Health & safety bulletin
On Site Risk Assessments - Why Bother With Clearance Certificates?
6th November 2008
All of our employees have attended the UK PIA safety passport course, but refreshing parts of it at times does us no harm.
As part of the Health & Safety at Work Act 1974, we have an obligation as an employer to ensure that all employees operate to a safe system of work. The same Act specified that “employees must take reasonable care of their own health and safety, and that of others who may be affected by their acts or omissions” i.e. wear a safety helmet, do not obstruct a fire exit, drive carefully, or use guards on equipment and specified PPE.
The Management of the Health & Safety at Work Regulations 1999 specifies that a site specific risk assessment MUST be carried out - this is the law! As the person on site, you are therefore individually responsible for complying with that law.
Where work is repetitive, i.e. on maintenance jobs, we recognise that asking you to do this is unreasonable, so in this instance, please generate a generic JSA or Safety Method Statement.
The clearance certificates that you complete on site make the risk assessment and safe systems of work site specific. They also ensure that we comply with the law; providing we have clearly identified all foreseeable and significant risks not included on the generic document, and reduced the risk to a level ‘as low as reasonably practicable‘.
I have spent some time randomly reviewing our clearance certificates, and have had discussions with some of you, but would ask that you all look at your recent clearance certificates and think how they could be improved.
Entries onto clearance certificates such as, “the risk is traffic; the control measure is PPE”, is far too woolly and shows that you are effectively “asleep at the wheel” and more likely to have an accident. For this reason, we will be looking out for the generic use of “PPE” on our clearance certificates and asking individuals, for example, will ear defenders stop a moving car? PPE covers a multitude of risk controls and we need to be more specific; what PPE is needed? What is the first stage of risk control for this particular situation? etc.
HSE guidance on what to look for is as follows:-
- Identify the hazard
- Identify who and how harm might occur (including third parties!)
- Evaluate the risks
- Record the significant findings (i.e. on the clearance certificate)
- Review (individuals to review on each job and location)
In my experience traffic and the general public are always a hazard, but the risks vary on every site.
You may wish to ask if there is a school nearby where children might cut across the working area. Are other contractors on site and what risks could they pose? Does rain, snow or ice increase the risk of a car not stopping in time or make the work area and tools slippery?
What other businesses or facilities are nearby, e.g. shops, retailers of hazardous materials or substances, e.g. fireworks, which may affect your work or you may affect them?
You ask about tanker deliveries and record whether one is expected on your clearance certificate before you start work, but do you think about the risk and control measures?
When identifying hazards, we should try to implement control measures in line with the hierarchy of risk control i.e.
- Eliminate the risk totally - i.e. try to valet sites without working at height.
- Reduce the risk - can we do it at the quietest time?
- Isolate the risk - use the van and barriers to keep the public out.
- Control the risk - use an MEWP and harness if working at height for long periods of time.
- Use PPE - PPE should be used at all times when on-site, however in the instance of it being used as a primary risk control measure, it should be the last resort - where the risk cannot be controlled by any other means (specified on the JSA/SMS).
- Discipline - the risks can change as fast as the weather, so continue to carry out last-minute risk assessments as you do when you look in the mirror to change lane whilst driving! Self discipline is important in ensuring you remain familiar with your safe system of work and not become complacent (or fall asleep at the wheel!)
Remember - report changes in work procedure; tell us if the JSA/SMS is wrong or can be improved, and continue to be vigilant, carrying out your LMRAs before each step of the job.