Safety Management System Overview
1. Imperial College is a large and highly complex organisation. It has a wide range of diverse activities, many of which are potentially hazardous, and operates on a large number of sites. These sites are shared with many other persons who are likely to be unfamiliar with the hazards and risks associated with the College’s activities. The effects of an incident or a breach of health and safety legislation at the College or involving its staff or students could be very serious. It could have a devastating effect on the people involved as well as on the College’s business. The potential costs in terms of lost research and damaged reputation are also significant.
2. The College is committed to giving health and safety the highest priority in all of its activities. This commitment to the health, safety and welfare of staff, students, visitors and contractors whilst they are at the College or carrying out its business is reflected in its Health and Safety Management System (HSMS). This system is modelled on good practice as described in the Health and Safety Executive’s guide Successful Health and Safety Management (HSG65) and is designed to:
a. Support and promote a positive health and safety culture across the College.
b. Achieve effective communication on health and safety matters throughout the College,
c. Control the inherent and work-related hazards,
d. Ensure that the College’s staff, students and contractors are competent in all health and safety-related aspects of their work, including in the use of control measures and emergency procedures.
e. Ensure cooperation within the College and between it and the visitors, contractors, other employers and members of the public who share the workplace or may be affected by its activities.
3. The College’s HSMS has been developed in accordance with the following principles:
a. The health and safety of staff, students and others are to be protected by implementing systems of work that minimise risks to health and safety.
b. Health and safety duties, and the necessary authority and resources to discharge them, are delegated down the line management structure but responsibility remains with the person making the delegation.
c. Those to whom health and safety duties have been delegated are accountable for ensuring that they are effectively discharged and, where this is not possible, for ensuring that work is not initiated or, where it is in progress, is suspended.
d. Notwithstanding the above, members of staff, students and contractors are individually responsible for taking all reasonable precautions to ensure their own health and safety and the health and safety of others who may be affected by their acts or omissions.
e. The risks of all activities which may affect the health and safety of staff, students and others are to be assessed and appropriate control measures implemented.
f. There must be effective arrangements for representation, consultation and communication with staff and students on health and safety matters.
g. Staff, students and others affected by the College’s activities must be provided with appropriate information, instruction, training and supervision to ensure they can achieve the level of competence necessary to work in a safe and healthy manner.
h. Appropriate health and safety performance standards are to be set.
i. Procedures are to be documented to provide for effective communication and for the monitoring of change.
j. Regulation and compliance are to be based on systematic and regular audit, inspection and review.
4. The key elements of the HSMS are:
c. Planning and Implementation.
d. Measuring and Reviewing Performance.
e. Auditing Performance.
5. These key elements are described in more detail below. The relationship between them is set out in the diagram below:
General College Mission Statement
6. Imperial College London “embodies and delivers world class scholarship, education and research in science, engineering and medicine, with particular regard to their application in industry, commerce and healthcare”. It fosters interdisciplinary working internally and collaborates widely externally. This Mission can be broken down into a series of strategic intentions:
a. To remain amongst the top tier of scientific, engineering and medical research and teaching institutions in the world.
b. To harness the quality and breadth of our research capability, across multiple disciplines, to address major challenges.
c. To continue to attract and develop the most able students and staff worldwide.
d. To develop our range of academic activities to meet the changing needs of society, industry and healthcare.
e. To communicate widely the significance of science in general and the purpose and ultimate benefits of our activities in particular.
7. The College’s commitment to pursuing excellence in all its activities includes the management of health and safety across the College. This commitment is set out clearly in the Health and Safety Policy Statement, which is approved by the Management Board and signed by the Rector.
8. A key principle for the management of health and safety at the College is that health and safety duties and the necessary authority and resources to discharge them, are delegated down the line management structure as appropriate. To enable staff to carry out these responsibilities effectively the College’s Health and Safety Management Structure includes arrangements for support and guidance, which are provided by the Safety Department, the Occupational Health Service, the Security Department and the Fire Office.
9. The Council, as the College’s governing body, carries the ultimate responsibility for health and safety at Imperial. It delegates the executive responsibility for the development and implementation of health and safety policy to the Rector, who in turn delegates responsibilities to the principal officers who report to him. The organisation of health and safety below the Rector is shown in the College Safety Management Structure Diagram, whilst individual responsibilities for health and safety at every level in the College are detailed in the Health and Safety Responsibilities section. These responsibilities are used to inform individual job descriptions and are also employed by line managers for information, training, personal development and monitoring purposes.
10. The promotion of a positive health and safety culture across the College is led by the Safety Champion, who is a member of the College’s Management Board and is also the Chairman of the College Health and Safety Management and Consultative Committees. The Safety Champion is responsible for raising the profile of health and safety and ensuring that the Management Board is made aware of the health and safety implications of all strategic and operational developments.
11. Faculty Principals and Heads of Department/ Division are responsible for ensuring the safe operation of their Faculty/ Department/ Division and for providing and maintaining an environment which secures the health, safety and welfare of their staff and students.
12. To assist and advise them in the discharge of their health and safety responsibilities, every Head of Department/ Division is required to formally appoint a Departmental/ Divisional Safety Officer, together with Section Safety Coordinators and other specialist safety personnel whose areas of competency and remit must reflect the type and extent of the Department/ Division’s activities.
13. Local arrangements for health and safety also include the appointment and training of first aiders and fire marshals, and the establishment of emergency response groups capable of dealing with local hazards to be found in their buildings.
14. Specialist support and guidance is provided by the Safety Department which is responsible for advising the College on its statutory health and safety obligations, of the effect of new or amended legislation on the management of health and safety at the College, for the formulation of College policy on health and safety, the preparation of codes of practice and guidance and for carrying out inspections and audits across the College. As a necessary part of this remit, the Safety Department also takes an active role in health and safety committees at College, Campus and Departmental level.
15. Specialist support and guidance is also provided by the College’s Occupational Health Service and its Fire Department, which both work closely with the Safety Department.
16. The College has several campuses and operates on many other sites. Many of its buildings are also shared between more than one Faculty, Department/ Division and/ or, in some cases, external organisations. The College has instituted structures to ensure that health and safety arrangements are properly co-ordinated at these Campuses and in these buildings. This particularly applies on the medical campuses at Charing Cross, Chelsea and Westminster, Hammersmith and St Mary’s and at the College’s other campuses at Silwood Park and Wye. On these campuses, responsibility for co-ordination has been given to the Campus Deans who discharge this through campus Health and Safety Committees supported by campus safety advisors.
Health and Safety Committee Structure
17. The prime means for communication and consultation on health, safety and welfare issues between management and staff and student representatives is through the College’s health and safety committees. Their objective is to promote the health and safety culture and to encourage discussion, understanding and consensus between the various communities within the College about health, safety and welfare issues and their resolution.
18. The College’s senior health and safety committee is the Health & Safety Management Committee, which is chaired by the Safety Champion and reports directly to the Management Board. Its membership includes representation from each of the Faculties as well as the Support Services. Reporting to it is the Health and Safety Consultative Committee, also ch aired by the Safety Champion, which has been constituted in accordance with the Safety Committees and Safety Representatives Regulations 1977 for the purpose of c onsultation on matters pertaining to health and safety between management and union representatives. This includes representatives from the recognised trades’ unions and management nominees.
19. Every Department/ Division has a departmental/ divisional health and safety committee which reports to the Departmental/ Divisional Executive, and advises the Head of Department on the discharge of his or her health and safety responsibilities. There are also Campus health and safety committees at each of the College’s outlying campuses, which assist the Campus Deans in the coordination of health and safety across the Campus. Where appropriate, the constitution of departmental/ divisional and campus health and safety committees provide for representa tion from other employers based at the Campus.
20. In addition to the specialist health and safety committees, every management committee at College, Faculty and Departmental/ Divisional level includes health and safety as a standing item at each of its meetings. The College’s Management Board receives a monthly report on health and safety matt ers from the Safety Champion.
21. Model Terms of Reference are available for health and safety committees at all levels. The relationship between each of these committees is detailed in the published Committee Structure diagram. The minutes of health and safety committee meetings are made widely available, either through publication on the College’s Web site, or from the secretary of the relevant committee.
22. The College has a Health and Safety Communication Strategy, the objectives of which are to:
• Promote the health and safety culture, by improving awareness and understanding of the importance of health and safety by all those associated with the College.
• Promulgate health and safety policies, procedures and guidance
• Promote best practice in health and safety
• Receive feedback on health and safety improvements, incidents, reports
• Provide accurate and timely health and safety management information.
• Champion health and safety initiatives and celebrate health and safety achievements.
23. New and revised policies and procedures, once approved by the Health and Safety Management Committee, are published on the College website and are promoted by poster campaigns, seminars, workshops and roadshows. General health and safety news items are circulated to the staff and students via a termly newsletter Health and Safety Matters. The Safety Forum (SHRUG), which meets on a termly basis and to which all College safety personnel are invited, is also a key means of communicating health and safety issues and sharing good practice. In addition, Departmental/ Divisional Safety Officers and Safety Co-ordinators have a crucial role in communicating and promoting a health and safety culture across the College. The Safety Department keeps a list of current College Safety Personnel.
24. As part of its promotion of a positive health and safety culture, the College has instituted an annual Provost’s Award for Excellence in Health and Safety, which is open to all staff below professorial level. The Award carries a prize of £2,000, together with up to two "Commendations for Health and Safety" of £500. The main criterion for the Award is that candidates must be able to demonstrate that they have made a major contribution to the management, development or practice of health and safety in the College during the previous academic year.
Ensuring Competence - Assessing Needs, Training and Review
25. Members of staff, students and contractors are individually responsible for taking all reasonable precautions to ensure their own health and safety and the health and safety of others who may be affected by their acts or omissions. This means that they must have, or acquire, the necessary skills, knowledge and understanding to make them competent in the health and safety aspects of their work or activities. Training is a major part of ensuring competency, and will include courses, instruction, mentoring and counselling. Individual training requirements will vary according to a person’s role and responsibilities. For example, the training requirements for those working in an office environment will be less than those working with hazardous substances or in confined spaces or other potentially dangerous locations.
26. Notwithstanding the above, line managers have a particular responsibility for the health and safety of the staff and students working for them. A line manager must therefore ensure that their staff and students receive adequate training and instruction to enable them to carry out their activities safely and to understand the associated control measures and what to do if these fail.
27. The College has a Training Matrix, which details the training requirements (both mandatory and advisory) for each job category. All staff at every level are required to attend a standard introduction to health and safety. Mandatory training requirements beyond this will depend on each individual’s specific role and responsibilities. To ensure that individuals receive the training relevant to them, their line manager must carry out a Training Needs Assessment based on the individual’s job description and specific responsibilities.
28. Although much training is carried out locally within Departments/ Divisions, the main health and safety training programme is provided by the Safety Department and a full list of courses is published on the LDC website. Departments/ Divisions must keep a record of the training given at a local level and the Safety Department also keeps training records for all of its courses.
29. As a person’s career progresses, his or her training needs will evolve. Similarly, as information and standards change, so competencies may need to be refreshed and updated. Line managers must therefore periodically review the individual training needs of all their staff using the Training Needs Assessment Form. This review should normally be completed as part of the annual Personal Review and Development Planning (PRDP) process.
Planning and implementation
30. In addition to the Health and Safety at Work etc. Act, there is much specific health and safety legislation with which the College must comply. The legislative requirements and how to meet them in the College context are detailed in the appropriate Codes of Practice and in Guidance Notes. A compliance register listing all current relevant legislation and the College’s available codes of practice and guidance notes is available on the Safety Department web site.
31. The Health and Safety Risk Management Policy is a key element of the College’s SMS. Risk Assessment methods are used to decide on priorities and to set objectives for eliminating hazards and reducing risks. Wherever possible, risks are eliminated through the selection and design of facilities, equipment and processes. Where risks cannot be completely eliminated, they are minimised by the use of physical controls, systems of work and/ or personal protective equipment.
32. Hazard Identification. The College has carried out a number of hazard surveys and information from these is held centrally by the Safety Department, and by the individual departments.
33. Risk Assessment. Risk assessment of health, safety and environmental hazards and the identification of the relevant control measures is a vital part of good business management. It is also a legal requirement for risk assessments to be carried out by those who control work. Each Department/ Division must identify the hazards associated with its activities, assess the risks arising from them, and identify and implement appropriate control measures where these risks are significant. These risk assessments must be recorded and must be reviewed in the event of significant change to the workplace and/ or the activity, following an accident or incident, or when new legislation, information or guidance on the hazard is published.
34. Risk Registers. Each Faculty and Department/ Division is required to keep a Health and Safety Risk Register, which details its significant risks and the control measures used to control them. The Safety Department maintains a College-level Health and Safety Risk Register, which is derived from the Faculty and Departmental/ Divisional Risk Registers and the results of its own hazard surveys.
Monitoring and reviewing performance
Setting Performance Standards
35. Heads of Department and line managers are responsible for ensuring that appropriate performance standards are set and enforced. Their Departmental/ Divisional Safety Officer will provide advice on the standards to be met and will also advise where these are not being met.
36. Where there is no existing College policy or guidance, the standards which Departments/ Divisions must follow are those defined by relevant legislation. If this does not exist, then the British Standard European Normal (BS EN) or an international equivalent standard must be followed. Wherever there is uncertainty, the Departmental/ Divisional Safety Officer, in consultation with the Safety Department, will advise on the appropriate standards to be followed.
37. Line managers must monitor the performance of the individuals for whom they are responsible and must assess whether or not they are competent to carry out the activity and to implement the associated control and emergency procedures.
38. The performance of equipment and control measures must also be monitored. In particular, systems such as fire alarms, oxygen depletion alarms and radiation monitors must be tested regularly and calibrated.
39. Line managers must conduct periodic inspections and audits to ascertain whether agreed control measures have been implemented and to ensure that safety procedures are being followed.
40. The reporting of accidents and near misses and the statistics drawn from them are essential to identify trends, monitor the effectiveness of remedial action and identify and promote best practice. Departments/ Divisions are responsible for investigating accidents and near misses arising from their activities, and may call upon the Safety Department to assist with their investigations. The College Accident Investigation Officer based in the Safety Department is responsible for the monitoring of accident and near miss reports.
41. Each Faculty, Department/ Division and Campus is required to provide an Annual Report on its activities, hazards and concerns as they relate to health and safety to a joint meeting the Health and Safety Management Committee and the Health and Safety Consultative Committee. After the meeting an Action Plan is prepared for the following year and progress in completing this is monitored by both Committees.
42. Every part of the SMS, policy, organisational arrangements, planning, monitoring, and review is subject to audit. The College has appointed a Safety Auditor, whose role is to identify shortcomings in the system as a whole, or in part, and to provide solutions wherever possible. In addition to the College Safety Auditor, every Departmental/ Divisional Safety Officer and Building Manager is also expected to audit their local safety arrangements.
43. The College is in the process of adopting the Universities’ Safety and Health Association’s system for auditing, which will allow the College’s performance to be benchmarked against that of comparable universities, as well as providing for internal benchmarking between Departments and Divisions.