COMPLIANCE AND HEALTH & SAFETY
Creating fit-for-purpose Safe Systems of Work
David George, an Authorising Engineer (AE), Mechanical, at Eta Projects with over 30 years’ experience of high-risk Safe Systems of Work (electrical, mechanical, petroleum, confined spaces), and 19 years’ experience as an AE, and a Co-ordinating Authorising Engineer and trainer in the development of Safe Systems of Work, debates some of the issues around the requirement for a formal mechanical SSoW for the healthcare estate.
This article builds on a previous article which appeared in the April 2024 HEJ – titled ‘Limitations with HTMs need addressing’, written by Ashley Morpeth (Eta Projects).1
The
HEJ article stated that ‘People often think that because, for example, they can demonstrate compliance with the Pressure Systems Safety Regulations (PSSR) 2000 (i.e. they have a written scheme of examination for relevant systems, and they are inspected at the required frequencies), they have covered all the bases. This isn’t necessarily true’. The sole requirements of the Pressure Systems Safety
Regulations, in relation to SSoW, are contained in Regulation 92
– Examination in accordance with the written
scheme – ‘The user of an installed system and the owner of a mobile system shall, before each examination, take all appropriate safety measures to prepare the system for examination, including any such measures as are specified in the scheme of examination pursuant to regulation.’
A legal requirement Safe Systems of Work should be part of everything we do at work, and are a requirement of the Health and Safety at Work etc Act, under Section 2,3
General duties of
employers to their employees, which states: ‘It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees… the matters to which that duty extends include in particular – the provision and maintenance of plant and systems of work that are, so far as is reasonably practicable, safe and without risks to health.’ This is one of five duties contained in Section 2 that are
the foundation of health and safety at work. The level of risk exhibited by the system or the task will determine the level of detail of that Safe System of Work. The higher the risk, the more involved, and the more formal, the Safe System of Work will become. This then brings in some of the requirements of the Management of Health and Safety at Work Regulations, in particular Regulation 3 – Risk assessment, Regulation 7 – Health and Safety Assistance and, Regulation 5 – Health and Safety Arrangements. From this, we can interpret a requirement to assess
the mechanical systems for risk, to appoint Authorising Engineers and Authorised Persons (where required), and to look to align the controls on certain mechanical systems with HTM 00. When discussing the requirement for a health estate- specific Mechanical Safe System of Work, I often get the reply ‘Why reinvent the wheel?’ However, this is not reinventing the wheel. There isn’t a health estates wheel out there. At present, for a mechanical SSoW, there are only pieces out there: spokes, rims, and tyres. It is time now to
May 2025 Health Estate Journal 45
fit all these pieces together, using appropriate materials, to produce a functioning and specific wheel, suitable for use within the healthcare estate.
What is a ‘a Safe System of Work’? So, what is a ‘Safe System of Work’? One definition is: ‘A formal procedure which results from systematic examination of a system/task in order to identify all the hazards’. The SSoW defines safe methods to ensure that hazards are eliminated or risks minimised, and: n Combines materials, people, plant, equipment, task, and environment.
n Must have a logical, well-thought-out approach. n Should fully identify and document all the hazards, safety precautions, and safe working practices, associated with all activities performed by employees.
n Must be practical, or will be bypassed and ignored. n Remember non-routine work, as well as normal operations.
The systematic examination could form the basis, for example, of a site survey to look at the risks exhibited by the mechanical systems, and decide what will come under the formal Safe System of Work, and what can be controlled under risk assessments and method statements. The identification of the systems to be covered under
the mechanical SSoW can be problematic. Some obvious ones are such systems as: n Steam. n High temperature hot water. n Medium temperature hot water. n Compressed gases.
A suitable and sufficient supply of lock-off devices and signage is essential.
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84
