Six months of rapid health and safety improvements
Background
Whilst performing the role of Health and Safety Advisor for 63 sub-stations in Ireland, our Coyle Group consultant proactively drove significant improvements in making our customer’s business a safer place to work, in the first half of 2021.
Five Critical Issues
Our Coyle Group consultant identified many opportunities to improve the safety of sub-station work on this assignment. Safety on sub-stations is particularly important due to the high voltage electricity that workers can be potentially exposed to in the case of error or accident, which can lead to fatalities. We observed five key areas which presented critical risk to our customer and their staff. Our consultant alerted the customer’s management to these issues and played a core role in implementing the appropriate action to resolve them.
1. CLIENT AGREEMENT
Coyle Group identified that there was no client agreement in place between the customer’s client and our customer on a specific site in Ireland.
It is a client’s duty to ensure the client is defined and agreed in writing. Without this, there is a lack of clarity over legal responsibilities, especially in the case of a serious incident occurring. Coyle Group acted swiftly to draft a client letter and get it signed off, resolving the issue altogether.
2. DESIGN RISK ASSESSMENT
Coyle Group identified that construction designers were not fully complying with Procedures or Construction Regulations Design Risk Assessment requirements. Safety Health and Welfare at Work Regulations 2013 state that designers shall take account of the General Principles of Prevention. All designers must take into account existing hazards on the project. The customer was potentially breaching this regulation when construction designers were not fulfilling design risk assessment requirements.
On identifying this gap, our consultant worked with the Asset Management team to develop a Design Standard Hazard Register suitable for our customer’s projects. This enabled Asset Management designers to demonstrate compliance with Procedures and Construction Regulations in eliminating or mitigating the risk throughout the design process. Once embedded in the design process, construction designers can conduct appropriate site-specific design risk assessments.
3. EMERGENCY PLAN
Our consultant also identified that network technicians were operating mobile elevating work platforms (MEWPs) without an emergency plan in place. This was potentially breaching the Work at Height Regulations 2007, which specifies that an employer must put in place a system that includes emergency instructions and procedures.
After identifying this issue, our consultant worked with the customer team to develop a revised national MEWP procedure (including an emergency plan), a risk assessment and put in place a plan for training network technicians on the procedure. When approved, the training will be rolled out nationally by the customer training team.
4. EASY ACCESS TO PROCEDURES
On observing and engaging with the network technicians, our consultant received feedback that existing procedures were too numerous and lengthy to be practical to the technicians. This often led to network technicians not using the procedures when doing maintenance work on the sub-stations. However, to comply with legislation (Safety, Health and Welfare at Work, 2005), procedures must be used due to the high-risk nature of the work that the technicians are conducting.
To resolve this issue, our consultant developed a new sub-station maintenance risk assessment method statement (RAMS) template with relevant procedures easily accessible in an appendix. This template enabled the procedures to be easy to find, always at hand and making it simpler for the network technicians to use.
5. LIFT PLAN
When reviewing the customer Lift Plan, which should provide guidance on good practice lifting procedure, our consultant identified important areas for improvement. Coyle Group recommended that additional information be included in the plan and that it should be signed off by an appointed person (AP). This action would prevent a potential breach of compliance with General Application Regulation 42, which states that an employer should ensure that all lifting operations are properly planned.
To mitigate this issue, our consultant drafted a new, more detailed national Lift Plan, and provided this to the customer for approval by the AP.
Results
Working with the customer team, our consultant delivered solutions to mitigate the critical risks identified:
- A client’s letter was developed to clarify client responsibilities
- A design standard hazard register was developed
- MEWP national procedure and risk assessment developed
- Plans to roll out a national training plan to network technicians once procedure and risk assessment approved
- Substation maintenance RAMS template developed with risk assessment and easy access procedures
- A new detailed national Lift Plan was developed
Benefits
By July 2021, multiple critical Health and Safety risks at our customer had been mitigated and even, in some cases, eliminated. Not only did these ensure the safety and compliance of our customer’s work on specific sites but some of the improvements had a nationwide impact, putting good practice in place across the whole organisation.
Our customer’s management can have confidence that they now have the plans and procedures in place to keep staff safe and be compliant with legislation on sub-stations.
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RIDDOR and COVID-19
Many employers are concerned about their reporting obligations for COVID-19/Coronavirus/SARS-CoV-2 under RIDDOR in the ongoing pandemic. You may be pleased to know that you do not have to report everything to the Health and Safety Executive (HSE). We'll provide more info about when, what, and how to report.
The most common concern we've seen recently from employers is whether they need to report all COVID-19 and coronavirus testing results to the HSE. The short answer is no. According to the HSE: “There is no requirement under RIDDOR (The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) to report incidents of disease or deaths of members of the public, patients, care home residents or service users from COVID-19. The reporting requirements relating to cases of, or deaths from, COVID-19 under RIDDOR apply only to occupational exposure, that is, as a result of a person's work.”
Generally speaking, the ordinary RIDDOR rules already cover COVID-19. You should only make a report under RIDDOR when one of the following circumstances applies:
• an accident or incident at work has or could have caused the release of coronavirus (SARS-CoV-2). (Report as Dangerous occurrence)
• a worker is diagnosed with COVID-19 due to occupational exposure. (Report as Disease)
• a worker dies because of occupational coronavirus exposure. (Report as Work-related death due to exposure to a biological agent)
The bottom line is that existing rules cover most COVID-19 measures, and most of the COVID-19 guidance comes from public health authorities rather than the HSE. The environment remains chaotic, but you can minimize your legal exposure by continuing your existing compliance steps. This will include communicating with your insurer about risks, following public health guidance, and communicating regularly with your workers or unions on any of their concerns.
© Gavin Coyle, 2021