LTB 284/23 – Delivery Office Revisions/Floor Plan Changes and Sorting Frame Moves and Adjustments in Breach of ‘Mandatory’ SAC1, SWI, TBRA etc., and ‘Mandatory’ ASR Engagement and Consultation
No. 284/2023
9 November 2023
Our Ref: C1/23
To: All Branches
Dear Colleagues,
Delivery Office Revisions/Floor Plan Changes and Sorting Frame Moves and Adjustments in Breach of ‘Mandatory’ SAC1, SWI, TBRA etc., and ‘Mandatory’ ASR Engagement and Consultation:
The Health, Safety and Environment Department continues to receive a large and continual number of health and safety complaints and health and safety dispute/escalations from Branch Area Health and Safety Representatives involving Delivery Offices where Revisions, Floor Plan Changes and Sorting Frame Moves and Adjustments are being undertaken in breach of the ‘Mandatory’ Safety Concurrence (SAC1), Safe Working Instructions (SWI), Task Based Risk Assessment (TBRA) etc., plus the ‘Mandatory’ requirement to undertake ASR engagement and consultation as set out in RMG SHE Instructions, National Agreements and of course the law (SRSC Regulations 1977).
This matter has been raised with Elizabeth Lloyd Royal Mail Group Director Health and Safety, Sue Cuddihey Royal Mail Group Head of Safety for Programmes plus all newly appointed Field Operations Directors and Regional Operations Directors, requesting that all Unit Managers, PiCs, COMs, OPLs and Planners be reminded of the rules and correct approach to safety compliance when planning, initiating and undertaking changes with CWU ASR consultation being the first action.
In every one of these cases of complaint the consistent theme involves Unit Managers and Planners breaking the rules and blatantly breaching ‘Mandatory’ Safety and Operational Instructions, National Agreements and Health and Safety Regulations, all of which Managers and Planners should be more than familiar with. The first versions of the ‘Mandatory’ SAC1, SWI and TBRA were put in place two and a half years ago with later updated versions issued around a year ago.
Every Office Revision has a ‘pre-populated’ action plan embedded, which reinforces key CWU ASR engagement points to ensure consultation takes place in good time. Some actions are not necessarily applicable to all Office Revisions but should be discussed and discounted.
There is no reason or excuse that Managers can therefore legitimately offer for not being aware of these important safety instructions and we have requested an investigation and explanation as to why such blatant and obvious breaches of safety and other mandatory Royal Mail Instructions are occurring.
The law is crystal clear that when changes of this nature take place the ASR (Accredited and Credentialed) Area Safety Rep, must be consulted in good time as reiterated by the RMG SHE Standards and RMG Safety Policy signed by the CEO.
Reports from ASRs inform us that without warning or engagement and consultation, sorting frames are being moved and floor plans re-arranged in a hap-hazard, non-compliant way, causing damage to the sorting frames, affecting stability and damage to the unit floor surfaces as well as affecting things such as work station space standards, aisle widths, lighting, fire escape routes etc. The Health, Safety and Environment Department has requested that:
- These situations are curtailed.
- Managers ignoring the SAC1, SWI, TBRA and breaching Safety Instructions to be investigated as to the reason for this.
- Any frames moved incorrectly to be inspected by RMP&FS to ensure they are safe and free from damage.
- Delivery Offices to be jointly checked and inspected with the CWU/ASR to ensure floor plans and space standards are in compliance.
- Workplace Risk Assessments to be reviewed jointly to ensure full compliance.
We have also requested that all PiCs, COMs, OPLs and Planners, be reminded of the need to work with the CWUs ASRs and the RMG SHE Team of SHE Advisors, ensuring compliance with the attached:
- Mandatory Delivery Revisions (Inc.Frame Moves) SAC1 (Safety, Health & Environment Concurrence).
- Mandatory SWI (Safe Working Instruction) for Frame Movements (Dismantling, Removal and Relocation of RM2000 Frames and Wings).
- Mandatory Frame Movements TBRA (Task Based Risk Assessment).
- Royal Mail Managers “Frame Moves” Sharepoint Extract. Covering Mandatory rules on “Frame Moves”, the SAC1, SWI and TBRA documents can be accessed shown alongside Delivery Office Space Standards, Overarching Delivery Revisions SAC, RM2000 Prep Guide and What Goes Where Guide.
- RMG Safety Policy.
- CWU ASR Job Description based on The Health And Safety At Work Act 74 and Safety Reps and Safety Committees Regulations 1977 and legal guidance.
- CWU ASR’s Legal Rights To Carry Out Inspections.
It’s important to stop sorting frames being dragged around and damaged or not constructed correctly, leading to the risk of sorting frames being unstable and at worst collapsing.
Sorting frames that have been moved incorrectly need to be checked over by RMP&FS at the earliest opportunity to ensure they are safe and not damaged and that all components, strengthening struts and retaining screws are in place, tight, secure and not stretched or broken with any missing parts replaced.
Sorting frames moved locally have to follow the attached SAC1/SWI/TBRA and this is the message ASRs need to get out there and be enforced with the support of the RM SHE Team FODs and RODs.
The ‘MANDATORY’ SAC1/SWI/TBRA puts in place a number of strict controls and limitations on Floor Plan Changes And Sorting Frame Moves being done locally as follows:
- Before any workplace changes and alterations the CWU ASR must be fully engaged and consulted with his/her input taken into account.
- Before moving/relocating any Sorting Frames, the RM Central Programmes Team/ RM Delivery Design Team must be consulted for clearance regarding the changes and a ‘CAD drawing’ should be obtained from the Property Records Team via the Delivery Estates Team. Any revised floor plan must ensure Space Standards are met, with a fire plan/evacuation plan updated, Workplace Risk Assessment, aisle widths/walkways, escape routes and lighting standards checked and standards met and equalities act protected staff with disabilities given appropriate consideration etc., – all to be done in full consultation with the ASR.
- If the Sorting Frames are bolted to the floor they cannot be moved locally. (The moves must be referred to RMP&FS).
- If the Sorting Frames have Electric Task Light Fittings they cannot be moved locally. (The moves must be referred to RMP&FS).
- Those performing the Frames moves must be MH trained.
- The base unit and wings must be completely unbolted and dismantled with the base and wings moved separately.
- All bolts have to be changed when re-assembling the Sorting Frames base and wings (which can be a base and six wings).
- If any bolts are broken off in the anchor bolt sockets then RMP&FS Engineers will have to be called in to drill them out and replace them with a nut and bolt.
- All staff moving Sorting Frames must be provided with PPE protective (Toetector) footwear before they start (ordered and delivered from RM Uniform/Dimensions).
- All staff moving Sorting Frames must undergo Manual Handling Training.
- The movement of the assembled ‘Base’ Unit must be a ‘four-person lift’.
- The movement of wings is a ‘two-person lift’.
- The Frames must not be ‘dragged’ across the floor which can damage both the sub-frame structure of the frames and the floor
- The Task Base Risk Assessment ‘bottom line’ states “Individuals should only complete this task if they feel able to do so”. (Our operational members can therefore opt out of moving Sorting Frames if they are asked to undertake Sorting Frame moves).
The Health, Safety and Environment Department does not support and has objected to Frames being moved locally. Our view is that it’s best done by RMP&FS Engineers. The RM COO however continues to support a ‘DIY approach’.
To reiterate my advice above, following any Frame moves, I recommend that the Frames be checked for safety by RMP&FS Engineers.
ASRs are requested to make proactive representations to OPLs and PiCs reminding them of the above and attached should they have any plans to make changes in Units.
ASRs should also carry out inspections (in line with the attached ASR Job Description and Safety Inspection Guide), looking carefully at the condition of Sorting Frames, recording and reporting any Frames found with faults or safety issues.
Yours sincerely
Dave Joyce
National Health, Safety & Environment Officer
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