Health & Safety Service Plan
2011-2012 www.southwark.gov
.uk Drawn up in accordance with the Health and Safety Commission’s Guidance issued under Section 18 of The Health and Safety at Work etc Act 1974 Approved by the Cabinet Member for Finance, Resources and Community Safety xxxxx 2011
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Introduction
This is Southwark’s occupational health and safety service plan focused on the
health and safety enforcement function. It covers all elements of health and safety
relating to premises and functions falling within this local authority’s remit for health
and safety enforcement. The Service Plan also covers objectives relating to non-
enforcement activity, including advice and education to business and partnership
working.
The Service Mission statement for the whole of Environmental Health is
included within this service plan; the objectives are designed to reflect and contribute
towards the achievement of the fairer future vision within the Council Plan, and the
six key principles that underpin it.
This service plan is an expression of the authority’s commitment to the development
of the occupational health and safety team and is a requirement of the Health and
Safety Executive (HSE) as the body that monitors and audits local authorities’
activities on health and safety enforcement.
The format and content of this service plan incorporates mandatory guidance
issued by the HSE under Section 18 of The Health and Safety at Work etc. Act 1974.
Consistency in plan format enables the HSE to assess how we are doing and allows
for local authorities to compare and contrast service plans for any fundamental
performance reviews under the local government Best Value agenda.
David Littleton
Business Unit Manager Environmental Health & Trading Standards
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Contents
Section One -
Paragraph Service Aims and Objectives Page
5
1 Mission Statement 5
3 Aims and Objectives 5
5 Contributions to Council Plan 5
Section Two Background 7
15 Borough Overview 7
18 Southwark’s Profile 7
24 Organisation Structure 8
25 Cabinet Member Structure 8
28 Directorate Organisation 8
30 Team Organisation 9
Section Three Service delivery 9
32 Scope of the Occupational Health & Safety Service
9
34 Night-time Economy Team 10
37 Demands on the Service 10
39 Service Hours
42 Enforcement policy 11
47 Olympics 2012 12
51 Proactive Planned Inspection Programme 12
65 Health & Safety Inspection Programme 15
72 Revisits 16
74 Non-programmed Inspections 17
76 Health & Safety Related Complaints 17
78 Reports of Accidents, Diseases and Dangerous Occurrences
17
80 Topic Based Inspection Work Plan 17
85 Lead/Primary Authority Principles 19
88 Advice to Businesses 19
91 Liaison with other Organisations 20
Section Four Resources 20
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95 Financial Allocation 20
98 Staffing Allocation 21
101 Staff Development Plan 22
106 Section 18 Compliance 22
108 Regulators Development Needs Analysis RDNA 23
Section Five Quality Assessment 23
111 Quality assessment 23
Section Six Review 24
114 Review Against the Service Plan 24
118 Identification of any Variation from the Service Plan 25
125 Areas for Improvement 25
Appendix 1 Organisational Chart- Occupational Health & Safety Team
26
Appendix 2 interventions plan 28
Appendix 3 timetable of project and topic work 29
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SECTION 1: SERVICE AIMS AND OBJECTIVES
1 Service Mission Statement
2. The environmental health and trading standards service mission statement is:
‘To enhance and protect the health, safety, economic welfare and
environment for people and stakeholders in Southwark’
3. Aims and objectives
4. In relation to occupational health and safety, it seeks to pursue this through a
number of key aims and objectives which include: -
• To ensure that the health and safety of those who live, visit, and work within
the borough is not affected by the work or activities undertaken by any
employer – ‘so far as is reasonably practicable’.
• To secure so far as is reasonably practicable compliance with health and
safety legislation and seek to ensure that regard is had to Approved Codes of
practice and guidance issued by the Health and Safety Executive.
To support the HSE strategy “The Health and Safety of Great Britain – Be
Part of the Solution”
• To develop new ways to establish and maintain an effective health and
safety culture in a changing economy, so that all employers take their
responsibilities seriously, the workforce is fully involved and risks are
properly managed;
• To do more to address the new and emerging work-related health
issues;
• To achieve higher levels of recognition and respect for health and safety
as an integral part of a modern, competitive business and public sector
and as a contribution to social justice and inclusion.
5. Contributions to the Council Plan
6. In its council plan, Southwark council highlights its promises of what it will
deliver as a council. It outlines the new relationship between the council and
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residents, built on trust, openness and transparency in all it does and
absolute commitment to creating a fairer future for all.
7. The occupational health and safety team works to the Council’s medium term
objectives and supports the council plan in the following areas:
8. Being more transparent – by following best practice as promoted by the
Better Regulation Executive and the Hampton Review of regulatory
inspections and enforcement. The service will be:
• Proportionate in activity intervening only when necessary and using remedies
that are appropriate to the risk posed, and costs identified and minimised.
• Accountable and be able to justify decisions made and be subject to public
scrutiny.
• Consistent and open and will try to keep regulations simple and user-friendly
within the limitations of legislational requirements, which are often out of the
control of the service.
• Targeted, and focused upon problems and minimising side effects.
9. Creating a fairer borough – by ensuring that Southwark continues to be a
place where people are treated fairly and have the opportunity to get involved;
by providing timely health and safety advice and regulation to local
businesses and contributing to a level playing field locally.
10. Making southwark a place to be proud of- by assisting premises and
businesses through support, education and enforcement to improve and
comply with health and safety regulations, so improving quality of life now and
for future generations for the people of Southwark making the borough a
better place to live, work, invest in and visit.
11. Realising potential- by recognising that good occupational health and safety
regimes has a secondary effect, as the goal of all programs is to foster a safe
work environment, which in turn protect co-workers, family members,
employers, customers, suppliers, nearby communities, and other members of
the public who are impacted by the workplace environment.
12. Spending money as we would our own –by continuing to employ new and
modern ways of working to ensure our service is flexible, responsive, efficient
and effective representing excellent value for money.
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13. Transforming public services- by being committed to continuous
improvement in service delivery, and addressing the needs of our
communities by using our resources innovatively and to best effect.
14. SECTION TWO - BACKGROUND
15. Borough Overview
16. Alongside the City of London, Southwark is one of the oldest areas of
London, with a history stretching back to Roman times. The borough is also
one of the busiest and most demanding metropolitan authorities in the
country. It is a borough of tremendous opportunity, situated as it is with its
northern boundaries opposite the prosperity of the cities of London and
Westminster. But it also has all the challenges and interest of an inner city
area; low incomes, high state dependency and complex social problems.
17. Southwark is undergoing one of the most ambitious social and physical
regeneration programmes of any authority in the country, together with a
wide range of initiatives aimed at improving educational standards, housing
and the environment, reducing crime and tackling health inequalities.
18. Southwark’s Profile
19. Southwark’s population reached 285,500 in 2010 and is believed to be
growing by as much as 4,000 per year, with a projected population of over
310,000 by 2016. The population has a young demographic profile and
demonstrates rich ethnic and cultural diversity, with around one-third (90,600)
of the population from black or ethnic minority communities. Southwark is
arguably one of the most diverse areas in the capital.
20. Southwark is made up of eight very distinctive urban neighbourhoods that
extend along the river Thames and down into South East London. The
borough also encompasses some of London's top attractions, creative
hotspots, scenic villages and acclaimed green spaces.
21. Southwark has a wide-range of leisure and cultural opportunities; and makes
a significant economic and employment contribution to the local community.
The north of the borough is recognized as one of London’s fastest growing
tourist quarters and a thriving business location.
22. Alongside the borough’s rich vibrancy, Southwark has its fair share of
challenges. The Index of Multiple Deprivation (IMD) 2007 shows Southwark
as the 27th most deprived local authority nationally and 60% of the borough’s
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wards are among the 10% most deprived in the country. Consequently, the
borough faces many challenges associated with meeting the complex health
and social needs of an inner-city population.
23. To meet our challenges, Southwark has a large number of physical
regeneration programmes across the borough, alongside a wide range of
initiatives aimed at improving educational standards, reducing crime and
improving health, housing, social care and the environment.
24. Organisational structure
25. Cabinet Member Structure
26. As part of the modernising Local Government Agenda, the Council has
adopted a Cabinet style of Local Government, embracing a new Constitution
and new Executive arrangements, based on a Leader and Cabinet model.
27. The current Cabinet consists of –
Leader of Council
Deputy leader of Council and cabinet member housing management.
Cabinet member for regeneration and corporate strategy
Cabinet member for health and adult social care
Cabinet member for transport, environment and recycling
Cabinet member for finance, resources and community safety
Cabinet members for children’s services
Cabinet member for equalities and community engagement
Cabinet member for culture, leisure sport and the Olympics
28. Directorate Organisation
A corporate management team led by the Chief Executive and Strategic
Directors undertakes the day-to-day operation of the Council. Council
services are currently provided by seven directorates covering all service
functions.
29. The community safety and enforcement division, which includes the
Environmental Health and Trading Standards Services, is situated in the
Directorate of the Environment. The Head of community safety and
enforcement has delegated responsibility for all matters relating to health and
safety. Individual post holders have been given direct delegation to take any
action and exercise functions in relation to the Health and Safety and other
relevant acts.
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30. Team Organisation
31. The occupational health and safety team forms part of an amalgamated
health and safety, licensing and environmental protection unit (HSLEP), and
sits within the division’s environmental health and trading standards business
unit. Occupational health and safety enforcement activities are carried out by
environmental health officers within the occupational health and safety team;
the structure of this team is provided in appendix 1.
32. SECTION THREE- – SERVICE DELIVERY THE SCOPE OF THE
OCCUPATIONAL HEALTH & SAFETY SERVICE
33. The occupational health and safety team is responsible for undertaking the
following work activities:
• To carry out a risk based health and safety inspection programme having
regard to HELA Circular (LAC) 67/2 (rev 2) (10 March 2010);.
• To investigate and resolve complaints about breaches of health and
safety legislation having regard to HSE’s guidance regarding ‘Incident
selection criteria’ stipulated under HELA Circular LAC 22/13.
• To investigate and take appropriate action following receipt of a
notification of reportable accidents, diseases or dangerous occurrences.
• To investigate and take appropriate action following receipt of asbestos
removal notifications and unsatisfactory lift inspection reports.
• Attend premises where allocated to local authorities and carry out
inspections, special visits, and revisits in relation to results and other
investigations.
• Take informal or statutory action including notices, seizure, prohibition,
prosecution or issuing formal cautions to secure compliance with the
legislation having regard to the Service’s enforcement policy and HSE’s
guidance on the ‘choice of appropriate enforcement procedure’.
• Maintain an accurate database of health and safety premises in the
Borough and record information to enable the completion of the annual LAE1
return to the Health and Safety Executive’s (HSE) Local Authority Unit.
• Receive and act upon all warnings sent by the HSE about
dangerous practices or equipment as appropriate.
• Provide advice and assistance to businesses and the public on health and
safety issues.
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• Provide or arrange the provision of health and safety training courses
and one off courses designed for specifically targeted groups and promote
both trade and public education of health and safety issues.
• Comment on proposed health and safety legislation, codes of practice
and other official documents as necessary and as requested.
• To liaise with other organisations such as the Chartered Institute of
Environmental Health, HSE, the London Chief Officers
Health and Safety Group and the Fire Authority to ensure a consistent
approach to the enforcement of health and safety issues.
34. Night- time Economy Team
35. Approval was received to commence a night-time economy team within EHTS
service comprising a multi-agency partnership. The team became operative in
April 2011. The primary aim of the team is to address a range of community
safety issues such as alcohol related violence, crime and disorder and anti
social behaviour associated with night-time trading operations in a target area
of the Borough. However, it is well established that these occurrences
invariably occurs on, or around premises whose trading operations extend
well into the night. These businesses are not likely to have received health
and safety law enforcement visits during such late trading hours and therefore
potential compliance issues may not have been identified.
36. The team consists of police, licensing officers, food safety officers, health and
safety officers and wardens. Health and safety officers will therefore be able
to undertake official health and safety interventions on theses premises
which, together with a range of other coordinated enforcement measures will
secure needed improvements.
37. Demands on the Service
38. Demands on the Service include: - carrying out proactive inspections and
interventions based on risk categorisation, carrying out health and safety
projects targeting certain types of premises and activities for inspections and,
responding to and investigating work related accidents and incidents. Planned
inspections account for the major demand.
39. Service Hours
40. The service is currently provided from the Chaplin Centre, Thurlow Street,
SE17 2DG, but may be relocated to the council’s main Tooley Street office
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before the end of the financial year. The office is open to members of the
public between the hours of 0845 and 1700 Monday to Friday. Telephone
contact is available 24 hours, 7 days a week via the customer contact centre
on 020 7525 2000, as is fax (020 7525 5007) and email
via: [email protected]. General health and safety advice and
information can be found on the council’s web site at
http://www.southwark.gov.uk/info/100002/business/722/health_and_safety_at
_work
41. The service will also carry out inspections and investigations outside of office
hours, as necessary. A standby arrangement exists to respond to any public
health emergency occurring at evenings and weekends. This is accessed via
the council’s emergency duty officer.
42. Enforcement Policy
43. We regulate through a mix of enforcement and advisory action. Our efforts
are targeted at those situations which present the greatest risk to health.
The Authority has a documented enforcement policy that sets out how the
occupational health and safety service will deal with infringements of the
legislation and will intervene to bring the operation back into compliance.
44. Southwark is a signatory to the enforcement concordat. This forms the core of
the council’s current enforcement policy. The council’s enforcement policy
can be found at
:http://www.southwark.gov.uk/site/scripts/google_results.php?q=enforcement
+policy Alternately a paper copy is available from the Chaplin centre.
45. Local authorities must also follow the HSE’s Guidance on Enforcement
Practice (LACS 22/18: Enforcement Management Model (EMM) and 22/20:
New Enforcement Guide (England and Wales) and Enforcement Handbook
Scotland). Where a simple caution is being considered, additional guidance is
provided in LAC 22/19.
46. Additionally, on 6 April 2008, the then department for business enterprise &
regulatory reform’s (BERR) (now the department for business innovation and
skills (BIS)) “Regulator’s Compliance Code” came into force. The health and
safety team is mindful of the code throughout all its activities.
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47. Olympics 2012
48. The 2012 Olympics in London will attract more visitors to the capital. While
the Borough does not host any of the games, Southwark recognises the
potential impact of the games on the local economy, infrastructure, the
population and its services. The Cultural Olympiad is also being held on the
South Bank and will impact on Southwark resulting in increased number of
visitors to the Borough. With more people visiting the Borough, the
occupational health and safety team anticipates an increase in service
requests and accident notifications.
49. The service is working closely with all its partners, including the Public
Service Operation Group (PSOG) to identify and access any available funding
to secure necessary resources to optimise preparation for the games. The
occupational health and safety team is working closely with the Chartered
Institute of Environmental Health (CIEH) and the London Occupational Health
& Safety Group (LOHSG) to ensure a consistent and well-coordinated London
wide approach to health and safety law enforcement during the games.
50. In preparation for the events, Southwark occupational health & safety team
will endeavour to focus on the following areas:-
• Education and training- for both health & safety law enforcers and business
operators.
• – Full inspections of hotels in the borough to give advice and take any
necessary enforcement action. Inspections will include examination of lifts
and circulation spaces used by guests.
• Legionella Working Group – in partnership with the Health Protection
Agency formulate a working Protocol for preventing and dealing with
cases of Legionella
51 Proactive Planned Inspections Programme
52. There are currently 10,959 known premises at which this Local Authority
are responsible for enforcing health and safety legislation. These premises
can be categorised as shown in figure 1: -
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53.
Description No.
Retail Shops 1,574
Wholesale shops, warehouses and fuel storage depots
276
Offices 1,416
Catering restaurants and bars 1,371
Hotels, campsites and other short stay accommodation
82
Residential care homes 289
Leisure and cultural services 822
Consumers services 122
Other premises (description not known) 3965
HSE enforced premises 1,042
Total 10,959
Figure 1 Number of premises in borough by type 54. Inspections have been carried out in 2316 of the above-mentioned known
premises and a risk rating has been assigned to them in accordance with the
nationally recognised scheme. As a consequence of the new risk rating
system being implemented as a result of Priority Planning Guidance LAC 67/2
(rev 2) premises have had their ratings reassigned in accordance with the
table in figure 2 below.
55. Although records indicate that this proportion of premises have been
inspected, undoubtedly, a very high proportion of the premises will have
changed hands since many of the inspections would have been carried out
over ten or more years ago. With only limited resources available only the
data currently on the database may be used. However, in 2011 the authority
will be liaising with Southwark’s business rates team to identify and inspect
businesses not currently featuring on its database.
56. All other business sectors are overseen by the HSE. These include factories;
farms; building sites; nuclear installations; mines; schools/colleges;
fairgrounds; gas/electricity/water systems; hospitals and nursing homes;
government premises (including local authority); and transport systems.
57. In addition to those premises shown above, the service also deals with 49
premises that are registered under the Notification of Cooling Towers and
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Evaporative Condensers Regulations 1992. Furthermore, as responsible
authority under the 2003 Licensing Act, the service may consider up to 150
applications for premises licences per year.
58.
Old LAC 67/1
Categorisation
New Category Description
A A Highest Risk
B1 B1 Medium Risk – 1
B2 and B3 B2 Medium Risk -2
B4 and C C Lowest Risk
Figure 2: Old and new categorisations of risk
59. In the transference of premises ratings between the old and new schemes
inspection dates for Local Authority Circular LAC 67/1 (rev 3) ‘A’ and ‘B1’
category premises will be carried over. However, under this new system
premises now rated as either a ‘B2’ or ‘C’ do not need to be subject to a rigid
inspection regime. Furthermore, it is expected that category ‘C’ premises will
now fall outside of any inspection-based intervention. As a consequence, the
Borough will carry out 126 routine proactive inspections in all new category ‘A’
and 108 inspections in ‘B1’ rated premises.
60. In relation to unrated premises of which there are
7601, 755 will receive an intervention by way of an inspection to determine
the ‘nature of the undertaking’ should they be currently trading. In addition,
where the authority has agreed to adopt a number of topic-based inspections
as part of the All London Health and Safety Group (ALHSG) then these will
also feature as part of the inspection program. Within these obligations
(discussed further in this document) the Authority plans to undertake 989
inspections in total.
61. The risk rating profile of current businesses that have been inspected
previously is shown in figure 3 below: -
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62.
New Risk Rating Band No Of premises
A 126
B1 216
B2 886
C 1088
Unrated 7601
Total 9917
Figure 2: Number of premises in new rating bands 63. The system by which premises are rated has also changed in accordance
with the Local Authority Circular. The new rating process consists of
evaluating 4 different elements as they relate to a work activity. A rating value
is then assigned to each of these 4 elements: -
• Confidence in management
• Safety performance
• Health performance
• Welfare compliance gap
64. After reviewing all the findings from the inspection or intervention, these
separate ratings are assigned to the premises and recorded appropriately.
There is no longer any cumulative addition of individual question scores as
was adopted by LAC 67/1. The inspector's assessment now represents a
balance of the findings from all of the issues identified. Inspectors will also
take into account that some topics may be more important than others at
particular premises (such as the risk of dermatitis within a hair dressing
salon). Thus, if a company performed badly in a key area, the overall safety
and health performance ratings should be heavily influenced by this, even if
standards are good in more minor topic areas.
65. Health and Safety Inspection Programme
66. The system by which premises are proactively inspected has been
explained earlier along with the categories of premises to be inspected. The
guide as to the appropriate inspection frequencies is contained within HELA
Circular LAC 67/2 (revision2) as shown in figure 4 below.
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67.
Description New
Category
Rating Score Intervention Frequency
Highest Risk A Score of 5 or 6 on any risk
Inspection of not less than once a year
B1 Score of 4 on any risk
Premises for inspection (e.g. programme directed; new employers/premises; local priority programmes. Those premises without an intervention contact within 18 months to be reviewed.
B2 Score of 3 on any risk
Premises for intervention (e.g. programme directed; new employers/premises; local priority programmes)
Lowest Risk C Score no greater than 2
Use non-inspection intervention methods\techniques
Figure 4: Frequency of Interventions
68. All ‘A’ rated premises will be visited at least once every 12 months (this
may be part of a programme directed approach or in accordance with any
reactive work and the Incident Selection Criteria (LAC 22/13). If at an ‘A’ rated
premises conditions have either deteriorated or not improved since the last
visit, enforcement action will be strongly considered to achieve improvements
in conditions and systems, thereby enabling the premises to be re-rated to a
lower category.
69. If a premises that was previously rated ‘B1’ is re-rated as an ‘A’, the
chosen intervention(s) will aim to reduce the risk profile of the business or
duty holder. There is an expectation that enforcement action will be taken in
these circumstances. It is not acceptable for a premise to be rated at a higher
risk level with no relevant intervention-taking place before a revisit is made.
This also applies if a premises moves from ‘B2’ to ‘B1’.
70. The Borough will undertake appropriate interventions with premises rated
as a ‘B1’ and as necessary where they form part of any topic-based priority
program. There is no expectation that all B1 premises will be inspected within
a single work year, however, the Borough will undertake this given their small
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number. If they were not inspected during year 1 then they would be
inspected in the first half of year 2.
71. During visits officers will also check that smoke free legislation is being
complied with i.e. the display of appropriate signage and that smoking is not
being allowed in public places and enclosed spaces.
72. Revisits
73. It is estimated that of those premises which receive a proactive inspection
an estimated 20% will require revisits.
74. Non-programmed Inspections
75. It is estimated that there will be non programmed inspections for new
premises to be carried out during 2011/12. These will be inspected in addition
to the 989 total.
76. Health and Safety Related Complaints
77. The Service seeks to investigate all health and safety related complaints
within the target period. It is estimated that there will be 200 such complaints
during 2011/12.
78. Reports of Accidents, Diseases and Dangerous Occurrences
79. Notifications of accidents, diseases and dangerous occurrences are all
considered upon receipt as soon as is reasonably practicable. A decision as
to whether a full investigation is required is then made in accordance with the
‘Incident Selection Criteria’ (to be found within LAC 22/13). It is estimated that
there will be 200 such notifications during 2011/12.
80. Topic Based Inspections Work Plan
81. As part of the ALHSG and in cooperation with the Health and Safety
Executive the Borough will undertake a proportion of topic-based inspections.
These are allocated to the Borough and are indicated below.
82. National Priorities
• Asbestos – Asbestos is currently biggest occupational health killer, killing
around 4000 people a year and rising. In 2010-11 the team took the
opportunity to promote an HSE country wide initiative to raise awareness of
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the duty to manage asbestos. Officers also disseminated information to the
business community on the Control of Asbestos Regulations 2006. The work
done in 2010/11 will be followed up by revisits and enforcement as necessary
to the premises visited. New premises will also be identified for inspections.
This remains a high priority area for the Health and Safety Executive and
local authorities alike. 50 inspections are envisaged.
• Slips, Trips and Falls –– Slips and trips are the most common workplace
hazards and make up over a third of all major injuries. Over 10,000 workers
suffered serious injury because of a slip or trip last year. The team will target
slips and trips risk in the catering and hotel industry, care homes, food retail,
building and plant, retail, warehouses and cleaning companies during
inspection visits.
• Contribution toward European Health and Safety Week - focussing this
year on safe maintenance in the manufacturing industry; to rraise awareness
among businesses and their workers and to help them implement simple
solutions. Also, to promote 'one stop shop' safe maintenance section of the
HSE website
83. Local Priorities
• Work Related Violence in Licensed Premises – this is a local priority to
contribute to making Southwark a safe place to live, work and visit.
• Places of Worship – Many unauthorised places of worship are operating
from unsuitable and substandard accommodation, regardless of
designation, resulting in immediate health and safety risks for both
members of the congregation and the general public.
• Age related sun-bed use – New regulations which came into force on
9th April 2011 restrict the use of sun-beds to those who are 18 years or
over. Based on the information gained from the tanning project in 2010/11
looking at sun bed safety focussed visits will be made to premises offering
tanning and enquiries made as to what systems are in place to restrict
use.
• Hotels / Hostels – Compliance in advance of London Olympics 2012
(see 3.6.3)
• Legionella - Compliance in advance of London Olympics 2012 (see
3.6.3)
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• Railway Arches Industrial Estates – Assess the occupational health
and safety risks posed on industrial estates, in particular, LPG storage
and use and fire risks. Also to identify any wider community safety risks
posed by activities undertaken in railway arches.
• Poundshops – There has been an increase in these types of premises
presenting unsafe storage and displays, slips, trips and falls, risk of fire
through overstocking including manual handling risk both to employee
and members of the public. Work with Buddy borough partnership officers
– Camden & Islington to deliver a joint project.
84. The number of topic–based inspections and topic–based revisits cannot
be strictly ascertained as this depends on the number of premises available to
visit within the work areas identified. However, these interventions will be
included within the number of premises identified for inspection.
85. Lead/Primary Authority Principles
86. Lead and Primary Authority gives companies the right to form a statutory
partnership with a single local authority, which then provides robust and
reliable advice for other councils to take into account when carrying out
inspections or dealing with non-compliance. The Council endorses this
approach to health and safety.
87. We are currently lead authority for the Save the Children Fund and are
actively in talks with securing primary authority arrangements with The
Salvation Army. The Primary Authority allows the service to make reasonable
charge for the service. The team will actively explore such arrangements
where suitable candidates are identified
88. Advice to Businesses
89. The service encourages businesses to seek advice. It is preferable to
resolve problems through co-operation at an early stage before the situation
becomes serious, when formalised enforcement action may have to be
considered. The service would like to be perceived by businesses as
supportive and helpful.
90. Advice is mainly delivered on a one-to-one basis whilst officers are
carrying out inspections and other visits but may also be given via telephone
calls, seminars, news letters, leaflets, letters or telephone calls. Officers give
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advice in accordance with recognised guidance and codes of practice.
Currently there are no specific health and safety related business
partnerships or forums in operation.
91. Liaison with other Organisations
92. Arrangements are in place to ensure that enforcement action taken by the
Service in the Southwark Borough is consistent with enforcement action
carried out in the neighbouring local authorities. This is achieved by: -
• Active support of the London Environmental Health Managers Group which
includes regular meetings and contact between authorities.
• Partnership working with the Health and Safety Executive e.g. joint
inspections.
• Peer review bench marking exercises with other London Local Authorities.
• Regular discussions amongst officers in respect of HSE guidance.
• Attending Chartered Institute of Environmental Health’s branch meetings,
monitoring and responding to e-mail messages on the Environmental Health
Computer Network (EHC Net).
• Liaison as deemed necessary with Southwark Council’s trading
standards service, food and licensing teams,
93. Section Four – Resources
94. Following a service review and reorganisation of the community safety and
enforcement division, resources have been reduced by 8% (against a
background of a 40% reduction across the wider Division). From 1 April 2011
the team has 10 staff dealing with food safety matters. There are 2 vacant
posts which, the service intends to fill at the earliest opportunity subject to
available funding. Administrative support is provided by 1 member of staff.
95. Financial Allocation
96. The financial allocation for 2011/12 iis shown in figure 5 below: -
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97.038-ENVIRON
BUDGET £1000’s
Salaries 266
Running costs 55
Recharge 41
Total 362
Income 0
TOTAL 362
Figure 5: Health & safety team budget
98. Staffing Allocation
99. Staffing allocation for all occupational health and safety law enforcement is
given in figure 6 below:
100
Designation Number in post
Number of Vacancies Competencies Necessary
Unit Manager 0.33 0
Team Leaders 0.5
0
Principal Environmental Health Officers
1.8 0
Health and Safety Inspections
Complex accident/incident investigations including fatalities.
Lead officer for major projects
Service of formal seizure, improvement and prohibition notices.
Principal Enforcement Officers
1 0
Health and Safety Inspections
Complex accident/incident investigations including fatalities.
Lead officer for major projects
Service of formal seizure, improvement and prohibition notices.
Enforcement Officers 2 0
Health and Safety Inspections
Non complex accident/incident investigations
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Minor projects lead officer
Service of formal seizure and improvement notices.
Totals 5.6 0
Figure 6 staffing Allocation
101. Staff Development Plan
102. The council is Investors in People (IIP) employer.
103. Training needs of each staff member is documented through the performance
management process and recorded on each individuals work plan and on an
excel spreadsheet held centrally.
104. Staff involved in health and safety enforcement work are required to be
assessed using the HSE RDNA and hold a learning portfolio. The tool also
suggests that each officer receives appropriate identified training each year
as a minimum to maintain competency. The service ensures this by using:-
• In house documented competency based training
• Participation in relevant external learning and development courses
• Regular review against the service’s own performance management learning
and development scheme.
105. In addition, the Chartered Institute of Environmental Health (CIEH), ,requires
its members to undertake twenty hours of training each year as part of the
Continuing Professional Development (CPD) scheme. 5
106. Section 18 Compliance
107. Both the Health and Safety Executive and Local Authorities have a duty to
‘make adequate arrangements for enforcement’ under Section 18 of the
Health and Safety at Work Act. Local Authorities are required to perform this
duty in accordance with mandatory guidance from Health and Safety
Commission. To this end ‘Local Government Regulation’ has in partnership
with the Health and Safety Commission produced a toolkit with which Local
Authorities may assess their current level of service against a prescribed
standard. This in turn enables an action plan to be produced in order to
address any shortcomings identified and participate in a joint peer review
process. The Borough completed this assessment in 2010/11 and will receive
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peer review upon it in 2011/12. Any shortfalls identified via the self-
assessment and peer review processes will be actioned.
108. Regulators Development Needs Analysis RDNA
109. Under Section 18 every enforcing authority must: -
(a) have a system to train, appoint, authorise, monitor and maintain a
competent inspectorate, and
(b) have a documented policy and procedures covering appointment,
authorisation and competence.
110. To meet this standard the authority must put in to place systems for
appointing and authorising suitably qualified inspectors under Section 19
HSWA; implementing standards of competence, and making arrangements
so that competence levels may be maintained. This will require appropriate
officer training.
111. SECTION FIVE – QUALITY ASSESSMENT
112. Monitoring measures are in place to assess performance, particularly having
regard to the number of visits/inspections carried out on a month by month
basis and is monitored by the business unit manager of EHTS. The main
means by which quality is assed is as follows:
• Monitoring and support provided by experienced principal enforcement
officers
• Monitoring of notices and letters
• Shadow inspections
• Post inspection audits of records, risk rating, inspection reports and
enforcement decisions
• Regular team meetings
• Regular Technical Meetings
• Regular one-to-one work reviews
• A Section 18 assessment of the health and safety service
• Implementation of the RDNA tool for officer competencies 7: REVIEW
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113. SECTION SIX - REVIEW
114. Review against the Service Plan
115. Under the current performance management framework service plans
include a number of targets and performance indicators. During the course of
the year Environmental Health formally monitors its performance against
targets and on a monthly and quarterly basis. Performance indicators in
relation to the occupational health and safety service delivery will be reported
to the Director of Environment every month. The occupational health & safety
team’s 6-year performance as per CIPFA returns is set out in figure 7 below.
116.
Health, safety & welfare
2005-2006
2006-2007
2007-2008
2008- 2009
2009-2010
2010-11
No. accident notifications received
232 266 324 305 261 217
No. other complaints and requests for service
424 627 331 350 252 343
Total no. inspections carried out
893 516 534 705 784 827 (+ 605 other interventions)
No. written warnings
267 355 291 355 447 658
No. improvement notices served
91 181 127 125 128 246
No. prohibition notices served
9 67 25 32 30 38
No. summons served and formal cautions
1 8 13 8 0 9
figure 7-year performance as per CIPFA returns
117. Figure shows that 2010-11 saw
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• A 5.5% increase in the total number of inspections carried out over 2009-10;
• In excess of 600 other interventions;
• A reduction in he number of unrated premises by more than 800;
• A reduction in the numbers of accident notifications received for the third year
running;
• A rise in other service requests back to 2007-8 / 2008-9 levels; and
• The highest levels of enforcement notices served across the period covered;
118. Identification of any Variation from the Service Plan
119. The 2010-11 service plan was prepared on the basis of an additional 3
staffing resources being provided to the team. Due to the need for the
business unit to make savings during the course of the year, these resources
did not materialise in full. The team benefitted from one extra resource
120. Consequently, targets set for inspections and other interventions could not be
met in full, but were met proportionately, given the staffing resource available
within the team.
121. It was also intended that 2010-11 would see all unrated premises brought into
the new HSE risk rating system. This did not happen, primarily due to
problems with the IT support systems. Firstly, it was anticipated that the new
version of the rating system would be incorporated into the services database
at an early stage in the year. However, the new software release which
incorporated the changes, was not received until the end of the financial year.
Work on desktop rating of unrated premises by business sector will follow
once the new rating system is operable.
122. Despite this delay, the number of unrated business premises was reduced by
800 through direct intervention methods. Cross-referencing of business
databases is also in progress so as to provide the best available information
on current businesses before desk top rating exercise is concluded.
123. The service did achieve a 8% increase in the numbers of premises within the
risk rating system through physical intervention and otherwise completed all
other programmed interventions and topic work.
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124. The performance levels for inspections during the period 2011/2012 will be
reported at year end. At the end of 2010-2011 the service performance
remained in the bottom quartile as compared to other London authorities.
125. Areas for improvement 2011-12
126. Areas of improvement for 2010-11 and beyond are:
• To bring the estimated 7,601 currently unrated premises into the
inspection programme by 2015 and subject to risk assessment;
• To improve the councils performance in this area from bottom quartile to
top quartile, and subsequently protect the council’s reputation;
• To initiate necessary IT support updates and development;
• To further examine potential for data matching with internal and external
partners, to ensure that the most current and relevant information on
business activity is used to shape and facilitate joint working initiatives.
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Appendix 1: Organisational Chart - Occupational Health & Safety Team
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Health and Safety Team
Farhad ChowdhuryPrincipal Enforcement Officer
Samantha CoePrincipal Enforcement Officer
Ian FarringtonPrincipal Enforcement Officer
Mohammed AslamEnforcement Officer
Debra Lawless Enforcement Officer
Sailesh ChudasamaTeam Leader
Health & Safety and Environmental Protection
David FranklinTeam LeaderLicensing
Kirty ReadSenior Unit Support Officer
Richard ParkinsUnit Manager
Licensing, Health & Safety, Environment Protection
David LittletonBusiness Manager
Community Safety Enforcement
Jonathon ToyHead of Community Safety and Enforcement
Gill DaviesDirector Environment and Leisure
29
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