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Matthew Lee

36 years with HSE now

H&S consultant

Questions as we go

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HSG65 version 3 in context

Demise of management regulations ACOP

Slightly confused birth
BS and ISO standards

Shorter - 62 pages from 98 pages

Accompanying INDG 275 – New version
slightly longer

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Management of H&S at work

Regulations 1999
Provides the legal requirement for
the overall management of H&S
within an organisation

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Regulation 5
Every employer shall make and give effect
to such arrangements as are appropriate,
having regard to the nature of his activities
and the size of his undertaking, for the
effective planning, organisation, control,
monitor and review of the preventative
and protective measures.

The two full pages of further guidance in

the ACOP has now been removed.
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Where does this leave -
Regulators –
HSG65 says that it is not compulsory but if you follow
it you will normally be doing enough to comply with
the law.

H&S Inspectors may use HSG65 as a benchmark.

But unlike the ACOP it has no legal status.

Employers and H&S professionals – What does

“compliance” look like?
You may have a different system – if you do you
need to be able to explain how it complies with Reg 5
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Where does this leave -

Courts – May have some difficulty in

understanding what “non compliance” looks like.

Corporate manslaughter guidance is that a jury

must have regard to H&S legislation and may
consider guidance produced by the regulator.

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Management - HSE web site

Directs you towards:-
Health and Safety made simple

Health and safety toolbox – PDCA

HSG65 – Managing for health and safety – PDCA in

detail with a brief guide Plan Do Check Act INDG 275

INDG 417 – Leading on health and safety at work

Some more similar guidance

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HSG 65 – PDCA in detail

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General style of document

Each element is described in detail with references for
further information.

It has helpful key actions boxes for:-

Leaders
Managers
Worker consultation and involvement
Competence

and tables of:-

What it looks like if done effectively and
What it looks like when done badly or not at all

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Policy
Proportionate to risk and risk profiling

Designed to meet legal requirements

Where you are and where you want to be

How you are going to measure performance and deal with

emergencies.

Who is going to do what and how (? organisation)

Consultation – difference between HSG 65 and 417

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Planning for implementation
Co-ordinated action by all members of the
organisation to achieve control of risks and
react to changing demands.

Leaders have a key role to play in setting the

agenda – INDG 417 – different from HSG65

Linked to how you mange other aspects of

your business
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 Links to how you mange other aspects of
your business

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Planning for implementation

Role of leaders and managers have to play

Worker consultation

Competence

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Do
Risk Profiling –

Who could be harmed and biggest risk

Assessing risks – suitable and sufficient – compare with

industry standards

Health surveillance (? Check)

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Do
Organising – Involving workers, communication, resources

Controls within the organisation

Leadership
People know what they have to do

Co-operation between workers and managers and external

services and others (inc contractors)

Communication across the whole organisation

Competence – at all levels, internal as well as external. Not

just training – skills, knowledge and experience
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Do
Implementing - decide what you need to do and then
make sure it is achieved.

Implement necessary controls as identified by your risk

assessment process

Give people the right tools to do the job

Ensure competence - train, instruct and supervise.

Documentation will help

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Check
Measuring performance

Proactive – different methods looking at:-

What has happened in the past
What is happening now
What is in front of you

Reactive – accidents and incidents

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Act
Review performance
Learn from incidents
Revisit plans policies and risk assessments

Take action

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Main Standards
All based on PDCA model. All auditable

BS EN ISO 9001 – Quality Management Standard

BS EN 14001 – Environmental Management Standard

BS OHSAS 18001 – Occupational Health and Safety

Management Standard – 90K certifications in 127
countries.

“to enable an organisation to proactively improve its

OH&S performance in preventing injury and ill health”
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Approach by standards
Control loop
Identify the issues that need to be addressed
Set direction/standards that need to be achieved
Plan what needs to be done
Organise who is going to do it
Equipment them to do so
Do it
Check that it has been done
Check that it worked
Learn from/ feedback lessons from this exercise to
(continually) improve (the process and the outcomes)
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Standards
The customer is the main stakeholder for some
standards such as 9001.

Society (via the regulator) is the main stakeholder for

others such as 14001 and 18001.

There can be conflicts between H&S and environment.

There can be benefits in having an integrated

management system which incorporates all elements as
this is likely to achieve overall reduction in risk to the
business.
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18001 to be replaced by ISO 45001
Draft in April 2015, Final Draft June 2016. Publication
October 2016

“to enable an organisation to control its OH&S risks and

improve its OH&S performance”

Is there any real difference between to two?

ISO and BS both are based on the PDCA approach

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45001
ISO requires consideration of more external issues to be
considered such as stakeholders.

Those involved in auditing for 45001 will require a

better understanding of the sector in which the
organisation operates and this is likely to involve
challenging those at the highest level of an organisation
which may be new to many of them.

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HSG 65 v 18001
HSG 65 is just guidance from the HSE on what you might do.
OHSAS 18001 is an auditable H&S standard. The basic core
requirements are similar to that in HSG 65 but 18001 goes
into much more details of what you must do to comply with
the standard.

It depends on what you want-

Anybody can follow HSG 65 but if you want to go for OHSAS
18001 then you will need to expend some time, effort and
money to make it happen.
Remembering that OHSAS will disappear in the next few
years and be replaced by ISO 45001.
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Changes between HSG65 versions 2 and 3

Healthandsafetyatwork – HSG65 Foundation sculpting June 14

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Changes between HSG65 versions 2 and 3

Much clearer guidance on what compliance

looks like

Each element has key guidance for leaders,

managers, worker consultation and
competence

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Changes between HSG65 versions 2 and 3

Links H&S to other business risks

More on risk profiling, leadership

competence, worker involvement and
contractors

Less on hazards and auditing

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References
Management of Health and Safety at Work Regulations 1999
Managing for Health and Safety - HSG 65 (third edition 2013)
Plan, Do Check, Act – INDG 275 (rev 1 12/13)
Health and Safety Made Simple - HSE
The Health and Safety Toolbox - HSE
Leading Health and Safety at Work – INDG417 (rev 1 6/13)
Managing Integration - IIRSM Technical paper March 2012
Health and Safety at work Feb 14 – End of L21
ROSPA – Sept 13 -What’s happened to HSG65 and POPIMAR

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References
BS EN ISO 9001:2008 Quality management systems.
BS EN ISO 14001:2004 Environmental management systems.
BS OHSAS 18001:2007 Occupational health and safety
management systems.
(Not free e.g. 14001 – 38 pages £174 or £87 for members !)

HSE Comparison of HSG 65 with other key management

“standards”

ILO-OSH 2001 Guidelines on occupational safety and health

management systems (free)

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