GUIDANCE
The author says: “As with Work at Height, well-written procedures, guidelines, and training requirements, and consistency in controlling Confined Spaces, are required.”
to control the health and safety risks of the work, as is common practice, but instead to ensure that there is no unintended interruption of medical gas supply. What this means in turn is that the NHS, and the wider healthcare estate in general, are missing an overriding, centrally driven set of Policies, Procedures and Safe Systems of Work that do focus on the health and safety of the workforce. Until such a time that all the high-risk activities on the healthcare estate are addressed, and a central system is developed for the other areas of concern (think JSP 375 for the Ministry of Defence estate), each Trust will continue to be left to fend for itself, and in such an instance one of two things usually happens: either nothing is put in place, the workforce is still at risk, and accidents continue to happen, or Trusts end up paying out large sums for external companies to provide solutions to problems that could (and should) have been addressed centrally years ago. The short answer is that we need
to consider both the welfare of the patient, and the health and safety of the workforce (and any third parties who may be affected by their acts or omissions). The HTMs need to include all high-risk activities across the estate. HTM 00 and the other current suite of documents will need updating to reflect the importance of health and safety, rather than it being an afterthought. There are several benefits to having
a centralised suite of health and safety procedures for all high-risk activities across the health estate. Among these are: 1 Cost: Having a central set of procedures to refer to means that Trusts will be able to save time and money not having them produced at a local level. There will also be a marked reduction in HSE fines, enforcement notices, and fees for intervention for non-compliance with
58 Health Estate Journal April 2024
Boilers and Pressure Systems are ‘an often overlooked or misunderstood’ Safe System of Work, Ashley Morpeth maintains.
health and safety Acts and Regulations.
2 Commonality: Much in the same way that the HTMs already provide a common system of reference across the entire estate, expanding them to include a full set of health and safety procedures will ensure that everyone is working in the same way, to the same standards, and thus that benchmarking between Trusts will be possible. With a bit of tied- together thinking this could also feed into the Premises Assurance Model (PAM).
3 Accident reduction: Unfortunately, because of a lack of central direction, there are a lot of sites that are still not doing all that is required, and – as a result – accidents still happen. Having central procedures with a focus on ensuring health and safety compliance at a local level will reduce accident statistics.
So, what things specifically, do I think are missing?
Work at Height Now this is often a controversial subject, but it really shouldn’t be. Work at Height is the biggest risk, not just in healthcare estates, but in the workplace in general. Falling from height is the most common cause of fatal injury in the workplace, accounting for approximately 25% of all fatalities annually. So why do some people still not take it seriously? In the past 10 years there have been over 500 successful prosecutions involving a breach of the Work at Height Regulations 2005. What is needed is a well-written, clear set of central procedures, guidelines, and training requirements, and some consistency in the way we approach Work at Height. I sometimes get sneered at when I suggest implementing a HTM-style system for Work at Height, as it ‘isn’t engineering’, but why not? What do we think is happening when someone is working at height? They aren’t up there for
the fun of it, but rather to perform work that will ultimately be engineering of one form or another. It’s thus incumbent on us to ensure that they are safe while that happens.
If people are familiar with the HTM
hierarchical structure, familiar with the terminology, and familiar with the processes, then why not keep that consistency and commonality throughout all the different disciplines? This would also help to achieve compliance with the Work at Height Regulations 2005, and the Management of Health and Safety at Work Regulations 1999.
Confined Spaces It is difficult to obtain precise statistics on fatalities in Confined Spaces in the UK, partly due to the fact that the HSE does not publish them (they end up being hidden in the construction statistics). However, according to various sources, it is estimated that an average of 15 people die each year in the UK as a result of work carried out in Confined Spaces, and that many others are often seriously injured. Now this isn’t going to be another article on what a Confined Space is, and why they are so dangerous (there are many existing such articles). As with Work at Height, however, a well-written set of procedures, guidelines, and training requirements, and a consistent approach to controlling Confined Spaces, are required – including the ability to audit and monitor the management system, and a HTM-style system is best placed for that. Again, I encounter reluctance at times for it not being an engineering discipline, but again, my answer always remains the same. What is it you think we are doing in these spaces if not performing engineering works? Unfortunately, the lack of understanding of the requirements of the Confined
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