22 August 2012
Although the Robens Report, on which our current legislative framework, the Health & Safety at Work, etc. Act, is based is now 40 years old, last year’s review by Prof. Ragnar Löfstedt and his committee found that in essence it was still a sound piece of legislation. While implementing a risk based approach to health and safety management, it did provide a mechanism for the introduction of more specific legislation which incorporates the provision for public consultation on any proposals to introduce, repeal or revise regulations.
For example in his report, Prof. Löfstedt proposed a review of RIDDOR to provide clarification for businesses in addition to the proposal in the previous year’s review by Lord Young, to increase the 3-day reporting requirement to 7 days. This has resulted in the publication, by HSE, of a consultative document which is open for public comment until October 28th 2012.
In what seems to be an unusually busy period for our health and safety regulators we have also seen consultative documents published on subjects as diverse as:
• Revoking fourteen legislative measures and seven Statutory Instruments which are felt to be no longer applicable
• Reviewing the format of Approved Codes of Practice with a view to making them more readily understandable by business
• Exempting some categories of self-employed workers from health and safety legislation where their activities are not deemed to present a risk to others
• Implementation of the European Directive on prevention of sharps injuries in hospitals.
Of these, the last three are still open for comments.
All these documents are available for download from the HSE website (www.hse.gov.uk) together with forms on which responses can be made.
This consultation process provides all stakeholders with an opportunity to help ensure that the changes are appropriate and acceptable. But this will only be achieved if a sufficiently high proportion of stakeholders participate. As a key stakeholder IIRSM will be presenting a response but we would always encourage our members to make their views known to HSE and also to send them to us so that they can also be incorporated in the Institute response. We have already had some responses from members to the RIDDOR consultation and further thoughts on this and the others would be welcome. These should be sent to myself at barry_h@iirsm.org, as I shall be coordinating our responses. Please take this opportunity to be constructive and help shape these changes.
Barry Holt, IIRSM Director of Policy & Research
