LTB 395/20 – HSE Workplace Inspections Medway Mail Centre and Ashford Delivery Office – Notification of Contravention & Fee For Intervention (FFI) Charge
28 July 2020
Our Ref: E1/20
To: All Branches
HSE Workplace Inspections Medway Mail Centre and Ashford Delivery Office – Notification of Contravention & Fee For Intervention (FFI) Charge
This Letter to Branches is being issued for the information of Branches and in particular Area Health and Safety Reps and Workplace Safety Reps and is in relation to health and safety enforcing authority intervention by the Health and Safety Executive (HSE) at both Medway Mail Centre and Ashford Delivery Office, the findings of which may be relevant in other offices across the UK. From that perspective, the attached HSE intervention Inspection Report may be useful in local discussions where ASRs/WSRs find ‘social distancing’, hygiene, cleaning standards, safety management and unrealistic work targets an issue.
See attached the HSE Inspector’s ‘Notice of Contraventions’ letter dated 22 June 2020 along with the ‘Fee For Intervention’ (FFI) charge. As Royal Mail have been found to have been in material breach of health and safety law, the company will have to pay for the time taken by the HSE to identify the breach. This includes investigating and taking enforcement action and is called FFI. If the contraventions are repeated the HSE can take one of three courses of action;
(a) Improvement Notice
(b) Prohibition Notice
In summary; The HSE Inspector found that Royal Mail was failing to protect their staff’s health and safety!
- There was no social distancing evident or being observed on both sites.
- Hygiene failures.
- Lack of cleaning hours spent on the sites.
- Lack of hand washing facilities.
- Work stations not cleaned between shifts.
- Lack of health and safety management and reactive support.
- Unrealistic work targets and expectations of pre-Covid-19 levels encouraging unsafe working systems.
Our two ASRs covering Ashford DO and Medway MC confirmed the findings of the HSE Inspector in relation to issues they had been raising with the employer for some time, without response and the rising pressure in the operation for more productivity which will ultimately encourage unsafe acts.
In addition to this very point, one ASR confirmed that Operational Management had given notice of intention to introduce reduced 1M social distancing working in various areas of a Delivery Office, not subject to risk assessment and discussions with the Union along with an intention to introduce mandatory wearing of face masks in the same Delivery Offices, on the basis of low productivity on packets! However, the idea was dropped after the ASR challenged the proposal.
Our ASRs add that there is prompt need for additional hours to be allocated to the RMPFS cleaning staff at Ashford DO to cover the workload associated with a 24hr operations along with the additional workload associated with the current Covid-19 sanitisation requirements. Additional cleaning hours were put in for one week only at Ashford then withdrawn.
I’m sure these findings will be replicated in offices across many parts of the country and the attached report will be of use to ASRs ADRs and APRs in discussions with local management as an indication of enforcing authority interest.
Following the HSE inspection RM/CWU discussions have been set up to progress remedial actions plans including social distancing issues and a joint local CWU/RM communication has been distributed to the workforce explaining the outcomes of the HSE inspection visit.
Lack of Royal Mail communication and guidance has been highlighted with many offices being left to develop their own signage and communications in an often amateurish way. Much smaller businesses up and down the country are providing a more professional approach to visual communication to their staff and members of the public alike.
Since the Covid-19 outbreak in March, Ashford DO has tried to change shift patterns, move some staff onto the nights, trialled a 3-day week to reduce the amount of staff in the office at any one time and eventually went over to a staggered start time shift pattern to reduce staff numbers in the office at any one time.
The HSE Inspector also made reference to toilets and wash room cleaning which wasn’t included in her report and also suggested that face masks should be worn by staff working at drop bag fittings due to them working too close, with face to face movements when sorting. This however was a verbal comment, not contained in the report. This is being taken up by the ASRs with the HSE as are issues in relation to toilets and compliance with the Workplace (Health, Safety & Welfare) Regulations regarding toilet facility ratio requirements and temporary washing facilities.
Meetings have been taking place involving the RM SHE Team and the Office PiCs plus CWU ASRs to discuss and work through a remedial action plan. The Health, Safety & Environment Department has stressed to RMHQ the importance of getting support and resources necessary to properly address the problems and legal contraventions.
Some of the issues identified are business wide issues which the Health, Safety & Environment Department have raised with RMHQ.
The lessons learned from this visit need to be widely communicated to avoid possible HSE enforcement action, prosecutions and fines in other mail centres and delivery offices.
I would like to record the Union’s thanks and appreciation for the efforts of our Area Health and Safety Reps and their deputies; Richard Harrington and Andy Gill (Kent Invicta Branch) plus Andy Irving and Paul Plim (Southdowns, Weald and Rother Branch).
National Health, Safety & Environment Officer