'Better regulation' strikes again
Health and Safety Bulletin looks at the latest government attempt to “improve” health and safety standards in, and expectations of, SMEs and “low-risk” enterprises.
On this page:
Burdensome concerns
Evidence wanted
General issues
Confused perceptions
Driving beyond the enforcers
Information and advice
Health and emerging risks
The impact of regulatory structures
Small does not always mean low risk
Reasons to be cheerful
A burdensome myth
Stop me if you’ve heard this one before
The seemingly endless attempts of successive governments to “better regulate” or “deregulate” health and safety – depending on one’s political standpoint – is approaching a defining moment, with the publication of a consultation paper and call for evidence on “improving outcomes from health and safety”1. Launched on 27 November 2007, consultation will close on 31 January 2008, with the government publishing a final report in spring 2008 (see box 1). The review concentrates on “low-risk” and small and medium-sized enterprises (SMEs). The potential of the review is therefore significant, with SMEs (organisations that have fewer than 250 employees) representing 99% of enterprises, half of all business turnover and 59% of public sector and 48% of private sector workers.
Although the document is issued by the Department for Business Enterprise and Regulatory Reform (DBERR), it bears all the hallmarks of the Better Regulation Executive (BRE), which was moved from the Cabinet Office to the newly formed DBERR after Gordon Brown became prime minister. The review was announced on 25 July 2007, and from its inception the HSE has had a senior inspector attached to the project team.
DBERR insists that its review “supplements, but is distinct from” the work that is being conducted as part of the Hampton Implementation Review of the HSE, which considers the HSE’s performance against the principles set out in Philip Hampton’s 2005 report on the enforcement of business-related legislation. While the BRE will publish its implementation report in early 2008, the HSE’s chief executive, Geoffrey Podger, informed the HSC’s monthly meeting on 11 December 2007 that the review had concluded:
- that the HSE was “Hampton compliant”, but that there were likely to be criticisms of the level at which HSE guidance was sometimes pitched (a “good criticism”, Podger agreed);
- that HSE staff were “not always convinced of the value of what they are asked to do (the HSE is starting to address this, advised Podger); and
- that the HSE does not have a sufficiently good database for selecting which businesses should be inspected (“there is a limit to the resources available” for the compilation of the database, argued Podger, “beyond which you have to cut down on the number of inspections carried out”).
Burdensome concerns
The new consultation is clear that “health and safety protections are absolutely paramount to the UK’s position as a fair and decent society” and that outcomes in the UK have “improved significantly” since the HSW Act reached the statute book in 1974, with a 68% decrease in the incidence of serious injuries and the UK “especially successful” by international standards. It also points out, though, that 241 workers were killed in 2006/07 and 30 million working days were lost in 2005/06 from work-related injury and ill health, at a cost to society of between £24 billion and £38 billion annually.
At the same time, “businesses, especially small firms in low-risk sectors, have become increasingly concerned by the burden of health and safety regulation. While they understand that protecting the health and safety of their workforce is crucial, they are concerned that some of the paperwork involved is overly complex. The administrative cost across UK industry of complying with health and safety law is estimated at over £2 billion per year.” The HSC/E are already, through their 2006 and 2007 simplification plans (see box 2), aiming to cut this administrative cost by 25%. The new review, claims DBERR, “is considering what more can be done to deliver strong health and safety outcomes in a modern working environment while minimising the burden on business and maintaining the confidence of society”.
The review correctly points out that the use of goal-setting, non-prescriptive self-regulation by employers under the HSW Act – while sensible and successful for many employers – can be “particularly challenging” for SMEs. Smaller firms, DBERR acknowledges, “often prefer specific advice that requires no interpretation and may struggle to translate general duties into specific actions for their organisation”. Problems include limited time and resources, a lack of awareness of responsibilities, lack of access to external advice, and a disproportionate cost of meeting responsibilities. The problems, notes DBERR, have “led some business representative bodies to call for greater clarification and simplification”.
Evidence wanted
The “key question” for the review, therefore, is: “are there new or better ways to help employers meet their health and safety responsibilities more easily that will also improve protection for their employees?” The “call for evidence”, which will help inform the evidence base for answering this question, looks at six themes:
- general issues;
- perceptions of health and safety;
- drivers for better health and safety;
- information and advice;
- health and emerging risks; and
- the impact of regulatory structures.
General issues
The review cites research evidence that shows that “some small businesses struggle to meet all of their legal obligations around health and safety, and that smaller employers may find this hardest”. There is also a low level of awareness among small firms of health and safety legislation. It advises that injury rates in smaller firms are higher than in larger enterprises (although the situation is sometimes less clear-cut than this, and absence rates are often lower) and acknowledges that the HSE has targeted smaller firms with many initiatives: “Yet, in spite of this activity, and even though the flow of new health and safety regulation has diminished significantly in recent years, business representatives have been critical of the UK health and safety system. Negative views appear to be particularly strong among small businesses.” DBERR points out that some firms “struggle” with risk assessment but also that investment in health and safety “does no harm” and, indeed, can produce many benefits.
There may, however, be “better ways” to help SMEs, and DBERR cites approvingly the situation in the US, where businesses with fewer than 10 employees have access to free, advice-only workplace visits and seminars, or in some Australian states that have schemes to provide SMEs with good-quality, free advice on occupational health issues. DBERR’s positing of such a service here in the UK is not without irony given the steadfast criticism of the UK’s attitude towards the provision in the 1989 Framework Directive that calls on member states to ensure access to competent health and safety advice. The UK’s position – in the face of overwhelming evidence to the contrary – has always been that the UK was compliant with this proviso. There is also, in the DBERR document, only passing mention of initiatives such as Workplace Health Connect, which is providing free access to good occupational health (and, in practice, safety) advice in pilot regions.
In terms of general developments, DBERR notes that the HSE’s simplification plans “are expected to make a real difference to businesses, aiming to maintain or improve health and safety outcomes while reducing administrative costs”. Other initiatives include the HSE’s legislation web pages, and a Business Link scheme that allows businesses to create a personal regulation checklist.
Among the views in which DBERR is particularly interested are whether it would be helpful if employers could demonstrate that they meet their obligations through completing a checklist or by being accredited to a standard. Should such ideas gain wings during the consultation, the outcome might have significant practical impact.
Confused perceptions
DBERR notes that while there is public support among business and the public for the HSE as an institution, business representative groups have publicly criticised the health and safety system, and while the views of individual employers vary, “there appears to be a pattern of complaints about over-complexity”. Further, “media coverage about the whole subject of ‘health and safety’ appears largely negative”, even though some coverage is “misleading or factually inaccurate”. DBERR acknowledges that: “It is difficult to know how this apparent contradiction should be interpreted – between, on the one hand, support for the aims of health and safety regulation and respect for its key overseer, and on the other, considerable criticism.”
One possibility, says DBERR, is “that there is a disconnection between perceptions and reality”, noting in addition that “other complaints are not about the actions of regulators at all but about other players in the system.” It does not, however, look at two further possibilities. First, negative and agenda-driven (and often inaccurate) reporting characterises much journalism, not just that on health and safety, and DBERR does not mention the many positive column inches that health and safety also enjoys. Second, health and safety may be becoming entangled – unfairly – in the “nanny state” political zeitgeist. It will be a troubling day if DBERR recommends significant changes to health and safety regulation for SMEs based on a small number of unrepresentative, inaccurate and usually trivial stories.
Driving beyond the enforcers
One of the most positive aspects of the consultative document is the emphasis that it places on what might be termed “third-party regulation” – essentially, non-statutory regulation by bodies other than the HSE and local authorities (LAs). (This is linked to the question of “demonstrating” compliance in the “general issues” section.) DBERR is particularly looking for evidence about how best to encourage and recognise good health and safety management. Potential motivators may include insurance premium adjustment, procurement processes and customer–supplier relationships. DBERR also seeks evidence as to whether or not the fear of compensation claims has any influence on health and safety management.
DBERR notes that public procurement tenders often require a contractor to provide evidence that their organisation actively promotes and manages health and safety. It also believes that “health and safety requirements set by customers and suppliers may be an important influence on how many small businesses manage health and safety, but we have not found evidence to confirm this.” (The Royal Society for the Prevention of Accidents has recently produced a report on the role of such “pre-qualification” schemes, as part of its ongoing inquiry into health and safety assistance for SMEs.)
In principle, advises DBERR, “insurance should encourage health and safety activity through providing lower insurance premiums for employers with better systems and health and safety records.” In practice, small firms have not benefited “because insurers have not found a reliable way of determining an employer’s performance without visiting them”, which is usually prohibitively expensive. Instead, insurers use a sector-based “book rate” system, which does not allow for individual recognition. Any discount, DBERR adds, would in any case have to be substantial to provide an incentive for employers.
DBERR notes that studies have concluded that, although the UK does not have a compensation culture, “there is evidence that suggests some feel litigation is becoming more common”. The Association of British Insurers, for example, bases “an increasingly litigious culture” on the growing number of personal injury claims companies and, as recent research found, an increase in the average amount paid per claim. Although DBERR does not query this finding, it should be noted that the number of claims, rather than the number of claims companies, is a more accurate determinant of the prevailing culture, and that the number of accident claims against employers notified to the Department for Work and Pensions’ compensation recovery unit fell from 97,675 in 2000/01 to 77,765 in 2004/05. Although disease claims rose – from 121,508 in 2000/01 to 175,737 in 2004/05, having peaked in 2003/04 – this total is skewed by the fact that 2004 was the final year in which claims could be made under the Coal Health Compensation Scheme. This massive scheme followed a legal judgment righting decades of Coal Board negligence and, by March 2006, had resulted in payments in excess of £3 billion to settle 442,000 claims for vibration white finger and respiratory.
Information and advice
DBERR acknowledges the large amount of health and safety information and advice that is available, including the HSE’s many initiatives for SMEs. The document highlights one of the main dilemmas facing regulators: some SMEs avoid turning to regulators for advice; others need more “direction” than a regulator would supply. Personal contact is generally “welcomed” (DBERR does not mention that most research concludes it is essential), if expensive, while “regardless of its source, SMEs respond best to sector-specific information that uses simple language.”
DBERR would like evidence of where stakeholders have received good and bad advice, views on the HSE’s example risk assessments (see box 3), whether and how government should ensure that tailored advice is available to employers that have limited resources, and whether or not there is a need for more information for people other than employers, for example workers and volunteers.
Health and emerging risks
DBERR notes that work-related ill health is a far bigger problem than injuries, and that the costs of absence to employers and to the economy as a whole are significant. “Some question how well the proven ‘safety approach’ of assessing and controlling risks works for preventing ill health which does not directly arise from work. This approach is recognised as a good way to deal with occupational diseases (for example, those caused by hazardous substances, loud noise or strong vibration). However, it is less well accepted for preventing problems with multiple causes, particularly stress, anxiety and depression.”
As laudable as many of these considerations are, it is unclear how asking SMEs, and even regulators, to address additional issues sits within a consultation that aims to reduce their “burden”. A fundamental problem with many SMEs is that they don’t do anything about basic safety issues, let alone tackle issues that are not wholly work-related.
The impact of regulatory structures
DBERR acknowledges that “a considerable degree of targeting by the HSE and LAs already takes place, based on the HSC’s priorities and a premises risk-rating system. Nevertheless, the report claims that: “There may be scope to target enforcement effort even more strongly on employers most able to benefit, or most likely to endanger their workers or the public.” Unfortunately, it gives no clue as to what it has in mind.
Currently, enforcement responsibilities are split between the HSE and LAs by the Health and Safety (Enforcing Authority) Regulations 1988; in broad terms, LAs enforce in the service sector, with the HSE taking on the agriculture, construction, manufacturing and extractive and utility supply sectors. There have, however, been significant changes in the numbers of workers in these sectors, with increases throughout LA-enforced sectors, and decreases in most of the traditional areas enforced by the HSE (see box 4).
DBERR notes that, by 2004, the HSE had accepted that there was “no lasting logic to the ‘complex [and] confusing’ arrangements”. Although the HSC has not called for further amendments to the 1988 Regulations, it has been exploring the use of “flexible warrants” with LAs as a means of breaking down the distinction. DBERR also highlights a pilot in Peterborough that gave LAs responsibility for higher-risk premises (dry-cleaning and motor vehicle repair) and notes that this “delivered a more effective use of both HSE and LA resources, and business reported preferring the ready accessibility of a local expert”. There are other schemes that the report could have mentioned in a similar vein, for example the Moving Goods Safely initiative. DBERR notes too that, more generally, the government is increasing the power of LAs in “local partnerships”.
DBERR states that it is particularly interested in views “on how regulators should target their efforts on employers who present the greatest risks. You may, for example, feel they should use information about business sector, occupation of employees, size of employer or attitudes or skills of managers.” It also wants to know about further flexibility and the most effective HSE–LA split. Many of these details are, however, precisely the information that the HSE currently uses to target businesses, and it is difficult to envisage a practical mechanism whereby regulators would have sufficient resources to obtain information on managers’ attitudes and skills as a basis for targeting. Geoffrey Podger’s comments on p.8 about the resource difficulties of compiling a better database are pertinent here too. It is also not clear how changing the spilt between HSE- and LA-enforced premises will improve the targeting of enforcement, although the suggestion that “health and safety activities could be better joined up with other services (regulatory or other) delivered by LAs (see box 5), such as Building Control”, is certainly worthy of consideration.
Small does not always mean low-risk
The essential problem with the consultation document is that it erroneously conflates SMEs with low-risk enterprises. At times, it appears to acknowledge the problems of using the two terms together, but then nevertheless uses them interchangeably throughout the document. Launching the HSE’s simplification plan, the HSC’s chair, Judith Hackitt, alluded to this when she said: “It is a dangerous mistake to assume that small business equals low risk in all cases. Let’s be in no doubt that in reducing bureaucracy it is the level of risk that counts and we must all be careful to ensure that levels of protection are maintained in all businesses – whatever their size.”
DBERR argues that it does not use a precise definition of “low risk”, focusing on “employers who feel their workplaces are, on the whole, at relatively low risk of accidents and occupational diseases arising directly from work (for example, those caused by hazardous substances, loud noise or strong vibration).” Again, the “feelings” of employers as to the risk their premises produce are not the best basis for targeting or action, unless the regulators are convinced that the employer is able to make this determination with accuracy. “Low-risk” service sector industries, for example, often leap into a different hazard category if road-traffic accidents are included.
“Low-risk” organisations, suggests DBERR, are likely to be found in the wholesale and retail trades; hotels and restaurants; communications; banking, finance and business services; leisure; and public administration and education. All but the last are LA-enforced. Perplexingly, DBERR adds that: “We recognise that in some of these sectors there are particular risks of other health problems, such as stress, musculoskeletal disorders, including back pain, and those related to the threat of violence.” But with stress and musculoskeletal disorders accounting for the vast majority of work-related ill-health conditions and sickness absence, it is not clear where DBERR is going with this.
There are also problems with the weighting that DBERR gives to differing evidence sources. For example, a Federation of Small Businesses survey of small businesses is given disproportionate value when set against the more objective research that has been carried out in the SME sector. The responses to the survey may well have been skewed by a higher response rate among the malcontents, and it is not hard to guess the responses to questions about whether SME owners and managers believe they are over-regulated.
Reasons to be cheerful
While there are many problematic aspects to this consultation, there are also many encouraging signs. In this sense, its major limitation – it was produced largely by non-health and safety experts – may also prove to be its greatest strength. While we can argue about what SMEs do and don’t do, there is no escaping the fact that the system works better for larger firms than it does for SMEs, which frequently report that the UK’s system of regulation and assistance is not appropriate to them. And the particular interest that DBERR has in changes that would help micro-businesses (0–9 employees) and small businesses (fewer than 50 employees) is welcome.
Of potential note here is the recognition by DBERR that the role played by non-regulators might be of “considerable importance in shaping how employers understand health and safety”. Non-regulators include specialist journals and consultants, and those “who make good health and safety management a condition of contracts” or work placements, for example customers, insurers, trade bodies and further education colleges: “We are interested in the broad range of influences on how these employers perceive and respond to health and safety requirements. It is not, therefore, narrowly focused only on the activities of the HSE and LAs.” While the HSE has made increasing inroads into non-statutory sources of support and encouragement in recent years, should DBERR choose to champion non-HSE and LA activity, this can only be a good thing, providing it is additional to, rather than in place of, vibrant state regulation and enforcement. Employers, as much as employees, have a vested interest in this.
A burdensome myth
There is in any case a tendency to overstate the regulatory burden placed on employers in the UK. The Forum of Private Business (FPB), which claims to represent 25,000 UK-based employers with 600,000 employees, said the government “should avoid placing unnecessary burdens on [firms’] ability to do business, rather than just helping them wade through the raft of legislation”. The FPB reports its finding that, among those attending its small-firms summit in October 2007, “the burden of health and safety legislation is the most pressing concern for business owners … particularly the onerous task of filling in the many different risk assessment forms.” The forum claims that a March 2007 FPB survey revealed that smaller firms devote an average of 14 hours each month to dealing with health and safety red tape. Aside from the obvious observation that the injury and ill-health incidence would be significantly lower if most SMEs were spending two working days a month on health and safety, there is still no convincing evidence as to how health and safety is obstructing business development. Most of the evidence is anecdotal and, often, inaccurate.
We are, in fact, one of the less – not more –regulated of developed economies. As the TUC head of health and safety, Hugh Robertson, who is also an HSC commissioner, says: “Britain’s health and safety laws are remarkably simple, yet a majority of small businesses have not done even a suitable risk assessment as required in law. This is not down to the regulations being unsuitable for small businesses; it is because of the lack of enforcement and the priorities that the employers have given to protecting their staff.” Robertson could also have added that many of the legislative requirements have their basis in EU Directives and, as such, the government’s hands are often tied.
Robertson emphasises that a combination of the HSE’s work on simplifying regulation and greater information, guidance and enforcement is the way forward. “Increasing the resources available to HSE to deal with breaches of the regulations would do far more good than simply reviewing how they are applied,” he says.
Stop me if you’ve heard this one before
In the end, one is left with the strong feeling that we have been here before – time and again. The Conservative governments of the 1980s and 1990s undertook huge “burdens on business”, red-tape and deregulatory reviews, without enjoying any significant success. And John Redwood, chair of the party’s economic competitiveness policy group, has been at it again recently, publishing in autumn 2007 his final report on cutting red tape for business (PDF format, 3MB) (external website).
The harsh truth is that it is difficult to identify areas in which to “better regulate” in any significant and practical way other than the initiatives and thinking that are already in place, whatever the political posturing that ministers feel obliged to present in public, or that have been advanced by campaigners and unions. A two-tier system for small and larger enterprises seems to remain off the agenda, while governments still trot out the “health and safety makes good business sense” mantra, often without appearing to believe in it themselves. In fact, successive Conservative and Labour administrations have probably achieved their lighter touch through under-funding the HSE and LAs for 25 years rather than through all the better regulation/deregulation initiatives they have undertaken. For all the activity around the preparation and implementation of the Hampton report, it is appropriate to ask how much the HSE has done differently as a result. True, there has been some repackaging and window-dressing, but arguably not a great deal more. The real impact of Hampton and its ilk may be in the subtle “pro-business” messages it sends to inspectors and employers, and in the pulling of the rug from under the HSE in terms of an adequate budget to do its job.
The possible difference this time around is that Gordon Brown, who, as chancellor of the exchequer spawned Hampton and the Better Regulation agendas, is now prime minister. This may mean that DBERR and the BRE will have the political clout to drive an agenda for change and force the HSE to think and implement the previously unthinkable. If this does happen, it must be in order to secure genuine improvements in health and safety standards in SMEs, rather than minor red-tape adjustments that garner headline coverage for a few days and then sink without trace, leaving employers and their workers no better off.
1 Department for Business Enterprise and Regulatory Reform (2007), “Improving outcomes from health and safety: a call for evidence”, responses by email to Ben Davison, tel: 020 7215 0278.
Howard Fidderman is a freelance journalist and editor of HSB.
Box 1: The DBERR review terms of reference “To deliver strong regulatory outcomes in a modern working environment while minimising the burden on business and maintaining the confidence of society, the review should:
|
Box 2: The HSE simplification plan The HSC launched the HSC/E’s second “simplification plan” on 3 December 2007. The HSC’s chair, Judith Hackitt, said that the aims of the plan are “to reduce paperwork … but not to reduce levels of protection”. The plan, she said, should make it easier for all businesses to know what’s required to comply with regulations. The plan has proved controversial within the HSC/E. Although there is no disagreement about the desirability of cutting unnecessary red tape, the target of a 25% reduction by 2010 is seen as arbitrary and open to interpretation as deregulation, not better regulation. The calculation of the £2.03 billion baseline annual costs and the estimated annual savings of £508 million that would arise from a 25% cut are, by the HSC/E’s admission, “not statistically robust”. The 2007 plan demonstrates the progress that has been made on the 2006 plan and includes new simplification projects to demonstrate how the 25% reduction will be delivered. The new initiatives are: looking at opportunities with the Department for Communities and Local Government for integrating the planning and building control regimes with the Construction (Design and Management) Regulations 2007; reviewing the overlap in the requirement for a written policy and a written record of health and safety arrangements; clarifying the requirement in the Manual Handling Regulations 1992 to make sure that workers are aware of the weight of loads and reduce unnecessary or duplicate labelling; and new or revised guidance to clarify the need to label where a water supply is not for drinking rather than simply labelling all drinking water. The major initiatives from the 2006 plan, which are still ongoing, are: sensible risk management (which at a saving of £200 million dwarfs other savings); three projects to reduce the number and burden of HSE forms; new guidance to clarify thorough inspection requirements for lifting operations and equipment; simplification of the process for checking contractors’ competence and consolidation of legislation; and revised guidance on hazardous substances that focuses on “how to” information for employees. Changes in the seventh major area of the 2006 plan – the requirement to display the health and safety poster in all workplaces – were agreed at the HSC meeting on 11 December 2007: instead of scrapping the requirement to display the poster, which had been one suggestion, the HSC has decided to opt for amending Regulations that would allow the poster to be changed significantly and on an ongoing basis without recourse to further legislation. |
Box 3: HSE example risk assessments The HSE is producing a series of “example risk assessments” targeted at SMEs in six sectors that contain 70% of all businesses (retail, wholesale, hotel and catering, transport, motor trade, property and business services). The HSE believes that the project will “help SMEs understand what a ‘good enough’ risk assessment looks like”. The HSC and HSE announced the project on 25 July 2007. The HSE estimates that SMEs spend an average of 14 hours a year on risk assessment requirements, and hopes that this will fall to fewer than 10 hours for firms that use the example assessments. The sample assessments include those for an office, car-repair garage, warehouse, contract bricklayer, convenience store/newsagent, estate agent, general office-cleaning contractor, dry cleaner, hairdresser, cold-storage warehouse, and caterer. |
Box 4: UK’s changing industrial base The DBERR consultation document starkly depicts the changing nature of the UK’s industrial base between 1978 and 2006. In (very) round terms, in the five main sectors enforced by the HSE, the number of jobs in:
During the same period, the number of jobs in the four main sectors enforced by LAs has:
|
Box 5: Better local regulation The draft Regulatory Enforcement and Sanctions Bill would establish a Local Better Regulation Office (LBRO), which would be charged with ensuring LAs exercise their functions effectively, appropriately and without giving rise to “unnecessary burdens”. The office will be able to provide guidance, financial support and assistance to LAs. It will also be required to prepare a list of priorities that LAs should provide resources for. The government does not specify how this links to the Rogers review of LA regulatory priorities, which recommended that health and safety be one of the top five. The Bill also provides for a “primary authority” (PA) where an employer carries on activities in more than one LA. If an employer has an agreement with a PA, another LA cannot take enforcement action against that employer in its own area without the consent of either the PA or the LRBO, unless there is an imminent risk of serious harm to health or the environment. The government advises that, following consultation over summer 2007, it is pressing ahead with the legislation. |
BOX 6: DBERR’s Top 10 questions DBERR asks for evidence in relation to 10 main questions: General issues 1. Do you believe the British health and safety system achieves the right balance between protecting workers, and the demands it places on employers and others? 2. Are legal duties applying to the charitable and voluntary sectors sufficiently clear to support charitable and voluntary activities while protecting the people affected by them? Perceptions 3. Do you think the way the health and safety system is perceived by employers, workers and the wider public in Britain has a significant impact, eg on accident rates or on the way employers act? Drivers 4. How can good health and safety management best be encouraged and recognised? 5. Do you believe fear of compensation claims has any influence on the way in which health and safety is managed? If so, how? Information and advice 6. What more, if anything, do you believe government should do to ensure employers have access to affordable, authoritative information and advice on health and safety? Health and emerging risks 7. How can regulators best ensure that employers minimise ill health that is caused or made worse by work? 8. (Question for specialists) Do you feel that regulators’ targeting methods adequately reflect the risks of work in terms of ill health, as well as injury? Impact of regulatory structures on outcomes 9. What improvements could be made to help HSE and local authority inspectors target rogue employers? 10. (Question for specialists) Could further flexibility in whether the HSE or a local authority regulates in a particular case improve outcomes? |
