According to the executive, a method statement “describes in a logical sequence exactly how a job is to be carried out in a safe manner and without risks to health. It includes all the risks identified in the risk assessment and the measures needed to control those risks” (bit.ly/2hRNhzx).
But a method statement is different from a safe system of work (SSoW). A method statement for changing a lightbulb could explain how to transport and check the ladder and its set-up, how to isolate the power, how to carry the bulb up the ladder, and what to do with the old one. The method statement’s effectiveness depends on adequate procurement processes for the ladder, the light fittings and the lightbulbs, inspections of the ladder and fixed wiring, and training for the lightbulb changer.
The method statement for changing the lightbulb is just one part of the total SSoW. S 2(2) of the Health and Safety at Work Act summarises some of the requirements for a SSoW (without using that term) and includes plant and systems, arrangements for maintenance and appropriate information, instruction and supervision.
A complete SSoW should also include emergency procedures and arrangements for monitoring and audit. A method statement that included this much information would be unwieldy and unhelpful for the person asked to carry out a single task.
The Rail Safety and Standards Board (RSSB) has replaced the term method statement with three separate terms: a project level health and safety plan, a site level work package plan and a briefing document called a task briefing (bit.ly/2h0KCQF). Hence, the SSoW can be recorded at project level, leaving the briefing to focus on the methods for a specific task.
A method statement is different from a safe system of work
Case law has made it clear it is not enough for employers to assume that an experienced employee will work out what to do to stay safe even if the risk in the activity they are carrying out is clear. As early as 1953 in General Cleaning Contractors v Christmas, the House of Lords concluded that the employer was at fault for failing to provide a safe working method for a window cleaner. The employer had argued that an employee should have known to wedge open a sash window, since holding onto the edge of the window was the employee’s only means of preventing a fall. But the law lords ruled: “It is the duty of an employer to give such general safety instructions as a reasonably careful employer who has considered the problem presented by the work would give to his workmen.”
Another window cleaning case provides guidance on when a generic method statement can be applied, or when a variant is required. In Drummond v British Building Cleaners, Mr Drummond had been provided with a safety belt and rope, and instructions on how to attach the belt to an eye-bolt or hook near a window.
Since the windows had no such attachments, the cleaner fell when his foot slipped. The employer argued that it was down to the employee to adapt the method to each type of window, and that he could have attached the safety rope to the transom above the window. But Lord Justice Parker found that, though an employer is not “expected to lay out the job window by window”, British Building Cleaners was at fault for not prescribing the use of the transom.
The level of differentiation needed in method statements will always be a matter of judgement, but such cases suggest that, if a method that is safe for one activity is unsafe or insufficiently detailed for another, a different method statement is required.
Method statements are often divided into multiple sections: equipment; method; safety issues; personal protective equipment and so on. Risk assessments and method statements commonly provided by contractors separate the former from the latter. These portioned approaches separate the steps required to maintain safety from the steps required to do the job, so that while following the task instructions the user needs to refer elsewhere for safety measures.
To avoid human error, the safety measures should be included within the method statement – for example, ensure the instruction “check the ladder is stable before climbing” is on p 1, rather than on p 3 in the “safety issues” section, where it will probably remain unread.