Update on MPA/MPS assurance process

Report: 11
Date: 11 September 2008
By: Director of Human Resources on behalf of the Commissioner

Summary

Central Operations (CO) and Directorate of Resources (DoR) will be the first Business Groups to submit assurance letters to the Commissioner in this financial year 2008/09. It is envisaged that the remainder of the Business Groups and their (Borough) Operational Command Units ((B)OCUs) / departments will provide assurance letters over the next two/three financial years.

A. Recommendation

That members note the report.

B. Supporting information

Background

1. The MPA Corporate Governance Committee (CGC) and MPS Management Board have endorsed the requirement for a health and safety assurance process. The process requires Management Board Members to provide a letter of assurance to the Commissioner who will subsequently provide a similar letter to the MPA; these letters of assurance are required to detail the MPS compliance with health and safety. This assurance process is now enshrined in the new MPA/MPS Corporate Health and Safety Policy dated December 2007.

2. The first stage of this process, therefore, is to ensure Management Board Members can give assurance to the Commissioner concerning their business activities. This will entail individual (B)OCU Commanders and Heads of Department (HoD) providing similar assurance to their relevant Assistant Commissioner (AC) or Business Group Director (BGD) on their level of health and safety compliance.

3. Owing to resource constraints, agreement has been reached with the MPA for a staged implementation programme. It has been established that Central Operations (CO) and Directorate of Resources (DoR) will be the first Business Groups to submit assurance letters to the Commissioner in this financial year 2008/09. It is envisaged that the remainder of the Business Groups and their (B)OCUs / departments will provide assurance letters over the next two/three financial years.

4. The MPS Safety and Health Risk Management Team (SHRMT) are co-ordinating this process for the MPA and Commissioner. The SHRMT have the role of safety advisor (supported on property related matters by the Property Services Compliance Team) and verifier to this process. The responsibility for achieving and reporting compliance and providing assurance rests with the (B)OCU Commanders, HoDs , ACs, BGDs and ultimately the Commissioner.

Assurance Process

5. All health & safety compliance in the MPS is measured in terms of adherence to the MPA/MPS Corporate Health & Safety Policy including the implementation of the Health & Safety Executive (HSE) recommended safety management system, more commonly referred to as HS(G)65. Business Groups, (B)OCUs and Departments will be required to report on their compliance with the corporate policy and the five broad elements of HS(G)65 (Policy, Organising, Planning, Monitoring, Audit and Review). If Business Groups, (B)OCUs and Departments comply with these policy arrangements, then they will be able to meet the assurance process standards.

6. For example (B)OCUs and departments should already be able to provide assurance that there is a current local safety policy, hold regular health and safety committees chaired by the (B)OCU Commander or HoD, evidence that staff have or are in the process of completing mandatory safety training. Additionally, that all activities are risk assessed and suitable controls have been implemented to reduce the risk to acceptable levels, all accidents and near misses are reported, investigated and trends identified, and local safety reviews are undertaken etc.

7. The assurance process will take the form of assurance letters detailing the levels of compliance, as well as any shortfalls or concerns that the (B)OCU, departments or business groups may be experiencing; including any work-in-progress and/or action plans drawn up to address shortfalls. It is just as important to capture genuine local, business group or corporate shortfalls and concerns in this process as well as providing assurance.

8. Template statements of assurance are attached:

• Appendix 1 – Template statement of assurance from (B)OCUs and departments;
• Appendix 2 – Template statement of assurance from ACs and BGDs.

Implementation Timeline

9. Central Operations (CO) and Directorate of Resources (DoR) will be the first Business Groups to submit assurance letters to the Commissioner in this current financial year. The following are the proposed timelines/action required for this first implementation round:

1. (B)OCUs and departments under CO and DoR are to review their compliance in accordance with the MPA/MPS Corporate Health and Safety Policy. Any local shortfalls in compliance or work-in-progress are also to be identified, including appropriate action plans. To support this review, each (B)OCU or department are to ensure that its local health and safety committee meets to support this process. (B)OCU Commanders and HoDs will be expected to submit their letter of assurance to their relevant AC/BGD by the end of November 2008.
2. During the period between August and November 2008, SHRMT safety advisors will be available to liaise with the (B)OCUs and departments affected in the initial staged implementation to advise on health and safety matters including the information required by their Management Board Member to satisfy the assurance process. Any property related health and safety matters will be referred to the Property Services Compliance Team. The safety advisors will only advise on safety matters, the compliance standard and assist in formulating action plans. It will remain the responsibility of the (B)OCU Commander/HoD, who has statutory responsibility for ensuring the health, safety and aligned welfare of the officers and staff under his/ her command, to ultimately provide the assurance. SHRMT safety advisors are a limited resource to this process as they have an average of 15 (B)OCUs and departments in their portfolios, as well as normal day-to-day safety business and operational activity.
3. November/December 2008, AC CO and BGD DoR review (B)OCU/department assurance letters and prepare draft assurance letter for the Commissioner. Any Business Group shortfalls in compliance or work-in-progress should also be identified; inclusive of appropriate action plans. The SHRMT Senior Safety Advisor CO and DoR will be available to advise AC CO and the BGD DoR on this stage of the process.
4. January – March 09, the SHRMT (senior safety advisor/s) will begin the process of verification of the draft letters of assurance on behalf of the Commissioner and MPA (where appropriate the verification process will be supported by the Property Service Compliance Team). This will be achieved by a process of dip sampling, as appropriate, to test the assurance given (SHRMT do not have the resources to test each (B)OCU or department by comprehensive audit in order to give a 'percentage level' of compliance). This will be evidence-based sampling and therefore (B)OCUs/departments will be expected to have the evidence to support the assurance statements available for the activities for which assurance compliance has been given. It is anticipated that this process will take two-three months to complete.
5. In early April 2009, the senior safety advisor/s will report their finding to AC CO and BGD DoR. AC CO and BGD DoR will be given the opportunity to amend assurance letters and non-compliance action plans, as appropriate, and then issue their letter of assurance to the Commissioner.
6. May 2009, the Commissioner will submit the first health and safety letter of assurance to the MPA.
7. June – August 2009, MPA/MPS to review the 1st year assurance programme rollout and confirm the next stage of the rollout programme.

10. The assurance standards have been kept deliberately simple in this initial rollout phase and will evolve as the process matures. In addition, no opportunity was given to pilot this assurance process therefore the initial rollout phase will also be used to learn and improve the overall process.

11. This assurance process will be resource intensive for the SHRMT and normal annual safety auditing has now been suspended to support the rollout. Urgent operational work will continue to take primacy and in the event of a protracted major incident the implementation of this process may be delayed.

C. Race and equality impact

There are no immediate implications on equality and diversity arising from this report.

D. Financial implications

There are no immediate financial implications from this report. Although there are no direct financial implications this process will increase the reporting burden on (B)OCUs, Departments and Business Groups. This assurance process is resource intensive for the SHRMT and normal annual safety auditing has now been suspended to support the rollout. Further work prioritisation may be required.

Abbreviations and acronyms

CO

Central Operations Business Group

DoR

Directorate of Resources Business Group

CGC

Corporate Governance Committee

HoD

Heads of Department

AC

Assistant Commissioner

BGD

Business Group Director (BGD)

SHRMT

Safety and Health Risk Management Team

HS(G)65

Health and Safety Executive Guidance Note 65 – Successful Health and Safety Management 

E. Background papers

None

F. Contact details

Report author: Nick Kettle, Head of Safety and Health Risk Management

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

Appendix 1: (B)OCU and Department Template Statements of Assurance

Part One

• I have discharged my health and safety responsibilities as the (B)OCU Commander or Head of Department (HoD) in accordance with the MPA/MPS Corporate Health and Safety Policy.

Health & Safety policy

• My (B)OCU/department has a local health and safety policy that reflect local safety arrangements; it has been signed by myself as the (B)OCU Commander/HoD and has been communicated to all staff;
• This policy has been reviewed in the last twelve months

Organising

• Duties and responsibilities for health and safety have been allocated to appropriate staff within my (B)OCU/department in accordance with the local and corporate health and safety policies;
• All staff have received training commensurate with their role and responsibilities;
• All staff have completed mandatory and, as appropriate, statutory health and safety training;
• Federation, trades unions and staff representative associations are appropriately consulted on health, safety and welfare issues that have a direct or indirect impact on staff they represent;
• Health and safety is co-ordinated through my quarterly (B)OCU/department health and safety committee, which are chaired by myself as the (B)OCU Commander/HoD. Membership of this committee includes all those with specific responsibilities in the local health and safety policy, Federation, trades unions and staff representative associations, as appropriate;
• Minutes of quarterly health and safety committees have been communicated to all staff.

Planning/Arrangements

• The (B)OCU/department has a health and safety plan for the current financial year, setting measurable targets for improvements in health and safety performance;
• The (B)OCU/department has completed risk assessments for all tasks and activities (including operational activity) undertaken in accordance with the MPS H&S Manual Volume 1 Chapter 5. These assessments, where appropriate, take account of risk to not only to MPS staff but others including those that may be affected by the (B)OCU/department activity including contractors, volunteers and the public. These assessments also include suitable controls that have been implemented to reduce the risk to acceptable levels;
• The RA4 risk assessment form has been signed by myself as the (B)OCU Commander or HoD;
• These risk assessments have been reviewed in the last twelve months;
• If the (B)OCU/department provides a pan MPS service/s (e.g. pan London firearms, property management, provision of equipment etc). - Assurance should also be given to that these activities are appropriately managed (including suitable performance monitoring) and, where appropriate, suitably risk assessed.

Measuring Performance

• Workplace inspections are regularly carried out and significant findings are reported to the (B)OCU/department health and safety committee;
• All accidents, incidents, near misses and reports of ill-health are recorded, reported and, where appropriate, adequately investigated;
• Where required accidents, incidents and ill health are reported to the Health & Safety Executive;
• The (B)OCU/department carry out trend analysis of reported accidents. This is reported to and reviewed by the (B)OCU/department health and safety committee.

Audit and Review

• The (B)OCU/department reviews its own H&S performance against the performance targets, set out in the (B)OCU/department annual health and safety plan;
• If the (B)OCU/department has been audited by the SHRMT, Property Services Compliance Team, HMIC or MPA Internal audit:
  • Recommended audit actions have either been completed or scheduled action plans are in place to achieve compliance.

Part Two

Health and safety - shortfalls/areas of safety concern

Any health and safety shortfalls or concerns which arise should be listed as part of the assurance process including any work-in-progress/action plans drawn up to address these issues. Shortfalls and concerns that affect health and safety could be as a consequence of many factors such as not fully complying with Part 1 above, general policy, organisational, resources, operational, building related issues, or other external factors.

Appendix 2: Business Group Assurance Process Letter

• I have discharged my health and safety responsibilities as the Assistant Commissioner (AC)/Business Group Director (BGD) in accordance with the MPA/MPS Corporate Health and Safety Policy.

Part One - (B)OCU and Departments

• I have received assurance from my (B)OCUs and Departments that they have discharged their responsibilities for health and safety in accordance with the MPA/MPS Corporate Health and Safety Policy. An example of the assurance that will be given by (B)OCUs and Departments to the relevant AC or BGD is shown below in italics:

Health & Safety policy

• My (B)OCU/departments have local health and safety policies that reflect local safety arrangements; it has been signed by the (B)OCU Commander/HoD and has been communicated to all staff;
• These policies have been reviewed in the last twelve months.

Organising

• Duties and responsibilities for health and safety have been allocated to appropriate staff within my (B)OCU/department in accordance with the local and corporate health and safety policies;
• All staff have received training commensurate with their role and responsibilities;
• All staff have completed mandatory and, as appropriate, statutory health and safety training;
• Federation, trades unions and staff representative associations are appropriately consulted on health, safety and welfare issues that have a direct or indirect impact on staff they represent;
• Health and safety is co-ordinated through quarterly (B)OCU/department health and safety committee, which are chaired by the (B)OCU Commander/HoD. Membership of these committees includes all those with specific responsibilities in the local health and safety policy, Federation, trades unions and staff representative associations, as appropriate;
• Minutes of quarterly health and safety committees have been communicated to all staff.

Planning

• The (B)OCU/departments have a health and safety plan for the current financial year, setting measurable targets for improvements in health and safety performance;
• The (B)OCU/department has completed risk assessments for all tasks and activities (including operational activity) undertaken in accordance with the MPS H&S Manual Volume 1 Chapter 5. These assessments, where appropriate, take account of risk to not only to MPS staff but others including those that may be affected by the (B)OCU/department activity including contractors, volunteers and the public. These assessments also include suitable controls that have been implemented to reduce the risk to acceptable levels;
• The RA4 risk assessment form has been signed by the (B)OCU Commander or HoD;
• These risk assessments have been reviewed in the last twelve months;
• If the (B)OCU/department provides a pan MPS service/s (e.g. pan London firearms, property management, provision of equipment etc). - Assurance has been given to that these activities are appropriately managed (including suitable performance monitoring) and, where appropriate, suitably risk assessed.

Measuring Performance

• Workplace inspections are regularly carried out and significant findings are reported to the (B)OCU/department health and safety committee;
• All accidents, incidents, near misses and reports of ill-health are recorded, reported and, where appropriate, adequately investigated;
• Where required accidents, incidents and ill health are reported to the Health & Safety Executive;
• The (B)OCU/departments carry out trend analysis of reported accidents. This are reported to and reviewed by the (B)OCU/department health and safety committee.

Audit and Review

• The (B)OCU/departments review their H&S performance against the performance targets, set out in the (B)OCU/department annual health and safety plan;
• If the (B)OCU/department has been audited by the SHRMT, Property Services Compliance Team, HMIC or MPA Internal audit:
  • Recommended audit actions have either been completed or scheduled action plans are in place to achieve compliance.

Part Two – Business Group Assurance

• Suitable arrangements are in place to communicate, direct and co-ordinate Business Group health and safety matters, and disseminate these to all (B)OCUs and Departments. Minutes of Business Group safety related discussions/meetings are disseminated to all staff;
• Duties and responsibilities for health and safety at a business Group level have been allocated to appropriate staff;
• Federation, trades unions and staff associations are appropriately consulted on health, safety and welfare issues at Business Group level that have a direct or indirect impact on staff;
• The Business Group carries out trend analysis of reported accidents and near misses. This is reported to and reviewed by the Business Group SMT and other health and safety forum as appropriate;
• The Business Group reviews (B)OCU and department health and safety performance.

Part Three - Health and safety - shortfalls/areas of safety concern

Any health and safety shortfalls or concerns which arise should be listed as part of the assurance process including any work-in-progress/action plans drawn up to address these issues. Shortfalls and concerns that affect health and safety could be as a consequence of many factors such as not fully complying with Part 1 above, general policy, organisational, resources, operational, building related issues, or external factors.

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