Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors...

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ISSN:1831-9343 Qualitative post-test evaluation of ESENER: National overview report Bulgaria European Risk Observatory European Agency for Safety and Health at Work

Transcript of Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors...

Page 1: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

ISSN1831-9343

Qualitative post-test evaluation of ESENER National overview report Bulgaria European Risk Observatory

European Agency for Safety and Health at Work

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Authors Jim Hillage Alice Sinclair Beth Foley Institute for Employment Studies

Carsten Bruumlck Reka Zayzon Katariina Roumlbbelen-Voigt Kooperationsstelle Hamburg IFE GmbH

Professor Katya Vangelova National Center of Public Health and Analysis (NCPHA) Bulgaria

Project Management William Cockburn (EU-OSHA)

More information on the European Union is available on the Internet (httpeuropaeu)

Cataloguing data can be found on the cover of this publication

Luxembourg Publications Office of the European Union

ISBN 978-92-9240-162-7

doi 10280269916

copy European Agency for Safety and Health at Work 2013

Europe Direct is a service to help you find answers to your questions about the European Union

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00 800 6 7 8 9 10 11 () Certain mobile telephone operators do not allow access to 00 800 numbers or these calls may be billed

European Agency for Safety and Health at Work ndash EU-OSHA 1

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Table of contents Introduction 3

1 Bulgaria National Overview Report 4

11 National context 4

Section 1 Structure of the Bulgarian Economy 4

Section 2 Human resources 5

Section 3 Overview of the public OSH infrastructure 6

Section 4 Overview of the OSH obligations for enterprises 8

Section 5 Approach to risk assessment 9

Section 6 Drivers for taking measures on OSH 10

Section 7 Level of concern at national level with OSH risks 11

Section 8 OSH training of employee representatives 12

Section 9 Worker involvement and participation in OSH 13

European Agency for Safety and Health at Work ndash EU-OSHA 2

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Introduction The Institute for Employment Studies (IES) in partnership with Kooperationsstelle Hamburg has been commissioned by the European Agency for Safety and Health at Work (EU-OSHA) to conduct a qualitative post-test of the European Survey of Enterprises on New and Emerging Risks (ESENER) The aim of the work is to build an in-depth understanding of results from the survey and to understand more about how OSH is managed at the workplace The work is intended to feed into the design and development of a new round of ESENER planned for 2014 and to further improve the quality of the survey instrument

This document presents the national overview reports for each of the five countries included in the research Bulgaria Finland Germany Italy and the UK Each national overview report draws on the interviews conducted with management and employee representatives in visited establishments In total cognitive interviews were conducted in 90 establishments (approximately 18 in each country) Each national overview report presents the country context in relation to OSH prior to discussing the technical issues with survey questions and their interpretations Overall findings from the research and recommendations will be included in the final report due at the end of May 2013

European Agency for Safety and Health at Work ndash EU-OSHA 3

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

1 Bulgaria National Overview Report 11 National context 111 Section 1 Structure of the Bulgarian Economy Bulgariarsquos economic and industrial relations development since the beginning of the 1990s has been characterised by two equally important and complex processes the transition to a market economy and the countryrsquos accession to the European Union in 2007 During the pre-accession harmonization process and in the first years of Bulgariarsquos membership of the EU Bulgaria experienced high levels of economic and employment growth and inward investment

Bulgariarsquos gross domestic product (GDP) for 2011 is estimated to be euro38482m with a growth of 17 per cent in comparison to 20101 Bulgariarsquos economy relies primarily on industry but the service sector increasingly contributes to GDP growth The strongest sectors are energy mining metallurgy machine building agriculture and tourism Data show that agriculture contributed 56 per cent of added value (a measure of economic activity equivalent to the value of produced goods and services minus the cost of producing them) in 2011 industry 311 per cent and services and construction combined 633 per cent In 2010 there were 353588 enterprises in the non-financial sector of the Bulgarian economy and their number had slightly decreased in comparison to 2009 Small and medium-sized enterprises (SMEs) dominate the Bulgarian economy Of all enterprises 988 per cent are SMEs Within this group 921 per cent are micro enterprises (employing nine or fewer employees) 65 per cent are small enterprises (employing 50 or fewer employees) and 12 per cent are medium-sized enterprises (employing between 50 and 249 employees) Large enterprises those with more than 249 employees represented 02 per cent of all enterprises2 The private sector has grown and recently generated 73 per cent of GDP

During the period 2003-2008 the Bulgarian economy experienced high levels of GDP growth reaching 62 per cent in 2008 according to Eurostat data In Bulgaria the economic crisis of the late 2000s started several months later than in other EU countries However in Autumn 2008 the first signs of the crisis were apparent and in 2009 the consequences of the crisis were visible in both the economic and social spheres The main noticeable effects of the crisis were a marked reversal in GDP growth to -55 per cent in 2009 However positive growth was restored in 2010 to 04 per cent and 17 per cent in 2011 Other effects of the crisis were a decrease in foreign investments and an increase in unemployment and the number of companies filing for bankruptcy in particular small and medium- sized enterprises The economic crisis of 2007-2010 had a negative impact mostly on industry with a ten per cent decline in the national industrial production index In particular there was a combined two-digit drop in output across machine-building metallurgy wood-processing chemical production textile and tailoring construction and real estate In 2011 a growth in industrial production of 58 per cent in comparison to 2010 was recorded with the best results achieved in the following industries 82 per cent growth for mining and quarrying 80 per cent growth for production and distribution of electric and thermal heat power and gaseous fuels and 52 per cent for the manufacturing industry1 In contrast to the industrial sector agriculture in Bulgaria has experienced a marked decline since the beginning of the 2000s with agricultural production in 2008 amounting to only 66 per cent of the level of production between 1999 and 2001 A five year modernisation and development programme was launched in 2007 but the decline of agricultural production continued and in 2011 it reached 974 per cent of the 2010 level Growth in the construction sector was recorded in the period 2007-2009 accounting for between 78 and 79 per cent of GDP but the crisis exerted a pronounced negative impact with a drop to 64 per cent of GDP in 2010 and further decline in 2011 reaching 871 per cent of the

1 Bulgaria 2011 Statistical panorama National Statistical Institute Republic of Bulgaria Available at httpwwwnsibgpublikaciaphpn=329ampr=|5|ampP=65ampSP=113ampPSP=5

2 Analysis of the Situation and actors for Development of SMEs in Bulgaria 2011-2012 Bulgarian Small and Medium Enterprises Promotion Agency Economic Recovery and Competitiveness prepared by NOEMA Sofia 2012 available at httpwwwsmegovernmentbguploads201107SME_Situation-REP_noemaENG-0612pdf

European Agency for Safety and Health at Work ndash EU-OSHA 4

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

production level in 2010 The decline was comprised of a seven per cent decline in the construction of buildings and a 20 per cent decline in infrastructure construction

Nevertheless Bulgaria continues to rank as the lowest-income member state of the EU with GDP per capita calculated to be euro 5168 Euros1 in 2011 45 per cent of the EU27 average (Eurostat)

112 Section 2 Human resources In recent decades there has been a steady decline in the size of the population The latest data from 2011 records a population of 7327224 (487 per cent male and 513 per cent female) The mean age of the Bulgarian population continues to increase and reached 427 years by 2011 Bulgaria has one of the most rapidly ageing populations in the EU due to negative natural growth and migration mainly of young people

In 2011 585 per cent of the population aged 15-64 were in employment This was 34 per cent below the rate in 2010 Men represented 521 per cent of those in employment in 2011 in comparison to 527 per cent in 2010 Women represented 479 per cent of those in employment in 2011 in comparison to 473 per cent in 2010 The share of women in employment has therefore risen slightly over this period Employment rates by gender are presented in Table 1 below The table shows that whilst the employment rate for both men and women has declined in the period 2008 to 2011 the relative decline for men has been much sharper leading to a narrowing of the difference in employment rates for men and women This is at least in part due to the greater impact of the economic crisis on male-dominated sectors Employers in the private sector provide a growing proportion of employment with private sector employment recently accounting for 75 per cent of employment Of the total labour force 75 per cent is employed in the agricultural sector 364 per cent in industry and 561 per cent in services and construction Employment by SMEs declined by 65 per cent between 2009 and 20102 In comparison the decline in employment observed over the same period for large enterprises was 21 per cent

Table 1 Rates of employment by gender in Bulgaria in the period 2008-2012 (Eurostat)

Rates of year 2008 2009 2010 2011

Employment ndash total () 707 688 654 639

Employment ndash men () 761 738 691 666

Employment ndash women () 654 640 617 612

The financial crisis of 2007-2010 had a marked impact on unemployment in the country With the first signs of an increase in unemployment rates the government adopted an anti-crisis plan based on three pillars preserving financial stability providing support to businesses and ensuring social protection for the countryrsquos population An anti-crisis council including the social partners and the prime minister was established in February 2009 to discuss on a monthly basis the state and measures related to the crisis

Table 2 Rates of unemployment and the proportion of unemployment by gender and age band in Bulgaria in the period 2008-2012 4

Rates of year 2008 2009 2010 2011

Unemployed 233 719 280 980 350 478 372 300

Rate of unemployment () 63 76 95 111

European Agency for Safety and Health at Work ndash EU-OSHA 5

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Rates of year 2008 2009 2010 2011

Proportion of men () 375 423 454 454

Proportion of women () 625 577 546 546

Proportion at age lt29 yrs 178 183 181 191

Proportion at age 30-49 yrs 426 437 443 448

Proportion at age gt50 yrs 396 380 376 361

Despite the measures introduced in response to the crisis the numbers of those unemployed increased and the unemployment rate increased each year from 63 per cent in 2008 to 111 per cent in 2011 (Table 2) The latest data of Eurostat from June 2012 show a further increase in the unemployment rate in the country to 124 per cent with higher unemployment rates for both men (139) and women (107) Table 2 shows that by 2011 whilst the greater share of unemployment was borne by women the proportion of the unemployed who are women has declined over the period 2008-2011 Comparatively the proportion of the unemployed who are men has increased over the same period In 2011 562 per cent of the unemployed had been unemployed for more than one year A high level of youth unemployment is also an issue with 266 per cent of those under 29 years of age registered as unemployed The Government has instituted a programme to support youth employment alongside other measures aimed at supporting employment

The share of informal employment remains high mainly in micro and small enterprises Nearly 90 per cent of the employees in small and medium enterprises are working in traditional forms of employment under a labour and civil contract but the remaining 11 per cent define their relationship with the employer as lsquoanother typersquo including informal employment3 Moving to a new geographical location in order to find or take up a job is more common amongst young people 83 per cent of young people have changed their jobs within the past year

Part-time work and shift work are the most popular forms of flexible employment during the crisis whilst working at home or flexible working time is rare4 Employers from small and medium- sized enterprises demonstrate a high level of awareness of and positive attitudes towards non-standard forms of work 90 per cent say that they know of and approve flexible forms of employment such as part-time work and flexible working hours However flexible forms of employment are only practiced in a small share of Bulgarian companies

113 Section 3 Overview of the public OSH infrastructure The Occupational Health and Safety Act 1997 laid the foundation for changes in the structure of the occupational health and safety system in the country The Act defines the main responsibilities for safety and health at work The Ministry of Labour and Social Policy (MLSP) and the Ministry of Health (MH) are jointly responsible for

Developing coordinating and implementing policy in the field of safety and health at work Analysing the conditions trends and problems in health and safety at work and proposing

measures for its improvement Harmonisation of national legislation with EU legislation

3 Beleva I and Tzanov V Decent Work Country Report ndash Bulgaria International Labour Office Regional Office for Europe and Central Asia February 2008 available online at httpwwwiloorgpublicenglishregioneurprogenevadownloadeventslisbon2009dwreportsdw_bulgariapdf

4 Violeta Zlateva SMEs in the crisis Employment Industrial Relations and Local Partnership Institute for Social and Trade Union Research EIRO ID BG1010031Q Publication date 15-06-2011 available at httpwwweurofoundeuropaeueirostudies

European Agency for Safety and Health at Work ndash EU-OSHA 6

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 2: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Authors Jim Hillage Alice Sinclair Beth Foley Institute for Employment Studies

Carsten Bruumlck Reka Zayzon Katariina Roumlbbelen-Voigt Kooperationsstelle Hamburg IFE GmbH

Professor Katya Vangelova National Center of Public Health and Analysis (NCPHA) Bulgaria

Project Management William Cockburn (EU-OSHA)

More information on the European Union is available on the Internet (httpeuropaeu)

Cataloguing data can be found on the cover of this publication

Luxembourg Publications Office of the European Union

ISBN 978-92-9240-162-7

doi 10280269916

copy European Agency for Safety and Health at Work 2013

Europe Direct is a service to help you find answers to your questions about the European Union

Freephone number ()

00 800 6 7 8 9 10 11 () Certain mobile telephone operators do not allow access to 00 800 numbers or these calls may be billed

European Agency for Safety and Health at Work ndash EU-OSHA 1

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Table of contents Introduction 3

1 Bulgaria National Overview Report 4

11 National context 4

Section 1 Structure of the Bulgarian Economy 4

Section 2 Human resources 5

Section 3 Overview of the public OSH infrastructure 6

Section 4 Overview of the OSH obligations for enterprises 8

Section 5 Approach to risk assessment 9

Section 6 Drivers for taking measures on OSH 10

Section 7 Level of concern at national level with OSH risks 11

Section 8 OSH training of employee representatives 12

Section 9 Worker involvement and participation in OSH 13

European Agency for Safety and Health at Work ndash EU-OSHA 2

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Introduction The Institute for Employment Studies (IES) in partnership with Kooperationsstelle Hamburg has been commissioned by the European Agency for Safety and Health at Work (EU-OSHA) to conduct a qualitative post-test of the European Survey of Enterprises on New and Emerging Risks (ESENER) The aim of the work is to build an in-depth understanding of results from the survey and to understand more about how OSH is managed at the workplace The work is intended to feed into the design and development of a new round of ESENER planned for 2014 and to further improve the quality of the survey instrument

This document presents the national overview reports for each of the five countries included in the research Bulgaria Finland Germany Italy and the UK Each national overview report draws on the interviews conducted with management and employee representatives in visited establishments In total cognitive interviews were conducted in 90 establishments (approximately 18 in each country) Each national overview report presents the country context in relation to OSH prior to discussing the technical issues with survey questions and their interpretations Overall findings from the research and recommendations will be included in the final report due at the end of May 2013

European Agency for Safety and Health at Work ndash EU-OSHA 3

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

1 Bulgaria National Overview Report 11 National context 111 Section 1 Structure of the Bulgarian Economy Bulgariarsquos economic and industrial relations development since the beginning of the 1990s has been characterised by two equally important and complex processes the transition to a market economy and the countryrsquos accession to the European Union in 2007 During the pre-accession harmonization process and in the first years of Bulgariarsquos membership of the EU Bulgaria experienced high levels of economic and employment growth and inward investment

Bulgariarsquos gross domestic product (GDP) for 2011 is estimated to be euro38482m with a growth of 17 per cent in comparison to 20101 Bulgariarsquos economy relies primarily on industry but the service sector increasingly contributes to GDP growth The strongest sectors are energy mining metallurgy machine building agriculture and tourism Data show that agriculture contributed 56 per cent of added value (a measure of economic activity equivalent to the value of produced goods and services minus the cost of producing them) in 2011 industry 311 per cent and services and construction combined 633 per cent In 2010 there were 353588 enterprises in the non-financial sector of the Bulgarian economy and their number had slightly decreased in comparison to 2009 Small and medium-sized enterprises (SMEs) dominate the Bulgarian economy Of all enterprises 988 per cent are SMEs Within this group 921 per cent are micro enterprises (employing nine or fewer employees) 65 per cent are small enterprises (employing 50 or fewer employees) and 12 per cent are medium-sized enterprises (employing between 50 and 249 employees) Large enterprises those with more than 249 employees represented 02 per cent of all enterprises2 The private sector has grown and recently generated 73 per cent of GDP

During the period 2003-2008 the Bulgarian economy experienced high levels of GDP growth reaching 62 per cent in 2008 according to Eurostat data In Bulgaria the economic crisis of the late 2000s started several months later than in other EU countries However in Autumn 2008 the first signs of the crisis were apparent and in 2009 the consequences of the crisis were visible in both the economic and social spheres The main noticeable effects of the crisis were a marked reversal in GDP growth to -55 per cent in 2009 However positive growth was restored in 2010 to 04 per cent and 17 per cent in 2011 Other effects of the crisis were a decrease in foreign investments and an increase in unemployment and the number of companies filing for bankruptcy in particular small and medium- sized enterprises The economic crisis of 2007-2010 had a negative impact mostly on industry with a ten per cent decline in the national industrial production index In particular there was a combined two-digit drop in output across machine-building metallurgy wood-processing chemical production textile and tailoring construction and real estate In 2011 a growth in industrial production of 58 per cent in comparison to 2010 was recorded with the best results achieved in the following industries 82 per cent growth for mining and quarrying 80 per cent growth for production and distribution of electric and thermal heat power and gaseous fuels and 52 per cent for the manufacturing industry1 In contrast to the industrial sector agriculture in Bulgaria has experienced a marked decline since the beginning of the 2000s with agricultural production in 2008 amounting to only 66 per cent of the level of production between 1999 and 2001 A five year modernisation and development programme was launched in 2007 but the decline of agricultural production continued and in 2011 it reached 974 per cent of the 2010 level Growth in the construction sector was recorded in the period 2007-2009 accounting for between 78 and 79 per cent of GDP but the crisis exerted a pronounced negative impact with a drop to 64 per cent of GDP in 2010 and further decline in 2011 reaching 871 per cent of the

1 Bulgaria 2011 Statistical panorama National Statistical Institute Republic of Bulgaria Available at httpwwwnsibgpublikaciaphpn=329ampr=|5|ampP=65ampSP=113ampPSP=5

2 Analysis of the Situation and actors for Development of SMEs in Bulgaria 2011-2012 Bulgarian Small and Medium Enterprises Promotion Agency Economic Recovery and Competitiveness prepared by NOEMA Sofia 2012 available at httpwwwsmegovernmentbguploads201107SME_Situation-REP_noemaENG-0612pdf

European Agency for Safety and Health at Work ndash EU-OSHA 4

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

production level in 2010 The decline was comprised of a seven per cent decline in the construction of buildings and a 20 per cent decline in infrastructure construction

Nevertheless Bulgaria continues to rank as the lowest-income member state of the EU with GDP per capita calculated to be euro 5168 Euros1 in 2011 45 per cent of the EU27 average (Eurostat)

112 Section 2 Human resources In recent decades there has been a steady decline in the size of the population The latest data from 2011 records a population of 7327224 (487 per cent male and 513 per cent female) The mean age of the Bulgarian population continues to increase and reached 427 years by 2011 Bulgaria has one of the most rapidly ageing populations in the EU due to negative natural growth and migration mainly of young people

In 2011 585 per cent of the population aged 15-64 were in employment This was 34 per cent below the rate in 2010 Men represented 521 per cent of those in employment in 2011 in comparison to 527 per cent in 2010 Women represented 479 per cent of those in employment in 2011 in comparison to 473 per cent in 2010 The share of women in employment has therefore risen slightly over this period Employment rates by gender are presented in Table 1 below The table shows that whilst the employment rate for both men and women has declined in the period 2008 to 2011 the relative decline for men has been much sharper leading to a narrowing of the difference in employment rates for men and women This is at least in part due to the greater impact of the economic crisis on male-dominated sectors Employers in the private sector provide a growing proportion of employment with private sector employment recently accounting for 75 per cent of employment Of the total labour force 75 per cent is employed in the agricultural sector 364 per cent in industry and 561 per cent in services and construction Employment by SMEs declined by 65 per cent between 2009 and 20102 In comparison the decline in employment observed over the same period for large enterprises was 21 per cent

Table 1 Rates of employment by gender in Bulgaria in the period 2008-2012 (Eurostat)

Rates of year 2008 2009 2010 2011

Employment ndash total () 707 688 654 639

Employment ndash men () 761 738 691 666

Employment ndash women () 654 640 617 612

The financial crisis of 2007-2010 had a marked impact on unemployment in the country With the first signs of an increase in unemployment rates the government adopted an anti-crisis plan based on three pillars preserving financial stability providing support to businesses and ensuring social protection for the countryrsquos population An anti-crisis council including the social partners and the prime minister was established in February 2009 to discuss on a monthly basis the state and measures related to the crisis

Table 2 Rates of unemployment and the proportion of unemployment by gender and age band in Bulgaria in the period 2008-2012 4

Rates of year 2008 2009 2010 2011

Unemployed 233 719 280 980 350 478 372 300

Rate of unemployment () 63 76 95 111

European Agency for Safety and Health at Work ndash EU-OSHA 5

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Rates of year 2008 2009 2010 2011

Proportion of men () 375 423 454 454

Proportion of women () 625 577 546 546

Proportion at age lt29 yrs 178 183 181 191

Proportion at age 30-49 yrs 426 437 443 448

Proportion at age gt50 yrs 396 380 376 361

Despite the measures introduced in response to the crisis the numbers of those unemployed increased and the unemployment rate increased each year from 63 per cent in 2008 to 111 per cent in 2011 (Table 2) The latest data of Eurostat from June 2012 show a further increase in the unemployment rate in the country to 124 per cent with higher unemployment rates for both men (139) and women (107) Table 2 shows that by 2011 whilst the greater share of unemployment was borne by women the proportion of the unemployed who are women has declined over the period 2008-2011 Comparatively the proportion of the unemployed who are men has increased over the same period In 2011 562 per cent of the unemployed had been unemployed for more than one year A high level of youth unemployment is also an issue with 266 per cent of those under 29 years of age registered as unemployed The Government has instituted a programme to support youth employment alongside other measures aimed at supporting employment

The share of informal employment remains high mainly in micro and small enterprises Nearly 90 per cent of the employees in small and medium enterprises are working in traditional forms of employment under a labour and civil contract but the remaining 11 per cent define their relationship with the employer as lsquoanother typersquo including informal employment3 Moving to a new geographical location in order to find or take up a job is more common amongst young people 83 per cent of young people have changed their jobs within the past year

Part-time work and shift work are the most popular forms of flexible employment during the crisis whilst working at home or flexible working time is rare4 Employers from small and medium- sized enterprises demonstrate a high level of awareness of and positive attitudes towards non-standard forms of work 90 per cent say that they know of and approve flexible forms of employment such as part-time work and flexible working hours However flexible forms of employment are only practiced in a small share of Bulgarian companies

113 Section 3 Overview of the public OSH infrastructure The Occupational Health and Safety Act 1997 laid the foundation for changes in the structure of the occupational health and safety system in the country The Act defines the main responsibilities for safety and health at work The Ministry of Labour and Social Policy (MLSP) and the Ministry of Health (MH) are jointly responsible for

Developing coordinating and implementing policy in the field of safety and health at work Analysing the conditions trends and problems in health and safety at work and proposing

measures for its improvement Harmonisation of national legislation with EU legislation

3 Beleva I and Tzanov V Decent Work Country Report ndash Bulgaria International Labour Office Regional Office for Europe and Central Asia February 2008 available online at httpwwwiloorgpublicenglishregioneurprogenevadownloadeventslisbon2009dwreportsdw_bulgariapdf

4 Violeta Zlateva SMEs in the crisis Employment Industrial Relations and Local Partnership Institute for Social and Trade Union Research EIRO ID BG1010031Q Publication date 15-06-2011 available at httpwwweurofoundeuropaeueirostudies

European Agency for Safety and Health at Work ndash EU-OSHA 6

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

European Agency for Safety and Health at Work ndash EU-OSHA 12

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

European Agency for Safety and Health at Work ndash EU-OSHA 13

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

European Agency for Safety and Health at Work ndash EU-OSHA 14

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

European Agency for Safety and Health at Work ndash EU-OSHA 15

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

European Agency for Safety and Health at Work ndash EU-OSHA 16

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

European Agency for Safety and Health at Work ndash EU-OSHA 17

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 3: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Table of contents Introduction 3

1 Bulgaria National Overview Report 4

11 National context 4

Section 1 Structure of the Bulgarian Economy 4

Section 2 Human resources 5

Section 3 Overview of the public OSH infrastructure 6

Section 4 Overview of the OSH obligations for enterprises 8

Section 5 Approach to risk assessment 9

Section 6 Drivers for taking measures on OSH 10

Section 7 Level of concern at national level with OSH risks 11

Section 8 OSH training of employee representatives 12

Section 9 Worker involvement and participation in OSH 13

European Agency for Safety and Health at Work ndash EU-OSHA 2

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Introduction The Institute for Employment Studies (IES) in partnership with Kooperationsstelle Hamburg has been commissioned by the European Agency for Safety and Health at Work (EU-OSHA) to conduct a qualitative post-test of the European Survey of Enterprises on New and Emerging Risks (ESENER) The aim of the work is to build an in-depth understanding of results from the survey and to understand more about how OSH is managed at the workplace The work is intended to feed into the design and development of a new round of ESENER planned for 2014 and to further improve the quality of the survey instrument

This document presents the national overview reports for each of the five countries included in the research Bulgaria Finland Germany Italy and the UK Each national overview report draws on the interviews conducted with management and employee representatives in visited establishments In total cognitive interviews were conducted in 90 establishments (approximately 18 in each country) Each national overview report presents the country context in relation to OSH prior to discussing the technical issues with survey questions and their interpretations Overall findings from the research and recommendations will be included in the final report due at the end of May 2013

European Agency for Safety and Health at Work ndash EU-OSHA 3

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

1 Bulgaria National Overview Report 11 National context 111 Section 1 Structure of the Bulgarian Economy Bulgariarsquos economic and industrial relations development since the beginning of the 1990s has been characterised by two equally important and complex processes the transition to a market economy and the countryrsquos accession to the European Union in 2007 During the pre-accession harmonization process and in the first years of Bulgariarsquos membership of the EU Bulgaria experienced high levels of economic and employment growth and inward investment

Bulgariarsquos gross domestic product (GDP) for 2011 is estimated to be euro38482m with a growth of 17 per cent in comparison to 20101 Bulgariarsquos economy relies primarily on industry but the service sector increasingly contributes to GDP growth The strongest sectors are energy mining metallurgy machine building agriculture and tourism Data show that agriculture contributed 56 per cent of added value (a measure of economic activity equivalent to the value of produced goods and services minus the cost of producing them) in 2011 industry 311 per cent and services and construction combined 633 per cent In 2010 there were 353588 enterprises in the non-financial sector of the Bulgarian economy and their number had slightly decreased in comparison to 2009 Small and medium-sized enterprises (SMEs) dominate the Bulgarian economy Of all enterprises 988 per cent are SMEs Within this group 921 per cent are micro enterprises (employing nine or fewer employees) 65 per cent are small enterprises (employing 50 or fewer employees) and 12 per cent are medium-sized enterprises (employing between 50 and 249 employees) Large enterprises those with more than 249 employees represented 02 per cent of all enterprises2 The private sector has grown and recently generated 73 per cent of GDP

During the period 2003-2008 the Bulgarian economy experienced high levels of GDP growth reaching 62 per cent in 2008 according to Eurostat data In Bulgaria the economic crisis of the late 2000s started several months later than in other EU countries However in Autumn 2008 the first signs of the crisis were apparent and in 2009 the consequences of the crisis were visible in both the economic and social spheres The main noticeable effects of the crisis were a marked reversal in GDP growth to -55 per cent in 2009 However positive growth was restored in 2010 to 04 per cent and 17 per cent in 2011 Other effects of the crisis were a decrease in foreign investments and an increase in unemployment and the number of companies filing for bankruptcy in particular small and medium- sized enterprises The economic crisis of 2007-2010 had a negative impact mostly on industry with a ten per cent decline in the national industrial production index In particular there was a combined two-digit drop in output across machine-building metallurgy wood-processing chemical production textile and tailoring construction and real estate In 2011 a growth in industrial production of 58 per cent in comparison to 2010 was recorded with the best results achieved in the following industries 82 per cent growth for mining and quarrying 80 per cent growth for production and distribution of electric and thermal heat power and gaseous fuels and 52 per cent for the manufacturing industry1 In contrast to the industrial sector agriculture in Bulgaria has experienced a marked decline since the beginning of the 2000s with agricultural production in 2008 amounting to only 66 per cent of the level of production between 1999 and 2001 A five year modernisation and development programme was launched in 2007 but the decline of agricultural production continued and in 2011 it reached 974 per cent of the 2010 level Growth in the construction sector was recorded in the period 2007-2009 accounting for between 78 and 79 per cent of GDP but the crisis exerted a pronounced negative impact with a drop to 64 per cent of GDP in 2010 and further decline in 2011 reaching 871 per cent of the

1 Bulgaria 2011 Statistical panorama National Statistical Institute Republic of Bulgaria Available at httpwwwnsibgpublikaciaphpn=329ampr=|5|ampP=65ampSP=113ampPSP=5

2 Analysis of the Situation and actors for Development of SMEs in Bulgaria 2011-2012 Bulgarian Small and Medium Enterprises Promotion Agency Economic Recovery and Competitiveness prepared by NOEMA Sofia 2012 available at httpwwwsmegovernmentbguploads201107SME_Situation-REP_noemaENG-0612pdf

European Agency for Safety and Health at Work ndash EU-OSHA 4

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

production level in 2010 The decline was comprised of a seven per cent decline in the construction of buildings and a 20 per cent decline in infrastructure construction

Nevertheless Bulgaria continues to rank as the lowest-income member state of the EU with GDP per capita calculated to be euro 5168 Euros1 in 2011 45 per cent of the EU27 average (Eurostat)

112 Section 2 Human resources In recent decades there has been a steady decline in the size of the population The latest data from 2011 records a population of 7327224 (487 per cent male and 513 per cent female) The mean age of the Bulgarian population continues to increase and reached 427 years by 2011 Bulgaria has one of the most rapidly ageing populations in the EU due to negative natural growth and migration mainly of young people

In 2011 585 per cent of the population aged 15-64 were in employment This was 34 per cent below the rate in 2010 Men represented 521 per cent of those in employment in 2011 in comparison to 527 per cent in 2010 Women represented 479 per cent of those in employment in 2011 in comparison to 473 per cent in 2010 The share of women in employment has therefore risen slightly over this period Employment rates by gender are presented in Table 1 below The table shows that whilst the employment rate for both men and women has declined in the period 2008 to 2011 the relative decline for men has been much sharper leading to a narrowing of the difference in employment rates for men and women This is at least in part due to the greater impact of the economic crisis on male-dominated sectors Employers in the private sector provide a growing proportion of employment with private sector employment recently accounting for 75 per cent of employment Of the total labour force 75 per cent is employed in the agricultural sector 364 per cent in industry and 561 per cent in services and construction Employment by SMEs declined by 65 per cent between 2009 and 20102 In comparison the decline in employment observed over the same period for large enterprises was 21 per cent

Table 1 Rates of employment by gender in Bulgaria in the period 2008-2012 (Eurostat)

Rates of year 2008 2009 2010 2011

Employment ndash total () 707 688 654 639

Employment ndash men () 761 738 691 666

Employment ndash women () 654 640 617 612

The financial crisis of 2007-2010 had a marked impact on unemployment in the country With the first signs of an increase in unemployment rates the government adopted an anti-crisis plan based on three pillars preserving financial stability providing support to businesses and ensuring social protection for the countryrsquos population An anti-crisis council including the social partners and the prime minister was established in February 2009 to discuss on a monthly basis the state and measures related to the crisis

Table 2 Rates of unemployment and the proportion of unemployment by gender and age band in Bulgaria in the period 2008-2012 4

Rates of year 2008 2009 2010 2011

Unemployed 233 719 280 980 350 478 372 300

Rate of unemployment () 63 76 95 111

European Agency for Safety and Health at Work ndash EU-OSHA 5

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Rates of year 2008 2009 2010 2011

Proportion of men () 375 423 454 454

Proportion of women () 625 577 546 546

Proportion at age lt29 yrs 178 183 181 191

Proportion at age 30-49 yrs 426 437 443 448

Proportion at age gt50 yrs 396 380 376 361

Despite the measures introduced in response to the crisis the numbers of those unemployed increased and the unemployment rate increased each year from 63 per cent in 2008 to 111 per cent in 2011 (Table 2) The latest data of Eurostat from June 2012 show a further increase in the unemployment rate in the country to 124 per cent with higher unemployment rates for both men (139) and women (107) Table 2 shows that by 2011 whilst the greater share of unemployment was borne by women the proportion of the unemployed who are women has declined over the period 2008-2011 Comparatively the proportion of the unemployed who are men has increased over the same period In 2011 562 per cent of the unemployed had been unemployed for more than one year A high level of youth unemployment is also an issue with 266 per cent of those under 29 years of age registered as unemployed The Government has instituted a programme to support youth employment alongside other measures aimed at supporting employment

The share of informal employment remains high mainly in micro and small enterprises Nearly 90 per cent of the employees in small and medium enterprises are working in traditional forms of employment under a labour and civil contract but the remaining 11 per cent define their relationship with the employer as lsquoanother typersquo including informal employment3 Moving to a new geographical location in order to find or take up a job is more common amongst young people 83 per cent of young people have changed their jobs within the past year

Part-time work and shift work are the most popular forms of flexible employment during the crisis whilst working at home or flexible working time is rare4 Employers from small and medium- sized enterprises demonstrate a high level of awareness of and positive attitudes towards non-standard forms of work 90 per cent say that they know of and approve flexible forms of employment such as part-time work and flexible working hours However flexible forms of employment are only practiced in a small share of Bulgarian companies

113 Section 3 Overview of the public OSH infrastructure The Occupational Health and Safety Act 1997 laid the foundation for changes in the structure of the occupational health and safety system in the country The Act defines the main responsibilities for safety and health at work The Ministry of Labour and Social Policy (MLSP) and the Ministry of Health (MH) are jointly responsible for

Developing coordinating and implementing policy in the field of safety and health at work Analysing the conditions trends and problems in health and safety at work and proposing

measures for its improvement Harmonisation of national legislation with EU legislation

3 Beleva I and Tzanov V Decent Work Country Report ndash Bulgaria International Labour Office Regional Office for Europe and Central Asia February 2008 available online at httpwwwiloorgpublicenglishregioneurprogenevadownloadeventslisbon2009dwreportsdw_bulgariapdf

4 Violeta Zlateva SMEs in the crisis Employment Industrial Relations and Local Partnership Institute for Social and Trade Union Research EIRO ID BG1010031Q Publication date 15-06-2011 available at httpwwweurofoundeuropaeueirostudies

European Agency for Safety and Health at Work ndash EU-OSHA 6

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

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119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 4: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Introduction The Institute for Employment Studies (IES) in partnership with Kooperationsstelle Hamburg has been commissioned by the European Agency for Safety and Health at Work (EU-OSHA) to conduct a qualitative post-test of the European Survey of Enterprises on New and Emerging Risks (ESENER) The aim of the work is to build an in-depth understanding of results from the survey and to understand more about how OSH is managed at the workplace The work is intended to feed into the design and development of a new round of ESENER planned for 2014 and to further improve the quality of the survey instrument

This document presents the national overview reports for each of the five countries included in the research Bulgaria Finland Germany Italy and the UK Each national overview report draws on the interviews conducted with management and employee representatives in visited establishments In total cognitive interviews were conducted in 90 establishments (approximately 18 in each country) Each national overview report presents the country context in relation to OSH prior to discussing the technical issues with survey questions and their interpretations Overall findings from the research and recommendations will be included in the final report due at the end of May 2013

European Agency for Safety and Health at Work ndash EU-OSHA 3

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

1 Bulgaria National Overview Report 11 National context 111 Section 1 Structure of the Bulgarian Economy Bulgariarsquos economic and industrial relations development since the beginning of the 1990s has been characterised by two equally important and complex processes the transition to a market economy and the countryrsquos accession to the European Union in 2007 During the pre-accession harmonization process and in the first years of Bulgariarsquos membership of the EU Bulgaria experienced high levels of economic and employment growth and inward investment

Bulgariarsquos gross domestic product (GDP) for 2011 is estimated to be euro38482m with a growth of 17 per cent in comparison to 20101 Bulgariarsquos economy relies primarily on industry but the service sector increasingly contributes to GDP growth The strongest sectors are energy mining metallurgy machine building agriculture and tourism Data show that agriculture contributed 56 per cent of added value (a measure of economic activity equivalent to the value of produced goods and services minus the cost of producing them) in 2011 industry 311 per cent and services and construction combined 633 per cent In 2010 there were 353588 enterprises in the non-financial sector of the Bulgarian economy and their number had slightly decreased in comparison to 2009 Small and medium-sized enterprises (SMEs) dominate the Bulgarian economy Of all enterprises 988 per cent are SMEs Within this group 921 per cent are micro enterprises (employing nine or fewer employees) 65 per cent are small enterprises (employing 50 or fewer employees) and 12 per cent are medium-sized enterprises (employing between 50 and 249 employees) Large enterprises those with more than 249 employees represented 02 per cent of all enterprises2 The private sector has grown and recently generated 73 per cent of GDP

During the period 2003-2008 the Bulgarian economy experienced high levels of GDP growth reaching 62 per cent in 2008 according to Eurostat data In Bulgaria the economic crisis of the late 2000s started several months later than in other EU countries However in Autumn 2008 the first signs of the crisis were apparent and in 2009 the consequences of the crisis were visible in both the economic and social spheres The main noticeable effects of the crisis were a marked reversal in GDP growth to -55 per cent in 2009 However positive growth was restored in 2010 to 04 per cent and 17 per cent in 2011 Other effects of the crisis were a decrease in foreign investments and an increase in unemployment and the number of companies filing for bankruptcy in particular small and medium- sized enterprises The economic crisis of 2007-2010 had a negative impact mostly on industry with a ten per cent decline in the national industrial production index In particular there was a combined two-digit drop in output across machine-building metallurgy wood-processing chemical production textile and tailoring construction and real estate In 2011 a growth in industrial production of 58 per cent in comparison to 2010 was recorded with the best results achieved in the following industries 82 per cent growth for mining and quarrying 80 per cent growth for production and distribution of electric and thermal heat power and gaseous fuels and 52 per cent for the manufacturing industry1 In contrast to the industrial sector agriculture in Bulgaria has experienced a marked decline since the beginning of the 2000s with agricultural production in 2008 amounting to only 66 per cent of the level of production between 1999 and 2001 A five year modernisation and development programme was launched in 2007 but the decline of agricultural production continued and in 2011 it reached 974 per cent of the 2010 level Growth in the construction sector was recorded in the period 2007-2009 accounting for between 78 and 79 per cent of GDP but the crisis exerted a pronounced negative impact with a drop to 64 per cent of GDP in 2010 and further decline in 2011 reaching 871 per cent of the

1 Bulgaria 2011 Statistical panorama National Statistical Institute Republic of Bulgaria Available at httpwwwnsibgpublikaciaphpn=329ampr=|5|ampP=65ampSP=113ampPSP=5

2 Analysis of the Situation and actors for Development of SMEs in Bulgaria 2011-2012 Bulgarian Small and Medium Enterprises Promotion Agency Economic Recovery and Competitiveness prepared by NOEMA Sofia 2012 available at httpwwwsmegovernmentbguploads201107SME_Situation-REP_noemaENG-0612pdf

European Agency for Safety and Health at Work ndash EU-OSHA 4

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

production level in 2010 The decline was comprised of a seven per cent decline in the construction of buildings and a 20 per cent decline in infrastructure construction

Nevertheless Bulgaria continues to rank as the lowest-income member state of the EU with GDP per capita calculated to be euro 5168 Euros1 in 2011 45 per cent of the EU27 average (Eurostat)

112 Section 2 Human resources In recent decades there has been a steady decline in the size of the population The latest data from 2011 records a population of 7327224 (487 per cent male and 513 per cent female) The mean age of the Bulgarian population continues to increase and reached 427 years by 2011 Bulgaria has one of the most rapidly ageing populations in the EU due to negative natural growth and migration mainly of young people

In 2011 585 per cent of the population aged 15-64 were in employment This was 34 per cent below the rate in 2010 Men represented 521 per cent of those in employment in 2011 in comparison to 527 per cent in 2010 Women represented 479 per cent of those in employment in 2011 in comparison to 473 per cent in 2010 The share of women in employment has therefore risen slightly over this period Employment rates by gender are presented in Table 1 below The table shows that whilst the employment rate for both men and women has declined in the period 2008 to 2011 the relative decline for men has been much sharper leading to a narrowing of the difference in employment rates for men and women This is at least in part due to the greater impact of the economic crisis on male-dominated sectors Employers in the private sector provide a growing proportion of employment with private sector employment recently accounting for 75 per cent of employment Of the total labour force 75 per cent is employed in the agricultural sector 364 per cent in industry and 561 per cent in services and construction Employment by SMEs declined by 65 per cent between 2009 and 20102 In comparison the decline in employment observed over the same period for large enterprises was 21 per cent

Table 1 Rates of employment by gender in Bulgaria in the period 2008-2012 (Eurostat)

Rates of year 2008 2009 2010 2011

Employment ndash total () 707 688 654 639

Employment ndash men () 761 738 691 666

Employment ndash women () 654 640 617 612

The financial crisis of 2007-2010 had a marked impact on unemployment in the country With the first signs of an increase in unemployment rates the government adopted an anti-crisis plan based on three pillars preserving financial stability providing support to businesses and ensuring social protection for the countryrsquos population An anti-crisis council including the social partners and the prime minister was established in February 2009 to discuss on a monthly basis the state and measures related to the crisis

Table 2 Rates of unemployment and the proportion of unemployment by gender and age band in Bulgaria in the period 2008-2012 4

Rates of year 2008 2009 2010 2011

Unemployed 233 719 280 980 350 478 372 300

Rate of unemployment () 63 76 95 111

European Agency for Safety and Health at Work ndash EU-OSHA 5

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Rates of year 2008 2009 2010 2011

Proportion of men () 375 423 454 454

Proportion of women () 625 577 546 546

Proportion at age lt29 yrs 178 183 181 191

Proportion at age 30-49 yrs 426 437 443 448

Proportion at age gt50 yrs 396 380 376 361

Despite the measures introduced in response to the crisis the numbers of those unemployed increased and the unemployment rate increased each year from 63 per cent in 2008 to 111 per cent in 2011 (Table 2) The latest data of Eurostat from June 2012 show a further increase in the unemployment rate in the country to 124 per cent with higher unemployment rates for both men (139) and women (107) Table 2 shows that by 2011 whilst the greater share of unemployment was borne by women the proportion of the unemployed who are women has declined over the period 2008-2011 Comparatively the proportion of the unemployed who are men has increased over the same period In 2011 562 per cent of the unemployed had been unemployed for more than one year A high level of youth unemployment is also an issue with 266 per cent of those under 29 years of age registered as unemployed The Government has instituted a programme to support youth employment alongside other measures aimed at supporting employment

The share of informal employment remains high mainly in micro and small enterprises Nearly 90 per cent of the employees in small and medium enterprises are working in traditional forms of employment under a labour and civil contract but the remaining 11 per cent define their relationship with the employer as lsquoanother typersquo including informal employment3 Moving to a new geographical location in order to find or take up a job is more common amongst young people 83 per cent of young people have changed their jobs within the past year

Part-time work and shift work are the most popular forms of flexible employment during the crisis whilst working at home or flexible working time is rare4 Employers from small and medium- sized enterprises demonstrate a high level of awareness of and positive attitudes towards non-standard forms of work 90 per cent say that they know of and approve flexible forms of employment such as part-time work and flexible working hours However flexible forms of employment are only practiced in a small share of Bulgarian companies

113 Section 3 Overview of the public OSH infrastructure The Occupational Health and Safety Act 1997 laid the foundation for changes in the structure of the occupational health and safety system in the country The Act defines the main responsibilities for safety and health at work The Ministry of Labour and Social Policy (MLSP) and the Ministry of Health (MH) are jointly responsible for

Developing coordinating and implementing policy in the field of safety and health at work Analysing the conditions trends and problems in health and safety at work and proposing

measures for its improvement Harmonisation of national legislation with EU legislation

3 Beleva I and Tzanov V Decent Work Country Report ndash Bulgaria International Labour Office Regional Office for Europe and Central Asia February 2008 available online at httpwwwiloorgpublicenglishregioneurprogenevadownloadeventslisbon2009dwreportsdw_bulgariapdf

4 Violeta Zlateva SMEs in the crisis Employment Industrial Relations and Local Partnership Institute for Social and Trade Union Research EIRO ID BG1010031Q Publication date 15-06-2011 available at httpwwweurofoundeuropaeueirostudies

European Agency for Safety and Health at Work ndash EU-OSHA 6

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

European Agency for Safety and Health at Work ndash EU-OSHA 12

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

European Agency for Safety and Health at Work ndash EU-OSHA 13

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

European Agency for Safety and Health at Work ndash EU-OSHA 14

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

European Agency for Safety and Health at Work ndash EU-OSHA 15

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

European Agency for Safety and Health at Work ndash EU-OSHA 16

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 5: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

1 Bulgaria National Overview Report 11 National context 111 Section 1 Structure of the Bulgarian Economy Bulgariarsquos economic and industrial relations development since the beginning of the 1990s has been characterised by two equally important and complex processes the transition to a market economy and the countryrsquos accession to the European Union in 2007 During the pre-accession harmonization process and in the first years of Bulgariarsquos membership of the EU Bulgaria experienced high levels of economic and employment growth and inward investment

Bulgariarsquos gross domestic product (GDP) for 2011 is estimated to be euro38482m with a growth of 17 per cent in comparison to 20101 Bulgariarsquos economy relies primarily on industry but the service sector increasingly contributes to GDP growth The strongest sectors are energy mining metallurgy machine building agriculture and tourism Data show that agriculture contributed 56 per cent of added value (a measure of economic activity equivalent to the value of produced goods and services minus the cost of producing them) in 2011 industry 311 per cent and services and construction combined 633 per cent In 2010 there were 353588 enterprises in the non-financial sector of the Bulgarian economy and their number had slightly decreased in comparison to 2009 Small and medium-sized enterprises (SMEs) dominate the Bulgarian economy Of all enterprises 988 per cent are SMEs Within this group 921 per cent are micro enterprises (employing nine or fewer employees) 65 per cent are small enterprises (employing 50 or fewer employees) and 12 per cent are medium-sized enterprises (employing between 50 and 249 employees) Large enterprises those with more than 249 employees represented 02 per cent of all enterprises2 The private sector has grown and recently generated 73 per cent of GDP

During the period 2003-2008 the Bulgarian economy experienced high levels of GDP growth reaching 62 per cent in 2008 according to Eurostat data In Bulgaria the economic crisis of the late 2000s started several months later than in other EU countries However in Autumn 2008 the first signs of the crisis were apparent and in 2009 the consequences of the crisis were visible in both the economic and social spheres The main noticeable effects of the crisis were a marked reversal in GDP growth to -55 per cent in 2009 However positive growth was restored in 2010 to 04 per cent and 17 per cent in 2011 Other effects of the crisis were a decrease in foreign investments and an increase in unemployment and the number of companies filing for bankruptcy in particular small and medium- sized enterprises The economic crisis of 2007-2010 had a negative impact mostly on industry with a ten per cent decline in the national industrial production index In particular there was a combined two-digit drop in output across machine-building metallurgy wood-processing chemical production textile and tailoring construction and real estate In 2011 a growth in industrial production of 58 per cent in comparison to 2010 was recorded with the best results achieved in the following industries 82 per cent growth for mining and quarrying 80 per cent growth for production and distribution of electric and thermal heat power and gaseous fuels and 52 per cent for the manufacturing industry1 In contrast to the industrial sector agriculture in Bulgaria has experienced a marked decline since the beginning of the 2000s with agricultural production in 2008 amounting to only 66 per cent of the level of production between 1999 and 2001 A five year modernisation and development programme was launched in 2007 but the decline of agricultural production continued and in 2011 it reached 974 per cent of the 2010 level Growth in the construction sector was recorded in the period 2007-2009 accounting for between 78 and 79 per cent of GDP but the crisis exerted a pronounced negative impact with a drop to 64 per cent of GDP in 2010 and further decline in 2011 reaching 871 per cent of the

1 Bulgaria 2011 Statistical panorama National Statistical Institute Republic of Bulgaria Available at httpwwwnsibgpublikaciaphpn=329ampr=|5|ampP=65ampSP=113ampPSP=5

2 Analysis of the Situation and actors for Development of SMEs in Bulgaria 2011-2012 Bulgarian Small and Medium Enterprises Promotion Agency Economic Recovery and Competitiveness prepared by NOEMA Sofia 2012 available at httpwwwsmegovernmentbguploads201107SME_Situation-REP_noemaENG-0612pdf

European Agency for Safety and Health at Work ndash EU-OSHA 4

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

production level in 2010 The decline was comprised of a seven per cent decline in the construction of buildings and a 20 per cent decline in infrastructure construction

Nevertheless Bulgaria continues to rank as the lowest-income member state of the EU with GDP per capita calculated to be euro 5168 Euros1 in 2011 45 per cent of the EU27 average (Eurostat)

112 Section 2 Human resources In recent decades there has been a steady decline in the size of the population The latest data from 2011 records a population of 7327224 (487 per cent male and 513 per cent female) The mean age of the Bulgarian population continues to increase and reached 427 years by 2011 Bulgaria has one of the most rapidly ageing populations in the EU due to negative natural growth and migration mainly of young people

In 2011 585 per cent of the population aged 15-64 were in employment This was 34 per cent below the rate in 2010 Men represented 521 per cent of those in employment in 2011 in comparison to 527 per cent in 2010 Women represented 479 per cent of those in employment in 2011 in comparison to 473 per cent in 2010 The share of women in employment has therefore risen slightly over this period Employment rates by gender are presented in Table 1 below The table shows that whilst the employment rate for both men and women has declined in the period 2008 to 2011 the relative decline for men has been much sharper leading to a narrowing of the difference in employment rates for men and women This is at least in part due to the greater impact of the economic crisis on male-dominated sectors Employers in the private sector provide a growing proportion of employment with private sector employment recently accounting for 75 per cent of employment Of the total labour force 75 per cent is employed in the agricultural sector 364 per cent in industry and 561 per cent in services and construction Employment by SMEs declined by 65 per cent between 2009 and 20102 In comparison the decline in employment observed over the same period for large enterprises was 21 per cent

Table 1 Rates of employment by gender in Bulgaria in the period 2008-2012 (Eurostat)

Rates of year 2008 2009 2010 2011

Employment ndash total () 707 688 654 639

Employment ndash men () 761 738 691 666

Employment ndash women () 654 640 617 612

The financial crisis of 2007-2010 had a marked impact on unemployment in the country With the first signs of an increase in unemployment rates the government adopted an anti-crisis plan based on three pillars preserving financial stability providing support to businesses and ensuring social protection for the countryrsquos population An anti-crisis council including the social partners and the prime minister was established in February 2009 to discuss on a monthly basis the state and measures related to the crisis

Table 2 Rates of unemployment and the proportion of unemployment by gender and age band in Bulgaria in the period 2008-2012 4

Rates of year 2008 2009 2010 2011

Unemployed 233 719 280 980 350 478 372 300

Rate of unemployment () 63 76 95 111

European Agency for Safety and Health at Work ndash EU-OSHA 5

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Rates of year 2008 2009 2010 2011

Proportion of men () 375 423 454 454

Proportion of women () 625 577 546 546

Proportion at age lt29 yrs 178 183 181 191

Proportion at age 30-49 yrs 426 437 443 448

Proportion at age gt50 yrs 396 380 376 361

Despite the measures introduced in response to the crisis the numbers of those unemployed increased and the unemployment rate increased each year from 63 per cent in 2008 to 111 per cent in 2011 (Table 2) The latest data of Eurostat from June 2012 show a further increase in the unemployment rate in the country to 124 per cent with higher unemployment rates for both men (139) and women (107) Table 2 shows that by 2011 whilst the greater share of unemployment was borne by women the proportion of the unemployed who are women has declined over the period 2008-2011 Comparatively the proportion of the unemployed who are men has increased over the same period In 2011 562 per cent of the unemployed had been unemployed for more than one year A high level of youth unemployment is also an issue with 266 per cent of those under 29 years of age registered as unemployed The Government has instituted a programme to support youth employment alongside other measures aimed at supporting employment

The share of informal employment remains high mainly in micro and small enterprises Nearly 90 per cent of the employees in small and medium enterprises are working in traditional forms of employment under a labour and civil contract but the remaining 11 per cent define their relationship with the employer as lsquoanother typersquo including informal employment3 Moving to a new geographical location in order to find or take up a job is more common amongst young people 83 per cent of young people have changed their jobs within the past year

Part-time work and shift work are the most popular forms of flexible employment during the crisis whilst working at home or flexible working time is rare4 Employers from small and medium- sized enterprises demonstrate a high level of awareness of and positive attitudes towards non-standard forms of work 90 per cent say that they know of and approve flexible forms of employment such as part-time work and flexible working hours However flexible forms of employment are only practiced in a small share of Bulgarian companies

113 Section 3 Overview of the public OSH infrastructure The Occupational Health and Safety Act 1997 laid the foundation for changes in the structure of the occupational health and safety system in the country The Act defines the main responsibilities for safety and health at work The Ministry of Labour and Social Policy (MLSP) and the Ministry of Health (MH) are jointly responsible for

Developing coordinating and implementing policy in the field of safety and health at work Analysing the conditions trends and problems in health and safety at work and proposing

measures for its improvement Harmonisation of national legislation with EU legislation

3 Beleva I and Tzanov V Decent Work Country Report ndash Bulgaria International Labour Office Regional Office for Europe and Central Asia February 2008 available online at httpwwwiloorgpublicenglishregioneurprogenevadownloadeventslisbon2009dwreportsdw_bulgariapdf

4 Violeta Zlateva SMEs in the crisis Employment Industrial Relations and Local Partnership Institute for Social and Trade Union Research EIRO ID BG1010031Q Publication date 15-06-2011 available at httpwwweurofoundeuropaeueirostudies

European Agency for Safety and Health at Work ndash EU-OSHA 6

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

European Agency for Safety and Health at Work ndash EU-OSHA 23

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 6: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

production level in 2010 The decline was comprised of a seven per cent decline in the construction of buildings and a 20 per cent decline in infrastructure construction

Nevertheless Bulgaria continues to rank as the lowest-income member state of the EU with GDP per capita calculated to be euro 5168 Euros1 in 2011 45 per cent of the EU27 average (Eurostat)

112 Section 2 Human resources In recent decades there has been a steady decline in the size of the population The latest data from 2011 records a population of 7327224 (487 per cent male and 513 per cent female) The mean age of the Bulgarian population continues to increase and reached 427 years by 2011 Bulgaria has one of the most rapidly ageing populations in the EU due to negative natural growth and migration mainly of young people

In 2011 585 per cent of the population aged 15-64 were in employment This was 34 per cent below the rate in 2010 Men represented 521 per cent of those in employment in 2011 in comparison to 527 per cent in 2010 Women represented 479 per cent of those in employment in 2011 in comparison to 473 per cent in 2010 The share of women in employment has therefore risen slightly over this period Employment rates by gender are presented in Table 1 below The table shows that whilst the employment rate for both men and women has declined in the period 2008 to 2011 the relative decline for men has been much sharper leading to a narrowing of the difference in employment rates for men and women This is at least in part due to the greater impact of the economic crisis on male-dominated sectors Employers in the private sector provide a growing proportion of employment with private sector employment recently accounting for 75 per cent of employment Of the total labour force 75 per cent is employed in the agricultural sector 364 per cent in industry and 561 per cent in services and construction Employment by SMEs declined by 65 per cent between 2009 and 20102 In comparison the decline in employment observed over the same period for large enterprises was 21 per cent

Table 1 Rates of employment by gender in Bulgaria in the period 2008-2012 (Eurostat)

Rates of year 2008 2009 2010 2011

Employment ndash total () 707 688 654 639

Employment ndash men () 761 738 691 666

Employment ndash women () 654 640 617 612

The financial crisis of 2007-2010 had a marked impact on unemployment in the country With the first signs of an increase in unemployment rates the government adopted an anti-crisis plan based on three pillars preserving financial stability providing support to businesses and ensuring social protection for the countryrsquos population An anti-crisis council including the social partners and the prime minister was established in February 2009 to discuss on a monthly basis the state and measures related to the crisis

Table 2 Rates of unemployment and the proportion of unemployment by gender and age band in Bulgaria in the period 2008-2012 4

Rates of year 2008 2009 2010 2011

Unemployed 233 719 280 980 350 478 372 300

Rate of unemployment () 63 76 95 111

European Agency for Safety and Health at Work ndash EU-OSHA 5

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Rates of year 2008 2009 2010 2011

Proportion of men () 375 423 454 454

Proportion of women () 625 577 546 546

Proportion at age lt29 yrs 178 183 181 191

Proportion at age 30-49 yrs 426 437 443 448

Proportion at age gt50 yrs 396 380 376 361

Despite the measures introduced in response to the crisis the numbers of those unemployed increased and the unemployment rate increased each year from 63 per cent in 2008 to 111 per cent in 2011 (Table 2) The latest data of Eurostat from June 2012 show a further increase in the unemployment rate in the country to 124 per cent with higher unemployment rates for both men (139) and women (107) Table 2 shows that by 2011 whilst the greater share of unemployment was borne by women the proportion of the unemployed who are women has declined over the period 2008-2011 Comparatively the proportion of the unemployed who are men has increased over the same period In 2011 562 per cent of the unemployed had been unemployed for more than one year A high level of youth unemployment is also an issue with 266 per cent of those under 29 years of age registered as unemployed The Government has instituted a programme to support youth employment alongside other measures aimed at supporting employment

The share of informal employment remains high mainly in micro and small enterprises Nearly 90 per cent of the employees in small and medium enterprises are working in traditional forms of employment under a labour and civil contract but the remaining 11 per cent define their relationship with the employer as lsquoanother typersquo including informal employment3 Moving to a new geographical location in order to find or take up a job is more common amongst young people 83 per cent of young people have changed their jobs within the past year

Part-time work and shift work are the most popular forms of flexible employment during the crisis whilst working at home or flexible working time is rare4 Employers from small and medium- sized enterprises demonstrate a high level of awareness of and positive attitudes towards non-standard forms of work 90 per cent say that they know of and approve flexible forms of employment such as part-time work and flexible working hours However flexible forms of employment are only practiced in a small share of Bulgarian companies

113 Section 3 Overview of the public OSH infrastructure The Occupational Health and Safety Act 1997 laid the foundation for changes in the structure of the occupational health and safety system in the country The Act defines the main responsibilities for safety and health at work The Ministry of Labour and Social Policy (MLSP) and the Ministry of Health (MH) are jointly responsible for

Developing coordinating and implementing policy in the field of safety and health at work Analysing the conditions trends and problems in health and safety at work and proposing

measures for its improvement Harmonisation of national legislation with EU legislation

3 Beleva I and Tzanov V Decent Work Country Report ndash Bulgaria International Labour Office Regional Office for Europe and Central Asia February 2008 available online at httpwwwiloorgpublicenglishregioneurprogenevadownloadeventslisbon2009dwreportsdw_bulgariapdf

4 Violeta Zlateva SMEs in the crisis Employment Industrial Relations and Local Partnership Institute for Social and Trade Union Research EIRO ID BG1010031Q Publication date 15-06-2011 available at httpwwweurofoundeuropaeueirostudies

European Agency for Safety and Health at Work ndash EU-OSHA 6

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

European Agency for Safety and Health at Work ndash EU-OSHA 12

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

European Agency for Safety and Health at Work ndash EU-OSHA 14

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

European Agency for Safety and Health at Work ndash EU-OSHA 15

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

European Agency for Safety and Health at Work ndash EU-OSHA 16

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 7: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Rates of year 2008 2009 2010 2011

Proportion of men () 375 423 454 454

Proportion of women () 625 577 546 546

Proportion at age lt29 yrs 178 183 181 191

Proportion at age 30-49 yrs 426 437 443 448

Proportion at age gt50 yrs 396 380 376 361

Despite the measures introduced in response to the crisis the numbers of those unemployed increased and the unemployment rate increased each year from 63 per cent in 2008 to 111 per cent in 2011 (Table 2) The latest data of Eurostat from June 2012 show a further increase in the unemployment rate in the country to 124 per cent with higher unemployment rates for both men (139) and women (107) Table 2 shows that by 2011 whilst the greater share of unemployment was borne by women the proportion of the unemployed who are women has declined over the period 2008-2011 Comparatively the proportion of the unemployed who are men has increased over the same period In 2011 562 per cent of the unemployed had been unemployed for more than one year A high level of youth unemployment is also an issue with 266 per cent of those under 29 years of age registered as unemployed The Government has instituted a programme to support youth employment alongside other measures aimed at supporting employment

The share of informal employment remains high mainly in micro and small enterprises Nearly 90 per cent of the employees in small and medium enterprises are working in traditional forms of employment under a labour and civil contract but the remaining 11 per cent define their relationship with the employer as lsquoanother typersquo including informal employment3 Moving to a new geographical location in order to find or take up a job is more common amongst young people 83 per cent of young people have changed their jobs within the past year

Part-time work and shift work are the most popular forms of flexible employment during the crisis whilst working at home or flexible working time is rare4 Employers from small and medium- sized enterprises demonstrate a high level of awareness of and positive attitudes towards non-standard forms of work 90 per cent say that they know of and approve flexible forms of employment such as part-time work and flexible working hours However flexible forms of employment are only practiced in a small share of Bulgarian companies

113 Section 3 Overview of the public OSH infrastructure The Occupational Health and Safety Act 1997 laid the foundation for changes in the structure of the occupational health and safety system in the country The Act defines the main responsibilities for safety and health at work The Ministry of Labour and Social Policy (MLSP) and the Ministry of Health (MH) are jointly responsible for

Developing coordinating and implementing policy in the field of safety and health at work Analysing the conditions trends and problems in health and safety at work and proposing

measures for its improvement Harmonisation of national legislation with EU legislation

3 Beleva I and Tzanov V Decent Work Country Report ndash Bulgaria International Labour Office Regional Office for Europe and Central Asia February 2008 available online at httpwwwiloorgpublicenglishregioneurprogenevadownloadeventslisbon2009dwreportsdw_bulgariapdf

4 Violeta Zlateva SMEs in the crisis Employment Industrial Relations and Local Partnership Institute for Social and Trade Union Research EIRO ID BG1010031Q Publication date 15-06-2011 available at httpwwweurofoundeuropaeueirostudies

European Agency for Safety and Health at Work ndash EU-OSHA 6

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

European Agency for Safety and Health at Work ndash EU-OSHA 12

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

European Agency for Safety and Health at Work ndash EU-OSHA 13

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 8: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The OSH structure in Bulgaria is tripartite including the state employer organisations and trade unions The main state actors are Ministry of Labour and Social Policy Ministry of Health National Social Security Institute (NSSI) The relevant structures in the Ministry of Labour and Social Policy are the Department of Occupational Safety and Health the General Labour Inspectorate Executive Agency (GLI EA) The relevant structures in the Ministry of Health are the Public Health Department National Center of Public Health and Analyses (NCPHA) and Regional Health Centers

Enforcement in the field of occupational safety and health is carried out by the General Labour Inspectorate Executive Agency under the Ministry of Labour and Social Policy according to Labour Inspection Convention No 81 1947 ratified by Bulgaria in 1949 In addition a specific Act on Labour Inspection regulates the functioning of the National Labour Inspection System the different types of enforcement activities and the way public enforcement authorities performing labour inspection interact As a main government body the General Labour Inspectorate Executive Agency takes overall control on the compliance with labour law in all sectors and activities and specialized control on the compliance with the Employment Promotion Act The structure of the General Labour Inspectorate Executive Agency 5 oversees the regional inspection activities through the Directorate of Labour Inspectionrsquos 20 Directorates

The Strategy on Safety and Health at Work 2008-2012 was developed by a committee of experts drawn from the Ministry of Labour and Social Policy the Ministry of Health the National Centre of Public Health and Analyses in addition to representatives from other ministries In addition the committee includes representation from the General Labour Inspectorate Executive Agency and the National Social Security Institute6 The strategy shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim was to reduce accidents at work by 25 per cent and to strengthen health protection and promotion at the work place The priority fields include

1 Guaranteeing correct application of legislation in the field of safety and health at work 2 Promoting the development and application of sector specific strategies 3 Occupational risk management of new and emerging risks 4 Promoting preventive culture and changes in workersrsquo and employersrsquo behaviour

Since the inception of the strategy programmes are developed annually based on the priorities in the strategy and the progress achieved7

Following the Strategy and the annual programmes the General Labour Inspectorate Executive Agency undertook a variety of actions to improve the approach to inspection and provided more training for the inspectors In addition the Agency adopted a policy aimed at improving the transparency of its performance The Agency also launched a number of information campaigns and conducted the National Study of Working Conditions in 20108 The study was representative for the country and helped to identify the main problems concerning health and safety of the working population in Bulgaria

The Ministry of Health manages the register of Occupational Health Services and through the Regional Health Centres monitors their work The Ministry of Health determines policy aimed at strengthening the provision and monitoring of Occupational Health Services including providing training in occupational health

5 Bulgaria Country Report Summaries NERCLIS Project vol1 Annex Cardiff University Cardiff Work Environment Research Centre 2011 pp23-35

6 Strategy on Safety and Health at Work 2008-2012 Republic of Bulgaria Ministry of Labour and Social Policy Sofia available at httpwwwmlspgovernmentbgbgdocsindexstrhtm (in Bg)

7 Annual Programs on Safety and Health at Work and follow-up reports available at httpwwwmlspgovernmentbgbgdocsindexprogramshtm (in Bg)

8 Report on the results of the Bulgarian National Working Conditions Survey Project BGo51PO001-2301 ldquoPrevention of safety and health at workrdquo General Labour Inspectorate Executive available at httpprojectsgligovernmentbgindexphpmod=contentampshow=43 (in Bg Summary in En)

European Agency for Safety and Health at Work ndash EU-OSHA 7

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 9: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

After preventive approaches in the field of occupational health and safety were introduced in the country several toolkits for assessment and management of health risks including those related to mechanical physical chemical biological and psychosocial risks at work have been developed or made available in Bulgarian In the last few years guidance for protecting safety and health for night shift workers9 guidance for providing safety and health for hairdressers10 and the assessment of health risks from exposure to optic electromagnetic fields were developed Check-lists for evaluation of ergonomic risks were translated and adopted

114 Section 4 Overview of the OSH obligations for enterprises According to the Act on Safety and Health at Work (1997) the employer is responsible for conducting a health and safety risk assessment covering work processes and equipment premises organisation of work use of raw materials and stocks and external factors Further the employer has to plan appropriate measures for risk prevention taking into account the specific risks for employees who may need special protection including those with limited work capacity The employer must provide adequate facilities to allow employees including those with limited work capacity to fulfil their occupational functions The employer must also establish the necessary organisation for the supervision and control of the planned measures organise adequate training provide safety leaflets and equipment to locations where serious or specific danger for health and life exists The employer is also responsible for making the necessary arrangements with regard to fire safety and first-aid The employer must appoint staff to take responsibility for the management of risks first aid fire fighting and the evacuation of staff The number and training of these staff has to correspond to the occupational risks present in the workplace All expenses for providing occupational safety and health are to be met by the employer

The employer has to provide staff with access to an Occupational Health Service registered with the Ministry of Health Employers can either establish and register an in-house Occupational Health Service or subcontract the service to an external provider Ordinance number 325 (January 2008) describes the functions and tasks of Occupational Health Services good practice and the quality standards for such services The ordinance also covers the nature and qualification requirements of staff working in such services The role of Occupational Health Services are predominantly preventive in nature providing assistance to employers in the process of planning organisation and fulfilment of their obligations regarding provision and maintenance of occupational safety and health and promoting the health and workability of employees in relation to the work they conduct

For Occupational Health Services to be registered with the Ministry of Health they must employ

A medical doctor with a specialism in Occupational Medicine An engineer with experience in the field of safety and health A technician Despite efforts to expand the number of suitably qualified medical doctors (in 2003 medical doctors working in the field of occupational safety and health and with a specialism in Hygiene were awarded the status of Occupational Medicine practitioners) their numbers are still insufficient to meet the requirements of the Ordinance The number of registered Occupational Health Services exceeds the number of suitably qualified medical doctors by a factor of more than two Most Occupational Medicine Practitioners work for more than one Occupational Health Service A related problem is that the interest of young doctors in the speciality is not high Recent attempts have been made to address this problem by launching a Masters degree in Occupational Medicine in 2011 at the Medical University of Sofia The aim of the course is to provide young doctors with the opportunity to learn more about the area and potentially encourage them to undertake further training in the area

9 Mincheva L Vangelova K Shift and night work Problems and decisions Guidance National Fund Working Conditions MLSA Sofia 2007 ISBN 978-954-90826-9-2 237 pp (in Bg)

10 Mincheva L Stanchev V Leading risks for health of hair dressers Guidance National Fund Working Conditions MLSA Sofia 2012 167 pp (in Bg)

European Agency for Safety and Health at Work ndash EU-OSHA 8

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 10: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

The Ordinance requires that an engineer with at least three yearsrsquo experience in the field of safety and health be employed by the Occupational Health Service However there are no recognised vocational qualifications that correspond with the role of an engineer in safety and health meaning there is no formalised career structure The Ordinance also requires that a technician be employed by the service The qualifications required for this role are not specified by the Ordinance and as a result Occupational Health Services employ a variety of staff in the role (eg in some cases a secretary is employed in the role in other cases a nurse etc)

The majority of Occupational Health Services employ the minimum staff required by the Ordinance potentially drawing on the services of experts (eg toxicologists psychologists engineers ergonomists etc) as required

The Act on Safety and Health at Work (1997) also requires the employer to appoint a representative for employees on health and safety at work establish a Safety and Health Committee investigate record and report every accident that occurs and investigate cases of occupational disease The employee representatives from the Safety and Health Committees and from trade unions have to be invited to participate in the investigation of occupational accidents and diseases

115 Section 5 Approach to risk assessment The Act on Safety and Health at Work (1997) requires the employer to carry out risk assessments and the approach is defined in Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessments issued jointly by the Ministry of Labour and Social Policy and the Ministry of Health

The risk assessment should include all work processes and equipment premises workplaces work organisation use of raw materials and stocks and external factors The employer has to develop a program for risk assessment and appoint people to conduct the risk assessments Risk assessment should be conducted with the participation and support of a registered Occupational Health Service The obligatory steps are to identify the hazards assess and evaluate the risk implement risk control measures inform the persons at risk and assess the effect of the control measures implemented

The risk has to be monitored continuously as defined in Ordinance No 511051999 and reviewed after any significant change in the work environment ( work processes work organisation equipment premises external factors) that could influence the risk after changes in the legislation or after an incident has occurred or if it is prescribed by the Labour Inspectorate The Occupational Medicine physician has to decide annually at which workplaces revision of the risk assessment is needed

Measurement of risk factors are carried out by staff with the required competence and certificated according to legislation in the country The safety limits of specific workplace hazards such as noise vibrations dust and hazardous chemical substances microclimate and electromagnetic radiation are specified in Regulation No 723091999 concerning the minimum requirements for healthy and safety of workplaces and using industrial equipment The Act for safe use of nuclear power specifies the ionizing radiation matters Limits with respect to physical loads ergonomic issues work with VDU work time patterns etc are also specified in the body of legislation on health and safety

The Ordinance No 5 of 11 May 1999 on the procedure manner and frequency of carrying out risk assessment is obligatory for all work places in the country including the self-employed Requirements do not vary with respect to the size and sector of the organisation However for some risk factors such as ionizing radiation and asbestos there are special licensing arrangements in place The use of asbestos was banned in 2005

The data indicate that in 2009 71 per cent of workplaces in the country were registered with an Occupational Health Service (National Program for Safety and Health at Work Report 11 ) The provision of an Occupational Health Service to micro- and small establishments is a difficult task

11 National Programme for Safety and Health at Work Report (2009) Protocol Number 267th July 2010 of the Council of Ministers Available at httpwwwmispgovernmentbgbgdocsindexprogramshtm

European Agency for Safety and Health at Work ndash EU-OSHA 9

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

European Agency for Safety and Health at Work ndash EU-OSHA 23

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 11: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

especially in regions at a distance from towns Such is the case with agricultural workers who are exposed to a variety of risk factors12 The coverage of agricultural workers by OSH services is quite unsatisfactory13 Some small industry establishments (less than ten employees) but with multiple risk factors experience difficulties subcontracting OSH services largely as a result of the lack of interest of providers in providing a service to small organisations (because providing such a service is not seen as commercially viable) Another important issue is the quality of service provided by registered Occupational Health Services This issue was discussed at a National Conference in November 2010 The Ministry of Health is taking measures to strengthen the monitoring of Occupational Health Service through the Regional Health Centres largely through training of staff employed at the Centres

116 Section 6 Drivers for taking measures on OSH The harmonisation with EU legislation is a driver of improved health and safety at work The General Labour Inspectorate Executive Agency performs overall control on the compliance with the legislation The inspection activity is performed either according to the annual plans set up for respective directorates within the inspectorate and approved by the Executive Director or according to monthly plans approved by the head of the respective section The Minister of Labour and Social Policy can assign extraordinary inspections not included in the annual plan

Inspectors determine and apply relevant compulsory administrative measures that they consider appropriate (these may include actions the employer is required to take and if not taken may result in a financial penalty) Inspections and investigations have to be documented according to the administrative legislation applicable in the country The main regulatory acts in this regard are the administrative Offences Act and the Administrative Procedural Code as well as the internal act of the General Labour Inspectorate Executive Agency entitled Guidance for planning performing and reporting the activity of GLI EA

Integrated inspection is prevalent in the control of enterprises ie the controlling inspector performs inspection on all matters related to safe and healthy working conditions7 Usually inspectors are allocated to different economic sectors according to their education (which means that inspectors are recruited and trained according to the requirements of specific sectors) In addition under the Occupational Safety and Control Activity Analysis Directorate a unit was set up specifically to deal with the high risk work places throughout the country including mines quarries big chemical and metallurgic enterprises etc

In 2010 the Safety and Health at Work Act was amended and a requirement for employers to submit an annual declaration to the General Labour Inspectorate Executive Agency on working conditions Software has been developed to store and process the information and the data are used to assist in the development of policy concerning inspection activity

The Ministry of Labour and Social Policy develops coordinates and implements state policy on public social insurance including work accidents and occupational diseases and the responsible institution is the National Social Security Institute The Institute is a public organisation which on the basis of legal obligations guarantees citizensrsquo pensions and benefits The National Assembly adopts a Law on the State Public Social Insurance Budget annually The compulsorily insured persons for work accident and occupational disease risks include all categories of employed persons Work accident covers all cases of unexpected injury to health that results in incapacity to work or death and which occurred during the process of work or performed in the interest of the enterprise It also covers incidents which occur during the commute to and from work Occupational Disease risk covers diseases contracted as a result of the work environment or work process It is generally accepted that the National Occupational Disease list is not complete and it is possible that there are diseases that are yet to be recognised as occupational in origin Compensation covers temporary disability benefits benefits in

12 Vangelova K Halkova Zh Toneva Ir Occupational risks of agricultural workers Bulg J Publ Health 2012 4 (1) 32-39 (in Bg En)

13 Vangelova K Halkova Zh Toneva Ir Occupational health care of agricultural workers in Bulgaria Bulg J Publ Health 2012 4 (2) in print (in Bg En)

European Agency for Safety and Health at Work ndash EU-OSHA 10

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 12: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

case of readjustment disability pension financial support for spouses and offspring in case of death medical services and treatment etc

Another driver is the Strategy on Safety and Health at Work 2008-20128 It shaped the national policy framework for workersrsquo health taking into account the relevant international labour conventions changes in the national legislation and the occupational health and safety situation in the country The main aim ndash in line with the Community strategy 2007-2012 on health and safety at work ndash was defined as reducing work accidents by 25 per cent and strengthening health protection and promotion at work place From 2001 a gradual decrease in occupational accidents was observed in the country but up to 2008 the number of fatal accidents was increasing and reached 180 persons in 2008 In 2009 for the first time fatal accidents decreased to 91 cases In 2011 the trend for decrease of both all and fatal accidents resumed and the expectation is that the target set in the Strategy for reducing occupational accidents by 25 per cent will be met in 2012

The activity of trade unions and workers representatives is another possible driver The trade unions undertake a lot of activity in the field of safety and health at work Networks of safety and health committees in six sectors were established with the active work of one of the trade unions within the context of a project supported by the Norwegian Government14 Unions also contribute a lot to raise awareness on different issues concerning safety and health at work

117 Section 7 Level of concern at national level with OSH risks Within the Strategy on Safety and Health at Work 2008-2012 the topic of new and emerging risks is identified as one of four priority fields Basic scientific research as well as applied research is deemed necessary as they ensure an up-to-date knowledge base The following topics have been identified as research priorities psychosocial issues musculoskeletal disorders dangerous substances knowledge of reproductive risks occupational health and safety management risks associated with several cross-factors (eg work organisation and work design issues ergonomics combined exposures to physical and chemical factors etc) and potential risks with nanotechnologies The Strategy also stipulated the necessity of developing a National OSH research Centre but due to the economic crisis this has yet to be established

There are no systematic data available for the overall level of stress at country level A number of small studies on stress in different branches or occupations have been carried out by researchers of the Institute of Psychology and the National Centre of Public Health and Analyses The Institute for Social and Trade Union Research based at the Confederation of Independent Trade Unions in Bulgaria (CITUB) conducted a few surveys of stress in the period between 2001 and 2005 In 2003 CITUB organised the first national tripartite conference which gathered more than 150 researchers social partners and government representatives A survey lsquoWork stress in the context of transitionrsquo was carried out in 2002 by the Institute for Social and Trade Union Research at CITUB providing an in-depth analysis of the specific factors and sources of stress and the extent to which they have been influenced by the process of transition covering the three largest public sectors ndash education health and public administration at both the central and local government level Further a survey of the Ministry of State Administration and State Reform (MDAAR) entitled Employee Turnover Working Conditions and Motivation of Civil Servants was conducted in 2008 within the framework of the project lsquoImprovement of human resource management policy within the state administrationrsquo under the Operational Program Administrative Capacity 2007-2013 It examines civil servantsrsquo perceptions about stress at work factors causing stress job satisfaction or dissatisfaction and motivation

14 Health Safety and Environment in the work place Confederation of the Independent Trade Unions of Bulgaria Project 2008108471 with the support of the Government of Norway Available at httpwwwhse-bgorgindexphpoption=com_contentampview=articleampid=2ampItemid=2amplang=bg

European Agency for Safety and Health at Work ndash EU-OSHA 11

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

European Agency for Safety and Health at Work ndash EU-OSHA 12

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

European Agency for Safety and Health at Work ndash EU-OSHA 13

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

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13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 13: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

EU-OSHArsquos ESENER study showed comparatively high concern regarding violence bullying and harassment in Bulgaria but employee representatives reported the lowest bullying and harassment for both genders in the EU15

In 2010 the Bulgarian National Working Conditions Survey lsquoPrevention of safety and health at workrsquo10 was carried by the General Labour Inspectorate Executive Agency The survey is representative for the country and includes issues such as the nature of work working environment work organisation working time occupational health work payment information and consultation and work-life balance The data in general show that the employees are content with working conditions but also that a lot could be done to improve safety and health at work

The research activities of the National Centre of Public Health and Analyses during the period were directed towards evidence-based measures for control of health risks from psychosocial issues risks associated with work organisation work design issues and ergonomics Within the current National Program Safety and Health at Work 2012 the National Centre of Public Health and Analyses is conducting a study on stressors leading to development of burnout and impairment of health of teachers

118 Section 8 OSH training of employee representatives The representatives in Safety and Health at Work Committees and Groups have to be provided with training on issues of safety and health at work according to the Act on Safety and Health at Work The programmes procedures and requirements are set out in Ordinance N 4 from 3111998 issued jointly by the Minister of Labour and Social Policy and the Minister of Health

According to Ordinance N 4 the employer has to provide initial and annual training on safety and health at work 30 hours of initial training has to be provided followed by six hours of annual training subsequently The training has to be carried out in working time The initial training has to cover a wide range of topics These are

government policy on safety and health at work national legislation on safety and health at work organisational policy for providing safety and health at work responsibilities of all participants in the process of ensuring safety and health at work harmful factors for safety and health at work ill health prevention and health promotion methods for the assessment and analysis of occupational risks and working conditions sources of information on occupational safety and health occupational accidents and diseases health social and economic consequences of occupational safety and health social partnership the main responsibilities and tasks of Safety and Health at Work Committees requirements for selection education training instructions and information provision to workers

on safety and health at work special protection of vulnerable groups organisation of risk control activities The aim of the annual training is to refresh and update knowledge to increase work efficiency and provide information on new or changed legislative requirements The documentation concerning the training is specified in the Ordinance Information concerning the training carried out has to be sent to the General Labour Inspectorate Executive Agency

15 Milczarek M Vartia M Pahkin et al Workplace violence and harassment A European picture OSHA European Risk Observatory Report ISSN 1830-5946 Luxemburg Publication Office of European Union 2010

European Agency for Safety and Health at Work ndash EU-OSHA 12

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

European Agency for Safety and Health at Work ndash EU-OSHA 13

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

European Agency for Safety and Health at Work ndash EU-OSHA 14

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

European Agency for Safety and Health at Work ndash EU-OSHA 15

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

European Agency for Safety and Health at Work ndash EU-OSHA 16

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

European Agency for Safety and Health at Work ndash EU-OSHA 17

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 14: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

119 Section 9 Worker involvement and participation in OSH The employeesrsquo representatives have to be nominated and elected in accordance with the provisions of Article 6 of the Labour Code In all establishments with 50 or more employees Safety and Health at Work Committees have to be established In establishments with fewer than 50 employees Safety and Health at Work groups are required to be established (the main difference between the Safety and Health at Work Committee and the Safety and Health at Work group is in the number of people involved) Legislation requires an equal number of representatives of the employees and the employer in the Committees but the total number should not exceed ten members Employee representatives may include leaders of the respective trade unions in the enterprises or employees nominated and elected by the workforce

The mandate of the employeesrsquo representatives is fixed and is four years Its pre-term cancellation may be requested by at least one third of the total number of the employees and be effected with a majority of more than two thirds of the employees

According to the Act on Safety and Health at Work employee representatives are authorised to have access to all information available regarding working conditions analyses of occupational accidents and injuries and the findings and recommendations of the General Labour Inspectorate control bodies Employee representatives can also demand that the employer take all necessary measures and suggest proposals for the elimination of hazards or limitation of safety and health risk The employee representative may also notify the enforcement authorities if the employer has not taken adequate measures for the effective protection of safety and health of employees The employee representatives may also take part in the inspections performed by enforcement authorities The employer has to consult with the employees or with their representatives and establish conditions for them to participate in discussions on measures related to health and the safety at work The employer also has to appoint an employee to be responsible for carrying out activities in case first aid is needed fire-fighting and eventual evacuation of the workers planning and organising training on occupational safety and health for employees

The employer is responsible for providing appropriate training on occupational safety and health to every employee in relation to workplace risk factors The training has to be carried out within working time with all expenses to be covered by the employer According to national legislation workers have a right to safe and healthy working conditions but also obligations Each employee is responsible for their own health and safety as well as of the health and safety of other individuals affected directly by their activity in relation to their qualifications and the instructions given by the employer The employees have to use machinery apparatus tools hazardous substances and materials transportation facilities and other work equipment in accordance with the rules for their operation The use of personal protective equipment and special work clothing are obligatory The employer or the authorised officials have immediately to be informed in case of occurrence of a situation at work which may represent imminent danger for their health and about any malfunction of the means of collective protection The employees have to assist the employer andor other officials to carry out measures for ensuring the occupational safety health and recommendations issued by enforcement bodies

In Bulgaria comparatively high proportions (gt40 weighted) of both general and specialist OSH worker representation in combination with high management commitment was found under ESENER The proportion was lower among enterprises with 10 to 19 employees (30) and higher (52) in enterprises with 20-29 employees16

16 Walter D Wadsworth E et al Work representation and consultation on health and safety An analysis of the findings of ESENER EU-OSHA European Risk Observatory Report ISBN 97892-9191-663-4 Belgium 2012

European Agency for Safety and Health at Work ndash EU-OSHA 13

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

European Agency for Safety and Health at Work ndash EU-OSHA 14

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

European Agency for Safety and Health at Work ndash EU-OSHA 15

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

European Agency for Safety and Health at Work ndash EU-OSHA 16

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

European Agency for Safety and Health at Work ndash EU-OSHA 18

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

European Agency for Safety and Health at Work ndash EU-OSHA 19

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

European Agency for Safety and Health at Work ndash EU-OSHA 20

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

European Agency for Safety and Health at Work ndash EU-OSHA 21

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

European Agency for Safety and Health at Work ndash EU-OSHA 22

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 15: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

12 Participants Interviews were conducted at 19 establishments in Bulgaria In all establishments an interview was carried out with the management representative for health and safety and in 18 establishments a separate interview was conducted with an employee representative In one micro establishment there was no employee representative and an employee was interviewed instead

The establishments spanned a range of sectors and sizes as shown in Table 3 below Please note that size here is at the level of the establishment rather than the organisation as a whole one establishment was part of a larger multi-site organisation

Table 3 Achieved sample breakdown in Bulgaria

Sector Size No establishments (corrected categorisation)

No employee reps interviewed

Producing Microvery small (10 to 19) 1 1

Small (20 to 49) 3 3

Medium (50 to 149) - -

Large 150+ 2 2

Private services 10 to 19 1 1

20 to 49 3 3

50 to 149 2 2

150+ 1 1

Public Services 10 to 19 2 2

20 to 49 2 2

50 to 149 2 2

150+ - -

Total 19 19

Notes Interview with employee In one establishment the TNS categorisation was incorrect

The management representatives interviewed for this research held general management roles of which one part was managing health and safety In most micro and small establishments they held the position of overall managerdirector except in three cases where the directors had appointed other employees with responsibility for managing health and safety In all medium-sized and large establishments the management representatives were appointed by the director but held general management roles Some medium and large establishments in Bulgaria have created dedicated roles for health and safety but that was not the case in the establishments visited Most respondents had been provided with health and safety training

In all establishments interviews were carried out with employee representatives except one where an employee was interviewed Some employee representatives had been appointed to their roles by the company director several were chosen at a meeting and a few were trade union representatives All employee representatives were provided with health and safety training - some only once others annually - but this bore no relationship to the size and type of the establishment The amount of time dedicated to health and safety varied amongst the employee representatives from one hour per month to 50 per cent of working time

European Agency for Safety and Health at Work ndash EU-OSHA 14

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

European Agency for Safety and Health at Work ndash EU-OSHA 15

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 16: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

13 Main findings This section of the report addresses the technical issues and summary of responses for each question looking at each area of the survey in turn

131 Management of health and safety 1111 Technical points

MM155ER200 lsquoIs there a documented policy established management system or action plan on health and safety in your establishmentrsquo

This question was well understood in a broad sense Some respondents referred exclusively to a health and safety policy whilst others also referred to a management system and action plan For some respondents the meaning of an lsquoestablished management systemrsquo was not clear

Some interviewees assumed that this question was asking whether they had received certification on their approach to health and safety Three respondents mentioned their certification by OHSAS and two mentioned their ISO 9001 certificates which include elements of health and safety at work After clarifying that the question was not limited to certified systems they also described their health and safety policy

MM156ER202 lsquoIn practice how much of an impact does this policy management system or action plan have on health and safety in your establishment Does it have a large impact some impact or practically no impactrsquo

The question was well understood by the respondents and lsquoimpactrsquo was generally interpreted to mean a lsquopositive resultrsquo Some management and employee representatives found it difficult to rate the impact and thought the question should specify criteria for them to use

Several respondents interpreted some as minor so rated the impact as lower than the label suggests For example a management representative from a small private construction establishment insisted that their health and safety policy had an impact neither some nor large but a lsquogood impactrsquo

MM159ER 214 lsquoOverall how would you rate the degree of involvement of the line managers and supervisors in the management of health and safety Is it very high quite high quite low or very lowrsquo

This question was interpreted as being more about the OSH activities that line managers and supervisors perform than how much they care for health and safety at work For example a management representative from a micro furniture producing establishment said the line manager in the establishment was involved because he provided employees with health and safety induction training A management representative from a small private construction firm said involvement was high because safety instructions were provided at every new site and daily training was provided by qualified technicians

The phrase lsquoline managers and supervisorsrsquo has been translated into Bulgarian in such a way that suggests a wider group other managers as well as line managers and supervisors Several respondents considered the involvement of senior management as well as line managers and supervisors in making their assessments

1112 Interpretations All establishments had a health and safety policy which set out responsibilities for health and safety throughout the managerial chain as required by Bulgarian health and safety legislation Some management representatives also noted the existence of an occupational health and safety

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

European Agency for Safety and Health at Work ndash EU-OSHA 16

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

European Agency for Safety and Health at Work ndash EU-OSHA 19

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

European Agency for Safety and Health at Work ndash EU-OSHA 20

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

European Agency for Safety and Health at Work ndash EU-OSHA 21

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

European Agency for Safety and Health at Work ndash EU-OSHA 22

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 17: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

development plan setting out key objectives and activities for the year which they reviewed and revised on an annual basis One respondent from a small private transport establishment stated that they have no action plan at present as the external occupational health provider they subcontracted had not prescribed any actions

All respondents answered that their health and safety policy had an impact on the establishment although three found this difficult to rate as they felt the impact was good but neither lsquolargersquo nor lsquosomersquo The rest of the ratings were divided equally between those who felt it had some impact and those who felt it had a large impact Most respondents referred to a lack of accidents or low accident rates in their answers The employee representative of a small private construction establishment referred to a variety of actions that had been taken to improve health and safety such as training for the employees discussions concerning the OHSAS standard etc

Some interviewees mainly from private service establishments felt the policy had only lsquosome impactrsquo as there were not many risk factors in their workplaces they suspected the impact would be larger in producing companies with a higher risk profile Three management representatives from producing establishments complained that the impact of their policies was limited by employees who disregarded rules concerning the use of protective devices such as helmets dust masks and ear plugs A few interviewees (from public service and producing establishments) complained that their policy had only some impact as financial constraints prevented them from completing their action plans

lsquoBefore the crises the policy had a larger effect as we could allow investments in improving working conditions and also provided lunch for the workersrsquo

Management representative small metal constructions producing establishment

Respondents from the majority of establishments rated the involvement of line managers and supervisors in the management of health and safety as quite high about one-fifth rated it as very high and only one as quite low High involvement was linked mainly to actions such as health and safety induction In more than one establishment the employee representative gave a higher rating than the management representative

132 Levels of concern with OSH risks 1113 Technical points

MM200ER250 lsquoFor each of the following issues please tell me whether it is of major concern some concern or no concern at all in your establishment

01) Dangerous substances (eg dusts chemical biological) 02) Accidents 03) Noise and vibration 04) Musculoskeletal disorders 05) Work-related stress 06) Violence or threat of violence 07) Bullying or harassmentlsquo

When asked explicitly nearly all respondents interpreted concern as lsquopreventative actions leading to a positive resultrsquo

lsquoConcern means complying with the requirements taking preventative measures and raising awareness of the risksrsquo

Management representative micro retail establishment

However in their discussions it was clear that two main interpretations of lsquoconcernrsquo emerged the presence of risks and the management of risks For example some risks were regarded as a major concern because they were present in other cases because they were well managed For some interviewees both interpretations were used in making their assessments For example a management representative from a large road construction establishment pointed both to preventative actions (eg dust masks) and to the presence of dangerous substances (eg carcinogenic substances

European Agency for Safety and Health at Work ndash EU-OSHA 16

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

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adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 18: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

such as bitumen and kerosene) in assessing whether dangerous substances were a risk in his establishment

Mostly the answers were based on whether preventative actions had been undertaken but the calculus used to determine whether a risk was of some no or major concern varied according to the items presented Sometimes this was in line with the severity of the risk for example an employee representative from a small metal producing establishment was more concerned about accidents than noise and vibrations because the implications were more serious even though preventative actions had been taken to deal with each As well as varied interpretations across the respondents different interpretations were used within the same interview

Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not Some management representatives did not recognise problems concerning psychosocial risks such as work-related stress bullying and harassment and to a lesser extent violence or the threat of violence because these issues fell outside of their remit Clearly their view of health and safety focused primarily on physical risks

As for MM156ER202 some respondents interpreted lsquosomersquo concern as a lsquominorrsquo concern and therefore would have liked a mid-point response option between lsquosomersquo and lsquomajorrsquo

1114 Interpretations 01) Dangerous substances

These were of concern in most producing establishments Some respondents referred to the presence of dangerous substances (eg the presence of bitumen and kerosene in a large road construction establishment) others to preventative actions such as issuing safety instructions and protective equipment Dangerous substances were mainly of no concern in private and public service establishments because no such substances were present There were some exceptions to this such as two hotels a school and a hospital in which care was taken in the use and preparation of cleaning products and a newsprint retail establishment which had put in place a dust aspiration system

02) Accidents

All respondents from producing establishments considered accidents a major concern and most pointed to actions they took to prevent these such as performing risk assessments In private and public service establishments accidents were considered of some concern by most of the respondents either because there was a potential for them to occur or because they had taken a number of preventative actions

03) Noise and vibration

In most cases responses to this question referred to the issue of noise rather than vibration This risk was considered a major concern in the producing establishments both because it had to be regularly monitored and because preventative actions had been taken such as the use of protective devices and limiting noisy work to certain areas or times of the day Noise was a major concern in three public schools (two micro primary schools and one small basic school) because the children were noisy In other private and public service establishments noise and vibration were either of no concern or some concern

04) Musculoskeletal disorders (MSDs)

Respondents from most establishments considered MSDs of some concern Only one management representative and two employee representatives considered them a major concern In four of the establishments MSDs were of no concern Most of those concerned about MSDs discussed the use of technical equipment in their establishments to reduce the need for physical labour In producing establishments these included cranes and vehicles for moving heavy objects In private and public service establishments these included efforts to make their offices and workspaces more ergonomically-designed Many respondents mentioned that they undertook medical checks and made

European Agency for Safety and Health at Work ndash EU-OSHA 17

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

European Agency for Safety and Health at Work ndash EU-OSHA 21

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

European Agency for Safety and Health at Work ndash EU-OSHA 22

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

European Agency for Safety and Health at Work ndash EU-OSHA 23

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 19: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

adaptations to the workplace for disabled employees For some of the respondents MSDs were of no concern

05) Work-related stress

In most establishments interviewees thought work-related stress was of some concern This was both because there were factors contributing to stress such as shift work or work with clients and because they took actions to try to prevent this such as scheduling tasks to avoid excessive time pressure or running team building sessions

lsquoWe divide the work between the employees and we take care to ensure the deadlines are realistic Where we get more work we increase the number of staffrsquo

Management rep small insurance establishment part of a holding company

lsquoWork-related stress is acknowledged in our policies on health and safety at work the issue is not only discussed after the occurrence of an event but also during a risk assessmentrsquo

Employee representative large private post establishment

Work-related stress was a major concern to respondents from a small public hospital and two smallmicro schools the latter of which provided training on work-related stress to employees

Employee representatives were more likely to consider work-related stress a major concern than management representatives

lsquoThe managers do not realize the stress the employees are exposed torsquo

Employee representative micro retail establishment

06) Violence or the threat of violence

Violence was not considered a concern by most interviewees as they had not experienced an incident A few respondents thought it was of some concern largely because of the potential impact of an incident and because they had put safeguards in place Two respondents (one from a small public school and one from a municipality) thought it was of major concern because colleagues had been threatened with violence in the workplace

07) Bullying or harassment

Bullying was of no concern to most respondents because they thought it did not occur in their establishments However some management representatives thought bullying was a major concern and were determined to stamp it out For example a respondent from small insurance establishment part of a holding company described a system in place for sending complaints about bullying to a senior level in the organisation Employee representatives tended to agree that bullying was of no concern Only one felt it was a major concern and referred to the fact that they had carried out an ISO audit of management-employee relationships

lsquoAny rude behaviour by employees or management representatives is not tolerated Actions are undertaken immediatelyrsquo

Employee representative large private post establishment

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

European Agency for Safety and Health at Work ndash EU-OSHA 19

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

European Agency for Safety and Health at Work ndash EU-OSHA 20

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

European Agency for Safety and Health at Work ndash EU-OSHA 21

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

European Agency for Safety and Health at Work ndash EU-OSHA 22

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 20: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

133 Approach to risk assessments 1115 Technical points

MM161ER207 lsquoAre workplaces in the establishment regularly checked for safety and health as part of a risk assessment or similar measuresrsquo

This question was well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly among the respondents from every three months to once per year Some pointed out that the legislation dictated the period between risk assessments for different risk factors

MM162 lsquoAre these risk assessments or workplace checks mostly conducted by your own staff or are they normally contracted to external service providersrsquo

The question was well understood by the management representatives

MM163 lsquoOn which occasions are these risk assessments or workplace checks carried outrsquo

01) Following a change in the staffing layout or organisation of work 02) At the request of employees eg in case of complaints 03) At regular intervals without any specific cause

Most respondents answered item 1 (following a change in the staffing layout or organisation of work) without confusion but one respondent gave a positive answer which was hypothetical

lsquoWe should carry out risk assessment if we have new staff or workplaces but actually we have no new staff or work placesrsquo

Management Representative small construction establishment

Item 2 (at the request of employees) was often answered from a hypothetical standpoint Eight management representatives said that risk assessments were carried out following employee requests but in six of these the answer was hypothetical as no such requests or complaints had been made These were mainly from the private and public service establishments In the remaining 11 establishments a negative answer was given precisely because no such requests had occurred

MM164 lsquoWhich of the following areas are routinely considered in these checksrsquo

01) Equipment and working environment 02) The way work is organised 03) Irregular or long working hours 04) Supervisor-employee relationships

The majority of management representatives were unsure about at least one aspect of this question Item 2 (the way work is organised) was interpreted in different ways including how information is shared between managers and staff how responsibilities are allocated amongst staff the arrangements for shift and night work and the use of technological processes Two management representatives said that lsquothe way work is organisedrsquo was not assessed by risk assessments but was included in the audit for compliance with ISO 9001

lsquoThis is not a part of these checks but it is part of the audit for ISO 9001 Work organisation is audited annuallyrsquo

Management representative medium-sized municipality

The response options lsquoyesrsquo lsquonorsquo and lsquonot applicablersquo may be insufficient to cover the range of responses to item 2 One management representative from a small construction establishment explained it was so broad that some aspects may be routinely considered whilst others are not

European Agency for Safety and Health at Work ndash EU-OSHA 19

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

European Agency for Safety and Health at Work ndash EU-OSHA 20

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 21: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

Another from a small manufacturing establishment interpreted lsquothe way work is organisedrsquorsquo as the structure of the enterprise internal rules and daily tasks He could not judge whether all aspects of this were included in workplace checks

Item 3 was translated into Bulgarian as lsquosupplementary or long working hoursrsquo (rather than lsquoirregular or long working hoursrsquo) although this did not appear to have a big effect on the responses Most of the respondents stated that they had no irregular or long working hours or that these were not a part of risk assessment

lsquoChanges in working time arrangements such as shift work schedules are not a part of risk assessment - these were developed to cover the different tasksrsquo

Management representative medium-sized hotel

A respondent from a large delivery establishment changed her answer from negative to positive after the term lsquoirregular working hoursrsquo was clarified She reported that shift schedules were part of a risk assessment One management representative did not identify compressed working weeks as irregular working hours

MM166 lsquoAnd which of the following actions have been taken as a follow-up to these checksrsquo

01) Changes to equipment or working environment 02) Changes to the way work is organised 03) Changes to working time arrangements 04) Provision of training

This question was well understood by all management respondents However several indicated that they had taken actions when these did not occur as a result of these checks A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

In relation to item 3 one interviewee pointed out the impossibility of avoiding irregular working hours for two of their employees

lsquoIn case of -20oC if in the evening the stoker did not start the heating the next day it would be impossible to carry out teaching and the heating system would be damagedrsquo

Management representative micro public school

ER209 lsquo Do you have a say in the decisions on when and where these risk assessments or workplace checks are carried outrsquo

This question was well understood by all of the employee representatives However after probing it was clear that the lsquoyesrsquo or lsquonorsquo options were insufficient to cover the range of answers Four options as follows may work better 01) Yes actively involved 2) Yes could have a say but has not made a contribution to date 03) No because another employee takes part and 04) No decisions are made by management Some interviewees answered negatively to this but from their discussions it was clear that other employee representatives in the establishment did get involved in these decisions

ER210 lsquoIf the risk assessment or workplace check identifies a need for action Is the necessary follow-up action takenrsquo

This question was well understood by all of the employee representatives

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 22: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER211 lsquoAnd are you as health and safety representatives usually involved in the choice of follow-up actionsrsquo

This question was well understood However several of the responses came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

MM169ER213 ndash lsquoAre there any particular reasons why these checks are not regularly carried outrsquo

None of the interviewees were routed onto this question as all stated that risk assessments were carried out in their establishment It is a legislative requirement in Bulgaria for all organisations to carry out risk assessments and to keep written records of these

1116 Interpretations Interviewees told how workplaces were regularly checked for safety and health and some mentioned that these adhered to the requirements of the Safety and Health at Work Act and subsequent specifications All confirmed that these were carried out regularly Written risk assessments were provided annually by their occupational health service

In the majority of establishments workplace checks and risk assessments were conducted by external providers usually an occupational health service The management representatives from two small establishments (a construction firm and a public hospital) told how risk assessments were carried out both by an external occupational health service and their own staff In one small construction establishment risk assessments were carried out mostly by their own staff who had all been provided with training and written guidance on how to do these

Risk assessments are carried out by our own staff We provide annual training on different health and safety issues for the staff carrying out the risk assessment they use guidance brochures etcrsquo

Management representative small construction establishment

In ten establishments risk assessments were conducted following a change in the staffing layout or organisation of work This was most frequent in the producing establishments (five out of six) followed by public service establishments (four out of six) and finally private service establishments (three out of seven) Management representatives from two small construction establishments told how risk assessments were carried out at every new site Risk assessments were carried out at the request of employees in just under half of the establishments but as previously mentioned often these responses were hypothetical In a large printing establishment employees had complained about dust levels on the site which had led to a risk assessment In 15 out of 19 establishments risk assessments were carried out annually without any specific cause

All management representatives stated that risk assessments routinely considered equipment and the working environment and told of portable appliance testing (PAT) noise and lighting tests being performed In producing establishments tests were extensive and included checks on equipment dust heat radiation vibration moving parts of machinery etc

lsquoEverything that could be a risk for the safety and health of the employee is routinely considered in these checksrsquo

Management representative large thermoelectric power station

The way work is organised was considered in risk assessments in about half of the establishments although this part of MM164 was not particularly well understood (see technical section for more details) Irregular (translated as lsquosupplementaryrsquo) or long working hours were rarely considered because employees in most establishments had standard working time arrangements or fixed shift patterns The management representative from a large thermoelectric power station told how their 12-

European Agency for Safety and Health at Work ndash EU-OSHA 21

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

European Agency for Safety and Health at Work ndash EU-OSHA 22

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

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Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 23: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

hour shift patterns were scrutinised by risk assessments The respondent from a large road construction establishment explained how their working patterns varied substantially so were covered by risk assessments

lsquoOur work in road construction is seasonal Occasionally we work long hours or during the holidays For several years we have worked during the winter too as we are engaged in the maintenance of roads that is associated with night shifts work on call etc Since then irregular and long working hours are checked as part of a risk assessmentrsquo

Management representative large road construction establishment

Supervisor-employee relationships were not considered part of a risk assessment in most of the establishments Only three management representatives said that they were In one a small construction establishment the interviewee explained that this was included because the compatibility of the teams was very important In a small public hospital the management representative explained that whilst they did not cover this issue in their risk assessments they did conduct anonymous questionnaires to assess staff opinion on relationships with supervisors In a small public school the management representative told how this issue was not yet covered by risk assessments but should be

lsquoSupervisor-employee relationships are not subject to these checks but I think they should be The good relationships contribute to positive results There are different interests of students parents teachers external organisations It is difficult to work with people - addressing the psychosocial factors is important for eliminating or reducing stressrsquo

Management representative small public school

Responses to the different parts of MM166 varied Most told how changes had been made to equipment or the working environment They gave examples of changes to equipment such as the purchase of new vehicles instruments and computers Examples of changes to the working environment included providing air conditioning aspiration systems for dust reduction placing anti-slip materials on floors and adding aluminium-framed windows to reduce noise

lsquoThe checks found insufficient lighting in some workplaces so we added additional lighting There was a requirement for the establishment to renew the electricity supply system and we have partially done this We are trying to replace the old equipment with new ones eg we have new light motor lorries The new ones are safer and quickerrsquo

Management representative medium-sized newsprint retail establishment

Two management representatives said that they had made changes to the equipment and working environment but not as a result of a risk assessment Only a few interviewees said they had made changes to the working environment but these examples pointed to actions to improve performance rather than health and safety More than half of the respondents reported that that training had been provided as a follow up to checks such as training on work-related stress for teachers and fire and earthquake safety training for hospital staff

Most of the employee representatives said they had a say on when and where risk assessments were carried out and thought they made a useful contribution

lsquoThe consultations with the employees can be very useful they often have a different point of view and can contribute to solving problems related to safety and healthrsquo

Employee representative medium-sized hotel

lsquoThe management enables all employees to shares views on health and safety both the management and employees are active and this brings good resultsrsquo

Employee Representative medium-sized municipality

All employee representatives said that follow-up actions were taken in their establishment although one said these were only partly completed Several said that actions were taken without delays whilst

European Agency for Safety and Health at Work ndash EU-OSHA 22

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

European Agency for Safety and Health at Work ndash EU-OSHA 23

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 24: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

others told how financial problems could slow down implementation In a small construction establishment the interviewee told how they stopped using machines until necessary follow-up actions were carried out even if funds were not available at the time

Most of the employee representatives attended workplace inspections so were able to have a say on the choice of follow-up actions One was responsible for the choice as he was the companyrsquos internal auditor for compliance with OHSAS An employee representative from a large delivery establishment stated that not only he but all employees could make proposals However an interviewee from a large power station explained that he lacked the competence to make much of a contribution to these decisions

134 Drivers and barriers to measures on OSH 1117 Technical points

MM171 lsquoIn your establishment how important are the following reasons for addressing health and safety For each one please tell me whether it is a major reason a minor reason or no reason at allrsquo

01) Fulfilment of legal obligation 02) Requests from employees or their representatives 03) Staff retention and absence management 04) Economic or performance-related reasons 05) Requirements from clients or concern about the organisationrsquos reputation 06) Pressure from the labour inspectorate

There were minor problems in understanding this question Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied

lsquoReputation is a major reason for addressing health and safety while requirements of clients are not a reason as they are not related to the health and safety of the employeersquo

Management representative large delivery establishment

An interviewee from a small public school said yes to this as the requirement of clients (ie parents) was very important in her role but her explanation did not relate this to health and safety

Most management representatives thought that the labour inspectorate (item 6) was a major reason for adressing health and safety but for all except one it was not clear that they had received any lsquopressurersquo as such Instead they were keen to avoid any problems with the labour inspectorate

Two respondents did not like the labels lsquomajorrsquo or lsquominorrsquo which they considered too extreme Instead they preferred to state that issues were either a reason or an lsquoimportantrsquo reason for addressing health and safety

Two respondents thought the list could include an additional reason for addressing health and safety lsquoto increase employee motivationrsquo

European Agency for Safety and Health at Work ndash EU-OSHA 23

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 25: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

lsquoAnother important reason to address safety and health at work is the motivation of the staff it is very important for achieving good results in workrsquo

Management representative medium-sized hotel

MM172 lsquoIn your establishment what are the main difficulties in dealing with health and safety Please tell me for each of the following whether it is a major difficulty a minor difficulty or not a difficulty at allrsquo

01) A lack of resources such as time staff or money 02) A lack of awareness 03) A lack of expertise 04) A lack of technical support or guidance 05) The culture within the establishment 06) The sensitivity of the issue

A management representative from a micro furniture manufacturing establishment initially said that a lack of awareness (item 2) was a minor difficulty but then hesitated and said it was a major difficulty because hypothetically it could present an issue

lsquoIf there are any new legislative requirements and we do not know about them and the occupational health doctor has not informed us about them it would become major difficulty if we were then inspectedrsquo

Management representative micro furniture manufacturing establishment

Item 6 (the sensitivity of the issue) was understood by all management representatives except one from a large road construction establishment However most did not understand why health and safety would be a sensitive issue

1118 Interpretations The answers to question MM171 (reasons for addressing health and safety) were as follows

01) Fulfilment of legal obligation

Fulfilment of legal obligation was considered a major driver for addressing health and safety in most establishments who thought it was normal or wise to focus on this

02) Requests from employees or their representatives

Most of the respondents stated that health and safety issues raised by staff were a major reason for addressing health and safety and added that these were addressed by the establishment

03) Staff retention and absence management

Most management representatives said that they had no problems with staff retention or absence management but thought that addressing health and safety at work was important for staff retention as it demonstrates that the employer cares Two respondents (from smaller producing establishments) stated that sickness absence was not a problem for them but added that this was partly because there was insufficient work so employees often had to take periods of unpaid leave A management representative from a large power station said that sickness absence was becoming more of a problem in his establishment as the workforce was ageing

04) Economic or performance-related reasons

Most management representatives thought that these were major reasons for addressing health and safety as any accidents could damage the establishment financially

05) Requirements from clients or concerns about the organisationrsquos reputation

European Agency for Safety and Health at Work ndash EU-OSHA 24

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 26: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

In ten establishments the management representative considered requirements from clients or concerns about the organisationrsquos reputation to be of major concern and in three establishments of minor concern In the rest of the establishments these were of no concern at all This was more likely to be a major reason for addressing health and safety in the private service establishments than the public service or producing establishments

06) Pressure from the labour inspectorate

This was considered a major reason for addressing health and safety by almost all respondents but none said they had received pressure from this body One management representative from a medium-sized municipality stated that this was not a reason at all for addressing health and safety

lsquoThis is not a reason at all We address health and safety issues because of our employees not because of the labour inspectoratersquo

Management Representative medium-sized municipality

The answers to question MM172 (difficulties in addressing health and safety) were as follows

01) A lack of resources such as time staff or money

Most management representatives from producing establishments considered a lack of resources a major difficulty because they lacked the financial resources and time required By contrast most from private and public service establishments considered this no difficulty at all whenever something was required it was provided

02) A lack of awareness

Generally a lack of awareness was not considered a difficulty because the interviewees felt they had a lot of information

03) A lack of expertise

Most respondents thought this was not a difficulty as they had trained teams and support from their occupational health service although two were displeased with the latter

04) A lack of technical support or guidance

All respondents felt that this was not a difficulty as they had the technical support and instructions required for working with different machines andor under different conditions

05) The culture within the establishment

Most respondents did not consider the culture within their establishment a difficulty although a few mentioned that despite their efforts to improve health and safety some employees still chose not to comply with health and safety procedures

lsquoThe employees are aware of the risks protective devices are provided but not all the employees use them (eg dust masks ear plugs) and the managers are not able to ensure that every employee uses the protective devicesrsquo

Management representative large private road construction establishment

lsquoI feel the health and safety culture is not high as some employees are not disciplined They are informed of the risks but do not strictly follow the rules For example smoking is forbidden in the establishment but we had to enforce it with high fines

Management representative medium-sized newsprint retail establishment

06) The sensitivity of the issue

Most respondents felt that this was not a difficulty because they did not consider health and safety a sensitive issue

European Agency for Safety and Health at Work ndash EU-OSHA 25

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 27: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

135 Worker participation and involvement 1119 Technical points

ER102 lsquoIs there a permanent committee or working group consisting of members of the management and representatives of the employees dealing with safety and health in this establishmentrsquo

This question was well understood by almost all employee representatives

ER107 lsquoHow often do controversies related to safety and health arise between the management and the employee representatives Is this often sometimes or practically never the case

This question was well understood Controversies were interpreted as lsquodifferent opinions and discussions between the management and the employeesrsquo

One respondent from a medium-sized hotel said she did not know the answer but interpreted the question as being about more general controversies rather than those related to health and safety

ER205 lsquoAre employees in this establishment regularly informed about safety and health in the workplacersquo

This question was well understood by all employee representatives

ER215_05 lsquoPlease tell me whether you agree (1) neither agree nor disagree (2) or disagree (3) with the following statement lsquoOur management gives proper consideration to occupational safety and health issues raised by employees or their representativesrsquorsquo

This question was well understood by all employee representatives An interviewee from a small construction establishment thought the question was too general and that the answer depended on the nature of the issue raised

11110 Interpretations In all establishments except one there was either a health and safety group (usually in smaller establishments) or committee (usually in larger ones) All establishments except one held meetings at least quarterly Health and safety issues could generally be raised by all employees at these meetings not just their representatives

lsquoHealth and safety issues can be raised not only by employee representatives but also by all other employees Every employee can submit written proposals questions requirements etc and they are discussed by the health and safety committeersquo

Employee representative large power station

Most employee representatives said that there were practically never controversies related to safety and health between the management and the employee representatives except for three who stated that there were sometimes controversies

Most employee representatives said that employees were regularly informed about health and safety in their establishment They discussed health and safety induction training and issuing of periodical guidance In the construction establishments employees were provided with safety instructions at every new site and refresher instructions every day

European Agency for Safety and Health at Work ndash EU-OSHA 26

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 28: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

All but two of the employee representatives agreed with the statement that their management gave proper consideration to occupational safety and health issues raised by employees or their representatives and many mentioned the number and nature of requests that had been made Some described how actions to deal with these were prioritised by management and made punctually Only two respondents (both of whom were from micro establishments) neither agreed nor disagreed with the statement In one of these cases (a producing establishment) this was because some health and safety issues were dealt with whilst others were not In the other (a retail establishment) it was because requests considering work-related stress were neglected

lsquoThe problems with stress at work are ignored this is an important issue for the employeesrsquo

Employee representative micro retail establishment

136 Resources and training in OSH issues 11111 Technical points

ER150 lsquoDo you as the employee representative for safety and health usually get sufficient time off from normal duties to perform these tasks adequatelyrsquo

This question was well understood by all employee representatives

ER154 lsquoDoes the management provide you with the necessary information for carrying out your health and safety tasks properly

This question was well understood by all employee representatives

ER155 lsquoDo you usually receive information on time and without having to ask for itrsquo

Most respondents gave a positive answer to this question Some employee representatives initially gave a positive answer but later changed their minds after mentioning that sometimes information was not provided but in these cases they could usually request it without problem

ER159 lsquoOn which of the following issues have you or your health and safety representative colleagues received trainingrsquo

01) Fire safety 02) Prevention of accidents 03) Chemical biological radiation or dust hazards 04) Ergonomics 05) Violence bullying or harassment 06) Work-related stress 07) Discrimination (for example due to age gender race or disability)

There were minor problems in understanding this question One employee representative found it difficult to answer item 2 (prevention of accidents) because although he had received instructions on this he had not received training A nurse from a public hospital incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

European Agency for Safety and Health at Work ndash EU-OSHA 27

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 29: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

ER160 lsquoIs this training sufficient or would more training in any of these fields be desirable lsquo This question was well understood

ER162 lsquoWhich of the following are the main reasons for receiving no or not sufficient training on these issuesrsquo

This question was well understood but some respondents were somewhat confused by it They explained that some of these reasons were applicable but thought that there were also other reasons not covered by the list

11112 Interpretations Almost all employee representatives stated that were provided with sufficient time to perform their health and safety duties adequately One clarified what was meant by this

lsquoFor me performing tasks adequately means conducting this particular work to the required standard and in timersquo

Employee representative small transport establishment

Most employee representatives said they were provided with the necessary information for carrying out these tasks properly and that they got this on time without having to ask for it They mentioned receiving information on risk assessments legislative requirements etc One respondent did not think he needed to be provided with any information

All employee representatives except one from a small transport establishment had received training on at least some of the topics listed in ER159 One interviewee from a medium sized municipality had received training on all of the topics Most employee representatives had been provided with training on fire safety Those from producing and private service establishments were more frequently provided with training on the prevention of accidents and chemical biological radiation and dust hazards whilst those from public service establishments were more frequently trained on violence bullying and harassment and work-related stress

The interviewees were equally divided between those who thought the training received was sufficient and those who felt that more training was desirable Those who felt that more training was desirable were often from public service and large private service establishments even though the latter group was generally provided with more training than others

Those who stated that they had not received sufficient training pointed to several reasons for this including financial difficulties a lack of information on the courses and the fact that some courses were not suitable The employee representative who had not received any training felt that that the courses available were not suitable for him

lsquoThe financial difficulties are the main reason but also often the courses are not suitable for the people working in the office they are more suitable for the staff of manufacturing enterprisesrsquo

Employee representative medium-sized municipality

137 OSH and organisational performance

European Agency for Safety and Health at Work ndash EU-OSHA 28

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 30: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

11113 Technical points

MM402 lsquoHow would you rate the level of absenteeism in your establishment compared with other establishments in the sector Is it very high quite high about average quite low or very low lsquo

The question was well understood but most management representatives did not know how other establishments performed in this regard They usually knew about absenteeism in their own establishments and based answers on their own opinions about whether this was highlow comparisons with earlier periods or anecdotal evidence obtained through discussions with colleagues

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of health and safety outcomes such as the number of accidents and injuries at work and the level of sickness absencersquo

This question was well understood but again most did not know how other establishments performed in this regard

MM403 lsquoHow would you rate the current economic situation of this establishment Is it very good quite good neither good nor bad quite bad or very badrsquo

Most management representatives had some idea of the economic situation of their organisation and some told how they were briefed on this by senior management

New question lsquoCompared to other organisations of your size and sector in Bulgaria how well would you say you perform in terms of business outcomes such as profit turnover or other relevant measures of performancersquo

This question was generally well understood by the management representatives but more than one did not answer because either they lacked the information concerning other establishments or did not feel confident to say how they compared

lsquoSorry but this question is not within my competence you should ask the Executive Director or the owners of the enterprise and discuss the issues related to business outcomes with themrsquo

Management representative large road construction establishment

A couple of the respondents (from a school and a public administration) said the question was not applicable to their organisation because they did not make a profit in the usual sense

11114 Interpretations Most management representatives said they had no basis on which to compare their levels of absenteeism Making a guess 15 considered it quite low two about average and one quite high because the establishment had an aging workforce One respondent chose not to answer the question

One management representative from a small public hospital explained that absence was low in the establishment because it was linked to pay Two others both from small or micro establishments explained that theirs was low partly because there was insufficient work for employees who sometimes had to take periods of unpaid leave

Similarly interviewees pointed out that they had no basis on which to compare their performance in terms of health and safety outcomes Four did not give a rating whilst other (guessed) responses were

European Agency for Safety and Health at Work ndash EU-OSHA 29

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 31: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

that the establishment performed about average well or very well Respondents referred to a lack of accidentslow accident rate and low levels of sickness absence

Views on the current economic situation of the establishment varied by type of business For producing establishments both quite good and quite bad ratings were provided with the latter explained by delayed payment of salaries and debts to suppliers In contrast most respondents from private service establishments thought their situation was either quite or very good except for one from a micro establishment who rated it as very bad In public service establishments views were mixed between neither good nor bad and quite or very good These trends were repeated in the new question on business outcomes such as profit turnover and other relevant measures for performance

14 Collecting health and safety performance data The health and safety proformas were completed in all 19 establishments However in several cases information was incomplete despite management representatives making their best efforts to find all the information required In some establishments the proformas were discussed after the interviews or subsequent calls were required to get the data

01) Staff resources

The management representatives found it difficult to answer the section on staff resources On several proformas the amount of time dedicated to health and safety was recorded in ranges rather than absolute figures eg two to three hours per month Several respondents did not complete this section either because they did not know how much time was spent in this area or because it varied greatly from month to month The management representative from a large power station explained that every staff member could spend from hours to days on health and safety monthly depending on the situation As many people were involved in health and safety he thought it impossible to provide accurate data

For those establishments where this data was provided time spent on health and safety varied from 05 to 20 hours per month with more time spent by managers in producing establishments The time dedicated to health and safety depended on the number of people involved and the risks present in the establishment

02) Cost of purchased health and safety services and equipment

Some proformas only detailed the total amount spent on health and safety services whilst in other cases this was broken down to cover the costs of occupational health services measurements of particular risks such as noise vibration or lighting medical checks and training A management representative from a medium-sized delivery establishment would not provide a figure as he considered the information confidential Two did not have access to financial information in one case this was because health and safety services were arranged by the holding company rather than the establishment

The total amount spent on health and safety services ranged from euro50 to euro200 in micro establishments euro550 to euro1000 in small establishments euro950 to euro1450 in medium-sized establishments and euro2500 to euro60000 in large establishments

Data on the cost of purchased equipment was approximate on some of the proformas and incomplete on others Some management representatives said that it was very complicated and time-consuming to provide this data A wide range of types of equipment were listed in this section including protective clothing and devices air conditioners fans lighting and office equipment The data provided show that during January 2011 to December 2011 the cost of protective clothing devices and equipment ranged from euro150 to euro6000 for micro establishments from euro300 to euro3000 for small establishments and from euro3000 to euro5000 for medium ndashsized establishments Only one large establishment provided figures for this of euro10000

03) Health and safety performance

European Agency for Safety and Health at Work ndash EU-OSHA 30

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 32: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

This section of the proforma was completed by all establishments Working days lost due to ill-health over the period tended to be provided for all staff rather than broken down for management and employees

Between January 2011 and December 2011 seven work accidents were reported six of which occurred in two large producing establishments There was one fatal accident but this occurred in a car accident that took place outside of the establishment The working time lost due to work-related accidents ranged from ten to 21 days over the period Working days lost due to ill-health ranged from 05 to 129 days over the period as follows for micro establishments from 06 to 38 days for small establishments from 04 to 72 days for medium establishments from 07 to 70 days and for the large establishments from 71 to 129 days

15 Summary and conclusions In this section we draw out the general conclusions and key points about the questionnaire that emerged from the interviews in Bulgaria

Some technical issues emerged in different sections of the questionnaire In addition to specific issues with individual questions there were some common themes concerning

Use of terms which could be interpreted in multiple ways Participantsrsquo desire for a greater range of response options and more mid-point options One question answered as two different questions by the respondents Hypothetical positive answers The main technical issues for each section of the survey are summarised in turn below

11115 Approach to management of health and safety The questions concerning health and safety management were well understood by the respondents In answering questions MM155ER200 most interviewees were able to describe a health and safety policy and many also explained their management systems and action plans However for some respondents the meaning of an lsquoestablished management systemrsquo was not clear and some assumed this question asked whether they had received certification on their approach to health and safety

Questions MM156ER202 on how much impact the policy has on OSH in the establishment was generally well understood but some found the extent of impact difficult to rate and thought the question should specify which criteria to use Several respondents interpreted some in the response option to mean lsquominorrsquo Questions MM159ER214 on the degree of involvement of line managers and supervisors in OSH was interpreted as being more about the OSH activities these individuals performed than how much they cared for or were engaged with this subject

11116 Levels of concern with OSH risks With regard to questions MM200ER250 there were different interpretations of lsquoconcernrsquo where it either related to the presence of risks the management of risks or the severity of risks Several respondents mentioned that item 1 (dangerous substances) was too broad as some substances in their establishment were of concern whereas others were not

Again a few respondents interpreted lsquosomersquo concern to mean a lsquominorrsquo concern and therefore would have liked a response option in the middle of the scale

11117 Approach to risk assessments Questions MM161ER207 on whether risk assessments are carried out were well understood by respondents from all establishments The term lsquoregularlyrsquo was generally understood to mean lsquoreoccurring within a specific time periodrsquo but the duration of this period varied greatly With regard to question MM163 on when these checks are carried out several said that they were prompted by item 2 (requests from employees) but in many cases their responses were hypothetical as no such requests had been made The majority of management representatives were unsure about at least one aspect of question MM164 Item 2 (the way work is organised) was interpreted in different ways and many considered it too broad to answer with simple lsquoyesrsquo lsquonorsquo or lsquonot applicablersquo answers as some

European Agency for Safety and Health at Work ndash EU-OSHA 31

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 33: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative post-test evaluation of ESENER ndash National overview report - Bulgaria

aspects of this were routinely considered whilst others were not In answering question MM166 concerning follow-up actions to these checks several indicated that they had taken actions when in fact these had been brought about by other processes in the establishment A few respondents answered positively to item 2 (changes to the way work is organised) but their answers pointed to actions to improve overall performance rather than health and safety at work

Question ER209 on whether employee representatives have a say in decisions on when and where checks are carried out was well understood but sometimes those who felt they could have a say explained that they had not contributed in any decisions to date A greater range of response options may provide more detailed information on this topic Several of the responses to question ER211 on whether employee representatives were involved in the choice of follow-up actions came from a hypothetical standpoint the interviewees believed that they could have a say but had not proposed anything to date

11118 Drivers of and barriers to management of health and safety There were minor problems in understanding question MM171 concerning drivers for OSH Several respondents felt that item 5 (requirements from clients and concern about the organisationrsquos reputation) covered two separate questions for which their responses varied Most management representatives said that item 6 (pressure from the labour inspectorate) was a major reason for adressing health and safety but for all except one it was not clear that any such pressure had been received Two respondents considered the response options of lsquomajorrsquo and lsquominorrsquo as extreme and wanted an option in the middle of the scale Although item 6 (the sensitivity of the issue) in question MM172 was clear in meaning most did not understand why health and safety would be a sensitive issue so did not consider this a difficulty

11119 Worker participation and involvement Questions on worker participation and involvement in OSH for employee representatives generally worked well

11120 Resources and training in OSH issues This set of questions was also well understood by the employee representatives There were some minor problems with specific items on question ER159 about the types of training received One employee representative found it difficult to answer item 2 (prevention of accidents) because he had received instructions on this but not training whilst another incorrectly included first aid training under this topic Several employee representatives found it difficult to answer item 3 (chemical biological radiation and dust hazards) stating that they had received training on some of these topics but not others Several employee representatives did not understand what was meant by the term lsquoergonomicsrsquo in item 4

11121 OSH and organisational performance Questions concerning OSH and organisational performance were well understood by the respondents but most management representatives did not know how other establishments performed in this regard Some did not feel equipped to state how their establishment compared in terms of business outcomes whilst some from the public sector did not think a question on profit applied to them

11122 Collecting data on OSH resources and performance Collecting health and safety performance data using proformas was a difficult task and in several cases information was incomplete despite management representatives making their best efforts to find all the information required On several proformas the amount of time dedicated to health and safety was incomplete either because this was not known or because it varied greatly from month to month The cost of purchased health and safety services was completed in most cases but providing costs for protective clothing devices and equipment was considered difficult and time consuming Health and safety performance data were provided for all staff rather than broken down by management and employee

European Agency for Safety and Health at Work ndash EU-OSHA 32

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance
Page 34: Qualitative post-test evaluation of ESENER – National ... · Analysis of the Situation and actors for Development of SMEs in Bulgaria: 20112012 Bulgarian Small and Medium - Enterprises

Qualitative Post-test Evaluation of ESENER Bulgaria Establishment Reports 1

TE-RO

-13-105-EN-N

European Agency for Safety and Health at Work E-mail informationoshaeuropaeu httposhaeuropaeu

The European Agency for Safety and

Health at Work (EU-OSHA) contributes to

making Europe a safer healthier and more

productive place to work The Agency

researches develops and distributes

reliable balanced and impartial safety and

health information and organises pan-

European awareness raising campaigns Set

up by the European Union in 1996 and

based in Bilbao Spain the Agency brings

together representatives from the European

Commission Member State governments

employersrsquo and workersrsquo organisations as

well as leading experts in each of the EU-27

Member States and beyond

  • Table of contents
  • Introduction
  • 1 Bulgaria National Overview Report
    • 11 National context
      • 111 Section 1 Structure of the Bulgarian Economy
      • 112 Section 2 Human resources
      • 113 Section 3 Overview of the public OSH infrastructure
      • 114 Section 4 Overview of the OSH obligations for enterprises
      • 115 Section 5 Approach to risk assessment
      • 116 Section 6 Drivers for taking measures on OSH
      • 117 Section 7 Level of concern at national level with OSH risks
      • 118 Section 8 OSH training of employee representatives
      • 119 Section 9 Worker involvement and participation in OSH
        • 12 Participants
        • 13 Main findings
          • 131 Management of health and safety
            • 1111 Technical points
            • 1112 Interpretations
              • 132 Levels of concern with OSH risks
                • 1113 Technical points
                • 1114 Interpretations
                  • 133 Approach to risk assessments
                    • 1115 Technical points
                    • 1116 Interpretations
                      • 134 Drivers and barriers to measures on OSH
                        • 1117 Technical points
                        • 1118 Interpretations
                          • 135 Worker participation and involvement
                            • 1119 Technical points
                            • 11110 Interpretations
                              • 136 Resources and training in OSH issues
                                • 11111 Technical points
                                • 11112 Interpretations
                                  • 137 OSH and organisational performance
                                    • 11113 Technical points
                                    • 11114 Interpretations
                                        • 14 Collecting health and safety performance data
                                        • 15 Summary and conclusions
                                          • 11115 Approach to management of health and safety
                                          • 11116 Levels of concern with OSH risks
                                          • 11117 Approach to risk assessments
                                          • 11118 Drivers of and barriers to management of health and safety
                                          • 11119 Worker participation and involvement
                                          • 11120 Resources and training in OSH issues
                                          • 11121 OSH and organisational performance
                                          • 11122 Collecting data on OSH resources and performance