Appendix 2
This appendix provides suggested answers or thoughts about the questions you are asked in each chapter.
Jump to the chapter on this page using the list below:
Chapter 1: Identify the hazards – the theory
Chapter 2: Understanding of what you are assessing
Chapter 3: Identify the hazards – doing it differently
Chapter 4: How to meet your duty of care, and make sure you don’t leave anyone out of your risk assessments
Chapter 5: The oversimplification of risk assessment and control
Chapter 6: Dealing with essential controls before you consider ‘reasonably practicability’
Chapter 7: The theory of assessment. This chapter turned out quite long, so I divided it into two:
Chapter 7a: The theory of assessment
Chapter 7b: What’s wrong with how we do risk assessment
This is followed by three chapters explaining some improved ways of doing the ‘assess’ or ‘evaluate’ step of risk assessment, with or without a matrix.
Chapter 8: Assessment without a matrix
Chapter 9: Assessment with a better matrix (if you insist!)
Chapter 10: Assesment – test your matrix
Chapter 11: How to generate better controls
Chapter 12: Is it enough, is it practicable?
Chapter 13: Documenting your findings – the theory
Chapter 14: How to document your findings better – using other documents
Chapter 15: How to document your findings better – the risk assessment package
Chapter 16: Reviewing assessments, or reviewing controls? The theory and where it goes wrong
Chapter 17: Effective and timely reviews of risk assessments and controls
Chapter 1: Identify the hazards - the theory
1.4 We don’t know what Things are
The broom’s hazardous potential is sufficiently low as to be trivial, unless it is stored badly and tripped over, or used in a way that creates muscle strains. Or if it is used as a weapon to hit journalists who write bad articles. The non-trivial hazard is the wood dust, and one that the journalist and the business owner didn’t understand.
1.6 We need to consider the right people, and at every step
The cyclist will be harmed. The hazard could be described as the car, the driver or “driving a car”. The cyclist might be a significant hazard to a pedestrian, but in this scenario, is unlikely to cause significant harm to the driver.
Back to Chapter 1.
Chapter 2: Identify the hazards - understanding what you are assessing
2.4 Systematic examination of tea-making
Here’s a version of the completed table.
| Task step | What if? | What could go wrong? |
|---|---|---|
| Unplug the kettle so that you can carry it to the sink | Too wet? | If your hands are wet you could be electrocuted |
| Carry the kettle to the sink | Too hot? | If the kettle has some hot water in it from a previous use you could be scalded |
| Too heavy? | If the kettle has water in it from a previous use you could spill it and create a slip hazard | |
| Empty any existing water into the sink | Too hot? Too full? | If the kettle has some hot water in it from a previous use you could be scalded |
| Fill the kettle with cold water | Too fast? | You could get water into the electrical socket on the kettle |
| Too full? | You could spill water and create a slip hazard | |
| Plug in the kettle and switch on | Too wet? | If your hands are wet you could be electrocuted |
| When the water has boiled, pour some into the pot to warm it | Too full? | You could spill the water |
| Too hot? | You could be scalded | |
| Take the tea pot to the sink to empty the warming water | Too fast? | You could drop the teapot, and the broken china could cause cuts to you or other kitchen users |
| Place leaves in the pot | Too much? | Tea could be too strong |
| Too little? | Tea could be too weak | |
| Pour boiling water onto the leaves in the pot | Too hot? | You could be scalded |
| Too full? | You could spill the water | |
| Wait three minutes and pour the tea | Too soon? | You could be impatient and have weak tea |
| Too late? | You could be distracted and have stewed tea |
Back to Chapter 2.
Chapter 3: Identify the hazards - doing it differently
Figure 3.1: Including risk factors to understand hazards
| Hazard | Hazardous event | Post-event risk factors | Consequence |
|---|---|---|---|
| Oil on floor | Slip and fall | Balance, infirmity, floor surface, footwear | Injury eg broken bones |
| Uneven floor surface | Trip and fall | Balance, infirmity, floor surface, footwear | Injury eg broken bones |
| Vibrating tools | Prolonged use resulting in excessive exposure to vibration | Health surveillance & reporting; reduce future exposure | Numbness, reduced grip strength, HAVS |
| UV from welding | Eyes exposed to UV light | Speed of first-aid following acute injury; surveillance & reporting for slower damage | Eye damage |
Back to Chapter 3.
Chapter 4: Identify the hazards - include all the right people
4.2 Traditional direction
Table 4.1 provided suggestions for people who could be more susceptible to harm by specific hazards. Here are some more. As before, links to the HSE website are provided for hazard-specific advice.
Table 4.1 extended: More hazards and people harmed
| Hazard | Who could be (more) harmed? |
|---|---|
| Prolonged sitting or standing or other static posture, or working in a restricted space | Pregnant workers. Heavily overweight people. People with pre-existing musculoskeletal conditions, or other health conditions, such as multiple sclerosis (MS). |
| Hazards that could result in slips, trips and falls | A person’s point of balance can change during pregnancy, increasing the likelihood of losing balance when slipping or tripping. The consequences of a fall can be greater, as it could result in harm to the unborn child. |
| (particularly if driving). Note impact of error can be broader than just the fatigued worker.Fatigue, leading to errors and accidents | Pregnant parents New parents (whether or not they gave birth to the child) Young people adjusting to work for the first time Workers suffering from physical or mental illness or any condition which reduces their sleep. |
| Lone working | People with pre-existing medical conditions which could become emergencies if fast treatment is not provided. For example, those with heart conditions, insulin-dependent diabetics, people in pregnancy stages where they may be more vulnerable. |
| Heights | People with recurring dizziness, vertigo, or poor balance. Those with a phobia of heights. People with physical impairments which make safe access and egress to a height difficult. People on medication that warns against “operating heavy machinery.” Additional checks might be needed for epileptics, diabetics, people with heart and lung conditions. |
Ask yourself: PEEPS and GEEPS
Traditionally applied to people with physical and sensory disabilities, these can be a useful approach for:
- people with learning needs
- temporary medical conditions
- people facing life events such as birth, marriage, divorce or death
Back to Chapter 4.
Chapter 5: Assess the risk - some theory and its flaws
Notes will be added later if needed.
Back to Chapter 5.
Chapter 6: Control the risk - what you have to do before you assess
Notes will be added later if needed..
Back to Chapter 6.
Chapter 7a: Assess the risk - theory
Might move the box on ordinal data here.
Back to Chapter 7a.
Chapter 7b: Assess the risk - what's wrong with the application
Section 7.7 of Chapter 7b asked this question:
What it would mean to have a 3% chance of a ladder accident every time someone climbed a ladder? How many times could people climb a ladder in an organisation before the chance of an accident was more than 50%? How many times before the chance was over 99%?
The probability of an accident NOT occurring on one occasion is 1 – 3% = 0.97
The probability of an accident not occurring on two occasions is 0.97 x 0.97
The probability of an accident not occurring on ‘n’ occasions, where n is the number of times the ladder is climbed, is 0.97n
If n = 23, probability of an accident not occuring drops below 50%
When n = 152, it drops below 1% – that is, you would by 99% certain of an accident.
Think about how often people climb ladders, and then decide if in your organisation you would call 3% ‘rare’.
References in Chapter 7b
Intergovernmental Panel on Climate Change (IPCC): Budesen DV, Broomell S, & Por HH (2009). Improving Communication of Uncertainty in the Reports of the Intergovernmental Panel on Climate Change. Psychological Science, 20(3), 299–308. www.jstor.org/stable/40575018
Royal London Hospital: Earlam R, Rizwan-Hasib M, Tross S & Morris G (2007). Obtaining consent for an operation: A choice of words or numerical probabilities? Clinical Risk, 13(2), 45-52. https://doi.org/10.1177/135626220701300202
Value assigned to “rarely” depends on consequences. Rector T S (2008). How Should We Communicate the Likelihood of Risks to Inform Decisions about Consent? IRB: Ethics & Human Research, 30(4), 15–18. http://www.jstor.org/stable/20460687
Probability depends on exposure. Herbstritt M & Franke M (2019). Complex probability expressions & higher-order uncertainty: Compositional semantics, probabilistic pragmatics & experimental data, Cognition, 186, 50-71. https://doi.org/10.1016/j.cognition.2018.11.013
Alternatives to single point risk matrices:
- Duijm NJ (2015). Recommendations on the use and design of risk matrices. Safety Science, 76, 21–31. https://doi.org/10.1016/j.ssci.2015.02.014
- Ale BJ, Burnap P, & Slater DH (2015). On the origin of PCDS – (Probability consequence diagrams). Safety Science, 72, 229-239. https://doi.org/10.1016/j.ssci.2014.09.003
Back to Chapter 7b.
Chapter 8: Better assessment
Here are some possible harm statements for ‘slipping on a wet surface’:
Office staff could spill coffee, which could lead to themselves or a colleague slipping, resulting in bruising or a minor break. You probably don’t want to go as far as banning coffee, but do you restrict where people can drink it or carry it? Do you insist on mugs with lids? Do you clarify the regime for cleaning?
Residents in a care home could spill coffee, which could lead to themselves or another resident slipping, resulting in a broken hip or other cause of hospitalisation. Without any numbers you can see that while further controls in an office might not have been necessary, in a care home restrictions on where drinks are consumed and who can carry them, and a prompt cleaning regime, have a higher priority.
Catering staff could slip on oil near the deep fat fryer, and part of their body be burned by the hot oil. This type of accident has happened multiple times. Most of the hot oil catering incidents I’ve read have been during the emptying or transporting of oil, which makes one control measure very obvious without needing a number for likelihood or severity. Don’t empty or transport oil while it is hot. Another case occurred where a chef plunged his arm into hot oil when he tried to steady himself after his foot slipped. Tackling this problem could involve involve covering the oil, looking at routes through the kitchen, considering cleaning regimes or looking at footwear and floor surfaces.
Back to Chapter 8
Add Your Heading Text Here
Chapter 9: Assessment with a better matrix (if you insist)
9.6 Understand your axes – severity anchor
Problem 3 was where to put an issue you expect to result in 5 days’ absence from work. If Moderate is “up to 3” and Major is “more than 7” there is no where to put 5 days.
9.8 Understand your axes – an alternative
This is the suggested answer to the question raised in Section 9.8, with Figure 9.8 completed. See the explanations below the table.
| Scenario | Monitor | Manage | Take action |
|---|---|---|---|
| Office staff using a stepladder to reach a bookshelf | X | ||
| Infant children crossing a busy road alone from the school to the playing field. | X |
||
| Trained technicians using tools for routine maintenance | X |
Office staff using a stepladder to reach a bookshelf – Manage (eg inspect ladder regularly, provide training so staff can make pre-use checks and use appropriately). Long term you might rearrange shelves to remove the need for using a ladder, or to reduce reliance on a ladder, but practically, it’s a lower priority.
Infant children crossing a busy road alone from the school to the playing field – Take action. Obviously has to STOP until there’s a safer solution.
Trained technicians using tools for routine maintenance – Monitor. Can’t see anything wrong with this, but like any system it needs monitoring.
Back to Chapter 9
Chapter 10: Assesment – test your matrix
Figure 10.8 showed possible risk management actions for the first four situations listed in Figure 10.5, and you were invited so suggest some for the remaining actions. The table below shows some possible answers. You might have different answers, and that doesn’t mak them wrong – it’s all down to context.
| Situation | Summary | Possible actions |
| A. Falling down well-maintained stairs in an office building. | Monitor | Condition of the stairs Behaviours on the stairs (eg carrying too much, walking while texting) Outcomes of investigations into near misses related to tripping on or near stairs. |
| B. A vehicle / pedestrian collision in a busy loading bay with no segregation. | STOP until | Design in segregation of vehicles and pedestrians |
| Then Manage ALARP | Check and monitor lighting, PPE needs and use, marking of walkways and signage. Check and monitor adherence of vehicles and people to segregation |
|
| C. A road accident in an organisation with hundreds of drivers driving a vehicle model which has recently had a safety alert, because of a fault that causes brakes to fail at speeds over 60mph | STOP until | STOP all non-essential vehicle movements, and require drivers to stay below 55mph until the problem is investigated, and as appropriate fixed in each vehicle. |
| Then Manage ALARP | Driver, vehicle and fleet safety. Monitor Outcomes of investigations into vehicle incidents (including near misses) |
|
| D. Charity shop worker pricks their finger with a price-tagging gun. | Manage ALARP | Improve near-miss reporting Work with procurement to replace tagging guns over time |
| E. Occupational asthma from use of hazardous substance. | STOP until | Eliminate use of asthmagens where reasonably practicable. When not practical to eliminate, full COSHH controls must be in place including screening, training, PPE and health surveillance |
| Then Manage ALARP | If not eliminated, continue to look for substitutes and safer methods of working. Monitor required controls for implementation and effectiveness. |
|
| F. Fall from a ladder. | Manage ALARP | Assessments to identify where work from ground or other means of access is reasonably practicable. WAH management plan to ensure procurement, choice of equipment, regular and on-the-job checks etc. |
| G. Work-related stress due to pressure at work. | Manage ALARP | Use stress management standards to assess pressures; identify how to remove/ reduce pressures. |
| H. A fall from a 2nd-floor window in a stairwell while moving furniture | STOP until | STOP any activities that put someone at risk of falling through a window. Fixing bars to the window provides a physical barrier, although elimination and reduction measures below should be considered too. |
| Manage ALARP | Allocate rooms to avoid the need to move equipment between floors Provide equipment on all floors so that regular movements are not required Install goods lift. |
|
| I. Musculoskeletal (MSK) pain that requires time off work but no treatment from manual handlng. | Manage ALARP | Review manual handling tasks and identify RP measures to reduce the risk, starting with redesign of tasks and environment, backed up by training and tools |
Back to Chapter 10
Chapter 14: How to document your findings better – using other documents
Other topics for inventories
Here are some further suggestions of where you might need an inventory before you launch into risk assessments:
- Lifts: You will already need a list of passenger and goods lifts for LOLER purposes, but you could expand the list to cover other checks you might make on lifts. For example, which of the passenger lifts can be used in a fire for evacuating people who can’t use the stairs? Who has been trained to use the evacuation lifts?
- Desks: Display screen equipment (DSE) assessments have to be personal, but if you have shared desks an inventory might be useful, particularly when you have a lot of desks below standard. One client asked me to include DSE assessments on regular checks of their premises. In 90% of cases the desks were too small to pass an assessment, regardless of how the user arranged the computer. Around 40% of desks didn’t have an office chair, and users improvised with dining room chairs or stools. An inventory of the locations of desks and the underlying faults would have enabled fixes across the organisation to be prioritised.
- Water outlets (taps, showers): Legionella controls and monitoring are best supported with a water schematic and a list of water outlets to be checked. This makes it less likely something is missed out.
Back to Chapter 14
Chapter 15: How to document your findings – what doesn't work in practice
This is a reformatted version of the risk assessment in section 15.5. I’ve retained the HSE five columns, but I’ve used the Scope section to remove the first two columns (hazard and who is harmed). This example shows that even if you can’t change the fields required in the risk assessment drastically, some formatting changes will improve readability.
Back to Chapter 15
Chapter 16: How to document your findings – a better way
Figure 16.5: Controls in advance and on the day
Here are some suggestions about how to complete the last two columns – you might have done this differently, because we’re assuming different contexts.
| Hazard | Harm statement | Controls in advance | Controls on the day |
|---|---|---|---|
| Handling deliveries | If a driver tries to move too many items in one go, they could suffer a musculoskeletal injury | Procurement will ensure appropriate trolleys are purchased Maintenance will check trolleys as per schedule PPM 8975 | Use the trolley for deliveries unless there is only one small item carried a short distance. Check the trolley and the load each time you use it, making sure the load is secure. |
| If a driver drops one of the deliveries, they could injure their own feet or those of a bystander. | Drivers are provided with a trolley and have been shown how to use it. Training doc ref: MH 0202 |
||
| If deliveries are made in poor weather or on uneven ground, a worker could fall while carrying items, causing sprains or bruising. | Procurement will ensure trolleys purchased have all weather wheels. Maintenance trolley checks PPM 8975 Training doc ref: MH 0202 | If you are unfamiliar with a delivery location, check the route first to avoid obstacles. If uneven or wet ground cannot be avoided, reduce the load on the trolley. | |
| If items are carried in a way that blocks the driver’s visibility, they could collide with another person or object, leading to impact injuries for the driver or other person. | Maintaining visibility while carrying is covered on training course Training doc ref: MH 0202 | Do not overload the trolley – you must be able to see the route ahead and any obstacles. Make two or more journeys if necessary. |
Chapter 16 also suggested re-writing Figure 15.5 in the same way. Here’s one possibility.
| Controls in advance | Controls on the day |
|---|---|
| Annual refresher training is provided as per training doc T6543 monitored in safety training log | Staff make visual checks as outlined in training doc T6543 |
| 6-monthly checks of maximum load capacities are ensured through PPM 5623 | |
| Weekly inspection of brackets, moving to 3-monthly inspection of brackets once new ones are in place. Inspection PPM 2722 | At start of the day, warehouse supervisor will send a photo of the checked racks to the safety manager. Reminder is provided by PPM 7468 |
Back to Chapter 16
Chapter 17: Effective and timely reviews of risk assessments and controls
Answer to ‘Ask yourself' in Section 17.2
‘Ask yourself: Find relevant clauses in any legislation that impacts you’ in relation to MHSW Regulation 5. Examples:
Table 17.1 expanded: More examples of review triggers in UK legislation and guidance
This is an expanded version of Table 17.1, with more examples of review triggers in UK legislation and guidance. Remember though that reviewing the risk assessment is not the same as reviewing and monitoring the controls.
| Review trigger | Evidence |
|---|---|
| Health surveillance and assessment | Legislation states that the risk assessment and relevant control measures should be reviewed if health surveillance suggests that despite controls, an employee suffers harm from exposure to relevant hazard eg COSHH 11(9), Noise 9(4) or Vibration 7(5) or Lead 10 (7,8) |
| HR records | Sickness absence reports – ask whether work-related, and look for stress and anxiety, as well as obvious work-related conditions such as musculoskeletal disorders. Resignations, especially where clusters are seen in workers under a single line manager (see Box 17.1), could indicate a need to review your assessment of workload, stress management or other pressures – use exit interviews to find out in detail why people are leaving. |
| Measurements and monitoring | L8 (65) is quite specific about checking, inspecting and monitoring water systems. HSG 274 provides detailed guidance on the types of checks and monitoring. If you have a scheme that requires checking water temperature, then there must be a review of the water risk assessment if temperatures are out of range; if the scheme requires checking for rust, there must be a response if rust is found. Noise levels or Vibration levels increase from previously assessed values. For example, you might re-assess controls if there is a change to working processes (L140 (44) and L108 (57)). This applies to all measurements and monitoring, even where there is no specific guidance. If you have an indication that controls are not effective, you need to review the system of controls. |
| Accidents or near misses | In relation to manual handling, L23 (56) advises that an accident or incident, or ill-health could all be indications of a “reason to suspect” that an assessment is not valid. A case of legionnaires disease or legionellosis would be a reason to review a water risk assessment (L8, 47). COMAH operators must review their safety reports (effectively, a comprehensive and detail risk assessment) following a major accident or from near misses – COMAH 10(2). Although not a requirement, HSE guidance HSG 245 explains the legal duty to use accident investigation findings to “point to areas of your risk assessments that need to be reviewed.” You’ll learn the most if as well as looking at internal events, you study news reports for external events and prosecutions. Ask: • Could this happen here? • If so, what controls do we have to prevent it? • Could our controls have failed in the same way? |
| People | The effect of MHSW is to require the review of existing risk assessments, or new risk assessments when expectant or new mothers are employed (Regulation 16) and when young people are employed (Regulation 19). The need to review controls where young people are near work equipment is reinforced in PUWER L22 (127 – 130). MHOR L23 (74 – 83) expands on the list of people who might need a specific review of the risk to include older workers and those with pre-existing health conditions or disabilities that might affect their handling capability. INDG 143 explains the need to review work activities and risk assessments when workers change – this could be staffing levels changing, a change in employment status (such as contracting work out) or just new people. |
| Process or methods, plant, equipment or tools, materials or substances, work location | PUWER L22 (207) advises the review of the stabilising method for mobile work equipment every time it is moved. MHOR 4(2) requires manual handling assessments to be reviewed if there is a significant change to the tasks, or any other reason to suspect the assessment is not valid. INDG 143 suggests a review should also be triggered by changes to “production processes”. L8 (47) has a list of reasons for reviewing the legionella risk assessment, including changes to the water system, the use of the water, or the use of the building. COMAH operators must review their safety reports before making modifications to the process or the building, or to any substances used. COMAH 10(2). |
| New information including experience | Maintenance is a key control measure for work equipment. L22 (76) guidance for PUWER advises the review of additional maintenance measures that might be needed in arduous conditions. MHOR requires manual handling assessments to be reviewed if there is any other reason to suspect the assessment is not valid. This could be damage to stock or products from mishandling, observations or suggestions from workers of alternative approaches. Since your original controls will have been based on the context of law, guidance, standards, good and best practice, if any of these change, this should trigger a review of those controls. |
| Calendar-based – minimum triggers where no other trigger applies. | These are a minimum, where no other triggers apply. In most cases organisations must set a “reasonable” period for review, for example depending on risk (MHSW). However, many organisations set the same review period (eg every 2 years) for all risk assessments, regardless of risk or frequency of use. Different review periods could be more cost-effective in managing risk. L143 (143) has an ACoP clause requiring asbestos management plans (AMP) to be reviewed at least once every 12 months (as well as when circumstances change). While an AMP is not a conventional risk assessment, it documents the arrangements for controlling risk. COMAH operators must review their safety reports at least every five years, even if nothing changes (which is hard to imagine). See COMAH 10(1). While HSG 274-2 Table 2.1, HSG 274-1 Table 1.2, and HSG 274-3 Appendix 6 list recommended starting frequencies for some monitoring tasks related to legionella control, the recommendation in previous versions of L8 to review the risk assessment every 2 years has been replaced by a risk-based recommendation. The detailed IET table which gave different frequencies for portable appliance testing (PAT) for different types of equipment disappeared in the 5th edition of the IET Code of Practice for In-Service Inspection and Testing of Electrical Equipment in 2021. |
References to UK legislation and guidance used in Table 17.1 expanded
COMAH – Control of Major Accident Hazards Regulations 2015. Although most readers won’t fall into COMAH regulations, the triggers in 10(1) and (2) are useful reminders of when it might be appropriate to review a risk assessment.
COSHH – Control of Substances Hazardous to Health Regulation; L8 is the Approved Code of Practice and guidance for Legionnaires’ disease, based on COSHH regulations and other relevant legislation. L8 is supported by three technical documents:
HSG 274-1 Legionnaires’ disease. Technical guidance Part 1: The control of legionella bacteria in evaporative cooling systems.
HSG 274-2 Legionnaires’ disease. Technical guidance Part 2: The control of legionella bacteria in hot and cold water systems.
HSG 274-3 Legionnaires’ disease. Technical guidance Part 3: The control of legionella bacteria in other risk systems.
HSG 245 – Investigating accidents and incidents 2014
IET Code of Practice for In-Service Inspection and Testing of Electrical Equipment 2020
L143 – Managing and working with asbestos. Approved Code of Practice and guidance for the Control of Asbestos Regulations 2012.
Lead – The Control of Lead at Work Regulations 2002
MHOR – Manual Handling Operations Regulations 1992; Guidance on Regulations is L23; Brief guide is INDG 143.
MHSW – The Management of Health and Safety at Work Regulations 1999
Noise – The Control of Noise at Work Regulations 2005
L108 Controlling noise at work. The Control of Noise at Work Regulations 2005. Guidance on Regulations
PUWER – Provision and Use of Work Equipment Regulations 1998. Approved Code of Practice and guidance is L22
Vibration – The Control of Noise at Vibration Regulations 2005
L140 Hand-arm vibration. The Control of Vibration at Work Regulations 2005. Guidance on Regulations
Back to Chapter 17
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Appendix 1: Case studies by year
Appendix 2: Answers to questons posed in each chapter
Appendix 3: Lost HSE references