From the archive: Just so you know, this article is more than 3 years old.
Words: Bridget leathley
Causality was discussed under "C" in this Lexicon (IOSH Magazine, April 2016) and is an important consideration when determining what should go in the hazard column.
The Irish and Canadian health and safety regulators define a hazard as the source of harm rather than the cause of the harm. This distinction might sound pedantic, but consider a box of matches. Is it, in itself, something with the potential to cause harm?
It is unlikely the matches would be used to hurt someone, other than by some "fanciful" consideration such as poking someone in the eye. But they have the potential to create a fire, which would then be something with the potential to cause harm. So if we use the NEBOSH definition we find ourselves talking about the matches as a "potential hazard" which, when unpacked, would mean "potentially the matches could create something with the potential to cause harm".
Defining a hazard as the source of harm allows us to define the matches simply as a hazard, without the adjective, since if anyone was harmed in a fire it would be true to say the matches were a source of harm, even though the immediate cause might be throwing a lit match into a pile of combustible material.
The HSE defines "Identify the hazards" as step 1 in the risk assessment process; step 2 is to identify who will be harmed; and step 3 involves, in part, evaluating the risk. But the determination of whether something is a hazard involves an evaluation of the significance of the risk to those who could be affected. If it will cause harm only when other circumstances coincide and, if those circumstances are unlikely, does it need to be documented in that first column? If the potential for harm is realised, is this significant enough to warrant consideration? Will this depend on who is exposed? Hence assessors must consider steps 2 and 3 before entering the hazard into column one. The example of "slips and trips" in the hazard column of the HSE risk assessment template tests the definition further. A trip can feature in the chain of events leading to an injury but it is not the part that can be easily controlled. In the hazard column, the risk assessor should be noting environmental factors, such as uneven surfaces or poor lighting, and behavioural factors, such as people carrying oversize loads or walking while looking at their mobile phones. Slips and trips should be regarded not as hazards, but as trigger words that remind the assessor to look for related workplace hazards.
If anyone was harmed in a fire it would be true to say the matches were a source of harm, even though the immediate cause might be throwing a lit match into a pile of combustible material
Other trigger words mistakenly included in the hazard column of HSE examples are "health of workers" and "welfare". These are desirable outcomes, not the source of harm. Similarly, a well-known health and safety training course lists "housekeeping" as a hazard when it would be more accurate to consider it a control method.
Even when we are clear about the source of harm, there is inconsistency in what is documented as the hazard. For work on a ladder, risk assessments will variously describe the hazard as "the ladder", "work at height" or "fall from height".
Each assessor will argue that their particular use is correct. The ladder is a "thing" with the potential for harm, because someone can choose to climb it and might then fall off. The work at height is the thing that creates the potential for harm because you can't fall if you are not working at height. At the extreme, it is only falling and then landing that causes harm -- if you stay on the ladder you won't be hurt.
Another dilemma is whether failures of controls should be added as hazards. If the hazard is wood dust, and the control is to wear a dust mask, should "failure to wear a mask" be entered in the hazard column?
Purists will argue that it should not, but, pragmatically, is it more helpful to consider each control failure as a hazard so that you can monitor them, or identify more robust methods?
The word "hazard" is not mentioned in the Health and Safety at Work Act and, though used twice in the Management of Health and Safety at Work Regulations, remains undefined there. But if practitioners are not clear on how they use this simple word, they risk leaving critical hazards and controls unidentified.
Words: Bridget leathleyWhereas Burglar Bill has to be assumed to be innocent until proven guilty, under Sections 2 or 3 of the Health and Safety at Work (HSW) Act an organisation is automatically regarded as having failed to ensure the health and safety of employees or others if an accident has occurred. As Lord Hope of Craighead explained in the House of Lords judgment on R v Chargot Ltd: “The onus then passes to the defendant to make good the defence which Section 40 provides on grounds of reasonable practicability.”
The judge in a more recent criminal case (R v Chargot, 2008) said employers did not need to consider “trivial or fanciful” risks. Even where prevention would be reasonably practicable, an employer could not be expected to protect against unforeseeable harm.
Elsewhere on the HSE website there are hints about a technique that will assist with hazard identification. In the Safety Report Assessment Guides for major accident hazard sites, the HSE lists job safety analysis (JSA) as an acceptable method. A similar term crops up in two research reports for the executive. One describes a toolkit of techniques to support behaviour change and worker engagement in small- and medium-sized construction companies, and refers to job hazard analysis (JHA) as one of the “safety programmes that were found to be most effective in reducing unsafe conditions”.
Words: Bridget leathleyThe first issue of the journal Ergonomics in 1957 explained its title was derived from the Greek for “the customs, habits or laws of work” and was coined “to denote an approach to the problems of human work and control operations”. During the Second World War, earlier approaches of trying to optimise the armed services’ performance by picking and training recruits to match the demands of the equipment shifted to considering how equipment could be designed to match human capabilities.
The placement of the conjunctions “and” and “or” in the definition of competence are curious. Did the legislator really intend us to think that knowledge along with other undefined qualities were suitable substitutes for training and experience? Surely knowledge is a result of training built upon by experience rather than an alternative route to enlightenment.
While it is no longer acceptable to assume that all men are stronger than all women, or that people of one colour have different personalities to those of another colour it is, it appears, entirely acceptable to declare that anyone born since 1980 is addicted to social media and will ‘challenge traditional hierarchical HSE systems’, while anyone born before that date is a luddite with no understanding of the modern age, but will be quite happy to toe the line.