Introduction u 62
3.1 Organisational health and safety roles and responsibilities of employers, directors, managers and supervisors u 62
3.2 Concept of health and safety culture and its significance in the management of health and safety in an organisation u 67
3.3 Human factors which influence behaviour at work u 69
3.4 How health and safety behaviour at work can be improved u 76 3.5 Further information u 88
3.6 Practice revision questions u 88
Appendix 3.1 Leadership actions for directors and board members u 90 Appendix 3.2 Detailed health and safety responsibilities u 92
Appendix 3.3 Safety culture questionnaire u 94
Appendix 3.4 List of typical legislation requiring health and safety training u 95
further recognised that a more active involvement of the workforce in such systems was essential if self-regulation was to work. Self-self-regulation and the implicit need for health and safety management systems and employee involvement were incorporated into the Health and Safety at Work (HSW) Act.
Since the introduction of the HSW Act, health and safety standards have improved considerably but there have been some catastrophic failures. One of the worst was the fire on the offshore oil platform, Piper Alpha, in 1988, when 167 people died. At the subsequent enquiry, the concept of a safety culture was defined by the Director General of the Health and Safety Executive (HSE) at that time, J. R. Rimington. This definition has remained as one of the key points for a successful health and safety management system.
3.1 Organisational health and safety roles and responsibilities of employers, directors, managers and supervisors
3.1.1 Control of the health and safety organisation
Like all management functions, establishing control and maintaining it day in day out is crucial to effective health and safety management. Managers, particularly at senior levels, must take proactive responsibility for controlling issues that could lead to ill-health, injury or loss. A nominated senior manager at the top of the organisation needs to oversee policy implementation and monitoring. The nominated person will need to report regularly to the most senior management team and will be a director or principal of the organisation.
Health and safety responsibilities will need to be assigned to line managers and expertise must be made available, either inside or outside the enterprise, to help them achieve the requirements of the HSW Act and the Regulations made under the Act. The purpose of the health and safety organisation is to harness the collective enthusiasm, skills and effort of the entire workforce with managers taking key responsibility and providing clear direction.
The prevention of accidents and ill-health through management systems of control becomes the focus rather than looking for individuals to blame after the incident occurs.
Introduction
This chapter covers the following NEBOSH learning objectives:
1. Outline the organisational health and safety roles and responsibilities of employers, directors, managers and supervisors
2. Explain the concept of health and safety culture and its significance in the management of health and safety in an organisation
3. Outline the human factors which influence behaviour at work in a way that can affect health and safety 4. Explain how health and safety behaviour at work can be improved
Figure 3.1 DO part of the management cycle involves Risk Profiling (Chapter 4), Organising and Implementing plans
This chapter is about managers in businesses, or other organisations, setting out clear responsibilities and lines of communications for everyone in the enterprise. The policy sets the direction for health and safety within the enterprise and forms the written intentions of the principals or directors of the business. The organisation needs to be clearly communicated and people need to know what they are responsible for in the day-to-day operations. A vague statement that ‘everyone is responsible for health and safety’ is misleading and fudges the real issues. Everyone is responsible (Figure 3.2), but management in particular. There is no equality of responsibility under law between those who provide direction and create policy and those who are employed to follow. Principals, or employers in terms of the Health and Safety at Work (HSW) Act, have substantially more responsibility than employees.
In 1972, the Robens report recognised that the introduction of health and safety management systems was essential if the ideal of self-regulation of health and safety by industry was to be realised. It
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3.1.3 Organisational health and safety responsibilities – directors
There is an absence of explicit legal duties that deal with directors’ responsibilities for health and safety, but if the organisation fails to fulfil the employers’
duties, directors can be held personally responsible.
There is voluntary guidance to inform directors of the requirements for good management of health and safety within their organisations. The HSE and the Institute of Directors have published a guide INDG417
‘Leading health and safety at work’. This guide is based on a plan that will deliver, monitor and review the management concept and the following information is closely based on this guide.
The following are quotations from health and safety leaders in the public and private sectors taken from the guide:
‘Health and safety is integral to success. Board members who do not show leadership in this area are failing in their duty as directors and their moral duty, and are damaging their organisation.’
‘An organisation will never be able to achieve the highest standards of health and safety management without the active involvement of directors. External stakeholders viewing the organisation will observe the lack of direction.’
For many organisations, health and safety is a corporate governance issue. The Board should integrate health and safety into its main governance structures, including board sub-committees, such as for risk, quality,
remuneration and audit. The Turnbull guidance on the Combined Code on Corporate Governance requires listed companies to have robust systems of internal control, covering not just ‘narrow’ financial risks but also risks relating to the environment, business reputation and health and safety.
Effective health and safety performance comes from the top; members of the Board have both collective and individual responsibility for health and safety. Directors and boards need to examine their own behaviours, both individually and collectively, against the guidance given by the HSE. If they fall short of the standards it sets them, then they must change so that they become effective leaders in health and safety.
Directors and board members need to take action so that:
u the health and safety of employees and others, such as members of the public, may be protected;
u risk management includes health and safety risks and includes health and safety as a key business risk in board decisions; and
u health and safety duties imposed by legislation are followed.
The control arrangements should be part of the written health and safety policy. Performance standards will need to be agreed and objectives set which link the outputs required to specific tasks and activities for which individuals are responsible. For example, the objective could be to carry out a workplace inspection once a week to an agreed checklist and rectify faults within three working days. The periodic, say annual, audit would check to see if this was being achieved and, if not, what the reasons for non-compliance with the objective were.
People should be held accountable for achieving the agreed objectives through existing or normal procedures such as:
u job descriptions, which include health and safety responsibilities;
u performance appraisal systems, which look at individual contributions;
u arrangements for dealing with poor performance;
u where justified, the use of disciplinary procedures.
Such arrangements are only effective if health and safety issues achieve the same degree of importance as other key management concerns, and a good performance is considered to be an essential part of career and personal development.
3.1.2 Organisational health and safety responsibilities – employers
The organisational health and safety responsibilities of employers are closely linked to their statutory duties which are covered in detail in Chapter 1 and in Chapter 15.
Figure 3.2 Everyone from senior management down has health and safety responsibilities
u ensure that any significant health and safety failures and their investigation are communicated to board members;
u ensure that when decisions are made the health and safety implications are fully considered;
u ensure that regular audits are carried out to check that effective health and safety risk management systems are in place.
By appointing a ‘Health and Safety Director’ there will be a board member who can ensure that these health and safety risk management issues are properly addressed, both by the Board and more widely throughout the organisation.
The Chairman and/or Chief Executive have a critical role to play in ensuring risks are properly managed and that the Health and Safety Director has the necessary competence, resources and support of other board members to carry out their functions.
Indeed, some boards may prefer to see all the health and safety functions assigned to their Chairman and/
or Chief Executive. As long as there is clarity about the health and safety responsibilities and functions, and the Board properly addresses the issues, this is acceptable.
The health and safety responsibilities of all board members should be clearly articulated in the
organisation’s statement of health and safety policy and arrangements. It is important that the role of the Health and Safety Director should not detract either from the responsibilities of other directors for specific areas of health and safety risk management or from the health and safety responsibilities of the Board as a whole.
Some form of health and safety training will probably be required for directors.
INDG417 states that there are four elements that boards need to incorporate into their management of health and safety. These are:
u planning the direction of health and safety;
u delivering the plan for health and safety;
u monitoring health and safety performance; and
u reviewing health and safety performance.
Details of these four elements are given in Appendix 3.1.
3.1.4 Typical managers’ organisational responsibilities
In addition to the legal responsibilities on management, there are many specific responsibilities imposed by each organisation’s health and safety policy. A summary of the organisational responsibilities for health and safety of typical line managers and their accountability of each level of the line organisation is given below.
Many organisations will not fit this exact structure but most will have those who direct, those who manage or supervise and those who have no line responsibility, but have responsibilities to themselves and fellow workers.
In INDG417, the Institute of Directors and the HSE state that:
‘Protecting the health and safety of employees or members of the public who may be affected by the activities of an organisation is an essential part of risk management and must be led by the Board.’
The starting points are the following essential principles.
These principles are intended to underpin the actions in this guidance and so lead to good health and safety performance.
u Strong and active leadership from the top:
Z visible, active commitment from the Board;
Z establishing effective ‘downward’ communication systems and management structures;
Z integration of good health and safety management with business decisions.
u Worker involvement:
Z engaging the workforce in the promotion and achievement of safe and healthy conditions
Z effective ‘upward’ communication;
Z providing high quality training.
u Assessment and review:
Z identifying and managing health and safety risks;
Z accessing (and following) competent advice;
Z monitoring, reporting and reviewing performance.
The HSE in its guidance on Directors and Board responsibility for health and safety recommends the following five action points:
u The Board needs to accept formally and publicly its collective role in providing health and safety leadership in its organisation.
u Each member of the Board needs to accept their individual role in providing health and safety leadership for their organisation.
u The Board needs to ensure that all board decisions reflect its health and safety intentions, as articulated in the health and safety policy statement.
u The Board needs to recognise its role in engaging the active participation of workers in improving health and safety.
u The Board needs to ensure that it is kept informed of, and alert to, relevant health and safety risk management issues. The Health and Safety Executive recommends that boards appoint one of their number to be the ‘Health and Safety Director’.
Directors need to ensure that the Board’s health and safety responsibilities are properly discharged. To achieve this, the Board will need to:
u carry out an annual review of health and safety performance;
u keep the health and safety policy statement up to date with current board priorities and review the policy at least every year;
u ensure that there are effective management systems for monitoring and reporting on the organisation’s health and safety performance;
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1. are responsible and accountable for their team’s health and safety performance;
2. enforce all safe systems of work procedures that have been issued by the Departmental Manager;
3. instruct employees in relevant health and safety rules, make records of this instruction and enforce all health and safety rules and procedures;
4. supervise any contractors that are working within their area of supervision; and
5. enforce personal protective equipment requirements, make spot checks to determine that protective equipment is being used and periodically appraise condition of equipment. Record any infringements of the personal protective equipment policy.