Monitor and Review and Close the Health and Safety Loop.

Many Health and Safety systems start off with the best intentions, the policies are prepared, a risk assessment programme is completed, all the employees are briefed and trained and signatures of employee recognition received.

It is often at this point that organisations take a collective sigh of relief, congratulate themselves for having dealt with Health and Safety and complied with their legal duties and turn their attention to the next project, say, quality improvement, environmental systems or launch of a new product or service. This is the time, however, when the organisation needs to take positive steps to ensure the hard work that has gone before is not wasted.

This article stresses the importance of ensuring effective monitoring and review of Health and Safety systems, safety performance and risk assessments.

HS(G)65

HS(G)65 is the Health and Safety Executives guide to Successful Health and Safety Management and contains the following diagram laying out the stages required when building a Health and Safety management system.

Before you can review your system, you need to develop methods of measuring performance. Some measurements are easy to determine, such as the number of accidents or near-miss incidents, others may be applied to Health and Safety actions, such as targets for the completion of risk assessments or to finances, such as measurement of accident costs.

Auditing or monitoring your system or risk assessments allows you to see how well your system or risk assessments are adhered to in practice.

Measurements and the results of auditing form the data on which a system review can take place.

Monitoring

To remain effective, monitoring of a Health and Safety system should be carried out at a frequency that is sufficiently often to ensure that the system is being consistently complied with. This frequency should be determined by the level of compliance demonstrated from previous monitoring and the importance of the part of the system being monitored.

As a general rule, new systems will require frequent monitoring (at least monthly), but as a system matures and the level of compliance rises, the frequency can be reduced. If, however, monitoring starts to show that there are problems with compliance with a mature system, then more frequent monitoring would be one tool which could be used to address these problems.

Similarly, whilst usage may suggest that first aid boxes should be checked at least monthly, you would not want to check levels of employee training on the same frequency (perhaps 3 or 6-monthly).

The frequency of monitoring, therefore, should be tailored to meet each organisation's specific operations, requirements and the history of any previous monitoring.

Review - Management Review

The management review of a Health and Safety system should occur annually and consist of the following objectives:

• to review the previous year's Health and Safety performance against any targets set
• to set new targets for the coming year
• to review any enforcing authority letters or notices and the progress with any corrective actions
• to review accident statistics and accident investigations and any actions taken to prevent reoccurrence
• to ensure that risk assessments have been prepared for any new operations and that existing assessments have been reviewed in the last year.

The review should be a formal meeting at which only Health and Safety issues are discussed. Members of the meeting should include the following as appropriate to the organisation concerned:

• the Board of Directors / Partners / Trustees
• the person responsible for day-to-day Health and Safety
• other Managers / Supervisors with appropriate Health and Safety responsibilities (e.g. the Personnel Manager might have responsibility for Health and Safety training and report on this at the meeting)
• Other Managers / Supervisors do not necessarily have to attend the whole meeting but can be called upon to attend the meeting just to make their specific reports.

Review of Risk Assessments

It is a requirement of all legislation which requires the carrying out of risk assessments (including the Control of Substances Hazardous to Health), that they are regularly reviewed and updated. This is to ensure that they remain fit for purpose and applicable to the tasks assessed. Risk assessments should be reviewed:

• periodically (i.e. every 12-36 months)
• when there are significant changes to processes (e.g. new equipment, change in working practice)
• as the result of accident investigations
• as the result of recommendations from enforcing authority inspectors
• when other factors (e.g. updated material safety data sheet or changes in legislation), would suggest that they need to be reviewed.

A risk assessment review does not require you to risk assess a task again, but requires that you look at your existing assessment and decide whether it still applies to the task it assesses. If, as a result of the review, you decide that an existing assessment is acceptable then you need to make no changes to it, just record the fact that you have reviewed it and the date on which the review took place.

Method Statements

Some organisations are required to prepare method statements. A method statement is a formal procedure for carrying out a task or job safely and often can include or refer to one or more risk assessments. As with risk assessments, you should ensure that any method statements are suitably reviewed using the criteria shown above for risk assessments.

Conclusions

To maintain an established Health and Safety system, it is vital that it is effectively monitored and that it is effectively reviewed. Carrying out these processes should ensure any Health and Safety system is compliant, not only once it has been implemented, but on an ongoing basis. Also, risk assessments and method statements need regular review to ensure they remain fit for purpose.