H&S Regulation and Recognition
CWU Response to
HSC Consultative Document
entitled HEALTH & SAFETY REGULATION AND RECOGNITION
TOWARDS GOOD PERFORMANCE IN HEALTH AND SAFETY
Including comments on the associated Hampton Review of Regulatory
Inspection and Enforcement
By Dave Joyce
Communication Workers Union
National Health, Safety & Environment Officer
December 2004
Index
1. Introduction
2. Death and Injury at Work
3. Executive Summary
4. Interventions Strategy - Inspection and Enforcement
(Interventions at and during exposure to risk)
5. Hampton Review of Regulatory Inspection and Enforcement
6. New Interventions
7. Low Risk Premises
8. HSE Resources
9. Advice, Education, Information and Publications
10. Worker Involvement and Consultation (Working with those at Risk
-Safety Reps)
11. Department of Work & Pensions Select Committee report
12. Directors & Senior Managers
13. Corporate Accountability, Manslaughter and Sentencing
14. Penalties
15. Victims
16. Partnership
17. Design and Supply Chain
18. Sector and Industry-wide initiatives
19. Education and awareness
20. Recognising good performance
21. Interventions at and during exposure to risk- intermediaries
22. Interventions when consequences of exposure to risk arise -
Accident and ill-health investigation
Introduction
This is the response to the HSC Consultation Document (CD) entitled
"Regulation and Recognition - Towards good performance in
health and safety" submitted on behalf of the Communication
Workers Union which represents 300,000 Postal and
Telecommunications industry workers.
Our membership includes a range of manual, technical and clerical professions including Postal Mail and Parcel Delivery and Processing staff, Call Centre employees, Clerical, Administration and Financial Services workers, Telecommunications Engineers, Mail Processing Equipment Engineers, Motor Vehicle Maintenance Engineers, LGV and light commercial Drivers, Retail network staff, Security Industry workers and Enquiry Officers. We are fortunate in being able to draw on this broad range of occupations and expertise to inform our views.
The CWU gives a high priority to the protection of the health and safety of all our members. We aim to provide the best advice and representation to our members and one of our greatest assets is our network of Safety Representatives who we fully support in their work and functions. To this end, the CWU has its own Education and Training Centre where we provide a full range of Safety Representatives Training courses based on the TUC programme. We continually review the training and guidance that we give to CWU Safety Representatives in order to support the valuable work they do to prevent accidents in the workplace and ensure that legislative standards are met.
The CWU is interested in all aspects of health and safety, particularly how to change the law to encourage better practice and to reduce totally unnecessary and preventable deaths and injuries. We welcome the opportunity to participate in this Consultative exercise, and to make a written submission on the question of Health and Safety Executive (HSE) and Local Authority (LA) interventions strategy and safety Law enforcement which in our opinion requires new impetus.
CWU policy established by our annual conference has consistently reflected the view that there must be no retreat by the Enforcing authorities (HSE & LAs) from inspection, safety law enforcement and prosecution, with increased court penalties for employers who fail to discharge their health and safety obligations, including the availability to the courts of the option of imprisonment for all health and safety offences. Further to this, our Union strongly believes that sufficient resources must be provided by government to the HSE/LA enforcers and we continue to call for a new Corporate Killing Offence, Legal Safety duties to be imposed on Directors, and greater powers and protection for trade union Safety Representatives.
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