Corporate Health and Safety Policy
3.12 Employee representation
6. Communication and consultation
The Board of Directors, the Chief Executive and the Executive team recognise and accept their responsibilities to fulfil the legal and moral obligations to provide not only a safe and healthy workplace for employees and contractors but also to ensure the safety of customers, service users, residents, visitors, members of the public and other stakeholders who may be affected by Wandle’s activities.
So far as is reasonably practicable we will provide and maintain plant and equipment which is safe and without risks to health; ensure that use, handling, storage and transport of articles and substances is safe; provide adequate information, instruction, training and supervision; provide a safe place of work including access and egress; provide and maintain safe working environments, without risk to health, and with adequate facilities and welfare arrangements; maintain the Health and Safety Committee; and consult with our staff and with recognised trade union representatives.
Wandle’s Board of Directors will ensure that our decisions reflect our intention that good health and safety management is integrated into all the services we provide by having a customer-centred approach that puts our employees, customers, service users, residents, contractors and members of the public and other stakeholders at the heart of everything we do.
To this end, the Board Health and Safety Champion exercises oversight on behalf of Wandle’s Board and the Executive team Health and Safety Lead takes the accountability for the effective implementation of safety policies, procedures and safe systems of working. The Executive Health and Safety Lead chairs the Health and Safety Committee and reports to the Board and to the Chief Executive on all aspects of health and safety, and ensures that appropriate resources are allocated for health and safety.
We will define acceptable health and safety performance and the resources needed, profile the risks and implement appropriate risk reduction measures, measure and review performance, learn from performance measurements and the findings of investigations and act on lessons learned.
We will develop policy and procedures to deliver high quality and efficient health and safety services and embed continual improvement in health and safety into service delivery. We will involve and communicate with our workforce so everyone is clear about what is needed and to develop positive attitudes and behaviours. We will provide our employees with information, learning opportunities and supervision to allow them to work safely.
Everyone who works for Wandle has a responsibility so throughout the business we will demonstrate leadership, commitment and ownership of health and safety and commit to preventing work-related injury and ill-health. We encourage others to safeguard their own and others’ health and safety by evaluating the risks being encountered and adopting sensible precautions to minimise risks to themselves and others.
There are Heads of Service/Assistant Directors not shown on this chart as they do not operate customer facing teams who operate out in the estates, these managers still have a role but in the responsibilities are included in 3.9 under people managers.
3.1 The Board
The Board of Directors sets the overall direction for health and safety management and takes the lead in ensuring that health and safety is appropriately and adequately resourced, competent advice is obtained and that certain boardroom decisions are made with reference to the Corporate Health and Safety Policy. One member of the Board acts as Health and Safety Champion.
Transparency and Scrutiny
The Board reviews organisational health and safety performance (on at least twice yearly intervals) and challenges this information where necessary, integrates health and safety in the governance structures, receives and considers reports from the Health and Safety Committee.
The Chief Executive has overall responsibility for ensuring the implementation of and compliance with this Policy and that it is properly assigned to named duty holders below. This includes adequate planning, delivery, monitoring and review of health and safety management systems, policies, procedures, the maintenance of a safe working environment, access to competent advice, provision of sufficient and appropriate information, instruction and training for employees and the health and safety of those who may be affected by Wandle’s activities.
The “Accountable Person” under the Building Safety Reform
One of the key recommendations to come out of the Building Safety Reform programme following the Grenfell Tragedy is the requirement for a more stringent building regime for certain high risk buildings in which residents reside. Within this framework will be the Accountable Person who will have a legal responsibility for assessing and managing fire and structural risks on an ongoing basis so buildings can be safely occupied.
This role is likely to be a corporate body and not an individual and will be the person with control of the building i.e. the building owner, head lessee or management company. The dutyholders role is expected to align closely with those dutyholder roles identified under existing health and safety legislation and as set-out above for the Board and Chief Executive. This role is expected to be clarified later in 2021 and should this necessitate a change to the health and safety governance framework for Wandle we will amend this Policy at that time to reflect this.
The Executive Directors are responsible to the Chief Executive for the implementation and effective management of the Corporate Health and Safety Policy and the health and safety procedures in the areas under their control.
The Chief Executive shall nominate an Executive Director, on their behalf, to be the Lead Director for health and safety. This is currently the Executive Director of Business Services and Transformation. That individual:
- Takes the lead role in ensuring compliance with this Policy and the procedures;
- Chairs the Health and Safety Committee;
- Oversees the annual health and safety action plan.
All Executive Directors are responsible for:
- Leading, promoting and championing health and safety in their business areas;
- Ensuring all Heads of Service and all people managers in their business areas have established safe systems of work for activities under their control and that risk assessments are carried out and are reviewed;
- Receiving and reviewing regular health and safety performance reports (at least at six monthly intervals) and where necessary challenging this information;
- Instilling health and safety as a routine management practice and considering health and safety in planning and decision making.
The Heads of Service are responsible for:
- Ensuring that health and safety is embedded in their business planning and day-to-day operations;
- Ensuring that all their employees adequately manage the health and safety aspects of the work under their control;
- Ensuring that managers for whom they are responsible carry out their responsibilities listed at point 3.9 for ‘people managers and supervisors’.
- Ensuring that health and safety performance is regarded as an integral management function throughout their business area;
- Ensuring that the health and safety training needs for all their staff are assessed and fulfilled;
- Ensuring that all necessary health and safety risk assessments are carried out within their department or operations and safe systems of work are implemented;
- Implementing and monitoring any identified health and safety risk management control measures within their designated area and scope of responsibility;
- Ensuring that any accidents, incidents or near-misses are reported and investigated and that appropriate remedial action is taken.
The Heads of Service for Asset and Portfolio Development, Property and Customer Service Delivery have additional responsibilities described in the following three sections.
The Head of Assets and Portfolio Development is responsible for:
- Leading on the management of risk in the housing stock including, but not limited to, fire risk and fire safety, asbestos, legionella, gas safety, electrical safety and testing, lift safety and servicing;
- Leading on construction safety in relation to Asset Management and Development operations and activities.
3.6 Head of Property
The Head of Property is responsible for:
- Leading on maintaining resident safety in the housing stock concerning all Repairs Service operations and that all operatives carry out work in ways which are healthy and safe to themselves and others.
3.7 Head of Customer Service Delivery
The Head of Customer Service Delivery is responsible for:
- Leading on maintaining health and safety in housing management services operations of Neighbourhood and Income teams including income collection, antisocial behaviour, allocations and lettings, tenancy management, supported housing and leasehold services.
The Health, Safety and Facilities Manager, supported by an Adviser, is the primary source of health and safety advice for Wandle and has been appointed as the competent person to assist Wandle to carry out the necessary measures to comply with the statutory provisions as required under Regulation 7 of the Management of Health and Safety at Work Regulations 1999. Responsibilities specifically include:
- Providing competent advice to the Board, the Chief Executive, the Executive Directors, Heads of Service, managers and staff on all health and safety matters including regulatory compliance;
- Developing, maintaining, monitoring and reviewing the business safety management systems and associated policy, procedures and guidance;
- Developing and maintaining recording systems for accidents and near-miss incidents;
- Developing the Health and Safety Training Matrix, identifying mandatory and recommended training needs, sourcing appropriate external provision or developing and delivering internal learning resources;
- Developing and maintaining lone worker risk management systems;
- Producing management information reports as required;
- Producing reports for the Health and Safety Committee and acting as adviser to that Forum;
- Liaising with partners, external agencies and regulatory bodies including local authorities, emergency services, Health and Safety Executive;
- Assisting managers at all levels with accident and near-miss investigations;
- Assisting with the procurement of contracts to ensure contractors health and safety arrangements are satisfactory;
- Assisting and advising on risk assessment;
- Developing appropriate systems and programmes for ensuring regular workplace inspections and audits are carried out.
People managers and supervisors have particular and important responsibilities for the health and safety of their staff. They may be managing or supervising a range of people whether full time or part time, permanent or temporary employees, agency workers, contractors, apprentices or young people on work experience placements.
They must ensure that:
- They are conversant with Wandle’s Health and Safety Policy and local health and safety procedures;
- They have carried out risk assessments for the work activities and for the people for whom they have management or supervisory responsibility;
- There are safe systems of work in place where necessary;
- They investigate accidents or incidents and revise risk assessments, where necessary;
- Suitable measures are in place to manage risks;
- All work equipment, including protective clothing or safety devices, is used and regularly checked and replaced if necessary (this includes the Skyguard safety monitoring device for lone working staff);
- Their staff are competent and equipped to carry out their activities;
- Their staff attend health and safety courses and complete health and safety e-learning activities as required;
- Their staff are appropriately supervised when carrying out tasks and adhere to safety instructions and safe systems of work;
- They consult with their staff and communicate health and safety messages and information to their staff;
- They communicate and coordinate with the Health and Safety team on any health, safety and workplace welfare matter.
People managers must ensure that health and safety policies and procedures are implemented in the areas for which they are responsible. Managers have a duty of care and responsibility for the health, safety and welfare of the people whom they manage and must ensure that hazards are identified, risks are assessed and appropriately managed.
Managers can contribute greatly to preventing work-related injury and ill-health by involving their staff in the risk assessment process, by encouraging and facilitating free-flowing communication on work tasks and processes and by holding team meetings, one-to-one and appraisal meetings at which health and safety is on the agenda.
Every employee, whether permanent or temporary and including agency workers, or those in interim roles and those employed as a contractor, has a legal responsibility:
- For their own health and safety and that of their colleagues or any others who may be affected by their actions;
- To cooperate with Wandle in pursuance of health and safety policy, procedures, practices and safe systems of work including measures identified in risk assessments;
- To use all safety equipment, clothing or devices provided for their protection and not intentionally or recklessly interfere with or misuse them (this includes the Skyguard safety monitoring device for lone working staff);
- To report any damage, loss or malfunction of any safety equipment, clothing or devices to their manager or supervisor;
- To notify their manager or supervisor and the Health and Safety team of any activities, work conditions, work practices, machinery or equipment which are hazardous and uncontrolled;
- To immediately stop any work activity which is dangerous and inform their manager or supervisor at the earliest opportunity;
- To immediately report accidents, near-miss incidents, hazardous conditions and inadequacies in any health and safety procedures or practices to their manager or supervisor and notify the Health and Safety team;
- To attend any health and safety training which is identified for their role as mandatory
- To immediately notify their manager or supervisor if they consider they are carrying out, or expected to carry out, something for which they are not adequately trained, qualified or equipped.
In the event of an investigation by the Health and Safety Executive or other regulatory or enforcement agencies into a health and safety failure employees should be aware that they may, depending on the particular circumstances of the case or the extent of their involvement, be personally held liable as well as Wandle as the corporate entity.
All contractors undertaking work on Wandle’s behalf are required to:
- Comply with all statutory requirements and legal obligations placed upon them in the course of their work;
- Demonstrate leadership, commitment and ownership of health and safety;
- Create a safe working environment by identifying and minimising the risk of injury or ill health;
- Recognise and accept responsibility for the health and safety of all those who may be affected by, or exposed to risks, because of their operations or activities;
- Carry out work in accordance with the risk assessment and safe method of working provided by them to, and agreed with, Wandle;
- Comply with Wandle’s health and safety policies, procedures and all requirements as are appropriate to their operations or activities;
- Comply with the health, safety and hygiene conditions specified in the contract and with all other statutory requirements;
- Only employ persons who are competent to carry out their duties without risk to the health and safety of themselves and others;
- When appointing subcontractors (with prior approval) to carry out all or part of the work, confirm the subcontractor’s competence and ensure the subcontractor complies with the same standards of work and requirements of the risk assessment and method statement documentation and any safe system of work;
- Immediately report all accidents and near-miss incidents to the agreed Wandle manager for the premises, work activity or contract.
3.12 Employee representation
We promote and value the contribution that employee representation can make to improving and maintaining health and safety standards. To this end we will provide facilities and assistance to safety representatives, both trade union and non-trade union appointed, to enable them to carry out their duties.
If the work is construction or building work there are defined duties under the Construction (Design and Management) Regulations, 2015. In all other works, for example redecorating an office, the person commissioning the work should normally be responsible for managing the contractor(s) and become the contract manager. This attracts health and safety responsibilities.
As a minimum standard the contract manager must:
- Identify all aspects of the work and consider the health and safety implications;
- Be satisfied the contractor can carry out the work safely and without risks to health – i.e. that they are competent and possess the right experience, skills and knowledge;
- Define how the work will be managed. Who will be responsible? How the work will be supervised? What checks the contract manager will make on materials and equipment?
- Ask about the contractor’s health and safety performance. How many accidents there have been? How many work-related ill-health cases? Has the HSE or other regulator taken action against the contractor?
- Confirm if the contractor has a Health and Safety Policy if they employ more than 5 people;
- Review, ideally two weeks before the work is due, the contractor’s risk assessment and method statement for the work;
- Request information about the skills, qualifications and experience of the contractors’ workers, what information and training they provide; and
- Check that the contractor has the appropriate compulsory Liability Insurance in place.
The contract manager must also:
- Assess the risks;
- Provide information and, if necessary, training to the contractor on health and safety risks of where they will be working and measures to reduce those risks;
- Manage and supervise the work; and
- Notify the contractor about any emergency procedures.
Successful management is achieved when the contract manager and contractor cooperate and coordinate activities. One way of doing this is to hold regular review meetings during the work. Frequency and form of those meetings is shaped by the nature and duration of the work. Another option is by consulting Wandle’s own staff who may be affected by the work, providing information to them, and explaining how to raise concerns about the work.
Specific procedural documents exist in relation to health and safety subjects, the purpose of which is to describe in detail what will be done in practice to achieve the aims set out in the Chief Executive’s Policy Statement. For example the Lone Working Procedure sets out how protecting the health and safety of lone workers and assessing the risks to them will be achieved, the responsibilities of managers and employees including risk assessments and use of the Skyguard lone worker protection device.
The health and safety procedures are developed, published, reviewed and maintained by the Health, Safety and Facilities Manager and available on the Health and Safety intranet site.
Health and safety policies and procedures are approved by the Executive team or Health and Safety Committee in line with the approvals framework. Advice and further detailed information relating to these procedures is available from the Health and Safety team.
- Communication and consultation
Wandle will ensure that everyone is clear about their health and safety responsibilities by communicating:
- This Health and Safety Policy and what it means in practice;
- The allocation of safety responsibilities;
- The significant findings of risk assessments;
- Details of the safe and healthy working practices that employees need to follow;
- Details of how employees will be provided with relevant information, instruction and training to enable them to work in a safe and healthy way;
- When new health and safety legislation is introduced.
This information will be given verbally, in writing, or as part of a practical demonstration or training session (such as a toolbox talk).
Wandle has a legal obligation to consult with employees either directly or via appointed representatives (see 3.12 above). More importantly, listening to staff and involving them in health and safety decisions can result in:
- A healthier and safer workplace – employees can help to identify hazards and practical solutions;
- Better decisions about health and safety- by involving people who have greater knowledge about the business and their particular job;
- A stronger commitment and cooperation to improving workplace safety.
Matters of which Wandle will consult with employees on, either directly, via appointed representatives or through the Health and Safety Committee, include the following:
- The introduction of any measure which may substantially affect their health and safety at work (i.e. the introduction of new equipment or new systems of work);
- Information on the risks and dangers arising from their work including measures to reduce or eliminate the risk altogether;
- Planning and organisation of health and safety training;
- Advances in health and safety technology and digitalization.
We recognise that our residents and leaseholders, and others who occupy our buildings, may be impacted by our health and safety and fire policies and arrangements. Where appropriate we will consult with residents, leaseholders and others on health and safety and fire matters that affect them and the buildings they live in. We will use a range of different options, depending on their needs and preferences, to communicate these arrangements or to highlight any significant risks to which they are exposed.
This Health and Safety Policy will be reviewed at least annually and revised as necessary to reflect changes to business activities and any changes to legislation. Any such changes to the Policy will be brought to the attention of all employees.