|
Inspection
of Police Training Activities
HSE’s "Operational Circular" gives
advice to inspectors on the following areas. Click
on the subjects below
- Self defence training
- Public Order Training
- Firearms training
Back
to main page on police
Self-defence training
| 45
|
Self-defence,
arrest and restraint training is delivered by
forces using standard ACPO guidance manuals: handcuffing,
unarmed defensive tactics, knife awareness, baton
training and use of CS aerosol spray. The DFP
Unit has copies of the first four manuals listed. |
Public order training
| 46 |
Public
order training is carried out by each force, using
suitable training facilities, to the guidelines
set out in the NPT document Safe Systems of Work
- Public Order Training (FOD subject file 334),
which was produced in consultation with HSE. Officers
are grouped into police support units (PSUs),
and are provided with flame-resistant overalls,
enclosed ‘NATO’ helmets with visors,
and polycarbonate shields for this training. |
| 47 |
The
normal crowd control scenarios involve the throwing
of petrol bombs and wooden blocks (to simulate
bricks) by volunteers who may not all be police
service employees. The training may also require
officers to work alongside horse mounted units,
which introduces additional risks. The whole exercise
should be thoroughly risk-assessed and properly
supervised by qualified staff; and the NPT document
sets out the standards to be followed.
|
Firearms
training
| 48 |
Recommendations for the design of 25 metre indoor
ranges for police firearms training are set out
in the Home Office Police Buildings Design Guide,
a copy of which is held by the DFP Unit. This
includes advice on range ventilation performance
and noise reduction. The guidance is principally
intended for use by forces when commissioning
new facilities, particularly those where capital
grant aid is being sought from the Home Office.
On request, the Army’s Technical Advisory
Section (TAS) will consider the issue of an MOD
Range Safety Certificate for internal and external
police ranges, although there is no presently
no provision for subsequent periodic checks on
range condition by TAS. |
| 49 |
Guidance
for forces on suitable hearing protection for
firearms training is published by the Police Scientific
Development Branch (PSDB). Advice for inspectors
on the control of noise and lead exposure in indoor
ranges will be given in a new SIM replacing cancelled
NIGM 7/B/1998/05. |
Back to main page on police
Police Operational
Activities
HSE’s "Operational Circular" gives
advice to inspectors on the following areas. Click
on the subjects below
- patrol duties
- CS aerosol incapacitant
- Firearms operations
- Scenes of crime
- Custody duties
- Diving teams
- Land-based searching duties
- Storage of explosives at police
premises
Patrol duties
| 50 |
One
of the generic risk assessments published by the
Home Office, and provided to inspectors for reference
deals with the risks to officers on foot patrol.
The control measures listed include training in
control and restraint techniques, knife awareness
and the use and limitations of personal protective
equipment (PPE). The provision of PPE such as
stab-resistant vests is subject to the force’s
risk assessment, hence the variation in the policy
for issuing this type of equipment across the
country. |
| 51 |
The
PSDB publishes the comprehensive Manual of Ballistic
and Stab Resistant Body Armours for reference
by police forces, containing test results against
their bullet and knife protection standards on
a variety of proprietary equipment. It cannot
be assumed that bullet resistant (ballistic) body
armour will also give adequate protection against
knife attack: those that offer dual purpose protection
are generally bulkier and heavier than single
purpose vests. The DFP Unit holds a copy of the
PSDB Manual for reference. |
| 52 |
The
weight of some types of body armour has given
rise to complaints of back pain after prolonged
use, and the more rigid designs, typically intended
for stab resistance, have caused discomfort, particularly
for female officers. There is often a conflicting
requirement for a vest to be stab-resistant yet
suitable for covert wear, and the so-called ‘magic
T-shirt’ does not yet exist with current
technology. |
| 53 |
In response to the Home Office’s concern
that police forces might not be able to comply
with the absolute requirement in the PPE Regulations
to provide equipment such as this when needed,
reg.4 was qualified by ‘so far as is reasonably
practicable’ where there was ‘inevitable
conflict’. |
| 54 |
Perhaps
the most sensitive issue in the recent redesign
of police uniform has been that of the traditional
patrol helmet, which has long been regarded as
the most recognisable symbol of the police service,
but which provides minimal levels of head protection.
The National Uniform Project Group is to produce
a specification for a helmet with a suitable standard
of protection, following a national survey of
head injuries to officers. (Note: PPE which is
designed and manufactured specifically for use
by the police is exempt from the Personal Protective
Equipment (EC Directive) Regulations 1992, and
hence the requirement for CE marking does not
apply). |
| 55 |
The
baton and handcuffs carried by police officers
are considered to be work equipment within the
meaning of PUWER. Accordingly, PUWER reg.4 was
amended by the Police (Health and Safety) Regulations
so that, in relation to work equipment for arrest
and restraint used by police officers, ‘suitable’
refers specifically to their health and safety. |
| 56 |
The
duties of a police constable include the protection
of life, and officers are trained in first aid
in order to fulfil this role. The approach which
has been endorsed by ACPO is that, in future,
all officers, having received first aid foundation
training to ‘appointed person’ standard
at recruit training centre, will receive refresher
training at 3-yearly intervals, and requalify
as an appointed person. Operational support staff
will also receive this level of training, known
as First-Aid Skills Police (FASP). |
| 57 |
The
Police First-Aid Training Project to produce a
set of national occupational standards for first
aid, which includes other modules designed for
custody staff and firearms officers, is currently
(2002) being considered for adoption by the Police
Skills and Standards Organisation (PSSO). |
CS
aerosol incapacitant (CS spray)
| 58 |
[information removed] The Police complaints authority
are responsible for dealing with complaints about
the conduct of police officers including the use
of CS Spray, and they published a report "CS
Spray: Increasing Public Safety" in March
2000 |
| 59 |
The
advice of the expert Committees on Toxicity, Mutagenicity
and Carcinogenicity on the use of CS spray as
an incapacitant was sought by the Department of
Health in 1999. The Committee on Toxicity concluded
that the available data did not, in general, raise
concerns regarding the health effects of CS spray
itself. However, they had concerns regarding exposure
in susceptible groups, and also recommended that
follow-up studies be carried out to obtain data
on whether delayed effects occur. |
| 60 |
The
operational CS incapacitant spray canister contains
a 5% (w/v) solution of CS (2-chlorobenzylidene
malononitrile) in MIBK (methyl isobutyl ketone),
using nitrogen as the propellant gas. MIBK is
a highly flammable liquid (150 C flashpoint),
although the 30 ml aerosol canisters fall within
the exemption in the Highly Flammable Liquids
and Liquefied Petroleum Gases Regulations 1972
reg.5(4)(c). Nevertheless, the canisters are classified
as weapons under the Firearms Act, and are therefore
stored in steel cabinets for security purposes. |
| 61 |
A generic risk assessment for the use of CS spray
(GRA 5.1) is given in Police Health and Safety
Volume 3, and aftercare procedures for persons
sprayed with CS spray are set out in the accompanying
COSHH assessment (GRA 5.2). |
Firearms
operations
| 62 |
Authorised
firearms officers (AFOs) wear ear defenders and
eye protection when training on firing ranges,
but, for firearms operations, ACPO has applied
to HSE for an exemption under the Noise at Work
Regulations 1989 (NAWR) reg.13 from the requirement
in reg.8(2) to provide ear protectors. Inspectors
will be advised on progress in due course. |
Scenes of crime
| 63 |
Scenes of crime officers (SOCOs) are responsible
for the collection of forensic evidence, such
as fingerprints, and may also take part in laboratory
work and attendance at post mortem examinations.
At scenes of crime, officers may be exposed to
a variety of microbiological, chemical and physical
risks. The Home Office prepared a generic risk
assessment for SOCOs’ duties, and issued
it to forces in Circular 17/2000. It was too late
to be included in the GRA CD-ROM, but inspectors
may obtain a copy from the DFP Unit. |
| 64 |
Scenes
of crime officers are trained by the Forensic
Science Service, a Home Office Agency, and two
of their guidance documents, Safety at Scenes
of Crime Handbook, and Health and Safety Advice:
Safe submission of items for examination, have
been issued to FOD subject file 334. |
| 65 |
The
processes used by SOCOs for the development of
latent fingerprints can involve a variety of chemical
reagents, such as dusting with aluminium powder,
or the application of ninhydrin in a fume cupboard.
HSE has advised the Police Scientific Development
Branch on the health and safety guidance in their
Manual of Fingerprint Development Techniques (copy
held by the DFP Unit). |
Custody duties
| 66 |
Custody
officers are responsible for the processing of
detainees on their arrival at the police custody
suite, and for their care and management while
held in the cells. Officers are subject to risks
from attack from detainees, as well as communicable
diseases such as hepatitis B, HIV or TB, or infestation.
Searching detainees who are drug users may expose
officers to needle stick injuries, and appropriate
precautions should be taken, including vaccination
for hepatitis B. |
| 67 |
Custody
staff should be trained in self-defence and restraint
techniques for dealing with violent detainees.
However, these posts are becoming increasingly
occupied by non-police officers (‘civilianised’)
and civilian staff, unlike police officers, are
empowered to use reasonable force only in limited
circumstances. |
| 68 |
The
HSW Act s.3 does not include the provision of
welfare facilities for non-employees, such as
detainees in police cells. Specific requirements
for cell hygiene facilities exist elsewhere, but
are not subject to enforcement by HSE inspectors.
These are:
(1) the Code of Practice for the Detention, Treatment
and Questioning of Persons by Police Officers,
made under the Police and Criminal Evidence Act
1984 (PACE) requires that access to toilet and
washing facilities must be provided for detainees;
and
(2) the general standards outlined in the PACE
Code of Practice are expanded in the Home Office
Police Buildings Design Guide, which is also used
in Scotland. |
| 69 |
Complaints
about conditions in police cells should normally
be channelled through the formal police complaints
procedure |
Diving teams
| 70 |
Police
diving operations (underwater search teams) are
inspected by HSE’s Offshore Division Diving
Inspection teams. Diving teams work to a specific
police diving Approved Code of Practice made under
the Diving at Work Regulations 1997. |
Land-based searching duties
| 71 |
Police
search teams can be called upon to deal with a
diverse range of situations, from searching street
furniture prior to VIP visits, to confined space
searching of sewers and culverts. The Home Office
GRA 10 and associated guidance cover the main
issues, although this was drafted before the Confined
Spaces Regulations 1997 were introduced. |
| 72 |
The
use of portable X-ray inspection devices for checking
suspect packages was dealt with in NIGM 7/B/1997/6,
since cancelled, but a revised SIM will be issued
during 2002/3. |
Storage
of explosives at police premises
| 73 |
Police
forces may store ammunition or pyrotechnic devices,
either for their own use or received from members
of the public. HSE is the enforcing authority
for the Control of Explosives Regulations 1991
(COER) as they apply to police forces, meaning
the county forces, Metropolitan, and City of London
Police. The term does not include the British
Transport Police, MOD Police or port, harbour,
or docks police. However, members of these forces
may hold the office of constable, and therefore
the provisions of COER relating to constables
include such persons. |
| 74 |
Regulation
7 (acquisition and keeping of explosives) and
reg.10 (keeping explosives for private use) do
not apply to:
| (1) |
a
police force, |
| (2) |
a
constable acting in the execution of his/her
duties, or
|
| (3) |
a police civilian employee, authorised in
writing by the chief officer. Police officers
are therefore not required to hold explosives
certificates and explosives may be transferred
to them with no explosives certificate. |
|
| 75 |
The
rest of the COER provisions apply in full to the
police but in effect is limited to the requirement
to keep records (reg.12) and to report any losses
of explosives (reg.13). |
| 76 |
The
police are not required to have a licence or registration
for the places where they keep explosives, but
they are expected to adopt and maintain standards
of construction and safety which are equivalent
to those required for licensed stores and registered
premises. HID Explosives Inspectorate recommend
that police forces should seek the advice of the
LA on appropriate standards for explosives stores
and registered premises. Contacts within the LA
regarding explosives storage vary but it is usually
the trading standards or environmental health
officers who have responsibility. Each force appoints
an explosives liaison officer who could also be
approached for advice. |
| 77 |
Where
inspectors find matters of evident concern during
visits to police premises they should contact
the Explosives Inspectorate for advice. Matters
of evident concern include explosives which:
| (1) |
show
signs of damage, deterioration or degradation,
eg exuding liquid, verdigris or crystal
growth; |
| (2) |
are
wet or contaminated with dirt or grit;
|
| (3) |
are
being kept in areas where the public have
access or in the cells; or |
| (4) |
are
being kept in damp, hot or in apparently
overstocked conditions |
|
Back
to main page on police
Occupational Health
HSE’s "Operational Circular" gives
advice to inspectors on the following areas. Click
on the subjects below
- noise
- lead
- musculoskeletal disorders
- hepatitis B
- Stress
Noise
| 78 |
Routine
audiometry is carried out by police force occupational
health departments for those at risk of hearing
damage, such as firearms officers, motorcycle
traffic officers, and dog handlers. As mentioned
at para 62, ACPO has applied to HSE for an exemption
from the requirement in NAWR reg.8(2) to wear
hearing protection, specifically for firearms
operations as distinct from firearms training. |
Lead
| 79 |
Under
the Control of Lead at Work Regulations 1998 the
exposure to lead of firearms instructors and range
cleaners is likely to be significant in terms
of reg.2, and so the specific requirements of
the Regulations will be triggered, including medical
surveillance. Specific precautions for the control
of lead in indoor ranges will be included in a
forthcoming SIM |
Musculoskeletal disorders
| 80 |
The
majority of ill-health retirements and long-term
absences of police officers result either from
musculoskeletal disorders or stress (Source: HMIC
Thematic Inspection Report 1997). Of the RIDDOR-reported
musculoskeletal injuries, those suffered by officers
on patrol duties predominate, but further detail
is given in SIM 7/2002/15. In order to address
the issue centrally, a Home Office police working
group developed a Moving and Handling Course Trainers’
Manual in 2000, which was then issued to NPT for
incorporation into their training schedule for
police trainers. |
Hepatitis
B
| 81 |
In 1998 the ACPO Joint Working Group on Organisational
Health, Safety and Welfare issued its Guidance
to the Police Service: Hepatitis B. The guidance
recommends:
| • |
that each force should have a written policy
for dealing with the risk of Hepatitis B; |
| • |
local risk assessments should be carried
out; |
| • |
a
range of control measures should be identified; |
| • |
where
those measures include vaccination a management
system should be established |
| • |
an
education programme for staff; and |
| • |
the
issue of an aide-memoire card to staff. |
|
| 82 |
It
is the force’s responsibility to carry out
a range of risk assessments for the range of tasks
and locations concerned, but examples of where
officers are at risk of infection would include
contact with intravenous drug users, searching
of suspects or vehicles, and custody duties. |
Stress
| 81 |
The 1997, HMIC thematic inspection report Lost
Time: the Management of Sickness Absence and Medical
Retirement in the Police Service concluded that
stress-related disorders comprised one of the
major causes of long-term absence, as well as
retirement, in the police. The ACPO Joint Working
Group responded in 2000 with its paper ACPO Guidelines
on the Management of Stress in the Workplace to
enable forces to audit their policies for dealing
with stress. This document is posted on the ACPO
website: www.acpo.police.uk/policies/index.html.
|
| 82 |
In
addition, a study on post trauma reactions to
critical incidents in two police forces was
carried out by the Police Research Unit of Glasgow
Caledonian University. This was published in
HSE Contract Research Report 290/2000 Managing
post incident reactions in the police service.
The National Police Staff College has for some
years offered courses for senior officers and
force welfare officers on:
| • |
post
traumatic stress, |
| • |
critical incident stress debriefing, |
|
Back
to main page on police
Application of the Working
Time Regulations 1998 to the police
Scope of the Regulations
| 66 |
Whilst it is intended that the limits and entitlements
of the Working Time Regulations 1998 (WTR) should
apply to all workers currently within the scope,
it is recognised that in some circumstances certain
provisions of the Regulations cannot be applied
in full because of conflicting needs. In particular
reg.18 states that certain provisions do not apply
‘where characteristics peculiar to certain
specific services such as......the police.......or
to certain specific activities in the civil protection
services, inevitably conflict with the provisions
of these Regulations.’ HSE has interpreted
this to mean that in most circumstances the duration
and pattern of working time for those in the police
service must still conform with the provisions
of the Regulations Part II (subject to modification
by workforce or individual agreements) |
| 67 |
HSE
has no definition of inevitable conflict. The
DTI guide states on page 6 the police service
should identify which activities conflict with
the Regulations. The time spent on these activities
would not be counted as working time. The employer
should identify what characteristics peculiar
to the police or specific activities inevitably
conflict with the provisions of the Regulations,
but examples of the types of activities that might
fall outside the scope of the Regulations would
be dealing with civil unrest, murder investigations,
terrorism, etc. Where the issue is purely staffing
matters the exclusion provided by reg.18 does
not apply. |
| 68 |
The
exclusions provided by reg.18 apply to those holding
the office of constable (including special constables),
or an appointment as a police cadet and not to
civilian staff.
Unmeasured working time |
| 69 |
Certain
provisions of the Regulations do not apply to
workers where, because of the work they carry
out, their working time is not measured or predetermined
or can be decided by the worker themself. However,
the structure and responsibilities of police forces
appear to preclude those ranks below assistant
chief constable from applying this derogation. |
Back
to main page on police
|
