The HSE's health and safety strategy

The HSE has published the final version of its new strategy for the health and safety of Great Britain¹. The strategy embraces all organisations and individuals involved in health and safety, not just the regulators, and, in essence, will pursue a "common-sense" approach to reducing the toll of work-related injuries and ill health.

On this page:
Strategy goals remain the same
The end of health and safety targeting
HSE free to intervene
Absence caused by stress
New strategy breaks little new ground
Strategy implementation
Box 1: From draft to final strategy
Box 2: The strategic goals
Box 3: Enforcement weakening?.

The strategy replaces the previous, somewhat optimistically titled strategy that has been in place since 2004, A strategy for workplace health and safety in Great Britain to 2010 and beyond, and follows an extensive consultation on a draft strategy. A different colour than adorned the draft text and a small number of minor changes aside (see box 1), the draft and final documents are to all intents and purposes identical in nearly every respect. This is hardly surprising: as we remarked at the consultation stage, the document read and looked like the finished article. The consultation process, says HSE Board chair Judith Hackitt, "evinced widespread support" from all stakeholders for the HSE's approach, although she may be over-egging the pudding when she claims the responses have enabled the HSE "to fine-tune the strategy to take account of the views expressed".

In this feature, we do not propose to review the whole strategy in detail because to do so would merely replicate our review of the consultation text - the two documents are the same length, share the same headings and say the same things. Instead, we will examine the most interesting themes and the limited changes that have been made (see box 1), and offer our own view of what it might all add up to.

Strategy goals remain the same

The strategy's 10 "goals" remain the same (see box 2). Of the 10, the only one where the detail has changed from the draft text to any degree concerns the issue of "building competence". While the final version restates the legislative requirement to have at least one competent person in each organisation, it now goes further, advising that:

• "legislative compliance should be regarded as the minimum acceptable standard. Truly effective health and safety management requires competency across every facet of an organisation and through each level of the workforce";
• competence is "the ability of every director, manager and worker to recognise [formerly "profile"] the risks in operational activities and then apply the right measures to control and manage those risks";
• there is a need for health and safety training to place greater emphasis on coaching so that directors, line managers and workers alike are able to determine what is sensible and reasonable; and
• the education system must "embed the basic understanding of risk as a life skill so that young people joining the workforce are more risk aware".

Underpinning much of the above is the HSE's belief that training in "soft skills", including the confidence to assess situations and take decisions (as opposed to detailed safety knowledge), will prove vital.

The end of health and safety targeting

The early years of the Labour government elected in 1997 saw an obsession with targets and tables that has often come back to haunt the administration. Health and safety did not escape New Labour's preoccupation with measuring, most notably with the three injury, ill health and absence targets set out in the government's and the then HSC's 2000 Revitalising health and safety strategy.

The new strategy is noticeably light on specific targets, stating only - in an addition from the draft strategy - that: "We will measure and report our progress, but we should be clear that we will be measuring the success of our collective efforts not just the role of the regulator." At the conference launching the strategy, Hackitt was unable to expand on measurement, beyond referring only to the fact that the HSE already had targets (notably those set out in its Public Service Agreement and Revitalising). Although it will not say this explicitly, the government appears to be recognising the folly of placing targets on the HSE and local authorities, when they have limited ability to sway progress towards those targets.

Like the consultation text, the final strategy implicitly questions the basis of two of the three Revitalising targets, advising that the setting of targets with regard to ill health is "complex" because of long latencies and the fact that it can be exacerbated by non-work-related factors. The HSE's chief executive, Geoffrey Podger, appeared to anticipate such a move in autumn 2008 when he told a LexisNexis conference²: "I don't regard self-declared views as to people being (a) ill and (b) that it was attributable to work as a very sound basis for determining policy. So I think we have to recognise this is an area where the statistical base is rather dubious, that there are genuine difficulties in distinguishing the categories of ill health that people suffer from."

What this will add up to is not yet clear; the best guess is that most new targets will be set on the basis of sector, subsector or location, with greater emphasis on the specific issues that affect individual sectors. There may also be more focus on inputs and outputs, such as investment in training and the numbers of staff completing training. The big, all-embracing campaigns such as Fit 3 appear to be a thing of the past. One problem with Fit 3 - and it did enjoy limited successes - was that inspection against national priorities and targets had little relevance to what inspectors were finding on the ground.

HSE free to intervene

A departure from such all-embracing targets would free up the HSE to intervene as it best sees fit. And indeed the strategy confirms the HSE's welcome intention to target its resources where it can get the best returns - in effect, on its core business. The HSE will identify activities within these priority areas that can "deliver a significant reduction in the rate and number of deaths and accidents". Pledges like this, however, are best looked at in the negative: if this is supposed to represent a change, why was the HSE ever engaged in targeting resources where it would not obtain the best returns? Part of the answer may be that it has spent a large amount of time pursuing government-driven Revitalising and other types of targets that many of its policy people believed pointless in the first place and founded on poor data.

For example, the easiest answer to parliamentary criticism of falling inspection numbers would be to introduce single-topic inspections, increasing the count but not necessarily the impact. Or a pursuit of stress might, in theory, be a good way of reducing the incidence of ill health and absence - two of the Revitalising targets - but it might also divert resources from issues that can result in more serious outcomes, for example the use of chemicals at work - fewer days lost, admittedly, but far more serious health problems.

It is disappointing, then, that enforcement of work-related road safety - where the potential reductions in injuries are greater than any other occupational area - remains as low on the HSE's agenda as it has been in recent years. This, though, is partly the result of the HSE struggling to cope with what it already does, let alone move out of the workplace onto the road (other than where the road is a place of work). It is also an implicit acknowledgment that if statistics are not compiled in the first place - and RIDDOR does not cover most work-related road-traffic accidents - there can be no political recognition of any HSE role in reducing the toll.

In terms of occupational health, "best returns" are likely to mean targeting key health issues that are directly attributable to the workplace, rather than issues such as rehabilitation and welfare. Recent years have seen significant attention paid to asbestos and, more recently still, silica. But the immediate future should also see occupational cancers more generally climb up the agenda, particularly with the acceptance that the official annual death toll is significantly higher than the 6,000 deaths a year that has been the accepted estimate for the past 25 years - some estimates now put the total at between 12,000 and 24,000.

Absence caused by stress

Quite where this leaves the issue of stress, with its multiple work and non-work causes, is unclear, although Podger again has given a clue: "One thing I think that is very clear," he told the same LexisNexis conference, "is that we in the HSE have been rather ambitious in trying to intervene in issues [around] work-related ill health. While there's clearly much we can do in relation to issues which have their specific origin in the workplace ... there are many issues which are extremely difficult to disentangle, for instance as to whether stress [problems] are really of workplace origin or whether they are related to people's domestic or personal circumstances or ... to some combination of the two."

Given the HSE's belief that stress is one of the two major causes of work-related sickness absence in the UK (although this is not a perception shared throughout the world) and its massive investment and backing for its stress management standards, it is hard to envisage the HSE pulling out of this area altogether. The most likely scenario would encompass increased collaborative working with other agencies, particularly the Health, Work and Well-being Directorate within the Department for Work and Pensions, as well as private sector organisations, backed by the knowledge that the guidance and tools that are now available for stress are more than fit for purpose. This would allow the HSE to maintain stress as a priority without drawing too heavily on its resources.

New strategy breaks little new ground

The new strategy is not, however, an ambitious blueprint in the way that Revitalising was. There is very little here for which the HSE can be held accountable. In fact, it reads more as if it were written for the non-specialist rather than the safety practitioner. But, of course, that may be the whole point of the document.

The HSE claims the strategy is "resetting the direction" for workplace health and safety. On close examination, this does not hold up; it is much closer to the HSE's other strapline of "evolution, not revolution", with most of the goals in the 2009 strategy present in the 2004 strategy - in one form or another. The call to focus on the HSE's core business, for example, was made with equal vehemence in 2004: one of its strategic themes was described as "focusing on our core business and the right interventions where we are best placed to reduce workplace injury and ill health".

In particular, there is little in the HSE's claim that the strategy breaks new ground in going beyond the regulators: "This is a strategy for the health and safety system ... the HSE or [local authorities] cannot do this solely through their own actions. This strategy confirms our intention to understand and value more the contribution of others to improving health and safety - not just employers but everyone, including workers, their representative organisations and professional bodies." This is, in fact, a quote from the 2004 strategy, not the 2009 version. The 2004 strategy even set out its vision of "how stakeholders will behave in a new health and safety system". The difference between then and now is likely to lie in the insistence with which the HSE embraces such "stakeholders".

Hackitt told HSB at the launch of the consultation for the new strategy that its 2004 predecessor, while a success overall, had failed sufficiently to engage other people; its messages had not permeated through organisations and there was a need for more industry sectors to become involved.

Strategy implementation

With the new strategy done and dusted, attention will now shift to its implementation. Hackitt said that the HSE intends to publish the strategy's delivery plan soon after the launch, although much of the work is already well under way (see, for example our feature on participation). The question, as ever, is can the HSE and the health and safety system deliver? Several organisations were quick to announce what they were prepared do to help implement the strategy, but closer examination reveals that these announcements often amount to just a repackaging of existing initiatives (and commercial expediency).

And, although the HSE is correct to posit a strategy that embraces everyone, the regulator will still have to show the way - both to local authorities and the health and safety system as a whole. The good news here is the clear resolve of the HSE and its board to make a difference (see HSE offers guidance "free for all"). There will be a welcome focus on the involvement of workers and their representatives, allied to a much needed investment in training, as well as greater emphasis on the more serious injuries and diseases rather than an obsession with nebulous and all-embracing targets. On the downside, however, there are real concerns about the HSE's ability to deliver, given the loss of all but 10 or so of its 300 London-based policy staff; however successful the recruitment of their replacements turns out to be, the loss of what are literally thousands of years of expertise can only damage the organisation in the short term. Further, inspector numbers, while better than they have been for a while, are still significantly below where they once were; and resources are a perennial problem that is likely only to worsen as the recession places limits on the public purse. Local authority regulators face similar problems. The new strategy, in particular, has nothing to say on enforcement that will change anything in what is a deteriorating and unacceptable situation (see box 3).

Most of all, however, the HSE needs unequivocal backing from the government. While the early years of New Labour delivered some of the policy and commitment on health and safety that it had promised in opposition, more recent years have seen an increasingly pro-business and anti-regulatory agenda, backed by a cut in resources for the HSE and a dangerous flirtation with what has sometimes seemed like an acceptance of health and safety "myths" and a compensation culture. In this respect, it was encouraging to see James Purnell, the secretary of state for work and pensions (who was to resign from his post the next day), and Lord McKenzie, the under-secretary of state with responsibility for health and safety, attend the launch. Said Purnell: "Amidst ridiculous myths about banning donkey rides and flip flops, the fact its that too many people are still needlessly killed or injured ... We need to do everything we can to drive down the toll of death and injury."

1. HSE (2009), "The health and safety of Great Britain. Be part of the solution (PDF format, 634K)" (external website), 06/09 C100. The draft version (PDF format, 196K) (external website) has the same title.

2. Second annual Health & Safety at Work conference, International Institute of Risk Management, Birmingham, 5 November 2008.