3.3 hazard identification risk assessment and management process review june 2011fintb1211
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Hazard Identification, Risk Assessment and Management Procedure
Documentation Control
Reference: GG/CM/007
Date approved:
Approving Body: Trust Board
Implementation Date:
Version: 3
Supersedes: Version 2 (2 September 2009)
Consultation: Clinical and NonClinical Hospital Staff Organisational Risk Committee Directors’ Group Trust Board
Distribution: Executive Directors, Directorate Clinical Directors, Clinical Leads, Directorate General Managers, Heads of Service Members of the Quality Assurance Committee, Quality Operational Group and it’s Sub Committees Specialists Advisors, as set out in the Trusts Risk Management Policy Relevant External Stakeholders
Target Audience All Trust staff and relevant Stakeholders
Supporting Policies and Procedures
NUH Risk Management Policy Trust Annual Plan Board Assurance Framework.
Review Date: December 2012
Lead Executive(s): Medical Director
Author/Lead Manager: Head of Organisational Quality, Risk and Safety
Further Guidance/Information
Head of Organisational Quality, Risk and Safety (ext 76018 / 62553)
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1. Introduction
This procedure sets out the Trust operational processes for Hazard Identification, Risk Assessment and the Management of risk. This document should be read in conjunction with the Risk Management Policy.
This procedure covers all of the Trust’s activities and should be used when assessing any kind of hazard (e.g. clinical, strategic, organisational, financial and health & safety).
It can be used by any member of the Clinical or NonClinical teams in all Directorates and Departments of the Trust.
The Hazard Identification, Risk Assessment and Management procedure supports the principle that risks which can be reasonably managed locally should be managed locally. Where this is not practical or where the risk score dictates the procedure sets out the escalation process to Trust Committees and Fora.
The tool has been designed for a wide range of purposes i.e.
• it can be used to review and manage all known risks, • it can be used to assess potential risks from new activities, service
development and projects • it can also inform business cases and development projects allowing
comparisons and prioritisation to be made.
2. Risk Registers
The Trust requires that all risks are recorded on DATIX. No other systems are permitted.
The Trust will maintain a Significant Risk Register which comprises of all 20 or 25 scoring risks (as ratified by the Quality Assurance Committee).
The Significant Risk Register will be reported to the Trust Board each month (except those months where the Trust Board receives the Board Assurance Framework).
The Trust requires that all Directorates, Specialties and Departments undertake systematic and proactive hazard identification and risk assessment to identify local risks to service provision, service quality, legislative compliance, financial and
HAZARD IDENTIFICATION, RISK ASSESSMENT AND MANAGEMENT PROCEDURE
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delivery of the Trusts objectives and operational requirements. Heads of Service are responsible for ensuring this happens
All Risk Assessments (irrespective of score) must be recorded on the DATIX system. The system entry must include details of any mitigating actions required to further mitigate the risk (including responsibilities and timescales). Where Risk Assessment forms are generated these must be uploaded into DATIX in the document section of the electronic record along with any supporting emails, reports and documents.
The Trust’s Risk Register is a live, continually evolving document.
The Risk Register provides a focus for the work of the Trust Board and its Committees by communicating risk information throughout the organisation, and providing the necessary assurances that risks are being effectively managed.
3. Definitions
Hazard is defined as a source of potential harm or a situation with a potential to cause loss [Graham & Kaye 2006]
Risk is defined as the possibility of suffering some form of loss or damage and / or the possibility that objectives will not be achieved or that opportunities will not be taken. This can be opportunities / benefits (Upside risk) or threats to success (Downside Risk).
Risk Assessment is defined as the process of determining the level of risk that a hazard poses in combination with the likelihood of its occurrence.
Risk Control is defined as the part of the risk management process that is concerned with the implementation of policies, processes, tools, and techniques that accept, eliminate, remove or transfer risk; or establish business continuity processes. Controls may be preventative, detective or postevent. [Graham & Kaye 2006]
Risk Treatment is defined as the selection and implementation of options for managing risks. [Graham & Kaye 2006]
Risk Transfer is defined as the treatment or control of risk through sharing the burden of loss or benefit from a risk with another party. [Graham & Kaye 2006]
Risk Register is a formal record that captures all known Trust Risks. For each risk, Risk Registers capture the source, nature, existing controls, the consequences and likelihood of a risk being realised and the actions required to further mitigate the risk.
4. The process
Step 1 IDENTIFING HAZARDS
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At local level, there will be different people leading on different aspects of risk management, e.g., Clinical Governance Coordinators, Health & Safety link persons, Directorate managers, risk assessors, infection control link persons, Trust Specialist Advisers to name a few.
It is not intended that these activities are merged into a single role. It is more about people working together to integrate activity at a local level and to work together in the identification, assessment and management of risk.
Hazard identification can take many forms including;
• Through the local review of Incident, Claims and Complaints data, • As a result of an Health & Safety audit / inspection, • Following a Patient Safety conversation, • In response to an Internal Audit report, • In response to an external report / directive / Alert, • In response to a Department of Health directive, • To respond to gaps identified from the Health & Safety Compliance review, • Accreditation Standards compliance (CQC, NHSLA etc.) • To respond to Trust requirements such as CIP’s, Essence of Care
Benchmarks, CQuins, HR including Mandatory Training performance • To meet legislative requirements • Through review of service specific standards, service quality and service
delivery • In response to advice received from Specialist Advisers
The above list is not exhaustive. The Integrated Governance Team can help facilitate hazard identification sessions if required.
When assessing any service or activity, you will identify a number of hazards. You will need to decide if you are going to record these risks on a single form or group the issues on more than one form. Either way is perfectly legitimate. Which ever method adopted you will need to ensure that the action plans address all component hazards and not just the highest scoring one. The hazards identified should be recorded in the “Hazards, Controls and Assessment” section on the Trust approved “Generic Risk Assessment Form” (see Appendix 2). For each hazard identified you will also need to decide who or what can be harmed (and how) and document any controls that are in place. The next step will be to determine the consequence and likelihood scores for each i.e. the risk (see steps 2&3 below).
No other risk assessment forms are permitted.
Step 2 DETERMINE THE CONSEQUENCE
The tool incorporates 5 consequences factors against which a hazard could impact,
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1. Objectives / Financial, (AObjectives) 2. Degree of Harm (to Staff, Patient, Visitor or Member of the Public), (BHarm) 3. Claims & Complaints / Patient Experience, (CExperience) 4. Impact on Services / Business Interruption / Projects, (DService Delivery) 5. Adverse Publicity / Reputation/ Inspection / Audit / Enforcement Action. (EExternal)
Appendix 3, sets out the 5 consequence factors along with descriptors for each that depict a range of outcomes from 1 to 5. For each hazard identified, you will need to determine a consequence score for each of the factors, which will need to be recorded on the form. You should look at the controls in place when deciding the level. If any of the factors don’t apply to the hazard being assessed then add a score of 1 in the appropriate column on the Generic Risk Assessment Form.
Helpful Process Definitions
Primary Objective For 2011/12, the Trust’s Primary Objectives are detailed in the Trusts Annual Plan. These are the “major things” that the Trust has declared it want to achieve in year to meet its Strategic aims.
Trust Key Task For each of the Primary Objectives the Annual Plan also describes a number of subobjectives that could impact on the delivery of the primary objective. These are important things the Trust wants to deliver on but failure of one or more would not necessarily prevent the Primary Objective being achieved.
Temporary NonCompliance This applies where you have an objective or key task, which at the time of assessment is not being complied with, but there is a plan in place that will bring the objective back into compliance within year.
Non Achievement This applies when the objective or key task, which at the time of assessment is not being complied with, and there is no plan in place or possibility that compliance will be achieved in year.
Control Measures These are the things that have already been put into place to manage/ mitigate the risk. These can be things such a Policies, training, safe systems of work, physical safeguards etc.. These are only control measures once they are in place. If things are planned but not in place, they should be recorded as actions. Generally as action are completed these will become controls.
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Step 3 DETERMINE THE LIKELIHOOD
Once you have determined the consequence (for each of the hazards you identified), you will need to determine the likelihood of the level of consequence you have identified being realised. Remember it’s the likelihood of the consequence occurring, not how often the activity takes place.
It is also important that any existing control measures are taken into account when determining the likelihood score. The derived score should also evaluate whether:
§ the control adequately addresses the hazard § the control measure is documented and communicated § the control measure is in operation and applied consistently.
Once you have determined the score enter the score(s) in the Likelihood box on the Generic Risk Assessment Form.
TIP: The worstcase scenario doesn’t always yield the highest risk. You can have a catastrophic consequence such as a death (consequence = 5) which due to the controls in places gives a likelihood of 1 and therefore a risk score of 5. But the same hazard may cause less severe harm (consequence = 3) each month (likelihood = 4) giving a risk score of 12.
Step 4 ASSESS THE RISKS
The risk score is determined by multiplying the consequence and likelihood scores you have recorded for each hazard.
It has been recognised that by using a 5 by 5 tool there will be limited stratification of risks within the possible score bandings. (i.e. the possible scores (CxL) that can be achieved are 1, 2, 3, 4, 5, 6, 8, 9, 10, 12, 15, 16, 20 and 25). To aid prioritisation of risks particularly within the higher scoring bandings (15, 16, 20 and 25) a second score is determined by adding together the 5 individual consequence scores to give a unique score for each risk.
This Priority Indicator Score will then be used to help stratify the risks recorded against a given scoring banding. The PI Score for each risk should be recorded on the Generic Risk Assessment Form.
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Step 5 MANAGE THE RISK
By comparing the Risk Score (Risk Rating) obtained with the table below, you will be able to determine whether the risk you have assessed is “unacceptable”, “tolerable” or “acceptable”. The table also prescribes where the risk needs to be communicated and the management action required.
Table 1 – Levels of Risk, Reporting and Accountability
Risk Rating Level at which the risk must be reported
Who needs to be informed
Management Actions Required
Significant (20 25) Unacceptable
Quality Assurance Committee (QUAC) and Quality Operational Group (QUOG)
Trust Board Immediate action required to eliminate or manage risk. Report to Directorate Clinical Director / Head of Department & The Quality, Risk and Safety Committee / Trust Board. Risks scoring 20 or 25 will be routinely monitored and actions performance managed via the Quality Operational Group. Operational management of these risks will be apportioned to the relevant governance committee / forum, for example clinical risks will be forwarded to the Clinical Risk Committee for monitoring delivery of agreed actions.
High (1519) Unacceptable
Appropriate Sub Committee of the Quality Operational Group
Quality Operational Group
Urgent action/senior management attention required to eliminate or reduce the risk. Report to Directorate Clinical Director / Head of Department. Risks scoring between 15 and 19 will be reviewed by the Organisational Risk Committee who will agree at what level the risk and subsequent actions should be managed.
Moderate (1014) Unacceptable
Directorate Organisational Risk Committee
Action/senior management attention required to eliminate or reduce the risk. Report to Directorate Clinical Director / Head of Department. Risk can be managed at Directorate Level if appropriate. Report upwards to relevant Risk Committee.
Low (49) Tolerable, manageable
Specialty / Directorate Directorate Action if cost efficient to reduce or manage risk. Local actions. Delivery against any plans will be monitored via the Directorate Governance arrangements.
Very Low (13) Acceptable
Specialty / Directorate Directorate Manage situation with routine procedures at a Specialty or Department Level. Action if easy to implement and inexpensive. Delivery against any plans will be monitored via the Directorate Governance arrangements.
If any actions / controls are required to further mitigate the risk these should be recorded in the “Action Planning & Monitoring” section of the form along with named persons responsible for undertaking the action and the timescale for completion. The responsibility for ensuring that any actions identified are taken forward will be dependant upon the risk score. For example a risk scoring 8 (from the table above) would be “reported / managed” by the Specialty / Department whereas a risk scoring 12 would be “reported / managed” by the Directorate.
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Step 6 IF RISK CAN’T OR SHOULDN’T BE MANAGED LOCALLY
Where possible, risks should be managed at the lowest practical level.
However where this is not possible (e.g. due to the resources required) the risk should be escalated to the next level. i.e. if a Department can’t manage a risk it should pass to the Directorate / Corporate Function. If the Directorate / Corporate Function it should be passed to the ORC.
It is also acknowledged that certain risks shouldn’t be managed locally, i.e. where the issue impacts across the Trust. In these instances it is appropriate to escalate the risk so that a Trust wide response can be actioned and implemented. A key part of the process within the Organisational Risk Committee will be to agree the route for handling those issues that can’t or shouldn’t be handled at Directorate level. The Organisational Risk Committee will oversee these risks and ensure that appropriate committees / groups are taking action.
Risks may have to be accepted or, in the case of significant risks, shared with the commissioners of services, members of the health care community and other stakeholders.
If you are unsure what to do please seek advice from a member of the Directorate Team or the Integrated Governance Team who will advise you on action to be taken.
Step 7 UPDATE THE RISK REGISTER
All risks identified, along with the risk score, controls and actions, need to be recorded on the DATIX Risk Management System in order to form the Trusts Risk Register. Each Directorate and Corporate Function has a named lead who will be able to assist with this process. All relevant information to support the risk assessment should be imported into the record. Staff adding risks to DATIX will need to access the training provided. Data can be copied and pasted from the Generic Risk Assessment Form into the DATIX risk entry.
All risks scoring 20 or more will be added to the Trusts Significant Risk Register and Board Assurance Framework. This will help to facilitate the management of risks, the identification of trends and significant risks, as well as the monitoring of risk management.
All risk registers need to be formally reviewed at least quarterly at Trust, Directorate, Speciality and Departmental Governance Forums. At each review the risk register needs to be updated to reflect progress on actions and to review risk scores.
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Appendix 1
HAZARD IDENTIFICATION, RISK ASSESSMENT AND MANAGEMENT PROCEDURE FLOWCHART
Directorates and Departments supported where appropriate, by the Integrated Governance Team
STEP 1 Record the details of the activity being assessed on the Generic Risk Assessment Form. Use the tools and
techniques available to identify and record the key hazard to the activity, process or task
being assessed.
Refer to Governance Checklists, Policies and Guidance to identify risks. (Checklists to incorporate legislation, external accreditation standards, best practice, etc.) Incident, Claims and Complaints data
STEP 2 – For each hazard identified determine the Consequences
STEP 3 Determine the corresponding Likelihood (for the highest scoring
Consequence)
STEP 4 – Determine the Risk Rating and Priority Indicator score
See Generic Risk Assessment Form
Add to Directorate, Specialty, Department Governance Action Plan
STEP 5 Manage the risk
Performance Managed by Directorate
STEP 6 Issues that can’t/shouldn’t be managed by the Specialty / Department, OR can’t be accepted, as they score 10 or more
Add to Directorate Governance Action Plan Manage the risk
Performance Managed by Organisational Risk Committee
STEP 6 Issues that can’t/shouldn’t be managed by Directorate OR can’t be accepted, as they score 15 or more
STEP 7
Update Risk Register
Filtered by Organisational Risk Committee and referred to relevant
Committee/group/individual for action, e.g., to Clinical Risk Committee to be added to
Trust Governance Action Plan
Performance Managed by the Quality Operation Group or relevant Trust Board Committee
STEP 6 Issues that can’t be managed OR can’t be accepted, as they score 20 or more
Any risks scoring 20 or more Raise at the Board
10
Appendix 2
GENERIC RISK ASSESSMENT FORM Assessment No.
Campus: Directorate: Speciality/Department: Location:
Assessor: Job Title: Date: Description of activity
Supporting information (for example, case of need, explanation of activity)
Hazards, Controls and Risk Assessment
No. Hazard Identified Controls in place A O
bjectives
B H
arm
C E
xperience
D S
ervice Delivery
E External
Likelihoo
d
Risk Sc
ore
(Highest Score A
E
x Likelihoo
d)
Priority Indicator Score
(A+B+C+ D+E)
Does the control
adequately address the
risk? Yes / No
Is the control measure
documented and communicated?
Yes / No
Is the control Measure in
operation and applied
consistently? Yes/ No
1
2
3
4
5
11
Summary of action taken to date
Action Planning and monitoring (dependant upon score)
Hazard Ref No. Action required
Cost (£) (If known) By Whom Due Date Review Date
Revised Risk Score
Official Use Only Approval Group Added to the Risk Register Y / N
Date Score Approved Date added to the Register
12
Consequence and Likelihood Matrix Appendix 3 Objectives* / Financial
Degree of Harm (to Staff, Patients,
Visitors or Members of the Public)
Claims & Complaints / Patient Experience /
Outcomes
Impact on Service Delivery / Business
Interruption / Projects
Adverse Publicity / Reputation / Inspection / Audit / Enforcement
Action Likelihood
1 Minor
Minor impact on Trust objective. AND /OR
Barely noticeable reduction in scope or quality
AND /OR Small loss.
Minor injury not requiring first aid or no apparent injury / adverse outcome, Near Miss.
Verbal locally resolved Complaint. Reduced quality of patient experience not directly related to the delivery of patient care Small claims (up to £25,000)
Negligible impact, brief loss / interruption > 1 hour of service. Insignificant cost increase / schedule slippage. <1%)
Local interest, rumours within Trust. Little effect upon staff morale. Small number of minor recommendations, which focus on minor quality improvement issues. Minor noncompliance with CQC
Not expected to occur for years Probability <1%
2 Moderate
Temporary non compliance with Trust Key Tasks*
AND /OR Minor reduction in quality /
scope AND /OR
Loss > 0.1% of Trust budget
Temporary Minor Injury / Illness / Effect. First aid treatment needed, referral to A&E / OH / GP
Justified formal Compliant. Unsatisfactory patient experience directly related to patient care readily resolvable
Local only. Some loss / interruption delays in service provision (> 8 hours) < 5% over budget / schedule slippage.
Local adverse publicity, local media coverage, adverse publicity for < 3 days. Minor effect on staff morale/public attitudes. Internal inquiry reported to local committee structure. Recommendations made which can be addressed by lowlevel management action. Noncompliance with the Developmental requirements of the CQC
Expected to occur annually in the UK or 15 years in the Trust Probability 15 % The event may only occur in exceptional circumstances
3 Serious
Temporary non compliance with Trust Primary
Objective* AND /OR
Reduction in scope or quality. AND /OR
Loss > 0.25% of Trust budget
Semipermanent Injury, Over 3 day reportable injury. RIDDOR / Agency reportable
Independent review. Mismanagement of patient care, short term effects (<1 week) Justified complaint involving lack of appropriate care. Significant claim (up to £250,000)
Critical Service loss / interruption, minor delays > 1 day. 5 10% over budget / schedule slippage.
Local media coverage, adverse publicity for > 3 days. Significant effect on staff morale / public perception of organisation. Internal inquiry reported to external agency. Challenging recommendations that can be addressed with appropriate action plan. Reduced rating. Noncompliance with core requirements of the CQC
x Expected to occur at least annually Probability 620% The event may occur at some time
4 Major Nonachievement of Trust’s
Key Tasks* AND /OR
Loss > 0.5% of Trust budget
Major injuries, or long term incapacity / disability, Major Specified Injury (RIDDOR)
Ongoing National publicity. Regional inquiry. Ombudsman. Serious mismanagement of patient care, long term effects (>1week) Multiple justified complaints. Multiple claims or single major claim (over £250,000).
Critical Service loss, major reduction in service > 1 week 10 25% over budget / schedule slippage.
National media coverage, adverse publicity for < 3 days. Regional inquiry. Severe effect on staff morale, public confidence in organisation undermined. Enforcement action Low rating / Critical report Major noncompliance with core requirements of the CQC
Expected to occur monthly Probability 2150% The event will occur at some time
5 Catastrophic
Non achievement of Trust Primary Objective(s)*
AND /OR Loss > 1% of Trust budget
Death or major permanent incapacity
Full National Inquiry. Select Committee. Public Accounts Committee. Totally unsatisfactory patient outcome or experience
Total loss of Critical Service or facility. >25% over budget/ schedule slippage.
National/international media coverage with adverse publicity for > 3 days. Loss of key staff. Public inquiry / MP Concerns raised in Parliament. Court enforcement. Noncompliance with legal requirement, which may result in Prosecution, Zero rating. Severely critical report
Expected to occur at least weekly Probability > 50% The event is expected to occur in most circumstances
*FOR CURRENT YEAR OBJECTIVES PLEASE REFER TO THE TRUST ANNUAL PLAN.