UNIVERSITY POLICY AND GUIDANCE SAFETY, HEALTH AND ENVIRONMENTAL MONITORING Author(s) Mike Turner John Frayling Policy Ratified by Safety Health and Environment Committee Date 05/09 Area Applicable Cardiff University Review Year 2012 This policy and guidance has been Equality Impact Assessed 1 DRAFT POLICY SAFETY, HEALTH AND ENVIRONMENTAL MONITORING 1. Legal Requirements: The Health and Safety Executive (HSE) places significant emphasis on the requirement for formal systems that cover inspection, monitoring and auditing as essential features of the action required by organisations to satisfy their statutory duties. Such systems are designed to prevent many of the failures that lead to accidents, incidents and prosecutions. The legal requirement to have in place formal systems to cover inspection, monitoring and auditing may be found in the Health and Safety at Work Act 1974, the Management of Health and Safety at Work Regulations 1999 and guidance such as the HSE publication HS(G)65 “Successful Health and Safety Management”. Furthermore, the role and responsibility of senior management in ensuring that periodic audits of the effectiveness of management structures and risk controls for safety health (and environment) are carried out, is explicit in the ‘Leading health and safety at work’ guidance issued by the Institute of Directors. Moreover, individual members of the University’s governing bodies and the University’s most senior staff may be guilty of criminal offences if they neglect their obligations under safety, health and environmental legislation The Health and Safety Executive promote both “active and reactive monitoring”. Active monitoring systems which monitor the extent of compliance with recognised standards; and Reactive systems which monitor accidents, incidents and ill-health. A low accident rate, even over a period of many years, is no guarantee that safety, health and environmental risks are being effectively controlled. This is particularly so in organisations such as Cardiff University where there is a low probability of accidents and incidents but where major hazards are present. In such cases historical accident data can be a deceptive indicator of safety, health and environmental performance. 2 2. Principal Objectives of the Policy: To protect the safety and health and environment of Cardiff University staff, students, visitors and any persons who may be affected by the University’s activities; To protect the physical assets of the University; To protect the reputation of the University; To provide information on where individual Schools and Directorates are relative to their overall safety, health and environmental objectives; To comply with relevant safety, health and environmental legislation. To assist Schools and Directorates in achieving continual improvement in the management of safety, health and environmental issues; and by association, ensure the University’s continuing productivity 3. Responsibility of Council: Cardiff University Council will have overall responsibility and accountability for ensuring that safety, health and environmental risks are effectively monitored, managed and that periodic audits of the effectiveness of management structures and risk controls for safety health and environment are carried out. In practice the Council has delegated the authority for ensuring compliance with its obligations to the Vice-Chancellor. The Vice-Chancellor has further delegated authority to the Heads of Schools and to the administrative Directors and this is consistent with the delegation of other responsibilities within the University 4. Responsibility of the Vice- Chancellor: a) Ensuring the implementation of the Monitoring Policy by securing the commitment and co-operation of all University’s staff; b) Allocating adequate personnel and financial resources; c) Agreeing inspection, monitoring and auditing procedures and protocols; d) Ensuring that adequate and appropriate information from the monitoring and auditing systems is received in order to exercise effective control over safety, health and environmental matters; e) Agreeing arrangements for staff training, at all levels; f) Regularly reviewing the University’s safety, health and environmental performance, and agreeing any necessary action plans. 3 g) Ensuring that the same management standards are applied to workplace inspections, monitoring and audit as are applied to other management functions h) Ensuring that the organisational structure in place is appropriate to manage health and safety matters related to workplace inspections, monitoring and audit issues; 5. Responsibility of Heads of Schools and Directorates: Ordinance 7 of the Cardiff University’s Rules of Governance state that the duties and responsibilities of the Head of School shall include: to ensure on behalf of the University compliance with its obligations with regard to the health, safety and welfare of staff and other persons in or affected by the School and for the premises, plant and substances therein. This is consistent with the responsibilities set out in the University’s Safety, Health and Environment Policy, including having responsibility for: a) The implementation of the Monitoring Policy; b) Ensuring that the organisational structure within the School/Directorate is appropriate to manage workplace inspections; c) Ensuring that adequate resources are provided to meet the requirements of the Monitoring Policy; d) Ensuring that the same management standard is applied to safety, health and environment monitoring as to other management functions; e) The quality of the inspection process meets an appropriate standard (see inspection guidance appendix A); f) Managers/ Supervisors are aware of their responsibility in ensuring inspections are undertaken for areas under their control; g) Agreeing who will carry out the inspection, monitoring and auditing; h) Ensuring the suitable training, instruction and supervision for all personnel so that they can competently carry out their responsibilities within the Monitoring Policy; i) Appropriate time is allocated for personnel involved in inspection, monitoring and audit to complete their work; i) There is a consistent approach across the whole School / Directorate and common problems identified in different areas receive consistent action throughout the School / Directorate; k) Inspections are completed on schedule; l) Remedial action plans are completed on schedule; and 4 m) Systems are in-place for maintenance of records detailing the inspections and the completion of any remedial action; n) The School / Directorate Safety Health and Environment Committee and Trade Union Safety Representatives are consulted on the precise arrangements for self-inspection; o) Reviewing School/Directorate safety, health and environmental performance 6. Supervisors and Managers are responsible for: a) Supporting the objectives of the Monitoring Policy; b) Ensuring areas under their control are inspected on schedule; c) Records of the inspections and remedial action plans are maintained; d) Remedial actions are completed on schedule; e) Inspection reports and/ or significant findings are reported to all relevant parties. 7. Role of Staff and Students All staff and students will be required to: Support the objectives of the University’s Monitoring Policy. 8. Monitoring and Inspection- Contractors It is the responsibility of each School/Directorate, through the appropriate line management, to ensure effective management of contractors under their control. As such each School/Directorate must monitor and inspect areas where contractors under their control are operating to ensure that appropriate safety health and environmental standards are being met. 9. Independent Audits: It is the responsibility of the University’s Occupational Safety, Health and Environmental Unit (OSHEU) to provide University Council, the University Board and senior staff essential information in order for them to exercise effective control over safety, health and environmental management. This information will be provided through a planned programme of integrated safety, health and environmental audits. 5 10. Frequency of inspection: The timing and frequency of inspections should take into account inherent safety, health and environmental risks and as a minimum will be based on the University’s zoning system for high, medium and low hazard areas which is as follows: High Hazard (Red) Areas.Red Zone definition Areas which have been identified through hazard assessment by the School / Directorate as containing such significant hazards that entry by maintenance staff or cleaners requires a written Permit to Work using the ‘Red Book system’ Each School / Directorate is responsible for ensuring that work place inspections are carried out at least once every 3 months. Suitable records must be maintained for audit purposes. Medium Hazard (Amber) Areas including Pool Rooms Amber Zone definition Areas which have been identified through hazard assessment by the School / Directorate as containing significant hazards and which require Permit to Work systems and written method statements for maintenance staff and cleaners. Each School / Directorate is responsible for ensuring that workplace inspections are carried out at least once every 6 months. Suitable records must be maintained for audit purposes. Any other areas Each School / Directorate is responsible for ensuring that all areas not falling within the University defined Red or Amber designation are subject to a recorded hazard assessment to determine the frequency of inspection. Should the assessment identify the area as having high or medium hazards then the frequency should be as the previous categories. Should the hazard assessment identify the area as ‘low’ then the workplace inspection frequency should be at least once every 12 months 11. Frequency of audit The timing and frequency of audits will take into account inherent safety, health and environmental hazards and the standard of safety, health and environmental management currently in practice. 6 Based on a School / Directorate rating system of Low, Medium and High Risk, audits will be scheduled to take place at required frequencies. Where an audit identifies significant problems it may be appropriate to repeat the audit outside the normal frequency to assess and verify progress. 7 Appendix A Draft Monitoring Policy Guidance 1. Self Inspection – Schools and Directorates: Workplace inspections have long been recognised as a valuable tool available to monitor the effectiveness of safety, health and environmental practices. Inspection for safety, health and environmental purposes often has negative implications associated with fault finding. A positive approach based on fact finding will usually produce better results, and co-operation from those taking part in the process. The aim of self inspection is for the School / Directorate to assess its own safety, health and environmental performance against agreed standards and objectives in order to recognise achievement and, where necessary, to take remedial action. Schools / Directorates should be carrying out a range of different types of checks as part of normal operating procedures. These may range from informal assessment of researchers working methods by their supervisors to planned formal inspections using standard inspection check-lists. The Inspection Report should also contain a corrective action plan covering each of the significant findings. The Action Plan should detail: The action recommended by the School / Directorate; Who will be responsible for carrying out the action; and A suitable timescale for corrective action to be completed taking into account the nature of the hazard and the degree of risk. 2. Workplace inspection –Safety Representatives It is acknowledged that recognised safety representatives are entitled to inspect the workplace in accordance with the ‘Safety representatives and safety committees’ guidance. These inspections should be seen as in addition to and not in place of the routine inspection of the workplace by the School/ Directorate 3. Inspection Teams: Ideally, the inspection, which should be co-ordinated by the person responsible for the area(s), should be conducted by a team of two or three people and include senior members of staff who are familiar with both the working practices of the School / Directorate and the safety, health and environmental standards relevant to the premises and activities. 8 In addition, consideration should be given to including personnel in the inspection team who are independent of the area being inspected to give a ‘fresh pairs of eyes’ so that faults /issues are not overlooked through over-familiarity. 4. Audit Teams Ideally, the audit should be conducted by a team of two or three people (including at least one competent auditor) and should include representatives of the School / Directorate. The auditors should be familiar with both the working practices of the School / Directorate and the relevant safety, health and environmental standards relevant to the premises and activities. 5. Hazard areas Typical examples of area designation are as follows (the examples given should not be considered exhaustive). Red areas may include: radiation areas; genetically modified organism laboratories; laser laboratories; x-ray laboratories; Nuclear Magnetic Resonance rooms; certain microbiological laboratories; neurotoxin laboratories; poisonous animal holding rooms; workshops. Amber areas may include: general laboratories; kitchens; pool rooms; refectories; libraries. Other areas may include: clerical areas; personal offices. 9