research report 418 - hse: information about health and ...training and information, and for access...

HSEHealth & Safety

Executive

Local authority health and safetyenforcement officer’s perceptionsof their support, information and

training needs (SITNA)

Prepared by the Health and Safety Laboratory for the Health and Safety Executive 2006

RESEARCH REPORT 418

HSEHealth & Safety

Executive

Local authority health and safetyenforcement officer’s perceptionsof their support, information and

training needs (SITNA)

Nadine Mellor, Caroline Sugden & Helen Balmforth

Human Factors Harpur Hill

Buxton Derbyshire

SK17 9JN

As part of the Local Authorities (LAs) and Health and Safety Executive (HSE) Working Together Strategic Programme, seven commitments were made by the Health and Safety Commission, HSE and LA representative bodies to create genuine partnership between LAs and HSE leading to improved health and safety. One of these commitments was to provide information, guidance and support to enforcing authorities equitably. The HSE Local Authority Unit (LAU) commissioned the Health and Safety Laboratory to carry out an analysis of these needs as perceived by LA Health and Safety Enforcement Officers. The research aimed to identify practical recommendations that could be implemented to meet this commitment.

Among the objectives of the research were:

● assessment of existing levels of support and information and identification of perceived needs; ● identification of training needs and options to meet these needs; and ● advice to LAU on the best options to answer health and safety enforcement needs

Among the conclusions, the report highlights the lack of awareness by LA Health and Safety Enforcement Officers of the support available to them by HSE and HSL. It also shows that a change of culture and awareness is required by many HSE Officers in their perception of the work LA Health and Safety Enforcement Officers are required to do - much is varied and complex - and the limited resources some of them have available. The report lists additional training that many LA Health and Safety Enforcement Officers perceived they needed if they were to feel confident in addressing the current and future Health and Safety challenges.

This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.

HSE BOOKS

© Crown copyright 2005

First published 2006

All rights reserved. No part of this publication may bereproduced, stored in a retrieval system, or transmitted inany form or by any means (electronic, mechanical,photocopying, recording or otherwise) without the priorwritten permission of the copyright owner.

Applications for reproduction should be made in writing to: Licensing Division, Her Majesty's Stationery Office, St Clements House, 2-16 Colegate, Norwich NR3 1BQ or by e-mail to [email protected]

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CONTENTS

Executive summary ...................................................................................................................... vii

1 Introduction ........................................................................................................................... 1

2 Methodology and Sample...................................................................................................... 3

3 Support, Training and Information........................................................................................ 5

3.1 Relative strengths of LAs and HSE............................................................................... 53.2 Support .......................................................................................................................... 63.3 Information.................................................................................................................... 93.4 Training ....................................................................................................................... 10

4 Conclusions - Balancing the needs of support and training ................................................ 13

Technical Annex.……...………………………………………………………………… 15

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ACKNOWLEDGEMENTS

The researchers would like to thank all those who took part in this study, for their availability and for the information they provided. Their contribution has been vital in identifying the support, information and training needs of local authority staff, and for considering the feasibility of various options.

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EXECUTIVE SUMMARY

As part of the Local Authorities (LAs) and Health and Safety Executive (HSE) Working Together Strategic Programme, seven commitments were made by the Health and Safety Commission, HSE and LA representative bodies to create genuine partnership between LAs and HSE leading to improved health and safety. One of these commitments was to provide information, guidance and support to enforcing authorities equitably. The Local Authority Unit (LAU) in HSE commissioned the Health and Safety Laboratory (HSL) to carry out an analysis of the support, information and training needs (SITNA) of LA Health and Safety enforcement officers. The research aims to identify practical recommendations to meet this commitment.

The objectives of the research were to:

• To assess the existing levels of support and information received by local authority health and safety enforcement officers and identify their needs in terms of form, content and type of information and support;

• To identify training needs and outline options to meet these needs;

• To advise LAU on the best options to answer health and safety enforcement needs.

METHODOLOGY

The study was based on the views of 315 LA Health and Safety Enforcement Officers, who comprise 8.5% of Local Authority staff who carry out health and safety enforcement. A multi-method approach was used which included:

• Semi-structured interviews with local authority officers on training and organisational objectives;

• Semi-structured interviews with stakeholders on topics within the SITNA theme;

• 7 regional focus groups on training;

• Questionnaire on training;

• 4 workshops on support and information;

• 20 syndicate exercises at 2 conferences in the Midlands on support/ information and training;

• Review of previous contemporary primary research on support, information and training.

The intention of using these multiple methods was to triangulate the data and use the various sources to strengthen the research findings.

MAIN FINDINGS

One of the key findings from this research was that enforcement officers have a desire to be provided with equivalent levels of support, information and training that they perceive is

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available to HSE inspectors. They believe they would function more effectively if they had the equivalent levels of service as HSE in terms of training, specialist support, colleagues, and the raft of information available over the HSE Intranet. Many of their suggestions for improvement concerned addressing their perception of a two tier system for enforcement, where HSE inspectors are perceived to be well-trained, well-equipped and well supported, whilst most local authority officers are less well trained and under-resourced. The main findings are:

• LA enforcement officers are dedicated professionals who want to deliver an effective service;

• LA enforcement officers perceive they have low resource and limited opportunities to develop their technical knowledge in comparison to HSE staff and believe they would function more effectively if they had support services equivalent to HSE, e.g. in terms of training, technical support and access to the HSE Intranet for guidance and information;

• There are varying tools used by local authorities to assess and manage competence;

• LA enforcement officers were not aware of the full range of technical support available to them from HSE/HSL;

• There are different approaches to health and safety enforcement by HSE and LAs. LAs are influenced by local circumstances and tend to be more locally focused;

• There is no systematic method of identifying individual LA officer training requirements because each LA has its own procedure and perception of what is required;

• Individual LAs lack the resource to analyse fully the individual training needs of their staff and research needs in the context of a coordinated national approach to health and safety enforcement;

• The full range of technical training perceived as necessary by LA enforcement officers could not, in any practical way, all be supplied by HSE.

RECOMMENDATIONS

The key recommendations from this report are given below. The full set of recommendations is presented in the main report.

Support

• Continue to build relationships between HSE and local authorities, including partnership events.

• Explore various models for the organisation of all health and safety enforcement officers, taking into account the varying strengths, skills and competencies;

• Planning cycles need to be aligned to ensure that HSC targets are incorporated into local authorities plans.

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• A service level agreement could be developed to help LA officers obtain support when they need it.

• Raise the profile of occupational health/medicine and outline the types of services that are offered in line with Revitalising Health Strategy targets/topic areas.

• Carry out a cataloguing exercise to categorise and summarise HSE research and specialist support documents to outline lessons pertinent to LA-enforced sectors.

• Explore options for providing enforcement officers with legal advice.

Information

• Raise profile of Infoline about the competence of staff and the service offered;

• Explore the possibility of offering a tailored Infoline service, via LACORS or the EXTRANET.

• Improve search engines and provide better knowledge management systems.

• Encourage the use of discussion groups for networking.

Training

• Develop, with all relevant stakeholders, a national system for the assessment of competence, including appropriate assessment regimes and linked to meaningful professional development.

• Explore options to develop a national body for the coordination of additional health and safety training needs in consultation with LACORS and other key stakeholders. Each LA would remain autonomous in the way they wish to address training provision but their training needs would be channelled through a coordination unit.

• Make available HSE training materials to local authorities, provided that it fulfils identified training needs.

• Awareness-raising to help enforcement officers understand the key issues concerning a topic, and recognise where and when expertise should be sought.

• Use of networks, both within HSE and between local authorities to cover critical situations. Including the development of a register of individual’s knowledge/experience.

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1 INTRODUCTION

The Local Authority Unit (LAU) of the Health and Safety Executive (HSE) commissioned the Health and Safety Laboratory (HSL) to carry out an analysis of the support, information and training needs (SITNA1) of Health and Safety enforcement officers within local authorities (LAs).

There are 410 LAs in England, Scotland and Wales enforcing Health and Safety, employing some 3,670 enforcement officers with responsibility for enforcing the Health and Safety at Work etc Act 1974 (HSW Act) together with the Health and Safety Executive (HSE). The HSE employs 4,122 staff including HSL, of whom around 1,600 are HSE inspectors, specialists and other professionals.

The Health and Safety (Enforcing Authority) Regulations 1998 (EA regulations) allocate responsibility for the enforcement of health and safety legislation at different premises between LAs and HSE. LAs cover over 1.2 million premises comprising around 12 million people. These premises include offices, shops, retail and wholesale distribution, hotel and catering establishments, petrol filling stations, residential care homes and the leisure industry. HSE covers factories, chemical plants and refineries, nuclear installations, construction, railways, agriculture, hospitals, schools, colleges and universities, police authorities and forces, fire authorities, offshore gas and oil installations, onshore major hazards including pipelines, gas transmission and distribution. However, the EA Regulations allow some flexibility in terms of coverage and enforcement responsibility between HSE and LAs (HELA, Annual Report 2004).

Since 2004, enforcement activities have been performed in the context of a partnership between HSE and LAs. In July 2004, a Statement of Intent was signed by the heads of key local government representative bodies, i.e. the Local Government Association (LGA), the Welsh Local Government Association (WLGA), the Convention of Scottish Local Authorities (CoSLA), the Local Authorities Coordinators of Regulatory Services (LACORS), the Health and Safety Commission (HSC) and the Health and Safety Executive (HSE). A number of commitments have been agreed to improve how HSE and local government work together towards better health and safety at work. One commitment is:

“Providing information, guidance and support to enforcing authorities equitably.We are aiming to move quickly to better ways of sharing the guidance that supports the day-to-day work of enforcing authorities and their staff. We will also develop systems for sharing training and information, and for access to expertise and specialist resources” (LACORS & HSE, 2004)2

A training, support and information needs analysis needed to be conducted in order to assist in the development of shared working systems between LAs and the HSE to help meet this commitment. The intention was to identify the requirements local authority health and safety enforcement staff perceived they have, and consider their needs and identify any gaps in terms of support, information and training.

The objectives on support and information were:

• To identify the relative strengths of LA officers and HSE inspectors as enforcers in order to use them adequately for an effective partnership;

1 SITNA stands for Support, Information, and Training Needs Analysis. 2 Local Authorities and HSE working together, LACORS and HSE, 2004.

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• To assess the existing level of support and information received by LA officers and what their needs are in terms of form, content and type of information and support (technical, legal, medical, scientific);

• To advise LAU on the best options to answer business and Health and Safety enforcement needs.

The objectives on training were:

• To explore LA views on priority given to their local health and safety topics and to the HSC’s priority topics;

• To identify training needs and outline options to meet these needs (portfolio of training);

• To evaluate the effectiveness of the training delivery mechanisms;

• To provide guidance to LAs on how to assess training needs and how to access services to meet identified needs.

This report is presented in three parts:

• An executive summary;

• A concise report;

• A detailed Technical Annex.

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2 METHODOLOGY AND SAMPLE

The study was based on the views of 315 Local Authority Enforcement officers, who make up an 8.5% sample from the 3670 who carry out health and safety enforcement within Local Authorities. A multi-method approach was used which included:

• Semi-structured interviews with local authority officers on training and organisational objectives;

• Semi-structured interviews with stakeholders on topics within the SITNA theme;

• 7 regional focus groups on training;

• Questionnaire on training;

• 4 workshops on support and information;

• 20 syndicate exercises at 2 conferences in the Midlands on support/ information and training;

• Review of previous contemporary primary research on support, information and training.

The intention of using these multiple methods was to triangulate the data and use the various sources to strengthen the research findings. Table 1 presented below summarises the methods used:

Method Support Information Training Summary Semi-structured interviews with LA senior managers

20 local authority senior staff. The topics covered training, competence and organisational objectives. Some interviewees provided documentary support.

Semi-structured interviews with stakeholders

Approximately 20 stakeholders with a range of specialisms were interviewed. They were selected in consultation with the HSE customer.

Regional focus groups

60 local authority health and safety enforcers addressing competence, training needs, training methods and evaluation.

Questionnaire 59 completed and returned questionnaires on skills and knowledge used, and the amount of training and information received on them.

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Workshops 45 local authority health and safety enforcers and 16 HSE specialist inspectors. Topics covered included:

Contribution to HSC strategy and targets

Relative strengths and weaknesses of local authority and HSE enforcers

Enforcement support, availability and access

Suggestions for improvement to the provision of information and support.

Syndicates 190 local authority health and safety enforcers with a third reporting on each topic of Support, Information and Training

Summary of past research

Contemporary primary research reviewed to support or refute research findings.

Table 1 – Summary of Multiple Methods

Detailed information about the methodology used and the sampling can be found in sections 2.2 and 3.2 in the Technical Annex.

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3 SUPPORT, TRAINING AND INFORMATION

One of the key findings from this research was that enforcement officers have a desire to be provided with equivalent levels of support, information and training as that which they perceive is available to HSE inspectors. They believe they would function more effectively if they had the equivalent levels of service as HSE in terms of training, specialist support, colleagues, and the raft of information available over the HSE Intranet. Many of their suggestions for improvement concerned addressing their perception of a two tier system of enforcement, where HSE inspectors are perceived to be well-trained, well-equipped and well supported, and local authorities less so. The main findings are:



• There are varying tools used by local authorities to assess and manage competence;


• There are different approaches to health and safety enforcement by HSE and LAs. LAs are influenced by local circumstances and tend to be more locally focused;

• There is no systematic method of identifying individual LA officer training requirements because each LA has its own procedure and perception of what is required;

• Individual LAs lack the resource to analyse fully the individual training needs of their staff and research needs in the context of a coordinated national approach to health and safety enforcement;

• The full range of technical training perceived as necessary by LA enforcement officers could not, in any practical way, all be supplied by HSE.

The following sections summarise the specific findings on support, information and training.

RELATIVE STRENGTHS OF LAS AND HSE

Both LA officers and HSE inspectors are committed to their role. However, their competences are significantly different, in part because health and safety is only one component of a local authority officer’s job. HSE Inspectors carry out health and safety enforcement activities full time, and are considered to be competent in health and safety. Only a small proportion of local authority staff exclusively carries out health and safety activities, and many therefore could lack

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3.1

health and safety experience3. This has implications when considering training requirements as it is possible that local authority staff may not have opportunities for using specialist training and this impacts the design of the training and competence assurance regimes. It is important to remember that skills and knowledge acquired during training need to be used regularly for the skills/knowledge to be remembered and for the individual to be deemed competent in those activities.

One of the challenges of partnership working is about addressing the relative weaknesses and capitalising on the respective strengths. In particular HSE needs to recognise the strengths of LA enforcement officers and work on changing their attitudes towards these staff. Previous research suggests that better partnership working will result from good relationships with HSE. For detailed research findings consult section 2.3.2 in the Technical Report.

Recommendations to address this are:

• Continue to build relationships between HSE and local authorities, including partnership events;


• Planning cycles need to be aligned to ensure that HSC targets are incorporated into local authority plans.

3.2 SUPPORT

A broad range of support and information mechanisms were explored in the course of this study and suggestions for improvement were proposed.

3.2.1 Enforcement Liaison Officers

Most of those involved in the study had contact with their local HSE Enforcement Liaison Officer (ELO), who answered queries on enforcement responsibility and acted as a gateway into HSE for obtaining specialist advice. There appeared to be a mismatch of perceptions, with an assumption that HSE has unlimited resources and that any support required by LAs could be delivered quickly.

For further information refer to section 2.3.3 in the Technical Annex.

Recommendations are:

• Explore the roles and responsibilities of ELOs. Review their real time activities and determine whether alternative routes could provide lower level support, such as information provision;

• Continue to build and maintain relationships with local authorities by ELOs attending liaison meetings and running partnership events.

3 Competence is considered to be a combination of practical and thinking skills, experience and knowledge (HSE website).

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3.2.2 Technical support from Specialist Inspectors;

Many enforcement officers had heard of, or used, Specialist Inspectors, which were accessed via the ELOs. On the whole they were satisfied with the service they received, but would prefer direct access. Specialists tended to be consulted for major accident investigations. Enforcement officers desire for greater access to Specialists could present a supply and demand issue, however requests could be dealt with using a risk prioritisation approach making clear the rationale for rejecting or accepting a request for work.



• Provide a catalogue of Specialist Inspectors services outlining the types of specialisms and the services offered;

• Provide Specialist Inspectors’ reports on previous topics, so that LA officers can understand the type of service they could receive;

• Explore the use of a risk-based approach to prioritise work requests to Specialist Inspectors. Communicate this to all relevant parties;

• A service level agreement could be developed to help LA officers obtain support when they need it.

3.2.3 Medical Support

Attendees at the workshops widely reported that they did not use Occupational health services. In fact only about 1 in 20 had availed themselves of these services. Participants attributed this to their lack of understanding about the discipline of occupational health and medicine. Furthermore they stated that organisational priorities typically focused on safety, which was considered easier to enforce. This is reinforced by enforcement officers’ comments concerning topic inspections on stress and manual handling, which they consider more difficult to enforce.




3.2.4 Scientific and technical services from Consultancies and HSL

Local Authority enforcement officers did not generally use the services supplied by the Health and Safety Laboratory. They were not aware of the range of services it offers, how it is accessed and how the services can be paid for. They commented that much research is published by HSE but that it is not always immediately obvious which is relevant or valid for the sector in which they have interest. A budget of £5m, over four years, has been allocated by HSE to be spent on scientific and technical services for the local authorities.

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In terms of recommendations HSL needs to:

• Raise its profile, clarify how its services can be accessed as well as outline the services it offers;

• In conjunction with this, improve the internet site to contribute to the above;

• Continue its consultation with Local Authority Liaison groups to identify valid and useful research projects for local authorities to commission;


3.2.5 Legal Support

Legal support was identified as a big issue during workshops and stakeholder interviews. In particular, concerns were expressed about:

• The competence of local authorities solicitors advising on health and safety, as this is rarely used;

• Court costs were also identified as a barrier to taking enforcement action, as taking a case to court could potentially consume an Environmental Health department’s entire budget. A further resource concern was staff unavailability, due to involvement in court cases;

• Miscellaneous enforcement issues, including: PACE interviews, taking statements, issuing notices and letters and presenting information. Information was requested as to how HSE inspectors undertook these functions.

Currently HSE cannot provide legal services to local authorities. However, HSE does provide information on the Enforcement Guide, including sample letters, notices, and protocols to follow, as well as legal guidance included in Local Authority Circulars (LACs). Material is also, currently available on the HELA Training-Coordination (HELA-TC) website, however, enforcement officers were concerned about its provenance and accuracy.4


Recommendations:

• Explore options for providing enforcement officers with legal advice;

• HSE to publish a wider range of sample notices, letters, protocols etc to support local authorities in their enforcement activities;

4 The HELA-TC website is being migrated to a HSE Extranet site. 8

3.3 INFORMATION

Information mechanisms explored in this study included Infoline, Computer-based Information systems, and Planning and Regulatory Services On-line (PARSOL). The main findings suggest that the Internet and computer-based information systems are the main information source for enforcement officers. However, they also consult the ELO for information, with many having a preference for speaking to individuals.

3.3.1 Infoline

Infoline is HSE’s public inquiry contact centre for addressing health and safety enquiries. Most participants stated they had not used it, although user statistics from Infoline suggest that many local authorities do use Infoline. One of the main reasons stated for not using Infoline was the level of expertise and competence of Infoline staff.

In terms of knowledge management and customer satisfaction, Infoline appears to be an excellent way of informing local authorities on topics and addressing local level information based services. Furthermore, Infoline could be tailored to address local authority enforcement officers’ specific needs.


Recommendations:

• Raise profile of Infoline about the competence of staff and service offered;


3.3.2 Computer-based Information systems

This was the most commonly used route by enforcement officers. There are many sources available to local authorities, including HSE Internet, HELA-TC website, LACORS website, LAU website, EHC Net. One of their main concerns was about the provenance of these, and the accuracy of material. There was a belief that HSE-published material would be accurate, whilst others may not be. Complaints concerned the user friendliness of sites, inadequate search facilities, closed material and poor information management.


Recommendations include:

• Improve search engines and provide better knowledge management systems;

• Encourage the use of discussion groups for networking;

• Clarify information providers and streamline those where possible;

• Capitalise on HSE as an authoritative source;

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• Increase linkages between websites to avoid duplication of material.

3.3.3 Planning and Regulatory Services On-line (PARSOL)

None of the participants in the workshops were aware of PARSOL, which is an Office of the Deputy Prime Minister (ODPM) sponsored e-Govt initiative to help local authorities develop effective and transparent provision and delivery of planning and regulatory information on-line. The project has developed guidelines, support documents, schemas and toolkits in order to assist local authorities in sharing their information online, without expensive and complicated bespoke solutions. HSE is not currently involved in PARSOL, although many other government bodies are.


In terms of recommendations:

• PARSOL needs to be considered as a potential mechanism for the provision of information share networks to local authorities.

3.4 TRAINING

The major components of training explored in this study included training needs assessment, training methods and training evaluation. The main findings indicate that most LAs have training systems, which aim to provide and maintain competence, but the lack of budget, resources and time dedicated to health and safety activities, weaken the training effectiveness.

3.4.1 Assessment of training needs

Individual local authorities lack the resource to fully analyse the individual training needs of their staff, or identify research needs in the context of a coordinated national approach to health and safety enforcement. Several local authorities have competency frameworks in place, as well as methods for the assessment of training needs. These were typically developed in conjunction with the health and safety liaison groups and included a list of core skills and knowledge derived from the Section 18 guidance (HSW Act, 1974).



• Individual training needs on generic and specific skills and knowledge should be further identified between line managers and their enforcement officers;

• LAs who have developed competency frameworks are encouraged to share this material and post it on the HELA training coordination website.

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3.4.2 National competency framework

There is a lack of a common management approach or standard of competence assessment for enforcement officers. For further information refer to section 3.3.6 in the Technical Annex.

The recommendations are:

• To revisit Wilson’s recommendation on assessment practices comparison contained in her 1998 report on ‘Health and Safety Enforcement Officers Standards of Competence’. It says that ‘the operation of the section 18 and the NVQ in local authorities and within HSE for its own inspectors should undergo a comparison investigation, to establish similarity and differences in evidence and assessment practices. This should include an evaluation of comparability in the training, evidence and assessment of each’;

• The development, with all relevant stakeholders, of a national system for the assessment of competence, including appropriate assessment regimes and linked to meaningful professional development.

3.4.3 Training coordination system

Currently no central body exists to coordinate additional H & S training needs, and no national picture exists of these training needs. This is vital to assist in the planned provision and coordination of training activities between local authorities, HSE and other providers.

For further information refer to section 3.5 in the Technical Annex.


• Explore options to develop a national body for the coordination of additional H & S training needs in consultation with LACORS, and other key stakeholders. Each LA would remain autonomous in the way they wish to address training provision but their training needs would be channelled through a coordination unit.

3.4.4 Training Provision

There was a call for: greater clarity about the coordination and positioning of health and safety; more training; and also more training or events with HSE inspectors or using packages developed for HSE inspectors. By receiving this, enforcement officers would see the partnership as being ‘equal’. The priority for future training seemed to be around HSC priority topics, legal and H&S management issues although local needs have also been expressed (e.g. legionella,) as well as more generic skills (interviewing, business skills). The full range of technical training perceived as necessary by enforcement officers couldn’t, in any practical way, all be supplied by HSE. For further information refer to section 3.3.5 in the Technical Annex.


• Make available HSE training materials to local authorities, provided that it fulfils identified training needs;

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• Awareness raising to help enforcement officers understand the key issues concerning a topic, and recognise where and when expertise should be sought.

Rather than attempting to provide all inspectors with training to cover all situations, e.g. ones inspectors may only encounter rarely, including fatal accidents and major incident investigations, the use of local support networks within LAs in a region is advocated.


• Use of networks, both within HSE and between local authorities to cover critical situations.

• A register of knowledge/experience would be of value to support enforcement officers.

Training provision needs to be supplemented by other learning and information gathering opportunities to foster common language, best practice and reduce organisational culture differences between LAs and the HSE. For further information refer to section 3.3.3 in the Technical Annex.

The recommendation is:

• To hold at least one annual event in each region gathering LA enforcers, HSE inspectors and HSL specialists to share their experience on major projects, legal and technical developments, etc.

3.4.5 Improvement of training methods and content

A variety of training methods ranging from face-to-face training to web-based materials are used but participants preferred practical and real situations. The most common training method is cascade training, which was generally not well regarded.



• Explore options for the improvement of cascade training, including guidelines for course providers for example have a pool of trainers for a given region. A study by Salford University on this topic needs to be taken into account in the development of these options;

• Ensure that training is evaluated after a suitable period to ensure that training meets the identified needs.

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4 CONCLUSIONS - BALANCING THE NEEDS OF SUPPORT AND TRAINING

LA health and safety enforcement officers believe that they would function more effectively if they had access to equivalent services as HSE inspectors in terms of training, specialist support, colleagues and the raft of information available over the HSE Intranet. Many of their suggestions for improvement concerned addressing their perception of a two-tier system for enforcement, with HSE perceived as well-trained, well-equipped and well supported.

Enforcement officers that work on health and safety recognise that their knowledge levels on OH&S are not equivalent to HSE inspectors, who all address Occupational Health and Safety (OH&S) full time. However, due to the organisation of work within LAs, as well as the risk profile of premises it is unlikely that enforcement officers’ enforcement experience is sufficiently broad for them to be considered competent/experienced on the full range of OH&S issues. Therefore, the research team do not consider it to be a viable or feasible option for enforcement officers to be trained to equivalent standards as HSE Inspectors. As a result a model is proposed that would allow the balance between Support/Information and training to be explicitly identified. For example, if a certain skill is used infrequently and is difficult to train then this would almost certainly be an area where local authorities should seek support. Conversely skills that are used often, even if the training needs are high, should be trained and internally resourced by local authorities.

Support and Training Resource Model

Com

plex

ity o

f tra

inin

g ne

eds

TRAINING REQ’D

SUPPORT REQ’D

High

Low TRAINING REQ’D

SUPPORT REQ’D

High

Low

Used infrequently Used often

Frequency of skills used

Figure 1 – Support and Training Resource Model

Figure 1 proposes an outline framework for such a model to balance the Support and Training Needs of Enforcement staff within local authorities. Further work is required to identify the shape and position of the line within the model to determine what skills/knowledge should be routinely given to enforcement officers and to identify where specialist support should be supplied. The space underneath the line defines those areas where training is required, and that

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above the line where specialists can provide their expertise. The exact position and shape of this line needs to be determined. Those skills that are used more frequently should be developed through training, whilst support should be offered for those skills that are used less frequently. For example, on issues such as legionella or asbestos it could be that the skills and knowledge is needed so infrequently that even trained individuals will not be competent to use the trained material when requested.

The advantages of developing and defining such a model include:

• A recognition by enforcement officers concerning the training that is core to their job, and the importance of ensuring experience of these skills;

• A recognition that competence needs to be actively maintained, and requires more than attendance at a training course;

• A recognition that training cannot be provided in all areas of occupational health and safety;

• An awareness of where support is needed and how it can be obtained.

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TECHNICAL ANNEX

Analysis of Support, Information and Training Needs of Local Authority Health and Safety

Enforcers

November 2005

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CONTENTS

1 Introduction ......................................................................................................................... 17

2 Support and Information ..................................................................................................... 192.1 Background ................................................................................................................. 192.2 Methods....................................................................................................................... 192.3 Results and recommendations ..................................................................................... 22

3 Training analysis ................................................................................................................. 423.1 Background ................................................................................................................. 423.2 Methods....................................................................................................................... 473.3 Results ......................................................................................................................... 49 3.4 Suggestions for improvement of training .................................................................... 603.5 Summary on training ................................................................................................... 62

4 Conclusions and recommendations ..................................................................................... 644.1 Recommendations ....................................................................................................... 644.2 Balancing the needs of support and training ............................................................... 69

5 Appendices .......................................................................................................................... 71 Appendix 1 – Local Authority sample .................................................................................... 71Appendix 2 – Interview schedule............................................................................................ 72Appendix 3 – Invitation to focus groups & workshops........................................................... 73Appendix 4 – Focus group questions guide ............................................................................ 75Appendix 5 – HSC guidance - annex 2 – October 2002 ......................................................... 76Appendix 6 – Training research questionnaire detailed results............................................... 79Appendix 7 – Support workshop agenda ................................................................................ 85Appendix 8 – PARSOL and other HSL research .................................................................... 86

6 References ........................................................................................................................... 89

7 Glossary............................................................................................................................... 91

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1 INTRODUCTION

The Local Authority Unit (LAU) of the Health and Safety Executive (HSE) commissioned the Health and Safety Laboratory (HSL) to carry out an analysis of the support, information and training needs (SITNA5) of Health and Safety enforcement officers within local authorities (LAs).

There are 410 LAs in England, Scotland and Wales enforcing Health and Safety, employing some 3,670 enforcement officers with responsibility for enforcing the Health and Safety at Work etc Act 1974 (HSW Act) together with the Health and Safety Executive (HSE). The HSE employs 4,122 staff including HSL, of whom around 1,600 are HSE inspectors, specialists and other professionals.

The Health and Safety (Enforcing Authority) Regulations 1998 (EA regulations) allocate responsibility for the enforcement of health and safety legislation at different premises between LAs and HSE. LAs cover over 1.2 million premises comprising around 12 million people. These premises include offices, shops, retail and wholesale distribution, hotel and catering establishments, petrol filling stations, residential care homes and the leisure industry. HSE covers factories, chemical plants and refineries, nuclear installations, construction, railways, agriculture, hospitals, schools, colleges and universities, police authorities and forces, fire authorities, offshore gas and oil installations, onshore major hazards including pipelines, gas transmission and distribution. However, the EA Regulations allow some flexibility in terms of coverage and enforcement responsibility between HSE and LAs (HELA, Annual Report 2004).

Since 2004, enforcement activities have been performed in the context of a partnership between HSE and LAs. In July 2004, a Statement of Intent was signed by the heads of key local government representative bodies, i.e. the Local Government Association (LGA), the Welsh Local Government Association (WLGA), the Convention of Scottish Local Authorities (CoSLA), the Local Authorities Coordinators of Regulatory Services (LACORS), the Health and Safety Commission (HSC) and the Health and Safety Executive (HSE). A number of commitments have been agreed to improve how HSE and local government work together towards better health and safety at work. One commitment is:

“Providing information, guidance and support to enforcing authorities equitably.We are aiming to move quickly to better ways of sharing the guidance that supports the day-to-day work of enforcing authorities and their staff. We will also develop systems for sharing training and information, and for access to expertise and specialist resources” (LACORS & HSE, 2004)6

A training, support and information needs analysis needed to be conducted in order to assist in the development of shared working systems between LAs and the HSE to help meet this commitment. The intention was to identify the requirements local authority health and safety enforcement staff perceived they have, and consider their needs and identify any gaps in terms of support, information and training.

The objectives on support and information were:

• To identify the relative strengths of LA officers and HSE inspectors as enforcers in order to use them adequately for an effective partnership;

5 SITNA stands for Support, Information, and Training Needs Analysis. 6 Local Authorities and HSE working together, LACORS and HSE, 2004.

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• To assess the existing level of support and information received by LA officers and what their needs are in terms of form, content and type of information and support (technical, legal, medical, scientific);

• To advise LAU on the best options to answer business and Health and Safety enforcement needs.

The objectives on training were:

• To explore LA views on priority given to their local health and safety topics and to the HSC’s priority topics;

• To identify training needs and outline options to meet these needs (portfolio of training);

• To evaluate the effectiveness of the training delivery mechanisms;

• To provide guidance to LAs on how to assess training needs and how to access services to meet identified needs.

This report is presented in three parts:

• An executive summary;

• A concise report;

• A detailed Technical Annex.

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2 SUPPORT AND INFORMATION

2.1 BACKGROUND

Support and information mechanisms are considered to identify how these can be best used to support enforcement action by LA and HSE enforcement officers with responsibility for health and safety. The main objective is to describe existing support and information systems, their perceived effectiveness and outline recommendations for improvement. The research questions underpinning this broad objective are as follows:

• To identify the relative strengths of LA officers and HSE inspectors as enforcers in order to use them adequately for an effective partnership.

• To assess the existing level of support and information received by LA officers and what the needs are in terms of form, content and type of information and support (technical, legal, medical, scientific).

• To advise LAU on the best options to answer business and H&S enforcement needs.

Support is considered to be where discretion is used to address an inquiry, and therefore covers:

• Advice from Enforcement Liaison Officers (ELOs);

• Support from Specialist Inspectors;

• Scientific and technical services from consultancies and HSL;

• Medical support;

• Legal support.

Information is considered to be about the provision of material involving no active discretion by the supplier and covers:

• Internet;

• Infoline;

• Intranet/Extranet;

• Planning and Regulatory Services On-line (PARSOL);

• Published documentation.

2.2 METHODS

Regional workshops were held in 4 locations across England, Scotland and Wales. 45 representatives from local authorities with responsibilities for Health and Safety, and 16 HSE specialist inspectors attended these workshops. Syndicate exercises were run at two conferences

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in the Midlands. Figure 2 shows the distribution of attendees by location. Table 1 shows the distribution of attendees across the workshops and conferences.

LA officers at workshops HSEspecialists at workshops EHPs at Midlands Conferences

11 3

15 5

11 3

8 5

55 65

0 10 20 30 40 50 60 70

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Figure 2: Number of LA enforcement officers and HSE specialists per region and event

Methods Sample LA Sample HSE

Structured Workshops 45 16 HSE specialists

Syndicate groups at Midlands conferences answering questions on support and information

120 N/A

Total of research participants on Support & Information topics

181

Table 2: Methods of data collection on Support & Information and sample

The local authorities were formally invited through the Liaison group chairs (see appendix 3 for the invitation letter). This was distributed to all local authorities within the specified geographic region. HSE Specialist Inspectors were nominated to attend the workshop by their Head of Specialist Group.

The workshop started with a brief reminder of the HSC targets and then participants were asked to share and discuss their views on their contribution to the HSC strategy and targets. Other themes were:

• Relative strengths of local authorities and HSE;

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• Enforcement support, availability and access;

• Suggestions for improvement to the provision of information and support.

2.2.1 Midlands Conferences

During the Midlands conferences at Melton Mowbray and Dudley, questions on support and information were addressed to the syndicate groups. Approximately 60 delegates answered the following:

• How can you, as an enforcement officer be effectively supported in H&S enforcement (e.g. all types of support: technical, scientific, legal, medical, etc)?

• How can you, as an enforcement officer be effectively informed in H&S enforcement (e-info, etc.)?

Participants presented their results in a plenary session.

2.2.2 Stakeholder interviews

Various stakeholders were identified throughout the course of this research, including the Partnership managers from HSE, representatives from training organisations and consultancies, solicitors and barristers, professional bodies, representatives of Infoline, NVQ assessors, and academics.

Interviews have been carried out with these on general issues relating to SITNA covering their thoughts on how local authorities will contribute to RHS targets, any problems they perceive with partnership and the ways that local authorities can be better supported. These interviews are used to support the findings from other sources.

2.2.3 Data Analysis

Views on support and information mechanisms, their usage and opinions of them are outlined in the following sections. Much of the discussion centred on a desire for local authorities to be provided with equivalent levels of training, support and information as HSE staff. In particular, enforcement officers want to understand what HSE inspectors use to do their jobs, in terms of, for example, Operational Circulars, guidance, case law, case studies, legal advice, specialist support and colleagues.

Many of the suggested improvements to the provision of information and support are made to address the perception of the two-tier system, where HSE is perceived to be well-trained, well-equipped and well supported.

The results are organised by theme, and the data was organised in this manner. During the workshops consensus between participants was sought, and conflicting views had to be supported. Additionally saturation and recurrent patterning was identified, such that the participants were reporting similar (as opposed to dissimilar) things. Findings from the workshops are presented with other data sources, including stakeholder interviews and previous research. These are then analysed to identify the implications and recommendations resulting from the data.

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2.3 RESULTS AND RECOMMENDATIONS

2.3.1 LAs’ contribution to the HSC’s strategy and targets

2.3.1.1 Findings

Representatives from the LAs cited a number of issues and concerns about contributing to the Revitalising Health and Safety (RHS) targets. Chief amongst these was the fact that LAs are under the charge of local government and are therefore subject to local political agendas. It was their opinion that these local political agendas can be at odds with HSC’s national programme. This was considered particularly the case for the Revitalising Health & Safety targets, as there is no ownership of these or interest in meeting them. Additionally some authorities’ resources are in conflict with other agendas, for example food safety, and public health (e.g. smoking in workplaces).

Concern was also expressed about politicians being more interested in enforcement as opposed to education. Inspection targets were frequently identified on the basis of RIDDOR reportable incidents. The enforcement officers felt that this was not the best policy, and that inspections should not be politically motivated.

Another issue that was mentioned concerned the discontinuity between risk ratings on HSE-enforced and LA-enforced premises. As a result of this discontinuity, their priorities do not match. This was particularly the case for stress, which is a priority topic area for RHS but is not viewed as central to LA regulated premises. In fact the enforcement officers admitted that they had the following problems tackling stress:

• Considered trivial for their premises;

• Difficult to address within SMEs, including a perception that it is not relevant to them;

• It does not appear as a RIDDOR reportable accident;

• Profess to a lack of confidence to inspect on this topic.

2.3.1.2 Implications/Summary

Lack of involvement and consultation in priority programmes and decision-making results in a lack of ownership and commitment to the targets, as HSE and LA programmes are not aligned. This is compounded by the planning cycles not being the same, and consequently HSE targets will not be included during local authorities’ decision-making. Furthermore HSE needs to ensure that their priorities and objectives have the same relevance to local authorities.

2.3.1.3 Recommendations

• See following section for recommendations.

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2.3.2 Relative strengths of LAs and HSE

2.3.2.1 Findings

The next topic addressed the perceived strengths and weaknesses of local authority health and safety enforcement officers and HSE. The views were consistent between the various participants. The strength of local authority enforcement officers surrounds the organisation of their job, including geographical proximity and work organisation. So strengths included:

• Local accountability managed by local politicians;

• Local Intelligence, so understand the local area and local needs;

• Interlinked relationships with other inspectors (e.g. food safety) allowing greater contact with premises;

• Can build relationships with stakeholders and are viewed as approachable;

• Committed staff.

However, many of the cited weaknesses are the converse of their strengths and are linked to limited resources, fragmented approach and the lack of a national agenda. Weaknesses included:

• Limited resources, especially concerning legal and specialist support;

• No national consistent approach to enforcement, each LA works independently;

• Small teams lead to massive duplication nationally, and there is no central support structure;

• Subject to local political interference;

• Their resources can be split and have multiple foci resulting in a dilution of expertise or conflicting demands (e.g. public health, food safety etc.);

• Low risk sites have to be visited because of political targets;

• Lack of consistent approach to officer competence between LAs;

• Limited technical ability and poor access to support;

• Limited experience of health and safety enforcement;

• Public perception that Environmental Health is about rat catching and food safety, with health and safety being the sole domain of the HSE;

• Cascade training is rife and is not an effective way of educating people.

The HSE’s perceived strengths and weaknesses concerned their organisation and the resources and levels of support. Strengths are identified as:

• Excellent technical skills;

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• Experience of enforcement;

• Public profile and acceptance as health and safety enforcer;

• Uniform approach;

• Health and safety is sole focus and hence there are no conflicting demands;

• Good support, resources and information network;

• No local political pressures;

• Committed and dedicated workforce.

Again, many of their weaknesses result from characteristics of their organisation and hence:

• Organisation is constantly changing which makes contacting people difficult;

• Leadership is poor, in particular failing to defend itself when attacked;

• Cover a large geographical area and are not locally accountable;

• HSE is elitist and considers local authorities as junior partners;

• Tend to be feared rather than respected;

• Slow to respond;

• Perception that HSE fails to consult stakeholders on policy and guidance;

• Overly bureaucratic.

One of the key findings during these workshops was the perception by LA officers that compared to HSE inspectors they feel under resourced and under supported. Furthermore, they are not aware of what services are available to them or what is offered. As such, many of the items concern providing and clarifying information, including:

• Clarify the information and relationships between HELA, HSE, LAU, LACORS, HSL, etc;

• Understand suppliers of Scientific and Technology Services, and clarify what expertise is available, how can it be accessed, and what it costs;

• Central database of premises & other information;

• Provision of toolkit, following Food Standards Agency model describing what the law is and how to comply.

During the workshop much effort was put into the ways that partnership can be promoted between HSE and LAs. Central to this was the need for both to understand each other better and

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to this end, suggestions were made to build relationships and promote equality between the services:

• Provide mutual support networks, both within and between the various enforcement officers, for example a buddy scheme;

• Joint working & actual partnership working, including joint visits, joint databases, secondments and peer review;

• Support to implement joint working e.g. lists of companies that are enforced by both LAs and HSE so joint working can happen more easily.

• Develop a culture of mutual support;

• Input into strategy and policy, so that LAs are actively involved in the definition of targets.

Many suggestions were made which would improve the level and quality of service currently offered by LA health and safety enforcement services. Some short-term tactical solutions offered were:

• Better and more sophisticated performance indicators;

• Clarify closed Information and make available to LA officers;

• Develop and provide centralised legal teams for H&S cases;

• Telephone line for emergencies.

2.3.2.2 Previous Research

Howard and Galbraith (2005) found that HSE attitudes towards local authority officers were viewed as the largest barrier to an effective partnership between LAs and HSE.

Continental Research (2005) undertook research for HSE looking at communications and relationships in terms of developing partnership between HSE and LAs. One aspect of this research was enforcement officers’ perceptions of their relationship with HSE. They found that HSE is most likely to be described as ‘knowledgeable’, ‘helpful’ and ‘approachable’, with 80% of respondents describing them as ‘Partners in health and safety matters’. However, just 43% are satisfied with the overall service provided by HSE. Furthermore there is a perception that HSE does not appreciate the pressures of local authority staff, or the local issues and problems, with fewer than 1 in 5 being satisfied with HSE.

Most respondents were aware that the HSE has taken forward initiatives with local authorities, in particular in the areas of Topic Inspections, Statement of Intent and Partnership Managers. Over 9 out of 10 felt they were well informed about HSE plans, and attributed this to meetings, seminars and conferences, material on websites and provision of information. However a third of respondents report that HSE imposes, as opposed to discusses or consults.

There was a variable response concerning the quality of partnership working, suggestions for improvement included:

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• Improved communication/contact;

• More direct/face-to-face contact;

• More joint inspections;

• Work more closely together;

• Listen to councils more.

2.3.2.3 Implications

It was perceived that local authorities have different strengths and weaknesses. One of the challenges of partnership working should be about addressing the weaknesses and capitalising on the strengths. In particular, HSE needs to recognise the strengths of local authorities and work on changing their attitudes to these staff. Previous research suggests that better partnership working will result from good relationships between HSE.



• Identify methods to capitalise on HSE’s support networks to aid local authority Enforcement Officers.

• Consider a radical model for organisation of all of health and safety enforcement officers, with differing roles and responsibilities contingent upon competencies. For example, the strengths of local authorities could lie with education and persuasion, whilst HSE could act as the enforcer / investigator of fatal accidents.

2.3.3 Enforcement Liaison officers (ELO)

2.3.3.1 Workshop findings

There were mixed views regarding the role of HSE’s Enforcement Liaison Officer (ELOs) and the HSE inspector in the ELO post. Typically ELOs act as the first port of call for local authorities in HSE. While some were satisfied with the local ELO, there were some examples where access to the ELO was problematic. Each HSE regional office has different arrangements for the allocation of enforcement liaison. It was not possible to link any comments to the specific arrangements in a particular region. It is worth noting that the Specialist Inspectors felt that ELOs had a valuable role and provided a useful filter between LAs and the specialists. The comments on the ELO, in summary, are as follows:

• Many liaison contacts concern premises and confirming enforcement responsibility;

• ELOs provide reports and give access to specialist groups;

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• The ELO acts as a gatekeeper and some LA officers would like to bypass the ELO if possible. Some already do.

• Not quick to respond –another mechanism to contact HSE in an emergency was required.

Changes requested included:

• Develop a service level agreement with the ELO, to ensure support is given at the right time;

• Back-up ELOs so that cover exists when they are absent;

• Review the effectiveness of the ELO role.

2.3.3.2 Other findings (e.g. stakeholder interviews, Partnership managers’ meeting)

All of those within HSE value the role of the ELO. In particular Partnership managers recognise the key role of ELOs, and state that the quality of the relationship depends on both LA officers and the ELO. ELOs are making efforts to increase partnership working by attending meetings and liaison groups with local authorities. A statement was made about a need for low-level material to be made available through another route, as opposed to time-consuming basic inquiries e.g. availability of guidance.

2.3.3.3 Previous research

McGowan (2005) is considering the access arrangements between LAs and specialists within Specialist Groups, in particular the role of the Enforcement Liaison Officers (ELOs). One of the ELOs main responsibilities is to act as a conduit between local authorities and the HSE’s specialist groups. The main triggers for assistance are:

• Technical advice/opinion outside of enforcement officers expertise;

• Section 6 enquiries;

• Local or national issue;

• Political importance.

Great emphasis was placed on the quality of the relationship between the ELOs and enforcement officers, and the fact that requests tended to be of better quality as a result of the quality of the relationship. The requests for help typically came over the telephone from the enforcement officer, whilst the ELO used the email system to forward help requests on to the specialists. About three quarters of requests were for reactive work to support a fatality or major incident, the remainder was for proactive work e.g. assistance with training programmes. Howard and Galbraith (2005) found that Enforcement Liaison Officers were generally highly regarded. However, their effectiveness depended on the individual appointee and how accessible they were.

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Continental Research (2005) found from their research that perceptions of HSE are more positive when good relationships exist between HSE Enforcement Liaison Officers/Partnership Managers and local authorities. The quality of these relationships and the increased contact that these roles enable has lead to improved communications between local authorities and HSE.

2.3.3.4 Summary/Implications

In terms of support used, most of those involved in the study had contact with their Enforcement Liaison Officer, answering queries on enforcement responsibility and acting as a gateway into HSE for obtaining specialist advice. A number of complaints were made about this role. In part this appeared to be due to a mismatch of perceptions, with an assumption that HSE has unlimited resources and that any support required by LAs can be delivered quickly. Previous research indicates that from the ELOs’ perspective, there are good relationships between LAs and ELOs. The current study found that it is good but changes could be made. Negative views were linked to specific known problems with ELO relationships (e.g. incumbents on long term sickness)


• Explore the roles and responsibilities of ELO. Review their real time activities and determine whether alternative routes could provide lower level activities, such as information provision.

• Continue to build and maintain relationships with local authorities by ELOs attending Liaison meetings and running partnership events.

2.3.4 Technical support from specialist inspectors


Many of the delegates had heard of or used HSE specialist inspectors. They typically accessed them through the Enforcement Liaison Officers (ELOs). On the whole they are satisfied with the service that they receive from the specialists, however they would prefer to have a better route to access them. Typically specialist support was sought for reactive incidents, although also, occasionally on enforcement support. Overall they were:

• Happy with the Specialist Group, but find access hard and HSE’s bureaucracy impenetrable.

• Not aware of the full range of services that HSE offers.

• The most commonly consulted were mechanical specialists looking at machinery design.

• Concerned that they do not always understand the sort of support that they need.

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Access to support was reported as an issue with enforcement officers not adequately understanding the access routes or the financial costs of technical/scientific support.

The following were proposed to address their concerns:

• Develop a service level agreement with the ELO, as support in the past has not always been given at the right time;

• Provide more specialist support to LA officers;

• Provide rapid feedback for urgent cases;

• Streamline access to services;

• Publicise what services are available.


HSE Specialist Inspectors have a fear that Partnership and a review of the ELO role could result in specialist inspectors being inundated and overloaded with requests from local authorities. Partnership managers do not think that Specialists will be overloaded as a consequence of increased Partnership working. Furthermore priorities should be determined on a risk basis, and local authority inquiries be addressed in the same manner.


Little work has been carried out on this topic. Tina McGowan is carrying some work out on the use of Specialist Inspectors by local authorities. No formal record is held of their usage, in fact when questioned Heads of Specialists could only informally estimate the use local authorities make of Specialists. Howard and Galbraith (2005) in their survey found that local authorities generally did not use Specialist Support.


Many of the delegates had heard of or used Specialist Inspectors. Their usual access route was via the ELOs. On the whole they were satisfied with the service that they receive but they would prefer a better access route. Specialists tend to be consulted about major accidents. If local authorities desire greater access to Specialists, this could cause a problem with supply and demand (NB it is worth noting that ELOs and Partnership managers do not anticipate a significant increase in demand). At the moment, internal HSE requests use a risk-based approach to determine specialist work priorities. LA inquiries should be dealt with in the same way and LAs would need to understand this process and the rationale for the prioritisation.



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• Provide Specialist Inspectors reports on previous topics, so that LA officers can understand the type of service they could receive;

• Explore the use of a risk-based approach to prioritise work requests to Specialist Inspectors. Communicate this to all relevant parties.

• Consider developing a service level agreement to help LA officers get support when they need it.

2.3.5 Medical Support


The perceptions of Employment Medical Advisory Service were as follows:

• EMAS are hard to get hold of;

• Confusion concerning LA officers’ ability to contact EMAS;

• Cannot get answers quickly from them;

• Those who had used EMAS were satisfied with the service;

• Some delegates at syndicate groups felt confused between advice they can get from EMAS, NHS or the local GPs and need clarification of their roles and responsibilities.


EMAS has undergone recent reorganisation. Occupational Health (OH) doctors are now in the Corporate Medical Unit (CMU), and OH nurses are within the Specialist Group. The intention being that OH nurses will offer day-to-day operational services and deal with reactive complaints, whilst the CMU will deal with strategy and research and provide a consultant role to the OH nurses (e.g. in-depth medical inspections, prosecution proposals) as required.

From a CMU perspective, local authorities will be addressed as a specific strategic area and they will look proactively at occupational health issues. A strategy will be developed to provide training (via a train the trainer route) and identify high impact enforcement areas. EMAS is moving away from joint visits, as there is a belief that this is not the best policy to look at LAs due to the size of OH services within HSE compared to the large numbers of local authorities.


Occupational health services are not widely utilised. In part participants attributed this to their lack of understanding about the discipline of Occupational Health and Medicine. This is compounded by Local Authorities not typically prioritising health issues, furthermore safety is generally more visible and therefore considered easier to enforce than health.

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• Raise the profile of occupational health/medicine and outline the types of services that can be offered in line with Revitalising Health Strategy targets/topic areas.

2.3.6 Scientific and technical services from consultancies and HSL


Delegates were not very aware of HSL, with only a small number having actually used their services. Consultancies were not widely used either. Typically, HSL was accessed via the ELO and the Specialist Inspector, although one LA had commissioned HSL directly. They reported HSL to be expensive, and delivery not timely although they recognized the work as high quality. In summary there was a:

• Mixed reaction to HSL;

• Lack of awareness of HSL’s services;

• Difficult route to obtaining HSL’s services;

• Perception that HSL’s website was hard to understand, provided no site map, and that it was not easy to match requirements to services offered;

Enforcement officers currently make use of the Internet and the services supplied therein. Some had made use of the research documents published on the HSE website, however they felt that much of this research did not address their needs. Instead they expressed interest in:

• Industrial best practice from LA regulated sectors;

• Samples and examples of enforcement advice, improvement notices and expert witness reports;

• Key information on priority topics;

• Having a categorised index of HSE and HSL research – organised into themes, include expert witness reports, case studies etc. The intention being to provide a one-stop shop in terms of the information requirements for LA officers.

• Provision of safer business packs following the Food Safety examples;

• A directory of topic expertise from both HSE and LAs e.g. agricultural, golf courses.


Howard and Galbraith (2005) found that HSL was not widely used by local authorities.

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Health and safety services commissioned either from HSL or consultants were not widely used. They were not aware of the sorts of services that can be provided, how these can be accessed and how to pay for them. Furthermore, they complained that whilst a lot research has been published by HSE and is available it is hard to find this material, and it is not always immediately clear how much is relevant. There is, therefore, a need to make sure that relevant previous research is accessible and presented in a fashion that is meaningful for LA officers.

Some of these issues are already addressed on the HELA TC website. There is a proposal for HELA TC to be incorporated into the HSE Extranet. There is a need to raise its profile and ensure that research is published in an accessible manner.

Money has been allocated by HSE for local authorities to spend on Science and Technology Services. At the moment, enforcement officers do not appear to be in a position to identify scientific research topics outside of immediate support needs. However, LAU recognises this gap and fulfil this role on behalf of local authorities.


HSL needs to:

• Raise its profile, clarify how its services can be accessed, as well as outline the services it offers;

• In conjunction with this, improve the internet site to contribute to the above;

• Continue its consultation with Local Authority Liaison groups to identify valid and useful research projects for local authorities to commission;

• Carry out a cataloguing exercise to categorise and summarise HSE research and specialist support documents to outline information pertinent to LA-enforced sectors.

2.3.7 Legal Support


Enforcement officers expressed a need for assistance on court cases from legal experts and experienced HSE inspectors. It was commented that HSE inspectors are expected to go to court and therefore have to be competent in this area, whilst local authority health and safety enforcement officers do not often do it. Whilst all local authorities have legal teams, they are rarely specialised in health and safety law. There was a poor knowledge of the HSE’s Solicitors Office. Some LAs did not know if they could use this service or others thought they could not use it because HSE is an enforcer of LAs. The suggestion has been made that there is a central resource for LAs to gain H & S legal advice.

The costs of taking forward enforcement action were also covered, with many enforcement officers stating that they thought a court case would destroy a whole annual budget. Information

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was sought on how HSE budgeted for health and safety cases. Information is also desired on how HSE inspectors take statements, PACE interviews and issue notices and letters.


A solicitor who represents defendants was interviewed. In summary the solicitor’s views were:

• Solicitor involvement means that a third party can review the case (and is the model that HSE now follows);

• Local authorities focus on legislation and specific topics as opposed to holistic risk control.

Jennifer Terry, Assistant Solicitor from HSE’s Legal Advisor’s Office provided HSE’s legal perspective on these issues. In summary:

• HSE cannot offer legal advice to LAs as they are not legally empowered to do so;

• The Enforcement Guide provides information and support on legal enforcement. The intention is that the entire document will be in public domain shortly.

• Currently, an arrangement exists where Local Authorities can obtain closed information from the Enforcement Guide via the ELO.

• HSE funds court cases from local budgets, although there are moves to centralise;

• Solicitors Office would like to support inspectors in terms of negotiating legal fees.

In terms of legal services, HSE could provide:

• A tailored version of Legalade, a bulletin supplied by the Legal Advisor’s Office which provides information on legal issues;

• Provide a list of solicitors providing health and safety services within their area;

• HSE can only use counsel listed by the Attourney General. If LAs are similarly constrained then HSE can inform LAs as to those counsel with health and safety expertise.


Howard and Galbraith (2005) found that HSE legal advice was not widely used by local authorities.

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2.3.7.4 Summary/Implications/Gaps

LA health and safety enforcement services have a number of legal needs. However it does not seem that HSE can help meet these, apart from providing information. In terms of the Enforcement Guide, there was a perception that information is not available, however, the majority of the Enforcement Guide is in the public domain. This should then provide sample letters, notices and protocols etc to follow and support enforcement. From a legal perspective, enforcement officers require support. Methods need to be explored to identify how LA officers can be supported to be more effective enforcers.



• HSE to publish a wider range of sample notices, letters and protocols etc. to support local authority officers in their enforcement activities.

2.3.8 Infoline


Infoline is the HSE’s contact centre operation that is aimed at public inquiries about health and safety. There was a mixed response in terms of whether LA officers actually use Infoline, and how positive they were about it. However, most felt that they would like more information on who is behind Infoline and their level of expertise.


A discussion was held with Chris Mawdsley (HSE Infoline Service Manager) to discuss Infoline and explore the possibilities for providing a service to local authorities. Infoline is supported by a complex knowledge management system, which includes briefings on many topics, question and answer sheets, and all of the HSE’s documents, including the LACs. If an enquiry cannot be addressed through this material then an inquiry is transferred to HSE for resolution. Chris believes that Infoline should be able to address any technical enquiry that local authority enforcement officers have.

2.3.8.3 Background

Infoline is HSE’s Public Enquiry Contact Centre. It is run by National Brittania on behalf of HSE and provides a multi-channel, multi-lingual enquiry handling service. It gives members of the public access to HSE’s health and safety information, and access to expert advice and guidance. It provides a seamless entry into HSE, from the provision of advice through to support from Specialists/Policy if appropriate. Almost 20,000 enquiries are dealt with each calendar month, with email/web/written enquiries increasing in popularity. Customer satisfaction surveys reveal high levels of customer satisfaction. Anonymous surveys reveal that in 2004 over 10% of enquiries came from local authorities/Government Departments in 2004. Infoline deals with over 90% of enquiries. Of the remaining, 5% are forwarded to ‘HSE priced publications’ and 5% are genuine referrals and complaints.

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Infoline was not widely used by our workshop participants. Those who had used it were not overly enthusiastic. In part, this was due to confusion over the service Infoline offers (e.g. it does not provide information on premises or on interpretation of legislation) and concerns over the competency of advice. However user surveys by Infoline suggest that currently LAs do make use of the service and are satisfied with it.

From this research, it seems that a tailored version of Infoline would provide a valuable service to local authority officers. The service would need to be tailored for local authorities, for example:

• Separate number for LA enforcement officer use;

• Call handler reacts in a slightly different manner;

• Could offer a route to ELO following provision of information;

• Provision of LA enforcement officer specific information;

• The benefits of this would be that entry level local authority inquiries could be dealt with by Infoline who could provide local authorities with the correct material, and signpost them to HSE and the ELO.


• Raise profile of Infoline about the competence of staff and service offered, including what they do not do;


2.3.9 Computer-based Information Systems


In terms of information systems, LAs made use of the many services available to them, including:

• HELA Training Coordination website;

• LACORS website;

• LAU website ;

• HSE internet.

Generally the web-based services were poorly perceived with usability, search facilities, pertinence and out of date material being common complaints. Furthermore, there were too

35

many sources providing too much information from disparate sources. The bulletin board facilities were seen as not being relevant and were not used. In fact, on the EHCNet, some enforcement officers reported that the poor content undermined their profession.

However, most felt that some information available at the moment is not adequate (e.g. EMM) and would like access to all the information that is available to HSE members of staff on HSE’s intranet. Their comments included:

• Need to address internet security issues;

• Want more access to information;

• Need a centralised database of premises.

Guidance documents frequently fail to address the needs of LA enforced premises, for example risk assessment guidance is not appropriate for SMEs. Additionally many are available only in one language. Local authorities would like greater consultation on these.

In terms of seeking information many local authorities used Technical Indices (e.g. Barbour Index) to keep up to date on health and safety information. They felt that internal mechanisms for changes to legislation, case law etc relied on inaccurate and unreliable management cascades.

A number of suggestions were made to improve the quality of computer-based information systems, including:

• Development of a common information point – one stop shop, collate various information sources;

• Better search facility on HSL and HSE internet/intranet/extranet;

• Inclusion of sample improvement notices like those in the topic packs, Case Law, best practice on investigations carried out by HSE/LA, case studies and peer review;

• Information should be up-to-date, relevant and easy to access;

• Prioritise important information, as it is possible to be overwhelmed;

• Include discussion groups/threads;

• Give free access to ACOPs/guidance etc.

• Equal access to information available to HSE;

• Provide free access to the material.

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A number of studies have been carried out looking at information provision to local authority officers. The majority of these have been carried out in recent years. Howard and Galbraith (2005) carried out one such study entitled ‘Factors influencing local authority health and safety interventions and enforcement activity’. The study used a variety of methods, including questionnaires, focus groups and interviews and reported findings on support and guidance, and Enforcement Liaison Officers. On support and guidance, questionnaire respondents judged the merits of a variety of materials and guidance mechanisms. These included HSE publications and web-based information. In summary, their findings are:

• Officially published information was valuable to develop good practice and as reference;

• HSE publications were particularly highly regarded due to their accessible style;

• HSE LACs were highly regarded, however concern was expressed about locating them;

• Concern was expressed about methods of updating local authorities on legislation, guidance and initiatives.

Continental Research (2005) carried out a series of telephone interviews with local authority staff with health and safety responsibilities on communication channels. It was found that the following communication methods were used and nominated as most useful in order of preference:

• HSE web-site;

• HELA web-site;

• LAU newsletter;

• HSE guidance & publications;

• Other websites;

• LACORS website;

• Updates from CIEH/REHIS;

• Meetings with PM/ELO;

• Infoline;

• H&S magazines;

• Institute of Occ H&S.

Salford University (Ford et al, 2005) were charged with developing a website for HELA on training and coordination. They recently completed an evaluation of the HELA Training Coordination website using a telephone survey to assess the effectiveness of the portal as a

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knowledge management system for local authority based health and safety enforcement officers. For the purpose of this evaluation, we have summarised the aspects pertinent to this section, namely:

• Usage of the site has increased to approximately 1,800 unique sessions per month from about 500 users;

• Usage of the bulletin board has trebled in use from autumn 2004 to February 2005;

• Over three quarters of users found the website user-friendly and liked the appearance of the site;

• Users were slightly less emphatic about how easy content was to locate (62%);

• A similar proportion found the search engine helpful;

• Almost three quarters of respondents (74%) felt that the portal achieved its objective to improve communications and information flow between LAs on priority topics;

• Four out of five individuals feel that the portal encouraged and enabled knowledge sharing between LAs on health and safety enforcement;

• Areas considered most useful were: topic inspection information, information and knowledge sharing between LAs and HSE; and training materials;

• The majority of respondents found the content of the site was reliable and useful.


Internet based materials was the route most widely used for information provision. There are many sources available to local authorities, including HSE internet, HELA training coordination website, LACORS website, LAU website, EHC Net etc. Most were confused about where to go to get accurate and up-to-date information. Another concern was the provenance of the various sites in terms of accuracy of material. There is a belief that HSE-published material will be accurate. There is a disparity between workshop findings and the KCL, Continental Research and Salford evaluations. Previous research studies identified more positive reactions to computer-based information systems. A number of issues raised in the current study were linked to the unequal information provision, including ‘closed’ material (i.e. that information not made available under the Freedom of Information Act). Many of the other comments concerned tactical improvements to the websites.






• Increase linkages between websites to avoid duplication of material. 38

2.3.10 PARSOL – Planning and Regulatory Services On-line

2.3.10.1 Findings

There was no awareness of this by participants. However, it is reviewed as part of this study as it offers a method for knowledge management and information sharing by local authorities and is considered to present an opportunity to share information between HSE and LAs. A number of stakeholders (e.g. HSE and LACORS) share this opinion.

2.3.10.2 Brief overview of PARSOL

PARSOL is an e-gov initiative to help local authorities develop effective and transparent provision and delivery of planning and regulatory information online to local authorities. The project has developed guidelines, support documents, schemas and toolkits in order to assist local authorities in sharing their information online, without having to bring in expensive and complicated bespoke solutions. These deliverables will be free to local authorities and should help facilitate the government’s target of bringing online access to information and processes in the Planning and the Regulatory Services by the 2005.The project is being financed by the ODPM and run by a consortium of local authorities led by Wandsworth Borough Council (www.parsol.gov.uk).

PARSOL covers the key areas of Planning, Environmental Health, Trading Standards, Building Control and Information Technology. The PARSOL work has been split into 4 streams to make the tasks more manageable and easier for the LAs’ to approach. These streams are:

(1) Accessible Planning Services – to provide assistance in offering online planning services to the mutual benefit of citizens and LAs. Includes:

Expert System Advice, Agent Certification, procurement, design and construction;

Enforcement.

(2) Interactions, Standards and Toolkits – this area focuses on the development of the tools and guidelines required to set up the online planning processes and ensure its continued success. Includes:

Best practice review;

Service delivery, standards and toolkits;

Consultations and negotiations;

Development plans and community strategies;

Coordination of monitoring to inform policy;

Baseline survey and PPA website review.

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(3) Technical Infrastructure – this activity focuses on setting the benchmarks and criteria for the technical infrastructure, which will provide the appropriate service. Includes:

Extranets;

XML schemas;

Knowledge management.

(4) Regulation and Licensing – this area is focused on providing appropriate tools and benchmarks in the enforcement of Regulation and Licensing arenas, e.g. environmental health and trading standards etc. Includes:

Linking external agencies;

Enabling business self assessment;

Regulation and licensing online;

Information users.

PARSOL’s aims are to:

• Help deliver consistent and accurate planning and regulation advice, information and online services to all sectors of the community and business.

• Assist LAs in the development of online application forms for Planning, Trading Standards, Environmental health and Building Control for use in 2005.

• Encourage the flow of information between LAs and National Agencies, e.g. IDeA (Improvement and Development Agency), The Environment Agency and HSE.

• Provide businesses and individuals with a single information repository covering aspects of property related regulation and guidance.

• Help LAs to deliver efficiency, service provisions, faster interaction and government targets.

2.3.10.3 Who is involved in PARSOL and what does it provide?

The PARSOL project has been set up to focus on the development of online exchange of information between LAs and the public. This shift towards online systems for providing information and interaction is in line with the Government’s e-gov initiative. The aim is to improve openness and the flow of information to the public and to follow guidelines that state that local authorities must have a wide range of services online by 2005.

PARSOL products have been created and developed by a group of LAs led by Wandsworth Borough Council for the benefit of all LAs across England. All LAs in England will have access to the tools and guidance on offer to help them meet the challenge of e-enabling their priority services by 2005.

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The PARSOL project has developed a number of deliverables, which are separated into the 4 streams, each of which offer 4-6 products or materials. These include information on Best Practice, Service Delivery Standards & Toolkits, Extranets, Knowledge Management, Enabling Business Self-Assessment and a number of other areas.

Where possible, PARSOL’s work involves hosting implementation workshops, priority services workshops and provision of accredited consultancy in order to assist the LAs in meeting the standards and deadlines.

The delivery of the PARSOL products is organised into three areas:

• PARSOL exchange for planning applications and local development plans;

• Enhanced LGOL.net messaging Middleware;

• Service Implementation Toolkits.

Further details about PARSOL and other HSL research is detailed in the Appendix 8.


Support for the PARSOL project already comes from many governmental departments including IDeA, LACORS, the Planning Officers Society and the Environment Agency. There are a number of possible benefits to HSE from supporting PARSOL. These include:

• Using PARSOL as an arena for passing H&S guidance and enforcement information on to the LAs and the public.

• Working with and supporting those LAs developing their online services will enable HSE to quality assure the H&S guidance to be incorporated.

• Through involvement at the development stage HSE had an input into the format of some areas of PARSOL.

• Closer working with LAs within an arena that they have developed will help achieve the HSE ‘LAs and HSE Working Together’ strategic programme.

• Efficiency gains from easier transferring of information.


• PARSOL needs to be considered as a potential mechanism for the provision of information share networks to local authorities.

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3.1

3 TRAINING ANALYSIS

BACKGROUND

In the past ten years, a number of studies have been conducted on training systems within local authorities. Some studies looked at the level of competence of LAs’ enforcement staff, the amount of training received and best practice within LAs. The study from Prince, Campbell, and Nanton (1995) of the Institute of Local Government (INLOGOV) indicated that training was given in a fragmentary manner, lacking co-ordination and integration. It was argued that this was partly due to the concentration of responsibility to identify training needs and their implementation, onto individuals within departments, rather than at the departmental level. There was also an over reliance on ad hoc and ‘unfocused’ induction procedures, and discredited cascade training methods. It was argued that the local political context was part of the problem dictating internal priorities. This study was later criticised for having a weak methodology that could have biased the results (CIEH letter, 1995).

Two years later, the situation within LAs is described more positively by Garton (1997) who found that ‘elements of good practice in health and safety enforcement, competence, consistency and training existed in parts throughout the country’. Some LAs had developed their own competency framework detailing the core and functional competencies needed in an enforcer role. Using a quantitative methodology, the report indicated that among the 247 authorities that responded to a questionnaire, 88% had a system in place for identifying training needs, 68% a training programme or action plan to prioritise training, 58% operate a system of cascade training to relay information, 57% had a system in place for evaluating training received. In addition some authorities had quality standards in place such as: Investor in People, Quality Management manual, ISO 9002. One of the main conclusions was that best practice should be applied where needed.

Wilson (1998) provided a very detailed competency framework that could be used for training, development and assessment of enforcement officers.

In parallel, another series of research studies investigated what type of organisation and support for training can be offered to LAs at national level. Ford and Green (1996) identified how a national training strategy and plan for Environmental Health Services (EHS) could be implemented. Having done an extensive consultation of main stakeholders (universities, professional bodies such as CIEH, REHIS, HELA) on the recommendations from the 1995 INLOGOV report, the authors suggested, among other things, the creation of a central management training unit, national and regional training user groups; a procedure for individual needs analysis and performance; a monitoring and review procedure that leads to the modification of the training strategy and training plan as necessary.

In 1997, the HELA training strategy was launched. This included a proposal for the national coordination of training and development activities. Between October 2000 and January 2001, another nationwide consultation exercise carried out by HSL led to the construction of the HELA website, developed and hosted by Salford University, to facilitate the co-ordination of training.

Casstles, Ford, Murply, Green & Rennie, (2000) used 12 case studies to investigate the organisation of training, budget allocation and training needs, training methods and evaluation. They also evaluated alternative types of training including three computer-based trainings (CBT) that were on floppy disc, CD-ROM and Internet. Twenty-three LAs were involved in the study and 96 trainees. Compared to a control group, those who use the CBT were more

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successful in knowledge acquisition. However, among the issues preventing successful training were the lack of suitable IT equipment, lack of support and computer literacy. This research provides some useful recommendations for a successful use of CBT within LAs. To assist line managers in LAs in managing H&S inspector training, the authors provided a comprehensive training guide that was distributed to all LAs in 1998. It had a step-wise approach to managing training including: identification of training needs; planning and design of training; implementation of training and evaluation of training.

More recently, a research exercise carried out by Howard and Galbraith (2005) from King’s College London, identified a number of factors influencing enforcement activities within LAs, including training, support and information. Findings show that a large majority of enforcement officers thought that the HSC Section 18 guidance provided an effective framework for LA health and safety enforcement. However, some stated that this section should be more specific and detailed. This would lead to greater consistency regarding the competence of inspectors. The most popular training materials were the HELA website, the guidance on topic-based inspections, and the EMM tutorial package. Video packages and CD-ROM and web-based materials were not viewed favourably. HSE training packages were perceived well especially the Slips and Trips road shows and the topic inspection training.

In reviewing this body of knowledge, it can be concluded that there are mechanisms in place to identify training needs (e.g. appraisal system, competence frameworks). There are effective and perhaps less effective training solutions to answer training needs. There are some benchmarks used to evaluate training practice in some LAs such as IiP. There is information available to support decision about training (HELA website, training guide for line managers). What is less obvious is to what extent LAs and those receiving training perceive the effectiveness of the current training system in maintaining their standard of competence and how it can be improved in light of the new partnership with HSE.

3.1.1 Objective of the present study

The objective of this part of the study is to describe the existing training system and the interconnections between the components. For example the identification of training needs cannot be taken in isolation but needs to be linked to LAs goals, and the needs themselves should be included in a training plan, etc. Starting at the organisational level, we will look at how the goals and priorities of LAs link to training provision. Then how the training needs are identified followed by how well these needs get answered (type, methods of training, etc). Finally transfer of learning to the workplace and evaluation mechanisms will be looked at. A conceptual model (figure 2) will help to capture the different components of the training system. This model is derived from the National Standards for Training and Development (Reid and Barrington, 1994), the Human Resource management literature in general (Cole, 2004; Arnold, 2005) and previous studies on training within LAs.

Organisational health and safety strategy and priorities of LAs are important to identify, as training and development should ideally contribute towards their achievement. For example:

• Are the HSC priority topics (e.g. slips and trips, falls from heights, etc) part of the targets LAs want to meet or do they focus only on local targets.

• What proportion of time and resources is dedicated to Health and Safety as opposed to Food Safety and Hygiene.

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If enforcement officers do not carry out Health and Safety work on a regular basis, training them could be a waste of time and money as it is well established in the literature that learning decreases with time and with no opportunities to apply it. The priorities therefore will impact on the human resources planning stage (how many people to recruit, train and develop and in which domain). Usually, each LA has a service plan detailing their goals, objectives and targets for the year from which training needs can be derived.

An annual training plan will collect all the individual training needs from the whole department and help to monitor activities and budgets. It is therefore important that LAs have some similar documents or mechanisms in place. A detailed training plan might encompass the following elements: What training is to be provided? How? When? By whom? Where? At what cost? (Cole, 2004).

An annual performance appraisal interview between the line manager and each enforcement officer will assess the level of competence attained and the related training needs. In HSC Section 18 guidance, note 6, it is stated in para 5.8 that HSC recognises the health and safety regulators N/SVQ as a means of demonstrating the achievement of the necessary standards of competence but that internal performance appraisal system is another means of demonstrating it. Therefore if LAs do not have a N/SVQ system in place, they would need to conduct regular appraisal interviews to assess competence levels. If LAs have a competency framework in place the exercise of assessing competence and determining training needs will help them greatly. Continuous Professional Development needs could also be monitored through this interview.

Data on training needs to inform the training plan and later on the training objectives and content can be sought at four levels as follow:

• Organisational: Examination of organisational/departmental goals as described in the service plans, HELA work plan, new legislation, technical updates, all need to be translated into training needs.

• Group: Analysis of competences (e.g. knowledge, skills, attitude, experience and other) needed for a given role (EHOs; non EHOs) level of responsibility and range of powers, leading to appropriate training needs for each role.

• Individual: Analysis of the competence of an enforcement officer and personal training needs through performance appraisal interviews and on going dialogue with the line manager. Reviews of legal notices, inspections forms, accompanied inspection or post inspection audit, peer review can also help in assessing individual’s needs for training and development. These reviews would need to be undertaken by managers who were themselves competent.

• Competence standards: HSC Section 18 guidance lists the core competencies for Health and Safety enforcement. These are national occupational standards and expressions of measurable outcomes of competence. Also professional bodies such as the Chartered Institute of Environmental Health (CIEH) and the Royal Environmental Health Institute of Scotland (REHIS) not only offer pre-entry qualifications (diploma, degree) but also post-entry mechanisms (e.g. Continuous Professional Development) for demonstrating professional competence.

Section 18 guidance Note 6 states that ‘the HSC expects enforcing authorities to satisfy themselves that all inspectors either have adequate standards of competence in all the relevant

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areas listed in Annex 2 or are subject to adequate and appropriate supervision by other inspectors who do possess these standards’.

Methods of training have to be chosen according to several criteria including costs and benefits, resource availability, media (classroom type, e-learning, videos, road shows, etc.), training methods (role play, case studies, etc.) and learning preferences (practical vs. theoretical).

Training transfer occurs when new learning acquired during training is used in new settings (e.g. on-the-job). It is linked to how relevant the training content was for participants in their job but also to how much feedback and opportunities for practising their new skills they receive after the training session. Activities to help training transfer can be joint visits, coaching, mentoring, group discussions, etc.

Training evaluation assesses the effectiveness of training and the attainment of individual achievements against objectives. Training is often evaluated at the end of a training session gauging the trainees’ reaction only and this gives a partial picture of the effectiveness of a training. A full training evaluation would include pre and post measures to confirm changes in learning or performance behaviour. It can be done by examining trainees’ reactions, but also individual learning, behaviour change and contribution to overall (departmental) performance improvement.

The main components of the training process are shown in Figure 3 and discussed in the results section.

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(planned or

• Organisational • Group • •

Methods • Cost & benefits of

• • •

• Video-training packages

• E-learning media (

•

• Road shows • EMM tutorial

package • Etc.

1. LAs’ organisational strategy in relation to training

& CPD needs)

4b. Define Training

4. Training needsunplanned) at 4 levels:

Individual Competence standards

5. Evaluate Training training delivery methods Resource availability Methods and learning preferences

Classroom media

CD-Rom and web based materials) Guidance on ‘topic based’ inspections

2. Annual training plan

7. Training Evaluation

(LA service plan, budget, Communication channels, etc)

(incl. Organisational/Departmental training needs)

6. Training Transfer (Joint visits, mentoring, coaching)

3. Performance Appraisal (incl. Individual training needs

4a. Determine Training requirements

objectives & content

Figure 3: Main components of the training process

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3.2 METHODS

A variety of methods have been used to collect information on the current management of training and potential improvements. This ensured that the data gathered was unbiased and balanced different perceptions. Interviews with senior staff were needed to identify their perception of the whole system of training including the organisational training needs. Focus groups, syndicate groups and questionnaires used with enforcement officers were designed to obtain their views on the whole system but more importantly to tap group training needs.

The overall number of LAs involved on all topics including training, support and information is 143. This represents 35% of all LAs across the regions and therefore provides an adequate representation of the overall profile. Table 3 and Figure 4 show the breakdown of the overall sample and the methods used to gather data more specifically on training.

Methods Sample Interviews 20 LAs senior staff Focus groups 60 enforcement officers through 7 focus

groups Questionnaires Among 60 enforcement officers attending

focus groups, 59 completed a questionnaire Syndicate groups at Midlands conferences 70 out of 190 delegates answer the question on

training Total of research participants on training 150 enforcement officers

LA senior staff Interviews LA officers at Focus groups LA officers at Midlands Conferences

Table 3: Methods of data collection on training and sample

20

16 17 15

12

40

30

0

5

10

15

20

25

30

35

40

h)ns n) y) y)s) ) eo iff ago d d brur dld eegi b aron C uw

ssre L Dn

MoL ( (di (( re es

dsEE io h n(E- alcr ntoks d lal& Wa n eE, dor aAs M

E & WMitlS- Y co (L

E & W dsh, S S-ut nN- laSo dW,

E & WMi

N-

Figure 4: Number of LA participants per region and event on training

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3.2.1 Interviews

Semi-structured interviews were conducted with Heads of Environmental Health or Health and Safety Specialists except one with a senior EHO, in 20 LAs (see table 4) across England, Scotland and Wales (Fifteen, two and three respectively) to assess training practice at organisational level. The LAs were chosen to ensure a geographical spread and a mix of size and types (unitary, district, metropolitan, London Borough). Appendix 2 includes the interview schedule used as a basis for discussion. Interviews were conducted mostly face-to-face and lasted between one and two hours. In addition, evidence was gathered by inviting LA officers to provide any document related to their organisational targets, competency or training.

Local Authority Type Number of LA officers interviewed

London Boroughs 2 Metropolitan Districts 2 District Councils 7 Unitary (England) 4 Unitary (Wales) 3 Unitary (Scotland) 2

Table 4: Composition of the interview sample

3.2.2 Focus groups

To identify training needs at a group level, 7 focus groups have been carried out on training in four locations covering the following regions: i) South, South East and East of England, ii) North-West and North-East & Yorkshire, iii) Scotland and iv) Wales and South-East of England. These were held in London, Leeds, Edinburgh and Cardiff. An invitation letter was sent to the chairperson of each liaison group inviting them to forward the letter to their respective LAs (Appendix 3).

The focus groups on training were attended by 60 enforcement officers across the regions. Almost 80% of them were EHPs, the remaining were TOs and one Technical Assistant (TA). Three quarters of them declared working on a full time basis on Health and Safety. Each focus group lasted three hours and explored the components of the training process with particular focus on competency, training needs, training methods and evaluation (see focus guide in appendix 4).

3.2.2.1 Questionnaire

Focus groups participants completed a questionnaire (see Appendix 6) on the skills and knowledge used by enforcement officers and the amount of training and information received on these. A total of 59 questionnaires were completed. This questionnaire was based on the HSC section 18 guidance annex 2 and was used previously to define HSE inspectors’ role specifications and training. In its full version, this questionnaire has two parts, one asks about generic skills and the other technical/enforcement skills and knowledge.

It was judged appropriate to use the technical/enforcement part only due to time constraints andthe fact this was a research rather than an evaluation study.The questions were split into 6 sections:

• Section A related to the inspection process

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• Section B to investigations • Section C to gathering evidence • Section D to enforcing statutory provisions • Section E to presenting guilty pleas in Courts (except for Scotland) • Section F to drafting and serving notices

3.2.3 Syndicate groups at conferences

The Midlands region had two conferences organised at Melton Mowbray and Dudley to share information on various topics. After discussion with the Partnership manager of that region, it was agreed that questions from the SITNA study would be asked of the enforcement officers attending the conferences through syndicate groups. Therefore no focus group or other events were held in this region. Around 190 participants attended both conferences and were split between 10 or 11 syndicate groups to answer a question either on training, support or information. A total of 70 people (7 groups x 10) gave their views on training, answering the following question:

• How can you, as enforcement officer be effectively trained in H&S enforcement (e.g. types and forms of delivery).

Participants discussed this topic in syndicate groups and presented their findings in plenary session. Although some enforcement officers of this region were promised, during one of the conferences, an additional workshop with HSE specialists to share views and experiences, this could not be arranged due to the lack of time but their request has been made part of this study’s recommendations.

3.2.4 Stakeholders consultation

Various stakeholders have been identified and interviewed throughout the course of this research, including the Partnership managers from HSE, representatives from training organisations and consultancies, solicitors and barristers, professional bodies, representatives of Infoline, NVQ assessors, and academics. Their views have been taken into account in the conclusions of this report.

3.3 RESULTS

3.3.1 LA organisational strategy in relation to training

3.3.1.1 LA goals

Most senior LA staff indicated that they had organisational targets set in terms of health and safety. Sometimes there were targets but not specific to health and safety. The targets were often detailed in the annual service/business plans. Several LAs used Section 18 guidance or information from the HSE to set the targets, whilst others referred to internal factors such as previous performance. The types of targets included the number of inspections (which may not be specific to health and safety) and to a lesser extent the reduced number of accidents.

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3.3.1.2 Priority given to Health and Safety

It was acknowledged that health and safety enforcement was generally given a lower priority compared to other topics, in part due to lack of resources or competence of officers and the emphasis placed on food safety. It was explained that the Food Standards Agency (FSA) sets national performance targets for food safety and require reports and audits. No similar system for health and safety exists. Another reason given for its lower priority is because local employers did not understand it as much as food safety and the public do not complain about it as much. Health and safety was also seen as ‘wordy’ and imprecise and difficult to define.

However, it is worth noting that some believed health and safety was given equal priority to, for example, food safety. They even felt the priority given to health and safety was increasing. The reasons given for the latter included the relaxing of objectives set by the FSA, allowing more time and resources to be dedicated to health and safety; or in one particular LA the result of a successful bid for more resources.

3.3.1.3 Priority given to HSC/E priority topics

The majority of LA officers interviewed stated that they followed either all or some of the HSC priority topics (e.g. stress, slips and trips, falls from heights, workplace transport, etc) in their inspections and work programmes. Slips and trips topic was the most common. The focus is also on sectors, local issues or specific topics. It was argued that it was easier to do more inspections in the same sector once officers had gained knowledge and skills in that sector. When low priority was given to HSC’s priority topics it was because they were judged irrelevant, e.g. to rural areas, or that senior officers within the LAs were not aware of them.

3.3.1.4 Annual training plan

As defined earlier, a training plan might include what training is to be provided? How? When? By whom? Where? At what cost? Over half the LA officers interviewed stated they had annual training plans developed on the basis of the performance appraisal, whilst one third did not really have a formal annual training plan but collected individuals needs when they were raised.

3.3.1.5 Budget

Training budgets and the way they were allocated varied greatly between local authorities. Half stated that their training budget was for the whole team/department, whilst others were allocated a specific budget for each individual. Many considered the money allocated to be insufficient. Further additional constraints such as travelling expenses and resource issues were mentioned. In consequence cascade training was frequently used as a way of providing staff with new information. A few commented that they receive few requests for training because of their experienced staff base.

3.3.1.6 Training provision

Training needs were determined in various ways, and included: • Did they meet the business plan;

• Did they meet HSE issues;

• Who was providing the training (e.g. internal or external).

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Attendance on a course depended on whether there was sufficient cover; and whether an individual particularly needed the training.

3.3.2 Performance appraisal

3.3.2.1 Individual training needs

The most common way of assessing training needs was through appraisals in addition to ‘chats’ or discussions in team meetings to identify any problems that could lead to training needs. Several LAs have put a lot of effort and time to create their own competency framework to assess competence and this was often developed with their local liaison group. Some competency frameworks that were given to researchers as supporting evidence were of high quality and commendable.

For example, the competency and training matrix of one LA, was specific to health and safety. It sets out the competencies officers need to carry out their health and safety duties. A matrix indicates at what stage in their employment officers should achieve these competencies such as ‘on appointment’, ‘after 6 months experience in H&S enforcement situations’ etc. It also indicates what kind of training would be needed to achieve competence such as ‘in house training’, ‘individual research’ or ‘external training’. The matrix contains ‘key activities’ and is broken down into detailed units of competence.

Inter-authority audits, peer review or joint visits with other officers were also cited as ways of assessing the competency of individuals. These produced action plans for development and improvement but in some cases it was only done every five years.Or others commented that inter-authority audits did not identify training needs.

However, an example of inter-authority audit provided for this study by one LA was to be carried out annually by another authority in the region. It included a pre audit questionnaire which requests a number of documents to be sent to the other authority; audit assessment notes which have a list of criteria and space to write comments or note evidence, it also has a best practice section; audit report sheets which ask for marking of the criteria and comments. The areas marked include ‘evidence that authorisation is linked to competence’, ‘arrangements for assessment of competence’, and ‘arrangements for the maintenance of competence’. There is also an audit action plan for competence and training that should refer to the points of nonconformity.

In general, training needs for officers following an induction programme or for those officers pursuing Continual Professional Development (CPD) were collected. In some locations, an individual’s competence and training needs were assessed on the basis of a senior person’s (e.g. the Principal officers) judgement, or when individuals’ correspondence with businesses was reviewed or on customer feedback.

However, a few felt they did not have a clear method of assessing individuals’ competence, and commented that this was partly as a result of a lack of guidance from the CIEH on whether they needed to have an NVQ level 5 on health and safety. Some had been waiting for something to be developed by the HSE. Some LAs found it difficult to assess technical training needs.

In addition, a number of LA enforcers during focus groups described their training needs analysis as not being very structured and training as being opportunistic. It was explained that if once a year there is an opportunity to collect training needs through a performance appraisal interview, very often there is no fund to provide the training.

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3.3.2.2 Group level training needs

To act as a warm up before having a focussed discussion on training, and to understand what skills are frequently used in their job, what training/information already received, participants were invited to fill out a questionnaire. A total of 59 questionnaires were completed across the regions (except the West and East Midlands region). The respondents’ profile is shown in figure 5 and 6. There were 45 EHPs (78.9%), 10 TOs (17.5%) and 2 TAs (3.5%). Some participants did not identify their job position. Forty-two of them (75%) worked full time on Health and Safety while the remaining 14 (25%) worked on other topics as well as on Health and Safety such as food safety, infectious diseases, licensing, animal welfare, pest control, etc. It is worth noting that even those who reported to work full time on H&S worked on other topics.

0

2

4

6

8

10

12EHPs TOs TAs

re nd Wan

d ksh

i S-lagl otn ndE Yor Sc a

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Figure 5: Profile of questionnaire respondents per region and job position

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35

30

25

20

15

10

5

0EHPs TOs TAs

Full time on H&S Part time on H&S

Figure 6: Profile of respondents per time spent on H&S

Data were processed using Excel and SPSS. Analyses of Variance (ANOVA) shows no statistical differences per region or per status except on section D where TOs use less frequently the skills on enforcing statutory provisions than EHPs. This result would be expected, as this activity is not part of the role of TOs.

There were some differences between respondents working part time and full time on health and safety. Full time respondents perceived the health and safety inspection activities (section A) as being more important and more frequent in their job. Also gathering evidence (section C) was seen as more important than it was for their colleagues working part time. These results could be expected as those who do not work full time on health and safety have other priorities.

Correlations analyses were also performed on the data and indicate positive correlations between importance and frequency in all sections (i.e. the more important a skill was perceived, the more frequently it was used), except on drafting and serving notices (section F) where no correlations were found. Only on investigations (section B), was there a positive correlation between frequency and training, i.e. the more frequently the skills or knowledge on investigations were used, the more training respondents said they had received in them. These findings were not found in other areas and suggest that factors other than training influence the use of skills.

A large proportion of respondents (more than 50% on all questions except one) felt that skills and knowledge were extremely or very important in their job. However in activities related to enforcement of statutory provisions (section D) and presenting guilty pleas in Magistrates Courts (section E), those skills although important were used infrequently and respondents declared having received little training in them. These results are not surprising for section E as LA officers do not present their own cases in court. However, section D is important as LA officers do prepare prosecution files. Many enforcement officers might have difficulty in accessing training and then maintaining competence in the less frequently used areas. This could be particularly true of major accident and incident investigation (B), evidence gathering and management (C), and preparing prosecution files (D).

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It is important to note that section A (inspections) and section F (drafting and serving notices) are generally satisfactory. It is only when around 40% of respondents claim to have had little or no training or information in what is seen as fundamental and frequent aspect of an officer’s work that attention should be drawn.

Training needs were subsequently explored in the focus groups and confirmed some of the results obtained through this questionnaire. For example perhaps more training is needed on questioning and listening skills (Figure 7) as shown in the figure above as among EHPs, forty per cent (22 out of 45) of them reported to have received little or no training.

0

10

20

30

40

50

60

70

80 Very/A lot Moderate Little or No

IMPORTANCE FREQUENCY TRAINING INFORMATION

Figure 7: Percentages of respondents for the question ‘Use questioning and listening skills to obtain information’ (B10)

However on another question such as preparing an investigation report (Figure 8) below, the low level of training (48% overall have received little or no training) might be interpreted in light of the frequency to which this activity is performed. Only 50% do prepare frequently an investigation report. Correlations analyses indicate that frequency and training are linked i.e. those who prepared investigation reports did receive training. Only 11 out of 45 EHPs (18%) reported having received little or no training.

0 10 20 30 40 50 60 70 80 90

100

IMPORTANCE FREQUENCY TRAINING INFORMATION

Very/A lot Moderate Little or No

Figure 8: Percentages of respondents for the question ‘Prepare an investigation report’ (B16)

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3.3.3 Limitations of the findings

The number of enforcement officers answering the questionnaire is too low to generalise the findings across all LAs. A larger sample would help to validate these findings. Further investigation between the line manager and each enforcement officer is needed to confirm training and information needs on each skill and knowledge. To do so, the full detailed survey is provided in appendix 6.

The present results do not necessarily reflect the level of training actually provided by LA's, but are a reflection of individuals’ perceptions. Some individuals might have received training in the form of in house training or as part of a larger course and therefore do not recognise having been properly or fully trained in these areas. Also a reason for mentioning no or little training could be because the skills have lapsed through lack of use and individuals therefore might not remember training received. Some of the skill areas may have not been fully understood by some respondents leading to somewhat erroneous results or do not necessarily require training as such as it can be acquired through experience or coaching, therefore a dialogue between the line manager and their enforcement officers will allow these perceptions to be examined.

Previous research in private sector industries shows that what drives training depends on the approach of the company towards training. In traditional establishments, it is largely a response to external pressures. In modern organisations, where there is a more systematic identification of training needs and training provision, training is the response to internal changes such as new technology and new working practices in addition to external pressures. It is often associated with a competence-based approach to the analysis of training needs. These approaches to training will impact on the type and amount of training undertaken. Training levels are often linked to flexible or high performance work practices. For example practices such as changes in the design of jobs toward greater complexity, higher skill levels and greater use of teamworking, increased delegation of responsibility and more effective communication lead to the provision of formal training programmes and higher levels of training received. A high commitment to training is generally associated with strong commitment of senior management to training and development, with industry sector, pay linked to skills, structure of the personnel function (Storey, 2001). What LAs might want to foster is a learning organisation type of culture and not solely providing a certain amount of training without changing the work practices (e.g. increasing delegation when possible, coaching, mentoring, using of variety of learning methods, etc).

3.3.4 New skills to develop

To the question as to whether they would have new skills to develop in the future, some enforcement officers stressed very strongly that they do not need new skills, but that LAs should give them the opportunity to practise their knowledge and skills on Health and Safety. These individuals currently do not apply them, as they are required to work on food regulations or other areas. This has implications in terms of the competence of local authority enforcers, as training alone does not provide competence. Competence is a blend of training and practice, as well as some assessment to ensure that an individual reaches the standard to be deemed competent. Due to the way that work is organised within local authorities it may be that it is not cost effective to provide high levels of technical skills to all enforcement officers within LAs, as they may not have cause to use these skills regularly.

Others suggested that the new skills to develop would be the core skills similar to the ones HSE inspectors are trained in. Some of these are the skills related to the five-topic areas (e.g. stress).

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Also as part of the new partnership, it is suggested that HSE acquire the understanding of how LAs work (e.g. not practical for LAs to sign up for events), the process of dealing with intermediaries and partnerships (no training or manual is said to be given on that). Finally as new skills, the NVQ5 is seen as a requirement for LAs to adopt to gain the same level of competence as HSE inspectors.

3.3.5 Topic training needs

The key training needs of enforcement officers elicited from the focus groups (not the questionnaire which was not analysed at this point) are summarised in the table below.

Knowledge and skills Training needs Key priority health and safety training needs

Generic skills Communication Interviewing and PACE Negotiation, influencing skills Assertiveness to be able to confront issues with duty holders Dealing with the public on the telephone and being able to calm people down and re-direct to suitable channels Project management Peer review training Letter formats Business acumen to be able to address senior management at premises, to address the boardroom (need to convince that H&S is money well spent). Understanding of financial and regulatory burdens on duty holders,i.e. NI, tax, staffing, etc.

Legal knowledge and gathering evidence

How to do a guilty plea How to take a statement Be an expert witness in court How to gather evidence Prepare cases for court Explain that cases take time – legitimacy of evidence –Coroners court is said to be difficult to explain to lay person. Regular/Continual updates 2 to 3 years changes/ legislation Use of mock up of courts with a barrister to provide training Make available previous cases/procedures set under simple headings easy to navigate system for looking at case law.

Priority topics skills HSE Priority areas topics Technical updates in relation to slips and trips Falls from heights (It is said to be currently misunderstood. Would like to work with HSE on this)

H&S management issues

Accident/fatality investigation Risk assessment (what works, what does not work) More training on HSG 65 especially safety management systems Evaluation management systems in relation to contractors How to apply EMM The ‘ powers of inspectors’ (mentioned by some)

Other health and safety training needs

Specific expert Botox Body piercing branding,

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knowledge Legionella Asbestos New area of regulation (e.g.Petrol stations) Tyre and exhaust Manual handling Electricity

Partnership Working in partnership behaviours Training on how to assess HSE and get information Other trainings How to deal with request for disclosure

Freedom of information, Data protection Race relations as a regulation Duty to report racist incidents. (Some say that information is provided on the latter but not tailored to their needs)

Table 5: Training needs from the LA focus groups across the regions (N=60) and conferences in the Midlands (N=70)

The key training priorities including HSC/E priority topics, interviewing skills, and legal knowledge match the results of a quantitative training needs survey done at the same period by the North East and Yorkshire region. The 10 most important training needs found are presented in table 6 below. The results are based on 48 respondents from 23 LAs in this region.

Workplace transport Slips and trips Musculoskeletal disorders

Advanced interviewing skills – PACE

Work related stress

Falls from a height, Work at Height Regulations

Principles of electrical safety Case management – assessing the prosecution case Evidence management

Investigative interviewing – PACE

Table 6: Top ten rated training needs in the North East-Yorkshire region (N=48)

3.3.6 Competence standards levels

3.3.6.1 Ensuring consistency across LAs and the HSE

More than half of the 20 LAs interviewed thought it was either important or very important to have similar competencies between LAs. Several reasons were such as:

• large companies expect consistency not just between LAs but also between LAs and HSE in terms of the questions they ask and the way they inspect.

• demonstrate to duty holders that LAs have competent officers.

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However, some commented that they were already comparing competencies with other LAs through for example, inter-authority audits, or through the liaison group. A formal quality assurance process, such as ISO 9000, was thought to ensure consistency. Finally, topic based inspections were seen as a way to increase consistency.

It is worth noting that sharing competencies between LAs was felt not to be an easy task by some staff, partly as a result of poor communication between larger LAs or the dependence on liaison group members. The appropriateness of giving enforcement officers to issue national warrants without ensuring their competence first was questioned, as in the commentator’s view, competence was considered to be the main reason for lower performance.

3.3.6.2 The NVQ as a standard of competence

A number of enforcement officers sought a debate as to whether the NVQ level 5 should be adopted by all LAs or if a nationally recognized qualification route backed by a mandatory national guidance (e.g. section 18 guidance with a Continuous Professional Development) was needed. Another suggestion was to perform a gap analysis on the level of entry in the profession between LA and HSE to ensure competence and consistency. It should be noted that the gap analysis was recommended by Wilson (1998).

In 2004, CIEH, after extensive consultation, introduced a new core curriculum, which has now been adopted by all the accredited universities. The Honours degree enables the student to develop reflective learning skills through a process of academic and theoretical study and work based learning through the Experiential Learning Portfolio (ELP). Which provides a benchmark against which the student develops a range of embedded and transferable based on reflective learning .The ELP health and safety matrix provides a good assessment of competency at that stage. However, this does not provide a basis for on-going on-the-job professional development and competence assessment.

3.3.6.3 CPD

It is the individual responsibility of enforcement officers to maintain their own professional development, for chartered members of CIEH and REHIS this involves the collection of Continuous Professional Development points (CPD). Some enforcement officers reported difficulties collecting CPD points from the training provided by their employer. Sometimes the training provided covers the breadth of environmental health as opposed to concerning health and safety specifically and therefore may not meet enforcement officer requirements in terms of occupational health and safety.

3.3.7 Training methods

Senior staff at a number of local authorities had difficulty determining the optimum training delivery method to use. Some stated that it is generally based on a cost or resource analysis, i.e. who is available to attend the training, or based on what was available at the time. The most popular training method remains cascade training, although other forms of training / development, such as mentoring, MScs, secondments to HSE, coaching through peer review and joint visits were mentioned. Preferences were for practical training, formal courses, short courses, DVDs, videos and disks, demonstration, and PowerPoint presentations.

The general enforcement officers’ perception on training was that the current training provision has to be more structured and some suggested modular training that got ticked off when attended. Local or regional training should be provided when one is judged more appropriate

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than the other. A range of training mechanisms has to be considered for training and development including events (e.g. workplace transport), practical projects (builders merchant project), technical guidance, internet, CD-ROMs, etc. Reasons for each method and examples of good practice were discussed and are summarised below.

• Face to face training was preferred especially when new guidance is issued. The guidance is also best delivered by the HSE because “HSE have their own interpretation on enforcement”. In a specific situation such as serving a notice, enforcement officers want to know how to respond and what is the appropriate course of action according to HSE.

• More practical training than theoretical training is sought. Some found the current five-topic programme, in which stress is included, does not go into sufficient depth and lacks practical exercises. Good examples of practical training courses were the forklift course, where participants drove the trucks; the ladder safety training and the slips and trips road show.

• Real situations or simulations are better perceived than role-play as a training method. Some had a local employer who made available a site, which enforcers were asked to inspect as part of their training. In London, some participants had enjoyed working on a major desktop exercise bringing HSE, LAs, and the emergency services together.

• Joint training with HSE and with other LAs means each can learn from the other and greater consistency can be achieved.

• Joint visits also enable mutual learning.

• Open learning was viewed as being good for acquiring theoretical concepts but not very good for translating into skills needed in carrying out the job.

• Some video packages (devised by HSE or other providers) were not always well perceived. An example is electricity at work, described as a boring ‘lecture on video’.

• On-line packages such as manual handling and CD-ROMs, such as workplace transport are acceptable as a method of training but some find the content too prescriptive.

• Technical updates could be given by video or on the internet.

• Cascade training was not favoured by all because of its variable quality, which largely depends on the motivation and skills of the ‘cascader’. It is thought easier to cascade information than to cascade training. A training pack made cascade training easier, as did two persons attending the initial training course and helping each other to cascade the training information. Some LAs make it policy to send two people as this can overcome the problems of one person missing important points or being poor at providing feedback. A recent research report by Williams and Ford (2005) shows that cascade training worked well when training had been designed to account for subsequent cascading.

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3.3.8 Trainers’ competence

Some enforcement officers wanted their competence and experience as enforcement officers to be taken into consideration during training delivery as sometimes they felt ‘talked down to’. Trainers need to have good training skills and/or be knowledgeable and experienced in the topic area. Specialised training was preferred and would be better delivered by specialists from, for example, CIEH, HSE, HSL, or LAs.

3.3.9 Training transfer

Local authorities did typically not carry out formal training transfer. Some LAs through feedback at regular team meetings reviewed training transfer, where specific issues, learning points or how the learning can be incorporated into the officers’ jobs would be discussed. Others used joint visits, demonstrations, shadowing or sharing knowledge with others as methods to check on training transfer.

3.3.10 Training evaluation

A range of training evaluation methods were used by local authorities, including:

• feedback forms following training courses, provided by the training providers or internally as part of their personnel and development systems;

• personal development reviews;

• skill checks through joint visits or by monitoring individuals’ work;

• Examinations;

• discussions with others about the training afterwards.

However, not all local authorities evaluated training.

Evaluation of the five priority topic training topics indicate a very high level of satisfaction immediately following training, but some participants later stated that they did not feel adequately equipped to carry out topic inspections, and wished for longer training and more practical applications.

3.4 SUGGESTIONS FOR IMPROVEMENT OF TRAINING

During the focus groups many suggestions were made for improvements to training. These ranged from the strategic to the operational level, and are categorised and outlined below. Where appropriate, some of these have been taken further in the recommendations.

3.4.1 Positioning of H&S

• Some senior staff felt that HSE needed to be more like the Food Standards Agency (FSA) if they expected LAs to commit more resources to health and safety. HSE needed to carry out more audits, request more frequent reports and be more authoritative about the consequences of LAs non-compliance.

• A consistent risk-rating scheme would be useful for HSE and LAs to work more effectively together.

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• Health and Safety needs more training (put on a similar level as food safety), this needs to be taken up at political level.

3.4.2 Partnership behaviours

• Identify if LAs have the core skills to deliver on the partnership management and communication skills.

• Consideration to the different roles and responsibilities of both organisations. • HSE and LAs can both learn from each other as both had specific knowledge and skills: • Consistency in approach • Avoid duplication therefore avoid inspecting sites separately that may end up repeating

the work the other officer has completed. • More discussion between LAs and HSE on improving the accessibility of the

Enforcement Liaison Officers under the current system • Asking LAs more what they want in terms of training. • The partnership to be equal, i.e. that the LA’s role to be recognised more.

3.4.3 National coordination of H&S training and budget

• Central database or central training coordination body for H&S under the responsibility of LACORS or CIEH that will recognise local needs but will ensure consistency and some economies of sharing. It will facilitate the organisation, and delivery of common training needs e.g. asbestos, legionella.

• A county pot of funding for training in specialist areas for specialists to be called out to all parts of county to give their specialist advice. Their time could be charged by hours worked to LA’s funding matched by central government /HSE.

• As LAs have twice as many inspectors than HSE, there should be a proportionate budget for training.

• LAs need full time Enforcement Liaison Officers rather than part time ELOs who are also working as inspectors

• Develop more internal experts within LAs and break reliance on HSE • Have one trained to be a specialist in each LA then list compiled of those trained in that

specialised area.

3.4.4 Sources of information about training and expertise

• A training forum or more information about available training • Knowing who specialises in what. • LAs to access HSE inspectors training directory, even if LAs have to then organise

accessing this training for themselves. • Sharing resources and expertise e.g. LA to be given access to HSE’s legal support as

HSE has more in-depth knowledge of health and safety law. • HSEs evaluation of courses so LAs do not waste money and resources on poor courses. • As a result of the SITNA study, to have a guideline of good and bad training practices

across LAs so that LAs can use it to identify where they fall on this scale.

3.4.5 Identification of training needs

• The best way to assess training needs is through team discussion and individual performance appraisal once a year;

• It should be part of a quality process; • Briefing on new legislation should be delivered by ELOs;

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• Liaison groups are a useful reference point to identify training needs; • A list to be made available of the types of training required.

3.4.6 Assessment of competence

• A common national competency framework would be helpful not only to assess competence but also training needs and ensure consistency between LAs and HSE.

• Greater coordination between HSE and IOSH is necessary. • More guidance from CIEH/REHIS and HSE on competency assessment and about CPD

(from CIEH)

3.4.7 Training and other forms of learning opportunities

• Targeted training on priority areas • Benchmarks (tool kits) on technical, legal aspects as well as premises and activities – to

be sources of reference (e.g. topic inspection packs). • Learning opportunity during jobs, in the form of coaching, self study, courses or open

learning on topics such as investigation skills, drafting notices, peer review, etc. • LAs should be trained by the same people that train HSE inspectors

3.4.8 Joint training

• LA officers and HSE inspectors to be trained together, although there are concerns about costs, course relevance, and local availability.

• Free training, as well as charging for some; • Accessing the same training packages, courses and expert support for training as HSE. • Training should be a two-way exchange between HSE and LA. LA might offer training

opportunities to HSE.

3.4.9 Joint working for learning and development purpose

• HSE inspectors and LAofficers to work more closely on, for example, investigating accidents, inspecting premises regulated by both HSE and LAs, and on organising other events. As an example, one LA noted how beneficial it had been when HSE and the LA had worked together on a fatal accident where the HSE inspector was more experienced in investigating accidents but did not have the equivalent knowledge of the industry as the LA officer.

• Secondments between the two organisations are useful although few people are prepared to do them.

• Hands-on joint visits

3.5 SUMMARY ON TRAINING

Most LAs said they had integrated the HSC priority topics (slips and trips, etc) in their objectives in addition to their local goals. There are various ways that LAs determine training budgets and annual training plans. The main training barriers concern low budget and the lack of resources to allow enforcement officers to attend training.

A formal appraisal system is usually in place to assess Health and Safety competence and training needs. To do this more accurately, a growing number of LAs are designing their own

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competency framework based on Section 18 guidance. However, some local authorities expect guidance either from the CIEH/REHIS or HSE on this matter.

Enforcement officers wish for more clarity on what standards of competence are expected of them and more clarity on Continuous Professional Development. An option put forward was to have a national competency framework between LAs and HSE that would bring clarity and consistency between regulators.

Given the low priority of health and safety in many LAs, some enforcement officers have infrequent opportunities to develop health and safety knowledge and skills. The priority for future training seemed to be around HSC priority topics, legal, and H&S management issues although local needs have also been expressed (e.g. legionella,) as well as more generic skills (interviewing, business skills).

Suggestions to improve the management of training and to establish an adequate training partnership include: stronger positioning of H&S within LAs, greater coordination of training activities, more precise definition of standards of competence, joint working activities and joint training between both regulators. Respective competences and strengths have to be recognised and shared for an effective LA-HSE partnership.

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4.1

4 CONCLUSIONS AND RECOMMENDATIONS

One of the key findings from this research is that enforcement officers have a desire to be provided with equivalent levels of support, information and training as that which they perceive HSE inspectors receive. They believe they would function more effectively if they had the same levels of service as HSE in terms of training, specialist support, colleagues, and the raft of information available over the HSE Intranet. Many of their suggestions for improvement concerned addressing their perception of a two tier system for enforcement, where HSE is perceived to be well-trained, well-equipped and well supported, whilst most local authorities are less well trained and under-resourced. The main findings are summarised thus:




• There is no systematic method of identifying individual LA training requirements because each have their own procedure/perception for what is required;

• There are different approaches to enforcement by HSE and LAs. LAs are more locally focused and influenced by local circumstances.

• Individual LAs lack the resource to analyse fully the individual training needs of their staff and research needs in the context of a coordinated national approach to health and safety enforcement.

• The full range of technical training perceived as necessary by LA enforcement officers cannot, in any practical way, all be supplied by HSE.

RECOMMENDATIONS

Relative strengths of LAs and HSE

Both LA enforcement officers and HSE inspectors are committed to their role, however their roles and organisations are significantly different. The recommendations aim to address the central barriers to partnership between HSE and LAs, and consider building relationships, exploring enforcement models and aligning planning cycles.

Recommendations to address this are:



• Planning cycles need to be aligned to ensure that HSC targets are incorporated into local authorities plans.

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SUPPORT

A broad range of support and information mechanisms were explored in the course of this study and suggestions for improvement were proposed.

Enforcement Liaison Officers

Enforcement Liaison Officers in the main were well perceived, though concerns were expressed about their abilities to meet demand. The recommendations around the ELO are:

• Explore the roles and responsibilities of ELOs. Review their real time activities and determine whether alternative routes could provide lower level support, such as information provision.

• Continue to build and maintain relationships with local authorities by ELOs attending liaison meetings and running partnership events.

Technical support from Specialist Inspectors

Overall enforcement officers were not aware of the range of services that can be provided by Specialist Inspectors, furthermore there was confusion over how the services can be accessed. Within HSE concern was expressed about overloading the Specialist Group with enquiries from local authorities. Recommendations to address these are:


• Provide Specialist Inspectors’ reports on previous topics, so that LAs can understand the type of service they could receive;

• Explore the use of a risk-based approach to prioritise work requests to Specialist Inspectors. Communicate this to all relevant parties;

• A service level agreement could be developed to help LAs get support when they need it.

Medical Support

Medical support services from HSE were not used or understood by local authorities; in part this reflects a general weakness in the area of enforcing occupational health issues. Recommendations are:


Health and Safety Laboratory (HSL)

Enforcement officers had not widely made use of the services provided by HSL. In terms of recommendations a number address raising HSL’s profile:

• HSL needs to raise its profile, clarify how its services can be accessed as well as outline the services it offers.

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• In conjunction with this, the HSL internet site requires improvement to demonstrate the above;

• HSL needs to continue its consultation with Local Authority Liaison groups to identify valid and useful research projects for local authorities to commission;


Legal Support

Most enforcement staff raised the need for legal support. Recommendations on this topic are:


• HSE to publish sample notices, letters, protocols etc to support local authorities in their enforcement activities.

INFORMATION

Infoline

Infoline is under-utilised by enforcement staff, and provides a valuable resource for them to use. Recommendations are:

• Raise profile of Infoline about the competence of staff and service offered;


Computer-based Information systems

The most common route for accessing information was via the Internet. A wide range of sites supplied their needs, however HSE was viewed as the best and most accurate provider. Recommendations are:





• Increase linkages between websites to avoid duplication of material.

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Planning and Regulatory Services On-line (PARSOL)

PARSOL is an initiative to help local authorities develop effective and transparent provision and delivery of planning and regulatory information on-line. HSE is not currently involved in the initiative and in terms of recommendation:

• PARSOL needs to be considered as a potential mechanism for the provision of information share networks to local authorities on health and safety.

TRAINING

The major components of training explored in this study included training needs assessment, training methods and training evaluation. The main findings indicate that most LAs have training systems, which aim to provide and maintain competence, but the lack of budget, resources and time dedicated to health and safety activities, weaken the training effectiveness.

Assessment of training needs

Individual local authorities lack the resource to fully analyse the individual training needs of their staff, or identify research needs in the context of a coordinated national approach to health and safety enforcement. Several local authorities have competency frameworks in place, as well as methods for the assessment of training needs. These were typically developed in conjunction with the health and safety liaison groups and included a list of core skills and knowledge derived from the Section 18 guidance (HSW Act, 1974).


• Individual training needs on generic and specific skills and knowledge should be further identified between line managers and their enforcement officers;

• LAs who have developed competency frameworks are encouraged to share this material and post it on the HELA training coordination website;

National competency framework

There is a lack of a common management approach or standard of competence assessment for enforcement officers.

The key recommendations are:

• To revisit Wilson’s recommendation on assessment practices comparison contained in her 1998 report on ‘Health and Safety Enforcement Officers Standards of Competence’. It says that ‘the operation of the section 18 and the NVQ in local authorities and within HSE for its own inspectors should undergo a comparison investigation, to establish similarity and differences in evidence and assessment practices. This should include an evaluation of comparability in the training, evidence and assessment of each’.

• The development with all relevant stakeholders of a national system for the assessment of competence, including appropriate assessment regimes and linked to meaningful professional development.

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Training coordination system

Currently no central body exists to coordinate training needs, and no national picture exists of the training needs. This is vital to assist in the planned provision and coordination of training activities between local authorities, HSE and other providers. Recommendations are:

• Explore options to develop a national body for the coordination of training needs in consultation with LACORS, and other key stakeholders. Each LA would remain autonomous in the way they wish to address training provision but their training needs would be channelled through a coordination unit.

Training Provision

There was a call for greater clarity about the coordination and positioning of health and safety, more training and also more training or events with HSE inspectors or using packages developed for HSE inspectors. By receiving this, enforcement officers would see the partnership as being ‘equal’. The priority for future training seemed to be around HSC priority topics, legal, and H&S management issues although local needs have also been expressed (e.g. legionella,) as well as more generic skills (interviewing, business skills). The full range of technical training perceived as necessary by enforcement officers cannot, in any practical way, all be supplied by HSE.


• Make available HSE training materials to local authorities, provided that it fulfils identified training needs.

• Awareness raising to help enforcement officers understand the key issues concerning a topic, and recognise where and when expertise should be sought.

Where the depth of expertise is less in some LAs, or when inspectors may only encounter a situation one or twice in their career, including fatal incidents and major incident investigations rather than attempting to provide all inspectors with training to cover these situations, the use of local support networks within LAs in a region is advocated.

Recommendations are: • Use of networks, both within HSE and between local authorities to cover critical

situations. • A register of knowledge/experience would be of value to support enforcement

officers.

Training provision needs to be supplemented by other learning and information gathering opportunities to foster common language, best practice and reduce organisational culture differences between LAs and the HSE.

The recommendation is: • To hold at least one annual event in each region gathering LA enforcers, HSE

inspectors and HSL specialists to share their experience on major projects, legal and technical developments.

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4.2

Improvement of training methods and content

A variety of training methods ranging from face-to-face training to web-based materials are used but participants preferred practical and real situations. The most common training method, is cascade training, which was generally not well regarded.


• Explore options for the improvement of cascade training, including guidelines for course providers for example have a pool of trainers for a given region. A study currently carried out by Salford University on this topic needs to be taken into account in the development of these options.

• Ensure that training is evaluated after a suitable period to ensure that training meets the identified needs.

BALANCING THE NEEDS OF SUPPORT AND TRAINING

LA health and safety enforcement officers believe that they would function more effectively if they had access to equivalent services as HSE inspectors in terms of training, specialist support, colleagues and the raft of information available over the HSE Intranet. Many of their suggestions for improvement concerned addressing their perception of a two tier system for enforcement, with HSE perceived as well-trained, well-equipped and well supported.

Enforcement officers that work on health and safety recognise that their knowledge levels on OH&S are not equivalent to HSE inspectors, who all address Occupational Health and Safety (OH&S) full time. However, due to the organisation of work within LAs, as well as the risk profile of premises it is unlikely that enforcement officers’ enforcement experience is sufficiently broad for them to be considered competent/experienced on the full range of OH&S issues. Therefore, the research team do not consider it to be a viable or feasible option for enforcement officers to be trained to equivalent standards as HSE Inspectors. As a result a model is proposed that would allow the balance between Support/Information and training to be explicitly identified. For example, if a certain skill is used infrequently and is difficult to train then this would almost certainly be an area where local authorities should seek support. Conversely skills that are used often, even if the training needs are high, should be trained and internally resourced by local authorities.

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Support and Training Resource Model C

ompl

exity

of t

rain

ing

need

s

TRAINING REQ’D

SUPPORT REQ’D

High

Low TRAINING REQ’D

SUPPORT REQ’D

High

Low

Used infrequently Used often

Frequency of skills used

Figure 9 – Support and Training Resource Model

Figure 9 proposes an outline framework for such a model to balance the Support and Training Needs of Enforcement staff within local authorities. Further work is required to identify the shape and position of the line within the model to determine what skills/knowledge should be routinely given to enforcement officers and to identify where specialist support should be supplied. The space underneath the line defines those areas where training is required, and that above the line where specialists can provide their expertise. The exact position and shape of this line needs to be determined. Those skills that are used more frequently should be developed through training, whilst support should be offered for those skills that are used less frequently. For example, on issues such as legionella or asbestos it could be that the skills and knowledge is needed so infrequently that even trained individuals will not be competent to use the trained material when requested.

The advantages of developing and defining such a model include:

• A recognition by enforcement officers concerning the training that is core to their job, and the importance of ensuring experience of these skills;

• A recognition that competence needs to be actively maintained, and requires more than attendance at a training course;

• A recognition that training cannot be provided in all areas of occupational health and safety;

• An awareness of where support is needed and how it can be obtained.

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5 APPENDICES

APPENDIX 1 – LOCAL AUTHORITY SAMPLE

Local Authorities who participated in the interviews, focus groups, workshops or conference syndicate groups.

Aberdeen City Council London Tower Hamlets Angus Council Macclesfield Borough Council Barking & Dagenham Council Merthyr Tydfil Council Barnsley MBC Mid Lothian Council Blaenau Gwent County Borough Monmouthshire Council Bradford Metropolitan Borough Council North Ayrshire Council Breckland District Council North Devon District Council Bridgend County Borough Council North Shropshire District Council Calderdale MBC North Somerset Council Camarthenshire Council Perth & Kinross Council Cheltenham Borough Council Purbeck District Council Cherwell District Council Redcar & Cleveland Chester City Council Reigate-Banstead City of Bradford MDC Renfrewshire Council City and County of Swansea Rochdale MBC Corporation of London Royal Borough of Kensington & Chelsea Darlington Borough Council Rugby Borough Council Derby City Council Runnymede BC (Addlestone, Surrey) Dundee City Council Ryedale District Council East Ayrshire Scottish Borders Council Eastbourne Council South Gloucestershire Council East Lothian Council Stevenage Eden District Council Tameside MBC Edinburgh City Council Trafford Metropolitan Borough Council Exeter City Council Vale of Glamorgan Council Gateshead MBC Wakefield MDC Glasgow City Council Warrington Borough Council Gwynedd County Council Weymouth & Portland BC Dorset Hambleton District Council Winchester City Council Hammersmith & Fulham

+ approx. 74 LAs in the West & East

Wrexham County Borough Council Hull City Council Inverclyde Kirklees Metropolitan council

MidlandsLeeds City Council Lichfield District Council

Total: 143London Borough of Bromley London Borough of Ealing London Borough of Lewisham London Borough of Newham

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APPENDIX 2 – INTERVIEW SCHEDULE

Organisational goals Are there organizational goals (i.e. set targets) in terms of H&S set by LAs? What are they? What priority is given to health and safety topics in LAs a) compared to other topics? (food safety, etc) b) in relation to HSC’s priority topics? (e.g. stress, slips and trips, falls from heights, workplace transport)

Existing systems for assessing competency How do LAs know their enforcement activities are effective? Prompt: What evaluation system is used to assess whether enforcement activities are effective? What quantitative measures do you have? What is the appraisal system in place for EHOs, Technical Officers and Technical Assistants? How is the competency of these individuals assessed? Prompt: Do you use a specific competency framework? If yes, does this set of competencies measure Health and Safety related knowledge, skills, abilities and other aspects? (If competency framework exists can we have a copy of it) How was the competency list developed? How important is it to share competencies with other similar LAs?

Training systems How are the developmental needs and training needs of individuals assessed and collected? (Is it through the appraisal system only or outside of it or both?) Do you have an annual training plan? If yes, how is it developed?Prompt: How do you prioritise health and safety training compared to other non-health and safety activities? Is the allocation of training funds for example decided according to goals?What is the budget allocated to training per year, per individual for H&S? How do training needs get answered? (Regrouped? Planned for the year, ‘First come, first serve’, Answered on a one-to-one basis? Group needs provided for?) How do you decide what type of delivery method will be used? e.g. Is a cost-benefit analysis or a resources analysis done?How is training transfer ensured at the workplace (Follow-up after training such as coaching, mentoring, supervision, joint visits?) Do you evaluate training once individuals have attended? If yes, how?

How can the current situation be improved? At each stage of the process (i.e. development of annual training plan, identification of training needs, evaluation of training, etc), what are the necessary improvements for LA and HSE to work more collaboratively on these matters? What do you perceive to be the relative strengths between LAs and HSE? E.g. LA staff can react more quickly to local issues?

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APPENDIX 3 – INVITATION TO FOCUS GROUPS & WORKSHOPS

1. Email sent to Liaison group Chairperson of all LAs in England, Wales and Scotland

Support, Information, Training Needs Analysis (SITNA)

Dear Liaison Group Chairperson,

We would like to ask you to forward the following invitation to the Local Authorities in your area. This is an important piece of research commissioned by the Local Authority Unit to the Health and Safety Laboratory (HSL).

HSL is carrying out the ‘Support, Information and Training Needs Analysis’, an essential element of the ‘Local Authorities and HSE Working Together’ Strategic Programme’.

In order to reflect the views of the Local Authorities accurately, it is vital that we hear a widespread of opinions across the country. For that reason, we are holding 2 focus groups and one workshop in your area.

We have already conducted interviews in some LA in you area on this topic and made them aware of these coming focus groups and workshop but the deadline is rather short. So it will be very helpful to send this invitation as soon as possible.

Thank you for your valuable assistance.

Best regards,

Dr Nadine Mellor Health and Safety Laboratory Work Psychology Section Harpur Hill, Derbyshire SK17 9JN Tel: 01298218379 Tel: 07976342831

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2. Letter sent to Liaison group chairpersons to distribute to all LAs in England, Wales and Scotland

SUPPORT, INFORMATION AND TRAINING NEEDS ANALYSIS (SITNA) STUDY

9 February 2005

Dear Environmental Health Managers, Health and Safety Specialists,

At the HELA conference on 8 December 2004, Allan Davies, Head of HSE’s Local Authority Unit and manager of the LAs and HSE Working Together Strategic Programme, announced that among other actions necessary to build the New Partnership between LAs and HSE, a Support, Information and Training Needs Analysis had been commissioned.

The Health and Safety Laboratory (HSL) based in Buxton, has been commissioned to carry out this work and we would like to invite Environmental Health Officers (EHOs) and Technical Officers (TOs) to focus groups and workshops to be held regionally. This research is building upon the base-line study carried out recently by King’s College London, to which you might have contributed.

During the focus group, we are seeking to identify, in more detail, the type of competencies EHOs and TOs judge to be important in their job, the training they would need to maintain or develop these competencies and how HSE or other partners can support this process. The focus group covering your area will be held on the 3rd of March at the HSE office, Marshall’s Mill, Marshall Street, Leeds LS 11 9YJ. Lunch will be provided.

3 March (at this session we will use a competency questionnaire that will form the basis for our discussion) Focus group: Discussion around EHOs, TOs’ specific competencies and training needs -From 12:30pm to 16:00pm.

We want also to look at the level of support and information (legal, technical, etc) that EHOs and TOs receive or would like to receive from HSE or other bodies. What do they suggest in order to build a strong partnership and effective working relationship between LAs and HSE? This will form part of a workshop that will last one day. To ensure we hear a wide spectrum of opinion we suggest that delegates to this workshop have not participated in the focus group the day before. The workshop will take place on the 4th of March at the HSE office, Marshall’s Mill, Marshall Street, Leeds LS 11 9YJ Leeds. Lunch will be provided.

4 March – From 9:30 am - 15:30 pm Workshop: Discussion around the Support and Information needed by Local Authorities (through their EHOs and TOs) from the HSE and other bodies. Please note that there will be a mix of EHOs, TOs and HSE inspectors at the workshop.

Please send your nominations to [email protected] before the 18th of February 2005. We look forward to hearing from you soon.

Yours sincerely,

Dr Nadine Mellor and Edward Corbett Health and Safety Laboratory Work Psychology Section Harpur Hill, Derbyshire SK17 9JN Tel: 01298218379 Tel: 07976342831

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APPENDIX 4 – FOCUS GROUP QUESTIONS GUIDE

Welcome and presentation of the purpose of the focus group We would like you to think about what you do in your job, the skills and knowledge required and what training you think you would benefit from. We want to have a structured discussion, so in order to do this; you will need to complete a questionnaire that will take no more than 30 minutes. You will use them during the focus group to discuss your answers. We will collect them at the end and there is no need to put your name on so you can be assured your answers are confidential. Let’s read the instructions together. Do you have any questions? 13. 15 Completion of questionnaire starts 13 :45 Completion of questionnaire finishes

13:45 Competency Q1: Are there any skills and knowledge that are not mentioned in the list and are important? Q2: Are there skills/knowledge which you think may become important for you in the future? Q3: Why? (Partnership, new areas of work, etc)Q4: Do you have enough training and information regarding these competencies? Q5: If yes, what sort of training have you received?

15:15 Training Discussion about training using the training cycle: Training Needs Analysis, Training content, Delivery methods (Cascade training etc), Follow-up (joint visits with HSE,) Evaluation.

Training Need Analysis Q6: How do you think your training needs should be identified? Q7: What are the current methods used and How effective are they?

Training delivery methods Q8: What types/methods of training are most appropriate to address these needs? Q9: What methods are currently used and how effective are they? Q10: What is your preferred way of learning? (Interactive method, computer interaction e.g. online training, read on the screen, read paper, book, case studies etc) Q11: Do you feel you would benefit by sharing training with HSE inspectors? You may think thatthis should only be for certain types of training needs/skills/knowledge, if so which? If not, why not? Q12: What are the ways you can be trained/briefed in HSE programme work areas?

Training transfer and follow-up Q13: What would you benefit from sharing with HSE? [e.g. Joint visits?]Q14: Some LAs have suggested that they only train staff as necessary in particular skills ortopics, and not in everything – is this a good approach? Should LA enforcement officers betrained in all aspects of H&S enforcement? Q15: How important is it to ensure consistency between LAs or between LAs and HSE in terms of H&S competence and training? How can this be achieved? Q16: In your job, what 3 key skills are most important to receive training on?

16:00 Close

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APPENDIX 5 – HSC GUIDANCE - ANNEX 2 – OCTOBER 2002

Competences for HSE and LA health and safety inspectors

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APPENDIX 6 – TRAINING RESEARCH QUESTIONNAIRE DETAILED RESULTS

This questionnaire is about the skills and knowledge that are required in order to ensure HSE and LAs continue to fulfil their responsibilities in respect of inspection, investigation and enforcement as set out in the HSC enforcement policy. We would like to have your view on each statement please.

Instructions For each skill/knowledge, you are required to indicate on a scale of 1 to 5 or ? how important the skill/knowledge is to your everyday job, how frequently you use the skill/knowledge in your everyday job, how much training have you received for each skill/knowledge how much information have you received regarding this skill/ knowledge.

The scales are indicated below:

A) Important to my job? B) Frequent in my job?

1 2 3 4 5 ? Not at all A little Moderately Very Extremely I don’t know

C) Training received? D) Information received?

1 2 3 4 5 ? None A little Some Quite a lot A lot I don’t know

Questionnaire:

Please indicate your current position: EHO (please tick a box)

TO TA

Is Health and Safety: Full time role: Part time role:

Do you have other responsibilities beyond Health and Safety (e.g. Food Services)?

Yes No

Please state what are your other responsibilities:…………………………………… …………………………………………………………………………………………………

ڤ

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information needs. It is up to each i

2-1: A little/No

Percentages highlighted in red might (but not necessarily) indicate some potential training/ LA to discuss with their respect ve Enforcement officers.

Results are expressed in percentages which have been merged to give the following categories:

5-4 : Extremely to Very 3: Some/Moderately

Skill or Knowledge Importance to my job

Frequency in my job

Trainingreceived

Information received

Section A: Inspect duty holders, worksites and activities for the purpose of work-related health and safety regulation.

5-4 3 2-1 5-4 3 2-1 5-4 3 2-1 5-4 3 2-1

A.1 Use appropriate databases and other information sources to identify duty holders or worksites for inspection or other contacts.

83 12 5 71 19 10 32 51 17 37 44 19

A.2 Plan a logical series of inspections or contacts, individual inspections or contacts consistent with operational plans and priorities (and topic areas).

83 12 5 73 17 10 22 47 31 37 36 27

A.3 Gain access to worksites and identify and secure co-operation of duty holders, employee/safety representatives and others (preserving personal safety).

88 8 3 71 19 10 42 32 25 36 40 24

A.4 Manage the inspections or contacts flexibly to deal with unplanned issues.

84 12 4 63 27 11 21 49 30 19 44 37

A.5 Use observation, questioning, listening, and process knowledge as appropriate.

97 3 0 88 8 3 44 31 25 38 34 28

A.6 Apply principles of risk control to ensure or advise on compliance, using judgement, discretion and discussion.

95 3 2 81 17 2 50 40 10 50 34 16

A.7 Identify remedial action, including (in the case of inspectors) formal enforcement.

95 3 2 78 14 9 45 43 12 44 39 18

A.8 Draft clear, concise inspection/ contact reports.

93 2 5 81 12 7 32 44 24 28 40 32

A.9 Evaluate the effectiveness of the inspection/contact.

71 17 12 45 34 21 19 34 47 12 33 55

A.10 Identify and arrange any further action.

83 12 5 61 30 9 26 41 33 18 41 41

A.11 Communicate findings to colleagues when appropriate.

81 14 5 59 29 12 16 43 41 9 42 49

80


Frequency in my job

Trainingreceived


Section B: Investigate work-related accidents, incidents, ill-health reports and complaints

5-4 3 2-1 5-4 3 2-1 5-4 3 2-1 5-4 3 2-1

B.1 Consider the severity of the incident or potential risk etc. to determine timing of response.

95 2 3 63 27 10 24 42 34 27 47 25

B.2 Identify relevant legal requirements, standards, guidance and policy to establish benchmarks.

95 3 2 73 19 8 39 44 17 51 36 14

B.3 Identify what information exists to aid the investigation.

90 8 2 58 34 8 24 46 31 29 41 29

B.4 Establish the aims and objectives for the investigations.

88 7 5 59 29 12 22 41 37 27 27 46

B.5 Organise resources, equipment and people.

75 12 14 41 34 24 17 28 55 16 24 60

B.6 Liase with any emergency services/other regulators and establish the LA’s role.

72 21 7 14 29 57 10 34 55 9 34 57

B.7 Secure co-operation of the duty holder.

93 3 3 72 17 10 12 49 39 11 40 49

B.8 Promptly identify any continuing risks to health and safety and take immediate action as necessary.

97 2 2 64 24 12 34 49 17 31 53 17

B.9 Call on expert help where necessary.

76 16 9 21 23 56 9 23 68 9 31 60

B.10 Use questioning and listening skills to obtain information.

98 0 2 80 17 3 17 37 46 14 36 51

B.11 Identify immediate and underlying causes of the incident/complaint.

97 2 2 76 20 3 10 51 39 19 44 37

B.12 Investigate all reasonable lines of enquiry.

93 5 2 64 25 10 8 58 34 12 51 37

B.13 Analyse and review evidence. 95 3 2 64 19 17 14 44 42 12 44 44

B.14 Communicate with duty holder, etc. during the investigation.

90 7 3 74 16 10 17 39 44 12 41 47

B.15 Manage and conclude the investigation effectively.

97 2 2 67 28 5 16 41 43 7 45 48

B.16 Prepare an investigation report. 78 19 3 50 24 26 12 40 48 12 40 48

B.17 Communicate clearly and effectively with interested parties the outcome of the investigation and any further action.

95 3 2 68 19 14 12 47 41 16 41 43

B.18 Secure commitment from duty holders for improvements to an appropriate timetable.

97 2 2 73 22 5 12 49 39 16 38 47

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Frequency in my job

Trainingreceived


Section C: Gather evidence 5-4 3 2-1 5-4 3 2-1 5-4 3 2-1 5-4 3 2-1

C.1 Identify likely sources of evidence and assess its relevance.

98 0 2 53 31 17 15 44 41 12 47 41

C.2 Identify the need for any immediate action to obtain and preserve evidence.

97 3 0 41 24 36 12 44 44 10 47 43

C.3 Take the rules of evidence into account to ensure that evidence gathered would be reliable, admissible and has continuity.

100 0 0 41 24 36 25 36 39 24 40 36

C.4 Analyse and review evidence and identify potential defences, weaknesses and mitigating circumstances and collect further evidence where appropriate.

95 3 2 33 26 41 19 29 52 12 42 46

C.5 Collect and manage evidence by using: a. necessary expert help.

80 14 7 14 19 68 10 21 69 9 29 62

b. Maintaining the integrity of the evidence throughout.

93 5 2 36 26 38 14 38 48 9 39 53

c. Taking voluntary statements and statements using statutory powers.

95 3 2 27 29 44 22 39 39 16 45 40

d. Taking statements under caution. 90 7 3 19 16 66 26 36 38 21 47 32

e. Using questioning and listening skills to obtain information.

98 2 0 51 24 25 17 46 37 10 50 40

f. Telling relevant people what action is being taken and why.

95 5 0 56 22 22 12 41 47 11 42 47

82


Frequency in my job

Trainingreceived


Section D: Enforce statutory provisions, brief a prosecutor / procurator fiscal and participate in other legal processes including Fatal Accident Inquiries / Inquests, Employment Tribunals and other civil proceedings as required

5-4 3 2-1 5-4 3 2-1 5-4 3 2-1 5-4 3 2-1

D.1 Demonstrate that there is a case to answer, that it is in the public interest and is worthwhile.

93 3 3 19 26 55 19 31 50 23 42 35

D.2 Assemble evidence and information to support the opinion that there is an offence.

97 3 0 21 31 48 24 28 48 23 40 37

D.3 Weigh the relevant factors in determining which charge(s) are appropriate.

97 2 2 17 28 55 21 28 52 23 42 35

D.4 Identify and evaluate possible defences.

86 10 3 17 24 59 14 28 58 18 40 42

D.5 Ensure that the case papers are developed and prepared in an appropriate way as to enable the arguments to be clearly followed and facilitates the preparation of relevant court documents.

95 2 3 16 22 62 14 36 50 14 45 41

D.6 Prepare, draft and serve court documents where required.

58 14 28 10 27 63 4 24 73 2 33 65

D.7 Record statutory data and other information.

77 16 7 30 25 45 5 38 57 7 37 56

D.8 Where relevant present written information to legal professionals to enable them to evaluate the content and value of the potential case.

91 3 5 19 19 62 7 36 57 11 43 46

D.9 Where relevant brief legal professionals about the case and LA’s perspective.

91 4 5 16 18 67 5 32 63 7 35 58

D.10 Report on the conduct and outcomes of proceedings in accordance with directorate / divisional instructions.

71 17 12 10 26 64 2 21 78 0 30 70

D.11 Act as a witness, expert witness or provide other support at legal proceedings.

83 9 9 16 19 66 16 29 55 16 43 41

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Frequency in my job

Trainingreceived


Section E: Enforce statutory provisions and present guilty pleas in Magistrates’ Courts. (Not applicable to Scotland).

5-4 3 2-1 5-4 3 2-1 5-4 3 2-1 5-4 3 2-1

E.1 Prepare documents that meet legislative requirements.

83 5 12 24 31 45 14 19 67 20 24 56

E.2 Arrange for laying of information and service of summons.

51 17 32 12 12 76 3 8 90 3 13 85

E.3 Provide advance information to defendant and agree any documents, exhibits or photographs to be used to assist the court.

53 20 28 15 18 68 5 15 80 5 21 74

E.4 Conduct themselves in court in accordance with the rules of procedure and LA’s policy.

74 7 19 12 24 64 17 19 64 15 20 66

E.5 Present the case for the prosecution precisely and clearly.

69 0 31 20 10 70 8 20 73 10 21 69

E.6 Respond to questions posed by magistrates and court officials.

76 2 21 17 17 67 14 12 74 15 17 68

E.7 Assist the court in their consideration of compensation to any victim of the offence.

29 12 59 5 7 88 0 0 100 0 8 93

E.8 Make application for costs. 54 7 39 20 7 73 0 5 95 0 13 88

E.9 Report on the conduct and outcomes of proceedings in line with LA’s requirements.

51 27 22 17 15 68 0 15 85 0 21 79


Frequency in my job

Trainingreceived


Section F: Draft and serve notices or other statutory enforceable documents.

5-4 3 2-1 5-4 3 2-1 5-4 3 2-1 5-4 3 2-1

F.1 Identify the duty holder and their legal title.

98 2 0 42 29 29 24 47 29 23 47 30

F.2 Identify the reason(s) for issuing the notice

100 0 0 51 24 25 20 56 24 28 47 25

F.3 Decide upon the type, content, expiry date and any conditions (schedule) of the notice to be issued.

100 0 0 47 31 22 17 53 29 25 50 25

F.4 Ensure that the detail of the notice is accurate and will ensure compliance with legislation and/or control the risk.

100 0 0 46 31 24 20 51 29 26 44 30

F.5 Ensure that the notice is correctly served and practical to enforce in the event of non-compliance.

100 0 0 47 29 24 20 46 34 28 42 30

F.6 Ensure that the recipient is informed of the appeals procedure and process, and receives the necessary appeal documentation.

100 0 0 49 27 24 29 44 27 37 37 26

F.7 Follow up notices served to establish compliance.

98 2 0 45 28 28 22 38 40 25 39 36

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APPENDIX 7 – SUPPORT WORKSHOP AGENDA

9:30 Welcome 9:35 Participants introduce themselves 9. 50 Presentation of HSC strategy and targets 9:52 How LA and HSE contribute to strategy and targets

LA Syndicate group: How LA enforcement officers contribute to it HSE Syndicate group: How HSE specialists contribute to it

10:15 Plenary: Syndicate groups present their findings 10:45 LA syndicate group describe:

What are the respective strengths and weaknesses of LA and HSE The types of Enforcement support (legal, technical, scientific, medical, etc), that they need from HSE and external providers in order to successfully deliver their contribution to HSE strategy and targets. For each type of support they indicate whether they access it and why? Do you access help /advice from specialists from HSE? If yes, how frequently? If not, why not? In which context/situation do you decide to get a specialist for help? Do you access help/advice from specialist from HSL? If yes, how frequently? If not, why not? The best way for this to be accessed. How do you know what support/information is available? How do you know what to do to access support/information? What has helped you to access support/information? What difficulties have you experienced in accessing support/information?

HSE syndicate group describe: The types of Enforcement support they think enforcement officers need from HSE and external providers in order to successfully deliver their contribution to HSC strategy and targets. Who is best able to provide each type of support The best way for this support to be accessed.

13.15 Suggestions for improvement LA syndicate group describe: What changes/improvements would help enforcement officers to access specialist technical support/information? Specific suggestions: Infoline Does infoline answer all your questions/needs? If not, what can be improved or what can we put in place to help you? Access to information through technology Role of ELO and Partnership managers in supporting enforcement officers What are the 3 major things that HSE should do immediately to support LAs? What are the 3 major things that HSE should put in place in the longer term to support LAs?

HSE syndicate group describe: What are the 3 major things that HSE should do immediately to support LAs? What are the 3 major things that HSE should put in place in the longer term to support LAs?

14.30 Plenary session: Syndicate groups present their findings 15.00 Conclusions and close

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APPENDIX 8 – PARSOL AND OTHER HSL RESEARCH

PARSOL Meeting 25 April

Martin Howel and Andrew Waren of Wandsworth Borough Council explained that as from the 31 March 2005 ODPM, who had been providing the funding for the PARSOL, had cut off support for the project. Wandsworth were committed to continuing with the project and are currently exploring methods for external funding. This may include commercial ventures, for example with Microsoft.

PARSOL is composed of 16 products, which have stemmed naturally from the initial 4 streams. The collective aim of these products is to help develop the effective provision and delivery of planning and regulatory information and services online to local authorities. The take up of PARSOL with local authorities varies with the individual products. Licensing on line, for example, is well developed and has 180 LA’s already expressing interest in this area. Other products are not as well supported as yet.

Government departments and agencies that are involved with PARSOL include the Environment Agency, and English Heritage and more recently English Nature. Contacts have also been made with the Scottish e-planning group, who expressed interest in joining PARSOL. The Environment Agency is fully committed to PARSOL and has put together an e-planning project of which PARSOL exchange is a key part.

PARSOL exchange is a delivery mechanism for the PARSOL products and is intended to help standardise data exchange and help provide a centralised service, dealing with planning documents, web interfaces and direct links to back office systems. It is an XML orientated exchange system, which has taken a relatively long time to develop. It has a live pilot running for the next 6 to 8 weeks, which includes Wandsworth and Macclesfield councils along with the Environment Agency, English Heritage and English Nature. Feedback will be available from this pilot at the end of the summer 2005, which will provide details on the types of areas that may of issue for further take up by LA’s.

Continued development and refining of PARSOL exchange will continue, with input from the Planning Portal, the system suppliers and the Environment Agency. (www.planningportal.gov.uk) Martin Howel the PARSOL exchange manager was very keen to hear HSE’s views on the format of the new standard planning information forms, as it is these that will form the basis of the XML data exchange format. The PARSOL management team are keen to emphasise having to capture data only once (i.e. for one form to be filled in once) and would value feedback on the forms at this development stage.

The PARSOL management team report back to the e-planning board, which is an ODPM run group. This is a forum for discussion and for obtaining feedback. The e-planning group has LA representation and also involvement from central government departments. The PARSOL team also present LA events, user group meetings and experience sharing sessions to promote and publicise the PARSOL project and its aims and deliverables. The PARSOL project is closely linked with the Planning Portal, for example the PARSOL XML schemas are based on those of the Portal. It is also a possibility that the Planning Portal may take over PARSOL exchange.

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Other HSL research in related areas

The Implementation of the Fundamental Review of Land Use Planning (IFRLUP) team of HSE’s Hazardous Installations Directorate (HID), have recently commissioned a scoping study from the GIS team of HSL. The aim of this study was to examine the format and delivery options for supplying mapping information to Local Planning Authorities (LPAs) to aid the land use planning decision-making process, which is one of HSE’s statutory duties.

Currently this mapping information is passed to LPAs on paper rather than electronically. Some of the objectives of the scoping study may be of interest to the SITNA project. These objectives were:

• To gather information from a range of Local Planning Authorities (LPAs) to determine their views on the most appropriate format and delivery options for mapping information from HSE.

• To examine the different format options for the information. Examples of different format options include hard copy paper maps and electronic formats such GIS layers or word documents etc.

• To examine the options for delivering the information to LPAs.

The study involved interviewing 14 LPAs to determine their views on the methods for exchanging mapping information with HSE, examining the options for the format and delivery mechanism for the information and coming up with recommendations. In addition to the LPA interviews a number of emails were also received from LPAs, which agreed with the interview findings. The main findings of the scoping study that are of relevance to the SITNA project were that:

• LPAs would like to receive mapping information from HSE in a GIS format, to allow easy integration into their own systems.

• A number of different GIS software packages are used within LPAs; however, translation between these systems is not necessarily restrictive.

• The HSE Extranet would probably form the best long-term solution to supplying the mapping information to LPAs.

A survey of LPA ICT usage was also examined for the scoping study. This survey had been commissioned from MORI by the PARSOL project. The survey showed that approximately 70% of LPAs have windows based IT systems, 95% of planning department staff use networked PC’s and 4 out of 5 LPAs use GIS software to share planning and other information within their authorities and wider, which was of direct relevance to the scoping study. Other areas of the survey may be of interest to the SITNA project, including details relating to the number of Environmental Health departments that have an information strategy (81%) and the number of departments confident of achieving the e-enabling targets set by the government (81%). When asked about the type of barriers to meeting these targets, problems with staff resourcing were given as the greatest restriction (67%), while problems with inadequate software and hardware were also cited (21%). The survey also examines the technology that is available to LA staff, the applications that are used within Environmental Health departments and provision of online guidance; with HSE being one of the most frequently cited national sources of information

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(34%). The full details of the survey are available on the PARSOL website (www.parsol.gov.uk/2_6.html).

From consideration of the views of the LPAs and the different options available to HSE, the recommendations of the scoping study were that:

• The mapping information is made available to LPAs in GIS format.

• The information is initially supplied in ESRI ArcGIS shape file format.

• Current paper copy maps that are not in this format are converted and any new maps that are created are done so in this format, to allow for easier transfer into the system and to realise future efficiency savings.

• Feedback is sought from the LPAs in the first phase of the information roll out to determine the satisfaction with the new format and delivery mechanism.

• Longer-term delivery options should be explored further as progress with the HSE Extranet in made.

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6 REFERENCES

Arnold, J. (2005) Work Psychology: Understanding Human Behaviour in the Workplace (4th Edn.). Prentice Hall.

Casstles, H., Ford, N.J., Murply, R.G. Green, L.M., & Rennie, D.M. (1998) Managing Training for Health and Safety Enforcement Officers – A Guide for First Line Managers. Department of Environmental Management. University of Salford.

Casstles, H., Ford, N.J., Murply, R.G. Green, L.M., & Rennie, D.M. (2000) Evaluation of Alternative Training Provision for Local Authority Health and Safety Enforcement Officers. School of Environment and Life Science, University of Salford.

Cole, G.A. (2004) Management Theory and Practice. 6th Ed. Thomson Learning. London.

Continental Research (2005) Presentation on Communication with Health and Safety Practitioners (unpublished, emailed).

Ford, N., & Green, L. (1996) Report of the Development of a Training Strategy for Local Authority Health and Safety Inspectors. TIME Research Institute, University of Salford.

Ford, N., & Green, L. (2004) Evaluation and Further Development of the HELA National Training Co-ordination Website. Built & Human Development Research Institute, University of Salford.

Ford, N.J., Brown, J.M. & Williams, H.J. (2005) An Evaluation of the HELA-Training Coordination portal’s ability to support communications between LAs and HSE, and to enable and encourage knowledge sharing by LA-based health and safety enforcement teams. Report submitted to HSE.

Garton, M., (1997) Health and Safety Enforcement: Competence, Consistency and Training. London: Chartered Institute of Environmental Health.

Hampton, P. (2005) Reducing administrative burdens: effective inspection and enforcement, HM Treasury.

Howard, M., & Galbraith, A. (2005) Factors Influencing Local Authority Health and Safety Interventions and Enforcement Activity. King’s College London.

McGowan, T., (2005) Summary Report: ELO interviews Jan/Feb 05- Draft.(Unpublished work)

Prince, L., Campbell, A., and Nanton, P. (1995) Training for Health and Safety Enforcement. Birmingham: The Institute of Local Government Studies (INLOGOV).

Reid, A., & Barrington, H. (1994) Training interventions, 4th ed. Institute of Personnel and Development.

Storey, T (2001) Human Resource Management: A Critical Text. Second Edition. Thomson Learning: London

Wilson, E. (1998) Health and Safety Enforcement Officers Standards of Competence. 89

7 GLOSSARY

ENFORCEMENT OFFICER The enforcement officers included in this study are Environmental Health Officers (EHOs), Technical Officers (TOs) and Technical Assistants (TAs). EHOs are specialised in one or several aspects of Environmental Health including food, health and safety and other environmental concerns. TOs are warranted in only certain specific areas.

HSE inspectors, specialists and professionals in post in 2005 (source: HSE Personnel)

Count FTE Agriculture, Factories, Quarries 953 916.09 Medical 16 14.04 Mines 14 14 Nuclear 164 162.73 Nursing 30 28.23 Offshore 141 138.54 Railway 66 65.01 Specialist 222 217.74 TOTAL 1606 1556.38

HSC Section 18 guidance It is a guidance issued by the Health and Safety Commission under section 18 of the Health and Safety at Work Act 1974 to local authorities which have the duty to act in accordance with the guidance. It includes enforcement policy and procedures, provision of a trained and competent inspectorate etc. It also states in Annex 2 the list of competences for HSE and LA health and safety inspectors which is drawn from the Level 5 NVQ for Regulators (the list is in appendix 5)

Competency framework It is a document or series of documents detailing how competency and performance are managed. It contains a list of the core and functional competences (skills, knowledge, experience, etc) needed in a particular role and also the standard of competence as defined in the HSC section 18 guidance. It can also include type of qualification and training needed to attain a particular competence level, other forms to explain and record performance or CPD.

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Printed and published by the Health and Safety ExecutiveC30 1/98

Published by the Health and Safety Executive01/06

RR 418

research report 418 - hse: information about health and ...training and information, and for access...

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