Contribution by Dominic Mooney

Comment by: Dominic Mooney

Focus area: Chemicals

Regulator concerned: Health and Safety Executive (HSE)

Comment:
Generally, my experience with the HSE has been very good. I am basing this on experience as Safety & Environment Manager for an Upper Tier Manufacturing and Warehousing site, previously lower tier.

My main concerns are:

1) The under-resourcing of the HSE (exacerbated by recent cuts) so Intervention Plans are rarely matched. Too often they have to react to incidents rather than do the pro-active work that would prevent harm.

2) The slowness of the issuing of reports from intervention visits, which can delay improvements.

3) The backlog at CI5 in Bootle for assessing hazardous planning consent. Presently 3 months which mismatches with planning expectations. Again, exacerbated by cuts based on feedback.

4) The fact that hazardous planning consent sits with local authority who are very inexperienced and ill-equipped to handle consent (forgetting to copy HSE for developments in the public information zone, forgetting to send applications to the HSE). The delays impact business ability to grow. Not HSE directly, but it ties to them.

Generally, COMAH remodelling has been very good and is the right way forward; it just needs the right resource behind it. The pro-active approach is the best way to prevent another Buncefield or Flixborough.

HSE Inspectors have been constructive and helpful, and supportive of the growth of the business. They are pragmatic rather than fitting the stereotype of ‘elf n safety gone mad’.

I am very concerned about the possibility of the Seveso III directive just being written into UK law as it stands. It is not especially clear and the HSE Guidance is excellent as a working document. It would have a big impact on safety were it to happen.

Overall, HSE guidance is very useful and the current attitude against it in government combined with the rhetoric of the Prime Minister and other Ministers about Health & Safety puts people’s lives at risk on the altar of cost. The insurance industry and no-win no-fee needs to be addressed. That would benefit business more than a wholesale disposal of regulations.