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OSHCR needs reform, says outgoing HSE chair

The Occupational Safety and Health Consultants Register (OSHCR) needs a “radical rethink”, according to Dame Judith Hackitt, who recently left the Health and Safety Executive (HSE) after eight years as chair.

Dame Judith Hackitt

“I have my doubts as to whether OSHCR in its current form can deliver,” she said. “We would probably be better off to have a much more radical rethink and look more closely at when expertise is needed and how that’s defined.” 

OSHCR was set up by the HSE in 2011 after the government report Common Sense, Common Safety, by Lord Young noted the lack of an accreditation scheme for OSH consultants. 

At the launch in 2011, Hackitt said the register would provide “an independent way of demonstrating professional competence in occupational health and safety consultancy and should also encourage those who have not yet met these standards to do so.”

However, in an interview with IOSH Magazine shortly before she left her post in early April, Hackitt said: “I don’t think it has done what it set out to do at all.”
The register did not filter out poor general OSH consultants.

“The good ones listen to what their customers want and provide proportionate solutions,” she said. “The not-so-good ones impose and sell through fear. [They say] ‘you must do this or you will be locked up’ or whatever.” 

Hackitt said there was a role for specialist consultants such as occupational hygienists, but she questioned whether generalist consultants were needed. “My first preference would be for the business to deal with the risks themselves,” she said.

Registration with OSHCR is voluntary and the register currently has details of 1,778 consultants. It is open to individuals who have achieved chartered member status with IOSH, the Chartered Institute of Environmental Health or the Royal Environmental Health Institute of Scotland. Fellows of the International Institute of Risk and Safety Management with degree-level qualifications and members of the British Occupational Hygiene Society and Chartered Institute of Ergonomics and Human Factors also qualify.

Applicants are asked to commit themselves to continuing professional development, have professional indemnity insurance, and provide proportionate advice. 

“There are many good consultants out there but unfortunately we only seem to hear about the bad ones,” said Craig Foyle, chair of the IOSH consultancy group. “The consultancy group is working closely with the IOSH representative on the OSHCR board and has also raised concerns over the effectiveness of the scheme. In addition the group is also trying to raise the profile of what good consultancy looks like.”  



Louis Wustemann is former editor, IOSH Magazine. He was previously editor of Health and Safety at Work magazine and Environment in Business. He has written, edited and consulted on health and safety, environmental and employment matters for more than 25 years.

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  • Perhaps they should have said

    Permalink Submitted by Roger Bentley on 27 April 2016 - 01:00 pm

    Perhaps they should have said this before taking my subscription!

    • I agree. It was already

      Permalink Submitted by Joe Portelli on 28 April 2016 - 07:39 pm

      I agree. It was already obvious that just paperwork does not override recognised competence, which the HSE has left accreditation schemes to the industry. Through just OSHCR the potential for a registered practitioner is not necessarily recognised by the very Industry one claims to service. For example some claim to be in Oil & Gas and never heard off IMCA, OGP etc., let alone the required industry competency scheme as recognised years back by the HSE themselves. A register has a place , but is not proof of competence as understood in industry and clients know their industry better than many of those registered.

  • I am disappointed to read the

    Permalink Submitted by Adele Partridge on 27 April 2016 - 01:07 pm

    I am disappointed to read the comment above. I have recently paid membership to OSHCR having worked as a H&S Consultant for over 12 years mainly on behalf of large consultancy companies. I always found fault with delivery of H&S for big companies who restricted me to provide partial H&S services to clients due to financial reasons. Many of these clients were left without suitable support to manage their H&S systems. I set up on my own and I am very successful in achieving positive H&S solutions for many clients and felt that the OSHCR was a great way to show my achievements to potential new clients. I completed every section of the register as fully as possible to ensure that potential clients could make a fair decision to choose my services, against others on the register. Albeit, I did notice some registry entries that were partially completed and I am unsure why those people would pay for registration when it was only a half attempted job. Doubtful that they would get work from the register for this reason. So I can understand that there should possibly be a system to assess registration (similar to CHAS registration which looks for supporting evidence and documentation). But to state that General Consultants should not be on the register and clients should handle H&S themselves is ridiculous. I have pulled several companies out of trouble with the HSE due to them trying to do it alone with severe consequences. I am proud to add both the IOSH Chartered membership logo and the OSHCR logo on my letterheads and I hope the ideas of a leaving Chairperson who has obviously not worked at floor level for a number of years does not lead people to consider the register to be an untrue reflection of our hard work.

  • In my role as a "generalist"

    Permalink Submitted by Jim Tassell on 27 April 2016 - 01:30 pm

    In my role as a "generalist" consultant I must disagree profoundly with Dame Judith's view of this part of my profession. It is far too simplistic to suggest that businesses should deal with risks themselves without analysing the reasons for many of them seeking help. It's not just because some salesman visits, shaking his head sucking through his teeth and muttering "new legislation... mega fines... even prison...". There are two perfectly good reasons, which are lack of available manpower and lack of in-house expertise. Businesses often need some external help to get to a position where they can run safety themselves to a large extent. They also have an ongoing need for someone to turn to for advice when, for example, they read another horror story in an article in a trade paper that is actually advertorial from a service provider.
    To review her comments from another perspective, let's imagine a simple case of a business with a process that involves dispensing chemicals from bulk and the movement of packages. It's all in a days work for many generalists and much more effective from a customer perspective to have one source of advice rather than than the alternative of a chemist to look at COSHH, an ergonomist to look at handling the containers and building pallet loads, a fire specialist to look at the DSEAR aspects and probably also a materials handling specialist to look at simple fork lift truck and lorry issues.
    I have often been impressed by the common sense approach adopted by Dame Judith but this time she has got it wrong. That's not to say that OSHCR should be protected, far from it, but this veiled attack is misguided.

  • I have been a member since it

    Permalink Submitted by Christopher Burwash on 27 April 2016 - 01:44 pm

    I have been a member since it started and I hoped it would indeed provide a benchmark of proficiency for the profession.
    It is not at all active so far as I am concerned as the only time I hear from them is when subscriptions are due..
    Surely, the time has come to make membership of a scheme, not necessarily this one, that demonstrates competence to the public and business alike, compulsory.
    Electricians and gas fitters MUST belong to a Register to practice....is our profession no less valuable, and, in the absence of competence, lethal......
    How many stories do we hear about deaths and injuries due to unsafe H&S practices before this happens?
    Registration for gas fitters occurred after the Ronan Point disaster, why do we not bite the bullett and make Registration compulsory for practising H&S consultants before we have our own Ronan Point?

  • I've been a member since day

    Permalink Submitted by W B Pilkington on 27 April 2016 - 02:24 pm

    I've been a member since day one and in all that time I've not had one contract or job offer from this organisation only as previously stated when my fee was needed .
    The out going chair has got it wrong on this one and needs to retract that statement on the various type of HSE Consultants.
    I for one like many others HSE consultants have become multi skilled on many subjects but it seems businesses are changing the goal post again you now have to wear the hat of Security,training , or the jobs not yours perhaps the HSE needs to get the message over to companies what actually a HSE consultants role is and not Having to wear six hats .
    Companies that I have worked for where the dollar rate on their barrels is down are not hiring and only have their own so called HSE people who are ex operations or engineers and not really Qualified as I have found out on many occasions to my dismay once the consultant rectify a the problem in some cases he is seen as a threat and a overhead cost and released until it goes wrong again.
    OSHCR needs to be updated with the input of the members and not just HSE office staff but the real HSE Consultants who can add experience ,knowledge gained over many years .

  • I too have been a member

    Permalink Submitted by John Jutson on 27 April 2016 - 03:09 pm

    I too have been a member since the register was introduced and find that there are many SME's that do not have the necessary resources to undertake the HSE role without some support and guidance from consultants such as myself. It is however true that with the exception of advising members that their subscription is due that there is very little communication from OSHCR.
    The original concept of the register was at the time it was created a much needed means of identifying suitably qualified consultants but I do believe the time is right for a rethink.
    Just as we have CPD as members of our Professional bodies is it not right and proper to consider professional development of the OSHCR.

  • There should be an official

    Permalink Submitted by Andrew Rustell on 27 April 2016 - 03:21 pm

    There should be an official register for qualified Health and Safety practitioners. However, OSHCR has never served this purpose because many people who work hard in the industry as consultants, particularly those who work for smaller Health and Safety consultancies like the one I run with my business partner, do not have Chartered IOSH membership and therefore cannot join this register. I have worked in the Health and Safety sector for 12 years and have held NEBOSH qualifications for 9 of those, but this isn't enough to get chartered status so I can't join this register and as long as only an elite of practitioners can join so it only represents a fraction of those who work in the health and safety industry, the current register will remain unfit for purpose. I also object to the fact that only four bodies were recognised as valid memberships for joining OSCHR, ignoring the other industry bodies that were involved in the consultation process and the fact the register provides no alternative mechanism for membership, such as possession of recognised health and safety qualifications (e.g. NEBOSH certificates, etc.).
    There was a perfectly good register on the HSE website which they abolished shortly before OSCHR was introduced. That register on the HSE website wasn't perfect, but any qualified and competent consultant could join it, so it was a true representation of the profession and not of an elite - HSE should go back to that.
    I respect the work Judith Hackett has done with the HSE, she seems to have worked hard to raise the profile of the HSE and I believe she has sincerely wished to improve health and safety in the UK - though I also believe (and it is only my opinion, nothing else) that many of the reforms introduced during her time in office will not improve health and safety standards. The feedback I have received from many small Companies has been that the reforms have severely undermined the importance of health and safety on their agenda, and many of them took from the reforms the message that the Government doesn’t think health and safety is important, which is a very dangerous message have conveyed, however unintentionally. I have even had various small business owners on the phone openly admitting they will be "winging it" as they took it that Government clearly were signalling health and safety wasn't important and why should they pay out for competent health and safety advice when they could get away without it. Needless to say, I never heard from again or would have accepted any of these as a Client, but there have been many such enquiries, particularly just after the HSE's reforms were introduced.
    I do think Judith Hackett's comment that those she calls 'generalist' consultants are not required are rather naive and an insult both to the many good consultants who work hard to provide high quality general health and safety services and to their Clients who need, seek and receive such services. I pride myself on providing affordable, high quality health and safety services, and would like to believe that within the Health and Safety Consultancy sector I am not alone.
    I do hope Martin Temple, the new HSE Chairman, takes these comments seriously and reforms OSCHR properly so qualified and competent consultants like myself can all join and contribute to the industry properly instead of feeling disowned by the HSE for no good reason.

  • Normally I would read these

    Permalink Submitted by Anonymous on 28 April 2016 - 07:33 am

    Normally I would read these articles and take them in but I am annoyed at such comments from the former chair. Having been a chartered member of IOSH and registered consultant (and paying member) with OSHR since it was introduced I find the comments rather derogatory to the 'generalist' consultants on the register. Many consultants are valuable members of teams within organisations helping them with their health and safety responsibilities. To be put down as 'generalist' and that companies should do it themselves I feel is unfair. I totally agree H&S should not be about scaremongering to make money but some companies genuinely need or want help. I would agree that the membership has not brought me any business and I never receive any news updates or anything from OSHR for that matter. Possibly if they introduced a slightly more rigorous questionnaire at the start of the membership process maybe they would 'weed out' the 'poor' consultants that Judith is talking about.

  • Well done Judith and to the

    Permalink Submitted by Gary Magee on 28 April 2016 - 09:56 am

    Well done Judith and to the other contributors above. I like Dame Judith Hackitt's comments about OSH consultants; “The good ones listen to what their customers want and provide proportionate solutions,” and “The not-so-good ones impose and sell through fear."

    I agree also with the comments above. Those of us who learn about the businesses that we are assisting in order to give proportionate advice and solutions are seeking a body that highlights the benefits of good advice and measured actions to improve health and safety in the workplace. Registration with OSHCR was a good starting point but OSH is moving on quickly and a better more effective solution is required.

    Different ways of managing OSH are being developed focussing on positives in H&S management rather than failings. The workplace today looks and feels much safer than 20-years ago but I think the changes are starting to accelerate again. Well done Dame Judith Hackitt for raising the issue but it is down to us to create a better solution.

    While we are at it, what about accreditation for those companies who are compliant, managing H&S and achieving great improvements in performance? In construction there are SSiP schemes such as CHAS, Acclaim, Safemark and others that audit H&S systems annually for accreditation but what about the kids' soft play company or the corner shop that are doing great work. Let's think about how we credit and promote them as well.

  • Well this certainly seems to

    Permalink Submitted by Phil Keeling AIOSH on 28 April 2016 - 01:14 pm

    Well this certainly seems to have stirred the mind. I trained as an electrical engineer in the mid 80's, but have worked with H&S professionals for many years. The vast majority I have come across do the job because they have a passion for keeping people safe and healthy at work. I recently passed my NEBOSH with distinction albeit NGC1 at second attempt, and was asked by the plant Mgr to assist him with his H&S obligations. I, with the mentoring help of a CMIOSH professional who is on the register, have just completed a new Safety Management System for the site where I work. My philosophy is certainly biased towards ensuring we send staff home safe and well, but with an eye on the legislative side also, after all accidents do happen and it is the legislation that will be used to prosecute if a court decides an employer didn't do what was reasonably foreseeable.

    Having read the exiting chairs reported comments, I can't help thinking that this is a case of lighting the touch paper and running? If she felt this way, why didn't she do something about it on her watch?

    Also I'm not sure I agree with some of the comments about competence and qualification. Correct me if I'm wrong but IOSH have a structure to their different levels of membership, and I know this being an AIOSH member.

    I believe there should most certainly be structure to different levels of competency and should be reviewed periodically and these levels of competency should be categorised to show industry that should they need to use the services of a consultant, they can make an informed decision as to the competency of one consultant to another. I also believe that registration of OSHCR should be a prerequisite of consultants in order to qualify their competency to industry, but I also believe the register should be fit for purpose and to quote Hackett " listen to what their customers want and provide proportionate solutions"

    This should not be a one way registration process and should be capable of relegating as well as promoting competency to deal with "the bad ones"

    I value my membership of IOSH and will continue while I feel it is fit for purpose

  • Oh, Dame Judith, what did we

    Permalink Submitted by John Sproul on 28 April 2016 - 01:17 pm

    Oh, Dame Judith, what did we consultants do to 'hack' you off so much? She oversaw the introduction of OSHCR and the initial running of the scheme but waits until she's leaving to have a go at 'generalist' consultants. As one such type of consultant, I work with many companies as an extension to their business, leaving them to concentrate on what they do best. As has been mentioned in other posts above, many companies do not have the financial resources to employ a full time H&S professional and to keep up with their training and CPD requirements. OSHCR could be better, could correspond more with us instead of just sending out fee requests but companies and organisations need to have somewhere to look for qualified and competent professionals to assist them with their H&S. As for comments regarding only the 'elite' being able to join the register, I do not class myself as 'elite', just someone who studied hard, sat the appropriate courses and exams, while still working, to demonstrate my competence and I have obtained work as a direct result of being registered. Schemes (OSHCR, GasSafe, etc.) need to have a minimum level/qualification/standard or anyone could join and then it would be the customer who lost out, possibly paying for an incompetent service and possible fines for failings. It should also be noted that the HSE themselves have 'generalist' Inspectors who often have to refer issues to their specialist Inspectors to assist them in deciding what is or what went wrong. As for Dame Judith, I think she has got it very wrong and if she thought the register was not working why did she not attempt to sort it prior to leaving. It's always easy to find fault, point the finger, etc. when you no longer have to sort the problem - if one actually exists.

  • Dame Judith's comments are

    Permalink Submitted by David Daniel BSc CMIOSH on 28 April 2016 - 02:21 pm

    Dame Judith's comments are regrettable. Perhaps a period outside the HSE bubble might change her views.

    She complains that consultants recommend "risk averse" solutions. I don't think I'm one of them with some 40+ years in H&S, but perhaps she would do well to consider the impact of S40 of the Health and Safety at Work Act which reverses the burden of proof for accused employers and requires them to seek extreme solutions to avoid conviction, coupled with the ongoing civil claims culture which again cultivates pressures to go beyond what is reasonable to defend oneself in civil litigation. If you fail to address these drivers, you shouldn't moan that employers are risk-averse or that consultants are recommending disproportionate controls.

    Regarding FFI - the last case I had was where the HSE inspector arrived on site, toured the woodworking shop without seeing anything, then looked at my report and noted that there were two minor items the company had yet to complete although they had worked through all the rest. On that basis she made an FFI charge effectively for her reading my report and agreeing with my recommendations, which she herself had not noticed. my client was not impressed. While the HSE use FFI as an exercise to obtain money for their own pocket I find it hard to see how they can complain about their perception in the eyes of hard-working businesses

  • Of course OSHCR is not

    Permalink Submitted by Joe Portelli on 28 April 2016 - 08:01 pm

    Of course OSHCR is not working, and it does not depend on who you ask. The fact is that HSE already delegated the responsibility for competency assessment to the various industry , i.e. Oil & Gas, Aviation , Maritime etc., and in turn their delegated associations who represent the industry through membership, who agree standards and codes of practices, medical recognition and so on. One could not really expect just because they meet CDP set by an institute not specialising in Industry and registration following a paid up fee would replace the Industry Competency Schemes ? If anything that would be contradictory to the HSE Accepted competency schemes that have been in place for several decades. Having a membership with an institute is important and essential, but in the end it does not verify speciality competency this is best left to the industry ie. Aviation safety , OGP safety, Drilling Safety etc. The OSHCR does nothing to compare if the Institutes and the Industry requirements are compatible and therefore has not foundation. As for a list of practitioners, the institutes themselves already do this service and do it without interfering with the industry competency schemes, which means for example, that the Maritime agency decides which IOSH member meets its competnecy and the Aviation agency or IMCA decides theirs , with reasonable proof and supported schemes behind them. Where does this leave OSHCR ? It has a place, for those offering service to the public directly and are not captured by any Industry Scheme. The HSE would than have to create an approved "competency" scheme to verify the registered individual's claim of expertise as this is outside an Institutes aims, the latter simply recognised the "Safety" qualification not the industry competence.

  • I expected more insight from

    Permalink Submitted by Kevin McCloskey on 29 April 2016 - 11:13 am

    I expected more insight from someone who has been in her position for so long.
    To say “My first preference would be for the business to deal with the risks themselves,” as justification for dismissing the need for H&S generalists is ridiculous. Judith - those of us who are acting ethically and responsibly would ALL like to see this utopian condition.
    You clearly haven't got out-and-about enough during your tenure to see what it's like on the SME side. I wonder if you feel the same about HR - is your first preference for small businesses to not use 'generalist HR professionals' too? It's not a bad thing to employ someone externally to help explain how to manage H&S in a reasonable, proportionate way.
    As for 'scaremongering', take a look at the HSE's weekly 'newsletter' - majoring on 'rouge employer taken to court' stories.
    As for OSHCR, it was predictable that some would 'game' the system for better advantage, but at least a local adviser can now be sourced much more easily.

  • I am a bit surprised at

    Permalink Submitted by Alan Overment on 29 April 2016 - 02:16 pm

    I am a bit surprised at Judith`s comments but when this register was first proposed I dont think that many of us really believed that this would be the end of all bad advice. I have been involved in Health and Safety for 20 years and have taken over the consultancy role from large providers who only provided generic Policies, Risk assessments, Method statements and assisted organisations with CHAS and Safecontractor with documentation that they had never even seen before it was submitted to the SSIP`s and yes these consultants are CMIOSH and on the register. To assume that being CMIOSH guarantees good advice is naive and wrong, (remember every full member became CMIOSH in 2007 automatically) but what is the alternative to a register. There are many Competent practitioners at GradIOSH and TechIOSH levels, there is no doubt about this, I have met many of them.

  • I think some comments here

    Permalink Submitted by Phil Pinnington on 29 April 2016 - 03:19 pm

    I think some comments here have missed the point somewhat. Dame Judith did make it clear that the register was her worry and she does make it clear that the problem isn't with everyone registered. From my own experience there are many consultants who do frankly scare the uneducated or simply misinformed. They pull out their tried and tested management system which isn't always appropriate to their customers business and charge a hearty fee for it. As it's Health and Safety often the customer just accepts it because an insurance company have warned them if they don't they wont be insured or their premiums will skyrocket.
    Many of these consultants have minimum qualifications and although their credentials are vetted by IOSH I'm sure some have grandfather privileges,
    Our industry really doesn't need this so I applaud Dame Judith's stand. There's nothing wrong with making sure what we have is fit for purpose.

  • In this OSHCR and the

    Permalink Submitted by Warren Fothergill on 10 May 2016 - 03:29 pm

    In this OSHCR and the relevant aspects of competence, are we not missing the point? If we are CMIOSH or above, within IOSH as the professional body, then why do we need a register? We already have a register, with membership numbers and CPD which to support our claims. Its not that we need another body, IOSH membership could and should serve the purpose and it has determined levels of competence within its membership criteria e.g. Tech, Grad and Chartered. We all pay membership fees, have the code of conduct and ethics to follow, so why do we need another organisation to determine competence, when its categorised within IOSH at different levels?

    OSHCR is worthless as it stands, it doesn't add value or provide anything other than a tick-box exercise and take your money. I was in it for a couple of years in 2011/12, but never got anything from it when I was working within a consultancy. Whilst its hard for companies to determine the level of competence they need, it should be considered a requirement for them to contact IOSH about membership and ascertain information on said practitioner (if they aren't on there, that says a lot).

    • I have to agree with the

      Permalink Submitted by Tom Price on 27 September 2016 - 11:48 am

      I have to agree with the above comment and the initial article. I have stated for sometime that unless you gave industry expertise or a specialism to demonstrate application of health and safety knowledge then you cannot add much to the debate. To some extent the last section of MHSWR Reg 7 states this...

      Recently a consult at came into my place of work as my replacement - he seemed set on applying knowledge from elsewhere into our industry and getting hands on industry bespoke information, possibly to inform fellow consultants.

      Training your own has to be the answer and Reg 7 doesn't say you must have cmiosh people carrying out functions such as monitoring..supervising etc.

      My belief is the profession needs to change... In the knowledge economy silo based consultants and not the answers as a good H&S manager should have the shill set to manage operational aspects of the business?



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