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.