Health & Safety Service Plan

2011-2012 www.southwark.gov

.uk Drawn up in accordance with the Health and Safety Commission’s Guidance issued under Section 18 of The Health and Safety at Work etc Act 1974 Approved by the Cabinet Member for Finance, Resources and Community Safety xxxxx 2011

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Introduction

This is Southwark’s occupational health and safety service plan focused on the

health and safety enforcement function. It covers all elements of health and safety

relating to premises and functions falling within this local authority’s remit for health

and safety enforcement. The Service Plan also covers objectives relating to non-

enforcement activity, including advice and education to business and partnership

working.

The Service Mission statement for the whole of Environmental Health is

included within this service plan; the objectives are designed to reflect and contribute

towards the achievement of the fairer future vision within the Council Plan, and the

six key principles that underpin it.

This service plan is an expression of the authority’s commitment to the development

of the occupational health and safety team and is a requirement of the Health and

Safety Executive (HSE) as the body that monitors and audits local authorities’

activities on health and safety enforcement.

The format and content of this service plan incorporates mandatory guidance

issued by the HSE under Section 18 of The Health and Safety at Work etc. Act 1974.

Consistency in plan format enables the HSE to assess how we are doing and allows

for local authorities to compare and contrast service plans for any fundamental

performance reviews under the local government Best Value agenda.

David Littleton

Business Unit Manager Environmental Health & Trading Standards

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Contents

Section One -

Paragraph Service Aims and Objectives Page

5

1 Mission Statement 5

3 Aims and Objectives 5

5 Contributions to Council Plan 5

Section Two Background 7

15 Borough Overview 7

18 Southwark’s Profile 7

24 Organisation Structure 8

25 Cabinet Member Structure 8

28 Directorate Organisation 8

30 Team Organisation 9

Section Three Service delivery 9

32 Scope of the Occupational Health & Safety Service

9

34 Night-time Economy Team 10

37 Demands on the Service 10

39 Service Hours

42 Enforcement policy 11

47 Olympics 2012 12

51 Proactive Planned Inspection Programme 12

65 Health & Safety Inspection Programme 15

72 Revisits 16

74 Non-programmed Inspections 17

76 Health & Safety Related Complaints 17

78 Reports of Accidents, Diseases and Dangerous Occurrences

17

80 Topic Based Inspection Work Plan 17

85 Lead/Primary Authority Principles 19

88 Advice to Businesses 19

91 Liaison with other Organisations 20

Section Four Resources 20

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95 Financial Allocation 20

98 Staffing Allocation 21

101 Staff Development Plan 22

106 Section 18 Compliance 22

108 Regulators Development Needs Analysis RDNA 23

Section Five Quality Assessment 23

111 Quality assessment 23

Section Six Review 24

114 Review Against the Service Plan 24

118 Identification of any Variation from the Service Plan 25

125 Areas for Improvement 25

Appendix 1 Organisational Chart- Occupational Health & Safety Team

26

Appendix 2 interventions plan 28

Appendix 3 timetable of project and topic work 29

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SECTION 1: SERVICE AIMS AND OBJECTIVES

1 Service Mission Statement

2. The environmental health and trading standards service mission statement is:

‘To enhance and protect the health, safety, economic welfare and

environment for people and stakeholders in Southwark’

3. Aims and objectives

4. In relation to occupational health and safety, it seeks to pursue this through a

number of key aims and objectives which include: -

• To ensure that the health and safety of those who live, visit, and work within

the borough is not affected by the work or activities undertaken by any

employer – ‘so far as is reasonably practicable’.

• To secure so far as is reasonably practicable compliance with health and

safety legislation and seek to ensure that regard is had to Approved Codes of

practice and guidance issued by the Health and Safety Executive.

To support the HSE strategy “The Health and Safety of Great Britain – Be

Part of the Solution”

• To develop new ways to establish and maintain an effective health and

safety culture in a changing economy, so that all employers take their

responsibilities seriously, the workforce is fully involved and risks are

properly managed;

• To do more to address the new and emerging work-related health

issues;

• To achieve higher levels of recognition and respect for health and safety

as an integral part of a modern, competitive business and public sector

and as a contribution to social justice and inclusion.

5. Contributions to the Council Plan

6. In its council plan, Southwark council highlights its promises of what it will

deliver as a council. It outlines the new relationship between the council and

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residents, built on trust, openness and transparency in all it does and

absolute commitment to creating a fairer future for all.

7. The occupational health and safety team works to the Council’s medium term

objectives and supports the council plan in the following areas:

8. Being more transparent – by following best practice as promoted by the

Better Regulation Executive and the Hampton Review of regulatory

inspections and enforcement. The service will be:

• Proportionate in activity intervening only when necessary and using remedies

that are appropriate to the risk posed, and costs identified and minimised.

• Accountable and be able to justify decisions made and be subject to public

scrutiny.

• Consistent and open and will try to keep regulations simple and user-friendly

within the limitations of legislational requirements, which are often out of the

control of the service.

• Targeted, and focused upon problems and minimising side effects.

9. Creating a fairer borough – by ensuring that Southwark continues to be a

place where people are treated fairly and have the opportunity to get involved;

by providing timely health and safety advice and regulation to local

businesses and contributing to a level playing field locally.

10. Making southwark a place to be proud of- by assisting premises and

businesses through support, education and enforcement to improve and

comply with health and safety regulations, so improving quality of life now and

for future generations for the people of Southwark making the borough a

better place to live, work, invest in and visit.

11. Realising potential- by recognising that good occupational health and safety

regimes has a secondary effect, as the goal of all programs is to foster a safe

work environment, which in turn protect co-workers, family members,

employers, customers, suppliers, nearby communities, and other members of

the public who are impacted by the workplace environment.

12. Spending money as we would our own –by continuing to employ new and

modern ways of working to ensure our service is flexible, responsive, efficient

and effective representing excellent value for money.

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13. Transforming public services- by being committed to continuous

improvement in service delivery, and addressing the needs of our

communities by using our resources innovatively and to best effect.

14. SECTION TWO - BACKGROUND

15. Borough Overview

16. Alongside the City of London, Southwark is one of the oldest areas of

London, with a history stretching back to Roman times. The borough is also

one of the busiest and most demanding metropolitan authorities in the

country. It is a borough of tremendous opportunity, situated as it is with its

northern boundaries opposite the prosperity of the cities of London and

Westminster. But it also has all the challenges and interest of an inner city

area; low incomes, high state dependency and complex social problems.

17. Southwark is undergoing one of the most ambitious social and physical

regeneration programmes of any authority in the country, together with a

wide range of initiatives aimed at improving educational standards, housing

and the environment, reducing crime and tackling health inequalities.

18. Southwark’s Profile

19. Southwark’s population reached 285,500 in 2010 and is believed to be

growing by as much as 4,000 per year, with a projected population of over

310,000 by 2016. The population has a young demographic profile and

demonstrates rich ethnic and cultural diversity, with around one-third (90,600)

of the population from black or ethnic minority communities. Southwark is

arguably one of the most diverse areas in the capital.

20. Southwark is made up of eight very distinctive urban neighbourhoods that

extend along the river Thames and down into South East London. The

borough also encompasses some of London's top attractions, creative

hotspots, scenic villages and acclaimed green spaces.

21. Southwark has a wide-range of leisure and cultural opportunities; and makes

a significant economic and employment contribution to the local community.

The north of the borough is recognized as one of London’s fastest growing

tourist quarters and a thriving business location.

22. Alongside the borough’s rich vibrancy, Southwark has its fair share of

challenges. The Index of Multiple Deprivation (IMD) 2007 shows Southwark

as the 27th most deprived local authority nationally and 60% of the borough’s

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wards are among the 10% most deprived in the country. Consequently, the

borough faces many challenges associated with meeting the complex health

and social needs of an inner-city population.

23. To meet our challenges, Southwark has a large number of physical

regeneration programmes across the borough, alongside a wide range of

initiatives aimed at improving educational standards, reducing crime and

improving health, housing, social care and the environment.

24. Organisational structure

25. Cabinet Member Structure

26. As part of the modernising Local Government Agenda, the Council has

adopted a Cabinet style of Local Government, embracing a new Constitution

and new Executive arrangements, based on a Leader and Cabinet model.

27. The current Cabinet consists of –

Leader of Council

Deputy leader of Council and cabinet member housing management.

Cabinet member for regeneration and corporate strategy

Cabinet member for health and adult social care

Cabinet member for transport, environment and recycling

Cabinet member for finance, resources and community safety

Cabinet members for children’s services

Cabinet member for equalities and community engagement

Cabinet member for culture, leisure sport and the Olympics

28. Directorate Organisation

A corporate management team led by the Chief Executive and Strategic

Directors undertakes the day-to-day operation of the Council. Council

services are currently provided by seven directorates covering all service

functions.

29. The community safety and enforcement division, which includes the

Environmental Health and Trading Standards Services, is situated in the

Directorate of the Environment. The Head of community safety and

enforcement has delegated responsibility for all matters relating to health and

safety. Individual post holders have been given direct delegation to take any

action and exercise functions in relation to the Health and Safety and other

relevant acts.

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30. Team Organisation

31. The occupational health and safety team forms part of an amalgamated

health and safety, licensing and environmental protection unit (HSLEP), and

sits within the division’s environmental health and trading standards business

unit. Occupational health and safety enforcement activities are carried out by

environmental health officers within the occupational health and safety team;

the structure of this team is provided in appendix 1.

32. SECTION THREE- – SERVICE DELIVERY THE SCOPE OF THE

OCCUPATIONAL HEALTH & SAFETY SERVICE

33. The occupational health and safety team is responsible for undertaking the

following work activities:

• To carry out a risk based health and safety inspection programme having

regard to HELA Circular (LAC) 67/2 (rev 2) (10 March 2010);.

• To investigate and resolve complaints about breaches of health and

safety legislation having regard to HSE’s guidance regarding ‘Incident

selection criteria’ stipulated under HELA Circular LAC 22/13.

• To investigate and take appropriate action following receipt of a

notification of reportable accidents, diseases or dangerous occurrences.

• To investigate and take appropriate action following receipt of asbestos

removal notifications and unsatisfactory lift inspection reports.

• Attend premises where allocated to local authorities and carry out

inspections, special visits, and revisits in relation to results and other

investigations.

• Take informal or statutory action including notices, seizure, prohibition,

prosecution or issuing formal cautions to secure compliance with the

legislation having regard to the Service’s enforcement policy and HSE’s

guidance on the ‘choice of appropriate enforcement procedure’.

• Maintain an accurate database of health and safety premises in the

Borough and record information to enable the completion of the annual LAE1

return to the Health and Safety Executive’s (HSE) Local Authority Unit.

• Receive and act upon all warnings sent by the HSE about

dangerous practices or equipment as appropriate.

• Provide advice and assistance to businesses and the public on health and

safety issues.

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• Provide or arrange the provision of health and safety training courses

and one off courses designed for specifically targeted groups and promote

both trade and public education of health and safety issues.

• Comment on proposed health and safety legislation, codes of practice

and other official documents as necessary and as requested.

• To liaise with other organisations such as the Chartered Institute of

Environmental Health, HSE, the London Chief Officers

Health and Safety Group and the Fire Authority to ensure a consistent

approach to the enforcement of health and safety issues.

34. Night- time Economy Team

35. Approval was received to commence a night-time economy team within EHTS

service comprising a multi-agency partnership. The team became operative in

April 2011. The primary aim of the team is to address a range of community

safety issues such as alcohol related violence, crime and disorder and anti

social behaviour associated with night-time trading operations in a target area

of the Borough. However, it is well established that these occurrences

invariably occurs on, or around premises whose trading operations extend

well into the night. These businesses are not likely to have received health

and safety law enforcement visits during such late trading hours and therefore

potential compliance issues may not have been identified.

36. The team consists of police, licensing officers, food safety officers, health and

safety officers and wardens. Health and safety officers will therefore be able

to undertake official health and safety interventions on theses premises

which, together with a range of other coordinated enforcement measures will

secure needed improvements.

37. Demands on the Service

38. Demands on the Service include: - carrying out proactive inspections and

interventions based on risk categorisation, carrying out health and safety

projects targeting certain types of premises and activities for inspections and,

responding to and investigating work related accidents and incidents. Planned

inspections account for the major demand.

39. Service Hours

40. The service is currently provided from the Chaplin Centre, Thurlow Street,

SE17 2DG, but may be relocated to the council’s main Tooley Street office

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before the end of the financial year. The office is open to members of the

public between the hours of 0845 and 1700 Monday to Friday. Telephone

contact is available 24 hours, 7 days a week via the customer contact centre

on 020 7525 2000, as is fax (020 7525 5007) and email

via: ohs@southwark.gov.uk. General health and safety advice and

information can be found on the council’s web site at

http://www.southwark.gov.uk/info/100002/business/722/health_and_safety_at

_work

41. The service will also carry out inspections and investigations outside of office

hours, as necessary. A standby arrangement exists to respond to any public

health emergency occurring at evenings and weekends. This is accessed via

the council’s emergency duty officer.

42. Enforcement Policy

43. We regulate through a mix of enforcement and advisory action. Our efforts

are targeted at those situations which present the greatest risk to health.

The Authority has a documented enforcement policy that sets out how the

occupational health and safety service will deal with infringements of the

legislation and will intervene to bring the operation back into compliance.

44. Southwark is a signatory to the enforcement concordat. This forms the core of

the council’s current enforcement policy. The council’s enforcement policy

can be found at

:http://www.southwark.gov.uk/site/scripts/google_results.php?q=enforcement

+policy Alternately a paper copy is available from the Chaplin centre.

45. Local authorities must also follow the HSE’s Guidance on Enforcement

Practice (LACS 22/18: Enforcement Management Model (EMM) and 22/20:

New Enforcement Guide (England and Wales) and Enforcement Handbook

Scotland). Where a simple caution is being considered, additional guidance is

provided in LAC 22/19.

46. Additionally, on 6 April 2008, the then department for business enterprise &

regulatory reform’s (BERR) (now the department for business innovation and

skills (BIS)) “Regulator’s Compliance Code” came into force. The health and

safety team is mindful of the code throughout all its activities.

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47. Olympics 2012

48. The 2012 Olympics in London will attract more visitors to the capital. While

the Borough does not host any of the games, Southwark recognises the

potential impact of the games on the local economy, infrastructure, the

population and its services. The Cultural Olympiad is also being held on the

South Bank and will impact on Southwark resulting in increased number of

visitors to the Borough. With more people visiting the Borough, the

occupational health and safety team anticipates an increase in service

requests and accident notifications.

49. The service is working closely with all its partners, including the Public

Service Operation Group (PSOG) to identify and access any available funding

to secure necessary resources to optimise preparation for the games. The

occupational health and safety team is working closely with the Chartered

Institute of Environmental Health (CIEH) and the London Occupational Health

& Safety Group (LOHSG) to ensure a consistent and well-coordinated London

wide approach to health and safety law enforcement during the games.

50. In preparation for the events, Southwark occupational health & safety team

will endeavour to focus on the following areas:-

• Education and training- for both health & safety law enforcers and business

operators.

• – Full inspections of hotels in the borough to give advice and take any

necessary enforcement action. Inspections will include examination of lifts

and circulation spaces used by guests.

• Legionella Working Group – in partnership with the Health Protection

Agency formulate a working Protocol for preventing and dealing with

cases of Legionella

51 Proactive Planned Inspections Programme

52. There are currently 10,959 known premises at which this Local Authority

are responsible for enforcing health and safety legislation. These premises

can be categorised as shown in figure 1: -

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53.

Description No.

Retail Shops 1,574

Wholesale shops, warehouses and fuel storage depots

276

Offices 1,416

Catering restaurants and bars 1,371

Hotels, campsites and other short stay accommodation

82

Residential care homes 289

Leisure and cultural services 822

Consumers services 122

Other premises (description not known) 3965

HSE enforced premises 1,042

Total 10,959

Figure 1 Number of premises in borough by type 54. Inspections have been carried out in 2316 of the above-mentioned known

premises and a risk rating has been assigned to them in accordance with the

nationally recognised scheme. As a consequence of the new risk rating

system being implemented as a result of Priority Planning Guidance LAC 67/2

(rev 2) premises have had their ratings reassigned in accordance with the

table in figure 2 below.

55. Although records indicate that this proportion of premises have been

inspected, undoubtedly, a very high proportion of the premises will have

changed hands since many of the inspections would have been carried out

over ten or more years ago. With only limited resources available only the

data currently on the database may be used. However, in 2011 the authority

will be liaising with Southwark’s business rates team to identify and inspect

businesses not currently featuring on its database.

56. All other business sectors are overseen by the HSE. These include factories;

farms; building sites; nuclear installations; mines; schools/colleges;

fairgrounds; gas/electricity/water systems; hospitals and nursing homes;

government premises (including local authority); and transport systems.

57. In addition to those premises shown above, the service also deals with 49

premises that are registered under the Notification of Cooling Towers and

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Evaporative Condensers Regulations 1992. Furthermore, as responsible

authority under the 2003 Licensing Act, the service may consider up to 150

applications for premises licences per year.

58.

Old LAC 67/1

Categorisation

New Category Description

A A Highest Risk

B1 B1 Medium Risk – 1

B2 and B3 B2 Medium Risk -2

B4 and C C Lowest Risk

Figure 2: Old and new categorisations of risk

59. In the transference of premises ratings between the old and new schemes

inspection dates for Local Authority Circular LAC 67/1 (rev 3) ‘A’ and ‘B1’

category premises will be carried over. However, under this new system

premises now rated as either a ‘B2’ or ‘C’ do not need to be subject to a rigid

inspection regime. Furthermore, it is expected that category ‘C’ premises will

now fall outside of any inspection-based intervention. As a consequence, the

Borough will carry out 126 routine proactive inspections in all new category ‘A’

and 108 inspections in ‘B1’ rated premises.

60. In relation to unrated premises of which there are

7601, 755 will receive an intervention by way of an inspection to determine

the ‘nature of the undertaking’ should they be currently trading. In addition,

where the authority has agreed to adopt a number of topic-based inspections

as part of the All London Health and Safety Group (ALHSG) then these will

also feature as part of the inspection program. Within these obligations

(discussed further in this document) the Authority plans to undertake 989

inspections in total.

61. The risk rating profile of current businesses that have been inspected

previously is shown in figure 3 below: -

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62.

New Risk Rating Band No Of premises

A 126

B1 216

B2 886

C 1088

Unrated 7601

Total 9917

Figure 2: Number of premises in new rating bands 63. The system by which premises are rated has also changed in accordance

with the Local Authority Circular. The new rating process consists of

evaluating 4 different elements as they relate to a work activity. A rating value

is then assigned to each of these 4 elements: -

• Confidence in management

• Safety performance

• Health performance

• Welfare compliance gap

64. After reviewing all the findings from the inspection or intervention, these

separate ratings are assigned to the premises and recorded appropriately.

There is no longer any cumulative addition of individual question scores as

was adopted by LAC 67/1. The inspector's assessment now represents a

balance of the findings from all of the issues identified. Inspectors will also

take into account that some topics may be more important than others at

particular premises (such as the risk of dermatitis within a hair dressing

salon). Thus, if a company performed badly in a key area, the overall safety

and health performance ratings should be heavily influenced by this, even if

standards are good in more minor topic areas.

65. Health and Safety Inspection Programme

66. The system by which premises are proactively inspected has been

explained earlier along with the categories of premises to be inspected. The

guide as to the appropriate inspection frequencies is contained within HELA

Circular LAC 67/2 (revision2) as shown in figure 4 below.

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67.

Description New

Category

Rating Score Intervention Frequency

Highest Risk A Score of 5 or 6 on any risk

Inspection of not less than once a year

B1 Score of 4 on any risk

Premises for inspection (e.g. programme directed; new employers/premises; local priority programmes. Those premises without an intervention contact within 18 months to be reviewed.

B2 Score of 3 on any risk

Premises for intervention (e.g. programme directed; new employers/premises; local priority programmes)

Lowest Risk C Score no greater than 2

Use non-inspection intervention methods\techniques

Figure 4: Frequency of Interventions

68. All ‘A’ rated premises will be visited at least once every 12 months (this

may be part of a programme directed approach or in accordance with any

reactive work and the Incident Selection Criteria (LAC 22/13). If at an ‘A’ rated

premises conditions have either deteriorated or not improved since the last

visit, enforcement action will be strongly considered to achieve improvements

in conditions and systems, thereby enabling the premises to be re-rated to a

lower category.

69. If a premises that was previously rated ‘B1’ is re-rated as an ‘A’, the

chosen intervention(s) will aim to reduce the risk profile of the business or

duty holder. There is an expectation that enforcement action will be taken in

these circumstances. It is not acceptable for a premise to be rated at a higher

risk level with no relevant intervention-taking place before a revisit is made.

This also applies if a premises moves from ‘B2’ to ‘B1’.

70. The Borough will undertake appropriate interventions with premises rated

as a ‘B1’ and as necessary where they form part of any topic-based priority

program. There is no expectation that all B1 premises will be inspected within

a single work year, however, the Borough will undertake this given their small

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number. If they were not inspected during year 1 then they would be

inspected in the first half of year 2.

71. During visits officers will also check that smoke free legislation is being

complied with i.e. the display of appropriate signage and that smoking is not

being allowed in public places and enclosed spaces.

72. Revisits

73. It is estimated that of those premises which receive a proactive inspection

an estimated 20% will require revisits.

74. Non-programmed Inspections

75. It is estimated that there will be non programmed inspections for new

premises to be carried out during 2011/12. These will be inspected in addition

to the 989 total.

76. Health and Safety Related Complaints

77. The Service seeks to investigate all health and safety related complaints

within the target period. It is estimated that there will be 200 such complaints

during 2011/12.

78. Reports of Accidents, Diseases and Dangerous Occurrences

79. Notifications of accidents, diseases and dangerous occurrences are all

considered upon receipt as soon as is reasonably practicable. A decision as

to whether a full investigation is required is then made in accordance with the

‘Incident Selection Criteria’ (to be found within LAC 22/13). It is estimated that

there will be 200 such notifications during 2011/12.

80. Topic Based Inspections Work Plan

81. As part of the ALHSG and in cooperation with the Health and Safety

Executive the Borough will undertake a proportion of topic-based inspections.

These are allocated to the Borough and are indicated below.

82. National Priorities

• Asbestos – Asbestos is currently biggest occupational health killer, killing

around 4000 people a year and rising. In 2010-11 the team took the

opportunity to promote an HSE country wide initiative to raise awareness of

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the duty to manage asbestos. Officers also disseminated information to the

business community on the Control of Asbestos Regulations 2006. The work

done in 2010/11 will be followed up by revisits and enforcement as necessary

to the premises visited. New premises will also be identified for inspections.

This remains a high priority area for the Health and Safety Executive and

local authorities alike. 50 inspections are envisaged.

• Slips, Trips and Falls –– Slips and trips are the most common workplace

hazards and make up over a third of all major injuries. Over 10,000 workers

suffered serious injury because of a slip or trip last year. The team will target

slips and trips risk in the catering and hotel industry, care homes, food retail,

building and plant, retail, warehouses and cleaning companies during

inspection visits.

• Contribution toward European Health and Safety Week - focussing this

year on safe maintenance in the manufacturing industry; to rraise awareness

among businesses and their workers and to help them implement simple

solutions. Also, to promote 'one stop shop' safe maintenance section of the

HSE website

83. Local Priorities

• Work Related Violence in Licensed Premises – this is a local priority to

contribute to making Southwark a safe place to live, work and visit.

• Places of Worship – Many unauthorised places of worship are operating

from unsuitable and substandard accommodation, regardless of

designation, resulting in immediate health and safety risks for both

members of the congregation and the general public.

• Age related sun-bed use – New regulations which came into force on

9th April 2011 restrict the use of sun-beds to those who are 18 years or

over. Based on the information gained from the tanning project in 2010/11

looking at sun bed safety focussed visits will be made to premises offering

tanning and enquiries made as to what systems are in place to restrict

use.

• Hotels / Hostels – Compliance in advance of London Olympics 2012

(see 3.6.3)

• Legionella - Compliance in advance of London Olympics 2012 (see

3.6.3)

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• Railway Arches Industrial Estates – Assess the occupational health

and safety risks posed on industrial estates, in particular, LPG storage

and use and fire risks. Also to identify any wider community safety risks

posed by activities undertaken in railway arches.

• Poundshops – There has been an increase in these types of premises

presenting unsafe storage and displays, slips, trips and falls, risk of fire

through overstocking including manual handling risk both to employee

and members of the public. Work with Buddy borough partnership officers

– Camden & Islington to deliver a joint project.

84. The number of topic–based inspections and topic–based revisits cannot

be strictly ascertained as this depends on the number of premises available to

visit within the work areas identified. However, these interventions will be

included within the number of premises identified for inspection.

85. Lead/Primary Authority Principles

86. Lead and Primary Authority gives companies the right to form a statutory

partnership with a single local authority, which then provides robust and

reliable advice for other councils to take into account when carrying out

inspections or dealing with non-compliance. The Council endorses this

approach to health and safety.

87. We are currently lead authority for the Save the Children Fund and are

actively in talks with securing primary authority arrangements with The

Salvation Army. The Primary Authority allows the service to make reasonable

charge for the service. The team will actively explore such arrangements

where suitable candidates are identified

88. Advice to Businesses

89. The service encourages businesses to seek advice. It is preferable to

resolve problems through co-operation at an early stage before the situation

becomes serious, when formalised enforcement action may have to be

considered. The service would like to be perceived by businesses as

supportive and helpful.

90. Advice is mainly delivered on a one-to-one basis whilst officers are

carrying out inspections and other visits but may also be given via telephone

calls, seminars, news letters, leaflets, letters or telephone calls. Officers give

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advice in accordance with recognised guidance and codes of practice.

Currently there are no specific health and safety related business

partnerships or forums in operation.

91. Liaison with other Organisations

92. Arrangements are in place to ensure that enforcement action taken by the

Service in the Southwark Borough is consistent with enforcement action

carried out in the neighbouring local authorities. This is achieved by: -

• Active support of the London Environmental Health Managers Group which

includes regular meetings and contact between authorities.

• Partnership working with the Health and Safety Executive e.g. joint

inspections.

• Peer review bench marking exercises with other London Local Authorities.

• Regular discussions amongst officers in respect of HSE guidance.

• Attending Chartered Institute of Environmental Health’s branch meetings,

monitoring and responding to e-mail messages on the Environmental Health

Computer Network (EHC Net).

• Liaison as deemed necessary with Southwark Council’s trading

standards service, food and licensing teams,

93. Section Four – Resources

94. Following a service review and reorganisation of the community safety and

enforcement division, resources have been reduced by 8% (against a

background of a 40% reduction across the wider Division). From 1 April 2011

the team has 10 staff dealing with food safety matters. There are 2 vacant

posts which, the service intends to fill at the earliest opportunity subject to

available funding. Administrative support is provided by 1 member of staff.

95. Financial Allocation

96. The financial allocation for 2011/12 iis shown in figure 5 below: -

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97.038-ENVIRON

BUDGET £1000’s

Salaries 266

Running costs 55

Recharge 41

Total 362

Income 0

TOTAL 362

Figure 5: Health & safety team budget

98. Staffing Allocation

99. Staffing allocation for all occupational health and safety law enforcement is

given in figure 6 below:

100

Designation Number in post

Number of Vacancies Competencies Necessary

Unit Manager 0.33 0

Team Leaders 0.5

0

Principal Environmental Health Officers

1.8 0

Health and Safety Inspections

Complex accident/incident investigations including fatalities.

Lead officer for major projects

Service of formal seizure, improvement and prohibition notices.

Principal Enforcement Officers

1 0

Health and Safety Inspections

Complex accident/incident investigations including fatalities.

Lead officer for major projects

Service of formal seizure, improvement and prohibition notices.

Enforcement Officers 2 0

Health and Safety Inspections

Non complex accident/incident investigations

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Minor projects lead officer

Service of formal seizure and improvement notices.

Totals 5.6 0

Figure 6 staffing Allocation

101. Staff Development Plan

102. The council is Investors in People (IIP) employer.

103. Training needs of each staff member is documented through the performance

management process and recorded on each individuals work plan and on an

excel spreadsheet held centrally.

104. Staff involved in health and safety enforcement work are required to be

assessed using the HSE RDNA and hold a learning portfolio. The tool also

suggests that each officer receives appropriate identified training each year

as a minimum to maintain competency. The service ensures this by using:-

• In house documented competency based training

• Participation in relevant external learning and development courses

• Regular review against the service’s own performance management learning

and development scheme.

105. In addition, the Chartered Institute of Environmental Health (CIEH), ,requires

its members to undertake twenty hours of training each year as part of the

Continuing Professional Development (CPD) scheme. 5

106. Section 18 Compliance

107. Both the Health and Safety Executive and Local Authorities have a duty to

‘make adequate arrangements for enforcement’ under Section 18 of the

Health and Safety at Work Act. Local Authorities are required to perform this

duty in accordance with mandatory guidance from Health and Safety

Commission. To this end ‘Local Government Regulation’ has in partnership

with the Health and Safety Commission produced a toolkit with which Local

Authorities may assess their current level of service against a prescribed

standard. This in turn enables an action plan to be produced in order to

address any shortcomings identified and participate in a joint peer review

process. The Borough completed this assessment in 2010/11 and will receive

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peer review upon it in 2011/12. Any shortfalls identified via the self-

assessment and peer review processes will be actioned.

108. Regulators Development Needs Analysis RDNA

109. Under Section 18 every enforcing authority must: -

(a) have a system to train, appoint, authorise, monitor and maintain a

competent inspectorate, and

(b) have a documented policy and procedures covering appointment,

authorisation and competence.

110. To meet this standard the authority must put in to place systems for

appointing and authorising suitably qualified inspectors under Section 19

HSWA; implementing standards of competence, and making arrangements

so that competence levels may be maintained. This will require appropriate

officer training.

111. SECTION FIVE – QUALITY ASSESSMENT

112. Monitoring measures are in place to assess performance, particularly having

regard to the number of visits/inspections carried out on a month by month

basis and is monitored by the business unit manager of EHTS. The main

means by which quality is assed is as follows:

• Monitoring and support provided by experienced principal enforcement

officers

• Monitoring of notices and letters

• Shadow inspections

• Post inspection audits of records, risk rating, inspection reports and

enforcement decisions

• Regular team meetings

• Regular Technical Meetings

• Regular one-to-one work reviews

• A Section 18 assessment of the health and safety service

• Implementation of the RDNA tool for officer competencies 7: REVIEW

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113. SECTION SIX - REVIEW

114. Review against the Service Plan

115. Under the current performance management framework service plans

include a number of targets and performance indicators. During the course of

the year Environmental Health formally monitors its performance against

targets and on a monthly and quarterly basis. Performance indicators in

relation to the occupational health and safety service delivery will be reported

to the Director of Environment every month. The occupational health & safety

team’s 6-year performance as per CIPFA returns is set out in figure 7 below.

116.

Health, safety & welfare

2005-2006

2006-2007

2007-2008

2008- 2009

2009-2010

2010-11

No. accident notifications received

232 266 324 305 261 217

No. other complaints and requests for service

424 627 331 350 252 343

Total no. inspections carried out

893 516 534 705 784 827 (+ 605 other interventions)

No. written warnings

267 355 291 355 447 658

No. improvement notices served

91 181 127 125 128 246

No. prohibition notices served

9 67 25 32 30 38

No. summons served and formal cautions

1 8 13 8 0 9

figure 7-year performance as per CIPFA returns

117. Figure shows that 2010-11 saw

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• A 5.5% increase in the total number of inspections carried out over 2009-10;

• In excess of 600 other interventions;

• A reduction in he number of unrated premises by more than 800;

• A reduction in the numbers of accident notifications received for the third year

running;

• A rise in other service requests back to 2007-8 / 2008-9 levels; and

• The highest levels of enforcement notices served across the period covered;

118. Identification of any Variation from the Service Plan

119. The 2010-11 service plan was prepared on the basis of an additional 3

staffing resources being provided to the team. Due to the need for the

business unit to make savings during the course of the year, these resources

did not materialise in full. The team benefitted from one extra resource

120. Consequently, targets set for inspections and other interventions could not be

met in full, but were met proportionately, given the staffing resource available

within the team.

121. It was also intended that 2010-11 would see all unrated premises brought into

the new HSE risk rating system. This did not happen, primarily due to

problems with the IT support systems. Firstly, it was anticipated that the new

version of the rating system would be incorporated into the services database

at an early stage in the year. However, the new software release which

incorporated the changes, was not received until the end of the financial year.

Work on desktop rating of unrated premises by business sector will follow

once the new rating system is operable.

122. Despite this delay, the number of unrated business premises was reduced by

800 through direct intervention methods. Cross-referencing of business

databases is also in progress so as to provide the best available information

on current businesses before desk top rating exercise is concluded.

123. The service did achieve a 8% increase in the numbers of premises within the

risk rating system through physical intervention and otherwise completed all

other programmed interventions and topic work.

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124. The performance levels for inspections during the period 2011/2012 will be

reported at year end. At the end of 2010-2011 the service performance

remained in the bottom quartile as compared to other London authorities.

125. Areas for improvement 2011-12

126. Areas of improvement for 2010-11 and beyond are:

• To bring the estimated 7,601 currently unrated premises into the

inspection programme by 2015 and subject to risk assessment;

• To improve the councils performance in this area from bottom quartile to

top quartile, and subsequently protect the council’s reputation;

• To initiate necessary IT support updates and development;

• To further examine potential for data matching with internal and external

partners, to ensure that the most current and relevant information on

business activity is used to shape and facilitate joint working initiatives.

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Appendix 1: Organisational Chart - Occupational Health & Safety Team

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Health and Safety Team

Farhad ChowdhuryPrincipal Enforcement Officer

Samantha CoePrincipal Enforcement Officer

Ian FarringtonPrincipal Enforcement Officer

Mohammed AslamEnforcement Officer

Debra Lawless Enforcement Officer

Sailesh ChudasamaTeam Leader

Health & Safety and Environmental Protection

David FranklinTeam LeaderLicensing

Kirty ReadSenior Unit Support Officer

Richard ParkinsUnit Manager

Licensing, Health & Safety, Environment Protection

David LittletonBusiness Manager

Community Safety Enforcement

Jonathon ToyHead of Community Safety and Enforcement

Gill DaviesDirector Environment and Leisure

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