GHS Response Collection Template - HSE Public...
Transcript of GHS Response Collection Template - HSE Public...
Health and SafetyExecutive
Health and Safety Executive
CD277 Proposals on the review of the Dangerous
Substances in Harbour Areas regulations 1987 (DSHAR),
Approved Code of Practice (COP 18)
and guidance HSE(R27)
Reply Form
Completing this Questionnaire
You can move between questions by pressing the ‘Tab’ / ’Shift-Tab’ or ‘Page Up’ / ‘Page Down’ keys or by clicking on the grey boxes with a mouse. Please type your replies within the rectangular grey boxes, or click on the square grey boxes to select an answer (e.g. ‘Yes’ or ‘No’).
Respondent’s details:
Name:
Email:
Town / City:
Telephone:
Job Title:
Postcode:
Street address:
Organisation:
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Fax:
Size of organisation:
Choose one option:
Not applicable 1 to 9 employees
10 to 49 employees 50 to 249 employees
250 to 1000 employees 1000+ employees
Self-employed
Type of organisation:
Choose one option:
Academic Charity
Consultancy Industry
Local government Member of the public
National government Non-departmental public body
Non-governmental organisation Pressure group
Trade association Trade union
If you chose ‘Other’ please specify:
Is your response being made in your capacity as:
Choose one option:
An employer An employee
Health and safety professional Trade union official
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Training provider
Other – please specify:
Confidentiality
Please indicate below whether your comments can be made available to the public or if you want them to be confidential. (NB if you do not indicate your choice they will be made available to the public. This takes precedence over any automatic notes on e-mails that indicate that the contents are confidential.)
Public
Confidential
Q1. Do you agree or disagree with our proposals in paragraphs 18-26 of the consultation document to amend the definitions and scope of DSHAR?
Agree
Disagree
If you disagree, please state why?
Q2. Would the changes proposed to the exemptions to DSHAR mean you had to do anything different to comply with the regulations?
Yes
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No
If yes, please state why?
Q3. Do you agree or disagree with our proposal to retain part II of DSHAR?
Agree
Disagree
If you disagree, please state why?
Q4. Do you agree or disagree with the amendments we are proposing in paragraphs 30 and 31 of the consultation document to the notification duty in regulation 6 of DSHAR?
Agree
Disagree
If you disagree, please state why?
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Q5. Should we revoke Part III of DSHAR – Marking and Navigation of Vessels?
Yes
No
If not, please state why?
Q6. Should we revoke Part IV of DSHAR, on handling dangerous substances?
Yes
No
If not, please state why?
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Q7. Should we revoke Part V of DSHAR on liquid dangerous substances in bulk?
Yes
No
If not, please state why
Q8. Should we revoke Part VI of DSHAR on packaging and labelling of dangerous substances?
Yes
No
If not, please state why.
Q9. Should we retain the duties in regulations 26 and 28 of DSHAR (emergency planning and untoward incidents) in the new regulations?
Yes
No
If not, please state why
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Q10. Do you agree or disagree that we should replace the duty in regulation 27 of DSHAR with a duty on berth operators to inform the master of a vessel of the emergency arrangements at the berth?
Agree
Disagree
If you disagree, please state why.
Q11. Should we revoke regulations 29-31 of DSHAR?
Yes
No
If not, please state why.
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Q12. Should we retain the requirement currently in regulation 32 of DSHAR for a designated parking area for dangerous goods?
Yes
No
If not, please state why.
Q13. (i) Should we replace the licensing requirement for harbours where ships carrying explosives are merely passing through, with a notification requirement on the ship?
Yes
No
If not, please state why.
Q13. (ii) We have assumed that this would make no difference to what ships carrying explosives through harbours would need to do in practice. Do you agree or disagree with this assumption?
Agree
Disagree
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If you disagree, please state why.
Q14. Should we replace the current military exemptions with an exemption for explosives under the control of Secretary of State and visiting forces, as set out in regulation 12(2)(e) of the proposed new regulations?
Yes
No
If not, please state why.
Q15. Do you agree or disagree with our proposals in paragraphs 94–98 of the consultation document to amend the explosives safety and security requirements in DSHAR?
Agree
Disagree
If you disagree, please state why.
←
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← Q16. If we reduce the record-keeping requirement from 5 to 3 years as proposed in paragraph 99 of the consultation document, would this lead to any cost savings for you, compared with what you do now?
←←
Yes
No
If so, please provide an estimate of any savings and explain your answer
← Q17. Should we keep the current provisions enabling statutory harbour authorities to make byelaws relating to dangerous substances in their harbour area?
←←
Yes
No
If not, please state why
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Q18. Do you have any comments on the proposal to retain the current enforcement arrangements in DSHAR?
←←
Yes
No
Please explain
Q19. Should we withdraw COP18 and HSR27 and replace these documents with a single consolidated ACOP?
←←
Yes
No
Please state why
←
Q20. Is the draft ACOP and associated guidance sufficiently clear for you to be confident about how you can comply with DGHAR?
←←
Yes
No
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Please state why
←
Q21. Are there any impacts from the revision of the guidance and ACOP that we should be aware of?
←←
Yes
No
If so, please explain
←
Q22. Do you agree or disagree with HSE’s estimate of the industry sectors and the number of enterprises affected in Table 1 on page 23 of the consultation document?
←←
Agree
Disagree
If you disagree, please provide further information
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Q23. HSE has assumed that the enterprises referred to in Table 1 (other than those involved in the transportation of freight by rail and road) may, at some point, come into contact with Dangerous Goods?
a) Is this reasonable?
←←
Yes
No
b) If not, what would be a reasonable estimate of the proportion of these enterprises that would come into contact with dangerous goods? Please state why
Q24. HSE estimates that 10% of enterprises undertaking freight transport by road are involved in the transport of dangerous goods to harbours and harbour areas. Is this assumption reasonable?
←←
Yes
No
If not, what would be a reasonable estimate of this proportion?
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Q25. Do you agree or disagree with our assumption that the proposed changes will be largely cost-neutral?
←←
Agree
Disagree
If you disagree, please state why
Q26. HSE estimates that familiarisation costs for businesses in the road and rail freight industries would be minimal. Do you agree or disagree with this assumption?
←←
Agree
Disagree
If you disagree, what would be a reasonable estimate? Please provide a basis for your answer.
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Q27. Is HSE's assessment of the process of understanding and communicating duties under DSHAR, as outlined in paragraphs 124 and 125 of the consultation document, reasonable?
←←
Yes
No
If you have said no, please state why.
Q28. How do businesses in your sector receive information about their obligations under DSHAR?
Q29. How often do businesses in your sector refer directly to the regulations and/or the guidance or ACOP documents?
Q30. Do you agree with the assumption that it will take approximately one hour of a Health and Safety Manager’s time, at a cost of £36.22 per hour, to understand and make provisions to communicate changes under the proposal?
←←
Yes
No
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← If not, what would be a reasonable estimate?
Q31. Do you have any other comments on the impact on businesses, including other assumptions made, that are not covered by questions 22-30?
←←
Yes
No
← Are there any further comments you would like to make on the issues raised in this consultative document?
Is there anything you particularly like or dislike about this consultation? Please provide comments.
Please send your response by 23 December 2015 to:
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DSHAR review teamHealth and Safety Executive
5S.3.18 Redgrave CourtMerton Road
BootleMerseyside
L20 7HS
E-mail: [email protected]
Thank you for taking the time to complete this questionnaire
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