HSE/05/05 Health and Safety Executive Board Paper HEALTH AND SAFETY EXECUTIVE

Health and Safety Executive Board Paper
Meeting Date:
Type of Paper:
Exemptions:
5 January 2005
Open Gov. Status:
Paper File Ref:
HSE/05/05
Fully open
SASD/226/1026/03
No
HEALTH AND SAFETY EXECUTIVE
The HSE Board
The way forward in Europe and plans for the UK Presidency
A Paper by Malcolm Darvill
Advisor(s): Peter Brown and Jonathan Rees
Cleared by Jonathan Rees on 22 December 2004
Issue
1. To allow the Board to review HSE’s current and international efforts in light of the
opportunity for influencing the content of the successor European OSH strategy that
will run from 2007-2011.
Timing
2. Immediate. The main opportunity for significantly influencing the shape of the new
European OSH strategy will come during the UK Presidency of the EU in the second
half of 2005.
A Presidency health and safety event, targeted at key EU OSH
stakeholders could form part, or be the main element of the influencing campaign.
Recommendation
3. That the Board note and comment
i. on the current level of effort HSE devotes to European and international
business. Are we doing the right things in the right places with the right
resources; and
ii. on the holding of a Presidency event to seek to influence the shape and
direction of the new EU OSH strategy.
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Background
4. HSE’s European and wider International work is diverse. HSE’s EU objectives and
negotiating strategy were set out in HSC/03/107. In general it is our aim to actively
support measures: (i) that will achieve real improvements in health and safety
standards across Europe, as long as consequences for the UK are not unacceptable;
and (ii) where standards in the UK are already acceptable, that will raise standards
elsewhere in Europe, thus to achieve a level playing field for UK business.
5. The annexes to HSC/03/107 gave full details of HSE’s EU and International activities
and those planned up until 2006, but in general, HSE’s other International work is
either based around international standards work, particularly those relating to the
nuclear, offshore and major hazard sectors, or is centred on passing on HSE expertise
and systems to developing poorer/counties, for example newer EU member states or
countries in the Far East. Some of this work is done in tandem with DTI who are keen
to promote UK plc abroad and drum up new markets for British equipment suppliers.
Further influencing work and the sharing of expertise is undertaken by membership of
wider international fora, again particularly in the nuclear and offshore sectors. With this
wider international work, a balance needs to be struck in terms of exercising influence
in international fora and the need to achieve domestic PSA targets. But what resources
we do devote to this work might need to be better focussed on achieving our strategic
aims.
6. In recent years our key role in Europe has essentially been to influence on a defensive
basis. That is to either head off unwelcome legislative proposals or where legislation is
unavoidable to seek to ensure that it is compatible with the UK system and does not
impose excessive burdens on business for little to no safety gain. But it may be time to
reflect on this approach, particularly given the changing face of the EU, with, for
example, enlargement, the adoption of the Lisbon agenda, migration and shifting
employment patterns – fewer “jobs for life”, market and labour flexibility, part-time and
extended working, etc. We should therefore ask ourselves whether the traditional OHS
approaches still work. Do we need to adopt new policies in order to ensure current or
improved levels of protection? And does the UK need to be out there playing its
traditional leading role, and by doing so ensuring that we both retain a fair labour
market and ensure that our own OSH system is protected.
7. The current EU OSH strategy ‘Adapting to change in work and society: a new
Community strategy on health and safety at work 2002–2006’, (see Annex 1) appeared
in March 2002. HSE sought to influence the content of the strategy (see HSC/02/21)
but its efforts were probably directed too late to achieve as big an impact as we would
have wished. Its development by the EC was marked by a general lack of real and
timely consultation and transparency. As a result it is far from strategic, has neither
clear priorities nor any action programme, and has no follow-up mechanisms. So
although it appears to be comprehensive and far reaching, apart from modernising and
tidying some of its consultation arrangements (mainly to reflect enlargement), it has
allowed the EC to carry on doing, or not doing, more or less what it wants.
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8. A unnumbered paper from Sandra Caldwell, then PG Co-Director, was sent to Board
members on 26 August 2003, flagging up the forthcoming UK Presidency, and asking
for views on what if any Presidency events HSE should host. Little or no response
resulted which was not surprising given that Board members were then fully engaged
in the development of the new HSC/E strategy and the necessary re-engineering of
HSE in order to deliver it.
9. The EC’s DG Employment is keen for the UK to mount a major health and safety event
as part of its Presidency during the second half of 2005 both in terms of evaluating the
current strategy and more importantly developing the content of the next strategy to run
from 2007-2011.
Argument
10. D/Ds have recently completed their plans for the next 3 years. T
o inform this paper
they have been asked to give some indication of their current and proposed
International activity, with reference to that set out in 2003. The response is reflected
in Annex 4. Although HSE/C’s strategy is quiet on EU and International work, if we
withdraw too much, we run the risk e.g. of the next EU strategy reverting to a "more
directives/hard regulation" approach that could divert HSE resources from delivering its
strategy. Equally we need to ensure that the resources we do apply to EU/International
work are directed where they can achieve the sort of outcomes we want, rather than
being "lost" in relatively low level activity. A balanced approach would appear to be
best described as ‘high-level targeted influencing with limited resources’.
11. We are now well past the mid-point of the EU strategy; and there are currently moves
to review its progress and evaluate its effects. If HSE, with the help of other member
states who share our general aims, wish to influence the next 5 year strategy, then the
UK Presidency, in the second half of 2005, offers an ideal opportunity to do so. Further
comments on the current EC OSH strategy and early thoughts about the next one are
given in Annex 2. Essentially we consider that our broad approach should be:
To argue against the need for any new regulation, with the thrust rather on better
evaluation of existing law, and more "soft law" approaches (e.g. as on stress).
To encourage continued efforts to improve the EC evidence base, working with the
relevant DGs and the Agency.
To encourage continued sharing of best practice on enforcement and peer review,
using SLIC and other fora.
To improve our links with key partners, at EU level, especially the TUC and CBI
given the likely renewed emphasis on social partners.
12. In considering our dealings with Europe and the EC, we should not lose sight of the
impending SFAIRP infraction case. We will need to handle this whilst still looking
carefully for an opportunity that may settle it without undermining existing UK practice.
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13. In considering mechanisms for the UK to influence the shaping of the successor EU
OSH strategy, advantage was seen in HSE’s taking the opportunity of the UK
Presidency in the second half of 2005 to mount a health and safety event directed at
seeking support for components of the next strategy that the UK sees as priorities.
Apart from seeking to continue to head off major new legislation, we are in a position to
promote the welcome trends developing within the EC, e.g. concepts of mainstreaming
health and safety into the broad range of Commission policies, the simplification of
legislation and the adoption of Social Partner agreements as alternatives to legislation.
Alternatively we could let developments take their course or trust to others to take the
lead, hoping that the wind for better regulation in Europe is now well set. However by
doing so we run the risk that the course set will not be in the UK’s interest – there could
either be a reversion to hard law or unnecessary simplification, which could lead to re­
opening and renegotiating existing directives without producing either OSH gains or
reduced business costs. Such moves would have resource implications for HSE
whereas a little more resource now could help to keep things moving in the right
direction.
14. Additionally, indications have been received from DG Employment that it is
disappointed that there was to be no OHS event during the UK Presidency, and that
should this be reversed, EC funding might be available to support it. We are therefore
now proposing to hold such an event in the middle part of the Presidency. Annex 3
gives further details.
15. Following the Board’s discussion of this paper, it is proposed to seek HSC’s views of
these proposals and the way in which we consider the EU OHS strategy should be
moving. When we do so, we would also like to produce an update on the annexes of
the last HSC paper and invite a general discussion of the appropriate level of
engagement in Europe and internationally against a background of domestic delivery of
PSA targets and more general expectations of HSE’s contribution to the broader UK
plc overseas interests.
16. With the reduced number of hard EU OSH proposals, HSE’s expertise in dealing with
Europe is diminishing. As well as the need to know e.g. how EU directives are
negotiated and implemented, it is important that HSE staff, particularly those dealing
with policy and similar work, have a general appreciation of European and International
matters. This aspect of HSE’s policy development course is minimal. This need could
be addressed by formal training courses, such as those provided by the CSC but this
may not be cost effective. IB therefore proposes to investigate whether there is merit in
providing more in-house targeted training, seminars, etc., building on the start of
presidency events we already hold.
Consultation
17. All D/D’s were asked, by email for an indication of their current EU and International
work, and to comment on the general proposal for the Presidency event. RPD has
been separately consulted on costs, benefits and financial/resource implications, and
Communications Directorate on presentational aspects.
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Presentation
18. Stakeholder analysis work by Communications Directorate has not identified the
EU/EC as a key corporate stakeholder. Overall our approach to Europe and
internationally must demonstrate we are prepared to play our part and contribute
actively subject to it being clearly understood we are working within restricted
resources.
Costs and Benefits
19. It is difficult to measure the benefits of HSE’s European and international involvement.
At the European level key effort is focused on ensuring legislative proposals are
workable within the UK system and do not impose unnecessary burdens on business
for little to no safety gain. Linked to this we seek to build influencing alliances in order
to shape policy more broadly. More widely on the international front, some of OSD’s
international effort supports the efforts of DTI in securing new markets abroad for
equipment suppliers.
Financial/Resource Implications for HSE
20. The arguments for European and wider international involvement need to be balanced
against PSA priorities and our longer term strategy. By far the biggest cost is the often
invisible opportunity cost of staff time. The most visible and quantifiable cost is for
travel and subsistence for this work. For 2003-04 this amounted to £828.5K. This was
significantly (about 20%) down from the sum for 2000 – 01, probably as a result of
more economical air fares and a reduction in activity. As regards the funding of the
various Presidency events and activities, despite early indications that additional
funding would not be available, £62K has been secured from DWP to help fund the
SLIC Meeting and up to € 200K has been promised by the EC to fund an additional
Presidency event, provided that the sum only presents 80% of the total spend (see
page 31). But if it is in our interest to set up such an event there is flexibility in the
Communications Directorate budget to contribute at a level commensurate with the
importance of the event.
Environmental Implications
21. None.
Other Implications
22. HSE’s European and international work covers the range of health and safety issues
and the successor European OSH Strategy needs to aligned as far as possible with our
domestic priorities.
Action
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23. Following this discussion a firm proposal for the EU event will be worked up in order to
secure the contract for the EU funding. A suitable opportunity will be identified for
announcing the event.
I:\Central Expertise Policy and Support\Better Regulation and International Branch\International\UK Presidency 2005\Board Paper
B0505 Rev 3.doc
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Annex 1: The EU’s current OSH strategy
Brussels, 11.03.2002 COM(2002) 118 final
Adapting to change in work and society: a new Community strategy on health
and safety at work 2002–2006
SUMMARY
Safety and health at work now constitutes one of the European Union’s most
concentrated and most important social policy sectors. As early as 1951, the
European Coal and Steel Community set about improving the safety of workers, a concern
which the Treaty of Rome extended to all employed people. As a result, a substantial
corpus of legislation aimed at raising standards of safety and health has developed since
the late 1970s, and especially since the Single European Act was adopted in 1987. It is
because the EU can call on such an abundant source of material that it is crucial for the
social policy agenda to set out a Community strategy. This strategy, which covers the
period 2002-2006, has three novel features:
It adopts a global approach to well-being at work, taking account of changes in
the world of work and the emergence of new risks, especially of a psycho-social
nature. As such, it is geared to enhancing the quality of work, and regards a
safety and healthy working environment as one of the essential components.
It is based on consolidating a culture of risk prevention, on combining a
variety of political instruments — legislation, the social dialogue, progressive
measures and best practices, corporate social responsibility and economic
incentives — and on building partnerships between all the players on the safety
and health scene.
It points up the fact that an ambitious social policy is a factor in the competitiveness
equation and that, on the other side of the coin, having a “non-policy” engenders
costs which weigh heavily on economies and societies.
1.
INTRODUCTION
Creating more and better jobs: that was the objective the European Union set itself at the
Lisbon European Council in March 2000. Clearly, health and safety are essential elements
in terms of the quality of work, and feature among the indicators recently adopted in the
wake of the Commission’s communication “Investing in quality” 1. The European Union has
a positive record here, as the number of occupational accidents fell by just short of 10%
between 1994 and 1998 2. Nonetheless, the absolute figures remain high, with not far
1
COM (2001) 313 final, 20 June 2001
This is the number of occupational accidents per 100 000 persons in employment. Source: Eurostat –
“Statistics in focus”, Population and social conditions: No 16/2001 “Accidents at work in the EU 1998–99”
and No 17/2001 “Work-related health problems in the EU 1998–99”.
2
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short of 5 500 deaths and 4.8 million accidents resulting in three days or more off work 3.
More importantly, a worrying return to a rising scale of accidents, in certain Member States
and in certain sectors, has been evident since 1999. What is more, the candidate countries
have an average frequency of occupational accidents which is well above the average for
the EU, mainly because of their higher degree of specialisation in sectors which are
traditionally regarded as high-risk.
These figures are still somewhat patchy, but they do call for heightened vigilance, since
what they indicate is that the preventive approach set out in Community directives has not
yet been fully understood and taken on board by the various players, nor applied
effectively on the ground. This is particularly true of the candidate countries. In other
words, the figures are prompting us to develop a more global approach to health and
safety at work, given that the quality of employment is based on a number of commonly
perceived constituent elements: the type of skills required, the level of employee training,
the nature of the employment relationship, the way work is organised and the working time
element. It follows that working towards a healthier occupational environment has to be
addressed as part of the general trend in economic activities (more service-oriented),
forms of employment (more diversified), the active population (more women, and an older
working population) and society in general (more diverse, but more marked by social
exclusion).
In addition, a safe and healthy working environment and working organisation are
performance factors for the economy and for companies. The exact relations between
health at work and competitiveness are more complex than just a matter of compliance
costs. As far as the economy is concerned, “non-quality” of work is expressed in a loss of
productive capacity — 500 million working days lost in 1999 as a result of accidents or
health problems — and compensatory payments and benefits 4, and a lot of this weighs
financially on companies. Almost 350 000 people have been forced to change jobs or their
place of work or to reduce their working time, and nearly 300 000 have varying degrees of
permanent disability, of whom 15 000 are entirely excluded from the world of work. Over
and above these human tragedies, this is a waste of resources against a background of
structural ageing of the working population.
At company level, “non-quality” gives the firm a poor public image, vis-à-vis its workforce,
clients, consumers and the public at large, which is becoming more and more sensitive to
safety issues. In other words, having a healthy working environment adds to a firm’s
quality image, and steps taken to improve that environment form part of a general
approach to “quality management” and social responsibility, both of which have a
beneficial effect on performance and competitiveness.
Community policy on health and safety at work must keep pace with these changes and
these new needs, with a view to promoting “well-being at work” 5, this being taken to
mean physical, moral and social well-being, and not just something that can be measured
by an absence of accidents or occupational illnesses. This means that Community policy
must itself strive for improved quality, and this will have two fundamental implications:
3
In 1998. Source: idem.
4
In 1997, this expenditure was estimated at $122 billion for the OECD (in Health data 2001). This figure
excludes Italy, the Netherlands, Portugal and Spain. France and Germany alone accounted for $92 billion
worth of expenditure (expressed in purchasing power parities).
5
The concept of “well-being at work” was developed by the ILO.
Page 8
It must combine the various instruments and find a basis in the substantial
acquis of many decades of Community policies, with the Framework Directive
89/391 6 being the keystone in that it gives priority to prevention. It must also be
founded on the experience vested in the various Community programmes in this
area 7. The normative approach, whether it be a matter of the ongoing adaptation of
existing standards or the formulation of new standards, remains essential: Article 31
of the Charter of Fundamental Rights states that “every worker has the right to
working conditions which respect his or her health, safety and dignity”. However, in
a constantly changing world of work, it is just as important to promote progressive
approaches, whether they be performance rating, based on transparent and reliable
data and indicators, action on the part of the social partners (at sectoral or
multisectoral level), or voluntary company schemes. It is, furthermore, essential to
improve the knowledge and awareness of all players, and to ensure that concerns
for health and safety at work are mainstreamed into all other relevant Community
policies.
To achieve this, it must involve all the players — for example, the public
authorities, the social partners, companies, public and private insurers — within a
framework of “good governance”, based on universal participation 8. The Social
Agenda, which was adopted at the Nice European Council, defined the essential
elements of a new Community strategy as helping to “anticipate and manage
change in the working environment”. The new strategy itself is based on broad
advance consultation, and takes account of the various views expressed. For
instance, the European Parliament called on the Commission, in its resolution on
the Social Agenda 9, to “put in place a real Community strategy on health and safety
at work which is based on the setting of common comparable objectives, contains
an action plan to reinforce the implementation, control and evaluation of the existing
directives and includes additional legislative initiatives on risks that are covered
inadequately or not at all, such as skin complaints caused by exposure to the sun’s
rays, newly emerging risks such as stress and musculo-skeletal disorders and the
new work situations, and encourage the use of risk analyses as part of a preventive
approach.” The Economic and Social Committee, for its part, adopted an
exploratory opinion 10 at the Commission’s request. The Advisory Committee on
Safety, Hygiene and Health Protection at Work (ACSHH), which includes the social
partners, adopted its opinion in December 2001. These advance consultations have
made paved the way for a new Community strategy, for the period 2002–2006,
which sets out a coherent policy framework and proposes concrete action, along
with a full implementation timetable.
2. KEEPING PACE WITH CHANGES IN THE WORLD OF WORK
The Lisbon European Council stressed that Europe was going through a transition to a
“knowledge-based economy”, marked by profound changes affecting society, employment
6
OJ L 183, 29 June 1989. More especially the latest programme (1996–2000), COM(95) 282, 7 October 1995. 8
European Governance — a White Paper; COM(2001) 428 final, 25 July 2001.
9
European Parliament resolution on the communication from the Commission to the Council, the European
Parliament, the Economic and Social Committee and the Committee of the Regions on the Social Policy
Agenda, A5-0291/2000.
10
SOC/065, 11 July 2001, following the opinion adopted on 9 December 1999.
7
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and health and safety at work. As a result, there is a need to take a fresh look at what
policy should be pursued in this strategic area and, at times, new priorities.
Nonetheless, these changes cannot mask the reality of the current situation: we still have
very high rates of occupational accidents in certain sectors, representing a large majority
of accidents recorded in the EU. Four sectors (fishing, agriculture, construction, and health
and social services) have an accident rate which is 30% above average. Four others (the
extractive industries, manufacturing industry, hotels and restaurants, and transport) have a
rate which is some 15% above the average. These figures are much higher still if we look
only at small and medium-sized enterprises (SMEs) and very small businesses: in the
construction industry, for example, the mean accident rate is 41% above the average,
jumping to 124% for firms with between one and nine employees, and 130% for firms with
between 10 and 49 workers 11. We need to be constantly vigilant, then, if we are to reduce
these “traditional” risks and develop a culture of prevention in SMEs.
2.1. Changes in society
2.1.1. An increasingly feminised society
The growing percentage of women in employment has been evident for decades. It was
one of the fundamental objectives laid down in Lisbon, against the background of an
ageing working population, and it introduces a new dimension into the subject of health
and safety at work. v83% of employed women work in services, which explains why they
suffer a much lower rate of accidents and occupational illnesses than men, and why they
stand much less risk of being involved in an accident. Nonetheless, the trend is not a good
one, since the kind of work in which women predominate is generating a growing accident
rate, including fatal accidents 12. Moreover, although women accounted (in 1995 13) for
only 17.8% of diagnosed occupational illnesses, the proportion was much higher in certain
groups: 45% of allergies, 61% of infectious illnesses, 55% of neurological complaints, 48%
of hepatitic and dermatological complaints. These figures underline the importance of
gender in terms of occupational illnesses 14. Preventive measures, and the assessment
arrangements and the rules for awarding compensation, must take specific account of the
growing proportion of women in the workforce, and of the risks to which women are
particularly liable15. These measures must be based on research covering the ergonomic
aspects, workplace design, and the effects of exposure to physical, chemical and
biological agents, and pay heed to the physiological and psychological differences in the
way work is organised.
2.1.2. An ageing active population
Europe’s active population will, over the coming decades, see an increase in the
proportion of workers aged 50 and above, with a corresponding reduction in the Age­
11
Source: Eurostat, Labour Force Survey 1999 (ad hoc module) and SEAT (European Occupational
Accident Statistics) data 1998.
12
Source: Eurostat, SEAT, op.cit.
13
Source: Eurostat
14
On the other hand, men accounted for 93% of musculo-skeletal problems and haematological illnesses,
97% of hearing complaints and 91% of pulmonary illnesses.
15
See more especially the report of proceedings of the seminar “Gender differences in working conditions”,
organised as part of the “Work Life 2000” project
(http://www.niwl.se/wl2000/workshops/workshop67/article_en.asp)
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related comparisons show, on the one hand, that young people tend to suffer more
accidents at work and, on the other, that workers aged 55 and above tend to suffer the
most serious accidents, with a fatality rate above the European average. The 55-plus age
group is also the one with the greatest incidence of long development- time occupational
illnesses, such as cancers (the majority of which are workers tend to develop more
allergies and infectious illnesses.
However, these figures depend very much on the nature of the jobs occupied nowadays
by the various generations: the older workers tend to be the less qualified, as well as being
over-represented in the manual industrial trades, while young people predominate in the
more precarious forms of employment. These differences mean the specific situation of
the generations and age groups in the world of work.
2.2. Changes in forms of employment
The labour market is seeing increasingly diversified forms of employment, with particularly
strong growth in temporary employment relationships. The type of contract and seniority in
the firm show a negative correlation with health at work. People who have been employed
for less than two yea s are more likely to suffer an accident at work than the average: for
temporary workers, this effect is particularly pronounced in the construction industry and in
health and social services.
Among these new forms of work, part-time work and non-standard working times (e.g. shift
work or night work) are likewise factors which add to the degree of risk. It can be explained
more specifically by the lack of proper training, psychosomatic problems caused by shift
work or night work, a lack of awareness on the part of company managers, or a lack of
motivation in the case of workers in an insecure working relationship.
However, the whole of the world of work is undergoing a shift towards more flexible forms
of organisation. The tangible link between the place of work (e.g. a mine, a factory or an
office) and the work to be done is weakening, with the rapid spread of information
technologies. These changes are not affecting employment relations as such, although
they may blur the distinction between employed and self-employed persons. The fact is,
though, that they raise specific problems, for example in relation to teleworkers: it is the
employer who is responsible for their health and safety, no matter where the work is being
done. This means that steps have to be taken to prevent risk and to carry out checks
where teleworkers work at different sites, or at home. Negotiations which began on 12
October 2001 between the social workers at Community multisectoral level are designed
to address these matters.
2.3. Changes in the nature of risk
The changing way in which work is organised, and especially more flexible ways of
organising working time and managing human resources on a more individual level, based
more on an obligation to achieve a fixed result, are having a profound effect on problems
associated with health at work or, more generally, on well-being at work. It is a known fact
today that “emerging” illnesses such as stress, depression, anxiety, violence at work,
harassment and intimidation are responsible for 18% of all problems associated with
health at work, with a quarter of them resulting in two weeks or more absence from work
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16
. These complaints are twice as frequent in education and in health and social services.
They are linked less to exposure to a specific risk than to a whole set of factors, such as
work organisation, working time arrangements, hierarchical relations, transport-related
fatigue, and the degree of acceptance of ethnic and cultural diversity within the firm. They
need to be addressed within a global context which the ILO defines as “well-being at
work”. These strategies for preventing new social risks should include the effect of
substance-dependence on accident rates, more especially problems associated with
alcohol and medicinal drugs.
3. TOWARDS A NEW COMMUNITY STRATEGY ON HEALTH AND SAFETY
3.1. For a global approach to well-being at work
The objective of the Community’s policy on health and safety at work must be to bring
about a continuing improvement in well-being at work, a concept which is taken to include
the physical, moral and social dimensions. In addition, a number of complementary
objectives must be targeted jointly by all the players.
1. A continuing reduction in occupational accidents and illnesses. Thought should be
given to setting quantified objectives, at both Community and Member State level,
particularly in sectors of activity with above-average incidence rates, and having
special regard to arrangements for implementing the European employment strategy.
2. Mainstreaming the gender dimension into risk evaluation, preventive measures and
compensation arrangements, so as to take account of the specific characteristics of
women in terms of health and safety at work.
3. Prevention of social risks. Stress, harassment at the workplace, depression and
anxiety, and risks related to dependence on alcohol, drugs and medicines, should all
be the subject of specific measures but should form part of a global approach in
association with health care systems.
4. Enhanced prevention of occupational illnesses. Priority should go to illnesses due to
asbestos, hearing loss and musculo-skeletal problems.
5. Taking account of demographic change in terms of risks, accidents and illnesses.
Preventive measures should take more account of the age factor, and should
specifically target young people and ageing workers.
6. Taking account of changes in forms of employment, work organisation arrangements
and working time. Workers in non-standard or precarious working relations constitute a
sensitive group.
16
Source: Labour Force Survey 1999
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7. Taking account of the size of firms. SMEs and very small businesses, as well as self­
employed workers and unpaid family helpers, should all be the subject of specific
measures in terms of information, awareness and risk prevention programmes.
8. Analysis of new or emerging risks, with special reference to risks associated with the
interaction between chemical, physical and biological agents, and those associated
with the general working environment (ergonomic, psychological and social risks).
3.2. Strengthening the prevention culture
The Community's policy on health and safety is based on preventive approaches bringing
in all the players, including the workers themselves, with a view to developing a genuine
culture of risk prevention, the aim being to anticipate risks and bring them under control.
3.2.1. Education, awareness, anticipation: improving people's knowledge of risks
Creating a controlled work environment means improving everyone's knowledge of the
risks. This means developing an approach which is both global and preventive, geared to
promoting well-being at work, and going beyond the mere prevention of specific risks.
There are three mutually supportive elements.
1.
Education does not start with entry into the world of work, as the Economic and
Social Committee has pointed out: it should be part and parcel of the school curriculum,
either with a view to making people more aware of the problem (much like road safety is
taught in some countries), or as a vocational subject in its own right. However, the most
important element here is continuing vocational training. This must be dispensed regularly
and be geared to the realities of day-to-day work, with a view to impacting directly on the
work environment. It means that the teaching has to be targeted to national, regional, local
and sectoral specificities and sensitivities.
2.
Awareness training must mobilise resources which are varied and geared to
specific situations, e.g. SMEs, very small firms and craft trade workers. These people and
organisations must be made aware of the need to reintegrate disabled people into
employment, with special reference to creating an adapted work environment 17
3.
Anticipating new and emerging risks, whether they be linked to technical
innovation or caused by social change, is vital if the risks are to be brought under control.
This requires, first and foremost, ongoing observation of the risks themselves, based on
the systematic collection of information and scientific opinions. The European Parliament
has stressed that this kind of analysis is an integral part of a preventive approach. It also
requires researchers to adopt a consistent approach: research organisations should
coordinate thei respective programmes, target them to address practical problems arising
at the workplace, and make preparations for the research findings to be transferred to
firms, and especially to SMEs.
17
The need to adapt the workplace to the needs of disabled people is covered by Directive 89/654, and the
concept of "reasonable adaptations" is defined in Directive 2000/78 (OJ L 303/16, 2 December 2000).
Page 13
The European Agency for Safety and Health at Work should act as a driving force in
matters concerning awareness-building and risk anticipation. In the second half of 2002,
the Commission will present a communication assessing the work of the Agency, and
spelling out the role the Agency should be playing in this field.
The European Agency for Health and Safety at Work:
will set up a "risk observatory", based on examples of good practice collected
from firms or specific branches of activity;
will organise exchanges of experience and information by way of the systematic
collection of data, with the support of Eurostat;
will integrate the candidate countries into these information networks, and devise
working tools which are geared to their specific situation;
will refocus the European week on health and safety on users and final
beneficiaries;
will establish, for the European Year of Disabled People (2003), a data base of
best practices and information concerning ways of integrating disabled people
and adapting equipment and the work environment to their needs.
3.2.2. Better application of existing law
Applying Community law effectively is essential if we are to improve the quality of the work
environment. This in turn requires an enhanced state of awareness on the part of all
concerned, and at all levels. The Commission will, in conjunction with the Advisory
Committee and the social partners, be producing guides on how to apply the directives,
taking account of the diverse nature of sectors of activity and companies, as suggested by
the Economic and Social Committee.
For its part, the Commission will, subject to the powers bestowed on it by the Treaty, adopt
a rigorous approach to ensuring that directives are properly transposed and the law is
properly applied. It will also be cooperating closely with the national authorities to find
ways of ensuring that Community directives are implemented correctly and equivalently. In
this respect, a fundamental role will fall to the Senior Labour Inspectors Committee (SLIC)
in terms of encouraging exchanges of information and experience and organising mutual
cooperation and assistance. There must be practical encouragement for common
inspection objectives as part of an annual action plan, the importance of which has been
underlined by the European Parliament, common principles for labour inspection in the
field of health and safety at work, and ways and means of evaluating national inspection
systems by reference to these principles. Integrating the candidate countries’
inspectorates in this committee is a matter of prime importance in terms of promoting the
effective implementation of Community law.
While it is important to pay heed to the diversity of the Member States’ institutional
structures and administrative traditions, it is also true that implementing the new strategy,
Page 14
geared to the quality of work and well-being at work, will require thought to be given to
which structures are best adapted to this global approach:
the prevention services should be genuinely multi-disciplinary, embracing social and
psychological risks, and the gender factor;
labour inspection activities must be capable of appraising all the risks,particularly in
those sectors where they tend to be complex and cumulative (e.g. in hospitals). The
inspectorate services must combine their inspection role with a prevention function
vis-à-vis firms and workers. They must in turn be open to audit, using result and
quality indicators to promote innovative approaches.
The checks carried out by the inspection services must give rise to uniform sanctions
which are dissuasive, proportionate and effectively applied. In this regard, two areas take
on a special significance:
Protection of young people, who tend to be more liable to the risk of accidents than
other population groups. This will involve, on the one hand, enforcement measures
to combat the illegal employment of young people who have not yet reached the
legal age 18 and, on the other, for those who are admitted to employment, the
rigorous application of the rules on health and safety.
Some companies operating within the European Union sometimes escape
administrative and criminal sanctions if the Member State in which they operate is
different from that in which they are established. This is the case where they
provide limited-duration services outside the country in which their headquarters are
based. Article 3 (1) (e) of Directive 96/71/EC of 16 December 1996 concerning the
posting of workers in the framework of the provision of services 19 says that firms
which send their employees to provide a service in a different EU Member State
must, during the period of secondment, apply the same standards of safety, health
and hygiene at work as apply in the host country. Cooperation in terms of the
mutual exchange of information between public authorities, as provided for in Article
4 of the Directive, is being gradually put into place, and should make it easier to
prosecute errant firms.
Nonetheless, it is worth looking into all possible ways and means of dealing with
infringements in transnational situations, and of strengthening ongoing work on the subject
within the SLIC.
3.3. Combining instruments and building partnerships
18
Article 32 of the Charter of Fundamental Rights states that “The employment of children is prohibited. The
minimum age of admission to employment may not be lower than the minimum school-leaving age, without
prejudice to such rules as may be more favourable to young people and except for limited derogations.
Young people admitted to work must have working conditions appropriate to their age and be protected
against economic exploitation and any work likely to harm their safety, health or physical, mental, moral or
social development or to interfere with their education.”
19
19 OJ L 18, 21/01/1997, p. 1 – 6.
Page 15
Promoting a quality working environment, taking account of all the aspects, requires a
global approach, utilising all the available instruments. It also requires all the actors
to assume full responsibility, and it means that each party’s efforts should be open to
assessment and appraisal.
3.3.1. Adapting the legal and institutional framework
The existence of a full, coherent and solid Community legislative framework is an essential
tool in terms of health and safety, where there is a need for standards and principles for
preventing risks and protecting workers. The Commission intends to pursue a balanced
approach in this field, based on experience gained in the implementation of legislative
texts, along a number of parallel routes:
1. Ongoing adaptation of existing directives to changes in scientific knowledge,
technical progress and the world of work. Work on analysing national reports on
how the directives have been put into practice, together with assessments done at
company level, will help to pinpoint any difficulties encountered by the various
players in terms of implementing the legislation, and should enable any deficiencies
to be corrected. The Commission, with the assistance of the Advisory Committee
(ACSHH), will produce reports on the practical application of the various “health and
safety” directives, with a view to identifying any practical problems and improving
certain of the provisions to make them more readily comprehensible, more
consistent, and to fill the gaps in the existing framework. It will also propose
extending the scope of the “carcinogenic agents” directive. In addition, it will submit
a communication on musculo-skeletal complaints, which will look into the causes of
these problems in the light of preventive measures provided for in existing
Community legislation (i.e. the directives dealing with heavy loads, computer screen
work and vibration), and will propose amendments or new legal provisions in fields
in which coverage is still incomplete (e.g. workplace ergonomics).
2. Taking account of new risks. The increase in psycho-social problems and illnesses
is posing a new challenge to health and safety at work and is compromising moves
to improve well-being at work. The various forms of psychological harassment and
violence at work likewise pose a special problem nowadays, requiring legislative
action. Any such action will be able to build on the acquis of recently adopted
directives rooted in Article 13 of the EC Treaty, which define what is meant by
harassment and make provision for redress.
3. Rationalisation of the legal framework. People tend to see the Community legal
framework as being excessively complex and not very clear. It has to be simplified
and rationalised, on the one hand, by consolidating existing directives to make them
more comprehensible and, on the other, by producing a single report on their
implementation, rather than the specific reports required under the various
directives. The Commission will be making the necessary legislative proposals for
consolidating and rationalising these reports.
4. Rationalisation of the Community instances. The effective implementation of
Community law requires close cooperation between the Commission and the
Member States’ administrations. This cooperation would be better and simpler if the
Page 16
two advisory committees ACSHH and SHCMOEI (the Safety and Health
Commission for the Mining and Other Extractive Industries) were to be merged into
a single Advisory Committee on Safety, Hygiene and Health Protection at Work.
The Commission will:
draw up, in conjunction with the Advisory Committee and the social partners,
guides on how to apply the directives, bearing in mind the diverse nature of
sectors of activity and undertakings;
propose extending the scope of the directive on “carcinogenic agents”;
adapt existing legislation to the emerging problem of musculo-skeletal complaints,
proposing an amendment to the directive on visual display screens, and
supplementing wherever necessary the existing provisions so as to take better
account of ergonomics at the workplace;
examine the appropriateness and the scope of a Community instrument on
psychological harassment and violence at work;
make the necessary legislative proposals for consolidating the Community
directives and for rationalising the implementation reports;
propose that the two existing advisory committees ACSHH and SHCMOEI (the
Advisory Committee on Safety, Hygiene and Health Protection at Work and the
Safety and Health Commission for the Mining and Other Extractive Industries) be
merged into a single Advisory Committee on health and safety at work;
propose that the representatives of the candidate countries’ inspectorates in the
Senior Labour Inspectors Committee (SLIC) be admitted to the Advisory
Committee ACSHH and to the various bodies run by the Bilbao Agency and the
Dublin Foundation.
3.3.2. Encouraging innovative approaches
Just as legislative action is necessary to lay down standards, other instruments are
needed to promote innovative approaches, to encourage the various parties to “go a step
further” and to associate all the interested parties in achieving the overall objectives of the
strategy, more especially in new fields which do not lend themselves easily to a normative
approach. The Commission intends to encourage such innovative moves.
1. Benchmarking and the identification of best practices: these should be used at three
different levels under the new strategy:
Page 17
Work towards “converging progress” in terms of the Member States’ policies.
The European employment strategy provides an effective framework for this
kind of approach 20, with input from the European Social Fund.
Quantified national objectives should be adopted so as to achieve:
a reduction in the rate of fatal and non-fatal accidents;
a reduction in the rate of recognised occupational illnesses;
a reduction in the number of days lost due to such accidents and illnesses.
Success in achieving these objectives can be measured by reference to indicators
using existing methods 21. These quantified objectives should take account of the
size of firms and the sector of activity, laying down the objectives to be achieved in
sectors where the incidence of accidents and illnesses is above average.
If these indicators are to be genuinely operational, the collected data must be more
precise, more comparable, have fuller coverage and be available earlier. To achieve
this, and to eliminate the problem of under-declaration in certain Member States,
the Commission and the Member States will have to step up ongoing work on the
harmonisation of occupational accident and illness statistics. These should cover
not just recognised occupational accidents and illnesses, their causes and
consequences, but also introduce some quantifiable elements relating to working
environment factors which are likely to cause the problems.
Make it easier to identify emerging phenomena. Stress-related complaints and
illnesses are one example of this, as are musculo-skeletal problems, and
dependence on alcohol, medicines and drugs. The Commission will be proposing
that this problem be integrated into the employment guidelines for 2003 and will, in
conjunction with the Dublin Foundation, instigate work on collecting data and other
information for measuring the phenomena and for creating monitoring indicators.
Develop knowledge of, and follow-up to, the “cost of non-quality”, i.e. the economic
and social costs arising from occupational accidents and illnesses. The Commission
will, in conjunction with the Bilbao Agency, instigate work on collecting data and
other information with a view to improving the fund of knowledge on this subject.
20
Guideline 14 (c): “(Member States will) endeavour to ensure a better application at workplace level of
existing health and safety legislation by stepping up and strengthening enforcement, by providing guidance
to help enterprises, especially SMEs, to comply with existing legislation, by improving training on
occupational health and safety, and by promoting measures for the reduction of occupational accidents and
diseases in traditional high risk sectors.”
21
SEAT for accidents at work, and EODS for occupational illnesses
Page 18
The Commission will:
considere to propose, in 2002, an amendment to the employment guidelines,
calling on the Member States to adopt national quantified objectives for
reducing accidents at work and occupational illnesses, giving specific attention
to sectors with a high accident frequency rate, and mainstreaming the gender
and age dimensions;
examine the appropriateness of proposing the integration of the problem of
stress-related complaints and illnesses into the employment guidelines for 2003;
analyse the role of the ESF in terms of promoting a healthy and safe working
environment, in conjunction with the mid-term assessment of the current
programming exercise;
step up harmonisation work on European statistics and on the construction of
progress-chasing indicators;
improve the fund of knowledge on the economic and social cost of occupational
accidents and illnesses.
2.
Voluntary agreements concluded by the social partners
The social dialogue is an ideal instrument for applying innovative methods: on the
one hand, the existing legislation can be applied effectively; on the other, it is
possible to address all the questions concerned with promoting well-being at work;
additionally, the risks and problems specific to sectors of activity and occupations
can be addressed individually. The sectoral social dialogue has already
accumulated a great deal of experience in this field 22. For their part, certain
European works councils have drawn up “good practices”. At multisectoral level, the
social partners are helping to improve the existing legislation within the Advisory
Committee ACSHH and by way of consultations under Article 138 of the Treaty.
The various elements of the social dialogue structure might usefully address certain
of the new risks, more especially stress, whose multifarious nature — bearing in
mind the wide range of complaints which can be related to it — fully justifies an
approach of this kind, involving the social partners.
The Commission will, in 2002, open consultations with the social partners on stress
and its effects on health and safety at work, pursuant to the procedure laid down in
Article 138 of the Treaty.
22
For example, the adoption of joint manuals, training material, common positions on draft directives etc. in
agriculture, construction, gas, cleaning, private security services, sugar, telecommunications, fishing,
hairdressing, road transport, civil aviation and sea transport. The tanning/leather sector and the hairdressing
business have adopted codes of conduct espousing the principle of a safe and health working environment
and the application of best professional practices on the health and safety front. The various transport
sectors have drawn up joint contributions and framework agreements on working time and on matters
connected with health and safety.
Page 19
3. Corporate social responsibility
The increasing trend towards outsourcing, along with the public’s enhanced
sensitivity to health issues, have led a large number of firms to make a healthy and
safe working environment an important criterion in the choice of their subcontractors
and the way they market their products. For instance, health at work has been
included in voluntary certification and labelling initiatives, more especially in
purchasing procedures, often using third parties 23.
The Green Paper "Promoting a European framework for corporate social
responsibility" 24 stressed that health at work is one of the ideal areas for voluntary
“good practices” on the part of firms which want to go beyond existing rules and
standards. The ensuing consultation exercise, which covered a wide range of
interested parties, will enable a number of possible responses to be identified.
4. Economic incentives
Economic incentives have long applied to accidents at work and occupational
illnesses, with insurance premiums, for individual firms and/or sectors of activity,
varying according to the accident rate. This encourages risk prevention and
complements the other instruments available in the field. Insurers — both public and
private sector — have already given thought to similar economic incentives, offering
prevention contracts which include an analysis of the risks in the company,
technical assistance, equipment aids and appropriate training. These kind of
practices would seem to warrant more systematic application.
3.3.3. Working to mainstream health and safety at work in other Community policies
Well-being at work cannot be brought about simply by way of health and safety policy:
there are strong links with the way work equipment is designed, with employment policy,
with policy on disabled people, and with other policies like transport and, of course, health
policy in general, whether it be preventative or curative.
There should be a stronger element of integration of health at work into the
European employment strategy, given its importance in terms of promoting the
quality of employment and making full use of the EU’s productive potential. This
strategy puts forward new proposals for strengthening this link.
There should be improved linkage with the Community rules on the manufacture
and marketing of work equipment and chemical products. This could be fostered by
a more systematic effort to collect information on the effects such equipment and
products have on health at work, and their repercussions for manufacturers. In this
respect, voluntary labelling practices can have an important contribution to make.
There should be stronger links between the new Community strategy on health and
safety and the Community's strategy on public health, by way of closer cooperation.
23
“Occupational Safety and Health in Marketing and Procurement”, report to the European Agency for
Safety and Health at Work, 2000, ISBN 92-95007-01-8.
24
COM (2001) 366 final.
Page 20
Experience gained on how to prevent the major public health scourges — more
especially the various types of substance dependence — should be built in to
preventive measures at the workplace. On the other side of the coin, health at work
should be recognised as an important determinant of the population’s general state
of health.
We should develop an approach which is coordinated with other policies pursuing
protection objectives and based on preventative measures, more especially
transport policy, the environment, civil protection and the common fisheries policy.
As regards the common fisheries policy, the Commission will invite the social
partners to identify measures for improving living, working and safety conditions in
the industry, for strengthening the role of women, and for helping to develop the
employment situation, particularly for young people, in regions which are dependent
on the fishing industry.
Whenever a public contract is awarded on the strength of a tendering procedure,
the contractor must fully comply with all the rules and regulations which are of
mandatory application in the field of health and safety at work. Bids entered by
tenderers who would appear not to have taken into account the obligations
concerning protection arrangements and working conditions as indicated by the
awarding authority in the specifications cannot be regarded as in conformity with the
specifications, or might appear abnormally low for the work in question, and can be
rejected on those grounds. The social partners in the private security and cleaning
businesses have addressed the question of compliance with health and safety
rules.
3.4. Preparing for enlargement
Enlargement is one of the major challenges facing the European Union. This is true first
and foremost of the EU itself, which has to ensure that the new Member States can be
absorbed in conformity with the rules and with a guarantee that the institutions and bodies
of the EU will continue to function smoothly. It is also true, though, of the candidate
countries themselves, which have to absorb into their national systems an enormous and
complex corpus of legislation. To ensure that the acquis communautaire is being properly
applied, there must be an effective transfer of experience and knowledge, with special
reference to:
1.
Beefing-up programmes of technical assistance, using partnership and twinning
arrangements;
2. Developing arrangements for the exchange of experience and access to knowledge
and to the results of Community research, by integrating the candidate countries
into the institutions and bodies concerned;
3. Strengthening the social dialogue at all levels, particularly in firms;
4. Promoting the collection and analysis of data on accidents at work and occupational
illnesses, notably by integrating the candidate countries into ongoing Community
work on statistical harmonisation.
Page 21
3.5. Developing international cooperation
Community policy on health and safety at work must link up with work being done by the
international organisations. The Commission will continue its active collaboration with the
agencies of the United Nations — the WHO and the ILO — which have a similar role to
play in improving the level of protection of workers’ health and safety, and with whom the
Commission has long enjoyed a fruitful cooperation. This cooperation should focus on the
following areas:
Eliminating the worst forms of child labour in the world, under the “IPEC”
programme and in application of ILO Convention No 182 of 17 June 1999, which all
the EU Member States have ratified or will shortly be ratifying;
Supporting improvements to occupational health throughout the world, more
particularly by encouraging the ILO to draw up conventions and recommendations
which take account of Community legislation, and by cooperating to ensure that
they are effectively applied;
The effects of dependence on medicinal drugs and alcohol on health and safety at
work, the importance of which is recognised by the WHO and the ILO.
Cooperation with third countries — more particularly those of the Mediterranean Basin,
ASEAN, NAFTA and the Mercosur group — is essential if we are to ensure that minimum
health and safety standards are adhered to, even though the prime objectives are to
facilitate the free movement of goods, services and capital. In this respect, the legislative
framework adopted by the European Union could serve as a basis for exchanges of
information with these countries.
Cooperation and exchanges of experience on occupational health and safety issues
already initiated with the USA under the Transatlantic Pact should be strengthened. The
two-yearly bilateral conferences involving the EU and the USA, and the exchanges of
information coordinated by the Bilbao Agency, are illustrations of a desire to cooperate in
the interests of improved labour protection at international level.
Page 22
Annex: 2
Early thoughts on the content and shape of the next (2007-11) European Union
Occupational Safety and Health (OSH) Strategy, and on how HSE may influence it
1. We are now well past the mid-point of the EU’s current 5 year EU OSH strategy (2002­
06 (see Annex 1); there are currently moves to review its progress and evaluate its
effects. The development of that strategy was marked by a general lack of real and
timely consultation and transparency. As a result it is far from strategic, has neither
clear priorities nor any action programme, and has no follow-up mechanisms. So
although it appears to be comprehensive and far reaching, apart from modernising and
tidying some of its consultation arrangements, mainly to reflect enlargement, in fact it
allows the Commission to carry on doing, or not doing, more or less what it wants.
2. HSC/02/21 set out how we sought to influence that strategy. Prior to that we sought to
engender a debate on how it should look by placing a discussion document on the HSE
web site and inviting comments. Few responses were received. The document was
amended to reflect those that were received, and it was then submitted to the EC and
its Luxembourg Advisory Committee. It was well received and stimulated other MS,
particularly the Danes, into trying to get some coherence and transparency into the
process of developing the strategy.
3. Before the next EU OSH strategy is developed, the current one needs to be evaluated.
The EC has set this in train and has given the task to its “Brussels Antenna”. This is a
small unit of DG Employment, based as its name implies in Brussels rather than
Luxembourg. Its main task is to monitor the OHS implications of directives and other
initiatives brought forward by other DGs, and also to try to “mainstream” OHS into other
DGs’ initiatives, for example by linking OHS with the distribution of the EU Social Fund.
4. In trying to shape the Current EU OHS strategy, we argued that it should aim to ensure
that OSH was strongly linked to the wider economic agenda, contribute to
competitiveness and be central to a well founded economic policy; for example by:
ensuring a fit, available and motivated workforce
preventing economic and social exclusion of families
minimising the costs of accidents and lost working time
promoting mobility of labour and good functioning of the single market, and
promoting productivity and competent management
5. We argued for the concept of “Quality in Work”, to recognises the positive contribution
OSH can make to a dynamic and productive economic system, and stressed that it is
most successful when introduced by effective and developed systems of risk control
and prevention, based on risk assessment - an approach which targets the real
problems, balances risk and response, and where the effectiveness and impact of
Page 23
interventions are measured and monitored. We also promoted the use of a variety of
tools: not only effective law – linked to inspection and enforcement, but also
stakeholder engagement. Some of this thinking was incorporated in the resulting
strategy and has now become accepted in the OHS world but still needs embedding
more widely.
The Lisbon Agenda
6. The current EU OSH Strategy notes and acknowledges the Lisbon Strategy (or
Agenda), which was adopted by the European Council in March 2000. The Agenda
commits the EU to a 10 year strategy to bring about economic, social and
environmental renewal, and to make it the world's most dynamic and competitive
economy. By achieving a stronger economy it is intended to drive job creation
alongside social and environmental policies that ensure sustainable development and
social inclusion. It is clearly recognised that the drive to achieve these aims should not
be at the expense of the health and safety of the EU’s workforce, although in practice
there is likely to be conflict. Progress towards the Lisbon aims is reviewed at every
spring council, when the commitment to quality work and good OSH has been
reinforced.
Simplification and Better Regulation
7. However, at the last review, under the Irish Presidency, other issues started to assume
a far greater importance, not least “better regulation”, which the Council decided was
needed, at both European and national levels, to enhance competitiveness and
productivity. It welcomed the four Presidencies initiative (recently extended beyond the
UK’s to the Austrian and Finnish Presidencies) on better regulation, called for a
programme of actions to drive this forward and welcomed the Commission's
commitment to further refine the integrated impact assessment process. Although the
current EU OSH strategy commits the Commission to making “the necessary legislative
proposals for consolidating the Community Directives and for rationalising
implementation reports”, as yet there has been little sign of activity.
Enlargement
8. There is no doubt that the enlargement of the EU, with the admission of 10 new MS on
1 May 2004, has overshadowed OSH as much as it has other issues. It is easy to fall
for the argument that OHS in the EU needs to stand still until the new members “catch
up” to the standards of the old ones. Others argue that the adoption of a better
regulation agenda for EU OSH will in fact prevent this and result in the MS having an
inferior, high hazard work environment. There is no doubt that there will be pockets of
antiquated working, with associated OHS practices, in the new MS but these can still
be found in the old ones, including the UK. But it is far more likely that factors such as
globalisation and trans-EU enterprises, e.g. such a Volkswagen, will rapidly spread
good OHS practices to every corner of the EU.
Page 24
The Amsterdam Conference
9. A milestone in the new thinking of how the EU OSH strategy should develop was the
Conference held under the Dutch Presidency. Titled “Effective Intervention and Sector
Dialogue in OSH”, it strongly promoted “soft law” and voluntary initiatives. We provided a
number of HSE speakers, including the Chair, to promote the philosophy and some of the
key themes of the new HSC/E strategy, as a model for the future of OSH in Europe. The
conclusions could well influence the new European Social Agenda that will be published in
2005. It strongly promoted the concept of Social Partner agreements, as already adopted
for teleworking and stress.
Law
10. We should continue to recognise the contribution made by the framework of OSH law
in establishing a sound basis for the protection of workers and the prevention of risk. The
Framework, daughter and related Article 137 worker protection and Article 95 / 175 single
market and environmental Directives now in place, provide a sound foundation on which to
base the EU’s OSH system. The key aim should now be to make sure this law is working
effectively across the EU, focusing on reviewing progress and studying the practical
results on the ground for example by the evaluations of each other’s inspection regimes
carried out by SLIC. It would be tempting, under the better regulation theme, to press for
the revision and simplification of this law. However, this would risk not only diverting
resources from other initiatives which could make a difference but would also give an
opportunity to others, who do not share our thinking on the way forward, to introduce new
burdensome legislation which would not necessarily improve OSH in practice.
The way forward – What?
11. As with HSC/E’s new strategy, the EU’s next one needs to focus more on outcomes.
Essentially we consider that our broad approach should be:
To argue against the need for any new regulation, with the thrust rather on better
evaluation of existing law, and more "soft law" approaches, such as those on stress
and teleworking.
To call for all proposals, whether hard or soft, to be accompanied by rigorous
impact assessments.
To encourage further moves to mainstream OSH into social and other EU policies.
To encourage continued efforts to improve the EC evidence base, working with the
relevant DGs and the Bilbao Agency.
To encourage continued sharing of best practice on enforcement and peer review,
using SLIC and other fora.
To resist any unnecessary simplification of existing legislation unless it can be
demonstrated that this will bring real benefits in terms of successful OHS outcomes
or significant reduced costs to EU business.
Page 25
To improve our links with key partners, at EU level, especially the TUC and CBI
given the likely renewed emphasis on social partners.
The way forward – How?
12.
Our attempts to influence the current EU OSH strategy started far too late. This
time we are not alone to realise that this will be a long process. At the last two meetings of
the Luxembourg Advisory Committee Government Interest Group the need for early
thinking on the next strategy has been raised, with the UK and Denmark leading the way.
It is likely that a virtual working group will emerge to produce a paper for the GIG to
consider. In the same way SLIC is likely to start considering the way forward on ways of
achieving better prevention and securing compliance; and the Bilbao focal point and Board
groups will be considering what role the Agency and its communication activities are likely
to have.
13. However, the recently emerged “European Directors General of H&S group”, although
it has no official status, is probably the body which should have widest oversight of the
future direction for OSH in the EU, embracing all the ambits of the groups mentioned
above (although it should be borne in mind that for some, especially the smaller MS, send
the same representative to all these fora. This group first met under the Irish Presidency
in April 2005 and is due to meet again under Luxembourg’s, in March 2005. The Irish
meeting was intended to be forward looking, concentrating on how OHS should develop in
the future but it was essentially a stock take with a few ideas for the future. The
Luxembourg event is due to discuss promoting excellence in OHS.
14. Should the UK hold a Presidency event it could incorporate a DGs’ meeting, and it
could be strongly focused on the EU’s next OSH strategy.
The way forward – Who?
15.
In addition to the EU OHS DGs and the members of the above mentioned fora, it
will be necessary to engage with and influence the key EU players. These would include
Commissioner Špidla, Commissioner for Employment, Social Affairs and Equal
Opportunities, Mme Quintin, his DG, Bernhard Jansen, the Director for OHS and chair of
the Luxembourg Advisory Committee, and M. Biosca de Sagastuy, head of OHS matters.
This will be far from easy: Despite some indication of moving towards a softer approach
e.g in Jansen’s speech to the Amsterdam Conference, all the evidence is that all these
players come with a history of favouring hard law approaches.
16.
Some, albeit less important players, seem already be committed to a more
enlightened approach. These include Hans Horst Konkolewsky, the Head of the Bilbao
Agency, who last visited HSE in April 2004, in connection with the 2003 Euroweek awards.
HSC/E’s new strategy had just been launched and he commented that it appeared to be a
model for the way forward in Europe. Recent Agency communications have reflected this
view. Paul Glynn, the head of DG Employment’s Brussels Antenna will also need little
persuasion, given his “ mainstreaming” remit.
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17.
But we may need to go wider. In order to make the case for good standards of
OSH across the whole of the EU being an essential element of a high performing
economy, such key players as Commissioner Mandelson, DG Trade and Commissioner
Kroes, DG Competition, and their teams, may need to be brought on board.
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Annex 3
HSE Events scheduled for the UK Presidency of the Council of the European Union,
July – December 2005
Events
1.
Main events are:-
• UK Presidency occupational health and safety conference incorporating a DGs’ event.
It was initially proposed to hold this event on 28-29 September 2005 but this is likely to
clash with the Labour Party Conference where Ministers want a clear window. The
event is therefore now more likely to fall into early October subject the timing of the
Labour conference – further information below.
• HSE’s Hazardous Installations Directorate (HID) organised CCA meeting – one day
conference looking at Seveso (control of major-accident hazards) implementation and
future strategies to enhance consistent compliance, followed by a site visit to the new
Health and Safety Laboratory (HSL) site in Buxton, Derbyshire. October 2005.
• 49th Meeting of the Senior Labour Inspectors Committee (SLIC) to be held in London 9­
10 November 2005.
UK Presidency occupational health and safety conference incorporating a DGs’ event
Background
2.
Hosting an event on occupational safety and health (OSH) issues in the EU and
how the next EU OSH strategy should be framed will provide a chance to influence
thinking on the strategy, which will run from 2007-2011 and will start to be developed in
2005.
3.
A submission was made to DWP Ministers on 1/11/04 inviting Ministerial agreement
to the UK’s staging a major health and safety event during the UK’s Presidency of the EU
in 2005. The response was very positive.
Proposed Format and Content
4.
2 day event. Event could possibly be run over 3 days if starting mid day and
finishing mid day but cost wise it would be more efficient to run as 2 full days if logistics will
allow and it is thought that delegates will be fresher and more engaged.
5.
Day 1 would be a conference event with Plenary and workshop sessions, utilising a
cross section of UK and EU speakers, including from business as well as OSH
organisations. A Minister could also be invited to speak. Invitees would include MS OSH
DGs and others (cf. section 8). High-level themes could be:
• Innovation and development beyond the existing bedrock of EU
legislation
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• What should be tackled at EU, Member State or enterprise levels
• Promotion of health and safety as an integral, beneficial, part of business
management
• Worker and stakeholder involvement
6.
DG Employment are keen that the event adds value to the EU OSH agenda and
that examples or discussions should not focus heavily on a few individual MS activities.
7.
In the evening of day 1 there would be a reception/meal for either key people who
attended day 1 (DGs and others) or just key people attending day 2 (mainly DGs).
8.
Day 2 would be a MS OSH DGs’ meeting, which following on from day 1 would:
• Evaluate the current Community strategy on safety and health at work – with the help
of Paul Glynn, head of DG Employment’s Brussels antenna.
• Set the framework for the next Community strategy on safety and health at work from
2007-2011, taking account of the conclusions of the previous day’s event.
9.
Topics that might be considered for the day 1 conference include:
• Under the ‘Innovation and development beyond the existing bedrock of EU
legislation’ theme:
• ‘Mainstreaming of OSH, e.g. OSH in education
• How HSE is tackling key issues such as stress
• Other EU MS and/or organisations to have input to or run some sessions
(under any theme)
• Under the ‘What should be tackled at EU, Member State or enterprise levels’
theme:
• Simplification at EU and MS level
• Corporate Social Responsibility (CSR)
• Feeding relevant event info into the 7th EU Research Programme
• New technologies such as Nanotechnology
• Under the ‘Promotion of health and safety as an integral and beneficial part of
business management’ theme:
•
• Workplace 2020 – what the workplace environment will be and how
health and safety (H&S) will fit in if it has been successfully mainstreamed
into business practices.
• Public sector as an exemplar
• A session (possibly from The Agency) on state of the art thinking and
best practice in terms of businesses taking H&S to the heart of their
business plans and operations. Getting inactive people back into the
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workplace and preventing people from becoming inactive (Mentioned by
Chris Pond, in response to our submission for ministerial approval for the
event)
• Under the ‘Worker and stakeholder involvement’ theme: •
• Using the HSC workplace strategy to 2010 and beyond as a suitable
model to learn from.
Invitees
10.
As well as the current, recently expanded, 25 EU MS, it has been indicated that
candidate countries could also be represented (Bulgaria, Romania, Turkey, Macedonia
and Croatia).25
Day 1 conference (number estimates in brackets):
People to definitely invite – MS OSH DGs (30); relevant staff from DG Employment (5-10); conference host, speakers, session leaders, administrative staff (note takers etc) (10-12); translators; Using this model would give a minimum total of 45+ any necessary translators and a maximum of approximately 52+ translators for the day 1 conference. Additional people to consider inviting – EU social partners (2); Luxembourg Advisory Committee (LAC) Government Interest Group members (30); MS social partners (60); other key European occupational health and safety experts (10). Adding to the higher total of people definitely attending would give a maximum total of approximately 150+ translators (there is overlap of roles in some MS). Day 2 MS OSH DGs’ event
People to attend – MS OSH DGs (30); relevant staff from DG Employment (5); host,
speakers, session leaders, administrative staff (note takers etc) (10); translators;
Using this model would give a total of 45+ any necessary translators.
Possible Locations
11.
Liverpool – HSE’s new Headquarters is due to be completed in May 2005, situated
in Bootle, which adjoins Liverpool. The DGs’ event on the second day could potentially be
held at the new HQ and the larger conference event could be held at a suitable venue in or
near Liverpool.
12.
London – holding the event in London would also be possible. Reaching London by
plane or train would be better for delegates.
Option 1
12.
2 day event in Liverpool. Day 1: Conference; Day 2: DG event.
25
It is assumed that candidate countries will be represented in comparative numbers to MS on all bodies
Page 30
The conference will need to be held in a suitable non-HSE venue if up to approximately
180 people attend. The DGs’ event could be held in same location or at the new
Merseyside HQ (maximum room capacity at the new HQ will be 80 in the auditorium.
Many meeting rooms are available with capacities of 15-20 for any breakout sessions or
smaller meetings if required).
Option 2
13.
2 day event in London. Day 1: Conference; Day 2: DG event. The conference will need to be held in a suitable venue if up to approximately 180 people attend. Costs, Funding and Resources
14.
EU funding of 80% of costs up to a maximum of €200,000 is available,
approximately £138,639 (at 9/12/04 exchange rate of approx £1 : €1.44, €1 : £0.69).
20% funding and any excess over €200,000 must be found elsewhere.
There is no further EU funding for other events, i.e. as well as funding 20% and any
excess for this event, HSE will need to find funds for other events such as the SLIC
meeting.
15.
Costs could reach or exceed the £200,000 estimate given in the submission to the
Minister and it would probably be difficult to keep costs much below £100,000 without
restrictions on the number of funded people attending both days (either by restricting
invitations or expecting some invitees to pay for themselves) as well as ensuring the event
was run only over 2 days rather than a late starting day 1 running into an early finishing
day 3, with extra accommodation costs etc. However, costs could be reduced if some
attendees where expected to pay for their own accommodation, subsistence etc.
16.
HSE staff resource estimate:
• 3/4 of a Band 3 for period from Dec 2004 to December 2005 in Better Regulation
and International Branch (BRIB)
• Band 5 in BRIB for period Jan 2005 to December 2005
• Use of staff expertise and resource in CDS as and when necessary
Outline Work Plan
16.
Initial thoughts are:-
November / December 2004
• Initial ideas for format and content, preparations and consultation within HSE and
EU.
• Paper to HSE Board.
January 2005
• Following feedback from Board and discussions with PEFD about funding, agree
event format and topics for event.
• Consultation with CDS and provisional booking of venue and accommodation.
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•
Paper to Commission.
•
Consult potential speakers
February 2005
• Announcement of event.
•
Send invitations.
•
Confirm sessions and speakers.
•
Confirm venue and accommodation bookings
February – September 2005
• Detailed organisation of event
October – December 2005
• Follow up work
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Annex 4
Summary of current European and International Work by Directorate/Division
Introduction
1.
Annex 2 to paper HSC/03/107 provided a comprehensive census of planned
involvement in International Working Groups, Conferences Etc/Visits/assistance to
Applicant Countries fro 1 April 2003-31 March 2004, across HSE under the headings:Europe
Working Groups/Committees
Standards/ Technical Committees
Conferences/Seminars/Workshops etc
Directives
International
Working Groups/Committees
Standards/ Technical Committees
Conferences/Seminars/Workshops etc.
2.
Paper B/05/05 has been produced in a comparatively short space of time that has
not permitted the collection of the latest extensive information that featured in HSC/03/107.
This Annex is therefore necessarily more impressionistic in nature in terms of whether
areas of work have expanded, reduced or remained the same.
3.
Before providing analysis of the material gathered, it is worth mentioning a
miscellaneous point that came out during the exercise. It has been suggested that there is
a moral dimension in HSE's European and other international work in seeking to raise
health and safety standards overseas. In meeting this moral obligation it can also help to
raise the profile of UK plc abroad and yield wider benefits to the British economy in terms
of generating demand for goods and services. The UK plc element is something that has
more actively been pursued by OSD in conjunction with DTI by participation in industry
events abroad, essentially aimed at generating new markets for British equipment
suppliers.
The overall picture
Legislative activity in Europe remains comparatively quiet. The Optical Radiations
proposal is proceeding and a proposal for an amendment to the Carcinogens Directive is
expected in 2005. A range of factors linked to Chemicals work may lead to increased
resource demands.
Activity on secondments remains modest.
Involvement in the major European bodies (ie the Senior Labour Inspectors Committee,
the Luxembourg Advisory Committee and the Bilbao Agency) in terms of attendance at
regular meetings remains consistent as does standards work.
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In summary, the overall impression gained is that European and International work is
decreasing in some areas but with some transient increases in others, prompted in a
number of cases by the UK Presidency of the EU in 2005.
HID
In the HID plan for 2005 -08 a similar level of resource will be committed to
EU/International activities and at this stage we do not foresee a significant increase or
decrease in the total. What is emerging is an expected decrease in percentage terms of
HID's involvement in conventional H&S and major hazards topics with the balance going to
an increase into sectors like biological agents, explosives (including fireworks) gas
conveyance, pipelines and the implementation of the SEVESO II Directive.
In 2005 HID will allocate the main part of its effort into the revised SEVESO II Directive.
With the UK having the EU presidency in HID will support Policy Group in its major event it
is sponsoring - the EU Competent Authorities Forum in the Autumn of 2005.
OSD are organising the spring of 2005 offshore International Regulators Forum (IRF) in
London and will be participating in the Offshore Europe Conference in Sep 2005. The
Head of OSD will continue to represent HSE on the IRF from 2006-08.
SI are putting in a bid to host the 2006 annual Heads of State Mining Authorities
Conference in the UK.
HID has discharged its commitments in respect of the working groups, conference etc as
outlined in the Annex 2 to HSC/03/107. Updated information on some of the main HID
contributions are:Activity
Directives
Committee of Competent Authorities
for Directive 96/3 on the control of
major accident hazards involving
dangerous substances
Working Groups/ Committees
EC Standing Working Party on
Extractive Industries
UK Offshore Oil Industry Health
Advisory Committee
Offshore International Regulators
Forum
Conferences/Seminars/ Workshops
Annual Heads of State Mining
Authorities Conference
Contact/attendees
Timothy Beals, HID HQ
Dan Mitchell, Specialised Industries
Ian Whewell, OSD
Taf Powell, OSD
Dan Mitchell, Specialised Industries
FOD
1.
Senior Labour Inspectors Committee Work included:-
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i. Adoption of ‘Common Principles of Inspection’ at November 2004 SLIC
Plenary meeting, a package that will be used to structure future SLIC
evaluations of Member States (Input by Adrian Ellis, Stuart Campbell and
Marcia Davies)
ii. SLIC Member State evaluations:• Germany – Sandra Caldwell/Graham Walker
• France – Stuart Campbell
• Finland – David Snowball
2.
Health Unit participation in European Workshops:iii. Workshop on MSD addressed by Claire Friend
iv. Workshop on stress – participation by Jo Walker
v. Workshop on the Chemicals Strategy – participation by Anne Wilson
3.
The Commercial and Consumer Services Transportation and Utilities Sector
(CACTUS) had a continuing involvement in the MSD problems of baggage handlers.
4.
Edinburgh based Specialist Electronic Inspectors monitored the development of the
C standards in relation to the packaging industry in conjunction with the Food sub-sector.
5.
Asbestos Work:i. ALU has contributed to SLIC Asbestos work over the past 4 years,
including a major contribution to the Dresden conference;
ii.
6.
S
wedish Workshop to consider elimination of dry stripping (Stuart
Campbell). Further work on asbestos by Stuart Campbell and Trevor
Johnson in 2005.
FOD Scotland international visits hosted:i. Polish delegation looking at Asbestos;
ii. Austrian delegation looking at inspection principles and practice.
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FOD Central Specialist Division
Biocides and Pesticides Unit - All of the international work of BPU centres around the
Biocidal Products Directive, for which HSE is the UK Competent Authority i.e. this is
mandatory work, which HSE and the HSC have signed up to. The international
contribution is expected to increase over the coming year - more people being involved
and more meetings. This is because the directive is now implemented and work has
started in Member States to review biocides. The UK has been allocated work which will
have to be presented at the Standing Committee on Biocides on the prescribed dates.
There is also a requirement to attend Competent Authority and technical meetings. This
had all been set in motion before the new strategy came into place and has not been
affected by it.
Industrial Chemicals Unit – European and International activity is assessed "slightly lower"
(<5% less), with a good deal of variability between each individual element.
Occupational Hygiene Units / Radiation and Ergonomics Noise and Vibration Pooling Units
/Medical Units –
Dr Oldershaw has stated he finds it impossible to make firm comment on the amount of
international work carried out in CHSD B as:
•
The Division is only now coming together, with the integration of the
pools and the significant transfers into FOD
•
There is no reliable measure
•
Staffing levels have fluctuated - there are vacancies in small
disciplines and reduction in international/standards work may well reflect
accommodating these.
All international and standards work continues to be closely challenged, and this was
increased with the implementing of the S&T Strategy.
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Policy Group
BRIB
1.
Acquisition of the Focal Point/European Week of Safety and running these even on
a reduced basis has made major demands on BRIB resources. Considerable demands
have also been made in relation to the SFAIRP infraction case and an increasing amount
of work is developing linked to the UK Presidency in 2005. This will involve the
organisation and planning of the Senior Labour Inspectors Committee that the UK will be
hosting in November 2005 and a major Presidency health and safety event in September
2005. The usual demands regarding attendance at the Luxembourg Advisory Committee
(LAC) and the Administrative Board of the Bilbao Agency will run on. Work is likely to step
up within the LAC connected to developing the successor European OSH Strategy.
Chemicals work
2.
EU - the proposed EU Chemicals Policy (REACH) signalled in para 7 of HSC
03/107 has now been published as a draft regulation and negotiations have commenced.
DEFRA have the lead and hope to achieve a UK Presidency success by reaching political
agreement at the Competitiveness Council in November 2005. The proposal presents
significant threats and minor opportunities to our programmes. We have an agreed
position based on ensuring the programmes are protected but a considerable effort will be
needed to deliver a successful outcome. The resource devoted to this work will need to
increase as negotiations move into areas we have a major interest (eg safety data sheets).
3.
Exposure limits - DG Employment’s continued failure to progress EU limits
threatens our policy of reducing domestic work in this area and saving resources by
adopting the EU system. This is a very difficult area and both TUC and CIA are uneasy
with the situation. Teresa Quinn's placement on the Ad Hoc Advisory Committee is an
essential tactic to manage this problem and there will be a continuing need for input,
possibly rising. There are further legal problems over the constitution of the expert group
on exposure limits (SCOEL) and this too could threaten our policy.
4.
UN - a Globally Harmonised Scheme for Classification and Labelling has now been
agreed and there is political commitment to amend EU law to implement it. This is an area
of great significance for us as much of our chemical risk control legislation depends on a
robust classification (COSHH, SEVESO and COSHH essentials). We foresee a proposal
to alter REACH to introduce this change late in 2005 - a good deal of work will follow which
will require additional resources to protect our domestic agendas.
5.
Mark Blainey has had his secondment extended for a further year to deal with
REACH, we also have a secondee in DG Employment dealing with exposure limits.
Biocides
6.
Activity in this area has stayed substantially the same. The review programme has
moved on, and we are now negotiating the third regulation (we were up to the second
when the table was prepared). Amendments to the directive itself are still being
contemplated but are probably some way off, the Commission being unwilling to devote
energy to such a demanding initiative while the system as it is still needs to be got up and
Page 37
running. More immediately - in time and space - some amendments to our UK transposing
legislation have to be made and that is likely to be the main call on our resources in 2005.
Railways Policy
7.
Key objectives over the next year will be to:
i. continue to provide the secretariat to the international liaison group of government
railway inspectors which provides a forum for insuring our European agenda can be
driven forward;
ii. supporting DfT/SRA in matters concerning implementation of forthcoming European
Directives (for example the driver licensing directive is currently in negotiation - Peter
Hornsby leads in supporting DfT);
iii. continuing our work on the effective implementation of existing European Directives
(here the key elements are finalising the regulatory package to implement the
European Railway Safety Directive and further work with DfT and other stakeholders
on the implementation on both the conventional and high speed interoperability
directives;
iv. "watching brief" on other EU initiatives which may affect Health and Safety on the
Railways (here for example there is some talk of a proposal for an urban railway
directive and one or two "gleams" in the eyes of the commission;
v. continuing to provide the UK secretariat for the channel tunnel safety authority.
Musculoskeletal Disorders (MSD)
The social partners Teleworking agreement has been signed and sealed and n further
action is in prospect unless EC move to bring forward a Directive at some point. The
social partners consultation on the proposed new MSD/Upper Limb Disorders was
published in November. HSE has briefed three of the four social partners involved in the
consultation and will be submitting written views to the EC’s DG Employment. As with the
Teleworking agreement the longer term issue is whether the proposal evolves into a
Directive at some point.
Nuclear policy
The international workload is likely to increase in 2005. This is because both the
Convention on Nuclear Safety and Joint Convention overlap. There will also be additional
work coming out of the UK's Presidency of the EU and potentially arising from the UK's
Presidency of the G8.
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NSD
During 2004-2005, the need to apply resources to specific licensing projects, whilst
maintaining its core regulatory function, led to a planned reduction in NDS's international
activities (about 10%). We expect this trend to continue into 2005-2006. It is essential
therefore that the remaining international work reflects the UK/HSE/NSD priorities.
The NSD international plan of work for 2004-2005 identified priority areas of work. It
recognised the importance of the continued development of international nuclear safety
standards and the harmonisation of regulatory practises within Europe. NSD management
agreed that this should be the first priority. This work is mainly (but not exclusively) carried
out in the framework of the IAEA, NEA/CNRA and WENRA. Of equally high priority is the
NSD participation in the Nuclear Safety Convention and the Convention on the safety of
spent fuel and radioactive waste. This is a vehicle for the UK to demonstrate to our
international peers that our standards and practices are satisfactory and do not pose any
threats to other states. It also give the UK to option to challenge safety in other states.
Other NSD international work is reducing. This includes some of the knowledge
dissemination and research orientated work of the NEA/CSNI. Also, for many years NSD
has been a major participant in the European Commission assistance programmes to the
Countries of Central and Eastern Europe and the Former Soviet Union. Now that many of
these countries are now (or soon will be) equal partners in the EU, this work will inevitable
decrease and eventually cease. For the time being we propose to maintain some activities
in well defined areas such as the decommissioning of Soviet designed reactors and some
assistance to the Russian Federation and Ukraine.
Bilateral arrangements with near neighbours (Ireland and France) will continue as will
exchanges with the US regulator - particularly on security matters.
HSE/NSD currently provides a secondee to the IAEA in Vienna - an arrangement which
has continued for many years. We also have and exchange of staff with our French
counterparts.
UK presidencies of G8 in 2005, the EU in the second half of 2005 may lead to some
initiatives that could place a demand on NSD resources (eg possible conferences).
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