KING’S COLLEGE LONDON · 6.1.2.2 Assessment of OH&S risks and other risks to the OH&S management...

Safety Policy Statement King’s College London 03/17

HSS2016 (SP001) Issue3

KING’S COLLEGE LONDON Health & Safety Services

STATEMENT OF GENERAL POLICY, RESPONSIBILITIES AND ARRANGEMENTS

IN RESPECT OF HEALTH, SAFETY AND WELLBEING PROTECTION

Issue Date: March 2017 Issue Number: 3 Procedure No:HSS(2016)SP001

Author: Anthony Scott Approved By: HSMG

Contents 1. Introduction 2. Health, Safety and Wellbeing Policy Statement

2.1 Statement of Intent 2.2 General Policy for Health and Safety

3. Governance of Health and safety

3.1 Safety Organisation and Responsibilities 3.2 Health & Safety Management Group

4. Health and Safety Management System

4 Context of Organisation 4.1 Understanding of organization and its context 4.2 Understanding the needs and expectations of workers and other interested parties 4.3 Scope of Occupational health and Safety management system 4.4 Occupational Health and Safety System 5. Leadership and worker participation 5.1 Leadership & Commitment 5.2 Occupational health and safety policy 5.3 Organisational roles, responsibilities, accountabilities and authorities 5.4 Participation and consultation 6 Planning 6.1 Actions to address risks and opportunities 6.1.1 General 6.1.2 Hazard Identification and assessment of OH&S risks 6.1.2.1 Hazard identification 6.1.2.2 Assessment of OH&S risks and other risks to the OH&S management system 6.1.2.3 Identification of OH&S opportunities and other opportunities 6.1.3 Determination of applicable legal requirements and other requirements 6.1.4 Planning to take action OH&s Objectives and planning to achieve them 6.2.1 OH&S objectives 6.2.2 Planning to achieve OH&S objectives 7. Support 7.1 Resources 7.2 Competence 7.3 Awareness 7.4 Information and Communication 7.5 Documented Information 7.5.1 General 7.5.2 Creating and updating



7.5.3 Control of documented information 8 Operation 8.1 Operational planning and control 8.1.1 General 8.1.2 Hierarchy of controls 8.2 Management of change 8.3 Outsourcing 8.4 Procurement 8.5 Contractors 8.6 Emergency preparedness and response 9. Performance Evaluation 9.1 Monitoring, measurement, analysis and Evaluation 9.1.1 General 9.1.2 Evaluation of compliance with legal requirements and other requirements 9.2 Internal audits 9.2.1 Internal audit objectives 9.2.2 Internal audit process 9.3 Management review 10 Improvement 10.1 Incident, nonconformity and corrective actions 10.2 Continual Improvement 10.2.1 Continual improvement Objectives 10.2.2 Continual Improvement Process

Appendix A Laws and Regulations



1. INTRODUCTION 1.1 This statement of general policy, responsibilities and arrangements in respect of health and safety

protection, including fire safety and wellbeing, and sets out how the university manages health and safety across all of its activities, both on and off campus. It describes the university’s safety management system and the organisational arrangements centrally and with Faculties/Schools and Directorates and managers’ responsibilities.

Detailed procedures covering all University health and safety arrangements (including Fire Safety) and wellbeing are available in separate procedural, guidance and advisory, documents and other safety publications issued and controlled by the Director of Health & Safety Services (H&SS) and all members of H&SS.

The university aims to establish a positive health and safety culture that includes awareness and understanding; effective processes; and positive behaviour by staff at all levels and by students and contractors and visitors. Wellbeing is more than the state of not being physically unwell; it includes physical, mental and social health. The university’s management system is based upon the requirements of the Management of Health and Safety at Work Regulations 9 (as amended), the health and Safety Executive publication “Successful Health and Safety Management (HSG65), and the Universities and College’s Employers Association (UCEA) leadership and management of health and safety in higher education institution (formally, Code of Best Practice “University Health and Safety Management“). All based on the Plan-Do-Check-Act model as also advocated in the Institute of Directors/HSE publication “Leading Health and Safety at Work: actions for directors, board members, business owners and organisations of all sizes”.

•Gap analysis

•Deliver training

• Implementation of procedures

•Risk Assessment

•Action significant findings

•Performance Evaluation

•Check compliance

•Annual audits

•Monitor

• Issue reports

•Strategic Review of Policy and Procedures

•Safety Risk Management Planning

• Identification of responsible persons

•Communication of plan and procedures

• Review findings from audits and risk Assessments

•Review legislative updates

•Review reports and trends

•Propose improvements

Act Plan

DoCheck



2. HEALTH, SAFETY AND WELLBEING POLICY STATEMENT

2.1. STATEMENT OF INTENT 2.1.1 The Council as the employing authority of King’s College London (the university ) issues this statement

setting out its general intentions for health and safety protection (incorporating fire safety). 2.1.2 The Council accepts that ultimate responsibility for health and safety lies with the employer and firmly

believes that successful health and safety policy is as important an element in good business practice as any other management policy. Development of a positive health and safety culture maintains high productivity in a safe working environment in which accidents and ill-health are reduced to a minimum, thereby contributing to good staff morale and overall business performance.

2.1.3 The university values its staff as its most important resources and is committed to not only meeting the

minimum legal standard required by legislation but, where practicable and in line with business need, to exceeding them and constantly striving for improvement in health and safety. High standards in managing health and safety protection are integral to the university’s delivery of world-class research and teaching. Although the Council carries ultimate responsibility, the management of the university is delegated to the Principal who is responsible inter alia for ensuring that the university provides a safe, supportive, inclusive and welcoming environment for staff, students and visitors. All employees and, where appropriate, students are expected to co-operate with the arrangements to deliver safe conditions and practices for work or study in the College so that accidents, occupational ill-health and other losses can be prevented or reduced. Employees are an important element in the safety system and all staff are encouraged to improve the university’s safety management by passing concerns or suggestions for improvements through their line managers.

2.1.4 The President & Principal has delegated, to those responsible for conducting university business at all

levels, the implementation and ongoing management of arrangements for the control of health and safety risks created by university activities. Safety management systems and arrangements shall be consistent with the principles set out by the Universities and College’s Employers Association (UCEA) leadership and management of health and safety in higher education institutions. The Principal shall ensure, through the provision of adequate financial and physical resources, including the appointment of competent assistance, that all commitments contained within the policy statement are met and that all employees are sufficiently trained and equipped. The Council will put in place relevant monitoring and reporting mechanisms to assure itself that the university’s safety management systems are fit for purpose.

The Governance arrangements, giving effect to this policy is shown in the section 3.

2.2 GENERAL POLICY FOR HEALTH, SAFETY AND WELLBEING 2.2.1 It is the policy of the university, so far as is reasonably practicable, to provide for the health and safety of

its staff1 and students and of visitors and members of the public using its premises and facilities and other persons who may be affected by its activities. The intention is to apply and maintain as a minimum the standards necessary to meet statutory requirements while seeking to achieve best management practice in accordance with higher education sector guidance.

2.2.2 The university seeks to provide and improve working conditions and accommodation to support its

teaching and research activities in accordance with its declared objective of achieving excellence in these areas.

2.2.3 It is the University will, so far as is reasonably practicable, and in accordance with legal obligations and

standards, to provide:

1 For purposes of this policy staff includes, so far as reasonably practicable, research post graduates.



premises maintained in a safe condition and without risks to health and adequate with regard to the provision of welfare facilities;

take such general fire precautions as will ensure, so far as is reasonably practicable, the safety of any of its staff, students and visitors including taking such general fire precautions as may reasonably be required in the circumstances of the case to ensure that the premises are safe.

a structured, risk based approach to the management and control of asbestos containing materials (ACMs) within its property portfolio to reduce the risk to its lowest practical level with the ultimate aim of providing an asbestos-free workplace

water hygiene management of all its operations, with regard to the design and maintenance of

domestic water and air handling systems to control the risk from Legionella bacteria.

safe access and egress to its premises for all staff, students and visitors including, subject to reasonable adjustments, those who are disabled, together with adequate and safe means of egress;

buildings and building services, plant and equipment that ensure safe and healthy working conditions;

arrangements for the safety and absence of health risks from the receipt, storage, transportation, use, maintenance and disposal, where appropriate, of articles, equipment, machines, substances and tools;

arrangements to ensure that articles designed, modified or constructed by employees or students in the course of their work or study for use in connection with College activities are safe and without health risks when being used, cleaned or maintained; that such articles are examined and tested by a competent person as necessary to ensure safety; and that adequate information is provided to users to ensure their health and safety;

arrangements to ensure that risks to the health and safety of employees, students and other persons who may be affected by the College’s activities are identified and assessed by competent persons and that control measures determined by such assessments are provided, used and maintained;

arrangements to manage emergencies and other unplanned events to protect the health and safety of staff, students and other persons and to mitigate damage or loss of University assets and harm to the environment;

suitable personal protective clothing and equipment for use by employees and to ensure that students, if not supplied with or loaned such items, are informed of the type of clothing or equipment required;

relevant and comprehensible information to employees, students and visitors to ensure their health and safety;

training for employees and students to enable them to carry out competently their duties and to work or study safely;

supervision by competent persons to ensure that employees and students undertake safely their work or study and to ensure compliance with general University or local procedures.

Arrangements for staff & students within clinical environments and confirm we will follow NHS clinical governance arrangements.

2.2.4 The University will co-operate with its NHS partners and all other employers with whom it jointly occupies

or shares control of premises to co-ordinate the respective arrangements for health and safety and controlling risks. It will also work with facilities management service providers and/or other contractors operating on its sites to ensure that safety arrangements and standards are consistent with this general policy. University staff will work to any higher standards that may obtain in jointly occupied or shared premises. If staff or students work in premises wholly under the control of another employer then the policy and arrangements of that employer will apply.

To give effect for this coorperation , the arrangements will be described in a Memorandum Of Understanding, incuding the clinical risk and goverance arrangement.

2.2.5 The University will establish and maintain arrangements to consult employees and students or their

elected Trades Union or other representatives. Employees will be consulted in making, monitoring and promoting this policy and be encouraged to participate actively in reviewing safety arrangements.



2.2.6 Deans of Faculties and Professional Services Directors and other senior managers are responsible for ensuring that their areas of activity operate within this policy and will draw up local arrangements, rules or procedures to manage those activities under their overall control and direction.

2.2.7 Individual and collective responsibilities and procedures for the management of risks to health and safety

are consistent with other business risk management policies and practices and management keeps under review the appropriateness and effectiveness of risk control measures.

2.2.8 Appropriate advice and assistance on health, & safety issues will be provided by a University Director of

Health & Safety Services who together with specialist and other safety officers will assist management at all levels in the effective discharge of legal duties and this policy.

2.2.9 University management will allocate funds to maintain, and where practicable and in line with business

need improve, legal safety standards consistent with this policy and with its strategic or financial objectives. Budget holders are responsible, within the University’s financial arrangements and regulations, for the direct costs of safety in areas or activities under their control and direction. Funding for the general improvement of the safety of buildings and the common services therein shall be a corporate responsibility.



3. GOVERNANCE OF HEALTH, SAFETY AND WELLBEING

3.1 LINE MANAGEMENT RESPONSIBILITIES 3.1.1 The Council acknowledges its legal responsibility for health and safety (including fire safety) and wellbeing

protection. It requires of its officers and senior University managers, its members and of University managers, individually and collectively, a commitment to implement this and supporting policies and arrangements through effective management systems and procedures. Further, to have regard to this policy in the general planning and control of University activities and functions. This includes activities or services provided by the University which may impact on visitors or other members of the public. The Council’s standing Audit and Compliance Committee will put in place relevant assurance, monitoring and reporting processes to ensure that the Council’s health and safety policy and procedures are being implemented effectively.

3.1.2 The Council will seek assurances from the Audit and Compliance Committee and the President &

Principal that appropriate health and safety management arrangements and practices are established throughout the University and are working effectively.

3.1.3 The Council assigns executive authority to the President & Principal to act on its behalf to ensure that an

effective management organization is established and maintained to implement this policy and to approve such general safety arrangements as are necessary. The Principal may seek the advice of senior University officers and managers in agreeing and taking action and will ensure that health and safety issues are considered and incorporated in the general planning, resourcing and co-ordination of the University’s operations.

3.1.4 The Health & Safety Management Group will advise the Principal on the management standards and

systems to deliver agreed policies and objectives and ensure that these systems are being effectively applied. It shall review health and safety performance and improvement on, at least, an annual basis to determine progress and effectiveness in delivering planned management objectives within the University. It shall review Business Plans to ensure the identification and deployment of adequate resources to control health and safety risks in accordance with legal obligations and the University’s risk management policy.

3.1.5 The Senior Vice President Operations is responsible for overseeing, as the nominated “Safety Champion”

Director on behalf of the Principal, the implementation of this policy. He or she is also responsible for supporting health and safety management arrangements across the Professional Services activities of the university. Directors and Heads of Professional Services Departments and/or subsidiary organizations are responsible for the health and safety of those activities and staff under their control or direction; and for ensuring that services commissioned or delivered meet all relevant statutory standards.

3.1.6 The Senior Vice-President/Provost (Arts & Sciences) and (Health) are accountable for ensuring that the

Deans of Faculties within their respective remits implement this policy and supporting arrangements to manage health and safety in respect of the activities and staff and students under their control. This is achieved by delegation of day to day assurance monitoring through their respective Chief Operating Officers.

3.1.7 The senior Vice President (Quality, strategy & Innovation) is accountable for supporting health and safety

management arrangements across the quality, strategy & innovation activities of the university. Ensuring that managers within their respective remits implement this policy and supporting arrangements to manage health and safety in respect of the activities and staff and students under their control.

3.1.8 Each Faculty Executive Dean and Professional Services Director or equivalent shall:

keep themselves aware of this general policy and University-wide arrangements as they affect the work undertaken by their Faculty/Directorate;

keep themselves aware of the fire safety responsibilities and arrangements for the University;

establish and record a Faculty/Directorate management structure to ensure specific responsibilities and functions to implement University and faculty/directorate health and safety statement, rules and arrangements are defined and allocated to responsible persons including Heads of Department, Division, Centre, Group, or other unit;



authorise and issue a Faculty/Directorate safety procedure recording the responsibilities and functions of staff and the arrangements whereby University Policy and faculty/directorate procedure are to be implemented;

formulate and keep under review a Safety Action Plan to identify and deliver key performance indicators for managing health and safety risks;

identify and manage health and safety risks arising from Faculty/Directorate activities on a systematic basis in accordance with University risk management policy;

ensure an effective communication system within their Faculty/Directorate so that University policy and local safety procedure and arrangements are brought to the attention of their staff and students, as appropriate;

ensure that all Faculty/Directorate equipment is installed appropriately and maintained in a safe condition and where necessary regularly tested or examined;

make budgetary provision for and ensure that before laboratories or other specialist work places are vacated, all unwanted and surplus materials are disposed of and furniture, fittings and equipment contaminated by hazardous materials are suitably cleaned, decontaminated or otherwise treated in accordance with University procedures;

based on the risk profile of the Faculty/Directorate ensure that a sufficient number of local safety officers or persons are available to advise on and monitor health and safety standards and that they have the necessary authority and resource to undertake such functions as may be reasonably required;

ensure that a planned programme of workplace inspections are undertaken, the frequency of which will be dependent upon the risk profile of the Faculty/Directorate

establish a Faculty/ Directorate Safety Committee, or other body including a similar remit, to monitor safety standards and to advise and co-ordinate safety arrangements. Such Committees should include representatives of all sections and interests within the Faculty/Directorate and will act as the forum for consultation with staff and their representatives locally on matters affecting health & safety. The number of meetings shall be determined by the level of risk within the Faculty/Directorate and issues within.

3.1.9 All staff who supervise or direct University employees or students are responsible, in

accordance their job description, for establishing and enforcing appropriate health and safety protection measures.

In particular, supervisors shall ensure that:

comprehensible information is provided to employees or students on the hazards and risks associated with their work or study including placements or other activities undertaken elsewhere within the UK or overseas;

the risks of the work or programme of study are identified and assessed, and the safety measures identified by that assessment are provided and properly used and that safe working practices are established and their effectiveness monitored;

the lowest hazards and risks consistent with the achieving the objectives of the work are selected and that regard is given to the capability of the employee or student concerned;

a record of the conclusions of the risk assessment is documented using such procedures as the University may determine and that these conclusions are kept under review;

instructions and training in safe working methods and techniques and in the use of safety measures are provided

checks are made to ensure people are working safely as advised.



3.1.10 All employees (and postgraduate research students, and employees of other organizations, including agency workers, and visitors working in university facilities and premises) must take reasonable care for their health and safety and that of others who may be affected by their activities. In particular, they shall:

comply with university safety policy and all local safety procedures, rules and instructions relating to their work;

report, in accordance with University procedures, instances of personal injury accidents and specified dangerous occurrences;

report unsafe conditions or activities to their supervisor, local safety officer or Help Desk so that remedial action can be initiated;

properly use any safety measures or devices provided for their work including personal protective clothing or equipment in accordance with instruction or training;

not intentionally or recklessly interfere with or misuse anything which is provided in the interests of health and safety;

co-operate with the officers and managers of the University to ensure the implementation of this policy and compliance with statutory provisions.

report any shortcomings found within the safety management system to their supervisor/manager

Notify their supervisor/line manager of any work situation that has, in their opinion, the potential for serious or imminent danger.

3.1.11 All undergraduate and postgraduate taught students must take reasonable care for their health and

safety and that of others who may be affected by their activities. In particular, they shall:

comply with university safety policy and all local safety procedures, rules and instructions relating to their studies;

report, in accordance with University procedures, instances of personal injury accidents and specified dangerous occurrences;

report unsafe conditions or activities to their supervisor, local safety officer or Help Desk so that remedial action can be initiated;

properly use any safety measures or devices provided for their studies including personal protective clothing or equipment in accordance with instruction or training;

not intentionally or recklessly interfere with or misuse anything which is provided in the interests of health and safety;

co-operate with the officers and managers of the University to ensure the implementation of this policy and compliance with statutory provisions.

report any shortcomings found within the safety management system to their supervisor

Notify their supervisor of any study situation that has, in their opinion, the potential for serious or imminent danger.

3.2 MANAGERS WITH ADDITIONAL SPECIFIC ORGANISATIONAL RESPONSIBILITIES

3.2.1 The Director of Real Estate (Estates & Facilities) is accountable for ensuring for the safety of University premises including the building structure, fabric and services, the safety of staff engaged in maintenance work and members of the public. Works to alter, repair, maintain or demolish any building or part thereof, including general plant and building services, must be carried out with due regard to this general policy, University procedures and any specific planning, building control, fire safety or other legal requirements.

3.2.2 the Director of Real Estate shall delegate these additional day to day accountability:

Facilities safety operations to The Director of Real Estates Management (DREM) who is responsible for the procedures and practices, including the overall strategic asbestos and legionella management and ensuring development and implementation of the Asbestos and legionella Management Plans.



new builds and major refurbishments to The Director of Real Estates Development (DRED) who is responsible for ensuring such infrastructure projects and programs complies with the relevant health and safety and other statutory requirements.

3.2.3 The DREM, in collaboration with H&SS, is responsible for coordinating the effective implementation

of the fire safety management system, so far as is reasonably practicable, as affecting University premises, including Fire risk assessment and local emergency evacuation procedures.

3.2.4 The DREM shall ensure that arrangements are in place to appoint competent building and

engineering contractors, for existing buildings, and to inform them of the hazards of University premises in which they work. Any other University Officers independently commissioning building or engineering including cable and wiring or other installation or adaptation works in University buildings must consult with the Real estates management team to ensure that contractors comply with University policies and procedures for working on University premises.

3.2.5 The DREM and DRED, as appropriate, shall ensure that sufficient and competent CDM Coordinators,

Project Managers or Officers and contractors are appointed so that existing building or refurbishment projects can be undertaken in compliance with relevant statutory requirements and University policy and arrangements.

3.2.6 DREM and DRED through Project Managers or other Estates Officers shall ensure that the work,

whether undertaken by contractors or University staff, complies with the relevant health and safety and other statutory requirements. Works undertaken by the University’s facilities management services provider(s) and other contractors must be undertaken in accordance with the output specifications of the Project Agreement as specified and in compliance with all relevant health and safety legislation.

3.2.7 The DREM is accountable for the health and safety of employees engaged in professional services

within his managerial remit, via delegated managers, including: audiovisual and photography, catering, cleaning, pest control, reception and telephones, security, non-hazardous waste disposal. He is also responsible for ensuring that services commissioned or delivered by his area meet all relevant statutory and regulatory standards.

3.2.8 Joint responsibility of DREM and Director of Students and Education to ensure that Residences are

constructed, maintained and managed to ensure the health and safety of student occupants including fire prevention and emergency evacuation.

3.2.9 The DRED shall ensure all new builds and major refurbishments covered by this part of estates and

facilities operations, complies with the relevant health and safety and other statutory requirements. Works undertaken by the University’s facilities management services provider(s) and other contractors must be undertaken in accordance with the output specifications of the Project Agreement as specified and in compliance with all relevant health and safety and other appropriate, e.g. Equality Act 2010, legislation.

3.2.10 The Director of Students and Education is responsible for the health and safety of employees

engaged in professional services within their managerial remit including: Libraries and King’s Sport. They are also responsible for ensuring that services commissioned or delivered by their area meet all relevant statutory and regulatory standards. Coordination of those safety, health and wellbeing aspects relevant to our student cohort including liaison with KCLSU and estates & facilities.

3.2.11 The Director of Human Resources is responsible for ensuring that human resource management

and administrative systems are in place for the appropriate pre-employment screening, health assessment and surveillance monitoring, induction and training of staff in order to promote and maintain a safe and secure working environment. Monitoring of sickness absence. Contributing to health and wellbeing initiatives.

3.2.12 The Director of Research Management & Innovation is responsible for coordinating the operational

safety arrangements associated with research and development activities.



3.2.13 A Director of Health & Safety Services (as the legally designated “competent person”) is appointed to the university to provide independent advice, assistance and assurance with regards to the university’s health and safety management system. the Health & Safety Services remit, which is strategic in nature and the main functions are to:

advise all members of the university community about health & safety (including fire safety) and wellbeing, in general and as the law applies to individuals

advise the university about its health & safety performance, using monitoring and auditing processes

advise and support managers and others carrying out health & safety work in accordance with duties and responsibilities assigned to them in law or through university procedures

advise the university about the implications of proposed or new legislative requirements or enforcement agency policies and arrangements

maintain a database of all reported accidents, incidents and near misses, together with appropriate documentation about their investigation

liaise with the Health & Safety Executive and other relevant enforcement agencies

make (or co-ordinate) all statutory notifications and returns including those required by the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations

draft and submit for approval policy and arrangements that apply across the university

provide and support health & safety training and develop new training material and courses

provide a reference source of relevant health & safety information and documentation, including university policy statement, arrangements and guidance relating to health and safety matters.

communicate with and assist faculties and directorates and local safety advisors appointed by senior managers.

research or otherwise investigate aspects of health & safety that are new or unfamiliar

liaise with external bodies with an interest in health and safety management, including the university’s insurers and sector-specific professional groups.

3.2.14 All Faculties and Directorates at all levels of management will accept ownership of, and

accountability for, health and safety management and that the university accepts that the primary functions of health & Safety Services are for the provision of safe system development, advice and assurance to assist and enable managers in fulfilling their legal duties and ensure regulatory compliance (Figures 1, 2 & 3 summarises the Governance arrangements).



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Figure 1: The University Safety Organisation Chart

COUNCILUltimate responsibility for health and safety

AUDIT, RISK & COMPLIANCE COMMITTEEResponsible on behalf of the Council for monitoring the management of health

and safety

PRESIDENT & PRINCIPALOverall executive responsibility for health and safety & accountable to the

Council

PRINCIPAL SENIOR MANAGEMENT TEAMIncludes nominated Safety Champion.

Accountable to the Principal for health and safety of faculties/Directorates and

for compliance with university and statutory requirements.

HEADS OF FACULTIES/DIRECTORATESAccountable to SMT for ensuring that effective local arrangements are in place

for the implementation of College health and safety policies, procedures and

codes of practice.

HEADS OF DEPARTMENT/DIVISIONSAccountable to HoS/HoD for the implementation of university health and safety

policies, procedures and CoP

FACULTY/ /

DIRECTORATE

SAFETY

OFFICERS/

SAFETY

COMMITTEES

HEALTH AND

SAFETY

MANAGEMENT GROUP

Key

Line Management delegation)

Reporting line (accountability)

Advice/support

DIRECTOR

SAFETY

SERVICES

(COMPETENT

ADVISORY

SERVICE:

HEALTH &

SAFETY

SERVICES)

Other specialist

advice, e.g.

Occupational

health

Radiation

protection

advisor/service

INDIVIDUALSResponsible for their own health and safety, and for complying with university

and faculty/Directorate arrangements

Policy & Safety system Monitoring and Approval

Local plans, implementation and protocol development

Safety Strategy

development &

assurance

TRADE UNIONS

CONSULTATION



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Figure 2: Management levels (UCEA)

Governing Body This is the group with overall accountability and

assurances for the strategy of the institution:College Council

Leadership/Executive Team This is the group which typically consist of the Vice-Principals, College secretary and Registrar (Chief

Operating Officer), Deans and Professional Services Directors who have the responsibility for influencing and

shaping the strategic direction of the Institution.

Front Line & Supervisory Staff This tier have responsibility for overseeing activities

of staff and/or students but are unlikely to be responsible for developing those activities e.g. a

technical officer supervising a laboratory or a supervisor of a frontline service.

Line Managers This is the group of staff either academic or support

who have responsibility for the day to day direction of activities and the management of staff in line with the strategic direction of the particular Faculty/ School or Directorate. Examples may include section leaders,

Principal Investigators (PIs).

Senior Managers This is the group who have responsibility for the

implementation of the strategic direction of a particular Faculty /School or Department. This group consists of Deputy Deans/Directors, Subject/Divisional Leads, and

Directors of Research

From a centrally based individual or team:

Annual reports and or quarterly reports on H&S.

Briefing sessions or papers on significant events, change to legal requirements

Submission of College KPIs

Provide contextual information about comparisons with sector norms and statistical information

Formal or informal training for the leadership team

Advice on interpretation of H&S legislation and best

practice

This would be a joint approach with significant contributions from local safety appointments, especially for specific hazards such as radiation, bio/GM, DSE, etc. and support from centrally based individual or team

Communications about significant events, changes to legal requirements of relevance to your faculty/school/directorate

Attendance at health & safety committees or other meetings where H&S is discussed

Information about accidents and incidents occurring in your faculty/school/directorate

Guidance on how to investigate incidents and H&S issues

Actions plans and recommendations from investigations

Advice on management actions and proportionate responses to incidents

Advice on interpretation of H&S legislation and best practice

Training courses or delivery of presentations and information

Completion of faculty/school/directorate returns of KPIs

Assistance to managers during audits, inspections, etc. This would predominantly come from your local safety appointment this may also include limited input from a centrally based individual or team

Communications about significant events, changes to legal requirements of relevance to your faculty/school/department

Attendance at local health & safety committees or other meetings where H&S is discussed

Information about accidents and incidents occurring in your faculty/school/department

Participation in discussions to resolve local H&S issues

Actions plans and recommendations from investigations

Advice on management actions and proportionate responses to incidents

Advice on interpretation of H&S legislation and best practice

Training courses or delivery of presentations and information

Completion of faculty/school/department returns of KPIs

Assistance to managers during audits, inspections, etc.

From a centrally based individual or team:

Annual reports and or quarterly reports on H&S.

Briefing sessions or papers on significant events, change to legal requirements

Formal or informal training for Board members and governors.

Submission of university KPIs

Provide contextual information about comparisons with sector norms and statistical information



Figure 3: University Accountability arrangements

H&SS /Principal & Senior Management Team Faculties/Directorates Staff/Students

Providing health and safety strategic direction, advice, assurance and guidance for the university

Development and review of university policy, procedures and guidance documents relating to health and safety arrangements

Contribute to consultations and comply with university arrangements for health and safety

Contribute to consultations and comply with university arrangements for health and safety

Produce safety related standards to support university safety management system

Develop and implement faculty/directorate strategies for meeting the university standards relevant to their area

Contribute to the implementation, as appropriate to your faculty/directorate, the safety management system

Develop training strategy and provide e-learning and classroom based training and monitor provision of specialist training.

Monitor and ensure training attendance. Allocate sufficient resources for any necessary activity specific training

Complete e-learning modules and attend classroom based training relevant to role

Liaising with insurers in collaboration with stakeholders and providing advice and guidance on safety risk and cost reduction options

Take part in and implement recommendations arising from insurance inspections

Implement, as necessary, recommendations arising from insurance inspections

Monitoring and, where appropriate, investigating accidents/ incidents and developing learning outcomes

Investigate causes of accidents & incidents, where appropriate, with advice from H&SS

Cooperate with management/safety officers as appropriate in investigation of accidents incidents

Carrying out periodic inspections and audits of University undertaking in relation to health and safety arrangements

Take part in audits of health and safety arrangements and implement recommendations. Ensure that there is a risk based programme of workplace inspections and monitor findings.

Cooperate with audits and workplace inspections. Report any unsafe conditions or unsafe acts that cannot be resolved locally to E&F or H&SS as appropriate

Advising the University’s various safety committees on issues relating to health and safety

Ensure that health and safety is reviewed and discussed at a Faculty/Directorate level either by convening a Faculty/Directorate safety committee or by a standing agenda item on an existing Faculty/Directorate level meeting.

Raise any health and safety concerns with the local committee representative when matters cannot be resolved locally.

Develop risk assessment strategy requirements and monitor/audit compliance in collaboration with relevant stakeholders

Ensure safety risk assessments are carried out and kept up to date, and improvement actions are appropriately managed

Contribute as appropriate with management to ensure that suitable and sufficient fire risk assessments for the buildings are undertaken

Develop and monitor contractor permit/procedure

Ensure compliance with contractors permit/procedure.

Report any suspected unsafe acts/conditions relating to contractors as soon as practicable

Monitor and advise on local safety arrangements

Develop in collaboration with Faculties/Directorates local safety arrangements

Collaborate with management in the development of local safety arrangements

Liaise with enforcement Authorities, HSE, EA and LFB etc., on safety arrangements and be the main contact point for these authorities

Inform H&SS of all contacts and visits by enforcing authorities. Where practicable this should be forehand.

Inform line management and/or H&SS of faculty/Directorate of all contact and visits by enforcing authorities

Liaise with insurers on safety arrangements and be the main contact point for these authorities

Inform H&SS of all contacts and visits by insurers. Where practicable this should be forehand.

Inform line management and/or H&SS of faculty/Directorate of all contact and visits by insurers

Advise the university’s safety committees on issues relating to health and safety

Ensure that health and safety is a permanent item on Faculty/Directorate safety /executive management committee agenda

Inform management of faculty/directorate, of health and safety concerns/issue for inclusion in faculty/directorate safety committee business.

Advise Faculties/Directorates of identified deficiencies relating to health and safety

Ensure unsafe acts and conditions that are reported to faculties/directorates are rectified within an acceptable period of time

Report unsafe acts and conditions (e.g. faulty fire doors etc) to faculty/directorate management and/or H&SS as appropriate

Ensure communal areas are kept clean and tidy. Report any repeated transgressions to the relevant Faculty/Directorate

Maintain good housekeeping

Communication

Cooperation

Coordination



4. HEALTH AND SAFETY MANAGEMENT SYSTEM The university has adopted, as current good practice, the development of a health and Safety

Management system based on OHSAS1800:2007 ( and the evolution into ISO45001 when formally adopted).



4 Context of Organisation 4.1 Understanding of organization and its context

King’s is:

one of the top 25 universities in the world (2016-17 QS international world rankings)

the fourth oldest university in England

research-led and based in the heart of London.

King’s has over 27,600 students (including nearly 10,500 postgraduates) from some 150 countries and almost 6,800 employees.

King’s provides world-class teaching and cutting-edge research:

In the 2014 Research Excellence Framework (REF) King’s was ranked 6th nationally in the ‘power’ ranking, which takes into account both the quality and quantity of research activity, and 7th for quality according to Times Higher Education rankings

Eighty-four per cent of research at King’s was deemed ‘world-leading’ or ‘internationally excellent’ (3* and 4*)

The university is in the top seven UK universities for research earnings and has an overall annual income of more than £684 million.

King’s has a distinguished reputation in:

the humanities

law

the sciences, including health areas such as psychiatry, medicine, nursing and dentistry

social sciences, including international affairs.

King’s has influenced many of the advances that shape modern life, such as:

being the largest centre for the education of healthcare professionals in Europe.

King’s Health Partners

King’s, Guy’s and St Thomas’, King’s College Hospital and South London and Maudsley NHS Foundation Trusts are part of King’s Health Partners. King’s Health Partners Academic Health Sciences Centre (AHSC) is a pioneering global collaboration. For more information, visit the King's Health Partners' website.

Supporting evidence: WHITE PAPER: CHANGING KING’S FOR A CHANGING WORLD: A

STRATEGIC VISION FOR 2029

4.2 Understanding the needs and expectations of workers and other interested parties

Interested parties include schools and faculties and the UK and overseas students attending courses at King’s; the alumni and the various funding and research organisations associated with the research undertaken at King’s.

4.3 Scope of Occupational health and Safety management system

The safety management system will cover all university activities both on and off campus under the control of the university. Through risk log/register all identified risks shall be managed through the university’s safety management system

Supporting evidence: SPR007 (current version)summary of safety management system

4.4 Occupational Health and Safety System

A safety management system has been established, maintained and aims for continual improvement.

Supporting evidence: SPR007 (current version)summary of safety management system

http://www.kingshealthpartners.org/

http://www.kingshealthpartners.org/



5. Leadership and worker participation 5.1 Leadership & Commitment

The health and safety policy statement has the authority (signed) by the Principal of King’s College London. The Principal chairs the overarching health & safety Management group.

Document: HSS (current version)SP001, STATEMENT OF GENERAL POLICY, RESPONSIBILITIES AND ARRANGEMENTS IN RESPECT OF HEALTH, SAFETY AND WELLBEING PROTECTION

5.2 Occupational health and safety policy

The safety policy has authorization of the principal, is published, communicated within the organisation, available to interested parties and reviewed periodically to ensure it remains relevant. This policy statement and safety system (including fire safety) will be reviewed at least annually by the Health & Safety Management Group in the light of changes in university activities, developments in health, safety and other relevant legislation e.g. environmental protection law and to ensure that it continues to meet the needs of the University. A report on the health and safety performance of King’s College London will be produced annually, taking into account Faculty Directorate annual reports.

Document: HSS (current version)SP001, STATEMENT OF GENERAL POLICY, RESPONSIBILITIES AND ARRANGEMENTS IN RESPECT OF HEALTH, SAFETY AND WELLBEING PROTECTION

5.3 Organisational roles, responsibilities, accountabilities and authorities

The Principal and the senior leadership team ensure that responsibilities, accountabilities and authorities for relevant roles within the OH&S management system are assigned and communicated at all levels within the university

Supporting evidence: HSS (current version)SP001, STATEMENT OF GENERAL POLICY, RESPONSIBILITIES AND ARRANGEMENTS IN RESPECT OF HEALTH, SAFETY AND WELLBEING PROTECTION

5.4 Participation and consultation

In accordance with the requirements of the Safety Representatives and Safety Committee Regulations 1977, the University is fully committed to consulting with members of staff on matters affecting their health and safety. This is normally achieved through elected Trade Union Safety Representatives (TUSR) who liaise with managers and staff and attend regular faculty/Directorate level safety committees. Management recognizes, and supports, the need for all TUSR to have sufficient time to train and carry out their official union safety representative duties. A sub-group of the Health and Safety Management Group, designed to consult with TU at a strategic level also exists and meetings are arranged to coordinate with the main Health and safety Management Group.

Supporting evidence: Minutes of meetings

6 Planning 6.1 Actions to address risks and opportunities

6.1.1 General

The Audit and Compliance Committee is established as a Committee of Council to advise Council on the University’s compliance with all relevant legislation and/or standards emanating from statutory, regulatory or funding agencies to include health, safety and environmental protection and risk management of health, safety and environmental protection. The Committee will monitor, with the assistance of the Director of H&SS, and ensure the review of this general policy and supporting arrangements to inform Council of the extent of compliance and to support continuous improvement and the application of best management practice. The Council of King’s College London whilst retaining the legal duty for health and safety delegates to the Audit and Compliance Committee responsibility for:



ensuring that there is monitoring of performance against key performance indicators for corporate health and safety management;

ensuring that there is proper monitoring of the effectiveness of the general policy and supporting policies, and the arrangements used to assess performance in health, safety and environmental protection.

Receiving reports on enforcement activities from regulatory authorities

Supporting evidence: Risk management Policy King’s College london 2016

6.1.2 Hazard Identification and assessment of OH&S risks

6.1.2.1 Hazard identification

All university undertakings, including biological, chemical, radiological other physical and psychosocial hazards, are risk managed. Wherever practical, risks must be avoided or steps taken to source a lower risk approach. Residual risks must be assessed and kept as low as reasonably practicable through use of a range of preventative measures including engineering controls, behavioural controls, and personal protective equipment. This process must be kept under regular review. The university is required to undertake fire risk assessments of its buildings to ensure that the risk of fire is reduced so far as is practicable and risks and hazards are controlled to an acceptable level and that the fire safety arrangements are suitable and sufficient. The fire risk assessments must be documented and regularly reviewed to ensure that remedial measures have been implemented and that risk assessments are updated following any works that affect the passive or active fire safety measures. Every university facility, including those shared with NHS trusts or other employers must have a “fire and emergency” procedures document to ensure the safety of staff and students in the event of foreseeable emergencies. In addition to risk from fire other incidents such as chemical, biological spillage, utility failure and flooding etc. should be covered. These procedures must be tested on a regular basis to ensure they are effective.

CHILDREN ON UNIVERSITY PREMISES

The University is a place of work, and its buildings are generally not designed for children. The University therefore discourages the inappropriate attendance of children in the workplace. However, it is recognised that members of staff may need to bring their children into work in exceptional circumstances, and also that Faculties/Schools/Directorates may wish/require to hold events designed specifically for children. In these circumstances, appropriate management permission must be sought and risk assessments prepared.

CONTRACTOR SAFETY The University has a duty to ensure the health and safety of contractors who may be affected by University activities. Likewise, contractors have a duty to ensure the safety of University staff, students and others who may be affected by their work on University premises. Those responsible for engaging contractors to undertake work on University premises must ensure that contractors are provided with comprehensive and understandable information on any health and safety risks arising from the University’s undertaking, including:

Emergency procedures

Site and local rules

Relevant information from risk assessments

Information about specific hazards, e.g. asbestos

Ensuring they are competent and comply with statutory requirements Contractors, too have obligations, and must inform the University of risks arising from their activities which adversely affect the health, safety and welfare of university staff and students.



SAFE WORKPLACE, PLANT AND EQUIPMENT The University will ensure all of its premises, plant and equipment are suitable for use and maintained in a safe condition. This includes, where appropriate, Statutory Inspections carried out by our insurers or other nominated competent and independent inspectors. SHARED ACCOMMODATION AND OFF-SITE WORKING Where university staff occupy accommodation managed or under the control of others, or share accommodation with other employers, University will

cooperate with the other employers to enable them to meet their health and safety obligations

take reasonable action to coordinate its procedures with those of the other employers to comply with legislation

take reasonable steps to inform other employers of the risks to their employees’ health and safety arising from the work of the University

ensure that, where appropriate, University risk assessments cover the workplace as a whole and not just the area occupied by University staff.

VISITOR SAFETY Visitors include the staff of other employers, such as suppliers and consultants, and members of the public. Visitors who enter university buildings must be provided with information on any hazards or risks to which they might be exposed, and any rules or emergency procedures which they must follow. Staff who invite visitors onto the premises are responsible for their health and safety.

Supporting evidence: SPR008 (current version) Safety responsibilities and arrangements in respect of the use and management of contractors SPR028 Young persons (current version) SPR031 (current version) Safety Memorandum of Understanding for embedded units SPR036 (current version) Fire Risk Management Strategy

6.1.2.2 Assessment of OH&S risks and other risks to the OH&S management system

Risk registers from all faculties and directorates are maintained and a corporate risk register is monitored by audit and compliance committee.

Supporting evidence: Risk management Policy King’s College London 2016 6.1.2.3 Identification of OH&S opportunities and other opportunities

Reviewing ways of working and safety management system is a continual process. Regular reviews are undertaken and assessed by HSMG.

Supporting evidence: H&S resources and strategy document

6.1.3 Determination of applicable legal requirements and other requirements

There are a number of laws and regulations affecting the university’s activities. The significant Health and Safety laws and Regulations impacting upon university business are shown at appendix A of this document. These are monitored on a regular basis by H&SS. Subscription to external legal and other resources.

Supporting evidence: Appendix A, safety Policy document

6.1.4 Planning to take action

Through the safety strategy actions planned to address the risks and opportunities identified are taken forward. Additionally business continuity and other senior

Supporting evidence: Health & Safety strategy 2015-2018

6.2 OH&s Objectives and planning to achieve them

6.2.1 OH&S objectives

The university through the HSMG sets objectives to maintain and improve the OH&S management system. These are monitored by the H&SMG and other management committees.

Supporting evidence: Health & Safety Strategy 2015-18



6.2.2 Planning to achieve OH&S objectives

The university through the HSMG sets objectives to maintain and improve the OH&S management system. These are monitored by the H&SMG and other management committees

Supporting evidence: Health & Safety strategy 2015-2018

7. Support 7.1 Resources

The university, through regular review of resources determines the resources needed for the establishment, implementation, maintenance and continual improvement of the OH&S management system.

Supporting evidence: OH&S resources review 2016 briefing paper for HSMG

7.2 Competence

HEALTH AND SAFETY ASSISTANCE ( COMPETENT PERSONS) A Director of Health & Safety Services is appointed to the university to provide independent advice, assistance and assurance with regards to the university’s health and safety management system. the Health & Safety Services remit, which is strategic in nature and the main functions are to:

advise all members of the university community about health & safety (including fire safety), in general and as the law applies to individuals

advise the university about its health & safety performance, using monitoring and auditing processes

advise and support managers and others carrying out health & safety work in accordance with duties and responsibilities assigned to them in law or through university procedures

advise the university about the implications of proposed or new legislative requirements or enforcement agency policies and arrangements

maintain a database of all reported accidents, incidents and near misses, together with appropriate documentation about their investigation

liaise with the Health & Safety Executive and other relevant enforcement agencies

make (or co-ordinate) all statutory notifications and returns including those required by the Reporting of Injuries, Diseases and Dangerous occurrences Regulations

draft and submit for approval policies and arrangements that apply across the university

provide and support health & safety training and develop new training material and courses

provide a reference source of relevant health & safety information and documentation, including university policy statement, arrangements and guidance relating to health and safety matters.

communicate with and assist faculties and directorates and local safety advisors appointed by senior managers.

research or otherwise investigate aspects of health & safety that are new or unfamiliar

liaise with external bodies with an interest in health and safety management, including the university’s insurers and sector-specific professional groups. The Director of H&SS will be provided with such assistance and resource as is necessary to undertake these functions including that necessary to provide specialist advice in biological, fire, radiation safety and construction. Additionally Faculties and Directorates may appoint local competent persons to implement their safety management system within their sphere of influence.

TRAINING The university will provide adequate and appropriate health and safety training for all its employees:

on being recruited



on being exposed to new or increased risks because of changes in responsibilities, work practice, new equipment or new policies and procedures This training will be repeated periodically to ensure continued competence. All staff must complete and pass the online fire safety training course and repeat at regular intervals.

Supporting evidence: H&SS (current version) SPR035, Training, instruction supervision

7.3 Awareness

Through our audit program and regular attendance at faculty/directorate safety or other management committees’ awareness of staff of the safety management system is gauged. A specific question is also included in staff survey.

Supporting evidence: staff survey

7.4 Information and Communication

INFORMATION Information to university staff The university provides its employees with information statutorily required and on risks to their health and safety identified by assessment and the risk control mechanisms used. Similar information is also provided, as appropriate, to visitors and contractors who may be affected by our undertaking. Sources of Information The university refers to organisations with regulatory or advisory duties to monitor health and safety, and provide guidance and information and assistance to ensure health and safety compliance such as:

Health and Safety Executive

Local Authority Health inspectors

Health Protection Agency (radiation Division)

London Fire Authority

Supporting evidence: provided by webpage and SharePoint (Health & Safety Services)

7.5 Documented Information

7.5.1 general

The university, through the H&SS office has designed a document control process.

Supporting evidence: H&SS(current version) SPR007, index to safety management system

7.5.2 Creating and updating

All documents will be assigned an issue date, document reference, change history and approval date.


7.5.3 Control of documented information

Only documents listed in H&SS central list, accessed and controlled only by H&SS, are deemed current safety management system documents.


8 Operation

8.1 Operational planning and control

8.1.1 General

The university manages its safety risks in line with current legislation.

Supporting evidence: SPR025 (current version) Safety Risk assessment

8.1.2 Hierarchy of controls

The university adopts the general principal of hierarchy of control following:

a) Eliminate the hazards b) Substitute with less hazardous options c) Use engineering controls

https://emckclac.sharepoint.com/teams/HSS/SitePages/Home.aspx



d) Use administrative controls e) Provide and ensure use of adequate personal protective equipment

Supporting evidence: SPR025 (current version) Safety Risk assessment

8.2 Management of change

The university assesses new products, work processes, and equipment brought into the university.

Supporting evidence: in progress

8.3 Outsourcing

Outsourced processes, e.g. occupational health provision, are integrated into our safety management system. Occupational health provision must be made available for all University staff. This service provision must include maintenance of our vaccinations program, health surveillance, where appropriate, and guidance on work related health problems.

Supporting evidence: SPR008 (current version) ) Safety responsibilities and arrangements in respect of the use and management of contractors

8.4 Procurement

The university follows Government procurement process.

Supporting evidence: under development

8.5 Contractors

The University has a duty to ensure the health and safety of contractors who may be affected by University activities. Likewise, contractors have a duty to ensure the safety of University staff, students and others who may be affected by their work on University premises. Those responsible for engaging contractors to undertake work on University premises must ensure that contractors are provided with comprehensive and understandable information on any health and safety risks arising from the University’s undertaking, including:

Emergency procedures

Site and local rules

Relevant information from risk assessments

Information about specific hazards, e.g. asbestos

Ensuring they are competent and comply with statutory requirements Contractors, too have obligations, and must inform the University of risks arising from their activities which adversely affect the health, safety and welfare of university staff and students.

Supporting evidence: SPR008 (current version) Safety responsibilities and arrangements in respect of the use and management of contractors

8.6 Emergency preparedness and response

The fire safety arrangements for the University are set out in the University’s Fire Safety

Responsibilities and Arrangements document, available on the University’s Health and Safety website. All staff and students must be aware of and adhere to the arrangements set out in that document and any other supporting University fire safety procedures.

All staff and students must ensure they cooperate with the fire safety requirements of the University to assist with maintaining a fire safe environment The need for first aid provision must be risk assessed in every University workplace, including shared premises with NHS Trust or other employers. Every university facility, including those shared with NHS trusts or other employers must have a “fire and emergency” procedures document to ensure the safety of staff and students in the event of foreseeable emergencies. In addition to risk from fire other incidents such as chemical, biological spillage, utility failure and flooding etc. should be covered. These procedures must be tested on a regular basis to ensure they are effective.

Supporting evidence: SPR036 (current version) Fire Risk Management Strategy



9. Performance Evaluation

9.1 Monitoring, measurement, analysis and Evaluation

9.1.1 General

In addition to the formal audit program (see 4.2 above) carried out by H&SS, Faculties Directorates shall undertake periodic monitoring of their health and safety arrangements and performance. This should be achieved by:

Reviews of risks assessments

Workplace inspections

Review of incident data and any work-related ill-health

An annual review and report on health and safety performance

Supporting evidence: SPR005(current version) auditing and measuring performance

9.1.2 Evaluation of compliance with legal requirements and other requirements

Forms part of the annual health and safety review.


9.2 Internal audits

9.2.1 Internal audit objectives

The university has adopted the Higher education sector audit process Hazard mapping and profiling (hasmap). All Faculties and Directorates of the University are subject to a formal, risk based, health and safety audit on a cyclical basis. Health & Safety Services are responsible for managing the audit program and will normally undertake the audits. The Health and Safety Management Group shall oversee and monitor the audit program.


9.2.2 Internal audit process

The internal audit process is published and regularly reviewed and communicated


9.3 Management review

The safety management system is reviewed annually, and an assessment made which is monitored and directed by the HSMG

Supporting evidence: Annual review report (current year)

10 Improvement

10.1 Incident, non-conformity and corrective actions

ACCIDENT REPORTING (INCLUDING CASES OF ILL-HEALTH) AND INVESTIGATION All accidents or near misses including incidents of work related ill-health, however minor, must be reported to the relevant line manager and recorded. This is achieved by using the University’s web-based accident and incident reporting system. All line managers must investigate reported incidents, to the relevant level, to establish root causes and introduce, where appropriate, management action to prevent recurrence. All notifiable incidents as defined by the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (as amended), must be reported to the local Health and Safety Executive (HSE) Office by the most appropriate route. AUTHORITY OF ACT (serious and imminent danger) The Director of Health & Safety Services and other designated competent persons of H&SS, empowered by the Principal, will take direct action to cease an activity, without prior reference to the relevant Manager, where a situation or condition presents a significant threat, or is believed to represent such a threat, to the health or safety of any individual, University building or property or if there is a serious breach of any statutory provision that may expose the University to enforcement action. When such action is taken, the relevant Manager shall be immediately notified of the “direct action”. The lifting of the direct action can only be done with agreement between H&SS and the manager.



DISCIPLINARY PROCEDURES Any member of the University (staff or student) who is found to be:

Deliberately misusing health and safety facilities; or

Flagrantly breaching the University health and safety policy or procedures (including fire safety); or

Flagrantly failing to observe any of the relevant statutory provisions (including fire safety)

may be subject to disciplinary action in accordance with the relevant University disciplinary procedure. They may also be personally liable under health and safety legislation and civil law. MONITORING AND REVIEW

In addition to the formal audit program (see 4.2 above) carried out by H&SS, Faculties Directorates shall undertake periodic monitoring of their health and safety arrangements and performance. This should be achieved by:

Reviews of risks assessments

Workplace inspections

Review of incident data and any work-related ill-health

An annual review and report on health and safety performance

WORKPLACE INSPECTIONS The university will monitor the safety system by:

Regular internal management inspections of the work area covering all university accommodation, including those shared with NHS Trust and other employers.

Supporting evidence:

SPR006 (current version) ACCIDENT REPORTING AND INVESTIGATION IN KING’S COLLEGE LONDON

SPR034 (current version) Responsibilities and arrangements in Respect of non-conformance,

corrective/improvement actions and escalation 10.2 Continual Improvement

10.2.1 Continual improvement Objectives

As part of the annual health and safety report, objectives shall be monitored

Supporting evidence: current health & safety annual report

10.2.2 Continual Improvement Process

As part of the annual health and safety report , objectives shall be monitored

Supporting evidence: current health & safety annual report



5. Document History

Revision Number

Date Amendment Author Approved by

01 24/10/2014 Complete rewrite from previous HSEPO policy statement (2013)

Anthony Scott HSMG

02 Oct 2015 Revision of 2014 policy statement. Changes highlighted

Anthony Scott HSMG

03 Feb 2017

Revision of 2015 policy statement. Complete rewrite aligning safety management system with OHSA18001 (ISO 45001) requirements

Anthony Scott HSMG

Signed

Professor Edward Byrne AC

Principal and President King’s College London HSMG approved 6th March 2017



Appendix A

Health and Safety Laws and Regulations The list below (not exhaustive) shows the main health and safety legislative framework within which the University operates: Health and Safety at Work etc. Act 1974 Management of Health and Safety at Work Regulations 1999 (as amended) Workplace (Health, Safety and Welfare) Regulations 1992 (as amended) Provision and Use of Work Equipment Regulations 1998 Personal Protective Equipment Regulations 1992 (as amended) Health and Safety (Display Screen Equipment) Regulations 1992(as amended in 2002) Manual Handling Operations Regulations 1992 (as amended) Control of Lead at Work Regulations 2002 Lifting Operations and Lifting Equipment Regulations 1998 Ionising Radiation Regulations 1999 Control of Substances Hazardous to Health Regulations 2002 (as amended) Confined Spaces Regulations 1997 Electricity at Work Regulations 1989 Control of Noise at Work Regulations 2005 Pressure System Regulations 2000 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (as amended) Dangerous Substances and Explosive Atmosphere Regulations 2002 Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 Carriage of Dangerous Goods and use of Transportable Pressure Equipment Regulations 2007 Regulatory Reform (Fire Safety) Order 2005 Genetically Modified Organisms (Continued use) Regulations 2000 Health and Safety (First Aid) Regulations 1981 Control of Asbestos at Work Regulations 2006 Construction (Design and Management) Regulations 2014 Health And Safety (Consultation with Employees) Regulations 1996 (as amended) Safety Representatives and Safety Committees Regulations 1977 (as amended) Registration Evaluation and Authorization of Chemicals Regulations 2007 Occupiers Liability Act 1957 Occupiers Liability Act 1984 Employer’s Liability (Compulsory Insurance) Act 1969 Working Time Regulations 1998

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