Goodbye

This is my last post on the Blog – I will be moving onto a new role. I will keep this blog site up and running but it will not be updated. For up to date details on ATC Risk Management visit the web site on www.atcrisk.co.uk

Sharps Training: why it’s important for workers at the sharp end

My health and safety training team has been busy these last few months working with clients on designing and delivering sharps training for workers across a number of industries. It’s an interesting subject and a significant risk to many workers – not just in traditional health care settings but in virtually all industries. I was talking to a client recently who specialised in void house clearances for local authorities, and the horror stories of needle sticks stuck to mail boxes, stair rails and hidden inside sofa cushions is quite scary.

So what is the problem?

A sharps injury is where a needle or sharp instrument, such as a scalpel (collectively referred to as ‘sharps’) penetrate the skin. This is sometimes called a percutaneous injury. If the sharp is contaminated with blood or other body fluid, there is a potential for transmission of infection. Although this is rare, injuries from sharps contaminated with infected blood can transmit more than 20 diseases, including Hepatitis B, C and human immunodeficiency virus (HIV). Good sharps training will give a clear overview of the risks to delegates.

Transmission of infection depends on a number of factors, including the person’s natural immune system.  We know the number of injuries each year is high, and only a small number are known to have caused infections that become serious illnesses.

What should employers do?

Employers should need to take action to manage the risks to workers. They should undertake a risk assessment. The risk management process will help you identify the hazards; consider the nature of the work; evaluate the risks; and implement, monitor and review control measures to reduce the risk.

Employers must:

• ensure standard precautions for infection control are in place;
• ensure all employees, and workers under your control, have information and instruction on safe use of sharps ideally through sharps training;
• ensure that suitable clinical waste disposal procedures, including use of sharps containers, are followed;
• ensure that suitable PPE is provided such as protective footwear, gators, gloves or equipment such as sharps grippers;
• provide access to occupational health advice, and immunisation, where appropriate
• have clear procedures for response to sharps injury, including speedy access to appropriate prophylaxis treatments
• record work-related sharps injuries in your accident book and report to the HSE an infection to an employee if it is reliably attributable to their work.

What to do if you receive a sharps injury?

If you suffer an injury from a sharp which may be contaminated:

• Encourage the wound to gently bleed, ideally holding it under running water;
• Wash the wound using running water and plenty of soap;
• Don’t scrub the wound whilst you are washing it;
• Don’t suck the wound;
• Dry the wound and cover it with a waterproof plaster or dressing;
• Seek urgent medical advice (for example from your Occupational Health Service), as effective prophylaxis  (medicines to help fight infection) are available;
• Report the injury to your employer without delay.

Good prevention such as effective risk management and sharps training is key to preventing this hazard becoming a reality.

Classroom learning, distance learning or e-learning?

Quite often I get asked my views on which route is best to learn, especially with in depth courses such as NEBOSH Certificates or the NEBOSH Diploma. The general options these days are traditional classroom based learning, distance learning or the more modern e-learning.

I have both experienced as a student and as a tutor all these methods, and firstly I have to say there is no real difference between distance learning and e-learning other than the use of a computer screen instead of a book. I was once told e-learning is the future of learning; however I expect this to realistically happen about the same time as I get my jetpack! I very much struggle learning from a box I spend most of my day looking at, and even with the “interactive” content of e-learning I find my attention slipping too easily. Tools such as smart phones and tablet PCs make the e-learning process easier, but I still believe that the attraction of spending even more time looking at the goldfish bowl of a computer screen not that appealing.

Distance learning is still a popular route to learning, and has its benefits. It allows for flexibility in learning and tends to be cheaper than traditional classroom based learning. It’s ideal for people who like to learn at their own pace, perhaps someone who can plan out a study schedule and stick to it. Intensive courses like the NEBOSH Diploma really do require a large degree of dedication and commitment to study so anyone planning on distance learning for this type of course really needs a high level of self discipline, otherwise it’s far too easy to fall behind. Often learners find that the support of a remote tutor is just not enough to assist them with tricky subjects.  

My preference has always been classroom learning as the best form of learning, especially for those longer or more intense programmes. The benefits of classroom learning include the presence of a tutor at all times and the support of the other learners. This is something often underappreciated by many. Other learners are great at offering support, encouragement and even anecdotes or experiences that help with learning. Classroom learning also offers a more structured approach to learning, with each subject broken into manageable chunks and covered in an effective way. Good tutors use a range of methods to engage fully with the different learning styles of learners, ranging from presentations, group exercises, case studies, videos and much more.

At ATC Risk Management we run our NEBOSH Diploma programme as a classroom based course. I am a big believer this is the best way for such a programme as it really allows for structured learning, with the ongoing support of the tutor and other delegates. The pace of the course is based on the learners’ needs, so the progress ensures that material is covered and the learning is embedded.

Whichever route you opt for, think seriously about what works best for you. How will you best learn, and what provider is going to offer you the best support.

NEBOSH Diploma done? What next?

Often I get asked what next after the NEBOSH Diploma – it’s a valid question because the NEBOSH Diploma is one of the most respected and well known professional level qualifications for a health and safety practitioner.

So if you’ve achieved this milestone where do you go next?

I believe there are two routes open to the practitioner.

The first is to go even further with your studies in health and safety such as a conversion course to an undergraduate degree in health and safety or further study to postgraduate diploma or even MSc level. Lots of Universities now offer health and safety programmes on a distance learning, blended or part time basis. This option makes a NEBOSH Diploma holder stand out even more, enhancing your professional knowledge and CV alike.

The second route is to diversify your knowledge – such as exploring environmental management, quality management or risk management. There are a good number of courses in the environmental field such as the NEBOSH Environmental Certificate, IEMA Associate Members course, and bodies such as the CQI and IRM can advise on other specialist areas. Alternatively courses such as noise assessment qualification from the IOA or an 18001 Lead Auditor course can also broaden opportunities and skills.

Whichever route you consider I strongly suggest the NEBOSH Diploma holder continues their learning. Ours is a profession where continually gaining new skills, experience and knowledge is essential.

Also don’t forget the IOSH IPD scheme – as a NEBOSH Diploma holder you should upgrade to Graduate Member status and work towards Chartered Membership. See my earlier blog on the benefits of this.

The Challenege Panel is launched

An independent panel to consider challenges to health and safety advice given by inspectors has now been launched.

The Health and Safety Executive (HSE) is supporting the new panel, which will look into issues raised by a business when they believe a HSE inspector or local authority environmental health inspector has given advice that is incorrect or disproportionate. The panel will not look at issues where other appeals processes exist, such as for enforcement notices or prosecutions.

The Government have announced the panel will be chaired by Tricia Henton, an experienced former regulator at the Environment Agency and is composed of independent panel members who have the competence and experience to assess advice that has been given on regulatory matters. 

Ministers asked for the panel to be established following a recommendation in the Löfstedt report, which proposed that the Government introduced a challenge mechanism that allows for cases of incorrect, over-application of health and safety legislation to be addressed.

For more information about the panelvisit the HSe web pages: http://www.hse.gov.uk/contact/challenge-panel.htm

Löfstedt – What does it mean?

The report by Professor Ragnar Löfstedt published on 28 November 2011 recommends no major changes to UK health and safety law. However there were a number of recommendations that are worth noting and which have accepted by the Government:

Exempting from health and safety law those self-employed whose work activities pose no potential risk of harm to others

The Health and Safety Executive (HSE) will be required to take action to remove health and safety burdens on the self-employed in low risk occupations, whose activities present no risk to other people. Whilst the enforcers are extremely unlikely to visit self employed persons in low risk activities, it is often the fear of inspection and prosecution which causes concern. This recommendation should remove that concern. The timescale for achieving this is 2013. It will be interesting to see how this is done without creating over complicated exceptions.

Review of all Approved Codes of Practice (ACoPs)

The HSE will be required to review the 53 ACoPs to ensure they are easier to understand. Quite often, ACoPs are criticised for being over complicated or vague. The Government wants to see simplified language and examples of good practice. The initial review should take place by June 2012.

HSE to make sector specific consolidations

The review identifies a number of areas where health and safety legislation can be consolidated. Legislation that is out of date or repeated elsewhere will be reviewed and it is anticipated that the number of health and safety regulations can be reduced by more than 50% without reducing the protection offered to employees and the public. Legislation which offers no improvement to health and safety outcomes or where there is duplication will also be repealed. There will be a requirement for the HSE to consult on the proposed changes and a detailed timetable will be drawn up. This review should be completed by April 2015. Many of you, like me, will be happy to see the of such frivolous regulations as the Notification of Convention Tower Crane Regulations and the Construction (Head protection) Regulations which are simply unnecessary or duplicatory.

HSE will direct all local authority health and safety inspection and enforcement activity

The Government is conscious that it does not want to move towards a centralised system that is further removed from local businesses and communities. Knowledge and experience of local inspectors is very important. However is was recognised there is a need for improved training of inspectors and the need to take a more consistent and proportionate approach to enforcement. A review of the Primary Authority scheme is ongoing and plans to address these issues will be announced soon.

The original intention of the pre-action standard disclosure lists is clarified and that regulatory provisions that impose strict liability should be reviewed by June 2013

Löfstedt noted that many employers do not make a distinction between health and safety regulation, which is criminal law; and personal injury claims, which is civil law. The fear of civil litigation has often been the main driver behind over zealous implementation of health and safety requirements – just look at any of the “bonkers conkers” stories to confirm that. In my view this complicates the issue and makes it difficult for employers to focus on the real health and safety risks.

Pre-action standard disclosure lists were originally designed to be a specimen list of documents that might be material in resolving personal injury claims as per the Lord Woolf Reforms of 1999. Löfstedt reported that employers are encouraged to settle claims if all the paperwork is not in place, regardless of their overall compliance record – again a practice many of us in the industry will be familiar with.

Löfstedt also reported concerns on offences which impose a ‘strict liability’ duty (i.e. there is no defence of having done all that is ‘reasonably practicable.’) From a criminal perspective, regulators still have the choice as to whether criminal enforcement action should be taken. However, in the world of civil litigation, liability follows as a result of health and safety breaches where the liability is strict. Therefore, employers find themselves paying damages despite having taken all reasonable steps to protect their employees from harm. The Government will look at ways to redress this balance.

Working with the EU

With half of all legislation affecting UK business originating from the EU, the Government recognises the need to work more closely with the Commission to ensure that both new and existing EU health and safety legislation delivers a proportionate, risk based approach.

Conclusion

The Löfstedt report follows on from the Lord Young report Common Sense, Common Safety. The UK regulatory regime is very cumbersome to negotiate, and doing all that is reasonably practicable is a difficult task – it is therefore important that businesses seek the correct advice so they can concentrate on reducing the risks that need to be reduced. Having a positive safety culture within your organisation is key. Good health and safety require the buy in from every member of staff, from director to worker. Without this, the system will fail. I hope the Löfstedt report assists employers with their duty whilst allowing for a more streamlined regulatory framework.

To Grit or Not to Grit

It’s now December – Christmas is coming and so too is the bad weather. To keep this blog topical I will talk about the weather, and ask the question to grit or not to grit?

It seems every year the media fuels more silly health and safety stories scaring organisations and business away from doing the sensible thing. If we believed some headlines then occupiers of property taking sensible precautions against an accident – such as gritting their own paths and roadways – are liable to find themselves in court.

If we look at the law then the position of employers and property owners is pretty clear. The Occupiers’ Liability Act states that property owners have a duty to maintain reasonable safe access to persons on site. This means taking reasonable steps to clear ice or snow from access ways.

The Workplace (Health, Safety and Welfare) Regulations and its accompanying approved code of practice is even clearer: “Arrangements should be made to minimise risks from snow and ice. This may involve gritting, snow clearing and closure of some routes, particularly outside stairs, ladders and walkways on roofs.”

The risk of legal action from clearing snow and ice from your premises comes if you acted completely unreasonably, and somehow created a new hazard that had not existed before your actions. With any properly planned and managed control measure this should not be the case.

Often the concern comes when companies and organisations consider snow clearing outside of their site – such as public highways and pavements. In this case there is no legal duty requiring the employer to clear the snow and ice, as this is the duty of the relevant highways authority. But if a business or organisation chooses to do so – for example to prevent staff or customers having accidents on their entrance and exit – then the same conditions apply, in that as long as the business acts reasonably and does not create a new hazard then it should not attract any liability.

So what’s the answer to the original question: the answer is be reasonable, be sensible, and make sure your staff and visitors can move onto and around your site safely. Treat the snow and ice as you would any other risk to people’s safety – a hazard that needs controlling sensibly.

NEBOSH Diploma – is it really that hard?

It is fair to say that the NEBOSH Diploma is the most prestigious qualification for a health and safety practitioner to hold. It has long been established as an internationally recognised standard of knowledge and expertise. 10,000 students have now achieved this qualification since its inception in 1988.

Often it is considered a very hard qualification to achieve – but is that a fair statement to make?

There has been a lot of stigma about the qualification, often supported by anecdotal evidence from past candidates and on occasion some low pass rates (the latest NEBOSH figures available, for January – June 2011, put the pass rate at 73%).

To answer the question we must look at the level of the NEBOSH Diploma. The current syllabus is regulated by the Scottish Qualifications Authority who have placed it at level 10, which is equivalent to level 6 in the English and Welsh system. This broadly equates to a Bachelors Degree. IOSH recognise the qualification as meeting the requirements for Graduate Membership, whilst IIRSM recognise it as meeting the requirements for full membership.

Any qualification at this level is going to be hard to achieve. So I guess the answer to the question is yes. But is that the end of the story?

I personally think that for a qualification to really mean something it has to be hard to achieve. This means those that hold the qualification have really achieved something. Lets think of the criticism of the Health and Safety Test for CSCS Cards – with questions often derided as being too easy, is the achievement of the test something to be very proud of? We certainly can’t say that of the NEBOSH Diploma. Every person who has achieved the NEBOSH Diploma can stand proud and say they have achieved a high standard of knowledge and expertise in health and safety.

So we have said the qualification is hard to achieve – but is it too hard? The answer to that is very much down to each student. There is no clear answer to this, as I would say you get out what you put in. Achieving the NEBOSH Diploma does require active involvement in the course, a large degree of self studying and good exam preparation. In my next blog article I will share some tips on how you can achieve these 3 elements.

Any good training centre will also provide ongoing help and support throughout the study period to support your learning. I would suggest this is a key question to ask of any potential provider you look at.

So my advice to anyone considering the NEBOSH Diploma is do some research – seriously look at what is involved, look at the support from your provider, look at the benefits when you achieve it – and if you can commit to the hard work then go for it. I have no doubt when it pays off, and you pass the NEBOSH Diploma, you will have achieved something to be very proud of.

Diploma or NVQ – which one is right for you?

Very often I get asked the question of which professional health and safety qualification is the best – mostly between the NEBOSH Diploma and the NVQ Diploma Level 5 in Occupational Health and Safety (formerly the NVQ Level 4).

Firstly I should say these are not the only options – IOSH maintain a list of qualifications they consider suitable for Graduate Membership which is well worth giving full consideration towards. Many universities now offer undergraduate and postgraduate qualifications in health and safety. However, the big two players still remain the NEBOSH Diploma and NVQ Level 5 Diploma.

So, is one better then the other?

Short answer: no. A lot of safety practitioners have a preference towards one or the other, and often I find they prefer to recommend the route they themselves undertook. But the reality is no one is better than the other. The difference is all about the learning process. The NEBOSH Diploma is an excellent qualification for those wanting to learn – it relies on the traditional method of teaching the student and then testing that knowledge is understood through exams.

Therefore the NEBOSH Diploma is great for those wanting to learn – maybe a new practitioner wanting that knowledge for the first time, or an experienced practitioner wanting to top up or refresher their knowledge whilst obtaining the qualification to enhance their career.

The NVQ Diploma Level 5 is specifically designed for those who are already in a health and safety practitioner role and who have already achieved a high degree of practical experience and theoretical knowledge. It replies on the student proving their competence through the submission of high quality evidence. The current standards expect that the student has an autonomous role for managing health and safety in an organisation with complex risks.

Whichever route is best for a student is very much an individual choice as to what they want to get out of the qualification. Contrary to popular myth no one is easier then the other – the NEBOSH Diploma has some tough exams that require hard work to pass, whilst the NVQ Diploma Level 5 expects you to be able to present a good selection of high quality evidence showing an equal amount of knowledge. Likewise no one is quicker than the other, as it all depends on where you are in your career and how much time you can commit to study.

For those considering either of these courses I strongly advise careful research into each. Make a considered decision as to which is going to give you the most valuable learning experience. It’s not just about the end result, but also what you learn and experience on the way there.

Six Little Letters: The Benefits of Chartered Membership

I often get asked the question of whether putting in the effort to attain Chartered Membership of IOSH (CMIOSH) is really worth it. After all, if you’ve been in the industry for many years, have lots of experience, surely that counts for the same?

The reality is that these days the market place is crowded – there are lots of health and safety professionals competing for jobs and you need to stand out. Likewise if you are a consultant, there are many competitors out there battling for the same clients.

What’s more, for my fellow consultants, the new voluntary Occupational Safety and Health Consultants Register (OSHCR) maintained by the HSE requires Chartered Membership (with a few others accepted).

So what are the benefits?

I think the main benefit is professional recognition. We have strived for many years as a profession to get health and safety seen as a key element of the business, and it is only right that we in the profession grow into the role we have created. If you are looking for a senior accountant, do you not look for a Chartered Accountant? If you want a professional building survey, don’t we look for Chartered Surveyors? Why should we be different?

These days the routes to achieve CMIOSH are varied; this could include university degree, the NEBOSH Diploma or the NVQ Level 5 Diploma (replacing the “old” NVQ Level 4). These different routes are each unique, and in my next blog I will discuss the merits of each. The IOSH scheme to upgrade from Graduate Member to Chartered Member is now easier to access than ever, and IOSH provide support throughout the process with their mentors. There really is a no excuse.

One of my great pleasures is working with health and safety practitioners through the NEBOSH Diploma or NVQ route to help them along the road to becoming CMIOSH – and I am more then happy to discuss this with any of my readers, you are welcome to give me a call.

Chartered Membership shows that the health and safety professional has achieved a high level qualification, demonstrates experience, has undertaken a rigorous process of selection to achieve the membership level and maintains ongoing continual professional development.

That’s quite a lot to show through 6 letters after your name.