Inspection of Multi-site Organisations

In 1995, the HSE has set up special inspection arrangements for ‘multi-site organisation’.

This is known as a system involving a ‘Lead Principal Inspector’

This is set out in an operational circular called the ‘Role of the Lead PI’

This page summarises the key points of this operational circular, but you can download it by clicking here.

The lead PI system does raise two issues of concern:

Reason for the Lead PI
Para 2 of the Operational circular states:

FOD needs to be able to co-ordinate its inspection effort at multi-site organisations. Currently FOD inspects national and regional organisations largely on an area basis. We do not know whether too much or too little attention is being paid to an employer overall, or whether the same advice is being repeated (in place and time) at various sites throughout the country. This concern was raised in the Impact Report and has since been reinforced by the National Audit Office (NAO) statement about the need for consistency, and the Review of Regulation conclusions that HSE needs to demonstrate consistency, transparency and proportionality. FOD proposes to meet these concerns by establishing a lead PI system.

It states at para 4 that the lead PI will:

The lead PI will be required to draw up an inspection plan for selected multi-site organisations, in conjunction with other interested parties. The plan will be binding, but there will be defined circumstances when the plan may be departed from. The plan should cover at least a rolling 3-year period and should identify the sites that will be visited and the key topics and issues that are to be assessed and the order in which they are to be dealt with.

Selection of organisations

Para 6 states:

An essential starting point will be to obtain accurate information about organisations' structures, activities and locations. This should help determine the appropriate level of the organisation at which to intervene and give some idea of the possible size and complexity of the intervention. Depending on the way the organisation is structured and run, it may be appropriate to establish a lead PI for the whole organisation, for an operating company or division, or for a regional unit. At the same time, information concerning the organisation's performance and hazard profile will need to be collated from a variety of sources (e.g.. internally, from SHIELD/FOCUS and local (FOD) opinion, and externally from company annual reports) to help determine priorities when making selections.

Content of the plan

Para 12 states:

The plan should identify the topics which are to be assessed, which sites are to be inspected and the timetable for inspection. The underlying philosophy, based upon the sector plan should be to target key risk areas and to make the most effective use of resources. This may mean that no inspection is planned for some sites in some years of the 3-year cycle (except in the circumstances laid down in para 18). Additional guidance is provided in the Guide.

Liaison with the organisation

Para 15 states

When the plan has been drawn up, the lead PI may liaise with the organisation and inform them of HSE's planned programme of inspection. Where the plan involves any significant withdrawal from inspection of parts of the organisation's sites, the organisation and its employees should be informed. If it is appropriate, the organisation's views may be sought about the contents of the plan. Although it is important to ensure that HSE retains the right to inspect as and when it considers appropriate, some modifications (for example to timing) which assist the organisation and ensure greater co-operation may be appropriate. Further, some organisations may be in a better position than HSE to identify their areas of weakness and if the organisation is cooperative the lead PI may wish to consider inviting their views at the planning stage.

Adhering to the plan

Para 18 states:

It is important to ensure that the plan is followed by all the interested parties; a departure without good reason would render HSE liable to criticism. There are, however, certain circumstances where it would not be appropriate to adhere rigidly to the plan, for example in the event of a major incident. The lead PI and the other interested parties should agree the circumstances which warrant departure from the plan and these should be recorded and included as part of the plan.

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