Safe Systems of Work
A safe system of work is a formal procedure which results from systematic examination of the tasks of a working process in order to identify all the hazards and defines methods of working which eliminate those hazards or minimise the risks associated with them.
The essence of the concept is that it is a system for dealing with the hazards. Based on the precise identification of hazards and assessment of risks for a particular task, job or process, the system comprises a comprehensive procedure for the way in which people may safely interact with each other, and with the materials, equipment and plant which form part of their work, so the risks are minimised. The procedure must be followed at all times in order to work safely in relation to the hazards.
Safe systems of work are needed whenever hazards cannot be physically eliminated and some element of risk remains. This applies to any task involving any risk. Thus, there is a specified routine for changing the toner in a photocopier to avoid spillages and dust contamination, just as there are specific practices for the separation of cooked and uncooked meats in kitchens, and detailed procedures for the setting and detonation of explosives in a quarry. In all these situations, the safe system is essential to prevent accidents or other incidents.
Section 2, subsection (1) of HSWA places a general duty on employers as follows:
It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.
This general requirement is made more specific by its application to five key areas in subsection (2):
- Provision and maintenance of safe plant and safe systems of work.
- Safe arrangements for storage, transport and use of articles and substances.
- Provision of adequate information, instruction, training and supervision.
- Provision and maintenance of a safe workplace, and safe means of access and egress.
- Provision of a safe working environment and adequate welfare facilities.
It is the first of these with which we are concerned here. An employer is under a duty:
To provide and maintain plant and systems of work that are, so far as is reasonably practicable, safe and without risks to health.
Note that this is a qualified duty in that the employer must take such action as is “reasonably practicable” to ensure the provision of safe systems of work. Reasonably practicable implies that a balance must be struck between the level of risk and the resources (money, time and effort) necessary to avert it. An employer can only use cost as the reason for not doing something when the risk is insignificant as compared with the cost of eliminating or further reducing it. The burden of proof lies with the employer. The size or financial position of the employer is not taken into account in this calculation.
As is the case with most general duties under HSWA, further Regulations make specific requirements in respect of safe systems of work. These apply to particular risks in respect of, for example, working with hazardous materials, manual handling or the use of display screen equipment, and also to general procedures and practices. Thus, the Workplace (Health, Safety and Welfare) Regulations 1992, as modified and amended 1994, 1995, 1996, 1997, 1999, 2002 lay down requirements regarding such matters as ventilation, traffic routes and room dimensions.
The “arrangements” section of an organisation’s safety policy will normally address safe systems of work, establishing the general guidelines under which they are developed and the rules under which they must be followed. Risk assessments must also consider them in respect of their continuing effectiveness in practice and anything that may be done to strengthen them.
Role of Competent Persons
One of the ways in which employers meet their duties in respect of health and safety is through the appointment of “competent persons”. The general definition of a competent person, as given in the Management of Health and Safety at Work Regulations 1999, is a person who “has sufficient training and experience or knowledge and other qualities” to assist the employer in compliance with his duties under the legislation. Other Regulations require that competence to relate to specific areas of health and safety.
The competent person cannot do the job alone. He or she will need to work closely with the employees who do, or will be doing, the work. They should take an active part in all stages of both the development and review of safe systems of work. Their practical knowledge and skills in the tasks provide a valuable source of information about the nature of the risks, including any unusual ones, and methods of working around them. They can also contribute by assessing plans and written documentation, and providing feedback on the effectiveness of the system in practice.
The safe system of work must be understood by all employees, and any others who may be involved from time-to-time (such as contractors), and applied correctly. For this to happen, it must be communicated effectively and the basis of this is written procedures.
All systems need to be properly documented to provide a precise reference for all operatives. This may be in the form of short notes and instructions about what to do if the toner needs changing in the photocopier displayed on the wall next to it, or it may take the form of manuals detailing exactly what steps to take in carrying out more complex and lengthy procedures such as calibrating and setting up grinding wheels for operation. These will form the basis of training programmes. They are likely to be accompanied by checklists for operatives to use as aids to ensure that all the correct steps are taken, and to check off details before continuing with the next operation or starting operations.