HSE reporting services restructured
Human contact is the latest casualty of cuts in the HSE's funding, reports Howard Fidderman.
On this page:
Box 1: HSE resources
HSE procurement tender cancelled
Box 2: Connaught Compliance and Santia
Reporting RIDDORs
Incident Contact Centre reports
Infoline - "a basic service"?
Health and safety referral issues
Impact on non-English speakers
Box 3: Different languages
Internet access issues
Online provision emphasised
HSE's current position
Provision is not practice
Table 1: Means of reporting RIDDOR incidents, June-August 2010.
September 2011 will see major changes to how employers seek health and safety information from the HSE and to how they report incidents under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR).
As a result of the changes:
- the HSE's Infoline telephone service, which offers advice on workplace health and safety, will cease on 30 September, with its more than 250,000 users each year being advised instead to turn to the HSE's website; and
- from 12 September, employers will have only one means - online - of notifying the HSE of over-three-day injuries (which the HSE has separately proposed will become over-seven-day injuries from either October this year or April 2012), diseases and dangerous occurrences. They will, however, retain the option of being able to notify the HSE of fatal and major injuries by phone.
The changes are the latest that the HSE has implemented to help offset the four-year 35% reduction in its funding from April 2011 (see box 1), although the HSE's director of communications, Sally Sykes, told HSB that the HSE's strategy is, in any case, to make "increasing use of intuitive web-based material" and that the changes were therefore, in part, "a natural solution" to the need to make savings.
An HSE spokesperson told HSB that the decision not to renew the Infoline and Incident Contact Centre (ICC) contracts with Santia, which until recently was known as Connaught Compliance (see box 2), is "expected to save the HSE £7 million over five years. Like every part of government, the HSE is improving efficiency and delivering value for money to the taxpayer." The spokesperson added that the £7 million saving "represents the cost of the new delivery model compared to the existing service".
Box 1: HSE resources The table below shows the cut in the HSE's funding from government ("net resource departmental expenditure limit") from £227.7 million in 2009/10 to £198.7 million in 20011/12. Net capital, which is capital expenditure offset by capital sales, is also being cut. Interestingly, while the HSE is talking about increasing its "income" from other sources (advice, charging regimes etc) to help make up for this drop, "income" is actually projected to decrease by £5 million between 2010/11 and 2011/12. This means that about one-third of the overall £14.3 million decrease in HSE funds between 2010/11 and 2011/12 will be caused by a drop in "income" (which currently accrues largely from charging regimes in the higher-hazard sectors and publications) and two-thirds by cuts in government funding. The HSE expects, however, that "income" will increase from the 2012/13 budget onwards once its plans to charge employers for more of its services start to take effect. The net resource fell by almost twice as much between 2009/10 and 2010/11 - before the HSE's grant was cut - as the decrease projected for the current year, which is the first year of the cuts. The HSE attributes this to several factors, including the introduction by the incoming coalition Government of reductions in spending and strict controls on certain types of expenditure, for example consultants. In addition, the HSE tried to reduce its financial risk and minimise disruption to frontline programmes by making economies and efficiencies early (200 staff, for example, left under the Voluntary Exit Scheme in February 2011).
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HSE procurement tender cancelled
The HSE's announcement brings to an end a process that saw it first invite tenders to run a new service but then, just months later, cancel the process when its looming financial predicament became clearer. In early 2010, the HSE sought "expressions of interest" in replacing and combining Infoline and the ICC - an "opportunity", it said, that arose "from the expiry of existing contracts and a desire to build on the success of the existing services". The Infoline contract had been due to end on 30 September 2011; the ICC contract ended on 31 March 2011 but was extended by the HSE pending its decision on a replacement.
Organisations had to return a prequalification form by 28 April 2010, after which the HSE had intended to draw up a shortlist and announce the winner in December 2010, with the service starting up on 1 October 2011 for an initial three years. On 7 October 2010, however, the HSE informed the 23 interested companies that it was scrapping the process. The HSE's chief executive, Geoffrey Podger, elaborated on the reasons in his monthly report (PDF format, 240K) (external website) to the HSE Board meeting on 27 October 2010: "In response to the Government's stated commitment to review all public expenditure, the HSE has taken the decision to cancel the procurement tender exercise and develop an alternative, predominantly web-based, delivery model instead." An HSE spokesperson subsequently told HSB: "The changes have not been prompted by any issue with the Infoline service and the quality of information given."
Box 2: Connaught Compliance and Santia The future of the HSE's Infoline service was also questioned after Connaught plc went into administration on 8 September 2010. Connaught Compliance, which was one of Connaught plc's three main operating businesses, runs Infoline, the Incident Contact Centre and the Gas Safety Advice Line (the future of which the HSE will also review). Connaught Compliance subsequently changed its name to Santia (external website). The HSE's deputy chief executive, Kevin Myers, reassured the HSE Board meeting (PDF format, 257K) (external website) on 29 September 2010 that the services were not threatened because Connaught Compliance itself was not in administration, continued to trade normally and its services to the HSE were "not disrupted in any way". The division's CEO had provided written assurances and KPMG, the administrators of the plc, had issued a public statement that Connaught Compliance was not in administration. |
Reporting RIDDORs
Although some employers may have preferred to continue to use the phone, email, post or fax to notify the HSE of over-three-day injuries, the limiting of the procedure to the website should not prove overly problematic given a majority of reports are already made online. The HSE has also addressed the most obvious stumbling block by allowing dutyholders the option of continuing to report fatal and major injuries by phone if they prefer. "People reporting a traumatic event still need that personal interaction," explains the HSE's director of strategy, Trevor Carlile.
Sally Sykes advises that the HSE will use an "internal" solution to handle the telephone reports, although it has yet to decide whether this will be through its own staff - possibly along lines similar to how it handles complaints - or in some shared government-operated telephone-handling service. The call centre taking the telephone reports will, the HSE advises, continue to be known as the Incident Contact Centre (ICC).
The HSE acknowledges that the move to online reporting "will enable HSE to make significant efficiencies" but "will also allow businesses to easily and conveniently report incidents". The seven new reporting forms "will be intuitive and interactive, with a help facility available to support businesses in making reports". Sykes also emphasises that the changes are to the "front end" of the service; the procedures for referring reports of injuries for consideration of further action will operate as they do currently.
Incident Contact Centre reports
The ICC handles about 225,000 reports a year; the percentage of reports made online has increased steadily year-on-year, from 21% in 2004 to 55% in 2010. The other means of reporting in 2010 were:
- phone (19%);
- email (15%);
- post (8%); and
- fax (2%).
These percentages mean that if email reports are added to the web reports - and they are, after all, an indication that the sender is capable of electronic communication - then seven in 10 RIDDOR reports are already sent electronically.
The picture is more complicated if broken down into the types of incident reported. Table 1 offers a "snapshot" provided by the HSE to HSB of all 47,348 reports made to the ICC under RIDDOR in the three months to 31 August 2010 (the work is not done routinely). HSB's analysis of the table shows:
- the website is already the most popular way of reporting major and over-three-day injuries (57% and 59% of all reports);
- the telephone is the most popular method of reporting a fatality (39%), with the website close behind on 32%; and
- the reporting incidents for which the HSE is likely to experience the greatest problems shifting to a web-only service are diseases and dangerous occurrences, where currently only 20% of reports are made online.
The issue of dangerous occurrences has also been highlighted by the construction union UCATT. Accepting "it may be appropriate that accidents are recorded online," the union argues: "This is not the case for the reporting of dangerous incidents. While it is employers who report accidents, it is workers and the general public who need to report dangerous working practices."
Workers, the union argues, need to be able to report dangerous working practices without the fear of reprisals or victimisation, which requires "an easily accessible method to ensure that concerns about a dangerous issue can be raised in the knowledge that a worker cannot be identified". The union implies that workers are less likely to be identified by their employers if they use a mobile phone rather than the internet, and adds: "While the vast majority of workers have access to a mobile phone, far fewer have access to email and internet. Also workers are far more likely to report an incident shortly after witnessing it rather than waiting until later, especially if they are concerned that an email could be traced back to them."
Infoline - "a basic service"?
Of the two changes, the scrapping of Infoline is likely to prove the more problematic for employers. The HSE insists there is no downside to the change, describing Infoline as a "basic information service to callers" that "never offered a tailored advice service for businesses - it only ever provided basic information publically available and searchable on the HSE website". An HSE spokesperson told HSB: "As the website is the key resource for Infoline answering queries, we don't anticipate anything being lost in web information provision. The website is continually updated and developed."
The HSE contrasts Infoline with its website, which it describes as "a huge knowledge bank where people can access and download information free of charge and use interactive web tools". The website receives 26 million visits a year and is, claims the HSE, "already overwhelmingly the most popular option for accessing health and safety information, with 100 times more visitors than Infoline has callers". Users, advises the HSE, are also satisfied with the web service, with 93% of users rating it as "very good" or "good".
The HSE's confidence further stems from the belief that its online provision is stronger than ever, with recent additions including risk-assessment tools for low-risk organisations and new guidance - "Health and safety made simple" - for small and low-risk businesses, as well as "expanded frequently asked questions to answer common queries".
The HSE adds that it provides information and guidance in other ways, including directly with organisations and trade associations, face-to-face at workshops and safety training days, and via books and e-bulletins. The HSE also offers advice through the Government's website for businesses, Business Link (external website).
Health and safety referral issues
The HSE is attempting to deflect requests for information in areas that it does not enforce to other regulators and sources of advice. In some ways, this emanates from its aim of encouraging others to play a greater role within the health and safety system in line with its 2009 strategy, The health and safety of Great Britain. Be part of the solution. This recognised that the HSE cannot do everything and is increasingly having to concentrate on its core work and statutory responsibilities.
Thus, as part of its justification for a web-only information service, the HSE states: "A significant proportion of calls to Infoline are also currently on non-HSE-related issues. On average, one in eight questions raised falls within this category." The website goes on to advise: "If you can't find any information related to your query it might be that it is not an area that HSE is responsible for. Check our new 'What HSE does and doesn't do' section to find out."
Aside from the observation that, by implication, seven calls in eight do concern HSE-related issues, what is important here is the use of "non-HSE-related" rather than "non-health and safety-related". While it is easy to understand the HSE's motivation for this stance, it ignores the fact that most callers just want help with health and safety and do not care a jot whether they are HSE- or local authority (LA)-enforced. Having to click through to find a different regulator will only deter some employers from pursuing their enquiry. A "single point of contact", as the HSE itself had once promised the new service would be, is what employers want.
Referring individuals to LAs for health and safety advice is not without problems, either. There are vast variations in the approaches adopted by the 400 or so LAs and they are not geared up in the same uniform way as the HSE to provide advice; councils are already under tremendous budgetary pressures and health and safety often plays second fiddle to more pressing concerns such as food safety. It can also be very difficult to locate and then speak to a council officer. Sykes says that while the HSE wants to improve the advice and guidance that LAs offer, she is "confident" they provide the information that is needed in the areas that they enforce. In terms of the cuts, Sykes adds, LAs have to manage their workloads and resources, as do the HSE and all government departments.
The website also offers an early indication of how the HSE intends to exploit the new Occupational Safety and Health Consultants Register, advising "if you can find information related to your query on the HSE website, but feel you need further specialist advice tailored to your circumstances, there are other, commercial health and safety advice phone services available, or another option is to approach a health and safety consultant" using the new register of "qualified, reputable health and safety consultants".
Impact on non-English speakers
There are questions too about the impact of the withdrawal of Infoline on the HSE's attempts to reach workers who speak no, or limited, English. Infoline currently offers a telephone interpreting service in 100 or more languages: call Infoline, advises the HSE's webpage, and the operator will "arrange for an interpreter to be connected into the telephone line within a minute or so" (see box 3).
When it first announced the tendering process in early 2010, the HSE boasted the new combined advice and reporting service would be "multichannel, multilingual ... [and] provide a high-quality single point of contact". With the new in-house provision, however, there is no such commitment. Sykes told HSB that the HSE "intends to keep a degree of language coverage", including meeting the statutory requirements covering Welsh. Language barriers, added Sykes, are an issue that the HSE "will be mindful of" when making the transition, although it has not yet reached any conclusions. She adds that the HSE is particularly aware of the needs of vulnerable workers and that they can also use the Pay and Work Rights Helpline (external website).
Box 3: Different languages The HSE's website has a section dedicated to advice in languages other than English. It offers downloadable versions of guidance in 30 different languages (external website), with between one and six publications in each language. These usually include general and topic-specific advice. The section also links to advice on an interpreting service (external website) that is contactable through Infoline: "If you would like to speak to someone about health and safety in a language other than English:
"It is HSE's aim to serve every part of our community and our telephone interpreting service covers over 100 different languages, so all you need to do is to tell Infoline which language you would like to speak and the operator will do the rest. "Depending on the nature of the information you are looking for, Infoline will endeavour either to answer your query directly or forward it to the appropriate part of HSE for a reply. Whatever your preferred language of use, we are here to help so please do take advantage of the service we offer." |
Internet access issues
The HSE dismisses fears about employers that do not have access to the internet: "Internet access is available in thousands of libraries and other public buildings and there are government plans under consideration to offer a network of assisted digital providers such as post offices, libraries and online centres providing access to the web." Clearly, the absence of internet access is less of a problem than it would have been 10 years ago and will decline further over the coming years, although it may still prove a particular issue for some groups, for example non-office-based workers wishing to report a dangerous occurrence.
Suggesting, however, that employers could go to a public library to report an over-three-day injury or seek out information seems faintly ridiculous (and decreasingly viable as public libraries face closures nationwide). Asked whether or not she really thought a small or medium-sized firm would visit a public library, Sykes points out that the HSE cited libraries as just one example of its efforts to make sure that employers without internet access could make use of the HSE's website. She also points out that businesses now carry out many standard interactions with government - on tax, for example - online.
Online provision emphasised
The move to a web-only information service also contradicts a reassurance that the HSE gave to HSB following its chief executive's report to the HSE Board in October 2010. When we raised concerns at the time about the implications of reducing the personal advice currently provided by Infoline, and asked about the extent of the telephone service that would be provided, an HSE spokesperson replied on 9 November 2010: "It is not possible to give a percentage but a telephone service will be maintained to make sure that HSE is able to receive calls for information and guidance from customers who are unable to access web-based services."
Given there will now be no telephone service from September, we asked Sally Sykes what had changed in the interim. First, she said, the Government published a strategy for citizen- and business-facing services that emphasises the role of online provision. Second, research into the information sought by callers showed many of the requests were straightforward - the address of a local HSE office, for example - and could be addressed with clearer signposting. Third, as we note above, not all the calls are HSE-related in any case. And finally, the interface with the Government's Business Link service has improved such that the advice is now the same as on the HSE's website.
Sykes adds, however, that there will still be access to specialist advice in some complex and technical areas, for example asbestos. A telephone number will be displayed on some of the subject pages, and the call handler will be able to put the caller in touch with specialist staff. She emphasises, however, that this service will be limited to complex enquiries that have exhausted the available online advice.
HSE's current position
We would summarise the HSE's position as essentially:
- resources are limited and need to be allocated where they secure the best returns;
- Infoline staff only ever gave out information that was already freely available on the HSE's website (a questionable assertion even now and one that could not have been the case until March 2010 when the HSE made all its guidance freely available);
- the website has improved, and is continuing to improve, such that it can cover all bases; and
- web-based provision is the way we live now.
To a significant degree, and for a regulator that faces huge cuts, this approach makes sense. The misgivings we have arise in part from the impression that some of the implications - for workers who do not understand English and the reporting of dangerous occurrences, for example - do not appear to have been fully thought through, and in part from the feeling that the HSE is over-stating its confidence. Some things will be lost as a result of this change and it is delusional to pretend otherwise; it was only six months ago that the HSE accepted that a web-based service still needed some telephone contact, and a few months before that it was extolling the virtues of a one-stop shop, while the HSE's own website still states that the HSE "recognise[s] that HSE's Infoline is an essential part of our business". A less strident approach that acknowledged the potential pitfalls of the changes would have been preferable.
Provision is not practice
The overriding reason why the HSE's optimism may be partially misplaced, however, is that provision is not an automatic precursor of practice: the mere fact that the information is available on the website does not mean that employers and others will be able to find it or, if they do find it, understand and make use of it. Taking the HSE at its word that all the information was already publicly available, 236,000 individuals last year still felt the need to telephone HSE Infoline for help, and a further 50,000 wrote in.
Acknowledging that provision does not automatically result in appropriate use, Sykes says that it is the "onus of the provider" to make the information as easy to understand as possible. The HSE's advice, she points out, is subject to robust testing. The HSE is also improving the search facility for its website: a new mechanism, for example, will allow complete pdf searching, starting with the top 25% of the HSE's guidance. An HSE spokesperson added that: "Topic pages are being revised and improved to make them as easy to navigate and as helpful as possible. Recent examples of the improvements are the revamped construction and woodworking pages."
Small firms in particular find the mass of health and safety information daunting and prefer personalised and tailored help. Sykes accepts this preference is a "difficult thing" but points out that no regulator can offer individual advice on such a level and that the website with all its additions and improvements - many of which are targeted at small firms - will be "good enough". She adds too that the use of the web has probably reached a "tipping" point where the norm when looking for help is to search the web. In all this, she is correct, as is the HSE in its claim that its website is of a high quality. Nor would we want to pretend that Infoline was a perfect service. The issue, however, will be whether or not employers - particularly those without any health and safety expertise - are able first to find that information and then to act on it.
Howard Fidderman is a freelance journalist and editor of HSB.
Table 1: Means of reporting RIDDOR incidents, June-August 2010 |
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Fatal injury1 |
Major injury |
Over-three-day injury |
Member of public |
Diseases and dangerous occurrences |
Fax |
30 |
126 |
425 |
297 |
50 |
Post |
15 |
507 |
1,792 |
1,114 |
209 |
33 |
795 |
3,959 |
2,036 |
100 |
|
HSE email |
3 |
126 |
501 |
192 |
14 |
Phone |
109 |
1,377 |
3,377 |
3,378 |
711 |
Web |
90 |
3,937 |
14,404 |
7,372 |
269 |
Total |
280 |
6,868 |
24,458 |
14,389 |
1,353 |
% reported via web |
32 |
57 |
59 |
51 |
20 |
% reported via web and email |
45 |
71 |
77 |
67 |
28 |
1. The 280 fatal injuries is the total notified to the ICC and includes those that subsequently turned out not to be RIDDOR-reportable. The HSE advises that further analysis shows that only 93 of the 280 fatalities were RIDDOR-reportable and that not all of these will end up in the final total. (Otherwise, the three-month figures would indicate that 2010/11 was the worst year for fatalities for many years, which it is not.) Source: The first six rows of statistics in the table are kindly supplied by the HSE. The last three rows are HSB's own calculations. |
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