MPS Health and Safety Policy implementation

Report: 4
Date: 2 December 2004
By: Commissioner

Summary

This report updates the Metropolitan Police Authority with respect to the MPS’s progress on the MPS Health and Safety audit system.

A. Recommendation

That members note the contents of the report.

B. Supporting information

The system for auditing the MPS Health and Safety Policy

1. The MPS Health and Safety Branch plans systematically to audit the implementation of the Policy and the performance against it, using a new health and safety audit question-set with guidance. The question set has been circulated for consultation with the MPA, Superintendents Association, Police Federation and Trade Unions. To date, only the Superintendents Association has responded - positively. The questions cover such ground as organisation, accountability, responsibility, communication, consultation, competence, training, planning, risk assessment, and active and reactive monitoring.

2. The Health and Safety (H&S) Branch has started to pilot the audit system with a thematic audit of Greenwich Borough in October, looking specifically at managing work-related road safety. That thematic audit did not give rise to immediate or high level findings. In addition, two further thematic audits for first aid at work and four management system audits are planned for November completion.

3. A formal audit programme using an agreed protocol in the next financial year will follow this. More details on the audit protocol are set out at Appendix 1. Further pilots of the audit tool are planned for December and January. Then, once the Health and Safety Policy is re-launched by the new Commissioner and the MPA in February/March 2005, the H&S Branch plans to implement a risk based audit programme on all Borough Operational Command Units (B/OCUs) and Departments at the start of the next financial year. It is anticipated that this programme will roll out over the next three years.

C. Equality and diversity implications

The auditing of the whole of the MPS will ensure that the health and safety of all officers and all members of staff will be addressed. It will also help to show if there is any disproportionate impact in terms of non-compliance with the Policy and enable the Branch to take remedial action if necessary.

D. Financial implications

There are no immediate financial implications arising from this report. The costs of complying with the audit will be met from within existing budgets.

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: The Health and Safety Management System (HSMS) audit process

1. Introduction

In accordance with the Commissioner’s new Health and Safety Policy, all Directorates, Departments and BOCUs have implemented local policies and the supporting Health and Safety Management System (HSMS). The HSMS audit process will be used to assess and benchmark performance against the requirements of the Policy, so that targets for improved performance can be set.

2. HS-MS review audit

The HSMS audit process will be conducted on a self-appraisal basis, using audit questions. Guidance on how to complete the questions will be provided. The results will be analysed using a software programme tool. The same tool will enable the Health and Safety Branch to track progress on implementing recommendations. Directorates, Departments and BOCUs, with assistance from the Health and Safety Branch, can verify that their HSMS has been fully integrated into day-to-day operations at all levels and that there is a developing proactive culture. The audit process is based on one of “assisted self-appraisal and improvement” whereby ownership rests with the Directorate, Department or BOCU.

The keys to a successful audit are:

• Health and safety improvement must be seen to be an integral part of business improvement/risk management in general.
• Emphasis on ensuring that the HSMS is a “living system” and on a proactive development of a better health and safety culture.
• Equal attention must be given to health and safety management throughout the business chain.
• Focus on implementation of the corrective action needed to fill the identified gaps.
• Emphasis on education to ensure sustainable improvement.
• Openness and co-operation.

On completion of the audit document, operational performance capability and cultural gaps will be identified within the HSMS. These gaps will be benchmarked with reference to MPS policies, health and safety standards, standard operating procedures, plus all relevant regulatory requirements.

3. The HSMS audit software tool

A new software tool has been developed to provide a quantified summary of the findings of the HSMS audit. The tool comprises of self-appraisal questions, guidance and includes a programme for analysing results and action tracking.

The software tool is designed to record the results of the HSMS review audit. It covers the three broad areas evaluated during the review and audit:

• HSMS documentation.
• HSMS operational performance.
• HSMS culture.

Every applicable self-appraisal question is assessed using the criteria set out in Annex 1. This gives each question and section a weighted numerical score. The software tool then derives an overall score for the Directorate, Department or BOCU and the scores are shown in a table and graph.

The software tool also facilitates and prioritises recommendations as defined in Annex 2 with a date generated for follow-up action.

4. Audit process

The Health and Safety Branch will assist the audit, which will proceed in three basic stages:

• Pre-audit preparation
• Audit
• Post audit follow-up.

Pre-audit preparation

The Directorate, Department or B/OCU SMT will undertake this stage with assistance from Health and Safety Branch. It will:

• Identify a focal point for the review.
• Place a duty on the Senior Management Team (SMT) to agree the terms of reference and programme of visits for the review.
• Require HSMS documents for the focal point under review to be provided. This will include the identification of actions and recommendations arising from Health and Safety meetings or previous inspections/audits.

Audit

The Health and Safety Branch, with the relevant members of the SMT, will:

• Review selected HSMS documents to include HSMS policy, annual health and safety plans and objectives, health and safety training plan, local risk assessments, minutes of relevant committee meetings and health and safety inspections.
• Review the implementation of actions/recommendations arising from relevant committee meetings, annual health and safety plan, annual training plan, local risk assessments, status of any action plan developed from the last HSMS audit or other health and safety inspections.
• Assess further aspects of the HSMS to evaluate whether the system is ‘living’ and whether the culture is reactive or proactive. This will include an assessment of the use of Key Performance Indicators (KPIs) incident reporting and follow-up, potential incident reporting and follow-up, competence profiling and training records, adequacy of local emergency response plans, health and safety committee structure and attendance, HS awareness campaigns, setting of proactive health and safety tasks and targets for key personnel, communications (use of site notice boards to display health and safety policies, performance information, safety bulletins, campaigns etc.), application of relevant standards and use of PPE (personal protective equipment e.g. respirator, hard hat etc.). An important feature of many of these assessments is the awareness and knowledge of all relevant staff.
• Undertake site visits and interview (staff and contractors) to validate/confirm identify (priority) gaps, as necessary. Site visits will also identify specific physical/technical and operational issues that need to be addressed.
• Record all observations in the HSMS audit tool software. Any observations on specific physical/technical and operational issues that need to be addressed which cannot be captured in the tool will be recorded in the review presentation or in a separate file note.
• Present initial key findings and action plan to the SMT. This will included both strengths and weaknesses.

Post audit

At this stage of the audit process, the key components are as follows:

• The SMT will have two weeks to review the draft HSMS audit software tool report with the results to questions, prioritised recommendations with action timelines, overall scores and recommended performance targets to ensure that it is realistic in terms of priorities, resources and timescales to achieve recommendations.
• Health and Safety Branch will provide the necessary support, where relevant, required to assist the SMT to implement the action plan, e.g. advice on solutions to specific action items, further targeted to provide focused specialist help or training, to review progress.
• The SMT and the Branch will monitor and review the implementation of the local action plan by receiving updates from the Directorate/Department or BOCU focal point at the agreed frequency. Updates will be obtained by routine contact by telephone, email and by a formal update at least every three months.

5. Audit frequency

An audit will be carried out in each Directorate, Department or B/OCU at least every three years or more frequently, if deemed necessary on the basis of the perceived risks of system failings.

A rolling programme for the audits is being developed and will be maintained by the Health and Safety Branch.

Annex 1: Rating criteria

Each applicable question that is assessed during the review and recorded in the HSMS software audit tool is given a rating using the criteria defined below:

Annex 2: Prioritisation of recommendations

During the review recommendations will be prioritised as follows:

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