UCLAN health and safety audit evaluation report :
Please note that File A: is a reference to the PowerPoint file by Muneef and File B is a reference to the Excel file by the internal auditor.
The health and safety management procedures (HSE, 1997), according to the health and safety executive depend largely upon the six key elements of
- planning and implementation,
- and review.
The University is not only an employer and thus under the statutory duties of ensuring that the health and safety of its employees is protected but also an “occupier” of its premises and thus subject occupier’s liability under the health and safety legislation towards its students and any person who frequents its premises. The aim and ambit of any good practice in an audit programmed which is the 5th pillar of the major health and safety elements remains the use of quality benchmarks by ensuring that the health and safety mechanisms are being effectively understood by the health and safety management, the effective implementation of the same and the accident frequency rates. Auditing remains an occupation, which can attract heavy legal and corporate competencies. It is possible to see all three elements of the HSE elements of health and safety present within the UCLAN management system. For this reason it would be reasonably be expected that these audit Files A and B would reflect such good practice. However, the divergence of methodologies of classifying risk scores as apparent from both files is only evidence that the concept of scoring as specified within the UCLAN report is not the final prerequisite for establishing the magnitude and aptitude of a risk occurring.
At the outset the author has taken into account the following official health and safety documents
- The UCLAN health and safety regulations (provided)
- Workplace (Health, Safety and Welfare) Regulations 1992. Approved Code of Practice L24
- HSE (1990) A guide to the health and safety at work etc act 1974.
- HSE (1990) Health surveillance under COSHH: Guidance for employers.
- HSE (1992 a) Personal Protective Equipment at Work regulations 1992.Guidance on Regulations
- HSE (1992) Workplace health, safety and welfare. Workplace (Health, Safety and Welfare) Regulations 1992. Approved Code of Practice
- HSE (1996) Safety representatives and safety committees
- HSE (1998 a) “Five Steps to Risk Assessment”.
Point wise evaluation of the audit
- The first major divergence, which was seen in the two types of audit, which were provided, was the use of a proper management format, which would elucidate more clearly upon the nature and category of the premises, which were being explored. Important categorization could have been done here in terms of places frequented, more by students and staff and those which are only within access of the latter and the school administration. A part of health and safety according the UCLAN standards remains not only ensuring that health and safety actually exists in the current scenario but such audits should also focus in their comments and evaluation at ways and means of making the same mistake proof. Furthermore the nature of both these audits is internal in nature. Which means this discussion will be limited to good or bad health and safety practice in auditing premises and buildings and not the external nature comparing the university framework’s compliance with health and safety.
- File A and File B had two divergent methodologies for the assessment of risk. File A used a colour coding system simply composed of three colours with Yellow for “improvement required” and Green for “complete or ongoing”. The colour Red indicated “Immediate Action”. This was a very simplistic means at the most basic level of communications whether or not “all was well” with the internal health or safety mechanism. However File B seemed to be utilizing a more professional system of rating health and safety through a scoring risk assessment through the scoring or rating methodologies. This technique is means of using a scoring methodology for risk assessment by the use of weighted scores or risk matrices.
- The reason the use of the scoring methodology has been criticized in management and health and safety literature is because the concept of assigning risk a “score” to a health and safety risk is theoretically flawed and can be based on the cognitive bias of the audit manager (Cox, 2008:2). It is well known that the perception of risk may be a subjective area and thus there is a danger that these scores may not accurately reflect or match up to the scores awarded for similar risks (Cox: 2008:2). It is possible to see from File B that at times the scoring methodology becomes slightly confusing to the lay person as opposed to the colour coding scheme and thus the accuracy of Risk analysis in an audit through point scoring may or may not be guaranteed (Cox, 2008:2).
- However this also goes to show that there should be uniformity in the benchmarking and management practices, which can form the backbone of the University’s health and safety management systems. Both audits reflect little use for long term benefits in health and safety management as an audit framework.
- The use of pictures and images , which has been done liberally especially in the case of the first File A is a sign of good practice which means any such H&S discrepancies when noted should be immediately recorded through pictorial evidence. However the audit undertaken may be more general and simplistic because it relates more to the dynamics of safety with in a building and not in a more complicated lab as evident from File Before this reason perhaps keeping in mind the legislation pertaining to hazardous substances File B was a more detailed audit as compared to File A.
- File B is an audit of a premises (a laboratory) with is subject to significant risks of chemical exposure, which can affect the environment, the employees and the people (students) who frequent this area. File B is therefore is a sign of good practice as it takes into account quite detail-wise the hazards and their point score assessment.
- What is missing in this audit however it clearly identifying a few things. Firstly “who may be affected” here as a consequence of not using properly the equipment at hand. This report should have clearly pointed out the ambit of risk in this regard by stating at the outset the possible affectees in this laboratory environment who could suffer from an exposure or mishandling of the equipment, premises or the chemicals contained therein. The File B audit report ends with the use of colour code schemes briefly indicated through the scores the need for action being taken but the scores are of little help unless it is made clear who might be affected or what kind of risks are concurrent here.
- Both reports make minimal reference to the governing regulations of the Health and Safety legislation. For example in this case of File B what was clearly required in the matter of good practice was a statement of which UCLAN health and safety regulations were being implemented here and what could be the consequence upon visitors who were possibly pregnant or had conditions or asthma or skin problems in the event of a disaster scenario. There was little mention of the parameters being used to make the premises at hand in File B mistake proof.
- The report has done well as far as testing the premises for the presence of control measures in this case, in terms of the use of treated materials being present and used in the laboratory and the frequency with which hazardous materials are replaced in light of their danger with less dangerous options. The report did a good survey of the presence of adequate ventilation but the presence of personal protective equipment (PPE) as far as the provision of masks , risks and over alls is concerned was not discussed properly.
- When we compare this will the general audit of the Kirkham building in the File A, the auditor went on the make a picture of areas where non-compliance could be seen and recorded the infringements of the code accordingly in this matter. This could have been appreciated with in File B as well. More could have been recorded here in terms of the exposure risks here in the context of good practice routine monitoring and surveillance. The premise for this comes not only from the UCLAN regulations but also from the COSHH 1999 Regulations: (The Control of Substance Hazardous to Health (COSHH) Regulations 1999)
- There are a lot of other hazards, which have been ignored or not dealt in detail within the two audit files. For example according to the UCLAN’s commitment to occupational health of the workers and a healthy environment for the students a more professional discourse which could have been adopted here would have involved taking into account the possible stress , suffocation and depression that could arise in these premises.
- There was no mention of the presence of educational literature and cautions for health and safety which are displayed in the key locations within these locations. For example the UCLAN and the general Health and Safety legislation requires the presence of caution and advice based information being displayed for the benefit of people who use a certain premises and for the workers. There seem to be no comments on this regard in detail in both Files A and B apart from the mention of “hazard” signs.
- The health and safety regulations have become extremely advanced after the EU took a proactive commitment to enhancing the health and safety conditions in its member-states (O’Hara et al, 2000).Now these regulations are extremely diverse and detailed with those that deal with Noise at Work, Work at Height and even construction site safety standards. The most recent of these regulations are the Management of Health and Safety at Work Regulations 1999, which deal with the provision of healthy premises for the workers and students. There is no mention of the hazards of isolation and the possibility of personal injury during a crisis.
- Furthermore the control measures have not checked the presence of PPE’s in File A either in terms of the presence of masks, gloves, overalls, especially the presence of an industrial vacuum cleaner and specialized filter in File B. In the case of the risk assessment being undertaken by the laboratory auditor in File B in particular and File B in general it is possible to note that Good practice would have noted the following the things in particular:
- A category for the substances being used directly in the work activities in the laboratory that would list the most dangerous chemicals being handled for example the storage and handling of potassium. The second category would take a review of substances generated during work activities for example the waste substances that could arise during teaching, storage or experiments. This would also take into account the satisfactoriness of the measures in place to check and account for the presence of naturally occurring substances and the occurrence of accidents like broken glass from test tubes or spilled liquids.
- As an employer the university (UCLAN) remains under a duty to control exposure of the same towards employees , staff, administration and students under the Control of Substances Hazardous to Health Regulations 2002 (COSHH) which requires that audits of chemically hazardous locations like laboratories should include the subscription to risk assessment from possible hazards in an itemized fashion and the need for being clear on the compliance measures and those required to prevent and control the exposure in case of an emergency.
- The auditors in File A and File B have clearly not observed these premises at a time when they are in use and the possible risks arising here become much more apparent. Furthermore there is a need to prepare plans and procedures within the audit, even if in a summarized form as far as the possible occurrence of accidents, incidents and emergencies involving hazardous substances arise.
- Last but not the least the audits both in File A and B should have at least checked for presence of professional skilled help in case of hazards. Also there was no mention in both files of emergencies and what could be done to de-clutter the environment so things like furniture and equipment would not get in the way of evacuees escaping from the building. While the attention paid to the fire risks was logical, the audit reports should have realized that in the UCLAN health and safety regime is much more holistic and broad than it seems at the first instance.
- Louis Anthony (Tony) Cox, Jr (2008) What’s Wrong with Risk Matrices? Risk Analysis, Vol. 28, No. 2,
- (PMI)Project Management Institute (2003). A Guide To The Project Management Body Of Knowledge (3rd ed. ed.). Project Management Institute. ISBN 1-930699-45-X.
- Workplace health, safety and welfare. Workplace (Health, Safety and Welfare) Regulations 1992.
- Approved Code of Practice L24 HSE Books 1992 Workplace health, safety and welfare: A short guide for managers leaflet INDG244 HSE Books 1997
- HSE (1990 a) A guide to the health and safety at work etc act 1974. HSE Books, 1990. ISBN 071760 4411.
- HSE (1990 b) Health surveillance under COSHH: Guidance for employers. HSE Books 1990 ISBN 0 7176 04918 (publication currently under revision).
- HSE (1992 a) Personal Protective Equipment at Work regulations 1992. Guidance on Regulations L25 HSE Books 1992 ISBN 0 7176 0415 2.
- HSE (1992 b) Workplace health, safety and welfare. Workplace (Health, Safety and Welfare) Regulations 1992. Approved Code of Practice L24 HSE Books 1992 ISBN 0 7176 0413 6.
- HSE (1996 a) Safety representatives and safety committees L87 (Third edition) HSE Books 1996 ISBN 0 7176 1220 1.
- HSE (1998 a) “Five Steps to Risk Assessment”. HSE Books 1998, INDG163, ISBN 717609049.
- O’ Hara R, Weyman A. and Dickety N, Report to the EU on Good Practice by Small and Medium Enterprises in the Assessment of Workplace Risks. HSL Report RAS/00/12.