Hi, I’m Chris Walker, Head of Health & Safety at Napthens Health & Safety, thanks for taking the time to join me for this month’s Health & Safety discussion. It doesn’t seem two minutes ago that I was recording my last QCS Health & Safety Podcast, however due to the publication of far more exciting recent Podcasts by my colleague Neil – it’s actually as far back as 2021 that I last sat down to record one of these! We’ve gone from being careful with driving during the Winter through to today’s subject in the blink of an eye, and when you listen to this, I’m fairly sure it will officially be British Summer Time - if the weather stays like it is today, I certainly won’t be complaining!
It's not just Crème Eggs and long weekends you know…April is also that time of year where health and safety professionals and businesses of all kinds are evaluating the impact of changes to Health & Safety legislation, working out which changes apply to which businesses and what needs to be done to comply - this is no different in 2022. We recently published an article on the subject of changes to the Personal Protective Equipment at Work Regulations. On 6th April 2022 the Personal Protective Equipment at Work (Amendment) Regulations 2022 will come into force and while we’ve covered this in detail in the article I mentioned, in a brief summary the new rules amend the 1992 regulations and broaden the types of workers for whom employers are responsible with regards to their duties related to PPE provision and management. Now, while there aren’t any changes to what employers are required to do, there are changes to who they need to do it for. Please take the time to review the changes in the published article and make sure you’re meeting your responsibilities which now include provision of suitable PPE to those workers with whom you have a more casual employment relationship.
Of course, the provision of suitable and effective protective equipment, specifically designed to prevent harm from whatever risk your employees are facing is critical, but it is only a very small part of the risk management requirements of an employer. You may well be fully compliant with your duties under the old and the new PPE regulations already but that on its own is nowhere near enough.
All too often in my experience across many businesses and in most industry sectors, PPE is seen as the only matter of importance as far as health and safety is concerned, good health and safety is only evident in a business if everyone is wearing a hi viz vest and a hard hat – whether there’s a relevant risk that would necessitate their use or not!
So often the risk assessment process is shortcut to a simple assessment of what might cause harm followed by a bulk order of PPE which gets unceremoniously dumped on employees without any explanation of what it’s for, how to use it and what might go wrong if they don’t! Now, not only does this approach leave it highly likely that the PPE itself isn’t going to get used or might not work effectively if it is used but it also completely misses the point from the point of view of meeting your employers’ duties!
If it’s dusty, let’s buy some dust masks – ignore what’s in the dust or how much of it there is and don’t bother trying to remove it from the workplace or remove the people from the workplace area it’s found in – just buy some masks – doesn’t matter what type! If its noisy, don’t worry about how noisy it is or how long it’s that noisy or waste time thinking about how we can make it quieter or remove people from the noise – just buy some ear plugs they’re cheap enough aren’t they.
This approach is all too common, ignoring the fact that, as an employer, you should be doing all that you can to properly understand the potential risks faced by your employees and others affected by your work activities and then find effective means of control! The provision of Personal Protective Equipment is right at the bottom of what we health and safety types refer to as the hierarchy of control and there’s a reason for this – it’s the least effective way of preventing your employees and others being harmed by hazards in the workplace.
The General Principles outlined in the Management of Health & Safety at Work Regulations 1999 must be followed in the implementation of control measures which are introduced to reduce the risk of harm to anyone from risks associated with their work activities. While there are a range of other regulations on specific hazards, such as the COSHH, Manual Handling or Work at Height Regulations which all describe effective control strategies for management of risks from workplace hazards – they all pretty much follow a similar path.
Ultimately, once you’ve identified something with the potential to cause harm in your workplace, a hazard, you should do what you can reasonably do to get rid of it rather than think about how to protect people from it! If it’s gone it can’t cause any harm, no one can interact with it and no one gets hurt. Now of course it’s not always simple and it’s certainly not possible to remove all hazards from all workplaces but thinking about how you could do the work differently, organise it in a different way, do it in a different place, using a different substance or tool should always be the first consideration. Only then, after we’ve confirmed there’s no reasonable way of removing or eliminating that hazard altogether should we be looking further down the ladder at less effective means of risk control.
These hazards we’re left with need to be managed, we have to look at means of reducing the likelihood of interacting with them or mitigating the consequence if interactions occur. We should consider how we can make the hazard less, well hazardous, different chemical substances could be used, lower weights handled, lower speed limits introduced. Then we can consider putting in place barriers, guards and preventing people coming into contact with the hazard altogether.
We must train people to work safely with the hazards we have left – using rules, safe operating procedures and safety signs. Now after all that we can think about what, if any, PPE might be needed to deal with any of the hazards that could still cause harm!
PPE might well add some critical additional risk mitigation against an identified hazard but please, don’t think PPE first, try and eliminate or reduce that risk at source.
I would like to thank you all for taking the time to listen to this recording and look forward to discussing further key health and safety topics with you in the coming months. Thank you and take care.
