REPORT ON THE MANAGEMENT OF 
HEALTH AND SAFETY

SCOTTISH AMBULANCE SERVICE BOARD

2 to 19 NOVEMBER 2004

INSPECTORS:

Douglas Philp – HM Principal Inspector of Health and Safety
Iain Brodie – HM Inspector of Health and Safety 
Archie Mitchell - HM Inspector of Health and Safety
Douglas Conner - HM Inspector of Health and Safety
Tracy McTaggart - HM Inspector of Health and Safety
Jean Edgar - HM Inspector of Health and Safety
Mike Orr - HM Inspector of Health and Safety
Nancy Hamilton – HM Principal Inspector of Health and Safety (Occupational Health)
Susan Donnelly - HM Inspector of Health and Safety (Occupational Health)
Brenda Wilson - HM Inspector of Health and Safety (Occupational Health)

EXECUTIVE SUMMARY

The findings from this inspection indicate that the Scottish Ambulance Service Board have systematically failed to implement systems to ensure compliance with minimum statutory requirements. 

Specifically, Improvement Notices have been served requiring compliance with:

•	The Health and Safety At Work etc Act 1974
•	The Management of Health and Safety at Work Regulations 1999
•	The Manual Handling Operations Regulations 1992

There is an endemic failure to carry out suitable and sufficient risk assessments for the topics sampled.  This failure is compounded by a lack of specific competence in these topics and a failure to provide adequate resources for health and safety compliance.

Without a systematic and competence based approach to risk assessment the service cannot implement an effective system for health and safety planning.

Previous advice from the Health and Safety Executive has not been adequately actioned and on occasions has been ignored.

The Service is now expected to pursue compliance with the Improvement Notices issued and develop an action plan to address the action points contained within this report.  This action plan should be outcome driven.

The Health and Safety Executive will continue to examine the management of health and safety within the Scottish Ambulance Service Board.

CONTENTS

ITEM									        PAGE

1. INTRODUCTION								4

2. ACKNOWLEDGEMENTS						6

3. POLICY									7

4. ORGANISATION								8

5. PLANNING AND IMPLEMENTING					14

6. MEASURING PERFORMANCE					18

7. AUDITING AND REVIEWING PERFORMANCE			20

APPENDIX 1	Summary of key elements of successful health and safety management

APPENDIX 2	Copies of Improvement and prohibition Notices served  (2000, 2002,  2005)

APPENDIX 3		Specific matters requiring attention

1. 	INTRODUCTION

1.1	A management inspection of the Scottish Ambulance Service Board (the Service) was carried out by the Health and Safety Executive (HSE) in September 2000.  Shortcomings in the management of health and safety were identified and recommendations made.  Three Improvement Notices were served along with one Prohibition Notice. 

1.2	In 2002, extensive investigations by the HSE into moving and handling practices in the Service revealed ongoing shortcomings.  A further two Improvement Notices were served on the Service.

1.3	A further inspection (the subject of this report) was undertaken in November 2004. The purpose of this inspection was to ascertain the Services progress in improving standards of health and safety management, following previous interventions. 

1.4	Health Services has been designated a priority sector for the HSE by the Health and Safety Commission (HSC).  This intervention is part of a five year health services industry programme to help reduce current levels of work related accidents and ill health.  This programme links to the targets within ‘Revitalising Health and Safety’, ‘Securing Health Together’ and ‘Towards a Healthier Safer Workplace’. 

1.5	This inspection and report is structured within the format of the health and safety arrangements required by Regulation 5 of the Management of Health and Safety at Work Regulations 1999, as detailed in the associated Approved Code of Practice (ACOP).  Guidance on compliance with this statutory requirement is contained within the HSE publication HSG 65 ‘Successful Health and Safety Management’ (See summary reproduced within Appendix 1).

1.6	The inspection comprised of three elements designed to achieve a balanced and factually accurate, evidence based, view of the Services arrangements for managing health and safety: 

•	Formal and informal interviews with staff from chief executive level downwards
•	Examination of health and safety documentation
•	Sample inspections of work activities

1.7	The inspection focused on three risk control systems (violence and aggression to staff, manual handling operations, and occupational stress) as a means of sampling the Service’s management of health and safety as a whole.

1.8	Trade union representatives were consulted prior to and during the inspection and will receive a copy of this report.

1.9	Whilst this inspection focused primarily on the management arrangements underpinning the risk control system for the topics sampled, the findings and action points contained within this report should, where appropriate, be applied to other areas of the Services health and safety management system.

1.10	The Employment Medical Advisory Service (EMAS) report on the management of occupational stress is being sent to the Service along with this report. The EMAS report contains more detailed findings and action points relating to this management of occupational stress.

1.11	During this inspection there were specific matters identified that require attention. Information on these matters is attached to this report as appendix 4.
2. 	ACKNOWLEDGEMENTS

2.1	An expression of thanks is extended to all members of staff and management for their co-operation and courtesy throughout this inspection.

3. 	POLICY

GUIDANCE ON LEGAL REQUIREMENTS

"Effective health and safety policies set a clear direction for the organisation to follow. They contribute to all aspects of business performance as part of a demonstrable commitment to continuous improvement. Responsibilities to people and the environment are met in ways which fulfill the spirit and letter of the law. Stakeholders' expectations in the activity (whether they are shareholders, employees or their representatives, customer or society at large) are satisfied. There are cost effective approaches to preserving and developing physical and human resources which reduce financial loss and liabilities."

INSPECTION FINDINGS

3.1	The Service has a health and safety policy that is signed by the Chief Executive and identifies the Human Resources Director as the director with responsibility to oversee the implementation of the health and safety policy throughout the Service.  The health and safety policy is supported by the ‘health and safety organisation and responsibility’ document.  The health and safety policy documentation does not contain details of how adequate resources will be allocated to the implementation of the policy (Ref.1, page 25, inset 7; Ref. 3, pp27).

3.2	Although the Human Resources Director has been allocated specific health and safety responsibilities by the policy, the health and safety organisation and responsibilities documentation does not provide information on these specific delegated responsibilities (Ref.1, page 25, inset 7; Ref. 3, pp27).

3.3	The Service does not have a Managing Stress at Work Policy.  This is inadequate given the level of employees’ exposure to occupational stressors.  The service does have a guidance note specifically tackling Post Traumatic Stress Disorder (PTSD).  This guidance not does not adequately address the issue of occupational stress.

ACTION POINTS

1.	The Service should review their policy documentation and ensure that it provides detail on how adequate resources will be allocated to the implementation of the policy.

2.	The health and safety organisation and responsibilities document should be reviewed.  This document should clearly provide details of the responsibilities delegated to the Human Resources Director and how these responsibilities are to be discharged.

3.	The Service requires to develop and implement a policy for managing work-related stressors. 
4. 	ORGANISATION

GUIDANCE ON LEGAL REQUIREMENTS

"Organising for health and safety involves establishing responsibilities and relationships which promote a positive health and safety culture and secure the implementation and continued development of the health and safety policy

There are four aspects to effective organising for health and safety. These are: 

•	The establishment and maintenance of management control, 
•	The promotion of co-operation, 
•	Communication of information throughout the organisation, and 
•	Ensuring the competence of employees. 

These four components are interrelated and interdependent therefore consistent activity in each area is essential to promote a climate in which a positive health and safety culture can develop.  Taken together, they provide the organisational framework required to manage health and safety effectively.”

INSPECTION FINDINGS

4.1	The inspection findings in sections 4.1 to 4.4 of this report demonstrate that the Service requires to make significant improvements in their health and safety culture.  These improvements are necessary at all levels and should be driven by senior management.

ACTION POINTS

4.	Action Points 5 to 17 should be planned and implemented as part of an integrated strategy designed to improve the overall health and safety culture of the Service.

4.1	CONTROL

GUIDANCE ON LEGAL REQUIREMENTS

"Establishing and maintaining control is central to all management functions.  Control is achieved by getting the commitment of employees to clear health and safety objectives.  It begins with managers taking full responsibility for controlling factors that could lead to ill health, injury or loss.  The arrangements start with nominating a senior figure at the top of the organisation to co-ordinate and monitor policy implementation.  Health and safety responsibilities are allocated to line managers, with specialists appointed to act as advisers.  If managers provide clear direction and take responsibility for the working environment, it helps create a positive atmosphere and encourages a creative and learning culture.  Safety representatives can also make an important contribution.  The emphasis is on a collective effort to develop and maintain systems of control before the event - not on blaming individuals for failures afterwards."

INSPECTION FINDINGS

4.1.1	Responsibility for the management of health and safety is delegated to the general managers of each of the Service’s six divisions.  Within each division responsibility is further delegated to middle and junior managers.

The Service has failed to ensure that all managers with health and safety responsibilities clearly understand what they have to do to discharge these responsibilities (Ref. 3, pp38 - 50).

4.1.3	Furthermore, the Service has failed to ensure these managers have the time and resources to discharge these responsibilities effectively (Ref.2 pp35).

4.1.4	Control is strongly exercised in the business areas that managers are measured on:

•	Finance,

•	Sickness absence, and

•	Response time for priority calls.

4.1.5	In some, albeit not all, divisions an appraisal system for health and safety is used for monitoring managers’ performance in these areas (Ref.3 pp46).

4.1.6	The Service is failing to exercise adequate control over health and safety matters.  The high degree of control exercised in the monitored business areas demonstrates that the Service is capable of achieving the desired level of control.

ACTION POINTS

5.	The Service requires to ensure that everyone with health and safety responsibilities understands clearly what they have to do to discharge their responsibilities.

6.	The Service requires to introduce systems that ensure managers have the time and resources to discharge their health and safety responsibilities. 

7.	The Service requires to set health and safety performance standards to judge performance of managers with health and safety responsibilities and ensure that they meet them.  The delivery of these performance standards should be managed through the appraisal system.

4.2	COOPERATION

GUIDANCE ON LEGAL REQUIREMENTS

"Participation by employees supports risk control by encouraging their 'ownership' of health and safety policies.  It establishes an understanding that the organisation as a whole, and people working in it, benefit from good health and safety performance. Pooling knowledge and experience through participation, commitment and involvement means that health and safety really becomes 'everybody's' business.”

INSPECTION FINDINGS

4.2.1	The Service has systems for co-operation with ‘recognised’ trade unions. Significant numbers of employees are not members of the ‘recognised’ trade unions and the current systems of consultation do not extend to these employees.

4.2.2	Some divisions do not have a health and safety committee, although health and safety matters are standing items on the partnership forum.  It is necessary to ensure that the work of the safety committee has a separate identity, and that safety matters don’t become interposed in the agenda of other meetings (Ref.13 pp37).  

4.2.3	Employees’ awareness of the health and safety committee and the health and safety representatives’ structure was poor.

ACTION POINTS

8.	The Service must implement systems for consultation with employees who are not members of ‘recognised’ trade unions.

9.	The Service must ensure that there is a clear health and safety committee structure at divisional level.

10.	It is recommended that the Service and the Trade Unions review the numbers of active appointed health and safety representatives.  This should be supported with a review of the involvement of health and safety representative in the practical management of health and safety.

4.3	COMMUNICATION

GUIDANCE ON LEGAL REQUIREMENTS

"Communication challenges organisations generally - not just on health and safety issues.  It is often seen as the single most important area requiring improvement.  The messages senior management may wish to communicate are often not the ones employees receive.   Two central elements are clear visible leadership and a common appreciation of how and why the organisation is trying to improve health and safety."

INSPECTION FINDINGS

4.3.1	The health and safety communication system relies heavily on the Service’s intranet system, Sampson.  While there are other methods of communication within the Service many staff believe Sampson to be a passive and one-way method of communication. 

4.3.2	The service carry out sample communications surveys which record bulletins received and not received, whether e-mail is opened or unopened and whether staff have read bulletins.  This demonstrates that some employees do not have ready access to computers and staff, can be missed from bulletin mailings and have not read bulletins.  This is particularly relevant to small rural locations and to personnel working from home.

4.3.3	Communication includes visible behavior and discussion.  Most employees and managers are aware of some of the health and safety deficiencies within the Service.   A lack of local control or resources often leads to a failure to address these concerns within a reasonable timescale. 

4.3.4	HSE’s previous interventions and the need for further enforcement action is clear evidence of a failure to adequately manage or resource health and safety matters.  This situation has led to some staff apathy in raising and seeking solutions to health and safety concerns. 

4.3.5	Employees were unaware of several health and safety developments and previous HSE interventions.

ACTION POINTS

11.	The Service should review their health and safety communication systems to encourage employees to actively participate in health and safety matters.  This review should consider all employee groups.

12.	The contents of this report should be made available to employees.

4.4	COMPETENCE

GUIDANCE ON LEGAL REQUIREMENTS

"If all employees are to make a maximum contribution to health and safety, there must be proper arrangements in place to ensure that they are competent. This means more than simply training them.  Experience of applying skills and knowledge is another important ingredient and needs to be gained under adequate supervision. Managers need to be aware of relevant legislation and how to manage health and safety effectively.  All employees need to be able to work in a safe and healthy manner."

INSPECTION FINDINGS

4.4.1	Health and safety management responsibilities have been delegated to managers.  These managers are not provided with adequate training to discharge these responsibilities. These managers also have insufficient training in the relevant legislation and standards.

4.4.2	Employees who are expected to carry out risk assessments do not have adequate training to undertake risk assessments on their own.  They do not know the relevant legislation or standards; furthermore, these employees do not have access to the relevant guidance documentation or standards.

4.4.3	Managers responsible for the reporting under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 were only aware of the over three day reporting criteria.  There was no knowledge of the other reporting criteria.

4.4.4	The Service does not have a competent backcare advisor. HSE previously issued an Improvement Notice on this matter.  The Service nominally complied by appointing an occupational health nurse one day a week. This individual resigned on 5 December 2003.  The Service has failed to replace this inadequate level of backcare advice.

4.4.5	The Service is presently in negotiations with an NHS Board to gain access to their backcare advisor.  Current funds available will allow a service provision of 1 to 2 days per month.  This is inadequate and does not satisfy current standards (Ref. 6, Page VII, item 2).  The provision of backcare advice has been dictated by cost not need.

4.4.6	The Service now has six substantive and seven seconded trainers (all from within the service) who have attended a B-TEC accredited moving and handling trainers course.   This training capacity is not adequate to clear the backlog of training requirement for existing staff.

4.4.7	Employees receive moving and handling training during their initial training at Barony College.  Only recent recruits have received this required level of moving and handling training.  There is an element of moving and handling training contained within some of the annual post proficiency courses.  This relates to new equipment and is insufficient in terms of duration and does not constitute adequate refresher training.

4.4.8	The Service does not have access to adequate competent advice on the management of violence and aggression (arising from both clinical and societal sources).  An example of where the Service should have sought competent advice is in the development of their management of aggression course.  We were informed that an employee was trained at Stirling University and was then involved in the development of this programme.  The Service could not provide any evidence of this or any other evidence to support the adequacy of the content of this internally developed course.

4.4.9	This management of aggression training was planned for delivery over a full day.  In some locations the duration of this course was shortened due to a number of reasons.  There is currently no refresher training.

4.4.10	The Service does not provide refresher training to drivers.  There has been previous advice on this matter.

ACTION POINTS

13.	The Service requires to provide health and safety training to managers, including senior managers and directors that is commensurate with their health and safety responsibilities.  Improvement Notice IN I/006108 has been issued requiring this.  A copy of this Notice is attached in appendix 2.

14.	The Service requires to appoint one or more competent persons to assist them in undertaking the measures it needs to take to comply with the Moving and Handling Operations Regulations 1992.  Improvement Notice IN I/006104 has been issued requiring this.  A copy of this Notice is attached in appendix 2.

15.	The Service requires to provide adequate training to all employees who are involved in manual handling.  Improvement Notice IN I/006107 has been issued requiring this.  A copy of this Notice is attached in appendix 2.

16.	The Service requires to review its moving and handling training in line with current best practice.  A competent person should be involved in this review.  Any deficiencies in training should be addressed as soon as practicable and a system of refresher training implemented. 

17.	The Service requires to carry out a training needs analysis for driver refresher training.  This should be completed as soon as practicable.

5. 	PLANNING AND IMPLEMENTING

GUIDANCE ON LEGAL REQUIREMENTS

"Since it is often a matter of chance whether dangerous events cause injury or loss, effective planning is concerned with prevention through the identification, elimination and control of hazards and risks."

INSPECTION FINDINGS

5.1	The Service failed to provide evidence of an effective health and safety planning system (Ref. 2 pp33).

5.2	There was a general lack of risk assessments and the majority of those seen were site based (i.e did not cover normal peripatetic work) and were not suitable and sufficient  (Ref.2 pp13(b)).  Although the task of risk assessment was delegated to middle and junior management, they had not been given the training or the resources to effectively discharge this duty.

5.3	There should be a systematic approach to the completion of risk assessments.  These risk assessments should be used to decide on priorities and to set objectives for eliminating hazards and reducing risks.  There should be a programme, with deadlines for the completion of the risk assessment process, together with suitable deadlines for the design and implementation of preventive and protective measures, which are necessary.  There was little evidence of a health and safety planning system meeting these requirements.

5.4	Prior to the visits copies of the current moving and handling assessments were requested.  The Service provided copies of equipment based Generic Operational Risk Assessment Reports.  These risk assessments do not satisfy the requirements of the Moving and Handling Operations Regulations 1992.  It was noted that a task considered to be unacceptable by HSE due to the risk of musculoskeletal injury (side loading trolley cot into ambulance) was classified as low to moderate risk in these generic assessments.

5.5	The B-TEC accredited moving and handling trainers are training new staff in the use of low tech moving and handling aids such as transfer boards, sliding sheets, turning disks and handling belts.  Currently, operational staff who are involved in moving and handling are not provided with this equipment.  There are plans to provide this equipment to all crews in the North East Division this year.  At present there are no resources allocated to provide this equipment throughout the Service.

5.6	A significant portion of accident and emergency vehicle in the total vehicle fleet are step vehicle. These are not provided with a ramp or a tail lift.  Crews are required to manually lift patients into these vehicles on York 4 trolley cots and carry chairs.  This is an unacceptable practice due to the risk of musculoskeletal injury to employees.  There are plans to replace all of these vehicles by the end of 2006.

5.7	In the meantime the Service should reduce the risk of musculoskeletal injury from the use of these step vehicles through the vehicle fleet management systems.  It is unacceptable to leave crews operating with a step vehicle, where it is foreseeable that patients require to be manually loaded, for longer than is reasonably practicable.

5.8	There is no moving and handling assessment for the new defibrillator.  This item presents a significant load for crews to manually carry along with other equipment.  The initial intention was for this to be a vehicle based item and that crews were to be provided with a smaller and lighter ‘shock box’ for use outwith the vehicle.  Board papers indicant that this was the intention.  However we have been informed that the ‘shock box’ is no longer to be provided.

5.9	There are no risk assessments for the management of violence and aggression.  This risk assessment process should be used to decide on preventive and protective control measures (including training content and refresher periods) and is integral to a system of planning for the management of the risk of violence and aggression.

5.10	The radio system is part of a system for managing the risk of violence and aggression.

5.11	Most operational staff could give examples of where the current radio system is deficient.  This included lost or damaged radios and known areas with poor or no reception (both rural and urban).  There is a growing reliance on mobile phones, including crews’ personal phones for operational communication.  It was also noted that current mobile phone arrangements provide a lower level of communication and risk control.  Compliance with health and safety legislation was not given adequate cognisance in the business case for the new radio system.

5.12	There are inconsistencies in mechanisms for crews to call for police assistance when confronted with the threat of violence and aggression.

5.13	Due to the nature of it’s undertaking the Service exposes employees to a risk of occupational stress.  However, the Service has failed to carry out any risk assessment for occupational stressors.

5.14	Within rural areas the Service operates an on call system.  There are some busy locations where crews experience a significant amount of calls during their on call period.  On occasions there can be more than one call in an ‘on call’ night shift. These crews are expected to attend work the next day.  HSE has given advice on the matter on a number of occasions.  Recently the Service introduced a system where crews can request a ‘lie in’ or book off fatigued.  This system is inadequate, with the onus being placed on employees.  There is no system for relief, if booked off crews know there will be no local emergency cover for their community.  Therefore crews feel a moral obligation and operational pressure to continue to work. 

5.15	Domestic washing machines are provided for crews to launder uniforms.  This includes soiled uniforms that are potentially contaminated with pathogenic microorganisms.  Domestic washing machines cannot be calibrated to ensure, register and demonstrate accurate wash temperatures (Ref.12, pp5).  Industrial washing and drying machines should be used for soiled and fouled linen, including uniforms.   We were informed that industrial washing machines were provided historically in some stations, however domestic machines have been used as replacements.

5.16	Control of infection was not a topic sampled during these visits.  However, in addition to the laundering of uniforms there were other areas of evident concern. These were as follows:

•	Reuse of single use equipment such as laryngoscope intubation blades,
•	Use of D10 disinfectant with cold water not hot as required,
•	Poor management of contaminated uniforms,
•	Poor management systems for cleaning equipment,
•	Practical conflicts between vehicle cleaning schedules and operational needs,
•	No hot water provided in some vehicle cleaning bays,
•	Poor provision of PPE for vehicle cleaning,
•	Use of a sink within a kitchen area as a sluice (a previous Prohibition Notice (copy appended, Serial No. P002006) has been issued on the Service regarding this matter in a previous audit),
•	Poor welfare provision, e.g. showers cubicles being used for storage.

ACTION POINTS

18.	The Service requires to make a suitable and sufficient assessment of the risks from moving and handling of patients by ambulance crews and reduce the level of risk, so far as is reasonably practicable, by the use of alternative equipment.  This includes lifting cushions and mechanically assisted lifting trolley cots or portable hoists.  Improvement Notice IN I/006106 has been issued requiring this.  A copy of this Notice is attached in appendix 2.

19.	The Service requires to take appropriate steps to reduce the risk of injury to employees who undertake manual handling of patients, to the lowest level reasonably practicable, by the provision of low tech aids.  Improvement Notice IN I/006105 has been issued requiring this.  A copy of this Notice is attached in appendix 2.

20.	The Service requires to take appropriate steps to reduce the risk of injury to employees who undertake the manual handling of patients, to the lowest level reasonably practicable, by avoiding manually lifting patients into ambulances in carry chairs and trolley cots.  Improvement Notice IN I/006109 has been issued requiring this.  A copy of this Notice is attached in appendix 2. 

21.	The Service requires to make and give effect to such arrangements as are appropriate, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures for the risk of violence and aggression which employees are exposed to whilst at work.  Improvement Notice IN I/006110 has been issued requiring this.  A copy of this Notice is attached in appendix 2.

22.	The Service requires to implement a systematic approach to the completion of risk assessments.  These risk assessments should be used to decide on priorities and to set objectives for eliminating hazards and reducing risks.  There should be a programme, with deadlines for the completion of the risk assessment process, together with suitable deadlines for the design and implementation of preventive and protective measures, which are necessary.

23.	Specifically, the Service requires to make a suitable and sufficient assessment of the risks to the health and safety of employees from their exposure to work related stressors.  This should be completed by 30 November 2005.  For further information on this matter the service should refer to the HSE management standards for stress (Ref. 15).

24.	The Service requires to carry out a risk assessment for driver fatigue and sleep deprivation, especially for crews in areas where excessive on-call working is foreseeable.  There is a requirement to proactively manage crews’ hours.  There should be clear unequivocal guidelines detailing when crews should receive uninterrupted rest breaks and mechanisms for relief.  This situation should be addressed as a matter of priority.  HSE will be involved in further investigations into this matter.

25.	The Service requires to meet existing NHS standards for the laundering of contaminated uniforms.  There has been previous advice on this matter. This should be addressed as soon as practicable.

26.	The Service should review their systems for the control of infection. This review should consider actual working practices.

6. 	MEASURING PERFORMANCE

GUIDANCE ON LEGAL REQUIREMENTS

“Organisations need to measure what they are doing to implement their health and safety policy, to assess how effectively they are controlling risks, and how well they are developing a positive health and safety culture.  A low accident rate, even over a period of years, is no guarantee that risks are being effectively controlled and will not lead to injuries, ill health or loss in the future.  This is particularly true in organisations where there is a low probability of accidents but where major hazards are present. Here the historical record can be an unreliable or even a deceptive indicator of safety performance.

There are two ways to generate information on performance:

•	Active systems which monitor the design, development, installation and operation of management arrangements, risk control systems and workplace precautions
•	Reactive systems which monitor accidents, ill health and incidents and other evidence of deficient health and safety performance

Effective procedures are needed to capture both sorts of information.”

INSPECTION FINDINGS

6.1	Active Monitoring

6.1.1	Some managers are conducting local inspections.  However, with inadequate training and a lack of performance standards, the value of these inspections is questionable.

6.1.2	The Service does not systematically identify failures that are common throughout the organisation and systematically address those issues.

6.1.3	The health and safety department undertakes health and safety inspections of the Divisions.  The score based system is used with a positive bias.  For example, some audits identify non-compliance for the completion of risk assessments.  The audit then goes on to record compliance in areas associated with risk assessment that could not be complied with where there are no risk assessments.

6.1.4	The Service has surveyed staff on violence and aggression.  This survey was not carried out under the supervision of persons with the suitable qualifications and experience in the management of violence and aggression.

6.2	Reactive Monitoring

6.2.1	Accidents and incidents are reported to the health and safety and risk management departments via the internal IR1 system.  The statistics from these are collated and reported bi-monthly to the risk management group meeting.  This system attempts to identify trends and patterns.  Moving & handling, violence & aggression and slips & trips have been identified as the main causes of reported incidents.

6.2.2	Managers are expected to investigate incidents and accidents locally.  These managers have not been trained in accident investigation.  The health and safety department also investigate some incident.  It is arbitrary whether someone, with the necessary health and safety qualifications and experience, investigates these incidents.

6.2.3	There is no systematic checking on the implementation of precautions identified as being required after the investigation of an incident.

6.2.4	There is significant under reporting of incidents of violence and aggression, particularly verbal abuse. 

6.2.5	The IR1 risk scoring can be amended by the administration to ensure consistency.  This should only be done once there has been a check on the information provided.

6.2.6	During the inspection it was claimed that the Service presently calculates the cost of accidents and this is used to inform the health and safety management system.  There is no evidence to support this claim.

ACTION POINTS

27.	The service should ensure that inspections are carried out to establish compliance with their health and safety performance standards.  There should be a system in place to hold managers accountable for failing to achieve these standards.

28.	The Service should ensure that those employees tasked with carrying out inspections have an adequate knowledge of the relevant risks, precautions and legal standards.

29.	The Service should provide adequate training for employees who are required to investigate accidents, incidents and near misses.

30.	The Service requires to develop and implement a system for rectifying deficiencies identified locally that are outwith the control of local managers.

31.	The Service should be calculating the cost of accidents and using this data to inform their health and safety management system.
7. 	AUDITING AND REVIEWING PERFORMANCE

GUIDANCE ON LEGAL REQUIREMENTS

“Auditing and performance review are the final steps in the health and safety management control cycle.  They constitute the 'feedback loop' which enables an organisation to reinforce, maintain and develop its ability to reduce risk to the fullest extent and to ensure the continued effectiveness of the health and safety management system.”

INSPECTION FINDINGS

7.1	There are systems for station and divisional audits.  However, there are no formal systems for the audit of the Services overall health and safety management system.

ACTION POINTS

32.	The Service requires to develop and implement auditing procedures for their overall health and safety management system.  This audit system should allow policy implementation to be assessed against four key indicators:

•	Assessment of compliance with health and safety performance standards;
•	Assessment of the achievement of specific objectives;
•	Identification of areas where standards are absent or inadequate;
•	Analysis of incident, accident and ill health data

9. 	REFERENCES

1.	Successful Health and Safety Management, HSE Books, HSG 65, ISBN 0-7176-1276-7

2.	Approved Code of Practice and Guidance to the Management of Health and Safety at Work Regulations 1999, HSE Books, L21, ISBN 0-7176-2488-9

3.	Management of Health and Safety in the Health Services, HSC Publications, HSE Books, ISBN 0-7176-0844-1

4.	Approved Code of Practice and Guidance to the Manual Handling Operations Regulations 1992, HSE Books, L23, ISBN 0-7176-2823-X

5.	Manual Handling in the Health Services, HSC Publication, HSE Books, ISBN 0-7176-1248-1

6.	Essential back-up: An Employers guide for setting up and maintaining an effective Back Care Advisory service. National Back Exchange. Revised 2002

7.	Violence and Aggression to Staff in the Health Service, Guidance on Assessment and Management, HSC Publication, HSE Books, ISBN 0-7176-1466-2

8.	Safe Disposal of Clinical Waste, HSC Publication, HSE Books, ISBN 0-7176-2492-7

9.	Approved Code of Practice and Guidance to the Control of Substances Hazardous to Health Regulations 2002, HSE Books, L5, ISBN 0-7176-2534-6

10.	The Cost of Accidents at Work, HSE Books, HSG 96, ISBN 0-7176-0439

11.	Approved Code of Practice and Guidance to the Workplace (Health, Safety and Welfare) Regulations 1992, HSE Books, L24, ISBN 0-7176-0413-6

12.	Guidance notes issued by the management executive NHS in Scotland on procedures for laundering and disinfection of linen, Scottish Office, NHS MEL (1993)7

13.	Safety Representatives and Safety Committees (Third Edition), HSC Publication, HSE Books, ISBN 0-7176-1220-1

14.	A Guide to the Consultation with Employees Regulations 1996, L95, HSE Books, ISBN 0-7176-1234-1

15.	http://www.hse.gov.uk/stress/standards/index.htm

16.	Healthy Working Lives – A Plan for Action, Scottish Executive, 2004, ISBN 0-7559-4251-5