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WORKPLACE SAFETY


and construction work resumes, another more pressing obligation is also starting to rear its head – the return of the health and safety review. Surprise inspections from the Health & Safety Executive have always been a reality for site managers, but now, they are upping their frequency and their visibility, and the construction industry needs to be ready. Why now? Well, it largely comes down to


the sudden increase in activity after a two- year hiatus. Even before Covid ground the world to a halt, the construction industry was notorious for its tight timetables and deadlines. In other words, a lot needed doing in a short space of time. This will only have intensified as businesses look to make up for lost time and get projects back on track. While this does not necessarily mean the industry will sacrifice quality for speed, it does make it more likely that risk assessments, site audits and PPE checks could be overlooked. For the construction industry, health and


safety is non-negotiable, even when there is a deadline at stake. It is consistently amongst the top three sectors in the UK for the greatest number of fatal and non-fatal accidents each year, and comes with numerous occupational health hazards, such as asbestosis, hearing loss and dermatitis, to boot. As well as costing lives, poor practice in


health and safety is expensive, it causes delays to projects and can permanently scar the reputation of a contractor or company. But this is exactly what can happen if health and safety is left to chance, and an inspector comes calling. The last thing any construction company needs, or wants, is a Prohibition or Stop Notice being served. That is why embedding good practice across your site, your workers, your supply chain and surroundings is vital, whether you are expecting a visit or not. Health and safety may feel like a


complicated web of rules, regulations and boxes to tick, but it does not have to be. There are a few key areas that, once nailed, can trickle down into, and improve, other aspects of your construction practices.


First things First: reFresh your risk assessments


A risk assessment is not a pretty folder that is only whipped out when the HSE comes calling - it is a living document that everyone on site should be aware of and engage with. It also influences all aspects of your site – from PPE to layout. If your site has been sitting quietly for a while, it is vital that you review your risk assessments now to make sure they are all still relevant. Has your team dynamic changed, for example? Are there any skills gaps? Have you had to add / change equipment to meet new project deadlines? Have there been significant changes to the site or its surroundings? A two-year-old risk assessment is useless and will not cover you if any incidents occur. Take time to review your assessment, as well as all other documents


and policies that this affects, such as training, control measures, handover documents and method statements. Keep the HSE’s hierarchy in mind as you do this: remember, you should prioritise removing a risk over reducing or mitigating it. Once done, re-induct your team on its findings and deliver toolbox talks, regardless of whether any major changes have been made. If you are concerned about the complexity or time requirements of this, consider outsourcing your risk assessments to a professional consultancy.


keep training on track


If an incident occurs on site, training and induction records are some of the first items an HSE representative will ask for. Proof of education and development is even more important now, as some members of staff may have been furloughed or away from the site for an extended period. It is tempting to assume that your people know what they are doing, or that skills will pass from one worker to another by osmosis, particularly if training costs are a concern, but this is short-sighted for several reasons. For one, it is highly likely that workers will pass on bad habits or unsafe practices if they have not also been properly trained. Furthermore, if an incident were to occur due to bad practice, you would have little proof of any actions you had taken to prevent it. Whether or not you choose to outsource your training, you need a training policy – one that highlights who needs to know what, as well as the frequency of updates or refresher courses. I would also recommend using a training matrix: a handy visual representation of your team’s capabilities, as well as any gaps. Records and documents are key.


is your ppe past its BBD?


You have completed your risk assessment, trained your crew, and still identified a few risks that are not reasonable or possible to remove. The next step is making sure you have the right Personal Protective Equipment (PPE) available to reduce or mitigate these risks. Be careful, though, of over-relying on existing PPE. Many of these items will have a limited shelf life, and their effectiveness will reduce greatly the longer they sit gathering dust in storage. Take time to review current PPE – does it have a best before date? Is there any wear / tear? Check with the manufacturer if you are unsure and, if necessary, bring a specialist in to review or test core PPE equipment.


Learn From your mistakes


Not every eventuality can be covered in a risk assessment, and sometimes accidents happen. In construction, these are most commonly slips, trips and falls. Your obligations regarding reporting will depend on the severity of the accident, but even minor ones and near misses should be logged. An accident record is a useful tool, not only because it informs future risk


assessments, but also because it helps you to spot problems and patterns before they become serious. For example, if workers keep slipping on a certain area, is it necessary to change the terrain, replace boardwalks or redirect the walkway entirely? Or could it be indicative of a wider issue regarding the quality of tread in shoes? The more insight you can squeeze from something, the more likely you are to avoid a major incident. A HSE inspector will want to review any accident logs, so keep these as detailed and as up to date as possible, also remembering your RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) obligations to report.


practice makes perFect


You have refreshed your risk assessments, trained your crew and polished your PPE. Now what? You need to make sure that all of this will have a positive impact on the health and safety of your site, so consider conducting mock inspections to review how they play out in practice, and who on your team is (or is not!) following your site’s policies. The HSE recommends using method statements as a benchmark of good practice for certain processes. These can be based on both your risk assessment, as well as specialist or manufacturer guidance, and can be a useful way of ensuring consistency across the site. Whether you choose to use a method statement or not, identifying discrepancies is vital to ensuring that everyone is embedding safe working practices across the site, regardless of whether they are a regular worker, a subcontractor or a visitor. Whatever your findings from these mock inspections, do not just log them and forget them – use them to adapt and revise your risk assessment or as rationale for providing further training. Again, you can outsource this if you feel a fresh perspective could spot the things you may have missed the first time around.


it’s heaLth anD saFety gone sane


Meeting your health and safety obligations is not about ticking boxes and passing inspections. Good, safe practice embedded across the site makes construction projects more efficient, more cost-effective and of a higher quality, and ultimately means that workers go home safely each night. It is worth noting that increased visits from the HSE are also revealing a few of its key areas of interest, namely: fire risk assessments, lone workers, mental health, PPE and ventilation – a particularly relevant one for a post-Covid construction site. I would strongly recommend checking that your risk assessments include reference to these. If you are struggling, consider outsourcing risk management to a specialist, which may save time, resource and – most importantly – should help you ensure all bases are covered.


Gateley legal www.gateleyplc.com


IndustrIal ComplIanCe | JulY/auGust 2022 11


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