HSE LAC 91/3

Posted: Fri Dec 10, 2004 11:49 am

The following Local Area Authority Circular is aimed specifically at Health, Safety and Welfare of Security Staff.
The content and scope of this circular is due for renewal in November 2005 and feedback is required to assess whether the scope of the document is wide enough (does it cover all the area's we think it should) and whether those area's that are covered at present - whether the recommendations laid down go far enough, or too far.
This is an excellent opportunity to have the HSE change their guidence on enforcement for the Security industry, so please take the time to give your feedback.
The original document can be found here;
http://www.hse.gov.uk/lau/lacs/91-3.htm
The content of which is reproduced below for your benefit.

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HEALTH, SAFETY AND WELFARE OF SECURITY STAFF

INTRODUCTION
1 It is believed that in the order of 100,000 people are employed by security firms in this country, of which some 30,000 are members of trades union (almost exclusively the GMB).

BACKGROUND
2 Many of these employees act as security guards on the premises of other companies when the normal process has ceased for the day and when the normal welfare facilities are unavailable.

3 Information received from the GMB suggests that the conditions under which many security personnel are employed fall well short of HSW Act requirements, particularly in the areas of welfare and training. Small security companies are likely to provide poorer facilities than national companies.

WELFARE REQUIREMENTS
4 At most premises enforced by LAs it will be reasonably practicable to provide the usual welfare facilities, including sanitary conveniences, washing facilities, a warm comfortable rest room (if a suitable office is not provided) and drinking water. Where lone working takes place, a telephone should normally be provided to allow help to be summoned.

5 Night time security staff are often expected to work long shifts and are forbidden to leave the site. In these circumstances it would normally be reasonable to expect facilities for producing hot beverages and warm food to be provided.

6 Staff who are required to work outside should be issued with suitable wet weather protective clothing and facilities should be provided for drying and storing that clothing and personal clothing.

TRAINING
7 Security staff are often required to inspect all parts of the premises to which they are allocated on a fixed routine. The primary duty rests with the occupier of the site to ensure that it is left in a safe condition but the security company also has a duty to its employees to provide adequate instruction and, where necessary, training so far as reasonably practicable to enable them to avoid danger.

8 Training is also required to ensure that the staff are able to react appropriately in the event of any kind of incident.

ENFORCEMENT APPROACH
9 During routine inspection of premises which are protected by security staff, enforcement officers should inquire into the facilities available and the other aspects outlined above. Particular attention should be paid to the conditions which prevail after the normal process has ceased for the day.

10 At routine inspections of the head offices of security firms the conditions of staff employed at remote locations should be discussed. The safety policy should, of course, address all the activities of the company.

Posted: Fri Dec 10, 2004 12:16 pm

My own thoughts are as follows;

John_Haywood wrote:

1 It is believed that in the order of 100,000 people are employed by security firms in this country, of which some 30,000 are members of trades union (almost exclusively the GMB).

This needs to be amended to represent a more accurate picture of the number of people it affect, current estimates are in the region of 500,000 security operatives working in the UK.

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3 Information received from the GMB suggests that the conditions under which many security personnel are employed fall well short of HSW Act requirements, particularly in the areas of welfare and training. Small security companies are likely to provide poorer facilities than national companies.

Personally, I think the size of the security company and the adequacy of welfare facilities are NOT directly linked. This statement by the GMB is misleading and could lead to enforcement officers being prejudiced in their assessment by 'assuming' that beacause the company might be large, the welfare facilities are automatically adequate.

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4 At most premises enforced by LAs it will be reasonably practicable to provide the usual welfare facilities, including sanitary conveniences, washing facilities, a warm comfortable rest room (if a suitable office is not provided) and drinking water. Where lone working takes place, a telephone should normally be provided to allow help to be summoned.

Erm, there is nothing 'reasonably practicable' about being able to provide adequate facilities. Providing toilet facilities, the means to make a hot drink, hand-washing facilities and a means of reliable VERBAL communication to summon help should NOT be subject to the 'as far as is reasonably practicable' rule - it should be compulsory - full stop - end of story!

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5 Night time security staff are often expected to work long shifts and are forbidden to leave the site. In these circumstances it would normally be reasonable to expect facilities for producing hot beverages and warm food to be provided.

As above, this should NOT be subject to the 'as far as is reasonably practicable' rule.
Where it is 'IMPOSSIBLE' to provide the facilities outlined, it should be subject to a means test - that is, if the site is in Outer Mongolia and there simply is no water, then a maximum shift length should be set and an onus on the employer to provide clear evidence of the steps taken to provide any facilities.

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6 Staff who are required to work outside should be issued with suitable wet weather protective clothing and facilities should be provided for drying and storing that clothing and personal clothing.

Perhaps some guidance here on the temperature versus length of exposure time could be issued as a guide, likewise, exposure to adverse weather such a rain, snow etc with a minimum working temperature introduced.

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7 Security staff are often required to inspect all parts of the premises to which they are allocated on a fixed routine. The primary duty rests with the occupier of the site to ensure that it is left in a safe condition but the security company also has a duty to its employees to provide adequate instruction and, where necessary, training so far as reasonably practicable to enable them to avoid danger.

This also should be removed from the 'as far as is reasonably practicable' rule. The employer is legally bound to provide a safe system of work - end of story, end of excuses.

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8 Training is also required to ensure that the staff are able to react appropriately in the event of any kind of incident.

As with any training, there should be refresher training and this should be documented.

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9 During routine inspection of premises which are protected by security staff, enforcement officers should inquire into the facilities available and the other aspects outlined above. Particular attention should be paid to the conditions which prevail after the normal process has ceased for the day.

So we are saying that, if the employer says the facilities are adequate, the enforcement officer just takes their word for it?
What about asking to see the risk assessment? Why are they not visitng a number of outlying sites selected randomly?

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10 At routine inspections of the head offices of security firms the conditions of staff employed at remote locations should be discussed. The safety policy should, of course, address all the activities of the company.

As above