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Ruth Stanier,
DETR,
Eland House,
Bressenden Place,
London SW1E 5DU
24 January 2000
Dear Ruth,
Following on from our conversation
on the phone last week, I thought it might be useful
to note down some of our continuing concerns about
particular HSE policies which have crystallised since
our meeting with you last year. In addition, I thought
it might be useful for you to know, at this stage,
a number of the issues that we are likely to raise
with the minister, Michael Meacher M.P when we meet
him next week.
The issues dealt with in this
note are the following:
| 1. |
Directors Duties:
Why legal safety duties should be placed on Directors
and why there should not be a voluntary code. |
| 2. |
HSE's "Enforcement
Policy Statement"
The inadequacies of HSE's "Enforcement Policy
Statement" and how it compares with the Environment
Agency's statement and guidelines |
| 3. |
The Protocol of Liaison
The Defects of the "Protocol of Liaison on
Workplace Deaths", and the inadequacy of
HSE's position in refusing to consider extending
it. |
| 4. |
Major Injury Investigations
Comparing HSE's performance with the Environment
Agency's statistics and the police, and the inadequacy
of HSE's guidelines to inspectors. |
| 5. |
Inspectors as Prosecutors
Why HSE inspectors should not prosecute cases. |
| 6. |
Referring Cases to the
Crown Court
The lack of HSE guideline to inspectors about
which cases they should press magistrates to refer
to the Crown Court |
| 7. |
Proportionate Fines
The Sentencing Advisory Panel should be asked
to prepare a consultation document on sentencing
health and safety offences. |
Yours sincerely,
David Bergman
Director
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