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Work
Instruction 2: Preperation
This work instruction states that
"Before
an investigation commences inspectors must prepare
as far as possible to ensure that they carry it
out effectively, efficiently and safely."
It
states that:
"This includes obtaining adequate information,
any necessary equipment, and ensuring that lines
of communication have been established and necessary
support has been secured."
This
Work Instruction is broken down into five key activities
which describe how HSE inspectors should "prepare"
for an investigation.
Key
activity 1:
IDENTIFY RELEVANT LEGAL REQUIREMENTS, STANDARDS, GUIDANCE
AND POLICY TO ENABLE BENCHMARKS TO BE ESTABLISHED
| 2 |
Inspectors
should, where possible, acquire sufficient knowledge
of the relevant process, machinery or activity,
and the associated hazards, risks and relevant
benchmarks to enable them to conduct their investigation
efficiently and effectively. Benchmarks describe
the acceptable levels of risk established by standards
enforceable in law. Where appropriate, inspectors
should acquire this information by additional
research, to support the competencies they have
acquired through experience and/or training. |
| 3 |
Where
inspectors do not already possess this information,
they should obtain it before starting the investigation,
or where this is not possible, as early in the
investigation process as possible. This is important
so that the investigation, and any potential enforcement
action arising from it, is not compromised. |
| 4 |
Inspectors
should possess an adequate understanding of:
| (1) |
interpretative
standards developed by HSE, FOD or sector
policy and instructions on the application
and enforcement of them; |
| (2) |
other guidance and standards relevant to
the process or activity involved in the
incident, against which actual risk will
be measured. This will include generic and
industry-specific HSE and industry guidance,
and relevant Harmonised European Standards:
| (a) |
specific
sector guidance is listed on the intranet
under Operational Guidance: FOD Subject
File; |
| (b) |
SIMs
(previously NIGMs) are also an important
source of information, and may be
identified using the intranet; |
| (c) |
Harmonised
Standards, once adopted, are indicative
of compliance with PUWERII and the
Supply of Machinery (Safety) Regulations. |
|
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| 5 |
When
there are no appropriate standards, inspectors
should use first principles to establish a benchmark.
Advice from SG may also help with this process. |
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Key activity 2:
LIAISON, IF APPROPRIATE, WITHIN FOD AND HSE
| 6 |
If
investigation planning identifies others within
FOD or HSE with potential interests in an investigation,
inspectors should arrange to liaise with them
and agree the extent of their involvement, if
any, and/or the manner in which their needs will
be addressed during the investigation, including
the feedback of information. |
| 7 |
Examples of who may have an interest in an investigation
include:
| (1) |
heads of operations and divisional directors; |
| (2) |
FOD
Secretariat, who following a fatal accident,
must be informed (see OM 2000/129); |
| (3) |
FOD
sectors, which may need to take action to
publicise the accident inside FOD/HSE, and
the industry, or which may have specific
intelligence needs (see Work
instruction 7 Key activity 1) |
| (4) |
FOD Safety Unit; |
| (5) |
FOD HU, ALU; |
| (6) |
lead PI (see
OC 18/3 The Role of the Lead PI); |
| (7) |
Hazardous Installations Directorate (HID) |
| (8) |
TD 6, who should be notified in the
early stages of an outbreak of legionnaire's
disease (see FOD Health and Safety Policy
supplement 30 Legionellosis); |
| (9) |
PI
supplier (see HSE Guide to the Inspection
of Manufacture and Supply); |
|
| 8 |
Inspectors
should be aware of, and observe, any relevant
OCs which describe specific demarcation and other
agreements within HSE. |
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Key activity 3:
CONSULTATION, IF APPROPRIATE, WITH EXPERT HELP AND
OTHER SUPPORT
| 9 |
Consultation
with specialist support staff may be necessary
during the preparation stage if it is likely that
inspectors will encounter more complex technical
or health issues during the investigation. Inspectors
may find it worthwhile to make contact to establish
the availability of an SG inspector prior to a
visit so that they can call upon help rapidly
if required. This may be particularly so if the
investigation involves a fatal or major injury. |
| 10 |
Specialist
support will usually be provided by SGs, TD,
HSL or AEA Technology. In all these cases,
the SG is the initial contact. FOD sectors may
also provide specialist support. |
| 11 |
See
FOD Health and Safety Policy for relevant supplements
which contain examples where specialist support
may be required to ensure an inspectorâs
safety while conducting an investigation. |
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Key activity 4
OBTAINING NECESSARY EQUIPMENT
| 12 |
Inspectors should make arrangements to obtain
the equipment necessary for the investigation,
including such equipment as is necessary to implement
the FOD Health and Safety Policy sector-specific
supplements. |
| 13 |
On joining an FMU, inspectors should have been
equipped with any specific protective clothing,
eye, foot and hearing protection, respiratory
protective equipment (PPE and RPE); and other
equipment and stationery etc appropriate for their
inspection responsibilities. Before beginning
an investigation inspectors should:
| (1) |
check
that they have the PPE and RPE and other
equipment detailed in the sector-specific
and topic supplements in the FOD Health
and Safety Policy relevant to the activity,
premises, site or location they are to visit
(see particularly FOD Health and Safety
Policy Supplement 24(1) A system for the
selection, use, examination and maintenance
of respiratory equipment for use by FOD
field professionals); |
| (2) |
consider
whether the effects of the incident to be
investigated will have increased the risk
from existing hazards, introduced new hazards
or changed the environmental conditions,
with the result that additional or different
PPE, RPE or equipment or specialist support
will be needed. Examples include
| (a) |
the
need for safety rubber boots for an
investigation of a significant fire, |
| (b) |
the
possible need to involve a nominated
inspector equipped with a higher standard
of RPE; |
|
| (3) |
select
appropriate hearing protection in accordance
with FOD Health and Safety Policy Supplement
35: Noise. |
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| 14 |
Inspectors
should also have the following items when conducting
an investigation:
| (1) |
a warrant; |
| (2) |
a
sufficient supply of visiting cards; |
| (3) |
a
tape measure; |
| (4) |
G2 numbered notebook; |
| (5) |
a
camera suitable for the purposes of the
investigation; |
| (6) |
where
appropriate, equipment for the formal taking
of samples (the appendix to FOD Health and
Safety Policy Supplement 34: Taking samples,
contains a list of basic items available
for this purpose. |
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Key activity 5:
COMMUNICATIONS AND BRIEFING COLLEAGUES
| 15 |
Normal
communication between the inspector at the site
of the incident and the HSE office in most cases
will be via mobile phone or occupier's phone. |
| 16 |
Briefing
of colleagues will be necessary particularly if
it's a team investigation or inspectors anticipate
specialist help prior to the visit. Briefing may
also be necessary if a trainee inspector is to
accompany the investigating inspector on site.
Inspectors should take care to adequately brief
colleagues participating in an investigation.
It is important that the briefing is as thorough
and explicit as possible in the light of information
available. Inspectors may need to cover the following
in their briefing:
| (1) |
details
of the incident; |
| (2) |
details
of any previous similar incidents involving
the same dutyholder; |
| (3) |
emerging
findings; |
| (4) |
initial conclusions drawn, if any, and the
reasons for them; |
| (5) |
any
gaps in the details known; |
| (6) |
other
potential lines of enquiry; |
| (7) |
the
aims and potential outcomes of the investigation; |
| (8) |
their
own role in the investigation; |
| (9) |
the
roles of others participating in the investigation; |
| (10) |
warnings
of any special hazards likely to be encountered
on-site; |
| (11) |
warnings
of any difficulties likely to arise in the
investigation; |
| (12) |
the
strategy devised for the investigation; |
| (13) |
arrangements
for other support, on-site accommodation,
communications and record logs; |
| (14) |
clear
directions to identify the location of the
site. |
|
| 17 |
Initial
briefings will be verbal. However, if expert help
is required following such briefings, inspectors
should submit a written request for help. |
| 18 |
For
matters concerning arrangements for personal safety,
decontamination of inspector's equipment, and
managing other work and avoidance of work-related
stress, inspectors should liaise with their line
manager, if appropriate, and consult and follow
any current policies and instructions. |
Evening and weekend visits
| 19 |
If an investigation needs to commence in the evenings
or weekend for reasons such as the need to preserve
evidence (traveling fairground etc) or due to
its serious nature, and although not a major incident
as defined, inspectors should be aware of the
divisional major incident response plan. This
contains useful information such as:
(1) phone numbers of colleagues and specialist
inspectors;
(2) phone numbers of police and other possible
interested parties;
(3) details of how to obtain equipment out of
hours. |
| 20 |
Decisions as to whether an out-of-hours response
is necessary should be made by band 2 or above. |
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