Occupational Health and Safety Awards

Every year, RoSPA seems to break records with its award entries. This fact flies in the face of what the popular media would have you believe – that “elf ‘n’ safety” is nothing more than a bothersome irritant, something to be given lip service and complained about.

Guests enjoying Wednesday night's gala dinner

However, our awards ceremonies tell a different tale. More than 1,800 organisations entered this year’s awards; the majority of awards are non-competitive, and are a prestigious way of celebrating and publicising commitment to continuous improvement in accident and ill health prevention. RoSPA’s awards scheme encourages firms to adopt a sound health and safety culture from the top to the bottom of their organisation – and instil a sense of pride and enthusiasm.

At the gala dinners which took place each evening after the presentations, the major awards were announced – and the feeling of pride was palpable from the hundreds of dinner guests. It isn’t just a good night out on the company dime; winners genuinely look forward to these events, and see them as an opportunity to show off their skills, good reputation, and commitment to their workers. And, not only do our awards provide well-deserved recognition for the winners, but they also encourage other organisations to raise their standards of accident and ill health prevention. We look forward to seeing all our winners again next year!

Tom Stade: a funny man

After the evening meal, we were treated to entertainment by Canadian comedian Tom Stade, who has written for Tramadol Nights and appeared on One Night Stand, and Stand Up For The Week.

He was extremely funny, waxing lyrical on the joys of Primark, Argos’s ordering system, and the local meat seller from Wolverhampton – as well as handing out marriage guidance advice to all and sundry.

All in all, the three days of Expo and Awards went with a bang and a fanfare – a roaring success enjoyed by all.

 

Vicky Fraser – Press Officer/Web Editor for RoSPA

 

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

RoSPA’s reaction to the DWP minister’s speech

Like me, many of you will have been considering the announcement made by Department for Work and Pensions minister, Chris Grayling. I attended the Round Table event on March 21 with key players from the health and safety community, to find out more about the future of health and safety. Called “Good Health and Safety, Good for Everyone”, it outlines a series of steps to be taken by his department.

He said that proactive health and safety inspections by the HSE (Health and Safety Executive) would be a cut by at least a third, with future targeted inspections focusing on “high risk” locations, such as major hazard facilities and on “rogue employers”. In future, such rogue employers would have to pay the cost of HSE investigations into their activities (fee-for-fault) if these showed them to be in breach of health and safety law. His statement also covered the successful launch of the Occupational Safety and Health Consultants Register (OSHCR) and the simplification of risk assessment for SMEs via a new online advice package for small and “low risk” employers.

And he announced that there is to be a(nother) major review of health and safety law by Professor Ragnar Lofstedt of Kings College London, with a view to simplification and the scrapping of unnecessary requirements and clarifying “the legal position of employers in cases where employees act in a grossly irresponsible manner”.

At one level there seemed to be a shift in tone towards recognition of the importance of health and safety to people and to business success. On the other hand much of what Mr Grayling said seemed to focus on accidents rather than the much bigger problem of occupational health. And he repeated many of the ideas underpinning the Lord Young Review such as “changing the health and safety culture that causes so much frustration in Britain today”.

What was interesting, though, was the strong emphasis Mr Grayling put on levelling the playing field for all businesses through the HSE getting tough with offenders. The flip side of this, of course, is that the Government is cutting the HSE’s resources by 35 per cent by 2014-15. Inevitably this will put them in a much more reactive position with fewer resources devoted to proactive interventions, whether through inspection or education.

The announcement contained the news that in the future, proactive inspection will cease in sectors such as agriculture, quarries, and health and social care where it is not thought to be effective, and that in many “lower risk” areas it will end altogether. The HSE is also having to scale back much of its information and awareness-raising work.

The minister repeated the key message in Lord Young’s review (with which we all agree of course) about the need for proportionality in relation to risk but he did not really spell out the cost of health and safety failures to the UK economy – up to three per cent of GDP – nor indeed the massive business case for good health and safety performance at company level and its potential contribution to business recovery.

He also seemed to reflect some of the other erroneous assumptions underpinning that Review, namely that businesses in the service sector are mainly “low hazard” and thus need only a light touch and that health and safety performance is mainly about reducing the reportable injuries figures (and not the much greater problem of cutting underlying work-related mortality and morbidity).

Focusing on RIDDOR notifiable injuries as the prime performance indicator tends to obscure the true extent of work-related death, injury and ill health including, for example, work-related road injuries (which are about five times higher than those recorded in RIDDOR), deaths due to work-related health damage (particularly from asbestos where many thousands more are expected to die with no immediate decline in sight) and the huge toll of work-related ill health (due especially to musculoskeletal disorders and stress).

And the suggestion that health and safety risks are less significant in “low hazard” workplaces while true in one sense, tends to gloss over the fact there are still lots of important issues that need to be properly managed in these settings: for example, in schools, shops and offices.

One of the issues which seems to be exercising industry most is the idea of the HSE adopting “fee-for-fault” cost recovery. This is not a system of administrative penalties related to the seriousness of any breach, but is designed to recover the costs involved in serving improvement notices needed to remedy breaches in order to control significant risks.

In many ways it simply follows the long-established principle in the environmental field that the polluter should pay. On the other hand, concerns are being raised in various quarters about whether this system might skew the HSE’s operational priorities or adversely affect its relationship with duty holders. And there could well be accusations in the popular press that the HSE is just chasing employers to raise revenue for the Government.

There are dangers here of course: the HSE will need to feel its way. But in my view fee-for-fault cost recovery is not the real issue. The far greater challenge for the health and safety community is how to come up with creative ideas to help make good the reduction in the HSE’s awareness-raising and educational role.

The Government’s critics seem to be focusing all their commentary at present on the HSE’s investigation and enforcement capacity (for example, the BBC R4 programme “File on 4” on March 7).

Enforcement is critically important. But my own view is that the fundamental value of education and awareness-raising in reducing casualties at work is being overlooked. Some have only ever seen it as a bolt-on to the HSE’s regulatory role while many of their critics take the view that it is not really effective anyway.

The HSE already works with a range of partners but we at RoSPA believe that developing an even closer partnership with us, the groups, the trade associations and the various professional bodies would produce great results and also avoid much of the bureaucracy and overkill which the Government fears can result from an unprofessional approach.

So while obviously we may need to debate issues arising from reduced inspections, the new fee-for-fault system and the Loftstedt review, filling the awareness-raising, information and advisory gap is actually critical too.

If we are to sustain the improvements in performance which have been made in recent years, all of us in the health and safety community now need to work together to boost a proactive approach to health and safety. People’s lives and health depend on it.

Roger Bibbings

RoSPA’s Occupational Safety Adviser