CWU Response to Hela
28th September 2001
To Phoebe Smith / Christine Sprigg, Health and Safety Laboratory Broad Lane Sheffield S3 7HQ
Dear Colleagues,
CALL CENTRE WORKING PRACTICES - HELA DOC 94/1 DRAFT V7 -
CWU RESPONSE
Please find the CWU Health, Safety and Environment Department
submission we would wish to make on the document.
Page 1 INTRODUCTION Para 2 Add - Safety Reps & Safety Committees Regulations.
Page 2 DEFINITIONS Para 10 - Definition of Call Centre too narrow and may be exploited by unscrupulous employers - Amend to: - Main Business is conducted via the telephone whilst simultaneously using DSE and/or processing documentation and/or data transfer or inputting.
Page 2 HOT DESKING Para 13 - Add - It is recommended that Hot Disking should be avoided or minimised wherever possible
Page 3 SOFTWARE Para 16 - Add - Minimum Software Screen Font Size should be Size 12.
Page 6 Para 31 WATER GOOD PRACTICE - Add - Ensure a sufficient number of Cold Water Fountains are positioned throughout the Call Centre to enable water to be obtained near the Workstations.
Page 7 REQUIREMENTS FOR THE WORKSTATION - After
Para 42 Add - GOOD PRACTICE
· Have a clear and easy procedure for reporting unacceptable
equipment. Hold a sufficient stock of replacement items e.g.
chairs, document holders, foot rests, wrist rests, Monitors etc
etc. Respond to complaints promptly and take them seriously and
replace faulty equipment immediately.
· Provide individuals with sufficient lockable secure personal
storage facilities.
· Regularly review Workstation assessments. Consult the Call
Handlers and their Safety Representatives.
Page 8 Para 45 LEGAL REQUIREMENTS AND RECOMMENDATIONS - Amend Rest Breaks to 10 Minutes after every 60 Minutes Worked or 20 Minutes after every two hours excluding lunch breaks, tea breaks, toilet breaks and fetching Water when they need to. (This is in line with the CWU Agreement with Royal Mail Service Delivery).
Page 11 After Para 55 STRESS GOOD PRACTICE -
Add: -
· In consultation with Call Handlers and Safety
Representatives, improve job design so as to reduce the risk of
call handlers suffering stress.
· Draw up and develop in consultation with the Trade Unions
and Safety Representatives a Stress Policy that recognises it is a
Health & Safety Issue. Undertake Risk Assessments and provide
joint monitoring and regular reviews. Guarantee a 'blame
free' approach to call handlers.
Page 11 & 12 Para 57 PERSONAL SAFETY GOOD
PRACTICE - add: -
· Provide Personal Safety Information and Training.
Page 13 Paras 68 and 69. Noise limiters/Acoustic shock:
These two paragraphs are completely unacceptable to the CWU and its thousands of members who are unfortunate to know all about Acoustic Shock. CWU members are increasingly being exposed to noise related injuries in Call Centres.
The CWU is the major union for representing these workers and thousands of members across the various employers we deal with now work in these environments. The hazards of acoustic shock and other forms of noise interference have brought suffering to some of these members. Over a hundred CWU Call Centre members are currently seeking damages for damage to their hearing. Also, the CWU has hundreds of accident reports of members suffering Acoustic Shock that has resulted in them suffering symptoms such as Tinnitus, perforated eardrums, headaches, fluid in the ears and depression. Acoustic shock definition of less than one second is not correct as the noise can and does in most cases far exceeds one second.
The risk of course depends on the intensity of the noise levels and the length of exposure. Also, people have different sensitivity levels. Pressure on the hair cells and nerves in the inner ear from unacceptable noise levels can cause permanent hearing loss, temporary hearing loss and tinnitus.
The union participated with BT and the Health and Safety Executive in the major survey by the HSE last year into noise including noise surveys of BT call centres
At one BT Call Centre involved in the survey in Leicester, CWU Health and Safety Officer, Steve Mann, observed the HSE's noise and vibration specialist set up a Knowles Electronics Manikin for Acoustic Research (KEMAR), which was wired up next to a number of call centre workers.
During this full noise survey, which took place at BT's Leicester Transactions Centre and 151 Residential Repair Centre, both witnessed a genuine Noise Incident sound burst which was actually recorded. The person suffering this was Jacinda Roberts. The noise lasted for about nine seconds and peaked at about 105 db. Jacinda suffered a numbing to the earlobe, headache, a feeling of water in the ear, headache and was shocked. The current standard setting of noise cut out on headsets at 118db is too high and we need to campaign to lower this level. We need to work on adequate noise suppression in the headset and the line that cuts out unwanted noise bursts much lower than 118db.
Medical opinion supports the case that damage sustained to the hearing by receiving acoustic shocks can permanently damage hearing.
Therefore Section 68 and 69 need to reflect the fact that much more needs to be done in the area of noise interference to call centre workers.
Page 15 Para 74 HEARING/HEADSET GOOD PRACTICE -
Add: -
· The issue of personal headsets to individuals is strongly
recommended.
· Ensure sufficient stocks of New/Sterile Headsets are
available.
(NOTE: We discussed the additional submission you were compiling on
Noise and Acoustic Shock in respect of this section)
Page 15 Para 78 DRINKS GOOD PRACTICE - Add on end of third bullet point - However they should also be allowed the choice of an occasional Hot Drink or soft drink at the Workstation.
Page 16 Para 83 EYES AND EYESIGHT GOOD PRACTICE
- Add -
· Prompt staff to request regular eye tests and inform them of
their entitlement to free eye tests and payment for any necessary
corrective appliances/spectacles.
Page 17 Para 87 GOOD PRACTICE - Add -
· Have a clear and easy procedure for reporting unacceptable
equipment. Hold a sufficient stock of replacement items e.g.
chairs, document holders, foot rests, wrist rests, Monitors etc.
Respond to complaints promptly and take them seriously and replace
faulty equipment immediately.
Page 20 Para 92 WORK RELATED STRESS GOOD
PRACTICE - Add -
· Set reasonable achievable targets in consultation with the
individual and Safety Representatives.
· In consultation with Call Handlers and Safety
Representatives improve job design so as to reduce the risk of call
handlers suffering stress.
· Draw up and develop, in consultation with the Trade Unions
and Safety Representatives, a Stress Policy that recognises it is a
Health & Safety Issue. Undertake Risk Assessments and provide
joint monitoring and regular reviews. Guarantee a 'blame
free' approach to call handlers.
· Introduce an effective Policy against bullying and
harassment policy after consulting staff and their Trade Union
Representatives.
Add New Section on FIRE SAFETY & COMPLIANCE - My recent investigations in PO Call Centres found that Fire Risk Assessments had not been completed and statutory records were not in order. Failure to complete Log Books, Fire Exits blocked, No Fire Alarm Tests, No Fire Drills, and Wrong Signage etc. Similarly Emergency procedures for Security Alerts and Bomb Threats etc should be referred to.
Add a new section entitled SAFETY REPRESENTATIVES. Employers are required to consult Safety Representatives in good time over the making and maintaining of arrangements to enable effective co-operation on health & safety and checking the effectiveness of such measures. They should be provided with information and their views and input taken into account. HSAW Act 1974. MHSW Regs 1999. SRSC Regs 1977. HSCE Regs 1996.
We hope this is useful.
Dave Joyce, Chair of the National Executive's Health & Safety Committee
HELA - ADVICE REGARDING CALL CENTRE WORKING PRACTICES
To contact the department: healthandsafety@cwu.org
