EU-OSHA Risk Assessment Campaign
The European Agency for Safety and Health at Work (EU-OSHA) — a Europe-wide information campaign on risk assessment — was launched earlier this year. But do all Union Safety Reps, realise the importance of the risk assessment process? We know from the figures alone that certainly employers do not!
The European campaign has support from two other major organisations - the Institution of Occupational Safety and Health (IOSH) and the Health and Safety Executive (HSE)
IOSH says: “Risk assessment should be about empowering people to do things — whether they’re working on an oil rig or planning a trek across the Alps. But in the UK, it’s often seen as a tangle of pointless paperwork and red tape and leads to headlines about ‘health and safety killjoys’ stopping pancake races.” It offers to take the myth out of risk assessment providing, for example, a “reality checklist” which includes the exhortation to “Think about the real world”.
It maintains: “You can’t get rid of all risk entirely, so don’t try. Solutions should be sensible, cost-effective, proportionate and based on good practice. And they shouldn’t bring miles of red tape.”
The HSE takes a similar approach, stressing that: “We believe that risk management should be about practical steps to protect people from real harm and suffering — not bureaucratic back-covering.”
Here, Unionsafety looks at the fine detail:
Looking at the facts
Every year, more than 5700 people die in the EU as a consequence of work-related accidents, while the International Labour Organisation (ILO) estimates that an additional 159,500 workers in the Union die every year from occupational diseases. Taking both figures into consideration, it is estimated that every three-and-a-half minutes, somebody in the EU dies from work-related causes. Most of these accidents and diseases are preventable, EU-OSHA claims, and the first step to be taken is risk assessment. The two-year campaign focuses especially on high-risk sectors such as construction, healthcare and agriculture, and on the needs of small and medium-sized enterprises (SMEs).
Foundation of EU health and safety law
The basis of all European health and safety legislation is Directive 89/391/EEC — the Framework Directive (FD) — which established the principles on which all its subsequent “daughter Directives” would be based. The FD puts risk assessment at the heart of health and safety legislation stating, as its main objectives, the need to prevent occupational risks, the protection of safety and health and the elimination of risk and accident factors.
The Directive also establishes the general rules which have underpinned all subsequent EU approaches to risk prevention, namely:
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avoid risks
* evaluate the risks which cannot be avoided
* combat the risks at source
* adapt the work to the individual, especially as regards the design of work places, the choice of work equipment and the choice of working and production methods
* adapt to technical progress
* replace the dangerous by the non-dangerous or the less dangerous
* develop a coherent overall prevention policy which covers technology, organisation of work, working conditions, social relationships and the influence of factors related to the working environment
* give collective protective measures priority over individual protective measures
* give appropriate instructions to the workers.
Importance of the risk assessment process
The risk assessment process, according to EU-OSHA, is the start of the health and safety management approach. If is not done well, or not done at all, the appropriate preventive measures are unlikely to be identified or put in place. Risk assessment is the process of evaluating risks to workers’ safety and health from workplace hazards. It is a systematic examination of all aspects of work that considers:
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what could cause injury or harm
* whether the hazards could be eliminated and, if not
* what preventive or protective measures are, or should be, in place to control those risks.
Above all, the Agency argues, risk assessment is a dynamic process that allows companies and organisations to put in place a proactive policy of managing workplace health and safety. To this end, proper risk assessment includes making sure that all relevant risks are taken into account (not only the immediate or obvious ones), checking the efficiency of the safety measures adopted, documenting the outcomes of the assessment and reviewing the assessment regularly to keep it updated.
While the purpose of risk assessment includes the prevention of occupational risks, and this should always be goal, it will not always be achievable in practice. Where elimination of risks is not possible, the risks should be reduced and the residual risk controlled. At a later stage, as part of a review programme, such residual risk should be reassessed and the possibility of elimination of the risk, perhaps in the light of new knowledge (the “technical progress” mentioned in the FD), can be reconsidered.
A risk assessment checklist
Risk assessment is not necessarily complicated, bureaucratic or a task only for experts, EU-OSHA insists, pointing out that this is a mistaken belief that is particularly common among SMEs. There are plenty of easily available tools available (such as checklists) that help in the process. For example, the risk assessment should be structured and applied so as to help employers to:
* identify the hazards created at work and evaluate the risks associated with these hazards, to determine what measures they should take to protect the health and safety of their employees and other workers, having due regard to legislative requirements
* evaluate the risks in order to make the best informed selection of work equipment, chemical substances or preparations used, the fitting out of the workplace, and the organisation of work
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check whether the measures in place are adequate
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prioritise action if further measures are found to be necessary as a result of the assessment
*demonstrate to themselves, the competent authorities, workers and their representatives that all factors pertinent to the work have been considered, and that an informed valid judgment has been made about the risks and the measures necessary to safeguard health and safety
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ensure that the preventive measures and the working and production methods, which are considered to be necessary and implemented following a risk assessment, provide an improvement in the level of worker protection.
The Five-Step Approach
Determined to demonstrate that even the smallest business has the resources to undertake a meaningful risk assessment, EU-OSHA has broken down the requirements into a five-step approach (which should work well even for micro firms).
Step 1 — Identify hazards and those at risk
This could begin with simply walking around the workplace and looking at what could cause harm. In addition, the company will have accident and ill-health records that may indicate areas of concern or be a guide to less obvious risks such as psychosocial or work organisational factors. This stage will also involve talking to experts — not bought-in consultants but the company’s own workforce and/or their representatives, who will have the most direct experience of dangers and problems in their working environment. It must be borne in mind however that it is not only the immediate workforce that must be taken into account: cleaners, contractors and members of the public may also be at risk.
Step 2 — Evaluate and prioritise risks
Having identified potential hazards, the next step is to evaluate the risks arising from each. This can be done by considering:
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how likely it is that a hazard will cause harm
* how serious is that harm likely to be
* how many workers are exposed and how often.
EU-OSHA suggests that a straightforward process based on judgment and requiring no specialist skills or complicated techniques could be sufficient for many of the hazards or activities identified. Many will be hazards of low concern, or workplaces where risks are well-known or easily identified and where a means of control is readily available. This should certainly be the case for most SMEs. Risks should then be prioritised and tackled in order of their significance.
Step 3 — Decide on preventive action
This is where the hierarchy of action established by the FD comes into play. First, decide if it is possible to get rid of the risk; if this is not possible then look at how the risks can be controlled so they do not compromise the safety and health of those exposed. Remember the need to substitute the non-dangerous or the less dangerous for the dangerous, and the prime obligation to combat risks at source. Going back to Directive 89/391/EEC again, take collective protective measures rather than individual ones, eg control exposure to fumes by local exhaust ventilation rather than personal respirators.
Step 4 — Take action
It is essential that any work to eliminate or prevent risks is prioritised and again EU-OSHA stresses the importance of involving the workers concerned and their representatives in the process. By this stage, the company should have a plan setting out:
* the measures to be implemented
* who does what and when
* a timescale for completion.
Step 5 — Monitor and review
Risk assessment is not a once-and-for-all option: it requires constant evaluation and adjustment in the light of previous action and experience. For example, an accident or “near miss” will provide new information and outside factors (such as product safety material generated by manufacturers in response to legislative measures such as REACH in the chemicals sector) will need to be taken on board. Record keeping is also essential if lessons are to be learned and if the organisation is to avoid constantly re-inventing the wheel. A record of specific details is recommended by EU-OSHA, and should at least include:
* the name and function of the person(s) carrying out the examination
the hazards and risks identified
* the groups of workers facing particular risks
* the necessary protection measures
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details of the introduction of the measures, such as the name of the person responsible and date
details of subsequent monitoring and reviewing arrangements, including dates and the people involved details of the workers’ and their representatives’ involvement in the risk assessment process.
