Part 1 of this article (TTJ October 28, 2000) covered the legal requirement for risk assessment, which employers must carry out under the Provision and Use of Work Equipment Regulations (PUWER) 1998. It also introduced the HSE‘s Five Steps to Risk Assessment and described Step 1 (planning how to organise your risk assessments, drafting a risk assessment tree, and ensuring that those who are going to be involved – the ‘assessors’ – have been trained). Now, we describe the process of risk assessment in terms that will have practical relevance to woodworking companies.
Having completed Step 1, the next stage is to carry out a pilot exercise. This will involve each assessor selecting a topic or an activity (see TTJ October 28, 2000) and carrying out an assessment. The pilot exercise will test the suitability of your risk assessment plan, allow assessors to become familiar with the process, identify any weaknesses in their understanding of the process and judgment, and help to ensure that there is a consistent approach.
The process of risk assessment – during the pilot exercise and thereafter – should cover the following steps.
Step 2: what is a ‘hazard’ and who is at risk?
The HSE’s ‘Five Steps’ defines a ‘hazard’ as any thing that can cause harm. However, this is too broad a definition and can lead assessors to conclude, for example, that heating, a forklift truck or a machine are hazards. Moreover, this definition often results in ‘things’ such as lighting or training (or the lack of it) or a task (eg machine setting) or an issue (eg wearing protective clothing) being wrongly identified as a hazard – whereas in fact each of these ‘things’ could involve several hazards.
It is therefore better to describe a hazard as ‘how a person can be harmed,’ since this makes it possible to break down an activity into a limited number of basic ways that injury or ill health can be caused. The list of hazards shown in Table 1, while not exhaustive, covers the ground sufficiently for the majority of cases.
For example, if operating a forklift truck is taken as the ‘activity’, then a number of hazards associated with it can be identified from Table 1. These include all those under the general headings of ‘falls’ and ‘struck or crushed by’ plus certain items under other headings such as machinery, fire, radiation (UV/sunlight), handling, hazardous environment and explosion.
Identifying the forklift truck as an activity rather than a hazard therefore results in a better analysis of the ways that a forklift can cause harm. Such analysis also emphasises the need to fully identify who is at risk. In this example it would be the driver in most cases, but some of the tasks carried out within the overall activity involve others – maintenance personnel, visitors and contractors.
When identifying hazards it is imperative that you disregard control measures that are in place: dangerous parts of machinery do not cease to be dangerous simply because they are guarded. They are still inherently dangerous even when you have taken steps to reduce the likelihood of harm. Which takes us to the next step.
Step 3: the degree of risk
The assessment of the actual risk breaks down into two aspects or functions: what is the likely outcome (injury or ill health) if something goes wrong? and what are the chances of something going wrong? It is the combination of these two factors that will determine the risk.
When making the actual risk assessment you should take into account any measures already in place to control the risk. It is worth writing these down because you will need to do this anyway to complete Step 4 of the process.
There are several ways to evaluate the risks. The simplest system is to categorise the risk as ‘high,’ ‘medium’ or ‘low,’ but while virtually all systems in use today are judgmental, this one can be over-simplistic and result in the status quo being wrongly confirmed.
The system of risk evaluation shown in Table 2 has, in the majority of woodworking establishments, been shown to be a better way. It also involves making a judgment about how a particular hazard associated with an activity might result in harm, but it gives a wider range of risk ratings and is more investigative, informative and precise.
To be successful the assessor has to apply common sense and be realistic but honest. For example, take the activity of ‘general administrative duties’ in the office and consider the specific hazard of a person falling down a flight of stairs. The worst outcome could be fatal, but realistically it would probably result in a minor injury. The chance of someone falling down the stairs will depend on several factors – the design of the staircase, lighting, surface material and condition, general maintenance, provision of a handrail and the actual use of the stair (carrying goods etc). The level of use and the experience of accidents or incidents over the years are also relevant.
In this case a reasonable assessment could be that it is ‘possible’ someone will fall and that ‘minor injury’ will result. Table 2 would therefore provide a risk rating of ‘D.’
With this system the rating is no more than an indicator and does not itself determine the necessary action (unlike some systems, described later). However, such an indication is useful when, later, you have to decide if the risk is adequately controlled. High ratings should cause you to examine even more closely your control measures. Middle or lower ratings will give you more confidence of being in control, but you should always be striving to reduce the risk further.
Some risk evaluation systems use numbers. Outcome (5 marks for a perceived ‘fatal’ outcome, 4 for ‘major’ and 3 for ‘minor’) is multiplied by chance (5 for a ‘frequent’ risk, 4 for ‘probable,’ 3 for ‘possible,’ 2 for ‘remote’ and 1 for ‘unlikely’) to give a rating between 3 and 25.
In some systems the final ratings actually determine – even dictate – the resulting action, thus: 20+ (A or high) means priority action – imminent risk, cease activity until risk has been addressed; 19-15 (B or medium) means priority 2 – urgent action required; 14-9 (C or medium/low) means priority 3 – action needed; below 9 (D/E or low) suggests a controlled risk – keep under regular review.
Although a system that dictates the required action has the benefit of reaching a conclusive result, it is open to abuse or a charge of unreliability. First, it can lead to a risk being underrated because the required action is unpalatable or unrealistic. Second, since the individual elements in the rating equation are based on an individual assessor’s judgment, it is perhaps unwise to use a system where the scoring of such subjective judgment dictates the required action.
Health and safety experts and managers will argue the pros and cons of the various systems, and in the final analysis it is for you to decide which to rely on. The real test is whether the system you use actually results in your proper control of the risks. However, note that any risk assessment system that delivers only maximum ratings in a typical woodworking factory of 14/C/medium must be considered suspect – given the proven dangerous nature of the industry.
Remember that some activities may have a high rating even after you have taken all the steps you can to reduce the risk. Driving a forklift truck is inherently dangerous. Even in the best-run factory the likely outcome of any significant accident would in most cases be fatal. The chance of such an accident happening is surely a possibility if not a probability. The benefit of arriving at a high rating is that it will demonstrate the importance of issues such as training, supervision, instruction and safe working practices.
Step 4: existing control measures
Identifying the control measures you are taking can be done at the same time as the evaluation of the risk. Recording them is important and a necessary part of the process. It enables you to claim credit for controls you already apply and, more importantly, helps you identify any additional measures that can be taken to further reduce the risk.
Recording your control measures also enables you to review whether they are being followed. If, for example, you record that ‘training is given’ against a hazard, you might be more likely to ask ‘if and how’ such training is being delivered and whether it is still effective. So often, what was once a recognised precaution is no longer practised or has fallen into disrepair. Health and safety standards and rules are often taken for granted.
Some control measures apply to several hazards and in this section of your assessment you can give a general description against the risk in general. You might find the examples of control measures in Table 3 helpful. You should, however, ensure that you have considered each hazard (Table 1) in turn so that you can make a proper judgment about the most important question of all: ‘Am I controlling the risk arising from the presence of this hazard adequately and what more need I do?’ This is the next and final step.
Step 5: action plan
The combination of the risk rating and the control measures taken enables you to make the crucial decision about whether the control of risks is ‘OK’ or ‘not OK’. In making this decision you should also be mindful of any specific regulations that apply to particular hazards or activities and their requirements; and also take account of the relevant industry ‘standard’ or ‘norm’ – in other words the state-of-the-art. Here, the Woodworking Approved Code of Practice and HSE books and guidance notes will have a considerable bearing on your decision.
The whole purpose of risk assessment is to enable you to decide whether you are doing enough. While you need to be thorough, you also need to be confident enough to decide ‘enough is enough.’ Often a risk assessment turns into an over-detailed inspection where every minor defect is identified and recorded. That devalues the true purpose of the assessment. Such an inspection might be justified and of great value, but only as a control measure within the risk assessment. If such an inspection reveals an abundance of failures it points to the need for a system or additional control measure to, for example, tighten the supervision or improve maintenance or training.
If, after identifying the hazards, evaluating the risk, and recording and reviewing your control measures, you come to the decision that you are taking sufficient precautions, then record against the hazard that your control measures are OK and you need do no more than keep the matter under review.
If you decide the situation is not OK, you must identify what further controls are necessary and say who needs to take what action and by when. The system must include an effective monitoring arrangement to ensure that appropriate action has been taken and that the risk assessment has, where necessary, been amended as a result.
If your company has already completed risk assessments it might be worthwhile comparing them against the objectives and system described in this article. Your risk assessments will need to be reviewed anyway to take into account the requirements of PUWER ’98.
The next article in this series will cover the important issue of tool spindle braking as required by PUWER ’98 and the associated Woodworking ACoP.
