HSE Inspection Report of Fast Roads And Police Community Support Officers

Report: 8
Date: 23 September 2004
By: Commissioner

Summary

This report updates the Metropolitan Police Authority (MPA) in respect of the Health and Safety Executive’s (HSE) inspection of the MPS in relation to fast roads policing and Police Community Support Officers (PCSOs).

A. Recommendation

That

1. members note the report; and
2. the MPS response to the HSE’s recommendations.

B. Supporting information

1. The following is a summary of the main action points and MPS response to the HSE report ‘Inspection by Health and Safety Executive 16-18 March 2004 Fast Roads and Police Community Support Officers’. The HSE thematic inspection is set out at Appendix 1.

General matters arising

Health and Safety refresher training

2. The HSE felt that the MPS should consider whether any types of health and safety training need to be repeated and/or refreshed. The Strategic Health and Safety Committee has endorsed a comprehensive review of all health and safety training. Specific training issues relating to Transport Police Community Support Officers (T/PCSOs) are as follows:

• CO11 and HR will shortly publish a new policy requiring that Officer Safety Training (OST) for all T/PCSOs will be subject to a pass/fail standard. This is now being considered by Management Board and is expected to be ratified shortly.
• OST refresher training frequency will be 6 hours once a year, which all PCSOs will be required to pass. This training will be identical to the OST given to Police Officers, but without the use of equipment assessments.

Risk assessments

3. The HSE have requested further details on the dynamic risk assessment process. The Branch will provide an appropriate briefing to the HSE on this issue.

Specific Topics

Attending Incidents on fast roads

4. Concern was raised regarding some current practices, such as removing debris from fast roads, the towing of broken down vehicles to a place of safety and rolling roadblocks. Current working practices have been examined in light of the HSE concerns, and the Traffic OCU is content that appropriate training is provided to support a dynamic risk assessment involving relevant hazards.

Non-Traffic Officers working on Fast Roads

5. Concern was raised that non-traffic officers may, on occasions, stop cars on fast roads. Last year, the Traffic OCU began providing fast roads training to (B) OCU trainers. All (B)OCU trainers have now been trained in dealing with incidents on fast roads, and cascade training is being given to (B)OCU drivers and response officers. In addition, this training is given during the Police Constables (PCs) training day, which takes place for all PCs on an annual basis.

6. The Highways Authority traffic officers will commence duty in London in late 2005 and will be the first response to debris calls on the motorways. This will, in turn, reduce calls to the MPS. On other fast roads, the MPS will still be the first response.

7. The Traffic OCU has purchased a training package on managing risk for their risk assessors.

PCSOs/TPCSOs

8. The HSE recommended that, in some Boroughs, the training of PCSOs should be improved. This action reflected the excellent training demonstrated at two Boroughs. Police Notice 3/03 provides the foundation for all Boroughs to ensure that their PCSOs are trained and deployed to the corporate standard. All PCSO training is now under the auspices of Training School instead of being delegated to Boroughs. A thorough corporate training needs analysis has been undertaken, and the new training course has been geared to both TPCSOs and Borough PCSOs. The course started in August this year.

9. The HSE felt that supervision of PCSOs could be improved. This comment reflects the shortage of sergeants in supervisory positions at the time of the report. The Transport OCU has now reached its budgeted complement of sergeants, including acting sergeants. All these sergeants have been given three days training specifically on the supervision of TPCSOs.

10. The HSE was keen to see dedicated PCSOs safety representatives. The Trade Union agreed to review and address this issue. A PCSO safety representative now sits on the Traffic OCU Health and Safety Committee at its quarterly meetings.

11. The HSE was informed that torches were not provided to TPCSOs. All TPCSOs have now been issued with torches for evening/night time patrols, in line with their risk assessment.

12. The HSE noted that some TPCSOs and PCSOs could not participate in OST owing to medical conditions and wondered how these officers could fulfil their duties safely without OST training. HR Board has now agreed on a set of medical standards for TPCSOs, while OST for PCSOs is about to be made a pass/fail standard. T/PCSOs who fail will be given the opportunity to retake the assessment after further training and a clause is to be written into all new TPCSO contracts, which allows for dismissal if the required standard cannot be attained.

13. The HSE was informed that some TPCSOs were being set tasks not covered by their role and training. T/PCSOs now have an additional two days training which reinforces their current role and gives them fast roads training. In addition, the training advises T/PCSOs how to resist the temptation to go beyond their role and perform tasks for which they have not been trained. All courses are now opened by a member of the SMT, which allows T/PCSOs to raise any concerns they might have.

14. The HSE noted that the hats offered to male T/PCSOs (similar to the flat cap issued to police officers) were not of the rigid type and may therefore not offer adequate protection. This is being addressed through a working party that was set up by the Clothing and Appointment Board. A decision regarding suitable future head wear will be made in due course, probably before the end of the year. There are currently three options on the table for this:

• wait for new beat duty helmet to be trialed and introduced (the MPS is not involved in this trial);
• use of the existing beat duty helmet with appropriate badging for T/PCSOs;
• reinforcing the existing flat cap.

C. Equality and diversity implications

There is no evidence of any differential impact on the health and safety on any particular group or minority amongst those involved in Fast Roads policing or amongst PCSOs. The Branch will keep this under review.

D. Financial implications

The improvements necessary to implement the HSE recommendations from its thematic inspections have been met from existing budgets. Otherwise, there are no direct financial implications arising from this report.

E. Background papers

None

F. Contact details

Report author: Louis Backwell, Head of Health and Safety

For information contact:

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

Appendix 1

Principal Inspector : Mrs M Pretty
Metropolitan Police Service
New Scotland Yard
Broadway
LONDON SW1H 0BG

Your reference:

Our reference: 060106016

19 April 2004

Direct line : 020 7556 2174

For the attention of Assistant Commissioner Hogan-Howe

Dear Mr Hogan-Howe

INSPECTION BY HEALTH AND SAFETY EXECUTIVE 16-18 MARCH 2004
FAST ROADS AND POLICE COMMUNITY SUPPORT OFFICERS

Thank you for attending the feedback session on 18th March at Belgravia Police Station. As you know, Inspectors from the Health and Safety Executive, including myself, interviewed a range of people, and visited a number of MPS buildings, between 16-18th March to determine compliance of the Metropolitan Police Service with the Health and Safety at Work etc Act 1974. Rather than consider all aspects of health and safety, we considered only two issues: safety of officers attending fast road incidents and secondly, general safety of Police Community Support Officers (including Transport PCSOs).

The first topic was chosen as there have been a number of serious injuries to officers attending fast road incidents across the country and the second was chosen because Police Community Support Officers are a relatively new tier of officers and we wished to determined whether there were any issues arising from this.

As we expected, the logistics of the inspection were well planned and we received a helpful and courteous responses from everyone that we spoke to.

General matters arising

Health and Safety Policy Statement of Operational Command Units

The health and safety policy statement of the Transport Operational Command Unit, updated 1 March 2004, is a document with much promise. I think it is one of the first ‘new-style’ Command Unit policy statements which will soon become force-wide in the MPS. It sets out how the Command Unit intends to comply with the aims given in HSE’s publication ‘Successful Health and Safety Management, HS(G)65’ and compliance with the policy should ensure high quality of health and safety management.

Refresher Training

With the exception of Officer Safety Training, I do not think that training with a health and safety content is repeated or refreshed at regular intervals. The MPS should consider whether any types of health and safety training need to be repeated and/or refreshed so that officers can readily recall their training should the need arise.

It is likely that some training will need to be refreshed more frequently than other types.

Risk Assessments

It was noted that there are many generic risk assessments for the activities of Police Officers and PCSOs. It would be useful for me to see how dynamic risk assessment, or other real time health and safety information source, is developing.

Specific Topics

The following notes relate to the topics that we considered in detail. The notes in brackets after most paragraphs are the most relevant management elements given in ‘Successful Health and Safety Management’

Attending Incidents on Fast Roads

Areas of good compliance

Many positive comments were received from traffic officers, for example “It’s just as well you weren’t here two years ago” (as conditions have improved). (Organising and Measuring Performance)

There is general recognition that the Motorway training course is greatly improved and that the equipment carried on traffic cars has also improved in the last few years. (Organising and Measuring Performance)

Most officers were aware of the generic risk assessments that related to road traffic. (Organising).

Areas for improvement

We received mixed responses from officers on whether Police Officers were expected to:

Remove debris from fast roads
Tow broken down vehicles from fast roads to a place of safety

If officers are expected to undertake these tasks, the decision should be made known to Traffic Officers. It may be that both activities can be undertaken in certain circumstances, and again this information needs to be passed on to officers. Risk assessments may help you make this decision. (Organising - communication/competence, planning and implementing).

It was also explained to HSE Inspectors that rolling road blocks are used in some situations, for example to remove debris from fast roads. It was explained that two traffic cars are needed; one stops on the hard shoulder ahead of the rolling block whilst the other traffic car forms the lead vehicle in the block. However, we were told that it is not always possible to have two traffic cars available but no alternative option was given if two cars are not available. What is the alternative in this situation?

It was also noted that in some situations, vehicles would try and get past the rolling road block. Clearly if vehicles pass the road block, officers and other people may be exposed to the risk of being struck by a vehicle when they believe the road is free of traffic.

From what we were told, it seems that there are safety issues around the use of rolling road blocks and again an assessment may assist with your decision. (Note: prior to the inspection, a number of documents were sent to HSE by the MPS, but I don’t think that we have an assessment or procedure for rolling road blocks. However, rolling road blocks are referred to in Risk Assessment 7 (Motorways and Fast Roads) and in Risk Assessment 22 (Tunnels and Underpasses)). (Organising - control/communication/competence, planning and implementing).

Reference was also made to non-traffic officers stopping vehicles on fast roads. This does seem to be relatively rare, but one specific location is outside Heathrow Airport where occasional ‘hard-stops’ are made. There may be valid reasons for this type of stop, but it also necessary to ensure that the risks to officers and members of the public are at the minimum. Again, this topic should be considered and assessed (if not already done so – I have no relevant assessments).

Another example that was given was the occasional stops by borough (non-traffic) officers and cars stopping vehicles on fast roads, but this seems to be rare). (Organising - control/communication/competence, planning and implementing).

Police Community Support Officers

Areas of good compliance

Several promising borough-wide initiatives were explained to HSE Inspectors. These may be widespread, but as we only visited a small number of boroughs, we cannot say just how widespread they are. (Organising - control/communication/competence, planning and implementing).

Additionally there were local initiatives for training supervisors and it was stated that in some boroughs there were regular debriefs, which were appreciated by PCSOs (Tower Hamlets). Another borough (North Woolwich) TPCSOs seemed to be very involved with their risk assessments and in some boroughs the generic risk assessments were customised to local circumstances. (Organising - control/communication/competence, planning and implementing).

Local funding for some PCSOs (e.g. the Poplar Area Neighbourhood) enabled some PCSOs to have mobile phones and torches, etc.

Areas for improvement

As noted above, there are local initiatives to ensure that PCSOs are well trained and properly supervised, but of course the inverse of this is that in some boroughs the training and supervision of PCSOs could be improved. (Organising - control/communication/competence, planning and implementing).

HSE inspectors were told that PCSOs are expected to undertake Officer Safety Training on a regular basis, and of course HSE Inspectors would agree with this. However, we were also told that some PCSOs are unable to participate in this training due to medical conditions. We were unclear how PCSOs can fulfil their duties safely if they are not given their mandatory Officer Safety Training. (Organising - communication/competence, planning and implementing).

We were also given some indications that PCSOs were sometimes asked to do tasks that were beyond their remit, and again we were concerned that there may be implications for their own safety if they are asked to do something beyond their training. For example, PCSOs were required to undertake traffic management duties which are outside the PCSO remit. (Organising - control/competence, planning and implementing).

We were also told that in some boroughs, there were no safety representatives at PCSO level. Whilst the MPS has no powers to make PCSOs volunteer, HSE encourages PCSOs to come forward to ensure that have full representation in matters affecting their health and safety.

Transport Police Community Support Officers

Areas of good compliance

It was noted that TPCSOs are given a standard six-week training course, which ensures consistency of delivery to all TPCSOs. We were told that personal safety is stressed right form the start. (Organising - communication/competence).

Areas for improvement

Some of the topics for improvement for PCSOs also apply to TPCSOs as well. For example, some TPCSOs are unable to participate in the ‘mandatory’ Officer Safety Training. (Organising - communication/competence, planning and implementing).

Similarly, we were told that occasionally TPCSOs were asked to do tasks that were beyond their training such as detaining shoplifters.

Some TPCSOs thought that additional training in handling public expectation might help to reduce aggression from members of the public. This point derives from the public’s lack of awareness of the role of the new TPCSOs. (Organising - communication/competence).

It was explained to HSE Inspectors that the information from the TPCSO risk assessments had not been passed onto the trainers at Hendon and this resulted in a slight mis-match between the training given and the needs of TPCSOs. (Reviewing performance).

Some TPCSOs did not know of the new Service-wide safety policy and the preventive and protective measures identified by the risk assessments. (Policy, Organising - communication/competence).

There were also concerns raised by some TPCSOs who said that there was a lack of experienced supervision of their activities and this compounded the lack of experience of many TPCSOs. (Organising - communication/competence).

We were told that torches were not provided to TPCSOs, yet risk assessment ‘Deployment TPCSOs’ by Inspector Maurice Hartnett (at item 11) states that torches to be carried for evening/night time. (Reviewing performance).

We were also told that the hats provided to female TPCSOs were a rigid construction but the hats offered to male PCSOs were of a softer type. This may be the same for other PCSOs and Police Officers, but it was only raised for TPCSOs. This in turn, raises an interesting point about the selection of personal protective equipment which I have discussed in the annex to this letter.

Circulation of this letter and information for employees

I have sent copies of this letter to Louis Backwell & Chief Superintendent Brian Wade both of the MPS Health and Safety Branch and Chief Superintendent Mark Gore and Superintendent Ian Chappell as the chosen topics are particularly relevant to them.

I have also sent copies to Steve Rands and Carol Palmer as they are entitled to receive copies. Copies of this letter may be shown to other employees in the MPS as Section 28(8) of the Health and Safety at Work etc Act 1974 entitles employees to see it.

Yours sincerely

S R Kirton
H M Inspector of Health And Safety

Cc

Louis Backwell, Head of Health and Safety Branch
Chief Superintendent Brian Wade
Chief Superintendent Mark Gore
Superintendent Ian Chappell
Steve Rands, Health and Safety Secretary, Metropolitan Police Federation
Carol Palmer, PCS

Annex 1

Choosing Personal Protective Equipment For Police Officers And Police Community Support Officers

The first stage in considering whether Personal Protective Equipment (PPE) such as head protection should be provided, is a risk assessment, conducted in accordance with Regulation 3 of the Management of Health and Safety at Work Regulations 1999 (the “Management Regulations”). This requires every employer to make a suitable and sufficient assessment of the risks to health and safety that his employees are exposed to at work. In this case, the employer is the Chief Officer of Police for Police Officers and/or (depending on whether the MPA employs PCSOs for the purposes of the Health and Safety at Work etc Act 1974) the Metropolitan Police Authority for PCSOs. For Officers (I will use the term Officer to include Police Officers and PCSOs for this note), such an assessment would need to include the risk of violence.

Regulation 4 of the Management Regulations requires that where preventative and protective measures are to be implemented (as a result of the risk assessment), they must be on the basis of the general principles in Schedule 1 of those same Regulations. These include avoidance of the risk; evaluation of the risk which cannot be avoided; combating the risk at source; adapting the work to the individual; adapting to technical progress; developing a coherent policy; giving collective protective measures priority over individual protective measures; and giving appropriate instructions to employees.

Where a risk cannot be adequately controlled by other means, then suitable PPE can, as a last resort, be provided. This requirement is found within Regulation 4 of the PPE at Work Regulations 1992. PPE is not “suitable” unless; it is appropriate for the risk or risks involved, the conditions at the place where exposure to the risk may occur, and the period for which it is worn; it takes account of ergonomic requirements and the state of health of the person or persons who may wear it, and of the characteristics of the workstation of each such person; it is capable of fitting the wearer correctly (if necessary, after adjustments within the range for which it is designed); so far as practicable, it is effective to prevent or adequately control the risks involved without increasing overall risk; and it complies with any enactment implementing any provision on design within any European Directive. The latter requirement gives rise to the CE marking of equipment. NB - PPE designed and manufactured specifically for use by the armed forces or in the maintenance of law and order (helmets, shields, etc), is not subject to the requirements of the Personal Protective Equipment Regulations 2002. So Police unique PPE does not need to be CE marked.

There is also a specific requirement in Regulation 6 of the PPE at Work Regulations, for an assessment of the PPE that it is proposed to provide, so as to ensure that is suitable. The assessment also has to consider any risks to health or safety which have not been avoided by other means; the definition of characteristics which the PPE must have in order to be effective, taking account of any risk the PPE itself might create; and a comparison of the two previous assessments, so as to endure that the PPE provided is suitable and appropriate.

The PPE at Work Regulations then contain further requirements for the maintenance of the PPE (which would include its cleaning); its storage (an absolute requirement); provision of information, instruction and training; its use by employees; etc.

How then could this process be applied to the particular issue of Police head protection? An appropriate person would have to conduct a risk assessment of his Force’s activities. If there were a risk of violence, which there almost certainly would be for many Police operations/work activities, then the employer would have to consider how that risk might be avoided or controlled. In some instances it might be avoided, but for much routine Police work, it probably cannot. Control measures would need to put in place, taking account of the general principles referred to above. These would no doubt include the use of intelligence; local knowledge; command and control; effective communication systems; training of officers in awareness and de-fusing techniques; provision of self defence equipment such as batons, rigid cuffs and CS (along with appropriate training and information); etc.

If, having provided these control measures, there was still considered to be a residual risk of violence (either constantly, on particular occasions or in certain locations), then the employer might decide that PPE could further reduce that risk. Having made that assessment, a further assessment must be made to determine the nature of the residual risk of violence, and compare it with the PPE that might be provided, as a precursor to selection of suitable PPE (this is the PPE specific assessment required by Regulation 6 of the PPE at Work Regulations). So if the residual risk was one of attack to the head, then protective head wear would seem appropriate. Whilst European standards do not exist for Police PPE of this kind, the Police Scientific Development Branch (PSDB) standards are considered appropriate.

Indeed there is now a type of police helmet constructed to PSDB standards which is in the process of being trialled. If these trials are successful, it may be worthwhile considering the new and old style helmet to see how they compare in terms of the information that I set out in this annex. However, I need to point out that there is no exemption in the PPE at Work Regulations 1992 for turban wearing Sikhs or other people who choose not to wear a helmet.

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