Dear Mr Keyes HEALTH AND SAFETY EXECUTIVE NORTHERN IRELAND (HSENI) - DRAFT CORPORATE PLAN 2002-05 The Committee for Enterprise, Trade and Investment has considered the draft Corporate Plan for the years 2002-2005 and offers the comments detailed below. Foreword The Committee welcomes the commitments given that HSENI are to work together with social partners and to the breaking down of barriers. It also welcomes the desire to see those vulnerable groups adversely affected by poor health and safety performance targeted over the period of the Plan. Context The Plan clearly identifies the important role small businesses play in the Northern Ireland economy and commits HSENI to developing a new strategic approach to working with small firms. It recognises the need to ensure ownership of this strategy by social partners such as District Councils and the Federation of Small Businesses (FSB). HSENI will work through Investing for Health to vigorously promote occupational health issues in a holistic way to meet the needs of employees and others affected by work activities. HSENI is also committed to e-Government initiatives and hopes to rollout a new Knowledge Management System in 2002. The Committee endorses the aspirations identified above. However, whilst HSENI certainly needs to project itself as a resource for SMEs to utilise in order to reduce liabilities in regard to Health and Safety issues, the organisation must prioritise its role in terms of accident and incident prevention. As such, it should be orientated towards the needs of the worker as well as the end-consumer. Over-reliance upon the employer will fail to reverse the culture in which management see Health and Safety as an 'add-on', to be avoided until an inspector comes. As such the objectives for achievement are somewhat limited and inadequate. Opportunities and Challenges HSENI recognises the need to change the perception that they are a threat to businesses, particularly small firms. This will be a major task for the HSENI and will require partnership with organisations such as FSB if they are to succeed. The Committee supports this initiative and agrees that competitiveness and profitability can be enhanced by good H&S practice in the workplace. Health and Safety legislation affords protection to those who may be affected by work activities, such as hospital patients, school children and the general public where they encounter work - from buildings sites to funfairs. Within this broad range HSENI has identified vulnerable groups deserving of special attention:
The Committee welcomes this focus, particularly the reference to children of farmers and suggests that low-paid workers (including temporary and part-time workers) should also be targeted for special attention. HSENI is very keen to building on existing relationships with its partners (District Councils etc) and to developing new ones. The Committee supports the approach adopted and suggests closer co-operation with other employer bodies (CBI, IOD), farming groups (UFU etc), voluntary & community organisations (ethnic minority associations, RNIB etc) and consumer groups (GCCNI) may be appropriate. The Committee notes the joint role HSENI carries out with District Councils on inspections of retail and wholesale shops, offices, restaurants and hotels. HSENI should consider managing this work itself and only using local authorities where necessary - this would ensure that the highest standards are applied consistently. The Committee believes this work should be covered in further detail in the plan. Strategic partnerships with colleges of further and higher education may also help promote health and safety policies and practices through vocational training. The delivery of services on a local basis is an important consideration for HSENI. The Plan foresees the creation of a new operational branch office 'West of the Bann'. This approach will also be enhanced by developing strategic alliances with libraries and Citizens' Advice Bureaux. The Committee welcomes this initiative. The Committee is keen that a timeframe for this development is included in the Corporate Plan. In addition, the Committee is interested to know if any locations are currently being considered. The dissemination of information to as many as possible will be a key factor if the goals and aspirations in this section are to be met. The section on intelligence details the current 'paucity of data' - this is a key issue for the HSENI and limits its ability to deal with bad practice. One of the key measures the plan needs to contain is the inclusion of a campaign encouraging workers and consumers to detail cases of bad practice. As a pre-requisite to this, the HSENI will have to ensure that the general public are fully aware of Health and Safety issues and of the standards which are required. This will require the diversion of funds away from being focussed on employers alone and more towards the workforce and the general consumer groups. The plan contains some developments in terms of providing access to information through the ICT media, whilst retaining cogniscence of the digital divide. The Committee welcomes this development. Vision, Objectives And Targets The Plan clearly identifies the key objectives and priority issues for the period covered by the Plan. The Plan also specifies targets against which the objectives will be assessed. The Committee has a number of points to make regarding the key performance targets, as follows. The Committee is concerned that the first two key performance targets are totally inadequate and that they should include responsiveness to queries from employees and consumers. They should be complemented with targets for inquiries and attendances at promotional events and these should include figures for employers, employees and general consumers. Targets should be set for the proposed promotional campaign detailing standards required in regard to Health and Safety and this should include number of responses and potential audience figures. The Committee believes that the third key performance target should be raised from 70% of employers to 95% of employers. It is simply not acceptable that 30% of employers would be allowed to fail to demonstrate a satisfactory improvement in compliance with health and safety standards. The Committee agrees that the fourth key performance target is reasonable although it should involve some linkage to the Republic of Ireland's Health and Safety Legislation in border areas. It is very important that employers in both jurisdictions have to apply the same stringent legislation. This should mean that the HSENI should increase its contacts with the Health and Safety Authority in the Republic of Ireland. The Committee feels that other key performance targets should be identified. These should include number of spot inspections, number of convictions, number of fatalities associated with HSENI breaches, number of serious injuries and minor injuries reported (by type). All these targets should be made against existing figures. Performance of HSENI should be monitored against these targets. The Committee is concerned that the figures given in Table 1 are insufficient to determine the success of HSENI in reducing the number of fatalities and increasing the number of incidents reported. Annex 1 - Facts & Figures The Committee believes that Board membership should include representatives from the community employment sector and from consumer groups. The Committee would like to be informed of the missing figures in the Executive section relating to staffing figures and budget for 2002/03. Eight additional staff are to be employed by HSENI - their roles are not discussed, neither are targets for their employment. The Committee is concerned that, in general, this report lacks quantification of anything meaningful. Annex 2 - Operating Principles And Values The Committee welcomes HSENI's commitment to the promotion of equality of opportunity, particularly in relation to developing a strategy to optimise access to information and services for all Section 75 groups. The Committee also welcomes HSENI plans to target specific groups/high risk industries in order to assist meeting New TSN commitments. The Committee also supports the HSENI's aims in maintaining a safe and healthy environment for their staff and in maintaining good working relationships with Trade Union representatives. Annex 3 - Review Of The Period 1999-2002 The Committee is satisfied that most of the numerical targets have been met and it was satisfied in relation to the numbers of companies participating in HSENI events. The Committee is concerned, however, that the number of days devoted to the construction industry and to enforcement activities did not meet the targets set for 00/01. In addition the HSENI did not meet the targets for Consultation papers issued, and regulations and Codes of Practice developed. The Committee would like an explanation for these failures and seeks an update for the year 01/02 when available. The reasons for failure to achieve these targets needs to be addressed as a central issue within the new corporate plan. Targets for achievement for the future years have not been given in Table 1. The Committee would like details of these targets and the rationale for them provided on the basis of an additional eight inspectors. No consideration was made of the failure of HSENI to actually investigate the cause of fatalities. The Committee has decided that all fatalities must be actively investigated with a view to pursuing individual cases through the courts. GENERAL The Committee is very supportive of the work undertaken by HSENI and is concerned at the levels of fatalities in the workplace, especially in the construction and agricultural industries. The Committee is glad, therefore to offer its support in helping HSENI achieve its aims in reducing the number of accidents at work. If helpful, the Committee is prepared to meet with you to discuss the Corporate Plan and its outworking, difficulties faced in achieving goals or any matter HSENI would wish to raise. I am happy to discuss any of the points raised in this letter if further clarification is required. Yours sincerely Pat Doherty PAT DOHERTY MP MLA cc John Hinds, DALO, DETI |
