Policy and Procedures on Risk Management 4 th January 2008 Policy... 1 Procedures... 1 Appointment of assessors and training... 2 Risk Assessment... 2 Health and Safety Action Plans... 4 Background information and guidance for risk assessors... 5 Hazard and Risk... 5 Scope and extent of an assessment... 5 Other legal duties requiring assessments... 6 Setting priorities... 6 Reducing Risks... 7 Records... 7 Assessment Review... 7 Policy It is the Policy of the University to implement the Management of Health and Safety at Work Regulations 1999 (MHSWR). Regulation 3 of MHSWR requires a suitable and sufficient assessment of risk to be made for the health and safety of employees whilst at work and also persons not in the employment of the University, for the purposes of identifying any measures needed to be taken to comply with health and safety legal requirements. Any significant findings following an assessment or any group of employees identified as being especially at risk must be appropriately recorded. The provision of records is an integral part of the risk assessment process. Records will provide positive proof that a risk assessment has been done, will provide a basis for the review process and provide the University with evidence to counter claims for ill health in later years as proof that hazards had been identified and proper precautions taken. Procedures The duty to carry out risk assessments may appear daunting but it is nothing to be feared and should be quite readily managed. 1
Appointment of assessors and training Heads of School/Department are responsible for the implementation of this risk assessment policy and they must appoint a risk assessor. This may well be the Workplace Safety Adviser (WSA) but it does not have to be. In areas where the hazards are likely to be few one person would probably be able to cope. Some areas may wish to share resources. On the other hand in areas where hazards are likely to be frequent and the risks high a number of assessors may need to be appointed. Training of risk assessors, which is mandatory, is carried out by the Department of Occupational Health and Safety, who should be contacted when your assessors are identified. The DOHS must be informed annually as to the name(s) of your risk assessor. Risk Assessment There are many ways of carrying out risk assessments. The following "5 steps procedure" has been adopted by the University's Occupational Health and Safety Committee and agreed by Council as one which is suitable and sufficient, neither over complex nor resource intensive. The Form in Appendix 2 should be used to record assessments. Step 1 - Look for the hazards Assessors should look only for hazards which could reasonably be expected to result in significant harm in your area of work. The following examples can be used as a useful guide; biological agents etc. chemical reactions cleaning dangerous substances electricity emergency situations environment fire lighting maintenance manual handling noise slipping/tripping hazards temperature transport VDU workstation violent behaviour work at height 2
You may wish to discuss your hazard list by talking to other employees or safety representatives of Unions to see what they think. The Workplace Safety Committee should certainly be consulted. Manufacturer's instructions or data sheets can also help to spot hazards and dangerous substances and put risks in their true perspective. Examination of accidents, ill-health and incident reports will also help in this first step. Step 2 - Decide to whom and how harm might occur Consider all staff including those working out of hours. Think about people who may not be in the workplace all the time, for instance cleaners, visitors, contractors, maintenance staff, security personnel etc. Members of the public and students would be included and other people who share the workplace if there is a chance they could be hurt by your activities. Inexperienced staff, lone workers and staff with disabilities may also be persons who are specifically vulnerable. It is also important for Heads of School/Department whose staff work in other areas (e.g. domestic, security and maintenance staff) to be aware of their responsibilities for the safety of these staff. They should consider what hazards such staff encounter, for example in laboratories, and liaise with the other Head of School/Department concerned. Step 3 - Evaluate the risks arising from the hazards and decide whether they are adequately controlled. You may find it possible to remove the hazard altogether and if this is so this is clearly the best solution to adopt. Where it cannot, you may find that precautions are already being taken. For instance Regulations such as COSHH, Manual Handling, VDU, Ionising Radiations etc. all require a risk assessment which by now should have been completed. If in these cases you are satisfied that they accurately represent the true picture then that is all that is required. When considering whether risks are controlled you will also need to examine what information, instruction, training, systems of work and planned maintenance is provided and whether they are truly implemented. The precautions should also take account of any standards which set a legal requirement e.g. British Standard, European Standard any recognised standard set by a legal requirement any recognised industry standard any current good practice the duty to reduce risks so far as is reasonably practicable. Further advice if required can be obtained from the Department of Occupational Health and Safety. You will need to indicate what precautions are in place to ensure that the risks are adequately controlled. Reference may be made to the procedures, safety handbooks, which should give this 3
information. The above should all then be recorded in Column 3 of the Form in Annex 2. Step 4 - Risks not controlled Where risks are identified as not being adequately controlled they should be prioritised and an Action Plan devised. See Appendix I (Setting Priorities). As an example, if the hazard or harm is likely to be serious and the likelihood of it occurring is high then this would score 9 points (3 x 3). On the other hand if the effect of the hazard is slight and the likelihood of harm arising is low then the rating would be 1 (1 x 1). Action Plan An example of an Action Plan is at Annex 3. The higher ratings scored in your Action Plan should normally be addressed first. The following sequence of consideration must be systematically adopted. These are: remove the source of the risk completely try a less risky operation prevent access to the hazard (e.g. by guarding or enclosing) organise work to reduce exposure to the hazard (e.g. numbers exposed, time of exposure) provide personal protective equipment. Step 5 - review and revision of assessments Sooner or later a new machine or substance or procedure could affect the validity of your assessments. If there is any significant change then review should take place to take account of any new hazard. In any case it is good practice to review assessments from time to time and at least once a year. There is no need to amend the assessment for every trivial change nor for each new job unless it introduces a new significant hazard. Health and Safety Action Plans Copies of risk assessments should be submitted to your Head of School/Department and Chairman of your Workplace Safety Committee. Health and Safety action plans including prioritised risks not adequately controlled and subsequent review should now feature routinely on Committee Agendas. 4
Background information and guidance for risk assessors Hazard and Risk It is important to understand the difference between hazard and risk. A hazard can be defined as something with inherent potential for causing harm or injury. Risk can be defined as the likelihood and extent of harm or injury arising from the hazard. Examples of hazards and the associated risks might include: handling of chemical substances - there may be a risk of exposure to the chemical; walking upon floor surfaces - there may be a risk of slips, trips or falls; fire risk - there may be a risk of entrapment due to the failure to maintain fire escape procedures; climbing up or down ladders - there may be a risk of falling from or the collapse of the ladder; use of electrical equipment - there may be a risk of electrical shocks or burns. The extent of risk can only be quantified by an examination of the adequacy of any existing control measures. In example (a) above, factors that would greatly increase risk include use of unlabelled containers, lack of employee training and poor ambient lighting. Those particular risks can be effectively reduced by means of control measures such as ensuring the containers are properly labelled, that employees have sufficient training and that lighting is suitable for the task. Scope and extent of an assessment Suitable and sufficient risk assessment is one that: correctly and accurately identifies the hazard; disregards inconsequential risks and those trivial risks associated with life in general; determines the likelihood of injury or harm arising; quantifies the severity of the consequences and the numbers of people who would be affected; takes into account any existing control measures; identifies any specific legal duty or requirement relating to the hazard; will remain valid for a reasonable period of time; provides sufficient information to enable decisions upon appropriate control measures to be made taking into account the latest scientific developments and advances; enables the prioritisation of remedial measures. 5
Other legal duties requiring assessments A risk assessment does not have to be duplicated in order to satisfy an identical requirement under a differing set of Regulations. For example, many Regulations already require some form of assessment, for example The Control of Substances Hazardous to Health (COSHH 2000), The Noise at Work Regulations 1989, The Manual Handling Regulations 1992, The Visual Display Units Regulations 1992. Where therefore, for example, an assessment made under Regulation 3 of the MHSWR identifies a chemical or a noise hazard then it is likely that the assessment has already been undertaken and therefore no further work is necessary other than perhaps to ensure its validity and that records cross-referencing between the two are made. An assessment must be reviewed when necessary such as where there is a significant change in work or work environment or in the light of subsequent experience. Emphasis should be given to those risks that present the greatest severity. Except where circumstances indicate to the contrary, trivial risks can be ignored as an everyday risk associated with life in general. The time and effort spent on risk assessment should reflect the nature and seriousness of the risk. It is not necessary to produce extensive paperwork to confirm the limited extent of an unlikely and inconsequential event. Setting priorities The risk assessment should enable prioritisation for remedial measures. In many cases it will be clear to the competent assessor that some risks require attention before others. Where there is uncertainty, a "risk rating" may be attributed to each identified hazard by using a simple formula such as given below. The risk rating is the effect of hazard (harm) multiplied by the likelihood of harm occurring (risk), i.e. Risk = Hazard x Likelihood of harm (e.g. Major x Medium = 3 x 2 = 6) Harm (Hazards) Rating Likelihood (Risks) Rating Major 3 high 3 Serious 2 medium 2 Slight 1 low 1 6
It may also be necessary to apply a rating factor to take into account the number of people exposed.) Reducing Risks The University is also under a general duty to reduce risks so far as is reasonably practicable. The following hierarchy of control measures should be used to suit any risk reduction programme; prevent exposure by discontinuing the hazard activity altogether; substitute the activity for a less hazardous one; enclose the hazardous activity or separate the activity from people by other means; organise work to reduce exposure to the hazard e.g. numbers exposed, time of exposure. provide personal protective equipment. Records An assessment must be supported by accurate record keeping except where the assessment is simple and can be easily repeated. The record should contain at least the following information: description of the process or activity assessed; identification of the significant risks; identification of any individuals or groups at particular risk; date of assessment and where appropriate next review; the name of the assessor carrying out the assessment. A permanent and retrievable record must be maintained. Assessment Review An assessment must be kept up to date and must be reviewed periodically to ensure that it remains valid. Assessments should be reviewed at least once a year. Factors that may require an automatic reassessment would include: a change in legislation; a change in control measures; any significant change in the work carried out; transfer to new technology; any other reason to suspect that the original assessment is no longer valid or could be improved. APPROVED BY COUNCIL 15TH MARCH 1996 Minor amendments to text June 2004, Jan 2008 7