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NEBOSH International Diploma

Unit IA
Exam Success
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NEBOSH International Diploma Unit IA Exam Success

NEBOSH INTERNATIONAL DIPLOMA


UNIT IA
EXAM SUCCESS

SUBJECT PAGE
EXAMINATION SUCCESS 1
AN OVERVIEW OF THE UNIT IA EXAM 3
EXAMPLE QUESTIONS AND ANSWERS 8
ELEMENT IA1: PRINCIPLES OF HEALTH AND SAFETY MANAGEMENT 9
ELEMENT IA2: LOSS CAUSATION AND INCIDENT INVESTIGATION 19
ELEMENT IA3: MEASURING AND REVIEWING HEALTH AND SAFETY
PERFORMANCE 28
ELEMENT IA4: IDENTIFYING HAZARDS, ASSESSING AND
EVALUATING RISKS 33
ELEMENT IA5: RISK CONTROL 37
ELEMENT IA6: ORGANISATIONAl FACTORS 43
ELEMENT IA7: HUMAN FACTORS 55
ELEMENT IA8: REGULATING HEALTH AND SAFETY 67

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EXAMINATION SUCCESS
INTRODUCTION TO THIS GUIDE
This guide is intended as an aid for candidates taking the NEBOSH
International Diploma in Occupational Health and Safety qualification. It
focuses exclusively on the Unit IA examination.
This guide will help you to understand the format of the Unit IA exam, the
type of questions that might be asked and the kinds of answers that are
expected. It will also introduce you to some important examination
techniques that can make a huge difference to performance.
This is not a revision guide. It does not contain any course materials and does
not discuss revision techniques or course content other than through
suggested answers to past exam questions. If you would like further
assistance with the revision process you can make use of other RRC resources
produced specifically to address these important issues, including revision
notes and structured revision programmes.
Other sources of information on the Diploma Unit IA exam are available.
NEBOSH publish a syllabus guide on the International Diploma qualification
that contains information about the examination process. This information
includes a sample Unit IA exam paper. If you have not already obtained a
copy of this syllabus guide we would encourage you to do so. NEBOSH also
publish past exam papers and Examiners reports which make excellent
examination preparation resources. You will find it useful to check all of your
course materials to identify additional sources of information that might
supplement this guide.

A NOTE FROM THE AUTHOR


Students taking the NEBOSH International Diploma qualification are often
very concerned about the assessments that they have to pass.
And rightly so.
NEBOSH qualifications are not easy to come by and each person who passes
a qualification does so on their own merits. In some ways this should be very
rewarding and reassuring. It represents one of the times in life when there
are no short cuts. Those who succeed deserve their success.

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But, when you are preparing for the assessment, this higher truth can be
somewhat shrouded in the more immediate practicalities of revision,
preparation and exam nerves.
Unit A is arguably the hardest of the three Diploma Unit exams to pass. This
may be due to the fact that Unit IA has far more content than either of the
other two units; or it may be due to the fact that Unit IA covers a wide variety
of topics, some of them rather nebulous in nature (take human factors, for
example) and some of them just downright intimidating in their complexity
(the law). It may also be due to the fact that Unit IA is almost always the first
Diploma exam that you will sit and is therefore your first exposure to the
reality of sitting a three hour exam. This first exam can be a hard learning
experience to go through, and the national pass rates would indicate that
once through Unit IA, candidates do progressively better in both the Unit IB
and Unit IC exams. This is perhaps because some hard lessons have been
learnt during that first Unit A examination experience.
Success in Unit IA depends on your performance during just three hours in
the exam at the end of your studies, and your exam performance will depend
on two key factors:
How much you can remember about the different topics.
How well you can apply that knowledge in the exam situation.
It is no use being good at one thing without also being good at the other.
Staying calm under pressure and interpreting questions is no use if you do
not have the knowledge in your head to answer those questions. Getting
that knowledge in your head is the whole intention of the revision process.
Having the knowledge in your head is no use to you if you cannot function in
an exam situation.
The whole purpose of this guide is to focus on that second essential element
of success: examination technique.
The following guidance sets out practical guidelines and hints and tips that I
have picked up over the last nine years of teaching on NEBOSH International
Diploma courses. I hope that you find it useful.

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AN OVERVIEW OF THE UNIT IA EXAM


The NEBOSH International Diploma Unit IA exam paper has a set format.
The exam is exactly three hours long.
Ten minutes reading time is allowed before the start of the exam during
which you may read the exam paper but you may not write anything.
The exam contains six compulsory short-answer questions in Section A; each
of these is worth a maximum 10 marks.
It also contains five long-answer questions in Section B. You have to answer
any three of these five questions. Each of these is worth a maximum of
20 marks.
Your answers should be written into a standard answer booklet. This answer
booklet contains lined A4 paper with a cover. You complete the cover with a
few personal details as instructed and then write your answers inside. There
is a space at the top of each page for you to indicate which question you are
answering on that page.
You can find a sample Unit IA exam paper in the NEBOSH guide to the
Diploma. You can obtain additional past exam papers from NEBOSH, though
these are probably less useful to you than the Examiners Reports.
Time Management in the Exam
You should aim to arrive at the exam venue early. Exams are stressful enough
at the best of times. Travelling to get there just in time or, worst case
scenario, arriving late will not help your nerves.
The exam paper clearly states that you have ten minutes reading time before
the exam proper starts. You may not write anything during this ten minute
period.
Section A contains six compulsory short-answer questions. The exam paper
states that you are advised to spend 15 minutes on each of these questions.
Six 15 minutes totals one and a half hours.
Section B contains five long-answer questions. You must answer three
questions only. The exam paper states that you are advised to spend 30
minutes on each of these questions. Three 30 minutes totals one and a
half hours.

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The only difficulty with following the advice on the exam paper is that it
leaves you no time to pause during the exam and no time for reviewing your
answers at the end of the exam.
I would therefore recommend that you reduce the amount of time that you
dedicate to each of the short-answer questions. I would recommend 12 or
13 minutes for each short-answer question and 30 minutes for each long-
answer question. This leaves around 15 minutes of spare time. You might
use some of this time to pause briefly between questions to give yourself a
short break from thinking and writing. You might use some of this time to
make a careful decision about which three Section B questions you intend to
answer. You might use the remainder of this time to briefly review your
answers before the exam ends.
Whichever time management plan you decide is right for you, you must put
this plan into effect. I would recommend that you take a watch into the exam
with you. Take your watch off and put it on the table in front of you. As you
start each exam question write the start time and projected finish times on
the exam paper next to the question. Now you do not need to remember
what time you started or intend to finish it is written down in front of you.
As you write your answer make sure that you check your watch to ensure that
you do not run over your intended finish time.
If you write the finish time down, check your watch and stick to your
intended plan then you cannot go wrong with time management during the
exam. If you do not have a plan, or if you have a plan but fail to follow it in
the exam room, then time management can go horribly wrong.
I frequently talk to students who run out of time. Dont let it happen to you.
Exam Technique
Exam candidates sometimes come unstuck because they do not fully
understand the question that they have been asked. Instead of answering the
question in front of them they answer the question that they THINK is in
front of them. There can be a big difference.
Below is a basic approach that might help with interpretation of the question:
Step 1: READ THE QUESTION
Slow yourself down and read the whole question. Read it carefully. Read
all parts of the question - not just the first half, but the whole thing.
There can often be useful clues and memory triggers in the second half
of the question.

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Step 2: LOOK AT THE MARKS


If a question has 10 or 20 marks allocated then there must be at least 10
or 20 pieces of information that the examiner expects to see for you to
win those marks.
It helps if the question is split into several parts and the marks available
for these parts are indicated in brackets since it indicates how much
information you should provide, how much writing is required and how
long you should spend on each part of your answer.
Step 3: HIGHLIGHT THE KEY WORDS
The key words are those words in the question which are essential to
understand the question's meaning. So, for example, if the question
was: "Define the meaning of the term Safety Culture", you could say that
the key words are:
DEFINE that is what you are being asked to do - provide a widely
acceptable definition of a word or phrase; and
SAFETY CULTURE that is the phrase you are being asked to define.
The verb or action word in each question is important. Below are a few
of the most commonly used instructions with a translation of their
meaning:
LIST literally list the words or phrases - no explanation or
description required at all. You are unlikely to get a list-type
question in the Diploma exams.
STATE say what it is there is often no widely recognised
definition. This should not require a huge amount of detail.
OUTLINE give the key features of. You need to provide a brief
description of something or a brief explanation of reasons why. A
huge amount of depth and detail is not required. Outline is
frequently used in Diploma exams.
DESCRIBE give a detailed description of what the thing is, what it
looks like, how it works, etc. Here a lot of depth is necessary.
Frequently used in Diploma questions, especially the long-answer
questions.
EXPLAIN give a detailed explanation - reasons why, reasons for,
how it works, etc. Again, this word indicates that a lot of depth is

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required. Frequently used in Diploma questions, especially the long-


answer questions.
Note that these are the same words that are used in the NEBOSH
Certificate exams, but here they are being used in a Diploma exam.
Consequently they do not indicate that exactly the same level of answer
is required. Certificate is a Level 3 qualification - Diploma is at Level 6. If
you give a Level 3 answer to a Level 6 question you will not get the
marks. So a question which asks for an outline of an idea in the Unit A
exam expects a more detailed and precise answer than an outline
question in the Certificate exam. The award is at a significantly higher
level; your answer must reflect this.
Step 4: READ IT AGAIN
Just to ensure that you understand its meaning.
Step 5: PLAN YOUR ANSWER
You should consider jotting down a brief answer plan before you start to
write your answer in earnest.
Answer Planning
You should consider jotting down a brief answer plan before you start to
write your answer in full. The examiner expects to see a logical answer that
has a beginning, a middle and an end. If your answer contains ideas that are
written down as they come to mind, the answer will not have a logical flow
and will not make sense. Answers like this are not easy to read and not easy
to mark.
It is not possible (unless you are a very gifted individual) to write long answers
with good logical flow unless you know what you are going to say first.
Hence the need for an answer plan.
For some short answers you can get away with not doing an answer plan.
This is especially true where the question already has a lot of structure and so
the structure of your answer simply follows the order in which the question is
asked.
But structuring your answer is only one of the reasons for writing an answer
plan. The other important reason is that in jotting down key words in your
plan, you start to recall all your memories associated with those key words.
Planning gives you the opportunity to pause for thought and remember.

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The form that your answer plan should take is entirely up to you. You could
note down a structured list of key words to show how your final answer will
be structured (rather like the contents page of a book); or you could simply
write down the odd word here and there in a random order on the page.
Perhaps one of the best ways of setting out an answer plan is to draw a mind
map. If you have used mind maps as a revision aid then you are simply
repeating what you already know; if you have not used mind maps for
revision, they make excellent planning tools.
Whatever method you use for planning, do not be concerned about the
appearance of your plan. It is there for you to jot down ideas as they come to
mind and then to structure those ideas. It does not have to look good.

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EXAMPLE QUESTIONS AND ANSWERS


Now you should work through the following selection of past Unit IA exam
questions with possible answers. For each question there is a short discussion
on interpretation, an outline plan and a suggested answer. This section has
been structured to follow the elements of the Unit IA syllabus, with short and
long answer questions for each element.

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ELEMENT IA1: PRINCIPLES OF HEALTH AND


SAFETY MANAGEMENT
Short Answer Questions

(a)
Question 1

Outline the difficulties that organisations face in trying to ascertain the


true cost of accidents and incidents. (5)
(b) Explain briefly how the principles of corporate governance would
support good safety management in an organisation. (5)

Interpretation
The question is in two parts and your answer must be presented in the same
way: an answer to part (a) and an answer to part (b).
Each part carries 5 marks, so five key pieces of information must be
presented in each part of your answer. You might decide to put down six or
seven pieces of information just to be on the safe side, but beware of writing
too much and taking up too much time.
Note that part (a) asks for an outline (brief explanation) and part (b) asks for
a brief explanation!
Part (a) of this question is clearly asking for a brief explanation of why it can
be difficult to accurately associate financial costs to accidents.
Part (b) is asking for a brief explanation of the holistic approach to business
risk management and some comments about why this approach might align
with health and safety management principles.
Plan
(a) Accidents may go unreported; where do you draw the line; some costs
are not discoverable influence on morale, business reputation, etc.;
delay between accident and cost claim, specialist nature of this
accounting.
(b) Corporate governance business risk management; similarities with
H&S management policy, organising, assessment, monitoring,

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review; philosophy is the same; intention is the same; one relates to


holistic business risk; other relates to H&S.
Suggested Answer
(a) Difficulties would include the fact that it is difficult to define the scope
and minimum level of incident to be analysed and costed; under-
reporting in the workplace will mean many incidents are not analysed
at all; there may be a failure to understand the full scope of costs
because those costs may be indirect; there are inherent difficulties in
obtaining realistic accurate costings for certain things (e.g. loss of
goodwill/productivity); there may be insufficient
time/resources/expertise within the organisation dedicated to the
exercise; there will be long delays in knowing some actual costs (e.g. in
the event of a claim for compensation).
(b) The concept of corporate governance has risk management at its
heart, though it does take in all business risks, not just health and
safety. Many of the principles are similar to good health and safety
management practices: it requires clear policy and commitment from
senior management, risk evaluation (using risk assessment) is a key
control mechanism, the risk control management processes are very
similar to those applied to health and safety management (i.e. a
hierarchical approach is used), monitoring is required, clear
communication and reporting arrangements must be implemented,
internal audit is a requirement, annual Board level review of risk
controls is mandatory and the board must make a statement to
shareholders about compliance

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Long Answer Questions

Question 2

A multi-site business has a quality management system compliant with ISO


9001. It also has a health and safety management system and an
environmental management system that operate independently. The board
of directors is now considering the possibility of developing an integrated
management system encompassing all three elements. In order that a
decision can be made objectively, prepare a brief for the board that outlines
the key potential benefits of:

(a) An integrated management system.. (10)


(b) Retaining the existing system of separate management systems. (10)

Interpretation
This question is scenario based and, though a lot of detail is not presented on
the scenario, there are a few key features that must be recognised. Firstly, the
QMS is ISO9001 compliant. We can safely presume that that compliance
must stay in place, which can complicate integration. Secondly, there is a
SMS and an EMS, but these are not stated as being certificated to a standard,
i.e. we are not told that they are OHSAS 18001 and ISO14001. We can
perhaps assume that they are not.
We are asked to prepare a brief; in other words write a report. It should look
passingly like a report, though detailed report formatting is not required. The
target audience is the board (of directors), so technical language can be used,
provided it is explained. Most importantly we are asked to outline the
potential benefits of integration and of staying put. The marks are evenly
divided between the two options. Note that we are not explicitly asked for
the disadvantages of either option.
Plan
(a) Integration Consistency of format, avoidance of duplication of
procedures, record-keeping, auditing, software. Holistic solutions rather
than just optimising for quality or environment. Synergy (benefits from
one area applied to other areas), encouraging interaction between
specialists, etc.

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(b) Existing system Flexibility, safety standards set by legislation, quality set
internally. May not need such a complex system in one area compared to
another; why fix what isnt broken? Integration may be a costly exercise;
may encourage more detailed auditing, if kept separate, specialists stay
specialists.

Suggested Answer
The business has a quality management system compliant with ISO 9001. It
also has a health and safety management system (SMS) and an environmental
management system (EMS) that operate independently. The business is now
considering the possibility of developing an integrated management system
encompassing all three elements. This report has been prepared in order
that a decision can be made objectively. In it, the key potential benefits of
integrating the three management systems and also of retaining the existing
independent management systems will be outlined.
The benefits of integration
There are many benefits that might potentially flow from integration of these
three independent management systems. These are outlined below:
Consistency of format integration will require that a consistent format is
applied to all three areas. The same basic philosophy underpins each area
(conformance to a standard) and therefore the same management process
and language can be applied to each.
Avoidance of duplication of procedures consistency of approach reduces
duplication, leading to efficiencies. These efficiencies might show in terms of
indirect labour costs, productivity increases and reduction in direct labour
paperwork.
Record-keeping (as referred to above) since systems are integrated,
personnel will look at three areas of concern once rather than looking at
three separate areas of concern independently. This should lead to improved
record keeping and a reduction in the amount of paperwork generated by
the three independent systems.
Auditing once integrated, all three management areas will be audited
together. Certainly from an internal audit perspective this should lead to
improved auditing across three areas and may lead to a reduction in the time
taken to audit. In short one audit will look at one management system rather
than conducting three separate audits to look at three separate management
systems.

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Software the integration of management systems will require the


integration of software systems. Again this should lead to efficiencies in time
spent interacting with the system.
Holistic solutions rather than just optimising for quality or environment one
of the major benefits of integration is that an holistic approach is adopted.
Unlike current arrangements, where one system (and therefore the
personnel who runs that system) is looking at one area of improvement and
has little interest in improving other areas, the integrated system gives
ownership of all three areas to all personnel. Therefore it is in everyones
interest to see improvements across the board. In other words, with an
integrated system an improvement that enhances quality but is detrimental
to environmental performance is not seen as worth making. One that
enhances health and safety (H&S) and has no negative impact on
environment and quality is worth taking.
Synergy another key benefit of the integrated system approach is synergy;
i.e. the idea that benefits from one area can be applied to other areas and
that when this happens the whole becomes greater than the sum of the parts.
One final benefit of integration is that it encourages interaction between
specialists and will require specialists to branch out into other areas of
knowledge. Though specialists may retain a higher level of competence in a
chosen area, they will have to develop their competence in other areas. This
can be of great benefit since cross-pollination of ideas should then flow
within the organisation; there is greater sharing of knowledge and practice
and less ring-fencing of know-how.
The benefits of retaining the existing system of separate management
systems
Flexibility current arrangements are highly flexible. This is especially the
case with the H&S and EMS since these are not in compliance with an
external system and can be operated as we see fit. The QMS is less flexible
since it is ISO9001 compliant and therefore must meet external standards in
order to retain certification. It must be recognised that in order to retain this
certification, any integration of systems would have to remain ISO9001
compliant. This complicates the integration process.
Safety standards set by legislation, quality set internally - whilst the general
philosophy of all three systems is the same (conformance to standard) both
H&S and environmental systems are driven by the need to comply with the
law. Quality, however, is driven by our own internal need to meet customer
expectation. Current arrangements allow internal standards to carry equal

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weight with legal standards. Integration may lead to more weight being given
to legal standards and a dilution of quality standards as a consequence.
May not need such a complex system in one area compared to another
integration inevitably leads to complexity because the need to achieve
compliance in one area ripples out across all three areas of concern. This can
lead to an over complication of systems. The QMS is driven by the
requirements of ISO certification. This might therefore drive complexity into
the SMS and EMS.
Why fix what isnt broken all three management systems are functioning
acceptably across the multi-site operation and look to be working well. Any
attempt to change these systems may lead to disruption (at least in the short
term) for little benefit.
Integration may be a costly exercise inevitably there are costs associated
with integration. An IMS will have to be selected, tailored to our needs and
then implemented across the whole operation. Personnel, both specialists
and others, will require re-training in new systems. The potential for business
disruption exists, which may have unforeseen cost implications.
May encourage more detailed auditing if kept separate current audit
arrangements require detailed focus on the three areas of concern
independently. This separate focus does mean that greater scrutiny is applied
to each topic area.
Specialists stay specialists the current system requires that QMS staff are
specialists in quality management only. The same applies to EMS and SMS
staff. These staff have developed their competence over years of practice
and study. Retaining the current system allows these people to stay specialist,
rather than requiring them to move into other areas where they have little or
no experience or knowledge and therefore no competence.

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Question 3

A financial review within your organisation has resulted in a proposal to the


Board of Directors to cut its health and safety budget and to cancel a capital
project that was designed to lead to significant improvements in the working
environment.
As the organisations Health and Safety Manager, present an argument to the
Board for rejection of this proposal. (20)
Interpretation
This is a straightforward question requiring a defence to be presented to the
threat of financial cutbacks. Note that the short scenario given threatens cuts
to the health and safety budget and the cancellation of a capital project.
Whilst a separate defence does not have to be presented to both threats, the
arguments used must be applied to both threats. Note that a report to the
Board (of directors) is required here, so your answer should look report-like
and your language should be for the non-specialist.

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Plan
Moral, legal and economic arguments.
Moral policy obligation to staff. Personal impact of accidents and ill-
health.
Industrial relations and PR implications of moral failure.
Directors personal values. (Put last.)
Legal compliance with legal requirements, enforcement notices,
prosecution, avoidance of legal action against directors and/or
managers, compensation.
Economic costs of failure; direct costs, indirect costs. Uninsured losses,
hidden nature of losses. Financial benefits of good standards, especially
working environment.
Suggested Answer
This report has been prepared following the proposal to the Board to cut the
health and safety budget and cancel the health and safety capital project. The
report will argue for the rejection of this proposal based on three basic
principles: the sound economic argument that underpins good health and
safety management within this organisation, the legal implications of failing to
manage health and safety effectively, and the moral imperative. Each of these
arguments will now be discussed in detail.
The Economic Argument
Health and safety (H&S) failings cost money; in fact they can cost a lot of
money. And whilst it is true that putting good H&S standards in place also
costs money, the costs associated with failures far outweigh the costs of
implementation. There are two ways in which this organisation may fail to
ensure H&S - one is a failure to ensure safety. This leads to accidents. The
other problem is failure to ensure health; this leads to ill-health, sickness and
chronic disease. Both accidents and ill-health have direct costs associated with
them. For example, a workplace accident leads to production downtime,
damage to equipment, plant and premises, and loss of product. Damaged
equipment and premises must be repaired or replaced. This in turn usually
leads to indirect losses to the organisation - losses that do not stem directly
from the event itself, but flow from it as inevitable consequences. Lost
product must be re-made, which incurs overtime or additional labour costs.
Personnel who have been injured remain absent from the workplace; they are
paid full salary during their absence and at the same time the organisation has

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to employ temporary labour to cover their work. In some instances this


temporary labour solution cannot be applied and then other workers in the
workplace have to pick up the work of their absent colleague. This leads to
overworking, fatigue and stress which in turn leads to an increase in human
error and higher absenteeism.
Whilst some of the costs highlighted above are quite apparent, some may be
hidden to the organisation; others are non-discoverable in nature. If industrial
relations are severely damaged by a workplace accident that reflects in poor
productivity, higher absence rates and reduced efficiency. But how could that
be exactly costed out? The answer is it cannot be. If bad publicity were to
result from a workplace accident, that might have a direct effect on our
customers willingness to do business with us. Again, this could be a very
significant cost that would be difficult to quantify and discover.
The above arguments relate to workplace accidents and ignore the cost
implications of work-related ill-health. Occupational ill-health often results
from poor working conditions and poor working environments. It almost
invariably leads to workplace absence and, in some instances, may be severe
enough to warrant dismissal on medical grounds. There are costs associated
with the worker absence, the management of that absence and the legal
action that often results from such ill-health and dismissals, not to mention
the poor industrial relations and PR that can accompany such illnesses.
Studies which have analysed workplaces looking for the costs associated with
workplace accidents suggest that the uninsured losses to an organisation are
greater than the insured losses by a factor of 8 as a minimum. In other
words, our insurance company cannot be approached to fund the vast
majority of losses that we incur when we injure people at work or make them
sick. We fund those losses ourselves
None of the above included any comment about the financial implications of
legal actions, which this report will now move on to consider.
The Legal Argument
There are legal standards that we must comply with and failure to comply can
lead to enforcement action being taken against us in the form of legally
binding notices that require us to carry out such improvements or to stop
certain activities. This enforcement action invariably carries with it the costs
associated with carrying out the improvement to the enforcement officers
timescale, or stopping an activity that we find to be financially beneficial. This
is not to mention the bad IR and PR that is usually associated with these
enforcement notices. In other instances, failure to achieve legal compliance

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may result in prosecution. Directors may also face personal liability for legal
failing of the organisation that they direct. Needless to say, all of the above
legal actions carry with them the risk of incurring huge legal fees in mounting
a defence (and paying the prosecution legal fees in the event of the case
being lost).
In addition, injure a worker, or cause ill-health, and we may well be sued by
the injured party. These cases may result in the payment of compensation to
injured victims. Though this money may come from our insurers in the first
instance, it invariably leads to higher insurance premiums in the short- and
long-term as those insurers attempt to claw back their losses from us.
The Moral Argument
We have a clear policy obligation to our staff to ensure their ongoing health,
safety and welfare. That has been made clear in the statement of intent
signed by our Managing Director as the headline of our H&S policy. Aside
from the legal and financial arguments discussed above, we must also
consider the huge personal impact of accidents and ill-health that can and do
occur as a result of our H&S standards. One worker may be injured or made
ill, but that one person has a family, friends and colleagues. The impact of a
serious accident or case of ill-health has wide-ranging implications. We must
reflect on our own personal values and decide whether we would wish to see
the unpleasant and sometimes tragic consequences of poor H&S standards
occurring in our organisation.
In conclusion, I would state that cutbacks cannot be made to the H&S
budget, nor to the capital project, on the basis of the three arguments
described above. We owe it to ourselves, to our workforce and to our
shareholders to retain our H&S budgets so that we are best able to avoid the
losses that workplace accidents and ill-health might cause.

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ELEMENT IA2: LOSS CAUSATION AND


INCIDENT INVESTIGATION
Short Answer Questions

Question 1

Describe the requirements of an interview process that would help to obtain


from witnesses the best quality of information relating to a workplace
accident. (10)
Interpretation
This question simply requires you to describe the best way to carry out an
accident investigation interview in order to obtain the facts. If you have been
involved in accident investigations previously, then much of this answer will
be familiar to you from past experience.
Plan
Interview as soon as possible after the event injury/shock make this
difficult.
Suitable environment.
Put witness at ease.
Interview one witness at a time.
Establish good rapport.
Purpose preventing reoccurrence, not to apportion blame.
Record the findings.
Establish facts.
Avoid leading questions/implied conclusions.
Sketches/photographs.
Listen to witness without interruption.
Give sufficient time to answer.
Issues summarized/agreed.

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Suggested Answer
The first requirement is to interview as soon as possible after the event
although injury or shock may make this difficult. The interview should be
carried out in a suitable environment where the witness can be put at ease.
Only one witness should be interviewed at a time, with the interviewer taking
time to establish good rapport. The purpose of the interview should be
explained, that of preventing a reoccurrence and not to apportion blame, and
also the need to record the findings. Questioning techniques should establish
facts and avoid leading questions or implied conclusions. Sketches and
photographs may help with the interview. Finally, the witness should be
listened to without interruption, given sufficient time to answer, and the
issues discussed should be summarized and agreed at the end of the
interview.

Long Answer Questions

Question 2

A forklift truck is used to move palletised goods in a large distribution


warehouse. On one particular occasion the truck skidded on a patch of oil. As
a consequence the truck collided with an unaccompanied visitor and crushed
the visitors leg.

(a) State, with reasons, why the accident should be investigated. (4)
(b) Outline the actions which should be followed in order to collect
evidence for an investigation of the accident. Assume that the initial
responses of reporting and securing the scene of the accident have
been carried out. (8)
(c) Describe the factors which should be considered in analysis of the
information gathered in the evidence collection. (8)
Interpretation
We have a simple scenario here and the answer must relate back to this
scenario wherever necessary. There are three parts to the question, so our
answer must be in three parts. Note the marks breakdown. Part (a) is simple
enough. Part (b) is concerned with the collection of evidence following the
event. Part (c) is concerned with the analysis of the investigation evidence;
this is perhaps the part of the question most open to misinterpretation.

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Factors to consider (things to think about) = organisational, job and personal


factors = HSG48.
Plan
Why investigate causes, prevention, insurance, morale of staff, IR, PR.
Evidence collection:
From scene photos, sketch, samples, text, CCTV.
From witnesses interview; from records & documents risk
assessments, maintenance logs, etc.
Factors:
Organisational culture, peer group pressure, practices, etc.
Personal - drugs/alcohol, training, experience, attitude, etc.
Job shift, comfort, environment, etc.
Suggested Answer
(a) The accident should be investigated for various reasons. First,
investigation allows for the identification of the immediate and
underlying causes of the accident and the various factors that may have
contributed to it. This in turn should allow for the identification of the
corrective actions necessary to prevent a recurrence of this event and
others like it.
Second, any investigation gives the organisation a good opportunity to
assess its compliance with legal requirements and best practice.
Third, an investigation provides an opportunity for management to
demonstrate a clear commitment to health and safety and show that
they are interested. This has a direct impact on the safety culture of the
organisation and on employee morale. Indeed, employee morale would
suffer badly if the event were not investigated.
Fourth, the factual evidence collected during the investigation will be
vital in deciding liability issues should there be a civil claim for
compensation based on this accident.
(b) Assuming that first aid assistance has been given to the injured visitor,
and that the scene has been secured, the first actions must be to collect
evidence from the scene itself before that evidence becomes
contaminated. This would be done by photographing the scene, or

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perhaps even videoing it, drawing sketches and taking measurements to


annotate that sketch. It would also be appropriate to write a brief
description of the scene including any additional information that may
be relevant but that is not apparent from photographs or a sketch (e.g.
a loud tannoy, or high or low ambient temperatures in the warehouse).
CCTV footage may be available and should be secured.
Factual information about the environment around the accident scene
must also be gathered, so the condition of the floor, light levels,
markings on the floor, the presence of pedestrian walkways and signage
must all be recorded in some way. The oil patch must be photographed
in situ before clear up and perhaps a sample taken as evidence.
The position of the forklift truck must be carefully recorded and any
forensic evidence that shows its route must also be noted (such as skid
marks on the floor, collision marks on surrounding structures such as
racking, etc.). The FLT must also be carefully examined to determine its
condition and the acceptability of its safety-related features. This
examination should also take into account the position of any load on
the FLT and the capacity rating of the FLT.
The oil spill on the floor will have to be investigated in more detail to
determine its source and the reasons for its presence on the floor.
Failures in the spill detection and clear-up procedures may be identified.
Following investigation of the physical evidence, the background
documents and records must be scrutinised and copies may have to be
taken. Risk assessments, safe systems of work, operating procedures,
FLT maintenance and inspection logs, training records and other
company documentation will all have to be examined.
Another vital source of information must also be addressed during the
investigation and that is, of course, the witnesses. The FLT driver should
be isolated from other people to prevent possible contamination of
their evidence. They should be interviewed about the event as soon as
possible to prevent the natural process of reviewing an event and then
embellishing it. Other witnesses would also be interviewed as soon after
the event as possible, including the injured party, although this may
depend on their availability. Other personnel who did not directly
witness the scene, but who have information relevant to the
investigation, may also be interviewed and this would include reception
staff who greeted the visitor to site, and maintenance personnel who

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recently carried out work on the FLT.


(c) The various factors that will have to be analysed in order to determine
the causes of this accident can be thought about in various ways, but
one way that might be useful is to consider Organisational, Job and
Personal factors.
Organisational factors that should be considered in the analysis would
include:
The safety culture of the organisation, especially as perceived by the
warehouse staff and the FLT driver.
Peer group pressure and the influence of this on the behaviour of
the driver (he may have been speeding because to drive slowly is
considered unmanly) and the visitor (they may have been in a
group of peers and behaving recklessly).
Pay and reward schemes in operation. The FLT driver may have
been incentivised to drive fast due to the pay and reward system.
Personal factors that should be considered would include:
The basic personality traits of the driver, their attitude towards
health and safety in general and pedestrian safety in particular.
Their training in FLT driving, including basic skills training, job-
specific training and any induction training they may have had into
the warehouse.
The FLT drivers experience and their general reliability and
competence level.
The intelligence level of the driver and their ability to understand
instructions.
The drivers fitness as assessed against the fitness criteria that exist
for FLT drivers.
Factors that may have compromised the drivers ability to function
correctly, such as fatigue, stress, drugs and alcohol.
Job factors would play an enormous part in the analysis and the
following factors would have to be considered:
Signage in the warehouse, markings on the floor and the provision
of barriers to segregate pedestrians and vehicles.
The levels of supervision in the warehouse.

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Procedures and rules in place to govern the movement of visitors


around the site.
Procedures and rules relevant to the movement of FLTs within the
warehouse.
Maintenance, testing and inspection regimes in place for the FLT.
Shift patterns, hours of work and workload allocation within the
warehouse.

Question 3

Accident investigations can vary in terms of duration, size and specialisms of


the investigation team and resources allocated.
(a) Explain why it is important for an organisation to investigate
workplace accidents. (10)
(b) Outline the factors that would influence the level of investigation
required following a workplace accident. (10)

Interpretation
A two-part answer is required here. Part (a) requires an explanation, so
depth and detail are implied. The question itself is very direct. Part (b)
requires a brief explanation of factors, but again is quite direct.
Plan
Identify causes (underlying and immediate), take corrective action,
identify cost, promote positive culture, provide information for legal
reporting and insurance claims.
Seriousness or potential seriousness (severity, number involved), nature
of accident (complexity), use of permits, breach of legal requirements or
may involve a civil claim.
Suggested Answer
(a) There are many important reasons why an organisation should
investigate workplace accidents. These might be considered under the
following areas:
Identification of causes. The true causes of an accident must be

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discovered if any form of effective corrective action is to be taken.


It is important that the true underlying causes are identified as well
as the immediate causes. These principles are clearly identified in
both the simple domino theory of accident causation as well as the
more complex multi-causality theory.
To take corrective action to prevent recurrence. Unless the true
root causes and underlying causes of accidents are known, then
effective corrective action to prevent recurrence cannot be
identified and taken. The prevention of accidents is a legal, moral
and economic imperative for an organisation.
Underlying deficiencies in safe systems, risk assessments, etc. must
be identified and corrected. Even though these deficiencies may
not have directly led to a particular event, they will contribute to
future accidents in the workplace. Deficiencies must be addressed
in the interest of continuous improvement.
Investigations can be used to determine cost (financial) to an
organisation. This may be important as a way of promoting good
health and safety internally, by highlighting the financial impact on
the organisation of failure.
Good accident investigation is vital for worker morale and helps to
promote a positive culture by involving people in a practical way in
health and safety in the workplace. In the absence of visible
investigation, workers will make their own minds up about the
organisations priorities and they may form negative views.
Accident investigation may be a necessity in order to gather
information for legal requirements regarding accident reporting
Finally, accident investigation is often mandatory under insurance
policies for the simple reason that an accident may result in a claim
for compensation. In such an event the insurance company must
have good quality factual information, gathered at the time of the
accident, in order to make an informed decision about liability; do
they fight the claim or pay out?
(b) The various factors that might influence the level and complexity of an
accident investigation would include the following:
Seriousness of the event. Accidents that have minor outcomes
may not require detailed, complex investigations because they had

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minor outcomes. No one was seriously hurt; there will not be a


claim for compensation, so why spend a lot of time and effort
investigating. This argument can be effectively applied to some
accidents but not all (as we shall discuss next).
Potential seriousness. Accidents that result in minor injury, or
minor property damage and even near misses, can have the
potential for very serious outcome. That outcome was not
realized in this instance, but the possibility existed. Therefore, one
factor that is crucial to examine is the potential of an event to
have serious outcomes in terms of severity of injury caused
and/or number of people involved. Where there is the potential
for high severity outcomes, then a more detailed and complex
investigation would be warranted. Where that potential does not
exist, then a simpler, quicker investigation will suffice.
Nature of accident. Many accidents are very simple in their
causation. They take little time to investigate and little time to
analyse. A complex and in depth investigation is not going to
reveal any hidden depths and therefore is unwarranted. An
organisation can learn all it needs to know with a simple, quick
investigation.
Permits-to-work. Any event involving permits to work (PTW) will
be, by the very nature of PTWs, high risk work and often complex
high risk work. It is therefore often sensible to undertake a
thorough and detail investigation to ensure that the permit system
is working correctly. Any accident occurring under permit control
implies a failure of the permit system itself and therefore must be
taken seriously (if the permit system was working well, then the
accident would not have happened).
Any event that results in the necessity to report to the enforcing
authorities should be investigated in more depth and detail
because of the reporting requirements. This is not because a
complex investigation is required to discover the facts of the
event. Often these events are relatively simple. Instead, it is
because of the potential involvement of the enforcer at some
stage after the event has been reported. Site visits, enforcement
actions and ultimately prosecution may result from the report and
therefore it is in the interest of the organisation to collect detailed

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factual information should the need arise.


Similarly, any event which seems to indicate that there has been a
breach of legal requirements (and possible enforcement action
that may follow) must be investigated to a higher degree.
Finally, as was mentioned above, any event that appears to involve
significant injury or loss to a person, and therefore may result in a civil
claim, should be investigated in more depth and detail because of the
liability issues that may rest on having detailed factual evidence and
analysis from the time of the event.

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ELEMENT IA3: MEASURING AND REVIEWING


HEALTH AND SAFETY PERFORMANCE
Short Answer Questions


(a)
Question 1

Using examples, explain the differences between active and reactive


systems for monitoring health and safety performance. (6)

(b) Outline FOUR limitations of using accident and ill-health data as a


means of measuring health and safety performance. (4)

Interpretation
Part (a) of this question asks for an explanation of differences, so some depth
and detail is required here. Part (b) requires a brief explanation of four
possible limitations.
Plan
(a) Active forward looking, lead indicators, objectives achieved,
inspections.
Reactive backward looking, lagging indicators, accidents and ill-
health.
(b) Negative.
Historic.
Poor reporting.
Latency.

Suggested Answer
(a) Active systems measure the compliance with standards, whereas
reactive monitoring measures previous failures in performance,
enabling an organisation to learn from its mistakes. Active measures

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are often referred to as leading indicators, since they measure


achievement of objectives and targets and therefore indicate the
direction that the organisation is currently taking. Reactive measures
are often referred to as lagging indicators since they reflect where the
organisation has already been - its history, in effect. Completion of
safety inspections might be used as an active measure; number of
accidents during a time period might be used as a reactive measure.
(b) Reactive data, such as accident and ill-health statistics, can be seen as
rather limited because they measure failure, even though there might
have been successes in other areas. They are therefore inherently
negative. This data as a measure of performance provides only a
prediction, rather than a determinant, for the future. The data lags
current performance, it does not lead current performance. Health
statistics can be very limited, simply because occupational diseases
have a long latency period, so current data reflects workplace
standards that existed years previously. One final limitation of reactive
data is that they are extremely reliant on good reporting systems.
Poor reporting leads to poor data quality and consequently poor
meaning.

Question 2

A national campaign aimed at improving standards of health and safety in a


particular industry has been deemed a failure due to a significant increase in
the rate of reported accidents over the period of the campaign. Explain why
accident rates may have proved a poor measure of the campaigns
effectiveness and identify other measures that might have been used. (10)
Interpretation
This question is quite straightforward, but note that there are two parts to it
hidden in the last sentence. We are asked to explain the inherent weaknesses
in using accident rates as an indication of success and we are also asked for
alternative measures that might have been used instead.
Plan
Under-reporting and effect.
Auditing, inspections, sampling, surveys.

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Suggested Answer
Accident rates may have been a poor measure to use to indicate the success
of the campaign because there may have been under-reporting of accidents
prior to the launch of the campaign. This under-reporting would have led to
an artificially low accident rate. The campaign would then have raised
awareness of safety issues within the industry. This draws peoples attention
to safety and accident reporting. As a result, accident reporting improves
despite the fact that the underlying accident rate might not change at all or
might even go down. Consequently the apparent accident rate increases
during and after the campaign. This is a common occurrence as safety
awareness improves within industries and organisations.
Other techniques that might have been used as an alternative to accident
rates to measure the effectiveness of the campaign might have included:
Auditing workplaces before and after the campaign to get an in-depth
view of safety management systems and their effectiveness.
Safety inspections of sites to gather a snapshot of the standards within
workplaces and the standards of behaviour.
Safety sampling exercises where representative numbers of workplaces
are visited before and after the campaign to make reliable predictions
about the industry as a whole.
Attitude surveys given to workers before and after the campaign to see if
there was any change in workers opinions about safety.
Long Answer Question

Question

As the health and safety adviser to a large organisation, you have decided to
develop and introduce an in-house auditing programme to assess the
effectiveness of the organisations health and safety management
arrangements. Describe the organisational and planning issues to be
addressed in the development of the audit programme. You do not need to
consider the specific factors to be audited. (20)
Interpretation
Though this question is scenario based, there is very little detail about the
organisation and therefore we have to express our answer in very general

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terms. Note the comments about not considering specific factors to be


audited. This question is concerned with the planning and organisational
arrangement issues that must be considered when establishing an audit
system.
Plan
Resources. Schedule.
Senior management support. Personnel.
Scope. Training.
Audit system. Feedback process.
Software. Launch.

Suggested Answer
The organisational and planning issues that would have to be addressed
would include:
Correctly identifying and then gaining the resources required (money,
time and personnel) through careful planning and analysis.
Gaining the support of directors and senior managers so that:
Those resources are made available.
Access is authorised to all of the necessary information and
personnel across the organisation.
Access to the senior managers themselves during the audit process
is agreed.
The scope of the auditing to be carried out must be decided upon; will
the audit stick to health and safety issues, or range across other areas as
well? And which parts of the organisation are to be audited? These will
be particularly important questions to answer with regards geographic
locations to be audited and consequently the legal standards that will
apply.
The type of auditing will also need to be decided upon. Will a
proprietary system be purchased, or will one be developed from scratch
internally, or a combination of the two? The manager will have to decide
on whether to use a scored audit system or one more reliant on narrative
judgments. A software system may need to be purchased to run the

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audit system, and again, decisions will have to be taken as to the type of
software and resource requirements.
An audit schedule will have to be designed, taking into account the
resources made available for conducting audits, the size of the
organisation and the frequency required. The frequency of auditing may
have to vary from one part of the organisation to another, depending on
the risk level presented by the different parts of the organisation.
Some thought will have to be given to the personnel who will carry out
the audits. Their time will have to be secured as well as their personal
commitment to the process. Training and ongoing support will have to
be made available and this may have to be supplemented with
background knowledge building as well. This will, of course, require the
co-operation of their managers.
The methods used to provide feedback on audit findings, the type of
feedback given, the methods used for resolving disagreement with
feedback and the review process will all have to be considered and
finalised.
Consideration must be given to how the audit programme will be
launched. This might involve clear communication of the programme, its
aims, methods and processes through various media. A test pilot may
have to be carried out to ensure the efficient working of the system and
the acceptability of the scheme to others.

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ELEMENT IA4: IDENTIFYING HAZARDS,


ASSESSING AND EVALUATING RISKS
Short Answer Questions

Question 1

Outline the range of internal and external information sources that may be
useful in the identification of hazards and the assessment of risk. For each
source, indicate the type of information available and how it contributes to
hazard identification or risk assessment. (10)
Interpretation
There is a lot of structure in this question, even though it is not broken down
into specific parts. The question clearly asks us to outline internal and
external information sources. I think a 50:50 split between the two sources is
sensible here (though this is not clearly indicated). The question also asks for
a range this indicates that we must take a step back and take in the wide
view; focus too narrowly on one set of sources and you will miss marks. For
each source of information we are clearly told to indicate the type of
information available and how it is useful, and everything relates to risk
assessment.
Plan
External information sources

Relevant governmental agencies (OSHA/HSE)


European Safety Agency.
ILO.
WHO.
Professional and trade bodies.
Suggested Answer
External information sources that might prove useful during the risk
assessment process would include:
National governmental enforcement agencies such as the UKs HSE,
USAs OSHA, Western Australias Worksafe. These all produce legal and
best practice guidance and statistics.

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International bodies such as the European Safety Agency; the


International Labour Organisation; the World Health Organisation.
There are various professional bodies that have an interest in
occupational safety and health and these bodies often issue guidance that
can help in hazard identification and risk assessment. In many instances
specific advice can be obtained relevant to a specific issue.
This guidance can often be augmented by further guidance available
from trade bodies and trade unions these organisations can often give
excellent practical guidance based on their close working knowledge of
the practical issues arising. They are in a good position to indicate exactly
what the principal hazards associated with their kind of work are, and the
consequent risks.
Finally, information can be obtained from manufacturers or suppliers
which can indicate the extent of a hazard and the relevant control
options that might be necessary. For example, safety data sheets from
chemical suppliers provide essential information on the chemical nature
of a hazardous substance and necessary controls. Similarly, the noise and
vibration magnitude data from a machinery supplier can give an insight
into the potential noise or vibration exposure and the subsequent
exposure controls necessary.
Internal information sources might include:
Accident and near miss reports and investigation reports. These are
useful because they will clearly identify hazards that either have or had
the potential to cause injury. They may also be useful during the risk
assessment process because they help in the evaluation of likelihood and
severity of injury, and hence the degree of risk.
Inspection reports may be useful in identifying the easily observed
hazardous conditions in the workplace and also the common types of
control failure. This process not only helps the hazard identification
process, but also influences risk assessment; the effectiveness of various
control options can be better estimated based on current controls.
Audit reports may also be useful in a similar way by identifying hazards
that have been overlooked and the effectiveness of existing controls.
Maintenance logs may be useful in determining the effectiveness or
otherwise of particular controls in the workplace, such as automatic
warning systems, guards and PPE.

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Question 2

When undertaking a risk assessment:


(a) Outline the factors that need to be considered to ensure that the
assessment is suitable and sufficient. (5)
(b) Identify the circumstances that would necessitate a risk assessment to
be reviewed. (5)

Interpretation
This is a two-part question so a two-part answer is needed. The question
refers to the need for a general risk assessment to be comprehensive and
provide a suitable and sufficient coverage of risks. Part (b) is straightforward
when do you need to review a risk assessment?
Plan
(a) Significant hazards, those exposed, evaluation of risk, adequacy of
existing controls and need for further controls recorded. Reference
to relevant standards and legislation, competence of assessors,
complexity is proportionate, should remain valid for reasonable period
of time.
(b) Change in nature of work, new equipment/materials, modification of
plant/premises. Legislative changes; suspect not valid; after incidents;
periodically.
Suggested Answer
(a) The following factors need to be considered in order to decide
whether a risk assessment is suitable and sufficient. The assessment
must address the significant hazards that exist. It must clearly identify
those exposed to the significant hazards. This might include broad
groups of people - staff, vulnerable groups (e.g. young persons) - and
individuals (e.g. a pregnant woman). The assessment must correctly
evaluate the risk generated (likelihood and severity) and the adequacy
of existing controls. It must correctly recognise the need for any
further controls. It must be recorded suitably (significant findings in a
retrievable medium). Reference to relevant standards and legislation
should be made. The complexity of the assessment process and the
competence of the assessors must be proportionate to the complexity

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and level of risk. Finally it should remain valid for a reasonable period
of time.
(b) A risk assessment might be reviewed because of a variety of
circumstances. Most notably, an assessment must be reviewed on
significant change or if the employer has reason to suspect that it is no
longer valid. Change might include a change in the nature of the work,
new equipment/materials, the modification of plant/premises, or
even changes to legal standards. Reasons to suspect that the
assessment is no longer valid would include following an accident, an
incident or a report of ill-health linked to the circumstances that the
risk assessment relates to. Good practice would indicate that a risk
assessment should be reviewed periodically as well. The review period
might be determined by the level of risk inherent in the operation to
which the assessment relates.

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ELEMENT IA5: RISK CONTROL


Short Answer Questions

Question 1

A risk management programme encompasses the following concepts:


(i) Risk avoidance. (2)
(ii) Risk reduction. (3)
(iii) Risk transfer. (3)
(iv) Risk retention. (2)
Identify the key features of each of these concepts and give an appropriate
example in each case.
Interpretation
This question has a clear structure, so your answer should follow suit. Note
that you are asked for an example in each case; failure to provide one would
imply that full marks cannot be awarded even if your explanation is full.
Plan
Avoidance dont do it, e.g. get someone else to do it for you.
Reduction control the risk; hierarchy, e.g. substitute chemical.
Transfer insure the risk, e.g. liability insurance.
Retention with or without knowledge.
Suggested Answer
(i) Risk avoidance: actively avoiding or eliminating the risk. This might be
done by, for example, discontinuing or avoiding a risky process or
activity or by eliminating a hazardous material. Closing down a
butchery operation within a food factory (with the hazards associated
with that operation) and buying in ready-prepared meat from a
supplier is an example of risk avoidance.
(ii) Risk reduction: reducing the level of residual risk. This might be done,
for example, by adopting a hierarchy of measures to control the risk,
such as removing one hazardous agent and introducing another less

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hazardous agent in its place, or adopting an engineering control by


guarding a piece of machinery, or adopting a safe person strategy by
training workers so that they are aware of a hazard and can behave
accordingly.
(iii) Risk transfer: transfer of risk to a third party. This is often done by
insurance. If the risk is realised and a loss occurs then the insurance
policy will pay for the loss, so the financial risk has been transferred
from the workplace on to the insurer (at a cost). Alternatively risk
might be transferred to a contractor. Here, a separate organisation is
retained to undertake an activity that the workplace does not want to
carry out directly. However, because of the complexity of health and
safety (and contract) law, it must be remembered that liability for
losses may be laid at the door of the workplace and not just the
contactor.
(iv) Risk retention: accepting a residual level of risk within the company.
This is often done with the knowledge of the workplace (i.e.
knowingly) where the risk is small and the costs of reducing the risk
seem disproportionate to any benefit. If a loss occurs, then the
organisation will have to cover that loss from revenues. Sometimes a
risk may be retained without knowledge (i.e. unwittingly). This can
occur when a risk has not been recognised (and therefore goes
uninsured) or when a risk is recognised and insurance is put in place,
but the insurance fails to cover the loss. This might occur if the loss is
greater than the amount of insurance cover purchased, if there is a
large excess, or if there are policy exclusions that mean the insurer
avoids payment.

Question 2

Production line workers in a textile plant are required to use knives routinely
as part of their work. Outline the factors to be considered when developing
a system of work designed to minimise the risk to these employees. (10)
Interpretation
This question outlines a simple scenario. Implicit in the question is the fact
that knives have to be used, so elimination of knives is not an option. The
question asks for factors to consider or things to think about when

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developing the safe system of work. An outline is required, so a brief


explanation of a range of factors is necessary.
Plan
Task analysis, risk assessment, control of risk. Must consider elimination
(automation, process change), type of knife, environment (space constraints,
lighting), individual factors (age, attitude, skill), PPE, consultation with
workforce, training.
Suggested Answer
The first factor to consider is the identification of the tasks requiring the use
of knives (by task analysis, for example). This might then be followed by risk
assessment. The people at risk, the hazards and various risk factors must be
identified and recorded in this risk assessment. The correct methods needed
to control the risk must be designed and implemented. During the risk
assessment process the potential for risk elimination by automation or
process change should be considered (though it must be expected that use of
knives will remain). Consideration must be given to the type of knife (safety
features), safe storage of knives, safe carrying of knives and knife sharpening
arrangements. The environment must be considered (factors such as space
constraints and lighting), as must individual factors relevant to staff using
knives (age, attitude, skill). Suitable PPE must be selected and supplied. Staff
training in much of the above will be necessary.

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Long Answer Question

Question

An investigation of a serious accident has concluded that maintenance


operations in a particular area of a factory should have been subject to a
permit-to-work system. Identify and explain the main factors that should be
considered when setting up such a system. (20)
Interpretation
Make sure that you have clearly identified the key words in the question. The
whole focus of the question is the set up of a permit-to-work (PTW) system.
The only piece of information of importance in the first part of the question
is to pick up on the fact that the PTW system is to address maintenance
operations.
Plan
Factors to consider:
Defining what the permit system covers (tasks to be performed, legal
requirements, personnel responsibilities).
Selection, training and competence of personnel (assessment, records,
certification).
What the permit itself prescribes (validity conditions, emergency
procedures, the tasks, hand-back conditions).
How the work should be co-ordinated and monitored.
Suggested Answer
Maintenance operations in a factory environment may involve various high
risk types of work, such as work on large complex items of machinery, work
on pressure systems, work on high voltage electrical systems, work in
confined spaces, work on plant containing hazardous chemicals, work at
height and work on plant at extremes of temperature, to name but a few.
Often multiple hazards will exist at the same time and generate high and
complex risk. Consequently maintenance work may often be designated as
high risk and made subject to permitto-work (PTW) control. In these cases,
a PTW system must be carefully designed and implemented to ensure safety
at all stages of the maintenance work.

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Various factors must be considered when such a system is being designed,


developed and implemented:
In the first instance the system parameters must be clearly identified so
that there is a clear understanding of what the permit system covers.
The system must define which work is covered by the permit system and
which work falls outside of permit control. This may sometimes be
subject to legal requirements. For example, confined space entry should
always be made subject to permit control as a matter of course. In other
instances the use of a permit system will be dependent on perceived risk
on site (e.g. hot work). The definition of permit parameters must also
identify the key site personnel and what their specific responsibilities and
authorities actually are with regards the permit system. Personnel with
responsibility for authorising work under the permit system must be
clearly identified, as must personnel who have responsibility delegated to
them in the absence of key personnel. Personnel responsible for
undertaking specific activities, such as risk assessment or atmospheric
monitoring, should have their responsibilities clearly allocated, as should
staff responsible for monitoring the effective operation of the permit
system.
Another factor to consider is the effective selection, training and
competence of personnel. Competence is a key word here. All
personnel associated with the PTW system must have the necessary
competence to undertake their specific roles or task. This implies
training, knowledge, experience and perhaps other qualities, such as
ability. Assessment of competence may be necessary. Training records,
and in some instances specific certification for key personnel, may have
to be obtained and records retained.
What the permit itself prescribes must be considered in the development
of the permit system. This will vary depending on the nature of the types
of work that fall within permit control. Generally, there would be
arrangements designed into the system for the formal specification of
key safety requirements before the commencement of work. These
safety requirements would be communicated to relevant personnel
through use of the permit system and the actioning of key controls
would be verified. There would be some form of formal hand over of
control from authorising manager to personnel undertaking the
maintenance work activities, as well as some specific restrictions placed
on those workers as to types of work permitted and types of work not

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permitted. The verification of safety throughout the operation and the


formal hand-back of plant/equipment or areas would then follow.
Formal acceptance of these areas would follow, with the cancellation of
the permit to prevent future work being carried out under old
permissions.
The PTW system must clearly identify how the work should be co-
ordinated and monitored. Personnel with key responsibilities must be
identified here, as well as the co-ordination and monitoring
arrangements being described in the system.

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ELEMENT IA6: ORGANISATIONAL FACTORS


Short Answer Question

(a)
Question

Explain briefly what is meant by the health and safety culture of an


organisation. (2)
(b) Identify, using practical examples, the barriers to the development of a
positive health and safety culture within an organisation. (8)

Interpretation
Part (a) is asking for a straightforward explanation of the phrase health and
safety culture. Note that only 2 marks are available here. Part (b) is asking
for an outline of a range of reasons why it might be difficult to improve the
culture. Note that you must give practical examples to illustrate your answer.
Plan
Beliefs, values, behaviour. Positive or negative.
Re-organisation, lack of confidence, poor leadership, no resources, no
commitment, poor communication.
Suggested Answer
(a) The health and safety culture of an organisation is the system of
shared values and beliefs about the importance of health and safety in
that workplace. The culture is how workers at all levels within the
organisation think and feel about health and safety, and about how this
translates into their behaviour. The culture may be positive or
negative and will pervade the whole organisation from top to bottom.
(b) There are many possible barriers to the development of a positive
health and safety culture within an organisation. These are not
dissimilar from the factors that promote a negative health and safety
culture and include the following:
Company reorganisations change is unsettling for all people in
an organisation and during times of change people may lose their
belief in the company and its aims and means. For example, a
company downsizing and making workers redundant will struggle

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to secure worker commitment to a health and safety policy that


states that people are our most valuable asset.
Lack of confidence in management if workers do not trust
management to make sound decisions about the direction of the
organisation and the methods used, then they will not engage in
initiatives started by management.
Lack of leadership people in organisations need to see that
people in management positions are showing clear leadership with
regards to health and safety. If no managers are clearly showing
leadership and indicating the way forward, then workers will not
be able to make their own way. Clear leadership, demonstrated by
clear decision making as to the way forward, coupled with action
will show others where to head.
Lack of resources health and safety cost money. If safety is not
adequately resourced in terms of money and personnel then
positive improvements will be hard to achieve. For example: a
health and safety budget being cut to achieve a short-term
financial target, resulting in the loss of a part-time safety officer.
Lack of management commitment in the absence of senior
management commitment, resources and attention will not be
paid to health and safety. Priorities will lie elsewhere and others
within the organisation will respond accordingly. It is only with
clear commitment from senior management that organisations
can hope to make positive improvements to their safety culture.
For example, if senior managers are heard to belittle and denigrate
health and safety in meetings, this will send a negative message to
middle and junior staff.
Poor communications in the absence of clearly communicated
policies and decision making, people will not be subject to the
positive influence of their organisation. They will be left to make
their own minds up about how important health and safety is. If
communications are clear, then they will know what the
organisation is thinking and what the organisation is doing to
improve health and safety. Examples would be notice boards,
team briefings and management meeting minutes which do not
feature any health and safety element.

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Question 2

(a) Explain the reasons for establishing effective consultation


arrangements with employees concerning health and safety matters in
the workplace. (4)
(b) Outline the range of formal and informal consultation arrangements
that may contribute to effective consultation on health and safety
matters in the workplace. (6)

Interpretation
This is a straightforward question in two parts. The first part asks you to
explain, in effect, the advantages of having effective consultation
arrangements in the workplace. The second part then requires you to outline
what those arrangements might be, ranging from formal safety committees
to informal day to day discussions.
Plan
(a) Reasons:
Ownership of safety measures by employees.
Improved perception of value of H&S.
Use of employee knowledge.
Encourage ideas from employees.
(b) Arrangements:
Safety committees.
Consultation with safety representatives.
Consultation at departmental meetings.
Informal consultation by leaders with employees.
Consultation during accident investigation or risk assessment.
Tool box talks.
Discussion at safety circles.

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Staff appraisals.
Questionnaires/suggestion schemes.

Suggested Answer
(a) Reasons:
Effective consultation arrangements with employees can result in a
number of benefits relating to health and safety matters in the
workplace. These include the development of ownership of safety
measures by employees and an improved perception of the value and
importance of health and safety. There is also the opportunity for the
input of employee knowledge to ensure more workable improvements
and solutions to health and safety problems. Finally, effective
consultation encourages the submission of improvement ideas by
employees.
(b) A key formal consultation arrangement is the establishing of a health
and safety committee. Another essential arrangement is consultation
with safety representatives. These may be trade union appointed
representatives or elected representatives. Planned direct consultation
can take place at departmental meetings or team briefings. Less formal
consultation can also take place during risk assessments or accident
investigations.
Other informal consultation arrangements include day to day meetings
with leaders and employees, tool box talks, safety circles or
improvement groups, staff appraisals and questionnaires or suggestion
schemes.

Question 3

The senior management of an organisation wishes to introduce a number of


new, safer working procedures but has met with resistance from the
workforce. Outline the steps that managers could take to gain the support
and commitment of staff when introducing the changes. (10)

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Interpretation
This question presents a simple case study that can be answered, in the main,
from your own experience. How would you overcome resistance to change
to safer work methods? Find out why, consult, explain, involve, train, review.
Plan
Reasons for resistance.

Consult with workforce


(formal/informal).
Step by step approach.
Clear explanation to the workforce.
Involve workforce in proposals.
Demonstrate benefits of change.
Training incentives.
Senior management commitment.
Review.
Suggested Answer
The first step to gain support and commitment from the staff should be to
find out what the reasons for resistance are. Might there be fear of
redundancy, de-skilling or simply a general dislike of any type of change? The
most important requirement is to effectively consult with the workforce.
This could be through formal means; such as the safety committee, or more
informally; through day to day meetings with leaders and employees, tool box
talks, safety circles or improvement groups. A steady, step by step approach
with trials and pilots of the proposed changes will ease the introduction, as
will clear explanations of any proposed changes and the reasons for those
changes. It will be important to actively involve the workforce in the
proposals, take on board suggestions and offer training in the new methods.
It will also be valuable to demonstrate the benefits of change, such as
improved accident rates and production rates. A final part of the process
should be continuing demonstration of senior management commitment and
regular review of the changes to learn from any mistakes.

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Long Answer Questions

Question 1

A manufacturing company is about to embark on a process of organisational


change that is intended to reduce costs and increase productivity. As planned,
the change will lead to a smaller workforce, a flatter management structure,
enlarged responsibilities for the remaining staff, outsourcing of most
maintenance tasks, increased use of automated processes and the need for
some employees to be multi-skilled.
Review the elements of a strategy designed to ensure that the company
maintains its current high standards of health and safety, and its positive
health and safety culture, both during and after the change. (20)
Interpretation
This is another organisational change question, similar to short question 3,
but we are given more details about the scenario which need to be included
in the answer. So, we need to think about how reducing costs, increasing
productivity, reducing the workforce, increasing responsibilities, automating
processes and outsourcing maintenance tasks will impact on health and safety
and how these changes should be managed. Consequently; consultation, staff
involvement, communication, risk assessment, training and monitoring of
standards will be essential elements of the proposed strategy.
Plan
Clear policy.
Allocation of senior management responsibilities.
Set performance measures.
Amend plans where safety is compromised.
Consultation at all levels.
Involve employees.
Communicate.
New risk assessments with employee involvement.
Map job skills.

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Assess training needs.


Capture/replace lost process knowledge/experience.
Procedures to manage risks in outsourced tasks.
Mitigate employee anxiety (communication/job replacement/
redundancy).
Allocate time and resources.
Monitor safety performance.
Review change process and safety implications.
Suggested Answer
The strategy should commence with the organisation making a definite
statement of safety objectives as part of the change process so that the policy
regarding health and safety during the change is well understood. It should be
clear that plans will be amended if it is identified that the change process is
adversely affecting health and safety. There should be senior managers
identified with clear responsibilities for managing safety during the change
and performance measures identified and set, against which the impact of the
change can be measured. To maintain the health and safety culture there
should be regular consultation at all levels in the organisation and employees
and their representatives should be involved in working groups dealing with
the change. In this way the organisation can utilize employee experience and
also encourage ownership of the change process.
In addition, there should be regular communication of plans and progress.
The planned change will render current risk assessments invalid and therefore
a programme of risk assessment revision will need to be undertaken with full
involvement of employees. The new roles will require mapping of job skills
and experience and also an assessment of training needs.
Because the proposed change will result in a much smaller workforce, this will
lead to loss of informal knowledge and process experience which will need to
be identified and preserved before employees are made redundant.
The move to outsourcing will lead to increased use of third parties and
contractors, and therefore these new risks will need to be managed, and also
consideration given to contractor competence.
The proposed changes will be stressful for the workforce and therefore steps
need to be taken to mitigate employee anxiety by regular and honest

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communication, help with job replacement and an open approach to


redundancy. It will also be important not to rush through the changes and to
allow adequate time and resources for training and implementation of the
new structure.
Finally safety performance should be monitored during and after the change
and also regular review of the process and its safety implications.

Question 2

The refurbishment of an organisations offices will involve the services of


several different trades from a number of small local companies and is to be
completed while the building is occupied. An interior designer specialising in
commercial properties will manage the project.
(a) Outline the criteria that should be used when selecting contractors to
undertake their part of the project. (6)
(b) Outline the organisational measures that the project manager may need
to consider in order to ensure the health and safety of office personnel
during the work.
You are not required to consider the specific risks associated with the
work. (14)

Interpretation
This question fits right into the third party control section of Element IA6.
The first part is straightforward how do you assess the suitability of a
contractor? Note an outline is required, not just a list of key words. Note the
marks.
Part two is concerned with organisational factors, i.e. the management of the
work. It is not concerned with the practicalities of doing the work.
Plan
Experience, references, policy, competence, history, trade member, tests,
risk assessments and method statements.
Work schedules, inductions, security, accident reporting,
accessibility/restrictions (including emergencies), emergency
procedures, hazards, waste, information.

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Suggested Answer
(a) The criteria to be considered when selecting a competent building
contractor are fairly straightforward and would include:
Previous experience with this type of work.
Reputation with previous/current clients (obtained by taking up
references).
Content and quality of health and safety policy document and risk
assessments.
Level of training and competence of staff.
Accident and enforcement history (accident statistics going back over
3-5 years; enforcement notices and prosecutions).
Membership of relevant professional bodies.
Equipment and statutory examination records.
Examples of risk assessment and method statements for work carried
out.
(b) The organisational measures that may need to be considered to ensure
safety of office staff during the work:
Clear agreement on work schedules and timescales that are then
clearly communicated to all contactors and the office staff.
Induction issues for contractors so that they understand the
implications of their work for office staff.
Security procedures such as signing in/out.
Accident reporting procedures so that in the event of an incident
involving office staff, the project manager is informed immediately.
Clear communication and co-ordination on the means of escape that
have to be maintained to ensure office worker safety as the project
progresses.
Procedures to be followed in the event of an emergency.
Information on hazards in the building (e.g. utilities and asbestos
location/presence) that not only present a hazard to contractors,
but also present a hazard (if disturbed) to office workers.

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Arrangements for delivery and storage of materials so as not to


interfere with office worker access and egress or emergency escape
routes.
Removal of waste that may pose a hazard to office workers.
Information on parts of the building where access might be
temporarily restricted.

Question 3

(a) Describe the indicators and measures that could be used to assess the
health and safety culture of an organisation. (12)
(b) Describe the organisational factors that may influence the success of an
attempt to improve an organisations health and safety culture. (8)

Interpretation
The first part of this question is concerned with how health and safety culture
might be assessed. Two important words appear in the question; indicators
and measures. How might an external assessor discover and qualify an
organisations health and safety culture? Part two of the question is concerned
with organisational factors, i.e. characteristics of the organisation that might
influence success.
Plan
(a) Attitudes, communication, business integration and decision making,
committee, advisor, enforcement action, policy documents
(b) IR, confidence, management commitment, resource allocation.

Suggested Answer
(a) The indicators and measures that could be used to assess the health and
safety culture of an organisation would include:
Attitudes towards health and safety by workers/managers and the
acceptance of health and safety responsibilities. This might be
assessed by questionnaire or interview.

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The extent of communication on health and safety within the


organisation. This might be assessed by viewing all of the various
forms of communication that are apparent.
The integration of health and safety into other management
functions (e.g. purchasing). This might be assessed by reference to
policy and procedure documentation and by interview.
The influence of health and safety on management decision-making.
This might be assessed by reviewing management meeting minutes
and by interview.
The effectiveness and composition of the safety committee. This
could be assessed by viewing meeting minutes and by interview.
The status of the Safety Adviser. This could be assessed by examining
the position of the safety advisor within the organisation and by
reference to salary.
The relationship with the enforcement agencies.
The quality of the health and safety policy and its effectiveness.
This might be assessed by reading policy documentation and by audit.
Reference to health and safety in the organisations annual report.
Other measures might include the standard reactive monitoring data,
such as lost time accidents, etc. though these are fairly limited in the
context of assessing safety culture.
(b) The factors that may influence the success of an attempt to improve an
organisations health and safety culture would include:
The industrial relations (IR) climate within the organisation. If this is
good, then achieving consensus and buy-in will be fairly easy. If IR is
poor, then certain groups of workers may not engage with attempts
to improve the culture and may even deliberately sabotage such
attempts.
The confidence of the workforce in their managements ability to
control risks. If management have the trust of the workforce in this
respect then workers are more likely to listen to and respond to
improvement programmes.
Management commitment to health and safety. If commitment is

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seen to be demonstrated, then those workers who support any


improvement programmes have ammunition to win the argument. If
management commitment does not exist, or is not see to exist, then
those arguments will be lost.
The resources and expertise devoted to health and safety. Lack of
resource handicaps any improvement programme. Good resourcing
and the presence of the right people in the right positions will allow
the best chance of success.

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ELEMENT IA7: HUMAN FACTORS


Short Answer Questions

Question 1

Perception may be defined as the process by which people interpret


information that they take in through their senses.
Outline the range of factors that may affect how people perceive hazards in
the workplace. (10)
Interpretation
This is a relatively straightforward question. Perception is obviously a key
word since it is the whole focus of the question and has even been defined in
the question. Note you are asked for a range of factors; focus too narrowly
on one or two ideas and you will miss the bigger picture.
Plan
Fatigue, drugs and alcohol, training, experience, aptitude, IQ, environment,
sensory impairment.
Suggested Answer
The range of factors that might affect how people perceive hazards in the
workplace are mostly factors associated with the person themselves. These
personal factors would include issues such as:
The effects of fatigue. A tired person is less likely to take note of sensory
information that an alert person would detect early.
Drugs and alcohol. These have an obvious effect on mental processes
and, in some instances, will be psycho-active and therefore directly
interfere with the processing of sensory information.
Education and training. A trained person will know the meaning of
various sensory inputs, will recognise their importance and act
accordingly. An untrained poorly educated person may not make the
same associations between sensory input and hazards.
Experience. Inexperienced workers often fail to recognise hazards for
what they are and underestimate the risk associated with hazards

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precisely because they lack experience. More experienced workers do


not fall into the same trap.
Aptitude. Some individuals will have an innate ability to respond to
sensory stimuli in an appropriate manner.
IQ. A worker with low IQ may struggle to correctly perceive the level of
risk associated with a particular hazard, particularly if the hazard is not
visible in nature. A person with high IQ may be better able to interpret
sensory information and translate that into hazard awareness.
Environmental factors may interfere with a workers ability to perceive
hazards in the workplace. Factors such as low light levels, dust, noise and
extremes of temperature can have an effect on hazard perception. This
is not only due to direct interference with the senses themselves, but also
to the psychological influence of environmental extremes.
Any form of sensory impairment will have an obvious impact on
perception of hazards. A partially sighted worker may not be able to see
hazards to avoid them; a colour blind worker may mistake red and green
indicator lights.

Question 2

Outline the organisational and behavioural factors that may lead new
employees to disregard instructions given during health and safety induction
training. (10)
Interpretation
This question is concerned with rule breaking, and with the reasons for rule
breaking (rather than the classification of rule breaking). Though the
question is not subdivided, there are two clear parts: organisational and
behavioural reasons.
Plan
Organisational recruitment, induction itself, peer group pressure, culture.
Behavioural age, experience, culture, IQ, attitude, sensory perception.

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Suggested Answer
Organisational factors that might lead new employees to disregard
instructions given during induction training might include:
The employee selection process, whereby poor recruitment and
selection processes allow employees with poor attitude, intelligence and
behaviour patterns into the workplace.
A poor induction process that fails to engage the employees, especially if
the training provided is not applicable to actual practice in the workplace.
The absence of refresher training.
A lack of awareness on the part of experienced workers for the safety of
new starters.
Peer group pressure coming to play on new starters forcing them to
disregard instructions so as to fit in with their newly acquired peer group.
Poor levels of supervision such that inappropriate behaviour is not
detected or challenged early.
Poor safety culture (including lack of management commitment) within
the organisation, which will be perceived by new starters early on.
The behavioural factors are those that relate specifically to the character of
the employee themselves, rather than relating to the organisation in which
they find themselves working. The behavioural factors that might lead to
employees disregarding instructions given during induction training might
include:
A lack of familiarity with the working environment.
Poor risk perception as a result of young age and or a lack of workplace
experience.
Issues associated with the cultural background of the individual and
consequently the beliefs and values that they bring into the workplace.
Language issues that might arise as a result of the nationality or cultural
background of the worker, their reading ability and any learning
difficulties they may suffer from.
Sensory impairments such as deafness, impaired hearing, impaired sight.

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Low IQ or poor mental capabilities leading to difficulties in


understanding instructions or the true nature of hazards and risks.

Question 3

Identify measures to improve human reliability in the workplace. (10)


Interpretation
This question is asking for an outline of measures. Be aware that improving
human reliability means in the context of improving safety related behaviour
(reducing the risk of human error, violations, etc.). We are not concerned
with improving time keeping, quality or any other aspect of reliability.
Plan
Employee selection, training (induction, refresher, etc.) and supervision;
management commitment; incentive schemes; workplace/equipment
ergonomic assessments of the workplace; improving working environment;
job rotation (monotony/boredom); rest breaks (fatigue/attention span);
communication and consultation.
Suggested Answer
There are many ways of improving human reliability in the context of safety
related behaviour. If these measures are taken, then there is less likelihood
that workers will break safety rules or will be subject to human error.
Employee selection recruiting the right worker for the job is an important
measure. For example, a worker with a high IQ working on a monotonous
job is more likely to bend and break the rules to relieve the monotony.
Training (induction, job specific and refresher) in the absence of proper,
effective training, workers will not know how to behave correctly and
consequently will have to do what they see as best.
Supervision it is vital that workers are supervised to an adequate level in
the workplace so that non-compliance and errors are detected and corrected
early. This prevents bad habits from forming and sends a clear message to
the worker: rule breaking will not be tolerated.
Demonstrable management commitment without strong leadership
workers will not feel motivated to behave correctly.

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Incentive schemes if workers see some form of reward for good behaviour
then they are more likely to comply with rules, etc. and they are also more
likely to exercise care when performing their duties because they have a
personal reason for caring about outcomes. Incentives can be financial in
nature, but may have no financial value at all (e.g. employee of the month
schemes).
Workplace/equipment ergonomic assessments of the workplace it is
important that the environment and the equipment and workstation of
employees is designed and laid out to be as comfortable as possible and to
minimise the chances of error.
Job rotation is a good way of relieving monotony and boredom and
maintaining some form of interest.
Allowing for appropriate rest breaks workers do not become so
excessively fatigued that decision making becomes poor (also to maximise
attention span).
Good workforce communication and consultation so that workers feel
engaged in the decision-making process in the workplace and therefore feel a
greater level of commitment to work.
Long Answer Questions

Question 1

Describe what is meant by skill-based, rule-based and knowledge-based


behaviour and explain how each of these operating levels can give rise to
human error and how, in each case, such error may be prevented. Illustrate
your answer with reference to practical examples and actual incidents. (20)
Interpretation
This is a complex question, but is set out in a very clear way. A description of
Rasmussens three behaviour models is required. These must be related back
to the main types of human error outlined in HSG48. You should also
include an explanation of how these types of human error can be avoided.
Examples must be included for full marks to be awarded.
Plan
Rasmussen skill, rule and knowledge-based behaviour modes.

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Errors skill-based slips and lapses; rule-based mistakes; knowledge-


based mistakes.
Error prevention skill-based: minimise fatigue and distractions, cross-
checks & supervision.
Rule-based training, supervision, background knowledge, drills for rare
events.
Knowledge-based competence, time, oversight, access to resources.
Suggested Answer
These three levels of behaviour (skills, rule and knowledge-based) are based
on the work of Rasmussen and they underlie the basic types of human error
described in the HSE guidance note HSG48: Reducing Error and Influencing
Behaviour.
Skill-based behaviour occurs when a person is carrying out tasks that are
routine and familiar. They may be physical tasks such as pushing a button on
a control panel or mental tasks such as adding a column of figures in the
head. The person is not using any higher-level reasoning skills in performing
the tasks - they are acting automatically. In this mode of operation, two types
of human error can occur: slips and lapses. A slip occurs when the person
performs an action incorrectly. For example, an experienced crane operator
attempts to lower a load slowly, but applies too much pressure to the control
lever resulting in a sudden violent lowering of the load. A lapse occurs when
a person omits a step in a process. For example, an experienced machine
operator forgets to remove the chuck key from a grinder, resulting in the key
being ejected on start-up.
These types of human error, which occur when a person is behaving in skill-
based mode, can be avoided by ensuring that people are not fatigued; this
might require attention to shift patterns and hours of work, as well as
ensuring that adequate breaks are taken. Ensuring that individuals undertake
a variety of tasks may help, by avoiding complacency and reducing
repetitiveness and boredom. Minimising distractions in the workplace can
reduce the likelihood of lapses. The Paddington rail crash, involving a signal
passed at danger, was probably caused (in part) by a skill-based error on the
part of the driver who omitted to correctly recognise the danger signal. Slips
and lapses can also be minimised by introducing double-checking systems
into the work routine so that others check that certain actions have been
carried out correctly. Supervision to detect errors is also useful.

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Rule-based behaviour is more complex than skill-based behaviour. Here a


person is starting to use reasoning skills with some higher level decision
making. However, because the person is familiar with the situation (or thinks
they are) they have a set of options that they can choose from in order to
help them decide on appropriate action to take. In short, a logical approach
is made to a situation along the lines of if A, then B, where B is the rule to
apply if situation A occurs. In this mode of operation, one type of human
error can occur: rule-based mistakes.
A rule-based mistake occurs when a person incorrectly applies a rule to a
situation. For example, a security guard attempts to evacuate a building
during a bomb-threat; they know the rule for fire is get out and stay out
and they incorrectly apply this rule to the bomb threat situation. The correct
procedure would be to stay in the building. The security guard has applied a
general rule incorrectly to a situation.
This type of human error can be prevented by providing clear guidelines to
follow for all foreseeable eventualities, by training people in correct diagnosis
of problems and the rules to apply, and by practise of the rules so that they
become well known. Good supervision and process design can also minimise
this type of error. The Kegworth air crash was caused, in part, by rule-based
mistakes on the part of the pilot (shutting down an engine that he thought
was on fire, when in fact the other engine was on fire). Rule-based mistakes
can also be minimised by good background training (education) so that
workers are more able to recognise the risks inherent with applying simplistic
rule-based solutions to problems, and by exposing workers to rare event
situations so that they become aware of times when standard rules do not
apply (e.g. conducting emergency drills).
Knowledge-based behaviour occurs when a person or group of people are
trouble-shooting and problem-solving. It involves higher cognitive skills,
reasoning and decision making. It occurs when an unusual situation arises and
the people involved have to take action and make decisions based on their
knowledge and understanding of the situation rather than relying on a rule
of thumb.
The type of human error that occurs during this mode of operation is the
knowledge-based mistake. This occurs when a person makes a mistake
because they do not fully understand the situation or the system they are
working on, or they lack background knowledge. For example, an electrician
electrocutes themselves whilst fault finding on a complex electrical system
because they lack the competence to correctly diagnose the problem safely.

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This type of human error can be minimised by ensuring that people have the
right level of competence for their roles, i.e. training, background knowledge
and understanding. It can also be minimised by allowing people time to think
a problem through and correctly diagnose problems and solutions. If time
constraints are imposed, then knowledge-based mistakes are far more likely
to occur. The Chernobyl nuclear disaster was largely caused due to
knowledge-based mistakes operators made incorrect decisions during a
simulation exercise because they did not have the background knowledge to
correctly interpret information being fed back to them by the reactor.
Competent operators would have made different decisions. Knowledge-
based mistakes can also be minimised by ensuring that workers are overseen
by competent persons and that they have access to sources of advice, either
within or external to the organisation.

Question 2

In relation to human error:


(a) Distinguish between routine, situational and exceptional violations.(6)
(b) Outline, with appropriate reference to actual major incidents, the
factors that might promote routine violations at work. (14)

Interpretation
This question is set in two parts so must be answered in the same way. Note
the marks. Part (a) is itself broken down into three topics, so each part will be
relatively short. Part (b) requires a much more in-depth description of
factors. Note that part (b) is only concerned with the promotion of routine
violations (not situational or exceptional ones); also note the comment
about reference to actual major incidents. You do not have to base your
entire answer on actual major incidents, but clearly you should refer to
several as you give your answer.
Plan
(a) Routine custom and practice.
Situational not usual, but forced by pressure.
Exceptional something is already wrong.
(b) Cut corners, save time working posture, slow controls, noise levels,

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false alarms, procedures, PPE, environments, reward/incentive


scheme, work overload, perception, enforcement, new starters.

Suggested Answer
(a) A routine violation is a violation (an example of rule-breaking
behaviour) that has become the normal way of working within the
work group (e.g. speeding when driving in a car); it has become
custom and practice to break the rule in this way.
Situational violations occur because the pressures of the job
encourage the rule to be broken; the procedures cant be adhered to if
the job is to be done, e.g. no PPE available, so pressure to continue
without it. Situational violations are not the norm within the
workplace and you would often expect workers to do the job the right
way, but then they will break the rule because of some form of
pressure (or perceived pressure) - if a deadline is approaching the rule
breaking starts (in order to meet the deadline). Once the deadline is
passed, the pressure is relieved and the proper application of the rule
returns.
An exceptional violation occurs when things have gone wrong
(typically emergencies) and a rule is broken in an attempt to rectify the
situation. As the name suggests, exceptional violations only occur in
exceptional circumstances.
These definitions do not have clearly defined edges and it is possible
that one type can merge into another type over time. For example, a
situational violation occurs, workers get away with the rule breaking
(nothing bad happens) and so they are encouraged to break the rule
again. Over time, standards slip and the situational violation becomes
the normal way of working - it has become a routine violation.
(b) Routine violations often occur due to cutting corners to save
time/energy, which is encouraged by: awkward, uncomfortable or
painful working posture; excessively awkward, tiring or slow controls
or equipment; difficulty in getting in or out of maintenance or
operating position (posture); equipment or software which seems
unduly slow to respond; high noise levels which prevent clear
communication; frequent false alarms from instrumentation;
instrumentation perceived to be unreliable; procedures which are hard
to read or out of date; difficult to use or uncomfortable personal
protective equipment; unpleasant working environments (dust, fumes,

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extreme heat/cold, etc.); inappropriate reward/incentive schemes;


work overload/lack of resources.
In addition, there are the following factors: perception that rules are
too restrictive/impractical/unnecessary (particularly true where there
has been lack of consultation in the drawing-up of rules); belief that
the rules no longer apply; lack of enforcement of the rules (e.g.
through lack of supervision/monitoring/management commitment
even sanctioned by management turning a blind eye in order to get
the job done); or new workers starting a job where routine violations
are the norm and not realising this is not the correct way of working
(may be due to culture/peer pressure or lack of training). Examples
could include Herald of Free Enterprise capsize (bow doors left open),
Piper Alpha (permit procedures).

Question 3

Outline the desirable design features of controls and displays on a control


panel for a complex industrial process aimed at reducing the likelihood of
human error. (20)
Interpretation
This whole question is focused on the idea of human error (or operator
error), so think slips, lapses and mistakes - not rule breaking. Note the key
words controls and displays. Note that we are not given a specific panel
or process, so we are free to discuss general principles.
Plan
Controls: minimise number needed, easily operated (position), ordered
logically (follows process), require positive action with feedback to
indicate successfully operated, stereotyping/conventions (switches up
for off, down for on; knobs clockwise for increase, etc.), position controls
next to corresponding displays, emergency controls (prominent,
distinctive), etc.
Displays: visible, labelled, positioning of safety critical displays,
conventions/stereotyping (colours on dials relating to danger and safe
conditions, dials increase the same way, etc.), analogue vs digital
(appropriateness), glare avoidance.

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Suggested Answer
It is important, during the design of control panels for industrial equipment,
to consider the possibility of human error. Equipment operators may be
subject to human error, they may commit skill-based errors (slips and lapses)
and they may make mistakes (both rule-based and knowledge-based). These
errors might result in highly undesirable consequences and therefore must be
prevented. This can be done by careful design of controls (those parts of the
control panel that an operator has to interact with to make changes to the
operation of the equipment) and displays (those parts of the panel that
deliver information to the operator about the status of the equipment).
Desirable features of controls might include:
Minimise the number needed so as to avoid operator confusion.
Place controls in positions where they are easily operated.
Ensure that controls are ordered logically (e.g. in such a way that the
operation of the controls follows the logical order of the process being
controlled).
Design controls so that they require positive action in order to be
operated and cannot be operated accidentally or knocked. For example,
a hand brake of a car cannot be released simply by pushing down on the
lever.
Ensure that feedback is available to the operator to indicate successful
operation of the control.
Obey any stereotyping/conventions that might already exist for that
type of control. For example, switches up for off, down for on; knobs
turn clockwise for increase, etc.
It may be possible and desirable to position controls next to
corresponding displays. For example, if a knob alters temperature it
might be desirable to site the knob next to the temperature readout.
Emergency controls should be prominent and distinctive so that they are
easy to see and activate. They might be positioned near to the
operators position so that they are within easy reach in the event of
emergency.

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Controls that have to be operated frequently might be positioned close


to the operator for ease of access, whilst those that are used infrequently
might be positioned further away.
Controls might be laid out in an arc around the operator so that they can
all be activated without the need to over-reach.
Controls that require force to operate should be power or servo assisted.
Controls must not be overly sensitive; minor changes to the control
should not result in excessive changes to the parameter being controlled.
Desirable features of displays might include the following:
Displays must be visible to the operator from their normal operating
position. They must also be large enough to be easily visible to the
operator.
They must be appropriately labelled, so that the parameter they are
displaying is clear to the operator; this might require the use of
pictograms (which might also help overcome language barriers).
The positioning of safety critical displays must be carefully selected so
that they are in the operators normal line of sight and in a commanding
position.
Again, any conventions/stereotyping that exist should be recognised and
used. For example, colours on dials relating to danger and safe
conditions would normally use green for safe, red for danger. Dials
should all increase the same way, normally clockwise.
Careful selection of analogue vs digital displays should be made. There
are times when a digital readout is perfectly acceptable and desirable.
There are other times when analogue is preferred since the position of
the needle on an analogue dial can be determined by a quick glance that
does not require the accurate reading of numbers.
Displays must be carefully placed and lit so as to avoid glare.
Duplication of adjacent displays should be avoided in some instances
where accidentally reading the wrong display might end in disaster.

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ELEMENT IA8: REGULATING HEALTH AND


SAFETY
Short Answer Questions

Question 1

An organisation has decided to adopt a self regulatory model for its health
and safety management system.
Explain Distinguish between:
(a) The benefits; and (6)
(b) the limitations (4)
of self regulation in connection to the management of health and safety.
Interpretation
This question simply asks you to explain the benefits of self regulation; i.e.
speed, flexibility and ownership, versus the limitations arising from poorer
compliance.
Plan
(a) Benefits: (b) Limitations:
Developed by those involved All those involved may not
ownership. operate within the self-regulatory
rules.
Quicker to achieve than
statutory regulation. Danger of self interest being put
ahead of employee or public
Higher levels of compliance.
interest.
Easily be adapted/updated.
Lower levels of compliance.
Cheaper/quicker means of
No independent auditing.
addressing issues.
May result in closer relationship
between industry and clients.

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Suggested Answer
(a) One of the more important benefits of self regulation is that it is
developed by those directly involved in the management of health and
safety and this can generate a sense of ownership. Other benefits
include the fact that it may be quicker to achieve than statutory
regulation and can result in higher levels of compliance. It can also be
easily adapted or updated and may offer a cheaper and quicker means
of addressing issues. Finally, the application of self regulation may
result in a closer relationship between industry and its clients.
(b) Key limitations of the model are that all those involved may not
operate within the self-regulatory rules and that there is a danger of
self interest being put ahead of employee or public interest.
Additionally, self regulation can result in lower levels of compliance
because there is no third party or independent auditing and it may not
be valued highly by stakeholders.

Question 2

Outline, with examples, the benefits and limitations of:


(a) Prescriptive legislation (5)
(b) Goal-setting legislation (5)

Interpretation
This question is clearly structured and simply requires a comparison of
prescriptive and goal setting legislation in terms of benefits and limitations.
Note that the benefits of one type of legislation, i.e. prescriptive legislation is
not difficult to enforce, is the limitation of the other i.e. goal setting
legislation is more difficult to enforce.

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Plan
(a) Prescriptive Legislation
Benefits: Limitations:
Requirements clear and easy Inflexible.
to apply.
May require standards to be
Provides the same standard too high or too low.
for all.
Does not take account of local
Not difficult to enforce. risks.
Does not require a high level May need frequent revision.
of expertise.
(b) Goal-setting legislation
Benefits: Limitations:
More flexibility in the way Open to wide interpretation.
compliance may be
Duties and standards may be
achieved.
unclear until tested in courts.
Is related to actual risk.
More difficult to enforce.
Can apply to a wide variety
May require a higher level of
of workplaces.
expertise to achieve
Less likely to become out of compliance.
date.

Suggested Answer
(a) The benefits of prescriptive legislation are that its requirements are
clear and easy to apply and it provides the same standard for all. It is not
difficult to enforce and does not require a high level of expertise.
Its limitations are that it is inflexible and may be inappropriate in some
circumstances by setting standards too high or too low. It does not take
account of local risks and may need frequent revision to keep up with
changes in technology and knowledge.
(b) The benefits of goal-setting legislation are that it has more flexibility in
the way compliance may be achieved and it is related to actual risk. Also
it can apply to a wide variety of workplaces and it is less likely to become
out of date.

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These benefits are countered by the fact that it may be open to wide
interpretation and the duties it lays down and the standards it requires
may be unclear until tested in courts of law. As a result it may become
more difficult to enforce and may require a higher level of expertise to
achieve compliance.

Question 3

(a) Outline what is meant by punitive damages in relation to a


compensation award, clearly stating their purpose and to whom the
damages are paid. (5)
(b) In relation to claims for compensation outline the meaning of the
terms:
(i) No fault liability (2)
(ii) Breach of duty of care (3)

Interpretation
This, again, is a well signposted question and simply asks you to outline key
concepts relating to punitive damages, no fault liability and duty of care..
Plan
(a) Punitive damages:
Monetary award paid to a claimant.
Not awarded to compensate.
Awarded to reform or deter the defendant.
Both a punishment and a deterrent.
Amount of award determined by court - not linked to the loss.
(b) (i) No fault liability:
Independent of any wrongful intent/negligence.
Injury sufficient to confer liability.
Compensation paid by insurance or government.

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(ii) Breach of duty of care:


Duty of care owed by an employer to employee.
Employer breached duty.
Breach led to the loss.

Suggested Answer
(a) Punitive damages, are a financial or monetary award which, whilst
paid to a claimant, are not awarded to compensate them, but in order
to reform or deter the defendant and similar persons from pursuing a
course of action such as that which damaged the claimant. As such
they are both a punishment and a deterrent. The amount of the award
is determined by a court and is not linked to the losses suffered by the
claimant.
(b) (i) No fault liability is a liability which is independent of any
wrongful intent or negligence. As such, an injury alone is
sufficient to confer liability with compensation being paid either
by an insurance company or from a government fund.
(ii) There are three standard conditions that must be satisfied in
order to establish a breach of duty of care. These are that a duty
of care was owed by an employer to his employee; that the
employer acted in breach of that duty by not doing everything
that was reasonable to prevent foreseeable harm and lastly that
the breach led directly to the loss, damage or injury.

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Long Answer Questions

Question 1

(a) In relation to the improvement of health and safety within companies,


describe what is meant by:
(i) corporate probation (2)
(ii) adverse publicity orders (2)
(iii) punitive damages (3)
(b) Outline the mechanism by which the International Labour Organisation
can influence health and safety standards in different countries. (7)
(c) Explain the role of legislation in improving workplace health and safety (6

Interpretation
This is another well signposted question, this time a long question. The first
part simply asks you to describe the concepts of corporate probation, adverse
publicity orders, and, again, punitive damages. If you are familiar with these
concepts, then providing the answer should not pose a problem. The second
and third parts of the question require a little more thought in order to
indicate the way in which both the ILO, and national legislation influence, in
their own ways, health and safety standards in the workplace.
Plan
(a) (i) Corporate probation:
Supervision order.
Imposed by court on a company which committed a criminal
offence.
The court might:
Require company to review policy/procedures.
Initiate training programme (directors/senior
management).
Reduce the number of accidents.

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Aim is to instigate change in culture under the supervision of


the court.
(ii) Adverse publicity order:
Publicise the failings of an organisation.
Seek to change conduct through public perception.
Requires company to make public statement and change
approach to management of H&S.
(iii) Punitive damages:
Monetary award paid to a claimant.
Not awarded to compensate.
Awarded to reform or deter the defendant.
Both a punishment and a deterrent.
Amount of award determined by court not linked to loss.
(b) Conventions/recommendations.
Ratification of conventions commits to national law.
Report to the ILO detailing compliance with conventions.
Complaint procedures for violation of ratified convention.
Technical assistance.
Apply pressure internationally on non-participating countries.
(c) Sets minimum standards.
Can be enforced by a regulator.
Allows punishment if standards are not achieved.
Kept up to date by government.
Applies to all workplaces ensuring consistent application.
May be prescriptive or goal setting (ACOPs, guidance).

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Suggested Answer
(a) (i) Corporate probation is a supervision order imposed by a court
on a company that has committed a criminal offence. When
applied to a health and safety offence, the court might require
the company to review its safety policy or health and safety
procedures, initiate a training programme for its directors and
senior management or reduce the number of its accidents. The
aim is to instigate a change in the organisations culture under
the supervision of the court.
(ii) The intention of an adverse publicity order would be to publicise
the failings of an organisation and seek to change its conduct
through public perception. It requires the company to make a
public statement and to change its approach to the management
of health and safety.
(iii) Punitive damages, is a financial or monetary award which,
whilst paid to a claimant, is not awarded to compensate them,
but in order to reform or deter the defendant and similar
persons from pursuing a course of action such as that which
damaged the claimant. As such they are both a punishment and
a deterrent. The amount of the award is determined by a court
and is not linked to the losses suffered by the claimant.
(b) The ILO develops international labour standards through conventions.
These are supplemented by recommendations containing additional or
more detailed provisions. Ratification of conventions by member states
commits them to apply the terms of the convention in national law.
There is also a requirement for member states to submit a report to the
ILO detailing their compliance with the requirements of the
conventions that they have ratified. The ILO can also initiate complaint
procedures against countries for a violation of a convention that they
have ratified and also provide technical assistance to member states
where this is necessary. In addition ILO can also apply pressure
internationally on non-participating countries to adopt ILO standards.
(c) Legislation improves workplace health and safety by setting minimum
standards which can be enforced by a regulator and allowing
punishment of the offender if standards are not achieved. It is kept up
to date by government and applies to all workplaces ensuring
consistent application. The legislation may be prescriptive, or goal
setting, supported by approved codes of practice or guidance to assist
interpretation of standards required.

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Question 2

Non-governmental bodies have an important role in influencing health and


safety standards. Identify FIVE relevant influential parties and outline their
role in regulating health and safety performance. (20)
Interpretation
The NEBOSH syllabus in IA7.3 The Role of Non-Governmental Bodies and
Health and Safety Standards requires you to be able to Identify relevant
influential parties (employer bodies; trade associations; trade unions;
professional groups (e.g. IOSH); pressure groups, public, etc., and outline
their role in regulating health and safety performance consequently this
question comes as no surprise. The bodies referred to are already listed in the
syllabus so all we need to do is to expand on their individual roles in
regulating health and safety performance.
Plan
Relevant influential parties:
Employer bodies
Represent interests of employer.
CBI in UK:
Main lobbying organisation for UK business.
Works with government, legislators, policymakers to help UK
businesses compete more effectively.
Trade associations
Membership of companies who operate in a particular area of
commerce.
Promote common interests/improvements in quality, health, safety,
environmental and technical standards:
Publication of guidelines, information notes, codes of practice, and
regular briefing notes on technical issues and regulatory
developments.
Sharing of good practice.
Provision of news and events.

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Meetings, workshops seminars to enable networking/exchange of


information/ideas on technical and safety issues.
Trade unions
Organisation of workers.
Common goals in key areas wages/hours/working conditions.
Negotiates with the employer on behalf of its members:
Contracts.
Wages.
Work rules.
Complaint procedures.
Workplace safety and policies.
Agreements negotiated binding on rank and file members.
Unions may appoint safety representatives:
Investigate accidents.
Conduct inspections.
Sit on a safety committee.
Professional Groups (e.g. IOSH)
Individuals who work in a particular profession.
Achieved a defined level of competence.
Members pay a subscription/receive benefits.
UK, Institution of Occupational Safety and Health (IOSH):
Largest body for health and safety professionals.
Chartered Safety and Health Practitioners.
Sets professional standards.
Supports and develops members.
Provides authoritative advice and guidance on health and safety
issues.
Pressure Groups
Organised group of people who have a common interest.

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Seek to influence government policy or legislation.


Carry out research.
Lobby members of parliament.
Aim to influence public and government opinion.
UK Centre for Corporate Accountability:
Promotion of worker and public safety.
Focus on role of state bodies in enforcing health and safety
law/investigating work-related deaths and injuries.
Suggested Answer
Employer Bodies
These represent the interests of employers. In the UK the main body is the
Confederation of British Industry (CBI). The CBI helps create and sustain the
conditions in which businesses in the United Kingdom can compete and
prosper for the benefit of all. The CBI is the main lobbying organisation for
UK business on national and international issues. It works with the UK
government, international legislators and policymakers to help UK businesses
compete more effectively.
Trade Associations
Trade associations are formed from a membership of companies who
operate in a particular area of commerce and exist for their benefit. They can
promote common interests and improvements in quality, health, safety,
environmental and technical standards. This can be through various
appropriate means. For example, the publication of guidelines, information
notes, codes of practice and regular briefing notes on technical issues and
regulatory developments. Sharing of good practice can be facilitated
together with provision of news and events appropriate to their members'
areas of activity.
There can also be meetings, workshops and seminars held, depending on an
association's membership, both internationally and at a national/regional
level, to enable networking and the exchange of information and ideas, for
example on technical and safety issues.
Safety is of prime importance in any industry and there is usually a way of
publicising and circulating safety messages to the members on a regular basis.

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Membership of a trade association is generally available to companies and


organisations active in the relevant industry.
Trade Unions
A trade union is an organisation of workers who have formed together to
achieve common goals in key areas such as wages, hours, and working
conditions. The trade union negotiates with the employer on behalf of its
members and negotiates contracts with employers. This may include the
negotiation of wages, work rules, complaint procedures, rules governing
hiring, firing and promotion of workers, benefits, workplace safety and
policies. The agreements negotiated by the union leaders are binding on the
rank and file members and the employer and in some cases on other non-
member workers. In the UK, Unions may appoint safety representatives from
amongst the workers who may investigate accidents, conduct inspections and
sit on a safety committee.
Professional Groups
A professional group is an organisation of individuals who work in a particular
profession and have achieved a defined level of competence. Members
typically pay a subscription to join the group and receive a range of benefits.
In the UK, the Institution of Occupational Safety and Health (IOSH) is the
largest body for health and safety professionals. It is an independent, not-for-
profit organisation that sets professional standards, supports and develops
members and provides authoritative advice and guidance on health and
safety issues.
Pressure Groups
A pressure group is an organised group of people who seek to influence
government policy or legislation. They can also be described as interest
groups, lobby groups or protest groups. They carry out research, lobby
members of parliament and so aim to influence public and ultimately
government opinion. One example in the UK is the Centre for Corporate
Accountability. This is concerned with the promotion of worker and public
safety. Its focus is on the role of state bodies in enforcing health and safety
law and investigating work-related deaths and injuries.

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