Part 4:

Improving safety performance

Part 4: Improving safety performance

Contents
Improving Health and Safety Performance ................................................................. 3
Plan ......................................................................................................................... 4
Health and Safety Policy ...................................................................................... 4
Plan for Implementation ....................................................................................... 4
Do ........................................................................................................................... 5
Identify the organisations risk profile.................................................................... 5
Organise for health and safety ............................................................................. 5
Implement the plan .............................................................................................. 5
Check ...................................................................................................................... 6
Measure performance .......................................................................................... 6
Act ........................................................................................................................... 6
Review performance ............................................................................................ 6
Act on lessons learned ........................................................................................ 6
Responsibilities .......................................................................................................... 7
Individuals ............................................................................................................... 7
Safety Representatives / Representatives of Employee Safety .............................. 7
Contractors ............................................................................................................. 9
Enforcement Officers ............................................................................................ 10
Systems and Procedures ......................................................................................... 12
Emergency Procedures ........................................................................................ 12
Safe Systems of Work (SSW) ............................................................................... 13
Permits-to-Work (PTW) ......................................................................................... 14
PPE ....................................................................................................................... 15
Safety Signs and Signals ...................................................................................... 17
First Aid Arrangements ......................................................................................... 18
Accident Reporting................................................................................................ 19

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Improving Health and Safety Performance

Health and safety is managed in the same way as any other aspect of business.
Management control is typically exerted through a cycle of Planning, Doing, Checking and
Acting (PDCA).
Plan: establish the objectives
and processes necessary to
deliver results in
accordance with the
organisations
health and safety
policy.

Do: implement
the process.

Plan

Do

Act

Check

Act: take actions

to continually
improve health and
safety performance.

Check: monitor and

measure processes
against health and
safety policy, objectives,
legal and other requirements;
report the results.

Figure 14: PDCA Cycle

Figures 15 and 16 show the structure of a health and safety management system designed
in accordance with the guidance in
Control link
HSG 65 Successful Health and
Policy
Information link
Safety Management.
HSG65 is the HSEs guidance for
Successful health and safety
management; it was first published
in 1991 and until 2013 was
structured around the POPIMAR
model shown in figure 15.
The third edition of HSG65 was
published in December 2013. The
guidance is now entitled Managing
for Health and Safety and is
structured around a Plan Do
Check Act model as shown in

Organising

Auditing

Planning and
implementing

Measuring
performance

Reviewing
performance

Figure 15: HSG65 Model 1991 2013

figure 16 and outlined thereafter.

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The change to a Plan Do Check Act model is intended to strike a balance between
the systems and behavioural aspects of management; and to treat health and safety
management as an integral part of good general management rather than as a stand-alone
system.
The key actions involved in delivering effective arrangements are shown in figure 15 and
described below:
Plan
Planning

Risk
profiling

policy

Plan for
implementation

Profile risks

Organise for health

and safety

Implement your plan

Measure
performance

Monitor before
events

Investigate after
events

Review performance

Act on lessons

Organising

Do
Policy

Plan
Act

Implement
your
plans

Do

Check

Check
Measuring
performance

Learning
lessons

Reviewing
performance

Determine your

Investigating
accidents/
incidents/
near misses

Act

Figure 16: HSG65 Version 3 Plan Do Check Act

learned

Plan
Health and Safety Policy
An effective health and safety policy should:

Determine clear organisational goals and set a clear direction for the organisation to
follow;

Demonstrate senior management commitment continuous improvement;

Identify roles and responsibilities for implementing the policy;

Explain the organisations approach to fulfilling its legal and moral obligations to that
satisfaction of interested stakeholders; and

Show that cost-effective approaches to preserving and developing physical and human
resources will reduce financial losses and liabilities.
Plan for Implementation

Establish the organisations current level of health and safety management and the future
state of best practice
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Decide how performance will be measured using both active (leading) and reactive
(lagging) indicators.

Establish effective plans for dealing with fire and other emergencies.

Co-operate with other organisations sharing the workplace and co-ordinate plans with
them.

Plan for changes and identify any specific applicable legal requirements.

Do
Identify the organisations risk profile

Identify what could cause harm in the workplace, who could be harmed and how

Assess the risks and determine what needs to be done to manage the risk.

Identify the most significant risks and decide what the priorities are.

Organise for health and safety

This refers to activities in four key areas (the 4 Cs that together promote positive health
and safety outcomes:

Controls within the organisation: the role of supervisors leadership, management,

supervision, performance standards, instruction, motivation, accountability, rewards and
sanctions; and controls for managing contractors;

Co-operation between workers, their representatives and managers through active

consultation and involvement;

Effective communication across the whole organisation through systems that effectively
manage the flow of information, coming into the organisation; being shared within the
organisation; and going out from the organisation; and

Competence of individuals through recruitment, selection, training and coaching, to

ensure that workers have the necessary skills and knowledge to carry out their work
safely and without risk to their health; and access to competent health and safety advice
including specialist help where required.

Implement the plan

Ensure any necessary preventive and protective measures are put into place.

Provide suitable tools and equipment and maintain them in safe working order

Train and instruct all workers as necessary to ensure they are competent to carry out
their work.

Provide an appropriate level of supervision to ensure that all preventive and protective
measures are properly utilised.

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Check
Measure performance

Check that the plan has been properly implemented paperwork on its own is not a
good performance measure.

Determine how well aims and objectives are being achieved.

There are many different types of monitoring but they can generally be categorised as either
active or reactive:
Active methods monitor the design, development, installation and operation of
management arrangements. These tend to be preventive in nature, for example:

Routine inspections of premises, plant and equipment by staff;

Health surveillance to prevent harm to health;

Planned function check regimes for key pieces of plant; and

For larger more complex organisations, or organisations with significant hazards formal
auditing may be required.
Reactive methods monitor evidence of poor health and safety practice but can also identify
better practices that may be transferred to other parts of a business, for example:

Investigating accidents and incidents; and

Monitoring cases of ill health and sickness absence records.

Act
Review performance

Learn from accidents and incidents, ill-health data, errors and relevant experience,
including from other organisations.

Revisit plans, policy documents and risk assessments to see if they need updating.

Act on lessons learned

Learning lessons involves acting on:

Findings of accident investigations and near-miss reports); and

Organisational vulnerabilities identified during monitoring, audit and review processes.

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Responsibilities
Individuals
All employees should be clear on their role and responsibilities for health and safety; and be
provided with appropriate information, instruction, training and supervision to ensure
competence and the ability to work safely.
Competence is the ability to do a job to the required standard. It is achieved through a
combination of skill, knowledge, positive attitude, training and experience.
Many accidents occur because of inappropriate behaviour rather than a lack of skill or
knowledge.
The relationship between attitude and behaviour is complex.
An attitude represents an individual's degree of like or dislike of an object, (person, place,
thing, or event); and involves the individuals thoughts, feelings and predispositions to act
towards the object. (i.e. involves the head, the heart and the hands!). Behaviour is the
action.
Attitudes can be modified as a consequence of feedback on behaviour and are also
influenced by the prevailing attitude of a peer group
As a result people with generally good attitudes can behave badly and people with poor
attitudes can be made to behave well.

Safety Representatives / Representatives of Employee Safety

The workforce should be consulted about anything in the workplace that could substantially
affect their health and safety. In general this will include:

any change which substantially affects health and safety, e.g. new or different
procedures, new equipment, or new shift patterns;

the arrangements for appointing competent person(s) to help meet health and safety
obligations e.g. health and safety advisor;

information on the likely risks in the workplace and the precautions to be taken;

the planning of health and safety training; and

the health and safety consequences of new technology.

Consultation may be directly with all employees or via their safety representatives (in a
workplace where the employer recognises trades unions for common bargaining purposes)
or their elected representative of employee safety.
The functions, rights and entitlements of safety representatives and representatives of
employee safety are summarised in table 10.
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Safety Representatives
Functions

to investigate: hazards and

dangerous occurrences; the
causes of accidents; and
members complaints;
to carry out inspections: three
monthly with notice; after a
substantial change; or
following a RIDDOR report;
to make representations to
the employer;
to consult with and receive
information from inspectors;
to attend safety committee
meetings; and
to inspect and take copies of
any relevant document.

Representatives of Employee
Safety
to make representations to
the employer on potential
hazards and dangerous
occurrences at the
workplace;
to make representations to
the employer on general
matters affecting the health
and safety at work of
employees; and
to represent the group of
employees in consultation
with enforcement officers.

time off with pay, during

training as is reasonable,
working hours, for performing
paid for by the employer;
their functions; and
paid time off as necessary for
undergoing training
performing their functions;
Reasonable facilities and
and
assistance for the purpose of Reasonable facilities and
carrying out their functions.
assistance.
Table 10: Safety Representatives and Representatives of Employee Safety
Rights and
entitlements

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Contractors
Where clients use contractors there are shared responsibilities for ensuring the health and
safety of client and contractor workforces and anyone else who may be affected by the work.
Health and safety requirements should clearly define the responsibilities of each party.
The HSE advocates a five step approach on how to manage contractors and ensure safe
working:
Step 1: Planning
The client should clearly identify all aspects of the work they want the contractor to do. The
client and contractor should both be involved in the risk management process and should
agree the controls required before the work begins.
Step 2: Choosing a Contractor
Contractors should be selected based upon a range of criteria including: availability, cost,
technical competence, reliability and health and safety.
The client has to take reasonable steps to satisfy themselves that the contractor is
competent to do the job safely and without risks to health and safety.
The best way of being satisfied of a contractors competence is through first-hand
experience; otherwise a pre-tender questionnaire (PTQ) may be used to broadly determine
the suitability of a contractor.
Step 3: Contractors Working On Site
Specific arrangements are required to:
Manage the movements of contractors on site through visitor sign in controls and possibly
permits-to-work;
Ensure that all technical and management controls are in place before allowing the work
to begin (e.g. correct work equipment and personal protective equipment is available,
safe system of work or permit to work in place);
Ensure regular meetings are held to facilitate effective co-operation and co-ordination of
client and contractor activities; and
Provide staff and contractors with all necessary safety information.

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Step 4: Monitoring the contract
The client and contractor should monitor their health and safety performance to check that
risk assessments are current and that control measures are effective.
The level of monitoring depends on the risks - the greater the risks, the more frequent the
monitoring.

Step 5: Reviewing the Work

The client should review both the job and the contractor. Consideration should be given to:
the effectiveness of the planning; the contractors performance; and how smoothly the job
went.

Enforcement Officers
Responsibility for enforcement of health and safety legislation is allocated based upon the
main activity undertaken at a workplace. The Health and Safety Executive (HSE) typically
enforces in higher risk workplaces such as factories and construction sites. The local
authority environmental health department (EHO) has responsibility for retail, office and
recreational workplaces and the Office for Railway Regulation (ORR) looks after railway
safety,
Powers of Inspectors
All authorised inspectors have the same powers, regardless of the area of enforcement.
Inspectors can:

enter any premises which they think it necessary to enter for the purposes of enforcing
health and safety law at any reasonable time or at any time if dangerous;

take a police constable with them if they anticipate serious obstruction;

take any other authorised person and any equipment needed;

order that areas be left undisturbed;

take measurements, photographs and samples;

carry out tests on, and/or confiscate articles and substances;

seize any article or substance which presents an immediate danger of serious personal
injury and have it made harmless, by destruction if necessary;

inspect and take copies of relevant documents; and

interview and take written statements from anyone they think might give them relevant
information.

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Enforcement Action
Inspectors have a range of enforcement options and tools available including:
Informal advice Based on level of risk and level of management cooperation an
inspector may deal with a situation informally by verbal advice or
an explanatory letter. Provided agreed actions are completed on
time no formal action will be taken.
Improvement
May be served whenever health and safety legislation is being
Notice
contravened. The notice will specify the breach of legislation and
may specify a means of complying. It has to allow a reasonable
time (minimum 21 days) to complete any specified works.
Prohibition
May be issued when the inspector considers that there is a risk
Notice
of serious personal injury. The notice prohibits the carrying on of
the work activity giving rise to the risk of injury.
Prosecution
Any breach of legislation may give rise to a prosecution in the
criminal courts. Maximum penalties for serious health and safety
offences are:

Prison sentence not exceeding 2 years and/or

Unlimited fine
The best option(s) will be chosen in each case. There is no hierarchical escalation route
from informal advice to prosecution.
Enforcement officers have to bring any concerns to the attention of employees (or their
representatives) as well as to the employer, for action.

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Systems and Procedures

Emergency Procedures
The risk assessment process should identify the potential for emergency situations (events
which pose a serious or imminent danger).
Risk control measures should include emergency procedures for a range of eventualities
such as:

Fire and explosion;

Workplace accidents and first-aid emergencies; and

Environmental emergencies, including flooding.

The employer is required to:

prepare procedures for employees to follow in the event of serious or imminent danger,
to communicate them to employees and to appoint competent persons to put them into
effect; and to

make any necessary contacts with external services regarding first-aid, emergency
medical care and rescue work.

The following items should be addressed in systems for assuring an effective emergency
response.

Identification of plausible emergency scenarios through the risk assessment process;

Clear identification of roles and responsibilities for those with specific tasks to undertake
during an emergency;

Communication of emergency procedures to staff and third parties and the organization
of appropriate staff training;

Regular inspection of emergency equipment to ensure it remains effective and ready for
use; and

Regular emergency drills with systems in place to identify weaknesses, learn lessons
and improve.

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Safe Systems of Work (SSW)

The Health and Safety at Work Act requires employers to provide, so far as is reasonably
practicable, systems of work that are safe and without risks to health.
The HSE defines a safe system of work (SSW) as:
a formal procedure which results from a systematic examination of a task in order to identify
all the hazards. It defines safe methods to ensure that hazards are eliminated or risks
minimised.
A SSW is required when hazards cannot be eliminated and a degree of risk remains after
technical control measures are introduced.
Assessing the Task / Identifying the Hazards
There are various ways of systematically analysing a task. A common approach considers:
What plant, equipment or materials are being used;
Who is responsible for what during the task;
Where the work is to be undertaken identifying local hazards; and
How the task is done.
A simple SSW may be defined verbally, as a written procedure or become a formal Permitto-Work (PTW) (discussed later), depending on the level of risk and the needs of the
organisation.
In all cases the SSW should:
Consider the preparations and authorisations necessary before beginning work;
Ensure the job sequence is logically and clearly planned;
Specify safe methods for undertaking specific activities;
Specify safe means of access and egress if relevant; and
Consider the end of activity tasks such as dismantling and disposal.
Implementing the System
The co-operation of the workforce is essential to the success of the SSW. Employees should
be consulted and involved in the development of the SSW.
The content of the SSW and managements commitment to it must be clearly communicated
to all employees.

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Managers and supervisors will also require training to enable the effective implementation
and ongoing monitoring of the SSW
Monitoring the System
Once implemented, the SSW will require periodic monitoring to ensure that it is workable
and that employees are comfortable following it.

Permits-to-Work (PTW)
A SSW is adequate for most work activities, but some require extra care. A PTW is a more
formal system stating exactly what work is to be done and when, and which parts are safe.
Examples of high-risk jobs where a written permit to work procedure may need to be used
include: hot work such as welding; vessel entry; cutting into pipe-work carrying hazardous
substances; and work that requires electrical or mechanical isolation.
A PTW is not simply permission to carry out a dangerous job. It is an essential part of a
system designed to ensure that authorised and competent people have thought about
foreseeable risks and that those risks are avoided by using suitable precautions.
It also requires those carrying out the job to think about and understand how they are going
to carry out their work safely, and to take the necessary safety precautions.
An effective PTW requires systems to ensure correct:
Issue by a competent issuing authority setting the parameters of the permit and
confirming that precautions are in place;
Acceptance by a competent worker (performing authority) confirming understanding of
the work to be done, hazards involved and corresponding precautions;
Hand back of the PTW, by the performing authority, confirming that the work has been
completed to plan; and
Cancellation of the PTW by the issuing authority confirming the work has been tested
and the work area returned to normal use.
Additional procedures are required for extension of agreed time limits if necessary and
for managing shift handovers.

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PPE
The employer has a duty to provide suitable PPE to employees who may be exposed to a
risk to their health and safety while at work, except where the risk has been adequately
controlled by other means.

To be suitable PPE must be fit for purpose, i.e.:

be effective in preventing or controlling the risk involved without increasing the overall risk
(so far as is reasonably practicable);
be appropriate for the working conditions;
be compatible with other PPE; and
fit the wearer correctly.
Any PPE provided should be CE marked to demonstrate compliance with relevant European
standards.
PPE is a last resort
PPE is the last resort of control measures for the following reasons:
it does nothing to prevent the harmful event;
it only protects the wearer, not other persons in the vicinity;
it relies on the wearer to wear it correctly;
it may impede movement, visibility or communication;
it may only be effective for a limited time, e.g. until a respiratory filter or chemical gloves
become saturated.
It may only be effective in specific circumstances e.g. a respiratory filter is only effective
against specific contaminants;
The effectiveness of PPE is difficult to assess but maximum levels of protection are
unlikely to be achieved;
it exposes the wearer to danger should it fail; and
it requires effective systems for regular inspection and maintenance.
Maintenance and replacement of PPE
Any PPE provided has to be maintained in an efficient state, in efficient working order and in
good repair.
An effective maintenance system includes the following:
(a) examination - checking for faults, damage, wear and tear, dirt etc. All PPE should be
examined, by a competent person, to ensure it is in good working order before issue;

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(b) testing - to ensure PPE is operating as intended. Records of tests and examinations
should be kept;
(c) cleaning cleaning and disinfection are particularly important for shared equipment to
control health risks to the next wearer;
(d) repair repairs should only be carried out by a competent person. Simple repairs may
be undertaken by the wearer.
(e) replacement If PPE exceeds its shelf-life, or is so badly damaged that it cannot be
used safely or repaired systems are required to ensure safe disposal and timely
replacement.
Appropriate Accommodation for PPE
Appropriate accommodation should be provided for storing PPE when it is not being used, to
protect against:
(a) damage from chemicals, sunlight, high humidity, heat and accidental knocks;
(b) contamination from dirt and harmful substances; and
(c) the possibility of losing the PPE.
Information, instruction and training
Employees should be provided with appropriate information, instruction and training to
understand: the risk(s) which the PPE will avoid or limit; when and how to use the PPE; and
how to keep the PPE in good working order.
Use of PPE
Employees are required to use any PPE provided in accordance both with any training,
information and instruction received regarding the use of the PPE.
Arrangements are required for appropriate levels of supervision and monitoring.

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Safety Signs and Signals

The Health and Safety (Safety Signs and Signals) Regulations 1996 require employers to
provide, and maintain, a safety sign where there is a significant risk to health and safety that
has not been avoided or controlled as required under other legislation, provided it can help
reduce the risk.
Safety signs are not a substitute for engineering controls and safe systems of work, they
should be used to warn of any remaining significant risk or to instruct employees of the
measures they must take in relation to these risks.
Safety signs need to contain a pictogram to convey the message instead of relying solely on
text, the standard signs are presented in table 11.
Prohibition (Red)
Prohibits behaviour likely to increase or cause danger (e.g. no
access for unauthorised persons or no smoking).

Warning (Yellow)
Giving warning of a hazard or danger, e.g. danger: electricity.

Mandatory (Blue)
Must be done, prescribing specific behaviour, (e.g. eye
protection must be worn)

Safe Condition (Green)

Information on emergency exits, first-aid, or rescue equipment
and activities.

Fire Fighting Equipment (Red)

Information on the identification or location of fire-fighting
equipment.

Table 11: Standard signs

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First Aid Arrangements

First-aid means:
(a) treatment for the purpose of preserving life and minimising the consequences of injury
and illness until medical help is obtained; and
(b) treatment of minor injuries which would not need treatment by a medical practitioner or
nurse.
Employers have to ensure that sufficient first-aid equipment, facilities and personnel are
made available to:

give immediate assistance to casualties with both common (i.e. non work related) injuries
or illnesses and those likely to arise from specific hazards at work; and to

summon an ambulance or other professional help.

Where the assessment identifies a need sufficient numbers of first-aiders should be

provided, at appropriate locations, to enable prompt treatment whenever necessary.
Where a first-aider is deemed unnecessary an appointed person may be allocated
responsibility to:

take charge of the first-aid arrangements;

look after the equipment and facilities; and

call the emergency services when required.

A suitable record should be kept of any first aid incidents. Where there are a number of firstaiders and/or appointed persons working for a single employer, one central book should be
used.

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Accident Reporting
Accidents and near misses both provide an opportunity for the organisation to learn from
experience and to improve its safety controls to prevent a recurrence.
Systems should be in place to promote the active reporting of accidents and near misses
and workers should be clear that the purpose is to provide an opportunity for the
organisation to learn and improve and not to apportion blame.
The Reporting of Injuries Diseases and Dangerous Occurrences Regulations 2013
(RIDDOR) also require the employer to report certain work-related accidents to the enforcing
authority (HSE, ORR or EHO) by the quickest possible means.
The following accidents must be reported:
Deaths arising out of or in connection with work;
Specified major injuries include:
-

bone fractures diagnosed by a registered medical practitioner other than to fingers,

thumbs or toes

amputation of an arm, hand, finger, thumb, leg, foot or toe

any injury diagnosed by a registered medical practitioner as being likely to cause

permanent blinding or reduction in sight in one or both eyes

any crush injury to the head or torso causing damage to the brain or internal organs
in the chest or abdomen;

Over-7-day injuries where an employee or self-employed person is away from work or

unable to perform their normal work duties for more than 7 consecutive days (up until
April 2012 this was over 3 day injuries);
Non-fatal injuries to non-workers - where any person not at work suffers (as a result of
a work-related accident) an injury, and that person is taken from the site of the accident to
a hospital for treatment in respect of that injury; or a specified injury on hospital premises;
Some work-related diseases including:
- Occupational dermatitis, where the persons work involves significant or regular
exposure to a known skin sensitiser or irritant;
- Occupational asthma, where the persons work involves significant or regular
exposure to a known respiratory sensitiser; or
- Tendonitis or tenosynovitis in the hand or forearm, where the persons work is
physically demanding and involves frequent, repetitive movements; and
Dangerous occurrences where something happens that does not result in an injury,
but could have done, e.g.: collapse, failure or overturning of lifting equipment; or collision
of a train with another vehicle; and

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The quickest and easiest way to comply with RIDDOR is to call the Incident Contact Centre
(ICC) on 0845 300 99 23. The ICC records the information so there is no need to fill in an
additional report form.
The easiest way to report an
accident, in most cases, is
via the appropriate online
report
form
at
www.hse.gov.uk/riddor.
The form is submitted directly
to the RIDDOR database and
a copy is provided for the
responsible persons records.
Figure 16: On-line Reporting
A telephone service is available for reporting fatal and major injuries only through the
Incident Contact Centre on 0845 300 9923. The service is available during office hours Monday to Friday 8.30 am to 5 pm.
The HSE has an out of hours duty officer available for responding in emergency situations
such as:

a work-related death;

a serious accident with a need to collect physical evidence before it is lost with time; or

a major incident where the severity of the incident, or degree of public concern, requires
an immediate public statement from the HSE or government.

A suitable record should also be kept locally regarding any reportable injury, disease or
dangerous occurrence.

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