Contents:

• Too many documented procedures?

• Employee consultation
• Work at Height Guidance
• Smoke-free workplaces
• Ladder safety
• Working with VDUs
• Recent prosecutions in the Eastern Region
• Directors' role in health & safety

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One of the criticisms of the 1994 version of ISO9001/2 was that written procedures were required for all requirements in the standard. This resulted in written procedures getting a bad reputation, with the frequent misunderstanding that every activity should be documented. Now that the 2000 edition of ISO9001 has reduced the need for written procedures, there is an opportunity to stand back and look at what is really required.

ISO9001:2000 requires that every organisation that seeks to meet the standard should have documented statements of its quality policy and objectives, a quality manual, documented procedures "as required by [the] standard" and documents " needed by the organisation to ensure the effective planning, operation and control by the organisation.

Taking each of these in turn, the quality policy can be incorporated into the quality manual, and quality objectives can either be incorporated in the manual (if they do not frequently change) or documented in the minutes of meetings at which the objectives were set. The quality manual does not need to be lengthy, especially if the opportunity is taken to refer out to other procedures, rather than include them in the manual. The minimum requirements are that the manual should describe the scope of the quality management system, include references to the procedures, and include a description of the interaction of the processes of the quality management system. The last requirement can be conveniently met with a diagram, meaning that the quality manual can be as short as one or two pages!

As far as procedures are concerned, ISO9001 identifies only six areas that must be covered by written procedures: control of documents, control of records, internal audits, control of non-conforming product, corrective action and preventive action. Anything else is at the discretion of the company under the proviso of procedures "needed by the company". The temptation is to say "nothing" but perhaps this is taking things too far.

Documented work instructions provide information about how a process is to be carried out, in order to achieve a consistent desired result. The process may be making a product or providing a service. If doing the job in the wrong way can have quality, reliability, safety or environmental impacts, it is worth writing down how it should be done correctly, as an aid to training or as a check-list for the person doing the job. The style will depend on the content and the user. Work instructions do not have to be lengthy wordy documents (indeed with a less literate workforce, or staff whose first language is not English, such documents may be a waste of time). Documented procedures can be in the form of flow charts showing the sequence of operations, or check-lists that highlight the key steps and requirements. The use of check-lists can be useful, as they can serve both as an instructions and records of what has been done, with the operator signing or initialling to confirm their actions. The instructions may include such things as the order of doing things, machine settings, materials and tools to be used, and quality checks to be done.

Once documented, the instructions are a living record of the changes to the process. The instructions should be updated whenever the process is changed. Staff should be encouraged to identify process improvements, and to get these incorporated into the work instruction officially, rather than developing their own personal method that is good, but non-standard. The review of such changes allows for identifying the unwanted side effects that might not have been foreseen by the originator of the idea. It is not unknown for one person's short-cut to present problems for people further down the line. Therefore, changes have to be properly reviewed before they are incorporated, but once the procedure has been updated, everyone using the process needs to be made aware of the change, so that the new process becomes the standard.

Written procedures may seem to be a nuisance, but if managed properly, and in a suitable format, procedures can help to avoid quality problems.

If you would like help with improving your procedures, or with improving your quality management system, talk to QES Connect.

This is not a new topic, but one that is worth airing occasionally, because it is not always well understood. The Safety Representatives and Safety Committees Regulations 1977, and the Health and Safety (Consultation with Employees) Regulations 1996 place legal duties on employers to consult with their employees about health and safety. In workplaces where the employer recognises a trade union, the employer must consult with trade union appointed safety representatives on health and safety matters affecting the employees they represent. In workplaces where a union is not recognised, employees must be consulted on health and safety, either directly or through their elected representatives. Employers must consult on a range of health and safety matters, including:

• any measure at the workplace which may substantially affect their health and safety. For example, changes in procedures, equipment or ways of working;
• the employer's arrangements for getting competent people to help him or her comply with health and safety requirements and evacuation procedures;
• the information employers must give to employees about risks to health and safety and preventative measures;
• the planning and organising of health and safety training;
• the health and safety consequences of introducing new technology.

It also makes sense to discuss changes to health and safety matters with employees, to get their buy-in when trying to introduce change. In small businesses, consultation is usually by discussion with all affected staff, for instance in general employee meetings, but it is worth keeping a record of what has been discussed, to demonstrate that the requirements have been met.

If you need advice on consultation with your workers, talk to QES Connect.

The Work at Height Regulations 2005 were amended recently by the Work at Height (Amendment) Regulations 2007 that came into force on 6th April 2007. The main change related to the introduction of requirements relating to the provision of training on caving and climbing. To coincide with the new amendment, HSE has published a revised leaflet giving guidance on the Work at Height Regulations. It can be downloaded from the HSE website at www.hse.gov.uk/pubns/indg401.pdf.

You can hardly have escaped noticing the new regulations coming into force on 1st July banning smoking in all enclosed work-places. In implementing the new regulations, employers need to consider other safety implications of moving smokers outside to smoke. Will the smokers come back into the building by a back door that should normally be kept locked? Will the floor become wet because they bring in rainwater on their shoes? Will their smoking materials cause a fire hazard? We have seen examples of ash-trays catching fire because of the build-up of discarded smoking materials. It's time to think about these things (which means doing a risk assessment) as you implement the new smoking policy.

If you need help with risk assessment, contact QES Connect.

Ladder Exchange is a new HSE initiative aimed at ladder users and those who manage the work. They want to get sensible messages to these people about using a ladder safely. Falls from height continue to be the main cause of workplace fatality and one of the main causes of serious injury. Over a third of falls injuries are the result of a fall from a ladder. In February a worker in Coventry died following a fall from a ladder.

HSE say they know from their inspectors that many of the ladders being used in the workplace are not up to scratch. In the Ladder Exchange scheme, they aim to take 4000 of these 'dodgy' ladders out of the workplace. Ladder Exchange is a local initiative that will take place throughout June and July. Each area will hold its own 'week'. HSE and its partners in Local Authorities, ladder manufacturers and hire companies are planning a series of events in the summer aimed at ladder users in building and plant maintenance.

HSE and Local Authority inspectors will also be looking at safe ladder use in June and July 2007. They have a simple message to ladder users. If it is right to use a ladder, use the right ladder, use it safely. If it's not the right ladder, exchange it.

Although the Display Screen Equipment (DSE) Regulations have been around for 15 years, there are still many small companies who do not understand the need to provide training for DSE users, and to assess their workstations. HSE has recently re-issued its leaflet "Working with VDUs" that is aimed at both employers and employees. Copies can be down loaded from www.hse.gov.uk/pubns/indg6.pdf.

If you need help or advice on DSE work station assessment, contact QES Connect.

A rare example of a prosecution for horse-play, in this case with a nail gun. The two people involved (who were firing nail guns at each other) appear to have been self-employed, rather than employees, as they was prosecuted under the section of the Health & Safety at Work Act relating to the duties of employers, rather than employees. Each received a conditional discharge for 2 years, but one was required to pay £600 costs.

A Bedford company was fined £10,000 after an employee fell 3.5m through a mezzanine floor where boarding had not been replaced. The employee suffered serious injuries.

A Hertfordshire company was fined £9,000 plus costs for failing to ensure the safety of employees. The light guard on a hydraulic press brake had been over-ridden, and an employee suffered a crushed hand.

An Essex company was fined £5,000 with £3,835 costs after an employee was found working at height without adequate measures to prevent a fall. The employee had been lifted to the top of a road tanker on a pallet lifted by a FLT.

Another Essex company was fined £14,000 with £4,754 costs after an incident in which a flour mill employee lost the top joint of his right middle finger while clearing a possible blockage in the dust collection unit in the flour mill.

Source: HSE published information.

The best way to avoid prosecution is to have a robust health and safety management system, built around the elements of "Plan - do - check - act". If you want help with health and safety management, talk to QES Connect.

At the request of the Health and Safety Commission, the Institute of Directors is leading a steering group consisting of key stakeholders to oversee the production of new, authoritative guidance setting out what is expected of directors. The Institute is conducting the consultation on the draft version of the guidance and has been running a consultation, for a 6 week period, until approximately 22nd June.

Views were being collected via the website www.iod.com/hsguide.

Produced by QES Connect Ltd. Except where stated, the material included in the newsletter is taken from freely available public sources. It may be reproduced without permission for non-commercial purposes.