Health & Safety Policy DATE ISSUED: 1 April 2014 DATE TO BE REVIEWED: 1 April 2014 Health & Safety Policy Page 1 of 11
CONTENTS POLICY OVERVIEW 1 Introduction 2 Purpose 3 Who This Policy Applies To 4 Key Principles 5 Legal Considerations THE POLICY 6 Roles & Responsibilities 7 Processes & Procedures Health & Safety Policy Page 2 of 11
POLICY OVERVIEW 1.0 Introduction The Health and Safety at Work etc Act 1974 places all accountability and responsibility for Health and Safety on the Chief Accountable Officer of the organisation. However, in reality, the practical application of Health and Safety requires many of these duties and responsibilities to be delegated to varying levels of organisational management. This policy seeks to define the principal Health and Safety duties and responsibilities of all Dudley CCG employees in the pursuance of those contained within the current Health and Safety Legislation. 2.0 Purpose This Policy is designed to meet the requirements of Section 2 (3) of the Health & Safety at Work etc Act 1974, Regulation 5 of the Management of Health & Safety at Work Regulations 1999 and the Equality Act 2010. 3.0 Who This Policy Applies To The policy applies to all staff who are employees of the organisation in either a permanent, fixed term or temporary post. This policy also applies to all those who carry out work on the organisations behalf including agency staff, consultancy staff and office holders. 4.0 Key Principles The Organisation recognises the importance of providing a safe and healthy environment for all employees and all other persons working or visiting its premises and grounds. In pursuance of this duty the Organisation undertakes to comply with the obligations placed on it by the Health and Safety at Work etc Act 1974 and all other associated legislation. This policy aims to demonstrate that the organisation and arrangements are in place to ensure that hazards will be identified, risks assessed and action taken to eliminate or control hazards within the scope of this policy and to this end ensure that appropriate provisions are in place for the maintenance and testing of work equipment, safe systems of work and premises. Safety is everyone s concern and all staff have a duty to co-operate in the operation of this policy by working safely and adhering to procedures aimed at providing a safe working environment. 5.0 Legal Considerations In addition to the requirements of this Policy reference should be made to supporting Dudley CCG documentation, in particular: Health & Safety Procedures and Policies Fire Procedure Display Screen Equipment Procedure Manual Handling Procedure Control of Substances Hazardous to Health (COSHH) Procedure Lone Worker Procedure Health & Safety Policy Page 3 of 11
Risk Assessment Strategy procedure Accident Report Procedure incorporating RIDDOR Violence & Aggression Procedure incorporating Domestic Abuse New & Expectant Mothers procedure First Aid procedure Electrical procedure Young Workers procedure No Smoking policy Stress Policy Staff Dress Code & Uniform Policy THE POLICY 6.0 Roles & Responsibilities 6.1 Dudley CCG Dudley CCG Board has a responsibility to conform to the Health and Safety at Work etc Act 1974, the NHS (Amendment) Act 1986 and all legislation pertaining to occupational health, safety and welfare in the interests of its employees and others and will establish and maintain a pro-active Health and Safety culture. They will set and monitor Health and Safety objectives, targets and priorities for the departments, premises and functions they control, and encourage ownership and responsibility at all levels. Collectively the Dudley CCG Board will: Ensure that the requirements of Health and Safety legislation are met, and where there are no statutory requirements; ensure that the Dudley CCG Health and Safety Policy Statement is upheld by promoting a best practice standard. Dudley CCG will ensure that all staff undertake the appropriate statutory and mandatory training with regard to Health and Safety. Ensure there is an effective consultation process for Dudley CCG employees on Health and Safety issues. Promote a consistent approach towards Dudley CCG Health and Safety issues and policy directives across the whole organization.. Allocate adequate financial resources to meet the needs of health, safety and welfare Ensure an effective risk assessment process in place and that is regularly monitored. 6.2 Chief Dudley CCG Board delegates responsibility for Health and Safety to the Chief Quality and Nursing Officer. The Chief Quality and Nursing Officer is responsible for organising the management of the Dudley CCG Health and Safety Policy and ensuring that an action plan is devised for its effective implementation. However the overarching statutory responsibility for health and safety remains with the Board. In summary the main duties are: Health & Safety Policy Page 4 of 11
Reporting to the Dudley CCG Board on issues concerning Health and Safety Ensure that an action plan is devised to meet the requirements of the Policy and any current legislation. Review and revise the Policy as is necessary to ensure the highest standards of Health and Safety practice are achieved and in line with any revised legislation Ensure that the Location Health & Safety Files relevant to Dudley CCG are maintained Ensure effective operation of the Dudley CCG Health and Safety consultation arrangements. Oversee the effective arrangements for monitoring Health and Safety In partnership with the premises landlords ensure the safe operation of all premises occupied by Dudley CCG employees 6.3 Estates Management for premises occupied by Dudley CCG The Chief Quality & Nursing Officer is responsible for ensuring that statutory requirements are met in conjunction with the landlord with regards to: Water Hygiene. Legionella Asbestos Management. Electrical Safety Inspection and Testing. Waste Control Management. Building Maintenance & Repair. Pest Control Services. Fire Safety 6.4 Senior Management Team The role of the Senior Management Team is to ensure that the Policy and the content of any relevant Location Health & Safety Files are communicated to members of their team and that all staff are aware of their health and safety responsibilities. A Summary of duties are: Ensure that the Policy is adhered to within their teams covering all services and local arrangements Act, in an agreed timescale, on any recommendations made following an inspection. Ensure clear lines of communication within the organisation. Ensure workplace hazards are identified and assess associated risks. If these cannot be eliminated, ensure that they are managed accordingly. Ensure the safety of any person likely to be affected by work activities, including employees and non-employees. Ensure implementation of Dudley CCG Policies in relation to Health and Safety. Ensure effective operation of the Dudley CCG Incident Reporting System. Ensure that staff receive the necessary training for understanding and complying with Policies and procedures. Ensure that the risk assessment in respect of Display Screen Equipment and New & Expectant Mothers are completed including any necessary action required to ensure control, and records are kept accordingly. Health & Safety Policy Page 5 of 11
Ensure all incidents are reported promptly in accordance with the Incident Reporting Policy and their cause investigated so as to eliminate any re-occurrence as far as is reasonably practicable. Ensure that induction and instruction of all employees is provided and recorded. All accidents/assaults/occupational ill health incidents occurring within their areas are investigated and reported. Any items of an appropriate nature to be reported to the Clinical Executive Team. In addition to promote a culture of Health and Safety: Set a good personal example with high safety standards. Areas of work are maintained to a high standard of housekeeping. The fire-fighting facilities provided are readily available for use, and that employees are familiar with their operation. All approved items of first aid provided are readily available for use, under the control of a responsible person or trained first aider, as required by the relevant statutory regulations, and that all employees are made aware of their location. The correct protective clothing or equipment is issued and is used when necessary. Suitable consideration is given to reasonable adjustments with respect to employees, service users and visitors with long term medical conditions and disabilities. Any matter brought to their attention by an employee receives prompt and appropriate action. The Senior Management Teams attention is drawn to any breach of statutory regulations or unsafe practice, which cannot be dealt with effectively by them and they will make the Clinical Executive Team aware. 6.5 Health & Safety Advisor At least one member of staff from the CCG will be trained as a Health and Safety Advisor. The Dudley CCG Health & Safety Advisor shall undertake the services of the competent person, as defined under section 7 of the Management of Health & Safety at Work Regulations, to provide suitable and sufficient support to the Senior Management Team with responsibility for achieving the goals set out in the Health and Safety plan when one is required. They will provide professional help, advice and assistance to all employees on aspects of Occupational Health and Safety. In addition the appointed competent person shall support the Chief Quality and Nursing Officer to: Review Health & Safety Policies within agreed time frames, with updates as required. Carry out annual Health & Safety audits, and make suitable recommendations where non-compliance is identified. Provide assurances to the Clinical Executive Team through an annual report. Procure the appropriate Health & Safety training to all levels of staff, in line with the Dudley CCG Training Strategy. Health & Safety Policy Page 6 of 11
Facilitate the joint Staff/Management consultation process. Have regular Health & Safety meetings with Staff Side Representatives Keep the Staff Side Union Health & Safety Representatives informed of all inspections etc as part of The Regulations, Codes of Practice and guidance relating to the Safety Representatives and Safety Committees Regulations 1977. The Regulations, Codes of Practice and guidance relating to the Safety Representatives and Safety Committees Re The role of Health & Safety Advisor includes the duty to carry out half yearly workplace health and safety inspections/audits, a periodic review of the content of the Location Health & Safety File, completing and reviewing the location COSHH Inventory. This will be done in partnership with the Chief Quality and Nursing Officer and with Staff Side/Union Health and Safety Representative(s). The Health and Safety Advisor will work with the Chief Quality and Nursing Officer in ensuring that information is disseminated to all relevant staff, with particular emphasis on new staff and temporary workers. 6.6 Employees All employees of Dudley CCG have a responsibility, along with the Senior Management Team, for maintaining safe working practices for the Health and Safety of themselves and other persons who may be affected by their acts or omissions at work. In addition Employees have a duty to report, and if appropriate, rectify any dangers of which they become aware and ensure that they comply with their duty under the Health and Safety at Work etc Act 1974 and familiarise themselves with the Health and Safety Polices applicable to the organisation and to their locality and to co-operate with the employer and others in meeting statutory requirements. 6.7 Tenants & Volunteers Where Dudley CCG staff are tenants (for example LIFT buildings), or provide a service, from a building which is not owned by Dudley CCG they will adhere to any Standard Operating Procedures assigned by the Landlord of that building. 6.8 Occupational Health Dudley CCG recognises the valuable role that an Occupational Health Service has to play in identifying the potential Health and Safety risks and in advising appropriate action to minimise risks. To support all issues relating to Health and Safety, Dudley CCG will have available the service of the Occupational Health & Safety Department, which is based at Heart of England Occupational Health and Wellbeing Service 0121 424 0610. They will deal with all matters pertaining to employees Health and Safety, and their advice will be impartial, confidential and advisory to both management and staff. 7.0 Processes & Procedures Health & Safety Policy Page 7 of 11
7.1 Location Health & Safety Files Each of the Dudley CCG premises at BHHSCC and Tiled House shall produce, and maintain, a Location Health & Safety File specific to that site. The Location Health & Safety Files will contain the local Health & Safety roles and responsibilities, Fire Arrangements, First Aid Arrangements, Control of Substances Hazardous to Health (COSHH) Inventory, COSHH Assessments, Locality risk assessments and Monitoring/Audit arrangements and it shall be the duty of the Health & Safety Co-ordinators/ Representatives to review and maintain these files. All Health & Safety Policies will be available for viewing on the Dudley CCG intranet 7.2 Risk Assessments Dudley CCG has a responsibility under the Health & Safety at Work etc Act 1974, to ensure, as far as is reasonable, the Health & Safety of employees and of other persons who may be affected by work activities. The Management of Health & Safety at Work Regulations 1999 further imposes a specific duty upon employers to carry out a suitable and sufficient assessment of all risks to the Health & Safety of employees and others, arising out of, or in connection with their work activities. Other Health & Safety Legislation also have requirements for specific assessments to be completed (Display Screen Equipment, Manual Handling, Control of Substances Hazardous to Health etc). The Location Health & Safety Files contain a portfolio of generic activity and COSHH assessments which shall be reviewed, and where appropriate updated, by the Health & Safety Advisor as part of the half yearly workplace inspection/audits. Operational Managers are responsible for ensuring that the information contained within the assessments will be brought to the attention of employees who will be instructed in the use of the control measures identified. 7.3 Active Monitoring Arrangements The Health & Safety Advisor shall ensure that half yearly workplace inspections/audits are carried out and recorded in the Location Health & Safety Files. An inspection/audit checklist has been produced and this format shall be used for completing and recording the findings of the workplace inspections/audit in the Location Health & Safety File. Where deficiencies in agreed standards have been identified the Health & Safety Advisor will report these to the relevant department managers for corrective actions. It shall be the role of the Health & Safety Advisor to update the Location Health & Safety File when these actions have been completed. Staff Side Health & Safety Representatives shall be invited to take part in these inspections/audits. 7.4 Fire Procedures All employees and their manager/supervisor will follow the Dudley CCG procedures for fire procedures and evacuation. All employees will have sight of and adhere to the Building Fire Policy which is held in reception and a copy will be placed in the CCG location Health & Safety Files Health & Safety Policy Page 8 of 11
7.5 Incident Reporting & Investigation All employees and their manager/supervisor will follow the Dudley CCG procedures for reporting accidents, slip, trips & falls, near misses, assaults, and instances of ill health, which are work related. In addition if an incident occurs then a suitable person will be identified to ensure that incidents are investigated to establish immediate and underlying causes and identify, as appropriate, remedial actions to prevent reoccurrence. Findings of internal investigations shall be stored in a secure location. Where applicable, Staff Side Health & Safety Representatives shall be invited to take part in incident investigations. 7.6 Procedures for Serious & Imminent Danger Managers will ensure that all staff are aware of the appropriate evacuation procedures for the building they occupy. Copies of these procedures will be kept in the Location Health & Safety File and will provide staff with: Details on what to do when a fire alarm sounds. Details of actions to be taken on discovering a fire. The names of designated people who undertake specific roles when an evacuation takes place. Details on the location and type of fire extinguishers and fire break glasses. All employees will be made aware of the evacuation procedures for their area and be clear as to what they are to do when a fire alarm sounds. In the event of an evacuation, all employees will vacate the building, along with any visitors to the building, assembling at designated areas. 7.7 First Aid Dudley CCG has trained first aiders who will undertake refresher training as required. Premises specific first aid arrangements shall be included in the Location Health & Safety Files and appropriate signage shall be posted in a prominent position at the entrances to the building detailing the first aid arrangements for the site. 7.8 Provision of an Effective Joint Consultative Process To promote the effective exchange of Health and Safety information, Dudley CCG will provide and facilitate a mechanism for Health and Safety joint consultation. It recognised the importance of consultation and the important role that Staff Side Health and Safety Representatives play. Health & Safety Policy Page 9 of 11
7.9 Staff Side Health & Safety Representatives Safety Representatives may be appointed by recognised Trade Unions under the Safety Representatives and Safety Committee Regulations 1977: Such Trade Union Safety Representatives have no legal liabilities beyond those of the ordinary employee. They cannot individually be liable at either civil or criminal law for anything they may do or fail to do as a Safety Representative. Within Dudley CCG these representatives have agreed to support non-union employees in respect of Health and Safety matters. Details of accredited Safety Representatives within Dudley CCG are to be kept up to date by Trade Union personnel and the Dudley CCG HR Lead within the Dudley CCG recognition agreement. The functions of a Trade Union Safety Representative/ Staff Side Representative are: To represent his/her colleagues in consultation with management on: Health and Safety matters. To investigate potential hazards without personal risk to their own safety. To investigate accidents and dangerous occurrences without personal risk to their own safety. To participate in risk assessments and carry out routine inspections. To receive appropriate Health and Safety information. Safety Representatives are required to give reasonable notice of their inspection visits to the manager of the unit and any designated competent person. Any such inspection should be conducted in the presence of the relevant Manager and a competent person where practicable. The appointment of Trade Union recognised representatives will not exclude the Employer from consulting directly with the workforce. The Head of Organisational Development will maintain a register of Trade Union accredited safety representatives to Dudley CCG. 7.10 Provision of an Effective Health and Safety Training Strategy/Plan The provision of statutory/mandatory Health and Safety training will be on an ongoing basis. The courses will take account of the Dudley CCG Health and Safety priorities, potential high risk factors, legislation or specific key issues. Every year Dudley CCG whilst evaluating departmental Health and Safety performance will assess the effectiveness of training completed and determines, where necessary, recommendations for further training. Employees will be instructed that attendance is compulsory for certain levels. Included in the formal induction training will be Health and Safety awareness as a minimum. 7.11 Personal Protective Equipment (PPE) All necessary equipment required for the protection of employees and those who may be affected by certain activities will be provided. All such equipment will comply with the relevant British and European Standards. Suitable clothing, overalls, footwear and other personal protective equipment will be worn by employees as dictated by our Risk Assessments and other Safe Systems at Work. Health & Safety Policy Page 10 of 11
Any damage, loss or defect to Personal Protective Equipment must be reported to the Health & Safety Advisor as soon as possible. Any staff entering provider organizations need to adopt and adhere to local PPE arrangements. Signed Signed Dr David Hegarty Dudley CCG Chair Mr Paul Maubach Chief Accountable Officer Health & Safety Policy Page 11 of 11