Latest updates

20-Feb-23..An “in-convenience”
1-Oct-22…..PUWER (Provision & use of work equipment Regulations)
1-Sep-22…..Ladder Safety
1-Aug-22…..Professional membership of IOSH
1-June-22….HSE 10 Year Strategy – Protecting people and places
13-May-22…HSE’s RAPP tool – pushing and pulling loads
28-Apr-22….Dynamic Risk Assessment
22-Apr-22….World Day for Safety and Health at Work 28th April 2022
15-Apr-22….What do the warning symbols on my chemicals mean?
7-Apr-22……How many first aiders do I need?
4-Apr-22……How to select a generalist health and safety consultant
28-Mar-22…Managing home workers’ health and safety

20-February-23 An “in-convenience”

A construction company and its director have been fined by the Health and Safety Executive (HSE) after they failed to provide suitable toilet facilities on site. East Sussex firm ID8 Design and Build had been warned by the HSE in 2021 after an inspection found an unflushable toilet without door or window coverings. The facilities had no sink, no hot water, soap or towels, and workers had no rest area.

HSE issued an Improvement Notice, which was found to be ignored on a follow-up inspection. The company and its director Adeel Bhatti have now been ordered to pay fines and costs of more than £3,000 and £2,000 respectively.

HSE inspector Emma Bitz said that many smaller sites fail to even have basic facilities for their staff.

She said: “Providing suitable and sufficient toilets is an absolute duty and there is no exception to them being provided or made available.

“Inspectors will not hesitate to take appropriate enforcement action against employers who fail to comply with an Improvement Notice. Welfare is a fundamental and basic necessity for workers. It is also required by law.”

1-October-22 PUWER (Provision and Use of Work Equipment Regulations)

The Building Safety Group (BSG) reported a 40% increase in PUWER equipment breaches occurring on construction sites during the first half of 2021. The consequences of not adhering to PUWER regulations were made clear in 2017 when Warwickshire plant hire company AGD Equipment was fined £800,000 following the death of an employee.

PUWER applies to work equipment (as identified in regulation 2) whether it is new, existing or second-hand. The scope of ‘work equipment’ is extremely wide. It covers almost any equipment used at work, including:

(a) ‘toolbox tools’ such as hammers, knives, handsaws, meat cleavers etc;
(b) single machines such as drilling machines, circular saws, photocopiers,
combine harvesters, dumper trucks etc;
(c) apparatus such as laboratory apparatus (Bunsen burners etc);
(d) lifting equipment such as hoists, lift trucks, elevating work platforms, lifting
slings etc;
(e) other equipment such as ladders, pressure water cleaners etc;
(f) an installation such as a series of machines connected together, for example
a paper-making line or enclosure for providing sound insulation or scaffolding
or similar access equipment (except where CDM imposes more detailed

1-September-22 Ladder safety

Contrary to popular belief amongst some safety practitioners, ladders and stepladders are not banned under health and safety law.

The law calls for a sensible, proportionate approach to managing risk, and ladders can be a sensible and practical option for low-risk, short-duration tasks, although they should not automatically be your first choice. The Health and Safety Executive say that there are simple, sensible precautions you should take to stay safe when using portable leaning ladders and stepladders in the workplace. Make sure that you use the right type of ladder and that you know how to use it safely.

1-August-22 Professional membership of IOSH

IOSH membership is recognised worldwide as the benchmark for professional safety and health excellence, yet many people who are eligible for membership fail to apply. There are 7 membership categories to be aware of:

Prices valid until 31 March 2023

Student Member – one-time fee of £15 that covers the duration of your studies.

Affiliate Member – You’ll join IOSH as an Affiliate Member at £198 (£140 membership fees + £58 joining fee). IOSH will then support you in upgrading to another category, depending on your qualifications and experience.

Associate Member (AIOSH) – ​ You will join as an affiliate, as above. On renewal, if you have transferred, your membership fee will remain at £140. ​

Technical Member (TechIOSH) – Technical membership requires a Level 3 qualification. You will join as an affiliate, as above. On renewal, if you have transferred, your membership fee will remain at £140.

Graduate Member (GradIOSH) – Graduate Members have achieved a recognised and relevant degree-level qualification and are working towards the goal of Chartered status.  As above you join as an affiliate. On renewal, if you have transferred, you’ll pay a membership fee of £155 and a one-off charge of £160 to enrol onto IOSH’s IPD scheme.

Chartered Member (CMIOSH) – As a Chartered Member of IOSH, you’re entitled to use the designation Chartered Safety and Health Practitioner and the post-nominal letters CMIOSH.  You can only become a Chartered Member after gaining Graduate status so IOSH will support you to do this. On renewal, if you have transferred to a Chartered Member, you’ll pay a membership fee of £176.

Chartered Fellow (CFIOSH) – Chartered Fellowship is IOSH’s highest level of professional membership. Fellowship is only awarded to Chartered Members of at least five years’ standing who demonstrate an outstanding dedication to the profession by going ‘above and beyond’. They are role models for other members, their organisations and the occupational safety and health community. They’re committed to promoting and leading the highest standards in the OSH profession and to developing themselves and others.  You can only become a Chartered Fellow after gaining Chartered status.  Like everything else in this world, reaching these lofty heights means you have to pay more for the privilege.

1-June-22 HSE 10 Year Strategy – Protecting people and places

The Health and Safety Executive’s (HSE) new strategy for managing OSH risks over the next 10 years has been published, reflecting the changing nature of the world of work.

Protecting People and Places outlines five strategic objectives for HSE, which includes expanding its focus beyond worker protection to support the UK’s move towards net zero and taking on additional responsibilities – the provision of a Building Safety Regulator (BSR) and an expanded remit on chemical regulation. 

Strategic objectives 2022-2032

  • Reduce work-related ill health, with a specific focus on mental health and stress;
  • Increase and maintain trust to ensure people feel safe where they live, where they work and, in their environment;
  • Enable industry to innovate safely to prevent major incidents, supporting the move towards net zero;
  • Maintain Great Britain’s record as one of the safest countries to work in;
  • Ensure HSE is a great place to work, and we attract and retain exceptional people

Sitting under these strategic objectives are six strategic themes which will guide HSE’s regulatory activities from 2022-2032.

A relevant HSE
A fair and just HSE
A people-focused HSE
A collaborative HSE
A financially viable HSE
An accessible HSE

13-May-22 HSE’s RAPP tool – pushing and pulling loads

Pushing and pulling of loads is a way to reduce or avoid manual lifting and carrying. Putting the load on a trolley and pushing it is one way of avoiding carrying. So, when people push and pull instead of lifting and carrying, less effort is required, but there may still be a risk of musculoskeletal disorders (MSDs), which you need to assess and eliminate or reduce.

The Health & Safety Executive says that although we may think that the Manual Handling Operations Regulations only apply to the lifting, lowering and carrying of loads, they also apply to pushing and pulling. This ‘pushing and pulling’ guide should help you comply with the regulations and control the risks to your workers.

risk assessment tool for pushing and pulling operations (the RAPP tool) is available from HSE:

  • It is a simple tool designed to help assess the key risks in manual pushing and pulling operations involving whole body effort.
  • It will help identify high-risk pushing and pulling activities and help evaluate the effectiveness of any risk-reduction measures.
  • You can assess two types of pulling and pushing operations using the RAPP:
    • moving loads using wheeled equipment, such as hand trolleys, pump trucks, carts or wheelbarrows;
    • moving items without wheels, involving dragging/sliding, churning (pivoting and rolling) and rolling.
  • For each type of assessment there is a flow chart, an assessment guide and a score sheet.

Note: the tool is not sensitive to the level of risk in some tasks (or parts of tasks) involving moving loads with hand pallet trucks or similar, with small wheels. In these tasks, small irregularities (including debris) and small gradients in the floor surfaces, which would otherwise be assessed as low risk (Good G/0) under the A-7 Floor surface and A-8 Obstacles along the route factors, can have a very significant effect on the manual forces required. In these situations, the RAPP will tend to underestimate the level of risk, although the need for high force should be identified from looking at worker posture in factor A-2 Posture.

28-Apr-22 Dynamic Risk Assessment

Dynamic risk assessments do not replace a risk assessment, but can complement one when there is a need to assess any unknowns that cannot be predicted, or that change during the task. They allow for flexibility, continual assessment and changing environments.

A dynamic risk assessment requires some quick decisions about safety. Therefore they are most likely undertaken by the worker carrying out a job or their manager. The manager responsible for completing the dynamic risk assessment should undertake to provide the reasoning for using this process (rather than completing a general risk assessment) on the dynamic risk assessment form. In doing so they will:

  • Provide a brief description of the activity and people at risk:  
  • Identify the risk. The risk assessor should first be able to spot and acknowledge a source of risk. Identifying risk dynamically is extremely important – workers should be attuned to the situation and be able to identify risk as it occurs.
  • Assess the risk. The risk assessor should then measure the risk of the developing situation. Is the risk large enough to merit further consideration or immediate action?
  • Consider the tools they have to mitigate the risk. Can a worker safely continue with a task, and do they have the controls or tools they need to prevent or minimise risk? Do they have the proper safety equipment and support to work safely?
  • Consider whether it is safe to proceed and either take the necessary steps to make a task safe or delay the task until it can be made safe, liaising with colleagues if necessary.

If the dynamic risk assessment has found risk, and there are the means necessary to reduce that risk to safe levels, the risk assessor should do so. This might mean phoning in an additional member of staff to provide support or requesting additional equipment.

If the situation is too dangerous to proceed this might mean walking away from a potential situation or delaying work until safe equipment is sourced.

Even if working conditions have been assessed for risk prior to the work being carried out, this might not be enough to protect staff in dynamic, changing conditions. A dynamic risk assessment allows staff to react to developing situations and work safely at all times.

Validity of Dynamic Risk Assessment – A dynamic risk assessment is normally only valid for a maximum of one work shift (unless your procedure says otherwise, for good reason.

22-Apr-22 World Day for Safety and Health at Work 2022

28th April 2022 – The annual World Day for Safety and Health at Work on 28 April promotes the prevention of occupational accidents and diseases across the world. it focuses on enhancing social dialogue towards a culture of safety and health.

According to the International Labour Organization (ILO) almost 3 million workers die each year from occupational accidents and work related diseases. This annual awareness-raising campaign is intended to focus international attention on emerging trends in the field of occupational safety and health and on the magnitude of work-related injuries, diseases and fatalities worldwide.

This link will take you to the ILO’s website where you can learn more

15-Apr-22 What do the warning symbols on my chemicals mean?

Hazard symbols are designed to provide a warning, even if a person cannot understand the writing that goes with them. The symbols (also called pictograms) you see on the sides of chemicals are there for two main purposes.

(1) The first type indicate the dangers associated with the substance inside and give information about how to work safely with the substance. They are shown below and were introduced by the European Regulation on the classification, labelling and packaging of substances and mixtures (known as the CLP Regulations).  They are also known as GHS labels.

(2) The second type are there to for transportation purposes, for example to help the emergency services tackle any event involving a load of hazardous materials. For example, for carriage by road in the UK “the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009” (CDG Regs) and the European agreement (“Accord européen relatif au transport international des marchandises dangereuses par route”, known as ADR) together regulate the carriage of dangerous goods by road. Materials that need to go by air need to conform to the labelling rules established under IATA.

A selection of ADR hazard symbols

7-Apr-22 How many first aiders do I need?

There are no hard and fast rules on exact numbers of first aiders required – it depends on the circumstances of your workplace.  The following indicative guidance can be found in INDG214 “First aid at work – Your questions answered”

Remember to ensure you have sufficient numbers to cover holidays, shift patterns, sickness absence etc.

  • The role of the Appointed Person includes looking after first-aid equipment and facilities and calling the emergency services when required. They can also provide emergency cover where a first-aider is absent due to unforeseen circumstances (annual leave does not count). An appointed person does not need first-aid training.
  • EMERGENCY FIRST AIDER – EFAW training enables a first-aider to give emergency first aid to someone who is injured or becomes ill while at work.
  • FIRST AIDER – FAW training includes EFAW and also equips the first-aider to apply first aid to a range of specific injuries and illnesses.

There are many first aid training companies out there, the most notable being the St John Ambulance (which I can vouch for) however be ready to shop around for others.

4-Apr-22 How to select a generalist health and safety consultant

Not everyone needs a Health and safety consultant. Often the advice they need is available online or someone within the business already has the knowledge required to complete the required task. However there may be a need for you to employ a consultant for either a short term project, or to provide you with longer term competent advice.

Therefore, it is important that you spend time selecting the right health and safety consultant for your business. Employing the wrong one can have a bad impact on you and your business through gaining poor/wrong advice, failure to solve the original problem, under or over-engineering the solutions you need and so on.

Note there are also specialist safety consultants who can help you with subjects such as ergonomics, noise, occupational hygiene etc. These are not covered in my advice below. For a full list of these specialities refer to the HSE website.

Here are some tips for how to choose a generalist health and safety consultant.

Would you employ a financial consultant simply because they have a maths GCSE? Wouldn’t you prefer someone with experience in a financial discipline and have an appropriate professional qualification?

(a) Check the qualifications of the health and safety consultant and if possible make sure they are a member of OSHCR. There are a variety of ways to do this. You can visit to see their membership, or you can check the consultant’s website or ask for their CV.

(b) If the consultant is not a member of OSHCR find out what makes them competent enough to act as a consultant for your business, particularly if they do not have the following safety qualifications: CMIOSH, CFIOSH, MIIRSM, FIIRSM.

(c) Beware of consultants that only say they have ‘NEBOSH’. That typically means that they only have a NEBOSH National General Certificate. It only takes a fortnight or more to get this qualification, and whilst it is perfect for an entry-level safety advisor or a production manager, do you really want to trust your company’s reputation to an under-qualified consultant? That takes me back to point (b) above – some consultants more than compensate for this in terms of other relevant professional qualifications and years of experience. Don’t take anything at face value. If in doubt seek out references, or ask to see examples of previous work.

How much does a health and safety consultant cost?

It is important you know exactly what you are paying for, so you should ask for a detailed quote that explains exactly what the health and safety consultant will deliver.

You need to know the scope of services being offered as well as the deliverables. Once you have this, you can ask questions to make sure everything is clear so there is no misunderstanding between what you believe you are getting and what the consultant believes they are delivering.

Typical costs for recruiting a consultant are:

  • Paying a day/hourly rate. A good health and safety consultant is likely to charge in the region of £600-1,000 per day, plus travel expenses, however there are regional variances, and sometimes larger or specialist firms charge higher prices. Don’t be afraid to shop around, and remember that if it seems too good to be true (i.e. cheap) then it is.
  • Paying a fixed amount for the project. Often the consultant works out a day-rate equivalent and then if the project goes over-budget that is at the consultant’s own risk.
  • Paying a retainer for services to be rendered over a period of time – the cost for this service is often tailored to your needs so varies on a case-by-case basis.

1-Apr-22 DSEAR

The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) apply to most workplaces where a potentially explosive atmosphere may occur.  At minimum, DSEAR covers the following activities:

  • storage and use of flammable liquid-based paints and inks;
  • handling and storage of flammable waste solvents and LPG;
  • use of flammable gases for welding;
  • use of flammable solvents;
  • transport of flammable substances in containers around a workplace;

Some industry sectors and work activities are exempted because there is other legislation that fulfils the requirements (such as shipping, mines and hospitals).

  • What is an explosive atmosphere?

An explosive atmosphere is a mixture of a dangerous substance or substances (gas, mist, dust or vapour) with the air, which has the potential to catch fire or explode. An explosive atmosphere does not always result in an explosion but, if it does catch fire, the flames travel quickly.

  • What are dangerous substances?

Dangerous substances are any substances used or present at work that could, if not properly controlled, cause harm to people as a result of a fire or explosion or corrosion of metal. They can be found in nearly all workplaces and include such things as solvents, paints, varnishes, aerosols, flammable gases such as liquid petroleum gas (LPG), dusts from machining and sanding operations, pressurised gases and substances corrosive to metal.

  • What does DSEAR require?

DSEAR requires employers to eliminate or control the risks from dangerous substances. In addition to the general requirements, the Regulations place the following specific duties on employers with workplaces where explosive atmospheres may occur.

  • Classification of areas where explosive atmospheres may occur

Employers must classify into zones those areas where flammable/explosive atmospheres may occur. The classification given to a particular zone, and its size and location, depends on the likelihood of an explosive atmosphere occurring and its persistence if it does.

30-Mar-22 COSHH – What is it?

There is a lot of material online about COSHH, and Cusack-EHS are specialists in helping you complete or update yours. One reason we are good at it is that Sean studied Chemistry at University, the second is that Sean was involved with HSE in piloting COSHH assessment in the 1980s before COSHH was even published and his deep understanding of the context helps our clients comply as cost effectively as possible.

So what is COSHH (Control of Substances Hazardous to Health Regulations)?

Most businesses use substances, or products that are mixtures of substances. Some processes create substances. These could cause harm to employees, contractors and other people. COSHH is the law that requires employers to control substances that are hazardous to health. You can prevent or reduce workers exposure to hazardous substances by:

  • finding out what the health hazards are;
  • deciding how to prevent harm to health (risk assessment);
  • providing control measures to reduce harm to health using the hierarchy of controls (Eliminate, Substitute, Reduce, Isolate, Control, PPE, Discipline/Training);
  • making sure the controls are used ;
  • keeping all control measures in good working order;
  • providing information, instruction and training for employees and others;
  • providing monitoring and health surveillance in appropriate cases;
  • planning for emergencies.

28-Mar-22 Managing home workers’ health and safety

As an employer, you have the same health and safety responsibilities for people working at home as for any other worker.  The Health & Safety Executive has published guidance, which applies to those who:

  • work at home long term
  • routinely split their time between their workplace and home (sometimes called hybrid working)

Most of the time, risks to home workers will be low and the actions you should take to protect them will be straightforward.

Things you should consider as part of your risk assessment for home workers include:

  • stress and poor mental health
  • using equipment like computers and laptops safely
  • their working environment

You should talk to your workers about their arrangements, as working from home may not be suitable for everyone. For example, some people may not have an appropriate place to work or may prefer to come into the workplace for wellbeing, mental health or other reasons. For more information see the HSE’s website

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