College of Medical and Dental Sciences Executive Summary of 2012/2013 Health and Safety Action Plan The system in the College of Medical and Dental Sciences where individual School Action Plans feed into and are informed by an overarching College Action Plan has proved to be successful and will be continued in the 2013/14 plan. Similar headings will be used to ensure all areas have been considered and there is continuity and consistency in our efforts to improve health, safety and environmental standards in the College. Although not specifically written in the action plan for 2012/2013 notable successes for the College over the last year include the introduction of two way radios to facilitate more effective management of emergency evacuations and the hosting of a successful ‘mini-environment day’ in the College in January. Review of achievement 2012/2013 (On reflection, the number of targets set for 2012-2013 was on the high side. A more holistic approach has been taken for the production of the 2013-2014 plan) Out of 23 targets 10 have been completed. 9 are in progress and will be carried over to the 2013/2014 plan. 4 have yet to be progressed. Successes The standard of housekeeping remains high; this is in part due to the introduction of Laboratory Managers across the College, inherent in their job description is a responsibility to monitor and manage basic H&S/general housekeeping issues within their geographical area. PEEPS policy has been approved by College Board and the necessary requirements implemented. Health surveillance for over 200 staff entering BMSU is now assured The Energy Reduction plan was completed in good time. Targets currently in progress The improvement of PI engagement in health and safety through the PDR process is an issue which needs to be incorporated in to the revised PDR process in order to ensure appropriate checks are made by senior management within Colleges and constituent Schools. We suggest that this is an issue which requires input at University level to ensure a consistent approach is achieved across all Colleges. The fire drill procedure guidance was overtaken by the introduction of 2 way radios to assist in emergency evacuations of the Medical School Building and IBR, this new development needs to be added to the guidance which can then be finalised. Induction and other training are in progress but engagement of office staff has been slow. Alternative methods for implementing the training need to be identified which will hopefully increase participation and uptake. Targets not achieved The College Health and Safety Advisor has not been able to progress the appropriate website training to enable necessary editing and maintenance of the H&S Website, however 1 this has not resulted in a lack of updates to the website which have been delivered by using alternative resources within the College as a short term solution. It is recognised however that the website does need a more thorough review and update. Following a review of the current procedures for checking action points identified via safety inspections, it is clear that the current system for the review the actions deemed as urgent works reasonably well. The system for assessing action points with a medium to long term timeframe is not functioning as effectively as we would like. Further work is required to investigate more effective methods of ensuring all action points are cleared in the designated timelines. 2 College of Medical and Dental Sciences Health and Safety Action Plan 2013-2014 ITEM Audit of GM animal work in preparation for HSE inspection School BSO’s to update list of projects Cross check lists with BMSU projects Arrange a pre-inspection of transgenic work Policies and procedures Local guidance for Fire Drills in the College to be finalised Formal procedure for following up action points from inspections to be established Training Safety training for office staff to be introduced Raise profile of POD among office staff Ensure Heads of Operations are aware of safety training opportunities Communication/Recordkeeping /IT Re-establish communication with UHBFT Health Person(s) Responsible Target date 31st October 2013 School BSO’s College HSA & University BSO College HSA & Head of Infrastructure & Estates College HSA December 2013 HSA/TM’s/Head of Infrastructure & Estates December 2013 HSA/Head of Infrastructure & Estates January 2014 College HSA/ Head of December 2013 3 6 monthly progress statement/date of completion and Safety Unit by setting up an Operational/Functional Committee Initial scoping meeting held Follow up meeting planned Update website by arranging training for HSA Database for accidents and incidents to be established Electronic record of safety training for Technical Management Team and College Safety Coordinators to be established Develop a repository of searchable repository of COSHH assessments for use by College staff and students Establish a robust connection between College H&S co-ordinators and specialists in the Central H&S Unit Ensure appropriate structures are put in place to guarantee lines of communication with HBRC and other HTA licensed areas in order to share compliance and best practice Infrastructure and Estates HSA September 2013 December 2013 December 2013 HSA January 2014 HSA/TMs/Medical Education Team January 2014 Head of Infrastructure and Estates/HSA March 2014 Head of Infrastructure and Estates /Director of HBRC /HSA/HTA Designated Persons June 2014 4 College of Medical and Dental Sciences Executive Summary of the 2013/2014 Action Plan In 2013/2014 the College of Medical and Dental Sciences remains committed to maintaining and improving the management of and operational standards for health and safety across all our activities. Following a review of the 2012/2013 action plan and reflecting on the success of targets set against targets achieved we believe we were perhaps over ambitious on the number of targets set and the spread of activity covered. This year a more holistic approach has been taken. The plan is an overarching one, covering the schools and is a consolidation of the following: Action points carried over from last year’s plan that were either outstanding or still in progress at the end of the year. Items arising from the review of the School Action plans. Items such as the audit of transgenic animal assessments which required because of the proposed HSE/DEFRA inspection. Items arising from communication with external bodies such as the re-establishment of the Joint UHBFT/UOB Safety Group. The slight difference in approach will, we believe, better serve a College of the size and complexity of Medical and Dental Sciences. The attached priority objective table is taken from the overarching plan, the first action being the most urgent, in this case the audit of the College’s transgenic assessments in preparation for the proposed HSE inspection. 5 College of Medical and Dental Sciences Health and Safety Action Plan 2013 -2014 Further JSAC Questions To demonstrate the effectiveness of the chain of command especially at PI/Supervisor level with the respect to the following issues; Being aware of the legal and University requirements in their respective areas of research This is done in a number of different ways: There are established policies and procedures to reflect legal and University requirements. The College of Medical and Dental Sciences Safety Executive (CSEC) meets termly to ensure compliance with requirements. In addition each constituent School of the College has established a School Safety Executive Committee which reports into CSEC All new lab staff and students attend Laboratory Safety training and also Chemical Safety training both of which include current legislation, University and College requirements. There are regular in- depth inspections of individual PIs and their research groups which includes a discussion of legal and University requirements with respect to health and safety. This type of inspection mirrors the approach taken by HSE inspectors and has been well received by the PIs and their teams we have visited to date Ensuring those with supervisory roles are trained to carry out risk assessments and are competent to supervise others. There are different arrangements for the various types of risk assessments the College of Medical and Dental Sciences is required to produce: All new staff receive training on the principles of risk assessment and are taken through a sample risk assessment for biological hazards and a ‘COSHH’ assessment. PIs are expected to complete GM assessments themselves however the GM pro forma is structured in such a way as to provide guidance to new PIs and assist more established staff in the preparation/review of these risk assessments. Biological assessments and COSHH assessments can be delegated to Research Fellows and Technicians. The quality of COSHH assessments has been found to be variable and so a COSHH assessment workshop has been set up to help Technicians in particular. A COSHH sub group has been formed to monitor and advise on the quality of COSHH assessments produced by research / technical staff Being able to identify and manage the risks associated with the research Given the training outlined above, PI’s and Supervisors should be able to identify the hazards and assess the risks they encounter in their work. Hazards and risks would also be discussed at induction training. Support is given to researcher groups by the Technical Management Team and cadre of Laboratory Managers. In addition there is a well-established network of Safety Co-ordinators located throughout the College who also contribute to the support systems. There is a lot of information on the Health and Safety Unit web pages and more local information is given on the College of Medical and Dental Sciences web pages, links to these are given at the safety training sessions 6 Ensuring that all people under their direction have adequate information about the risks and the risk controls that apply to their work and that these people have relevant training and appropriate supervision arrangements are in place. A primary function of the College Health and Safety Advisor is to ensure relevant information is disseminated effectively to research groups. In addition they will review and, where necessary, summarise new policies/initiatives in order to ensure they are presented in such a way as to engage staff/students and facilitate recognition of how such policies impact on our core business activities. In laboratories and offices new staff and students are usually assigned a ‘mentor’ to supervise them until they are deemed competent. In the College High Risk Containment Level 3 Laboratories (CL3) arrangements are written in the form of Codes of Practice and workers are not given access to a CL3 laboratory until they are judged to be competent. There are similar requirements in Radiation Laboratories and Liquid Nitrogen Facilities. Undergraduate project students are supervised constantly and are not allowed to work out of hours unless granted permission by the School Technical Manager for specified low risk work. Monitoring workplace safety compliance and the action taken if deficiencies are found such as unsafe acts or conditions, failure to follow safe systems of work, lack of planned maintenance or inadequate facilities Monitoring compliance is undertaken in a number of ways: There is programme of termly local inspections, the results of which are communicated to the College Safety Executive Committee As mentioned earlier a team representing the College Safety Executive Committee conduct in depth inspection of individual research groups. Any failures flagged up are followed to ensure issues have been remedied. For repeated non-compliances, situations of imminent danger or serious breaches of H&S rules/regulations there is an enforcement procedure similar to the HSE system. In essence the College can either issue an improvement notice, whereby staff are advised that activities must cease until prescribed remedial actions are taken to a standard approved by senior managers within the College, or a prohibition notice which requires immediate cessation of work, the relevant area is secured and a detailed investigation is undertaken. In the five years since this was established it has only issued one improvement notice. Issues for University to deal with An issue the College believes would be best dealt with at University level is the engagement of PI’s in health and safety via the new PDR process. We believe this would provide a useful vehicle for ensuring greater engagement and establish an effective process for monitoring compliance in conjunction with local College procedures. 7 College of Medical and Dental Sciences 2013-2014 1 2 Priority objectives Audit of GM animal work in preparation for HSE inspection Update Policies, procedures and guidance specifically: Guidance for fire drill The follow up of actions arising from inspections By whom School BSO’s College HSA, University BSO, Head of Infrastructure and Estates College HSA TMs, Head of Infrastructure and Estates By when 31st October Success criteria Satisfactory compliance with the GMO(CU) Regulations December 2013 Fire drills are carried out in all buildings. Action points from inspections are completed Communication of H&S improved within the college and between the College and H&S Unit 3 Communication/recordkeeping/ IT specifically: re-establish joint UHBFT/UoB safety group update H&S web pages create database for accidents and incidents Electronic record of M, LM and Safety co-ordinator training Develop a COSHH assessment database Establish a robust connection between College and HSU specialists College HSA TMs, Head of Infrastructure and Estates December 2013 March 2014 4 Introduce safety training for office staff College HSA, Head of Infrastructure and Estates December 2013 Steve Johnson Sue Chalder September 2013 8 Improved safety awareness for office staff Notes