Update on MPA/MPS assurance process

Report: 15
Date: 10 December 2009
By: Director of Human Resources on behalf of The Commissioner

Summary

During the first phase of the assurance process Central Operations and the Directorate of Resources were required to submit letters of assurance for Financial Year (FY) 2008/09. These letters are included in the report and were received by the Commissioner in September 2009. Assurance was given by the Commissioner to the MPA on the 14 September 2009.

In addition to achieve roll out of the annual assurance process across the MPS by 2012 Management Board agreed to the following roll out programme time table:

• CO, DoR, SO, SCD, DOI submit letters of assurance at the end of FY 2009/10.
• TP, HR, Deputy Commissioners Portfolio and DPA submit letters of assurance at the end of FY 2010/11.

A. Recommendation

That members receive the report.

B. Supporting information

Background

1. In accordance with the MPA/MPS Corporate Health and Safety Policy Management Board, members are required to provide a letter of assurance to the Commissioner who will subsequently provide appropriate assurance to the MPA.

2. During the first phase of the assurance process Central Operations and the Directorate of Resources were required to submit letters of assurance for Financial Year (FY) 2008/09. These letters were received by the Commissioner in September 2009 and appropriate assurance was given by the Commissioner to the MPA on the 14 September 2009.

3. In addition to achieve roll out of the annual assurance process across the MPS by 2012 Management Board agreed to the following roll out programme time table:

• CO, DoR, SO, SCD, DOI submit letters of assurance at the end of FY 2009/10.
• TP, HR, Deputy Commissioners Portfolio and DPA submit letters of assurance at the end of FY 2010/11.

4. The MPA are now seeking the next letter of assurance for FY 2009/10 by June 2010. The following programme is proposed to meet this timeline:

• OCU’s and Heads of Departments (HoDs) under CO, DoR, SO, SCD and DOI 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 should also be identified, including appropriate action plans. To support this review, each OCU or department should ensure that its local health and safety committee meets to support this process. OCU Commanders and HoDs will be expected to submit their letter of assurance to their relevant AC/Business Group Director (BGD) by the end of December 2009;
• January - February 2010, 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 OCU or department by comprehensive audit in order to give a 'percentage level' of compliance). This will be evidence-based sampling and therefore 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.
• March 2010, the senior safety advisor/s will report their finding to relevant ACs and BGDs.
• April 2010 business groups issue their letter of assurance to the Commissioner;
• May 2010, the Commissioner will prepare the health and safety letter of assurance to the MPA.

5. The MPA Corporate Governance Committee at their recent meeting on 14 September 2009 stated that they should now also receive the signed FY 2008/09 letters for CO and DoR by their December meeting. These letters of Assurance are attached at Appendix 1 and 2.

Assurance update Director of Resources

6. The shortfall and improvement areas that have been identified within the DoR assurance process are subject to remedial action plans and implementation is being monitored by the DoR and Property Services Health and Safety Committees. Nominated DoR/Heads of Department/Directors have responsibility to ensure the implementation/monitoring and confirmation of their respective actions which is monitored by the Director of Resources. Key improvement areas are also listed in the Directorate assurance letter and work continues against the schedules listed.

Assurance update Central Operations

7. Each CO OCU has an action plan that captures local shortfalls and areas for improvement. These plans and the status of actions are managed locally and reviewed at each OCU quarterly health & safety meeting. All these improvements remain local safety related matters, however, there is an escalated process within CO to the Business Group Health and Safety Committee should any significant or matters of strategic importance emerge.

8. SO OCUs that were within CO will now be captured within the forthcoming SO letter of assurance and process. Monitoring progress of these units is now captured within the developing process under SO.

Consultation

9. This report was produced in consultation with CO and DoR.

C. Race and equality impact

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

D. Financial implications

1. 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 further work prioritisation may be required. The current costs associated with the delivery of this process, at this stage, are being contained within existing central and local budgets.

2. Costs associated with any additional work arising out of the assurance process will be subject to a business case and submitted via the appropriate approval channel for consideration as part of the budget planning process.

E. Legal implications

The information in this report assists the Authority in the performance of its duties under Health and Safety legislation and of its strategic oversight role as set out in the joint MPA/MPS Corporate Health and Safety Policy.

F. Background papers

• None

G. 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

Abbreviations and acronyms:

• CO - Central Operations Business Group
• DoR - Directorate of Resources Business Group
• SO – Specialist Operations
• SCD – Specialist Crime Directorate
• DOI – Department of Information
• CGC - Corporate Governance Committee
• HoD - Heads of Department (HoD)
• AC - Assistant Commissioner
• BGD - Business Group Director (BGD)
• OCU – Operational Command Unit
• SHRMT - Safety and Health Risk Management Team

Appendix 1

 Directorate of Resources (DoR) Health and Safety Letter of Assurance

August 2009

Business Group Assurance Process Letter

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

PART ONE - DoR Departments

I have received assurance from each of my department heads that they have fulfilled their responsibilities for health and safety in accordance with the MPA/MPS Corporate Health and Safety Policy including:

Health & Safety policy

My departments have local health and safety policies that reflect local safety arrangements; these have been signed by the HoD and have been communicated to all staff;

These policies have been reviewed in the last twelve months and amended as necessary.

Organisation, Communication and Consultation

Duties and responsibilities for health and safety have been allocated to appropriate staff within my department in accordance with the local and corporate health and safety policies;

All staff has received training commensurate with their role and responsibilities;

All staff has completed mandatory/statutory health and safety training or are scheduled to attend as appropriate;

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 department health and safety committees, which are chaired by the 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 are communicated to all relevant staff.

Planning

The departments have a health and safety plan for the current financial year, setting measurable targets for improvements in health and safety performance;

Each department is reviewing and will complete risk assessments for all tasks and activities undertaken in accordance with the MPS H&S Manual Volume 1 Chapter 5 and the Property Services H&S Manual.

These assessments, where appropriate, take account of risk to not only to MPS staff but others including those that may be affected by the 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 will be signed by the HoD;

These risk assessments are reviewed on an ongoing basis, with all assessments being updated in the last twelve months and amended as necessary;

During July 09 the MPA external Health and Safety Auditor has indicated that it will be beneficial to review and where necessary develop Procurement Procedures to ensure that Health and Safety compliance is an integral part of the procurement process. In order to achieve the aforementioned review a steering group, consisting of members from Procurement, Property Services Compliance Team and SHRMT will prepare a report for the Director of Procurement identifying associated recommendations for consideration/implementation.

It is considered essential that the future provision of a compliant health and safety MPS estate must take into account the age and wear and tear of buildings and premises. It is considered essential for a programme of annual building compliance/health and safety audits to be established, with reports and information issued to relevant departments within Property Services/DoR. The aforementioned action will assist in providing best value by minimizing costs in relation to property damage, repair and refurbishment as well as avoiding potential business continuity and health and safety issues due to deterioration and premises becoming unsuitable for occupation.

In the event of a situation arising where capital funds are not readily available to resolve a significant health and safety issue or continue to maintain a building in a fit for purpose condition, this issue will be immediately referred to the MPA. Interim action may be taken as necessary to close or vacate areas of a building to ensure the safety of personnel, in such an event the MPA will be advised.

A review is to be undertaken by Property Services to ensure that Health and Safety Statutory Compliance audits of the MPA/MPS buildings and estate are effectively undertaken. Various monitoring activities currently undertaken by RCOS in respect of fire/food/water audits/health and safety inspections, Atkins in respect of FM contact compliance and HR5 SHRMT (MPS Chase Audits) will be evaluated and amended to streamline and coordinate the audit process.

The audits will also take into account the age, condition, maintenance arrangements and fit for purpose of buildings across the MPS Estate with information being disseminated to relevant departments within Property Services. The audits will assist in providing best value by minimising costs in relation to property damage, repair and refurbishment as well as avoiding potential business continuity and health and safety issues arising due to premises becoming unsuitable for occupation.

Departments providing pan MPS services

(e.g. Pan London statutory fire compliance, property management, provision of plant and equipment etc). - HOD’s have provided assurance 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 department’s health and safety committees and to Corporate SHRMT and Property Services Compliance Team.

All property related accidents, incidents, near misses and reports of ill-health are recorded, reported to RCOS and, where appropriate, adequately investigated and action taken to prevent a reoccurrence;

Where required accidents, incidents and ill health are reported to the Health & Safety Executive;

Each department carries out trend analysis of reported accidents. These are reported to and reviewed by the department health and safety committees.

Audit and Review

All departments review their H&S performance against the performance targets, set out in the department annual health and safety plan;

The department has been audited by the MPA Internal audit team in September 2008 and an external audit in June 2009. The Recommended audit actions have either been completed or scheduled action plans are in place/will be prepared to achieve compliance.

Compliance with both of the aforementioned audits is monitored by the Strategic Health and Safety Committee.

PART TWO – Business Group Assurance

Suitable arrangements are in place to communicate, direct and coordinate DoR

Business Group health and safety matters and disseminate these to all DoR Departments. Minutes of each of the Health and safety Committees within the DoR Business Group 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. These are reported to and reviewed by the DoR and Property Services H&S Committees and other health and safety forums as appropriate;

The Business Group reviews department health and safety performance and supports recommendations for action.

PART THREE - Health and Safety - shortfalls/areas of safety concern

The following health and safety shortfalls/areas of concern have been identified together with associated action plans drawn up to address these issues. The DoR Health and safety Committee will review and ensure compliance with the actions identified:-

1. Employee Training

HOD’s to prepare an employee training matrix to ensure that essential and mandatory health and safety related training is attended – i.e. Risk Assessment, Leadership course/Fire – Responsible Person/COSHH/Manual Handling etc, training to be attended by relevant/nominated personnel.

• Action: HOD’s - Ongoing to be monitored by DoR and each Departmental Health and Safety Committee
• Completion Date: 30th November 2009

2. Building Compliance Audits

A review is to be undertaken to ensure that Health and Safety Statutory Compliance audits of the MPA/MPS buildings and estate are effectively undertaken. Various activities currently undertaken by RCOS in respect of fire/food/water audits/health and safety inspections, Atkins in respect of FM contact compliance and also HR5 SHRMT (MPS Chase Audits) will be evaluated and amended to streamline the audit process.

The audits will also take into account the age and high usage of the MPS Estate with information fed back to relevant departments within Property Services. The audits will assist in providing best value by minimising costs in relation to property damage, repair and refurbishment as well as avoiding potential breach of statutory duty, business continuity and health and safety issues that could result in a premises becoming unsuitable for occupation.

• Action: RCOS – Phil Smith/Gordon Russell/Nick Kettle
• Completion Date: 31st December 2009

3. Review of MPS Health and Safety Procurement

During July 09 the MPA external Health and Safety Auditor indicated that it will be beneficial to review and where necessary develop Procurement Procedures to ensure that Health and Safety compliance is an integral part of the procurement process. In order to achieve the aforementioned review a steering group, consisting of members from Procurement, Property Services Compliance Team and SHRMT will prepare a report for the Director of Procurement identifying associated recommendations for consideration/implementation.

• Action: Anthony Doyle/Peter Brown/Nick Kettle
• Completion Date: 30th December 2009

4.Communication of Department Health and Safety Minutes

The minutes of the various MPS quarterly health and safety committee are communicated to all DoR staff via notice boards and the MPS intranet site. The Head of Compliance RCOS to confirm procedure to ensure that minutes are displayed and circulated within DoR and Property Services relating to the Strategic, DoR, Property Services, ESB, Hendon and NSY Health and Safety Committees.

• Action: Peter Brown -Head of Compliance RCOS
• Completion Date: 30th September 2009

5. Preparation of Risk Assessments

Each DoR and Property Services department to complete risk assessments for all tasks and activities undertaken and review/amend existing assessments as necessary, in accordance with the MPS H&S Manual Volume 1 Chapter 5.

• Action: HOD’s to confirm to the Chair of the DoR and Property Services Committees that the necessary risk assessments have been prepared/amended and the RA4 risk assessment form has been signed by each HOD.
• Completion Date: 30th November 2009

6. MPA Internal Audit Compliance

The implementation of the recommendations of the audit are being monitored by the Strategic Health and Safety Committee, the next meeting October 2009 and will subsequently be reported to the DoR health and safety committee.

MPA action plan/recommendations to be progressed via each HOD and monitored by the DoR and Property Services Health and safety Committees. A quarterly update of progress to be forwarded to the Strategic Health and safety committee.

• Action: Peter Brown
• Completion Date: 30th November 2009

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

Anne McMeel
Director of Resources

Appendix 2

 Central Operations Business group Health and Safety Assurance process 2008/09

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

Part One - OCU/Department assurance

I have received assurance from my OCU’s/departments that they have discharged their responsibilities for health and safety in accordance with the MPA/MPS Corporate Health and Safety Policy including:

Health & Safety policy

• My OCU’s/departments have local health and safety policies that reflect local safety arrangements; they have been signed by the OCU Commander/Head of Department (HoD) and have been communicated to all staff;

Organising

• Duties and responsibilities for health and safety have been allocated to appropriate staff within my Business Group in accordance with the local and corporate health and safety policies;
• All staff have received training commensurate with their role and responsibilities;
• All staff are required to successfully complete mandatory and, as appropriate, statutory health and safety training. Plans are formulated each year to meet the annual training requirements for my Business Group. Performance in respect of training attendance is monitored at both local (OCU) and Business Group level;
• 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 the quarterly OCU/department health and safety committee, which are chaired by the 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 OCU/departments have a health and safety plan for the current financial year, setting measurable targets for improvements in health and safety performance.
• CO1 incorporates H & S management for CO1, CO3 and more recently the new CO12. (Following the spilt of Olympics Security Directorate moving to the Home Office)
• All OCU’s provide pan MPS services and have all completed activity based health and safety risk assessments for all operational task and activities 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 OCU 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 each OCU Commander.
• These risk assessments have been reviewed in the last twelve months;

Measuring Performance

• Workplace inspections are regularly carried out and significant findings are reported to the OCU’s/departments 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 OCUs/departments carry out trend analysis of reported accidents. These are reported to and reviewed by the health and safety committee.

Audit and Review

• The OCU/department review their H&S performance against the performance targets, set out in the OCU annual health and safety plan;
• Where an 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

• In addition to the OCU health and safety meetings, Central Operations hold 6-monthly Strategic Health & safety meetings chaired by the Assistant Commissioner and attended by OCU Commanders/HoD, and others with designated responsibility for health and safety matters.
• The above meetings are scheduled to follow on from monthly CO SMT meetings, which also has health and safety as a standing agenda item. The Senior Safety advisor is by invitation an ex officio member of both the monthly SMT and the 6 monthly health and safety meetings.
• Suitable arrangements are in place to communicate, direct and co-ordinate Business Group health and safety matters, and disseminate these to all OCU’s/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 meeting and other health and safety meeting.
• The Business Group reviews OCU and department health and safety performance.

PART THREE - Health and safety - areas of safety concern

Since the submission of statements of assurance from OCU Commanders the following OCUs are no longer within Central Operations:

• Diplomatic protection Group (now SO6)
• Palace of Westminster (now SO7)
• Aviation Security (now SO18)
• Transport OCU

Some areas of concern were highlighted by OCU Commanders however, in each case these are supported by an appropriate action plan. All are monitored through the Health and Safety committee with a view to early resolution.

Costs associated with any additional work arising out of the assurance process will be subject to a business case and submitted via the appropriate approval channel for consideration as part of the budget planning process.

Olympics

As previously mentioned the Olympics Security Directorate has during this assurance process changed. The main part of this unit has now moved to the Home Office and as such the staff have moved on a secondment. Responsibilities for health and safety of the national policing operation are the subject of a developing project plan which will be adopted and implemented as appropriate to take account of MPS responsibilities.

The secondment process will take into account the Health & safety obligations and requirements of the MPS insofar as they apply to staff seconded to central service. The remaining small team sitting within CO12 will be brought under CO1 for the purposes of health, safety and welfare.

Chris Allison
Assistant Commissioner
Central Operations

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