hs/1 - robertson hs1- core... · hs/1 this document is our core health and safety procedural...

HS/1 This document is our core health and safety procedural document. It sets out the key processes to be followed and the documents required to be completed as part of our core health and safety related management processes. These may be supplemented either at site or regional level by additional requirements. Where direct entry forms are available within Conject these should be used to record information required on forms referenced within this document – it is recognised that the paper forms and electronic forms contain the same information and the company is promoting the move to electronic recording where possible. During the interval until all forms are updated, both paper and electronic versions will be deemed to satisfy the requirements of our management systems As a general rule - the only people authorised to provide a waiver to any requirement within this document are:

A Regional Managing Director;

The head of a business; (Where their job title doesn’t incorporate the term Managing Director)

The Managing Director Robertson Construction Group (Scotland);

The Managing Director Robertson Construction Group (England). Note – No member of the SHEQ team is authorised to provide a waiver to any of the requirements contained within HS-1.

In exceptional circumstances (e.g. emergency related situations) the most senior person on site is authorised to take any action deemed necessary to secure safety on site or to secure an accident / incident scene. As a general rule the most senior person on site at any time is the person responsible for health and safety at that time. Unless alternative, business specific, health and safety related procedures are in place (e.g. Robertson Timber Engineering factory, Building Services operations etc.) then where the procedures within this document refer to Robertson Construction Group they apply to all businesses within that group. Notes: 1. Robertson Construction Group businesses are autonomous businesses which are under the control of a Regional

Managing Director or a business head. 2. The management and reporting structure for emerging new regions or supplementary businesses will be specified within

local arrangements and communicated to those affected. 3. For simplicity within this document, unless otherwise stated, the term Regional Managing Director shall be used as a

designation for both Regional Managing Directors and heads of businesses – both carry direct responsibility for health and safety within businesses under their stewardship.

4. For ease of reading the following abbreviations are periodically used:

Robertson Construction Group = RCG

Robertson Group = RG

Regional Managing Director = RMD

Core Health and Safety Management Procedure (HS-1) _________________________________________________________________________

_____________________________________________________________________________________________________ HS/1 of 95 Rev 3 – April 2015

Chief Operating Officer = COO

Core Health and Safety Management Procedure (HS-1)

1.0 Contents HS/1 ................................................................................................................................................ 1 These may be supplemented either at site or regional level by additional requirements. ................. 1 Note – No member of the SHEQ team is authorised to provide a waiver to any of the requirements contained within HS-1. .................................................................................................................... 1 1.0Contents .................................................................................................................................... 3

1.1. ..........................................................................................................................................9 2.0INTRODUCTION...................................................................................................................... 10

2.1.Overview ......................................................................................................................... 10 2.2.Management Framework................................................................................................. 10

3.0OCCUPATIONAL HEALTH AND SAFETY POLICY .................................................................. 10 3.1.Overview ......................................................................................................................... 10 3.2.Policy .............................................................................................................................. 11

This policy statement shall be compliant with, and as appropriate supplement, RG requirements. 11 4.0PLANNING............................................................................................................................... 11

4.1.Overview ......................................................................................................................... 11 4.2.General Objectives and Programmes .............................................................................. 12

4.2.1.RCG SHE Business Plan..................................................................................... 12 The timetable for submission is to be based on that agreed between the parties. ......................... 12

4.2.2.Introduction to OHSMS and Management Arrangements - RCG Induction .......... 12 It shall be the responsibility of the person’s line manager to deliver this induction. ........................ 12 Attendance should be recorded on the prescribed Robertson Group HR Dept Induction Form. .... 12

4.3.Project Specific Planning ................................................................................................. 13 4.3.1.Overview ............................................................................................................. 13 4.3.2.Pre-construction Information ................................................................................ 13 4.3.3.Construction Phase Planning .............................................................................. 14

4.3.3.1.Project Notification to the SHEQ Department ......................................... 14 4.3.3.2.Project Notification to the Health and Safety Executive .......................... 14

No work shall be permitted on a construction project unless this notification has been made. ....... 14 4.3.3.3.Construction Phase Plan ....................................................................... 14

Overview ................................................................................................... 14 Preparation and Content ........................................................................... 14

Additional advice and guidance may be obtained from the SHEQ Department. ............................ 15 Development & Communication ................................................................ 15

The plan shall at all times be available for reference on site.......................................................... 15 4.3.3.4.Appointment of Competent Persons ...................................................... 15

The role of the "Appointed Person – Lifting Operations" will usually be fulfilled by a sub contractor.15 A ‘Slinger / Signaller’ may only act as ‘Crane Supervisor’ if they meet the criteria specified above.15

4.3.3.5.Delegation of Health and Safety Responsibilities ................................... 16 4.3.3.6.Disciplinary Procedures ......................................................................... 16

Robertson employees are subject to formal internal disciplinary procedures outwith this process. 16 The system shall be implemented at all RCG sites. ...................................................................... 16

Application of the Yellow / Red Card System............................................. 16 Appeals Procedure ................................................................................... 17

The individual will remain red carded until the appeal has been heard. ......................................... 17 Appeal Hearing ......................................................................................... 17 Implementation Process............................................................................ 18

Yellow Card ................................................................................................................................... 18 Red Card ...................................................................................................................................... 18 Upon issue of a red card the individual shall be stopped from working immediately. ..................... 18

Communication of Rules ........................................................................... 18 4.3.3.7.Unsafe Conditions or Working Practices ................................................ 19 4.3.3.8.Induction ................................................................................................ 19

Employers Briefing & Pre-induction Preparation ....................................... 19 Requirement, Scope and Record Keeping ................................................ 20


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Personnel working on ‘live’ areas .................................................................................................. 20 A record of this induction shall be maintained on Form HS/1-01 - Induction Record. ..................... 20 Personnel working within a Site Office .......................................................................................... 20 A record of this induction shall be maintained on Form HS/1-01 - Induction Record. ..................... 20 Personnel visiting ‘live’ areas ........................................................................................................ 20 No formal record of this briefing shall be required to be maintained. ............................................. 20 Delivery drivers accessing ‘live’ areas ........................................................................................... 20 No formal record of this briefing shall be required to be maintained. ............................................. 21 Personnel visiting the Site Office ................................................................................................... 21

Site Specific Induction ............................................................................... 21 Minimum Core Content ................................................................................................................. 21

4.3.3.9.Emergency Preparedness ..................................................................... 22 Overview ................................................................................................... 22 Emergency Action ..................................................................................... 22

4.3.3.10.Accident and Incident Notification, Investigation & Reporting ............... 23 RIDDOR Reportable Accidents and Incidents ............................................................................... 23 Notification & Reporting to the HSE .............................................................................................. 23 Investigation .................................................................................................................................. 24 Witness statements should be recorded using form HS/1-05E Witness Statement. ....................... 24 Reporting within RCG ................................................................................................................... 24

All Other Accidents & Incidents ................................................................. 24 Notification within RCG ................................................................................................................. 24 Investigation .................................................................................................................................. 25 Witness statements should be recorded using form HS/1-05E Witness Statement. ....................... 25 Reporting ...................................................................................................................................... 25

4.3.3.11.Provision of First Aid (For general guidance please refer to GE700 Section B05 – First Aid) ......................................................................................................... 26

First Aiders & Facilities .............................................................................. 26 At least one qualified first aider shall be available at workplaces during all hours of work. ............ 26 The appointed first aider(s) shall be suitably trained and hold a valid first aid certificate. .............. 26

Recording Accidents - Accident Book ........................................................ 26 Where the accident is recorded initially by RCG this shall be on the site BI 510 Accident Book. ... 27

4.3.3.12.Near Miss Reporting ............................................................................ 27 Near misses shall be reported to RCG on the form HS/1-05B – Near Miss Observation Report. .. 27

4.3.3.13.Temporary Works................................................................................. 28 Appointment of Temporary Works Co-ordinator......................................... 28 Design of Temporary Works ...................................................................... 29 Design Brief .............................................................................................. 29 A full example: TW/6050/22D .................................................................... 30 Design Check ........................................................................................... 30 Construction of Temporary Works ............................................................. 31 Examples of Temporary Works: ................................................................ 31

4.3.3.14.Scaffolding ........................................................................................... 33 Scaffolding Procedure ................................................................................................................... 33 Guidance ...................................................................................................................................... 33 Managing Scaffolding Flowchart ................................................................................................... 35

Introduction ............................................................................................... 36 Requirements ........................................................................................... 36

All scaffolding structures are required to be erected to a suitable design. ..................................... 36 Design ...................................................................................................... 37

All scaffolding structures are required to be erected to a suitable design. ..................................... 37 Hand-over Certificates .............................................................................. 37 Scaffold Inspections .................................................................................. 38

General Scaffolding....................................................................................................................... 38 Alloy Tower Scaffolding ................................................................................................................. 38


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These formal statutory inspections may be carried out by any competent person. ........................ 39 Scaffold Erection ....................................................................................... 39

General Scaffolding....................................................................................................................... 39 Alloy Tower Scaffolding ................................................................................................................. 40

Scaffold Access ........................................................................................ 40 Wherever reasonably practicable scaffold access should be by staircase rather than by ladder. ... 40

Loading Bay Platforms .............................................................................. 40 All loading bay platforms above ground level should be fitted with ‘up and over’ style gates. ........ 40

4.3.3.15.Excavations ......................................................................................... 40 Temporary Works design............................................................................................................... 40 Safe digging practice..................................................................................................................... 40 All such works should be managed under Form HS/1-14A - Permit to Work – Groundworks. ....... 40 Inspection & reporting ................................................................................................................... 41

4.3.3.16.Lifting Operations................................................................................. 41 Lift Plan ......................................................................................................................................... 41 Inspection and reporting ................................................................................................................ 41

4.3.3.17.Permits to Work ................................................................................... 42 4.3.3.18.Plant and Equipment ........................................................................... 42

Plant and equipment ..................................................................................................................... 42 Inspection and reporting ................................................................................................................ 43

4.3.3.19.Asbestos .............................................................................................. 43 4.3.3.20.Electrical Safety ................................................................................... 44

Electricity on Construction Sites .................................................................................................... 44 The term Low Voltage (LV) applies to all supplies up to 1,000v A.C. ............................................. 44 The term High Voltage (HV) applies to all supplies above 1,000V A.C. ......................................... 44

4.3.3.21.Portable Appliance Testing (PAT) ......................................................... 45 4.3.3.22.Health Screening and Health Surveillance ........................................... 46 4.3.3.23.Hand-arm Vibration (HAV) ................................................................... 46

Guidance .................................................................................................. 46 HAV Risk Assessment Flowchart .................................................................................................. 47

Hand-arm Vibration Prevention Programme .............................................. 48 Introduction ................................................................................................................................... 48

5.Employer’s responsibilities ............................................................................. 49 6.Hierarchy of control ........................................................................................ 50

General principles of prevention .................................................................................................... 50 The principles of prevention set out at Schedule 1 to the Management of Health and Safety at Work Regulations 1999 form the basis of our control strategy. These principles are reproduced below for clarity: ....................................................................... 50

Practical HAV hierarchy of control ................................................................................................. 50 In practical terms we must assess the HAV risks and take reasonably practicable steps to control those risks in line with the following hierarchical framework: .................. 50 Establish the need for the work to be undertaken and avoid wherever we reasonably can;50 Assess the risks associated with alternative means of undertaking the work and adopt the least risky option; ............................................................................................... 50 Wherever we reasonably can - avoid the need to use hand-held vibrating tools;50 Where they have to be used – use tools which will minimise individual exposure to complete the task; (See Note 1) ........................................................................ 50 Minimise the force required to use the tool by ensuring the equipment is well maintained and any tooling is sharp; .................................................................................... 51 Reduce the length of individual exposure through job rotation; .......................... 51 Educate those undertaking the work through the education strategy detailed below; ....... 51 Provide health surveillance to those identified as being at risk. (See Note 2) ... 51 Notes: ................................................................................................................ 51 1.Note that a tool with a lower vibration magnitude may take longer to complete the task than one with higher vibration magnitude which will facilitate doing the task much quicker.


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The key is to evaluate individual exposure for the task. This will form part of the risk assessment process. ......................................................................................... 51 2.RCG provide health surveillance to all operatives. Line managers should ensure that surveillance is being delivered. .......................................................................... 51 7.HAV risk assessment ...................................................................................... 51 When conducting a HAV risk assessment it is important that we consider both the needs of the individual sites and the wider needs of the business as a whole – both of which are inter-related. To facilitate easy management of the HAV risk at site level it is important that appropriate risk assessments are both conducted and stored on BIW / Conject for others to refer to and use as appropriate. The greater the databank of risk assessments we have in place the fewer we will have to undertake afresh in the future. ........ 51 HAV risk assessments have been, are being, and will be conducted to cover a range of work packages and specific activities. These have been, are being, and will be conducted whilst making reference to a number of different measurement tools and reference documents to determine the magnitude of the vibration. All risk assessment must however:............................................................................................................ 51 Contain specific reference to the source of the vibration magnitude data (m/s2 (A8) value) being used; (e.g. OPERC database, Hilti product selector, Speedy Hire vibration data sheet, Havmeter reading etc.) ........................................................................... 51 Be recorded on HS/1-17 HAV Risk Assessment Calculator & Guidance Notes; . 51 Where complete processes associated with a day’s work are being assessed (e.g. Erect partitions secure to concrete floor soffit and wall (drill fix) timber) then all tools associated with the process should be included and their respective partial exposures included. ..... 51 Where a risk assessment is being undertaken for use of a single tool which doesn’t give rise to exposures at or approaching the EAV then the risk assessment need not be formally recorded and uploaded to BIW / Conject. Simple reference to, and discussion of, the ready reckoner during the task briefing will be sufficient. ............................. 51 Where the use of a number of vibrating tools is required during the day then the cumulative vibration exposure needs to be determined. The risk assessment needs to be formally recorded where the cumulative vibration exposure is likely to approach or exceed the EAV or the activity is a common activity for which no formal risk assessment is available within the database of HAV risk assessments. .................................... 51 The formal risk assessment or the ready reckoner findings will need to be discussed, as appropriate, during the task briefing. ................................................................. 51 8.Information, instruction and training ................................................................ 51

Exposure points system and ready-reckoner................................................................................. 52 HSE Exposure Points Ready Reckoner ........................................................................................ 53 Guidance on use of the ready reckoner is provided below. ........................................................... 54

4.3.3.24.Noise ................................................................................................... 55 The Control of Noise at Work Regulations .................................................................................... 55 Noise levels - Action levels ............................................................................................................ 55 Noise levels - Action levels and Limit values ................................................................................. 56 Practical management of noise exposures .................................................................................... 56 Practical maintenance of hearing protection .................................................................................. 56

4.3.3.25.Tool Box Talks ...................................................................................... 57 4.3.3.26.Worker Involvement - Consultation Forums & Reporting of Safety Issues57 4.3.3.27.Notice Boards ...................................................................................... 58 4.3.3.28.Enforcing Authority Visits (i.e. HSE / EA / SEPA / Environmental Health)58 4.3.3.29.Personal Protective Equipment (PPE) ................................................. 58

A record of PPE issued shall be kept on form HS/1-23 Record of Issue of PPE. ........................... 58 4.3.3.30.Health and Safety Records .................................................................. 58

4.3.4.Selection and Management of Contractors, Designers & Suppliers ..................... 59 4.3.4.1.Overview ............................................................................................... 59 4.3.4.2.Assessment of Health and Safety Competence ..................................... 59

The above process reflects the approach required by CDM. ......................................................... 59


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4.3.4.3.Stage 1 Assessment – Health and safety considerations only ................ 59 Timescales within which to conduct a Health & Safety Competence Assessment ....... 60

4.3.4.4.Stage 2 Assessment – Health and safety considerations only ................ 61 4.3.5.Health and Safety File Information ....................................................................... 61

4.3.5.1.Overview ............................................................................................... 61 4.3.6.Requests for Information ..................................................................................... 62 4.3.7.Distribution of Information .................................................................................... 62

4.4.Safe Systems of Work (SSoW) ........................................................................................ 62 4.4.1.Overview ............................................................................................................. 62 4.4.2.Routine, Low Risk, Work Activities ....................................................................... 62 4.4.3.Activities Giving Rise to Significant Risk .............................................................. 63

The SSoW shall be determined by the organisation responsible for carrying out the work. ........... 63 The key RCG monitoring document is form HS/1-24A Safe System of Work Checklist. ................ 64

4.4.4.Risk Assessment (For general guidance please refer to GE700 Section A05 – Risk assessments & method statement) ............................................................................... 64 4.4.5.COSHH Assessment (For general guidance please refer to GE700 Section B07 – Control of Substances Hazardous to Health (COSHH)) ................................................ 65 4.4.6.Method Statements .............................................................................................. 66 4.4.7.Review of SSoW ................................................................................................. 67 4.4.8.Communication with the workforce ...................................................................... 67

4.5.Communication of General Health and Safety Information .............................................. 68 4.5.1.Overview ............................................................................................................. 68 4.5.2.Internal Communications ..................................................................................... 68 4.5.3.External Communications – Corporate Level ....................................................... 68 4.5.4.External Communications – Project Level ........................................................... 68 4.5.5.Management Information Systems ...................................................................... 69

Tasks allocated, and their status, can be monitored on-line within Conject. ................................... 69 4.6.Office Health and Safety .................................................................................................. 69

4.6.1.Overview ............................................................................................................. 69 4.6.2.Appointment of Competent Persons .................................................................... 69 4.6.3.Office Safety Plan ................................................................................................ 69 4.6.4.Delegation of Health and Safety Responsibilities ................................................. 70 4.6.5.Health and Safety Induction ................................................................................. 70

4.6.5.1.Personnel based at an office ................................................................. 70 Office Specific Induction - Minimum Core Content .................................... 70

A record of this induction shall be maintained on HS/1-01 - Induction Record. .............................. 70 Where appropriate guidance may be sought from the SHEQ Department. .................................... 70

4.6.5.2.Personnel Visiting an Office ................................................................... 70 4.6.6.Visual Display Unit (VDU) Assessments .............................................................. 70

4.6.6.1.Overview ............................................................................................... 71 A copy of the assessment shall be retained with the employees training records. ......................... 71

4.6.6.2.Eyesight Tests and Examinations .......................................................... 71 4.6.7.Portable Appliance Testing................................................................................... 71 4.6.8.Accident Reporting and First Aid .......................................................................... 72 4.6.9.Notice Boards ...................................................................................................... 72 4.6.10.Health and Safety Records ................................................................................ 72

4.7.Legal and Other Requirements ........................................................................................ 73 Compliance with legal and other requirements is monitored during inspections and audits. .......... 73 5.0IMPLEMENTATION AND OPERATION .................................................................................... 73

5.1.Overview ......................................................................................................................... 73 5.2.Individual Competence .................................................................................................... 73 5.3.Roles, Responsibilities & Resources ............................................................................... 74

5.3.1.RCG Board .......................................................................................................... 74 5.3.1.1.Collective Responsibilities ..................................................................... 74

Ensure a suitable Health and Safety Policy is in place for RCG. .................................................... 75


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Monitor health and safety performance both in general terms and in terms of specified KPI’s. ...... 75 5.3.1.2.Individual Responsibility ........................................................................ 75

Discharge specific duties set out within supporting documentation and their job description. ........ 75 5.3.2.RCG Managing Directors..................................................................................... 75 5.3.3.Regional Managing Directors .............................................................................. 76 5.3.4.Head of Department - SHEQ ............................................................................... 76

Delegated responsibility for health and safety within RCG. ............................................................ 76 5.3.5.Quality Managers ................................................................................................ 77

Delegated responsibility for health and safety within RCG. ............................................................ 77 5.3.6.Group SHE Manager ........................................................................................... 77

Delegated responsibility for health and safety within RCG. ............................................................ 77 5.3.7.SHE professionals providing services to RCG ..................................................... 78 5.3.8.Senior Managers ................................................................................................. 79

Delegated responsibility for health and safety at projects or workplaces under their control. ......... 79 5.3.9.Project / Site Managers ....................................................................................... 79

Delegated responsibility for health and safety during site operations. ........................................... 79 5.3.10.Site Supervisors ................................................................................................ 80 5.3.11.‘Appointed Person – Office Safety’ ..................................................................... 80

Delegated responsibility for office safety. ...................................................................................... 80 5.3.12.All Employees .................................................................................................... 80

6.0CHECKING AND CORRECTIVE ACTION................................................................................ 80 6.1.Overview ......................................................................................................................... 80 6.2.Performance Measurement ............................................................................................. 81

6.2.1.Measurement of Health and Safety Performance & OHSMS Compliance ........... 81 Scores allocated shall be at the sole discretion of the person undertaking the inspection. ............ 81

6.2.2.Measurement of Exposure to a Hazardous Substance ........................................ 82 6.3.Performance Monitoring .................................................................................................. 82

Performance monitoring is undertaken both formally and informally. ............................................. 82 6.3.1.Inspection and audits by SHE professionals ........................................................ 82

Visits by SHE professionals may be for the purposes of either inspection or audit. ....................... 82 6.3.1.1.Inspection .............................................................................................. 82 6.3.1.2.Audit ...................................................................................................... 83

6.3.2.Inspections by regional directors and senior managers ....................................... 83 Visits by regional directors and senior managers shall be for the purpose of inspection. ............... 83

6.3.3.Inspections by site management ......................................................................... 83 Arrangements for the annual, strategic level, performance review is contained at Section 6. ........ 84

6.3.4.Protocols surrounding monitoring activities .......................................................... 84 6.3.4.1.Inspections ............................................................................................ 84 6.3.4.2.Audits .................................................................................................... 84

Overview ................................................................................................... 84 Audit visits shall be announced in advance and follow the protocols set out below. ...................... 85

Audit Protocol ........................................................................................... 85 6.3.4.3.Non-Conformances ............................................................................... 85

NCR - Major .............................................................................................. 85 NCR - Minor .............................................................................................. 86 OFI ........................................................................................................... 86

Where an OFI is issued by an inspector or auditor - detailed guidance shall accompany it. .......... 86 6.3.4.4.Close-out of NCR’s & OFI’s ................................................................... 86

6.4.Control ............................................................................................................................ 87 Where appropriate RCG shall exercise control through use of the disciplinary system. ................. 87 7.0MANAGEMENT REVIEW ........................................................................................................ 87

7.1.Overview ......................................................................................................................... 87 7.2.Management review ........................................................................................................ 88

On-going review of SHE matters shall be maintained through the Directors SHE Forum. ............. 88 7.3.Monthly Reports .............................................................................................................. 88


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The report shall be submitted within 3 working days of the start of the next reporting period. ........ 88 7.4.Annual Reports ............................................................................................................... 89 7.5.Continuous Improvement ................................................................................................ 89 7.6.Review of Legislative Requirements & Good Practice ..................................................... 89 7.7.Change Management ...................................................................................................... 90

7.7.1.Overview ............................................................................................................. 90 7.7.2.Stage 1 – First Draft ............................................................................................. 90 7.7.3.Stage 2 – Second Draft ........................................................................................ 91 7.7.4.Implementation within OHSMS ............................................................................ 91

8.0DOCUMENTATION .................................................................................................................. 92 8.1.Overview ......................................................................................................................... 92 8.2.Forms, Supplementary Procedures, Documents & Guidance .......................................... 92

8.2.1.Procedures within the Occupational Health and Safety Management System (OHSMS)92 The following are the procedures within the OHSMS. ................................................................... 92

8.2.2.Documents & Template Forms within the Occupational Health and Safety Management System ......................................................................................................................... 92 8.2.3.Robertson Guidance Notes ................................................................................. 95 8.2.4.Robertson Group documents ............................................................................... 96 8.2.5.External documents ............................................................................................. 96

1.1.


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2.0 INTRODUCTION 2.1. Overview This core procedure sets out the framework and processes to be followed during the management of health and safety at RCG workplaces. The document is aimed at facilitating identification and control of occupational health and safety risk, and continuous improvement in our occupational health and safety performance. The requirements apply to construction sites, offices and other workplaces for which RCG are responsible. 2.2. Management Framework The basic framework provides for management of:

Occupational Health and Safety Policy;

Planning;

Implementation and operation;

Checking and corrective action;

Management review. Requirements and processes to secure efficient application of the framework are detailed under each separate topic heading. Requirements and processes contained within this procedure, and health and safety requirements within the wider management system, should be followed in all circumstances except where one of the following personnel provides written authorisation to deviate from them:

A Regional Managing Director;

The Managing Director Robertson Construction Group (Scotland);

The Managing Director Robertson Construction Group (England).

Written authorisation may be in the form of an email. Where an email is used no signature is required – however the email must originate from the relevant email account. 3.0 OCCUPATIONAL HEALTH AND SAFETY POLICY 3.1. Overview The objective of policy development is to provide clear direction to the organisation and its employees. As an employer of 5 or more people RCG is required to publish its general policy with respect to the health and safety at work of its employees and the organisation and arrangements in place for carrying out that policy.

This document, in conjunction with other documents within our Occupational Health and Management System (OHSMS), helps us meet this requirement.

The RCG general policy with respect to health and safety is required to meet any standards and requirements specified by RG.


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RCG requirements are stated in the RCG Health & Safety Policy Statement and specific details of how the policy commitments are delivered are contained within the RCG Health and Safety Policy, Organisation and Arrangements document HS/2. Development and publication of the RCG Health & Safety Policy Statement is the responsibility of the RCG Board. RCG, and its associated companies, may adopt supplementary policies in relation to specific health or safety related topics. Formal policy statements are not required to be produced in such circumstances. 3.2. Policy The RCG Managing Director (Scotland) and RCG Managing Director (England) shall sign the Health & Safety Policy Statement on behalf of the RCG Board. This policy statement shall be compliant with, and as appropriate supplement, RG requirements. This policy statement shall be issued in accordance with business planning procedures and shall be reviewed as part of the management review process. 4.0 PLANNING

4.1. Overview Adequate planning of, and for, work activities lies at the heart of good health and safety management. Through good planning appropriate control measures may be identified and suitable safeguards implemented. To this end RCG shall plan for activities taking into account the following:

General objectives & programmes. o RCG SHE Business Plan. o Introduction to OHSMS and management arrangements – RCG Induction.

Project specific planning. o Pre-construction Information. o Construction phase planning. o Selection and management of contractors, designers and suppliers. o Health and Safety File information.

Safe systems of work. (SSoW) o Risk assessment o Method statements o Review of SSoW. o Communication with the workforce.

Communication of general health and safety information. o Internal communications o External communications – Corporate level o External communications – Project level o Management information systems.

Office health and safety.

Legal and other requirements.


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Responsibility for ensuring the above plans are implemented shall be in accordance with individual roles and responsibilities identified within this document, or delegated elsewhere within our management arrangements. 4.2. General Objectives and Programmes 4.2.1. RCG SHE Business Plan A Divisional Health and Safety Business Plan shall be prepared annually by the SHE professional with lead responsibility for RCG in consultation with the RCG Managing Director (Scotland) and RCG Managing Director (England). The timetable for submission is to be based on that agreed between the parties. Approval of the Plan shall be the means by which the RCG Board approve the health and safety strategy for the period of the Plan, and confirm that appropriate resources to meet its requirements will be available. The Plan shall take account of:

Results of management reviews;

Relevant reports and statistical information from the previous year;

Areas of interest publicised by the HSE. It shall include:

Health and safety Key Performance Indicators (KPI's);

Health and safety objectives and targets;

Reporting periods;

Personnel with individual reporting responsibilities;

A schedule of the Directors SHE forum meetings. 4.2.2. Introduction to OHSMS and Management Arrangements - RCG Induction All RCG employees shall be provided with a basic induction to the Robertson Group in line with Robertson Group Human Resources Department requirements. This will be supplemented, within the first two weeks of employment, by a SHE Induction which will provide an introduction to OHSMS and the associated supporting management arrangements. The SHE Induction shall consist of:

Watching the RCG Health and Safety DVD;

Listening to ‘Health and safety law – What you should know’ (MP3 soundfile); Discussion of the DSE information provided in the RCG Induction Pack. (DSE Users only)

A basic introduction to the OHSMS on Conject. It shall be the responsibility of the person’s line manager to deliver this induction. Appropriate refresher or update training should be provided whenever there has been a significant change to the management system or the associated arrangements. Attendance should be recorded on the prescribed Robertson Group HR Dept Induction Form.

http://www.hse.gov.uk/pubns/talkingleaflets/law.htm


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4.3. Project Specific Planning 4.3.1. Overview Statutory requirements for health and safety planning in relation to construction projects are encompassed within the Construction (Design & Management) Regulations. Three principal designations of information / documentation are identified as being required to ensure adequate planning takes place.

Pre-construction information;

Construction Phase Plan;

Health and Safety File.

The main purpose of the ‘Pre-Construction Information’ is to make plain health, safety and environmental hazards and risks, and other critical factors, specific to the project. Its provision is designed to allow us take these factors into account during the negotiation or tendering process when preparing proposals for managing the work activities. Where one is available, the ‘Health and Safety File’ is a significant element of the ‘Pre-construction Information’. The ‘Construction Phase Plan’ is our project management tool and provides a structured, comprehensive, framework within which to manage the project. A ‘Health and Safety File’ must be prepared in relation to all new structures completed and is aimed at helping others plan future operations, maintenance, construction or demolition works so that they may be undertaken safely. Where one is available for existing structures it provides important information and should be included in the ‘Pre-construction Information’. Head, Regional and other office based planning is addressed through the preparation of a building manual and ancillary documentation. 4.3.2. Pre-construction Information Where more than one contractor will be working on the project, the client must appoint a principal designer and principal contractor in writing. Only the client may make these appointments and it must be done as soon as practicable after initial design work or other preparation for construction work has begun. The client has responsibilities to ensure that pre-construction information in respect of a project is provided to help with design and construction planning. This must be done in sufficient time to allow proper planning of construction works and the deployment of adequate resources to undertake any proposed works safely. For project with more than one contractor, the principal designer will assist the client in this duty. On receipt of ‘Pre-Construction Information’ the senior operational manager should ensure it is copied to the relevant Bid Manager - to help inform the bid stage risk assessment process. Where input is requested from the SHEQ Department in relation to consideration of hazards, risks and control measures which may be necessary - and for consideration of potential competency / resource requirements - the senior operational manager should provide the ‘Pre-Construction Information’ to the SHEQ Department in sufficient time for a SHE professional to contribute. Relevant pre-construction information shall be passed to our sub-contractors as soon as practicable during the enquiry stage to allow them to adequately plan and price for potential works.


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‘Pre-construction information’ is specified within industry and HSE legal guidance on CDM and shall include information on:

Planning and management of the project

Health and safety hazards, including design and construction hazards and how they will be addressed; and

Information in any existing health and safety file. Appendix 2 of the HSE’s legal guidance on CDM details specific documents and information associated within the above which, where relevant, should be included. Reference should be made to this document when considering the appropriateness of information provided. The requirements of CDM apply whether or not the project is notifiable. 4.3.3. Construction Phase Planning 4.3.3.1. Project Notification to the SHEQ Department Upon contract award the RCG ‘Appointed Person – Site Safety’ shall ensure that the SHEQ Department are notified - in order to initiate the SHE monitoring and reporting role undertaken by the SHEQ Department. 4.3.3.2. Project Notification to the Health and Safety Executive Where the construction project is notifiable, the client must submit the notification to the relevant enforcing authority, on Form F10, as soon as practicable before the construction phase begins. The client can request that someone else do this on their behalf. No work shall be permitted on a construction project unless this notification has been made. A copy of the notification shall be prominently displayed on the site safety notice board. The client can arrange this themselves, or ask the principal contractor or contractor to do so. 4.3.3.3. Construction Phase Plan Overview The Construction (Design and Management) Regulations (CDM) require a Construction Phase Plan to be prepared for all construction projects and this shall be carried out by RCG. This Plan is the core reference document in relation to the management of site-wide elements on the project. It is required to ensure site-wide elements are adequately planned for and managed. Preparation and Content It shall be the responsibility of the ‘Appointed Person – Site Safety’ to ensure that a suitable Construction Phase Health and Safety Plan (CPHSP) is prepared using the Construction Phase Plan template (Form HS/3) prior to commencement of work activities on site. No significant alteration to the Construction Phase Plan template (Form HS/3) should be made - with the core structure and format being retained. Additions to the template plan are permitted but no sections may be deleted. Where sections are not relevant or not applicable then those sections should be marked accordingly. Appendix 2 of the HSE’s legal guidance on CDM contains guidance on the content of the CPHSP. Reference should be made to this document when preparing the plan.


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Additional advice and guidance may be obtained from the SHEQ Department. Development & Communication The CPP is a ‘live’ document which requires to be updated and developed throughout the construction phase of the project. It shall be the responsibility of the ‘Appointed Person – Site Safety’ to ensure that the Plan is appropriately developed in discussion with, and communicated to, contractors affected by it. The plan shall at all times be available for reference on site. 4.3.3.4. Appointment of Competent Persons The Regional Managing Director shall appoint a suitably experienced and competent RCG employee to each work place to be responsible for the overall implementation of health and safety management. This will normally be a Site Manager or a Project Manager – and the designation will be specified within the CPP. The appointment shall be confirmed in writing by the Regional Managing Director on Form HS/1-02A ‘Appointed Person – Site Safety’. The competence of personnel shall be determined on the basis of knowledge, experience and training. In the event that cranage is to be employed on site, the ‘Appointed Person – Site Safety’ shall ensure that a suitably trained and competent person is appointed as the ‘Appointed Person – Lifting Operations’. The ‘Appointed Person – Lifting Operations’ shall be responsible for the overall implementation of procedures governing lifting operations under their jurisdiction. The role of the "Appointed Person – Lifting Operations" will usually be fulfilled by a sub contractor. Where RCG is in charge of crane operations the ‘Appointed Person – Site Safety’ shall appoint an ‘Appointed Person – Lifting Operations’ on Form HS/1-02B to plan the lifting operations and ensure a suitably qualified RCG employee acts as Crane Supervisor. Anyone fulfilling the role of ‘Appointed Person – Lifting Operations’ shall have undergone a course of instruction and training provided by an approved training organisation to comply with the requirements of BS7121 or LOLER 1998 and have been issued a certificate indicating they are competent as an "Appointed Person". The ‘Appointed Person – Lifting Operations’ does not have to be present on site but must plan and organise the lifting operations. They may delegate duties, but not their responsibilities, to others. The ‘Appointed Person – Lifting Operations’ may act, if they are present during the lifting operations, as the Crane Supervisor. Note - The Crane Supervisor is sometimes referred to as the Lift Supervisor. The ‘Crane Supervisor’ must be present to supervise all lifting activities. Anyone fulfilling the role of ‘Crane Supervisor’ shall have undergone a course of instruction and training provided by an approved training organisation to comply with the requirements of BS7121 or LOLER 1998 and have been issued a certificate indicating they are competent as a ‘Crane Supervisor’. A ‘Slinger / Signaller’ may only act as ‘Crane Supervisor’ if they meet the criteria specified above. Additional minimum competence requirements are specified within Robertson Guidance Note 7 ‘Lifting Operations – Cranes’.


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4.3.3.5. Delegation of Health and Safety Responsibilities

The RCG employee designated as having overall responsibility for health and safety on site may delegate health and safety responsibilities to competent members of the site team. This shall be recorded within the staff responsibilities chart which forms part of the Construction Phase Plan. The competence of personnel shall be determined on the basis of knowledge, experience and training. 4.3.3.6. Disciplinary Procedures

RCG operate a yellow & red card disciplinary system to help secure compliance with legislative requirements, general construction site rules and agreed safe systems of work. Yellow & red cards may be issued by any member of RCG’s supervisory or management teams and will follow the implementation process detailed below. The system applies to non-Robertson employees only. For the purposes of this section of HS/1, 714 and Agency personnel should be treated as non-Robertson employees. Robertson employees are subject to formal internal disciplinary procedures outwith this process. The system shall be implemented at all RCG sites. Application of the Yellow / Red Card System A Yellow Card may be issued for:

Breaches of site rules;

A failure to follow prescribed safe systems of work; or

General unsafe behaviours, and shall be valid for the duration of the project upon which it was issued. Where a yellow card is to be issued consideration should be given to the role of the supervisor for the works - and whether they have adequately discharged their responsibilities. A red card may be issued for:

A failure to comply with a requirement associated with a previously issued yellow card;

A repeat of the original yellow card offence;

A second yellow card offence; or

An individual placing themselves or others at immediate or wholly unacceptable risk, and shall be valid for the duration of the project upon which it was issued - unless an Action Plan is agreed with RCG site management, and implemented, to secure (i) improved understanding by the personnel involved - of risk management and the importance of following safe working practices; (ii) buy-in to delivering a change in behaviour; and (iii) a positive attitude to management of health and safety. Where a red card is to be issued consideration should be given to the role of the supervisor for the works - and whether they have adequately discharged their responsibilities. Any person in receipt of a red card can appeal against its application in the manner prescribed below.


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Where a red card has been issued, is not challenged, and no Action Plan implemented to facilitate the recipient being permitted back onto site – the issue of the red card will render the recipient banned from working on any RCG site for a period of 6 months. It shall be the responsibility of that persons’ employer to ensure that the recipient of a red card is not sent to an RCG site within that period. Where they are found to have done so the ‘Appointed Person – Site Safety’ for the site on which the red card recipient has been found to have been working shall notify the Regional Managing Director. The Regional Managing Director shall ensure a meeting is held with senior management of the contractor involved and thereafter direct whatever steps are deemed appropriate in the circumstances to be undertaken. Appeals Procedure An individual may choose to appeal against the issuing of a red card. The grounds for appeal are:

Against the facts; or

Against the decision. The individual must lodge an appeal, in writing, to the relevant RCG site manager, within 2 working days of the red card being issued. The appeal shall be heard by the next higher level of management not previously connected with the case:

Within 5 working days of the appeal being lodged; or

At a later date by agreement. The individual will remain red carded until the appeal has been heard. The manager hearing the appeal shall inform the individual of the arrangements for the hearing (e.g. date, time, location, who will be present and their right of accompaniment) and ensure any relevant records are available and reviewed prior to the hearing. Appeal Hearing The manager hearing the appeal shall determine whether the appellant is appealing on valid grounds. The manager hearing the appeal shall listen to the appellants evidence and make the final determination re outcome. Where new evidence arises during the appeal the appellant shall be given the opportunity to comment on that evidence before it can be taken into account by the manager hearing the appeal. The manager hearing the appeal may adjourn the hearing to investigate or consider any new evidence or points raised. The manager hearing the appeal shall confirm in writing the outcome of the appeal. Three options are available:

Uphold the original decision;

Reduce the severity of the original decision; or

Overturn the previous decision.


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Implementation Process Yellow Card Upon verbally advising an individual of them having committed a yellow card offence, a yellow card shall be issued, in writing, on HS/1-03A Yellow Card issue form. The person issuing the yellow card shall immediately inform that person, and their direct supervisor, that they shall both attend the RCG site induction the following morning. They shall also inform them that prior to attending that induction the supervisor shall induct and re-brief the offender in their own procedures and agreed Safe System of Work. The person issuing the yellow card shall inform the RCG ‘Appointed Person – Site Safety’ as soon as is practicable – and in sufficient time for them to comply with their responsibilities under this procedure – with details of the circumstances leading to the issue of the card. The RCG ‘Appointed Person – Site Safety’ shall then ensure that within 1 working day following the issue of the Card:

HS/1-03B Yellow Card - Letter to employer is completed and given or posted to the individual concerned;

A copy of HS/1-03B Yellow Card - Letter to employer is forwarded to the person’s employer;

A copy of HS/1-03B Yellow Card - Letter to employer and HS/1-03A Yellow Card issue form are retained within the site files on Conject;

The details surrounding the issue of the Yellow Card are directly entered into the relevant on-line Form within Conject.

Red Card Upon verbally advising an individual that they have committed a red card offence, a red card shall be issued, in writing, on HS/1-04A Red Card issue form. Upon issue of a red card the individual shall be stopped from working immediately. The person issuing the red card shall immediately inform the RCG ‘Appointed Person – Site Safety’ of the issue of the card and the circumstances leading to it. The RCG ‘Appointed Person – Site Safety’ shall then ensure that within 1 working day following the issue of the card:

HS/1-04B Red Card - Letter to employer is completed and given or posted to the individual concerned;

A copy of HS/1-04B Red Card - Letter to employer is forwarded to the person’s employer;

A copy of HS/1-04B Red Card - Letter to employer and HS/1-04A Red Card issue form are retained within the site files on Conject;

The details surrounding the issue of the Red Card are directly entered into the relevant on-line Form within Conject.

Communication of Rules


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The core elements of the RCG disciplinary procedure shall be communicated to contractor’s representatives and/or their personnel:

Pre contract award;

During pre-start meetings;

During site induction.

4.3.3.7. Unsafe Conditions or Working Practices

All personnel on site are empowered to request that work practices they consider to be being carried out in an unsafe manner are ceased. That request shall be made to the person undertaking the work. They are similarly empowered to highlight conditions they consider to be unsafe with any person who they consider may be either affected by the condition - or who has influence over making it safe. Where they believe that the matter is either of a particularly serious nature, or is not being addressed by those responsible, they may, under the Site Rules, formally raise the matter with RCG management so that formal action may be considered. RCG supervisors and members of the management team shall, where they encounter unsafe work practices or unsafe work conditions, verbally instruct those works to be ceased or the unsafe condition to be made good. Where they deem a matter to be particularly serious the RCG ‘Appointed Person – Site Safety’ may formalise that instruction, in writing, to the contractor involved. Upon receipt of a written notification the contractor shall remedy any shortcoming, without delay, to the satisfaction of the RCG ‘Appointed Person – Site Safety’. The RCG ‘Appointed Person – Site Safety’ shall ensure:

That appropriate remedial actions have been taken;

A copy of the formal written notification is loaded onto Conject within 1 working day of it having been issued.

4.3.3.8. Induction

Employers Briefing & Pre-induction Preparation Prior to presenting an employee for the RCG Site Induction the employer shall ensure that:

The employee has been inducted under the employers’ own site induction process;

The employee has been briefed in relation to the hazards, risks, control measures, and supervisory structure related to proposed work activities;

The employee understands that briefing;

The employee has the necessary minimum training / certification as required by RCG;

Copies of all relevant training certificates / cards are prepared for presentation to RCG;

A suitable translator(s) is available, as appropriate, to translate the RCG induction for employees who do not speak fluent enough English to understand the RCG induction;

Where employees do not speak fluent enough English to effectively communicate with others on site - that arrangements have been made for a suitable translator(s) to be available on site at all times that works are to be undertaken by the employer, to ensure adequate communication between RCG personnel and the employers’ workforce.


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Note: Where Robertson Construction Group employs personnel to work on the site the same requirements shall apply to those personnel as to the employees of other contractors.

Requirement, Scope and Record Keeping All personnel working on, visiting, or delivering to an RCG project shall undergo a health and safety induction in line with the following prior to entry to any ‘live’ area of a site: Personnel working on ‘live’ areas Where personnel are at any time to be working on a ‘live’ area of a construction site the Health and Safety Induction shall consist of:

Core section of the RCG Health and Safety DVD;

Site Specific Induction. (see Minimum Core Content below) A record of this induction shall be maintained on Form HS/1-01 - Induction Record. Personnel working within a Site Office Where personnel are to be working within a site office only, the Health and Safety Induction shall consist of a site specific Office Induction. A record of this induction shall be maintained on Form HS/1-01 - Induction Record. Personnel visiting ‘live’ areas Where personnel are visiting the ‘live’ part of a construction site the Health and Safety Induction shall consist of a briefing on:

Personal Protective Equipment (PPE) requirements;

Any restrictions on access or movement applicable to the visitor;

Any high risk activities ongoing in the areas to be visited – including any control measures to be adopted by the visitor; (e.g. use of eye or hearing protection)

Emergency arrangements and muster points. Visitors to a ‘live’ area of a site shall at all times be accompanied by someone who has undergone a full site induction. That person is responsible for ensuring that the visitor has been briefed in line with the above. No formal record of this briefing shall be required to be maintained. Delivery drivers accessing ‘live’ areas Where delivery drivers etc. bring their vehicle onto the ‘live’ part of a construction site the Health and Safety Induction shall consist of a briefing on:

Personal Protective Equipment (PPE) requirements;

Traffic management arrangements;

Rules in relation to them leaving their vehicle – including any restrictions on access to areas or movements away from their vehicle;

Emergency arrangements and muster points. This information shall be provided in the form of a Notice which shall be either:

Presented to the driver on their first visit to the site and thereafter once every time a delivery is made after changes have been made to these arrangements; or

Posted at the entry to the site.


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No formal record of this briefing shall be required to be maintained. Personnel visiting the Site Office All personnel visiting the site offices shall be required to read the core Office Induction Notice at reception and sign the Visitors Book to acknowledge they have read it. Whilst a visitor is within the office area the person hosting them shall ensure that they are escorted to safety in the event of an emergency. Site Specific Induction Minimum Core Content This element of the site health and safety induction process shall supplement the general content detailed above for those working on ‘live’ areas of a RCG site. The ‘Appointed Person – Site Safety’ shall ensure that the scope of this section of the induction covers all the topics detailed below plus any topics that are additionally relevant to the project or work environment. Where required - guidance may be sought from the SHEQ Department. Where practical - site specific inductions will include, as part of the familiarisation process, a site walk-round. Matters to be included in this induction shall include, but not necessarily be limited to, the following:

Project description - brief overview of project including client, scope of project, stage of works and programme;

Client requirements and restrictions - delivery hours, restricted areas, Client Permit requirements etc.;

Management team - key members of the site management team;

Intervention strategy – what is expected in terms of intervention re unsafe acts, unsafe conditions & safety non compliances;

Communication with others – behaviours expected when intervening, treating people with respect and dignity, avoidance of whistling & calling to members of the public;

Consultation with workforce - safety representatives, safety forums & meetings;

Occupational health hazards - main occupational health hazards present and any self-assessment questionnaires available;

Medical conditions - conditions inductees wish to make known to First Aiders, prescribed medication etc.;

Robertson Group’s Substance Abuse Policy and arrangements for “random” and “with cause” alcohol and drug testing;

Non-standard hazards on site - contaminated land, asbestos, high voltage cables, high pressure gas mains, work over water, etc;

Arrangements for reporting accidents and incidents - all accidents and incidents to be reported to RCG immediately, early investigation of incidents critical to avoid recurrence;

Waste management & housekeeping arrangements - skip & segregation arrangements;

Robertson Guidance Notes – status and key ones pertinent to works;

Site rules;

Site walk round - this is designed to facilitate familiarisation with: o Site accommodation - toilet, welfare, drying room; o Traffic management arrangements - pedestrian routes, speed limits, traffic routes,

use of banksmen etc.; o First aid arrangements - First aid post, qualified First Aiders;


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o Current high risk activities; o Emergency arrangements - fire points, fire alarms, escape routes, muster points; o Restricted areas - details of client specified or task related restrictions on access; o Areas where supplementary PPE is required - typically hearing protection zones.

Where a site walk round is not undertaken details surrounding management of, or arrangements for, the above items shall be communicated by other suitable means as part of the site specific induction. The Site Rules shall be prepared by the ‘Appointed Person – Site Safety’ and incorporate, as a minimum, the requirements specified within the Construction Phase Plan. 4.3.3.9. Emergency Preparedness Overview The ‘Appointed Person – Site Safety’ is responsible for:

Assessing health & safety risks and environmental impacts for specific projects;

Implementing appropriate control measures;

Preparation of suitable emergency arrangements for the site – including the preparation of an Emergency Call-out Directory to cover health, safety and environmental emergencies;

o This shall include details of contacts numbers for: Our Insurers; Legal advice & instruction; Press queries, including the Crisis Communications Protocol.

Ensuring the above information is prominently displayed within the site office and readily available to anyone who may require the information.

The flow chart HS/1-05A - Incident Reporting Flowchart provides a step by step guide of the actions required in the event of an accident or incident occurring on site. The ‘Appointed Person’ may also arranged for “with cause” alcohol and drug testing by the appointed specialist organisation. Further details on this may be found in the Substance Abuse Policy, contained within the HR suite of policies. Emergency Action In the event of a serious accident or incident the immediate priorities shall be to:

Contact the appropriate emergency services;

Assess any residual danger to the injured person(s) and others, and take appropriate action;

Provide First Aid if safe to do so;

Prepare for the arrival of the emergency services;

Secure - where safe, practicable and appropriate to do so - the accident scene and any relevant physical evidence;

Photograph - where safe, practicable and appropriate to do so - the accident scene. Where the incident is within the RIDDOR defined category of reportable accidents or incidents, or is otherwise major in nature, the RCG employee in charge of the location at the time shall ensure the following personnel are immediately informed by telephone:

Regional MD;

Regional Operations Director;

Head of the SHEQ Department.


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That person should also consult HS/1-05A - Incident Reporting Flowchart to establish any additional contacts which may be required. Direction shall be provided by the Regional MD or other senior members of staff in relation to further notifications to be made. These will be dependent upon the seriousness of the incident and may include:

Our insurers;

A company lawyer;

Our Public Relations advisors – reference should be made to the Crisis Communications Protocol.

4.3.3.10. Accident and Incident Notification, Investigation & Reporting RIDDOR Reportable Accidents and Incidents Notification & Reporting to the HSE Certain accidents, incidents and cases of disease are notifiable and reportable to the Health and Safety Executive (HSE) under the Reporting of Injuries, Diseases & Dangerous Occurrences Regulations (RIDDOR). In the event of a RIDDOR reportable accident, involving death or injury to someone working on site, formal notification and reporting to the Health & Safety Executive shall be undertaken by the employer of that person. In the event of a RIDDOR reportable accident, involving death or injury to someone not working on site, formal notification and reporting to the Health & Safety Executive shall be undertaken by the person in control of the premises – usually the Principal Contractor … which will normally be RCG. In the event of a Dangerous Occurrence (as defined within the RIDDOR Regulations) formal notification and reporting to the Health & Safety Executive shall be undertaken as follows:

Gas pipeline - the pipeline owner; All others – the person in control of the premises. (usually the Principal Contractor, which will normally be

RCG.)

In the event of a reportable disease (as defined within the RIDDOR Regulations) formal notification to the Health & Safety Executive shall be undertaken by that person’s employer. In all cases notification and reporting shall be undertaken in accordance with the following criteria:

Death or ‘Non-fatal’ Injury (formerly known as ‘Major Injury’) – Notification immediately by quickest practicable means (phone) and formal on-line report within 10 days;

>7 Day Injury - Formal on-line report within 15 days;

Dangerous Occurrence – Notification immediately by quickest practicable means (phone) and formal on-line report within 10 days;

Notifiable Disease - Formal on-line report as soon as practicable. Providing notification to the HSE in terms of ‘Fatal’ accidents, ‘Non-fatal’ injuries and ‘Dangerous occurrences’ should be undertaken by the relevant party by calling the HSE Incident Contact Centre on 0845 300 9923 (opening hours Monday to Friday 8.30 am to 5 pm). Should the HSE Incident Contact Centre be closed the HSE duty officer should be contacted on 0151 922 9235 in the following circumstances only:

Following a work-related death;

Following a serious incident where there have been multiple casualties;

Following an incident which has caused major disruption such as evacuation of people, closure of roads, large numbers of people going to hospital etc.


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Unless otherwise directed by the Regional MD or the Head of the SHEQ Department - all on-line HSE reporting of RIDDOR accidents or incidents which require to be made by RCG should be undertaken by a member of the SHEQ Department. Investigation Where a fatality or other major incident has occurred, the Group SHE Manager shall ensure a suitable investigation team is established and shall either lead, or, as appropriate, provide direction to that investigation team. That investigation team may involve third parties – including representatives from our insurer, our lawyers and/or specialists. A SHE professional from within the SHEQ Department shall conduct an investigation into all RIDDOR reportable accidents or incidents. They shall visit site to begin their investigations as soon as practicable after they are notified of an accident or incident. This shall normally be within:

2 working days for a >7 Day Injury; and

1 working day for a ‘Fatal’ or ‘Non-fatal’ injury. Witness statements should be recorded using form HS/1-05E Witness Statement. Reporting within RCG Unless otherwise instructed by legal representatives in relation to an alternative approach - the SHE professional conducting the investigation shall prepare an Accident Report on Form HS/1-05D - Incident Report – SHE Professional in relation to all such accidents and incidents and distribute this to:

Regional MD;

Any other personnel prescribed within the relevant business’ management arrangements;

Head of the SHEQ Department. The Regional MD shall ensure the regional management team review the findings of the accident report and take whatever remedial actions are deemed appropriate. The SHEQ Department shall liaise with the Regional MD and senior management team responsible for the workplace and review the immediate, underlying and root causes to establish the suitability of management arrangements and procedures. The Head of the SHEQ Department shall ensure, where appropriate, that:

Significant learning points are disseminated to relevant parts of the Robertson Group;

Suitable amendments are made to management arrangements and procedures. All Other Accidents & Incidents The flow chart HS/1-05A - Incident Reporting Flowchart provides a step by step guide of the actions required in the event of an accident or incident occurring on site. Notification within RCG All accidents or incidents involving injury to a RCG employee, visitor or member of the public are required to be immediately notified to RCG site management. This notification may be made by anyone but should ideally be undertaken either by the injured person themselves, their supervisor, or, in the case of an injury related accident - the first aider treating the injury.


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All accidents or incidents involving personal injury to a sub contract employee are required to be reported immediately to that persons’ employer and to RCG. This notification may be made by anyone but should ideally be undertaken either by the injured person themselves, their supervisor, or, in the case of an injury related accident - the first aider treating the injury. All significant non RIDDOR reportable accidents and incidents shall be reported, by the quickest practicable means, (usually the telephone) to:

Regional MD;



Head of the SHEQ Department. Investigation The ‘Appointed Person – Site Safety’ shall ensure that all accidents and incidents are investigated by RCG. In the first instance it shall be the responsibility of the ‘Appointed Person – Site Safety’ to evaluate the significance of the circumstances surrounding and leading to the accident or incident and determine the extent of investigation required. Where they believe a significant investigation is required they shall contact the SHEQ Department and seek the services of a SHE professional. In all other circumstances they shall ensure the RCG site management team investigates the circumstances surrounding and leading to the accident or incident. Where the regional management team or the SHEQ Department consider that further, or a more comprehensive, investigation is required they may initiate one. For significant accidents and incidents involving contractors / subcontractors - those organisations shall be required to independently investigate the accident or incident and provide a factual report to RCG. Witness statements should be recorded using form HS/1-05E Witness Statement. Reporting The ‘Appointed Person – Site Safety’ shall ensure that a report is provided for all accidents and incidents:

Using the on-line reporting mechanism within Conject;

On Form HS/1-05C – Incident Report – Operations Team. The ‘Appointed Person – Site Safety’ shall ensure that Form HS/1-05C – Incident Report – Operations Team and any supplementary reports provided by contractors or subcontractors are distributed to:

Any personnel prescribed within the relevant business’ management arrangements as required to be in receipt of such a report – given the seriousness of the accident or incident;

Head of the SHEQ Department. Notwithstanding the above, where a SHE professional carries out a supplementary investigation, unless otherwise instructed by legal representatives in relation to an alternative approach - they shall prepare an Accident Report on Form HS/1-05D – Incident Report – SHE Professional and distribute this to:


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Regional MD;



Head of the SHEQ Department. The Regional MD shall ensure the regional management team review the findings of the accident report and take whatever remedial actions are deemed appropriate. The SHEQ Department shall, dependent upon the circumstances surrounding and leading to the accident or incident, liaise with the Regional MD and senior management team responsible for the workplace and review the immediate, underlying and root causes to establish the suitability of management arrangements and procedures. The Head of the SHEQ Department shall ensure, where appropriate, that:

Significant learning points are disseminated to relevant parts of the Robertson Group;

Suitable amendments are made to management arrangements and procedures.

4.3.3.11. Provision of First Aid (For general guidance please refer to GE700 Section B05 – First Aid)

First Aiders & Facilities It is the responsibility of every employer to ensure that they have adequate first aid provision available to their employees. The ‘Appointed Person – Site Safety’ shall be responsible for ensuring that there is adequate first aid provision available:

To RCG employees;

For the site as a whole. Where contractors or subcontractors are working on site they are responsible for ensuring either:

Direct first aid provision, via their own first aiders, for their own employees; or

First aid provision is being provided by others. (e.g. RCG) Where first aid is to be provided by RCG this must be agreed prior to a contractor commencing on site. At least one qualified first aider shall be available at workplaces during all hours of work. The appointed first aider(s) shall be suitably trained and hold a valid first aid certificate. Every first aider shall have access to a suitable, stocked, first aid box. The box shall be clearly marked with a white cross on a green background. The contents of the first aid box shall be appropriate for the number of personnel it is required to cover and the type of work being undertaken. The first aider shall check the contents of the box at regular intervals (every 3 months maximum) to ensure the stock level is adequate and in date. Recording Accidents - Accident Book Details of any treatment administered as a result of an injury are required to be recorded in an Accident Book (usually a BI 510 Accident Book.)

This is usually done either by the first aider themselves or someone else dealing with the accident. Details recorded must include:

http://mpower.millerextra.com/mpower/livelink.exe?func=ll&objid=5028921&objaction=open


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Date, time and place of the accident;

Name and job of the injured or ill person;

Details of the injury/illness and what first aid was given;

What happened to the person immediately afterwards (e.g. went back to work, went home, went to

hospital) Name and signature of the first aider or person dealing with the accident.

Where the accident is recorded initially by RCG this shall be on the site BI 510 Accident Book. Where the accident is initially recorded in a sub contractor’s Accident Book details should immediately be provided to RCG and a copy of their Accident Book entry provided. Where an accident is not immediately reported to RCG no entry shall be permitted in the RCG Accident Book by any RCG representative unless there are reasonable grounds to believe the accident happened on site. Where the RCG first aider or employee dealing with the incident does not believe there are reasonable grounds to believe the accident happened on site the injured person may, if they wish the injury recorded in the RCG Accident Book, make the appropriate entry themselves. Where this is the case the RCG first aider or employee dealing with the incident shall record on the individually numbered report sheet:

The reason why the injured person claims they failed to report the accident immediately after it occurred;

Any other information they feel to be relevant. (e.g. extent of injury inconsistent with the alleged accident or

the timeframe within which it is said to have occurred. Where it is not insensitive to do so – taking photographs of the injury may help corroborate an opinion.)

Note: Injuries requiring absence from work will normally be of the type the injured person will recognise as requiring treatment at the time it happened. There is little, if any, excuse for failing to report an injury when it happens – and only seeks to bring the legitimacy of the circumstances in which it was received into question.

The reporting of all injuries, however minor, is to be encouraged to allow:

Prompt, effective, treatment of the injury;

Appropriate referral for additional treatment as necessary;

Appropriate investigation of the accident & identification of any remedial measures required to avoid a recurrence;

Avoidance of any doubt about where, when and how the injury was sustained. A copy of the BI 510 entry, or equivalent, shall form an Appendix within the accident report Form HS/1-05C – Incident Report – Operations Team and Form HS/1-05D – Incident Report – SHE Professional. 4.3.3.12. Near Miss Reporting For the purposes of this procedure a ‘Near Miss’ is defined as any unplanned event that did not result in injury, illness, or damage – but had the potential to do so. The ‘Appointed Person – Site Safety’ shall ensure that an appropriate near miss reporting process is implemented on site – details of which shall be contained within the Construction Phase Plan. Near misses shall be reported to RCG on the form HS/1-05B – Near Miss Observation Report. The ‘Appointed Person – Site Safety’ shall ensure that:

Near miss reports are entered on Conject – and provided to: o The Regional MD;


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o The Regional Operations Director; o Any other personnel prescribed within the relevant business’ management

arrangements; o The Head of the SHEQ Department.

Near miss incidents are discussed at appropriate site meetings and forums;

Actions taken in respect of reported near miss incidents are effectively communicated to the workforce.

4.3.3.13. Temporary Works Temporary Works Co-ordination

Action

It is the policy of the Company to generally work in accordance with the recommendation in BS 5975:2008 and A1:2011 Code of Practice for Falsework. This applies both for falsework and for all other substantial temporary works. Temporary works will be managed following the flow chart HS/1-06. In particular, a Temporary Works Coordinator (TWC) will be appointed for each project. This appointment will be made by the Temporary Works Manager (TWM) (HS/1-02C Appointed Person – Temporary Works Manager) on review of the proposed TWC’s competence. The TWC will be resident on all major projects but not necessarily on minor contracts (i.e.less than £1m). Each Region should compile a Temporary Works – Work Experience Matrix (HS/1-07) and issue to the TWM for review.

ROM

TWM

ROM

Design and construction of temporary works is usually the contractual and legal responsibility of the Company as contractor. Many parties may become involved, and one of the key roles of the TWC is to co-ordinate their activities. The other key role is to be alert to potential errors on site.

Appointment of Temporary Works Co-ordinator

Action

Submit nominees for approval to Temporary Works Manager. The Operations Manager should ensure that the nominee has the following skills for that particular project:

Relevant Experience

Formal TWC Training

Competence & Authority to be effective

Professional Qualification is desirable.

ROM

TWC to be appointed in writing on HS/1-02D

TWM

Ensure TWC is available to attend training sessions

ROM

Arrange for suitable deputy to TWC when TWC is unavailable due to holidays, sickness etc.

ROM

The duties and responsibilities of the TWC are detailed in this section.


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On a larger project the TWC may require assistance from a Temporary Works Supervisor (TWS). Where this is the case TWS’s should be appointed. The TWS will be responsible to the TWC and will assist the TWC in the supervision of temporary works.

TWC

Design of Temporary Works

Action

At tender stage the Regional Managing Director / Regional Planner will pass over to the Estimator the Pre-Construction Schedule Of Temporary Works (HS/1-08) which will highlight the items relevant to the bid.

RMD / RP

Where temporary works will be required as identified in the Pre-construction Schedule of Temporary Works then a Temporary Works Designer should be appointed for design, independent checking or both.

TWC / PM / PS

For simple temporary works, design may be carried out by site based staff who can demonstrate competence. The design should however be checked independently.

TWC

Where outside parties are used, such as suppliers of proprietary equipment or subcontractors, ensure clear relationships and areas of responsibility.

TWC

Design Brief

Action

Ensure that the designer of temporary works is in possession of all relevant information. This may include programme limitations, access, materials preferences and re-use requirements, ground and groundwater services, adjacent structures, unusual loadings, imposed restrictions etc. Prepare and issue Contract Schedule of Temporary Works (HS/1-09).

TWC

Ensure that the designer is informed of changes and developments to this design brief.

TWC

Agree Contract schedule with TWD (Temporary Works Designer) at initial issue and thereafter when altered.

TWC

Prepare Schedule of Temporary Works - Specific Design (HS/1-10) requirements and issue to the TWD

TWC

Develop the design to eliminate or reduce the risk utilising a temporary works risk assessment.

TWD

Exceptional residual risks shall be highlighted on the drawing

TWD

Ensure that particular requirements such as sequence of erection, loading and subsequent dismantling are noted on the drawing.

TWD

Identify on the drawings any HOLD POINTS requiring issue of authorisation.

TWD

Drawings produced by the company for a project will be numbered as TWD /


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follows: All drawings to have the prefix TW/ The project contract number (e.g. /6050/) The unique number for the drawing (e.g./22) The revision letter (e.g. D) A full example: TW/6050/22D

TWC

Establish a document control system in accordance with Robertson Quality Procedures.

TWC

For large and complex temporary works, convene a meeting with the TWD to discuss the design and all pertinent implications. The Regional SHE Manager should be involved in any discussion where a scheme has an unusual safety risk.

TWD / TWC

Ensure the status of the Design is clear during correspondence

TWD

Design Check

Action

Prior to issuing ‘For Construction’ ensure that all designs are checked independently by a person suitably qualified to carry out such checks. The check may be carried out within or outside the TWD’s Department depending on the category.

TWC

If any amendments are required to the scheme following Construction issue, then item 1.4.10 regarding the requirements of this procedure must be followed prior to re-issue.

TWD

Send designs prepared on site or by outside proprietary suppliers to the TWD for checking prior to the works commencing.

TWC

Ensure that all drawings have been independently checked before construction.

TWC

Check that the temporary works design meets site requirements.

TWC

Where appropriate ensure that the design is made available to other interested parties (e.g. the designer of the permanent works).

TWC

Ensure TWD is advised of outside design responsibilities.

TWC

Send all designs prepared on site or by outside parties to the TWD for independent checking

TWC

Do not commence any temporary works scheme unless formal approval has been given by the TWD.

TWC

Construction of Temporary Works

Action

Ensure that those responsible for on-site supervision receive full details of the design, including any limitations associated with it.

TWC


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Check that materials and equipment are adequate for their purpose. Take particular care to inspect materials that have been previously used.

TWC

At all stages, check that work is being carried out as designed. Rectification is frequently difficult and expensive to carry out later.

TWC

Ensure that any alterations have been approved by the designer and correctly carried out.

TWC

For substantial temporary works, hold training sessions with relevant staff and operatives prior to commencement. Issue works procedures and ensure that all personnel area aware of methods to be adopted and likely problems to be encountered.

TWC

Establish HOLD POINTS requiring a temporary works authorisation before subsequent operations are undertaken. Form HS/1-11 should be issued where there is a requirement for an “Authorisation to Load” or “Authorisation to Strike” – both of which will apply to all falsework. Form HS/1-11 should also be used where there is a need for an “Authorisation to Proceed”. This will apply to key stages of construction of other substantial temporary works – and the requirement will be established in consultation with the Temporary Works Designer. Examples are given below.

TWC

Issue temporary works authorisation (HS/1-11) when appropriate.

TWC

Ensure that appropriate maintenance is carried out for the lifetime of the temporary works.

TWC

Do not commence any temporary works scheme unless formal approval has been given by the TWD.

TWC

If any scheme is amended, changed, or revoked ensure approval for the change is authorised by TWD

TWC

The TWC has the overall site authority to stop site operations with regards to temporary works.

TWC

Review and provide comment upon all method statements associated with Temporary Works and ensure that all relevant permit systems and conditions are adequately described including the naming of responsible persons associated with the competent management of the permit systems.

TWC

Examples of Temporary Works:

Simple and/or potentially low risk temporary works

Standard scaffold

Formwork less than 1.2m high

Hoarding and fencing up to 1.2m high

Simple propping schemes – 1 or 2 props


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Internal hoarding systems and temporary partitions not subject to wind loading

Shallow excavations less than 1.2m deep/high

More complex and/or potentially medium risk temporary works

Falsework up to 3m high

Formwork for columns and walls up to 3m high

More complex propping schemes – multiple props at single level

Needling of structures up to 2 storeys high

Excavations up to 3m deep/high

Safety net systems fixed to robust primary members

Hoarding and fencing up to 3m high

Simple designed scaffold

Temporary roofs

Complex and/or potentially high risk temporary works

Falsework and formwork over 3m high

Trenchless construction, including headings, thrust bores, mini tunnels

Working platforms for cranes and piling rigs

Tower crane bases

Façade retention schemes

Flying and raking shores

Complex propping schemes – multiple props and multiple levels

Needling of structures greater than 2 storeys high

Ground support schemes greater than 3m deep

Complex designed scaffold

Cofferdams

Bridge erection schemes

Jacking schemes

Complex structural steelwork and precast concrete erection schemes

Hoarding and fencing over 3m high

River Diversions

Anchorage & Thrust Blocks

Temporary bridges, jetties, platforms, piling frames.

Underpinning

Operations where there are specific interfaces with the sequence of construction (e.g. Dewatering, pre-stressing etc.)

Any adaption to permanent works for a temporary situation which has not been considered as part of the permanent works design (e.g. strengthened structural design, lifting bolts in precast concrete units etc.)

Key:

TWM

= Temporary Works Manager

TWD = Temporary Works Designer

TWC = Temporary Works Coordinator

TWS = Temporary Works Supervisor


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RMD = Regional Managing Director

ROM = Regional Operations Manager

RP = Regional Planner

PM = Project Manager

PS = Project Surveyor

4.3.3.14. Scaffolding Scaffolding Procedure Guidance

Structures incorporating scaffolding components are required to be: Erected by competent personnel; Note 1

Erected to an appropriate design; Note 2

Inspected by a competent person: Note 3

o Before first being brought into use; Note 4

o After any significant modification or alteration; Note 5

o After any adverse conditions or events which may have affected its integrity; Note 6

o At periods not exceeding 7 days.

Suitable emergency arrangements are also required to be made for the rescue of personnel during erection, alteration, dismantling or use of the scaffold.

The standards to be applied in terms of competence of erectors and inspectors are covered elsewhere within the OHSMS and are not reproduced here.

What constitutes an appropriate design is clarified within this procedure – however there may be situations which arise where it is not entirely clear to site teams what reasonably constitutes an appropriate design. In this situation guidance should be sought from the SHE team. All scaffold designs are Temporary Works Designs and should be managed under our Temporary Works procedure.

The key points to remember in relation to scaffolding design are that:

An appropriate design must always be provided;

A copy of this design must be available on site, at all times, for reference purposes;

This design must be referenced by our site team during pre-acceptance checks prior to acceptance of a hand-over certificate Note 7 by our site teams;

Any significant alteration to the scaffolding: o Will require a review of the appropriateness of the design; o May involve the production of new design documentation;

(i.e. Unless the design is in accordance with NASC Technical Guidance TG20 (tube and fitting scaffolds) or manufacturers' guidance (system scaffolds) then new design will be required)

o Will require provision of a new hand-over certificate.

Notes:

1. The industry and Robertson recognised training registration schemes for scaffolders are (i) CISRS - for standard scaffolds; and (ii) PASMA - for tower scaffolds. Where ‘system’ scaffolds are erected by CISRS scaffolders – they should have been additionally trained in that specific system scaffold. 2. A bespoke design incorporating (i) drawings/diagrams; (ii) calculations; (iii) tying configurations or other stability measures to be applied; (iv) safe operating parameters in terms of loadings; and (v) sequencing and methods to be adopted when erecting, dismantling or altering the scaffold - are required to be specified unless the design is a basic configuration described in recognised guidance. (i.e. NASC Technical Guidance TG20 for tube and fitting scaffolds; or manufacturers' guidance for system and tower scaffolds) Where a scaffolding contractor is describing the scaffold as a basic configuration in accordance with the above then the supporting documentation must support this position and be available on site for reference. 3. The industry and Robertson recognised training registration scheme for scaffold inspectors is the CISRS. 4. In line with NASC guidance the hand-over certificate can be accepted as the initial pre-use statutory inspection report. 5. A common sense approach should be taken when considering whether a modification or alteration to a scaffold is significant. Movement of handrails, hop-ups, brick guards etc which do not affect the existing configuration of the scaffold or its stability are not significant whereas the movement or reconfiguration of ties etc which might affect its structural stability, or the extension of the scaffold to incorporate an additional elevation, would be. 6. Adverse conditions include adverse weather conditions (e.g. high winds, extreme rainfall which might destabilise ground etc). Typical events which may affect its stability include collision damage, temporary overload of a platform etc.) 7. The hand-over certificate should refer to relevant drawings, permitted work platform loadings and any specific restrictions on use.


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Managing Scaffolding Flowchart

Work may involve work at height

Apply work at height hierarchy of control

Scaffolding required

Alloy Tower Scaffold

‘Tube & Fitting’ Scaffold

‘System’ Scaffold (e.g. kwikstage, haki, layher, cuplok etc).

Training & Competence Relevant CISRS card

required

Training & Competence Relevant CISRS card required - including special endorsement for specific ‘System’

scaffold to be erected.

Ensure compliance with RGN 4 – Alternatives to

ladders, traditional stepladders and tower

scaffolds

Robertson site management: Ensure statutory inspections are carried

out. Ensure independent inspections are

carried out on a weekly basis. Monitor scaffold integrity. Monitor that ‘Scafftags’ are in place and

signed off.

Training & Competence PASMA certificate required

to erect

Arrange appropriate scaffolding package taking into account training requirements

RAMS & appropriate scaffold design provided to TWC & site management

team

Note: The erection manual constitutes the design

for a basic configuration. Bespoke drawings are required for non-

basic configuration.

Erection manual constitutes design

Site management team review the RAMS

& TWC co-ordinates re the TW design

Erect to design and attach a ‘Scafftag’

Note: Trainee Scaffolder – No supervisory

capability & cannot work alone.

Basic Level 1 Scaffolder – No supervisory capability & cannot work alone.

Basic Level 2 Scaffolder – Can supervise scaffolding operations other than in relation to complex / designed scaffolds.

Advanced Scaffolder – Can supervise any scaffolding operations.

Scaffold: Erected by suitable level of CISRS

carded scaffolders. Erected to appropriate design. Scafftag(s) attached to each elevation /

separate part to be noted on weekly inspection reports.

Ensure statutory inspections are carried out.

Robertson site management: Receive design drawings / details of

specification for safe use etc. Check that scaffold erected to

appropriate design. Accept ‘Hand-over Certficate’.

Note: The ‘Hand-over Certificate’ constitutes the

initial statutory inspection. (i.e. the one required before the scaffold is first brought into use.)

Additional statutory inspections are required:

After any significant modification or alteration.

After any adverse conditions or events which may have affected

the scaffold’s integrity. At periods not exceeding 7 days.

Note: Whilst the independent weekly inspections

can be used as the statutory weekly inspection they may also be used as a supplementary inspection to those carried out by the site management team.

Additional statutory inspections are required as specified above.

Regardless of who conducts whichever of the informal or formal statutory scaffold inspections - they should be competent to do so.


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Introduction

This core procedure sets out the framework and processes to be followed during the management of scaffolding at Robertson Construction Group workplaces.

The requirements apply to all construction sites, offices and other workplaces for which Robertson Construction Group are responsible.

The instruction and guidance contained within this procedure is based on:

Legal requirements;

Guidance from the HSE;

Guidance from relevant trade bodies;

Internal Robertson Construction Group requirements.

It is to be followed in all circumstances except:

In an emergency situation - where a dynamic risk assessment process may be adopted to manage an imminent risk to health or safety.

Where a Regional Managing Director or a Construction Group Managing Director has provided prior written authorisation to deviate from their requirements.

Requirements All scaffolding structures are required to be erected to a suitable design.

The extent to which this requires a bespoke design - as opposed to a standard design from a published erection manual – is the key factor to consider when determining whether scaffolding has been erected to a suitable design.

The direction provided within this procedure identifies what is considered a suitable design in different situations.

Site management teams must check that any scaffolding structure on site meets these criteria and that they are provided with a valid design (e.g. a bespoke design drawing, erection manual etc.) that they can check the erected scaffolding against before accepting the scaffolding into their possession - via the hand-over certificate.

Whilst site management teams are not expected to understand complex scaffolding structures before accepting the handover certificate they must nevertheless conduct basic checks to satisfy themselves that the scaffold has been erected to the stated basic design.

If no record of design is provided, or these are incomplete in terms of the documentation referenced elsewhere within this procedure, then site management teams are not authorised to accept the scaffolding on behalf of Robertson Construction Group.


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Design

All scaffolding structures are required to be erected to a suitable design.

All scaffolding structures are temporary works and are also required to be managed via the temporary works procedures. Unless a scaffold is a ‘basic configuration’ described in recognised guidance (e.g. NASC Technical Guidance TG20 - for tube and fitting scaffolds or manufacturers' guidance - for system scaffolds) the scaffold should be designed by calculation, by a competent person, to ensure it will have adequate strength and stability.

Designs are usually based on standard approaches to, and methods of, erection, dismantling and alteration of the scaffolding - therefore for scaffolds with a ‘basic configuration’ the design should be considered invalid unless the scaffolding is specified as being erected, dismantled or altered in accordance with either:

NASC guidance document SG4:10 - for tube and fitting scaffolds;

The manufacturers' erection guide - for system scaffolds;

A bespoke approach or methodology provided as part of the scaffold design.

Where scaffolds are not in a ‘basic configuration’ the design should include a specified approach or methodology for the erection, dismantling and alteration of the scaffold.

Any proposed modifications or alterations to any scaffold which are outside a generally recognised standard configuration should be designed by a competent person. Examples of typical scaffold structures which are not liable to be considered as being of a ‘basic configuration’ include:

Any scaffold structure: o Subject to vibration; o Subject to high loading; o Subject to loading from a passenger or goods hoist; o Of long term duration; o In high risk areas.

Buttressed free-standing scaffolds;

Cantilevered scaffolds;

Slung and suspended scaffolds;

Protection fans, nets and pavement frames;

Façade retention;

Towers requiring guys or ground anchors;

Dead, flying and raking shores;

Staircases and fire escapes.

Note: This list is not intended to be exhaustive but is intended to supplement the instruction provided above by providing specific examples of where bespoke designs should be sought.

Hand-over Certificates

‘Hand-over Certificates’ should refer to:

Relevant drawings;

Permitted working platform loadings;

Any specific restrictions on use.


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Where a ‘Hand-over Certificate’ makes reference to relevant supporting documentation AND that relevant documentation is on site for reference - then it may be used as the initial first-use statutory inspection.

Robertson Construction Group personnel are not authorised to accept a ‘Hand-over Certificate’ unless:

The design information is complete;

The design information is in their possession;

They are satisfied, after visual inspection, that the scaffolding has been erected in accordance with the basic design specified.

Note: Robertson Construction Group site management personnel are not expected to have a detailed knowledge of scaffolding design or inspection – however they are expected to have an understanding of basic scaffolding safety and the ability to read and understand design drawings and erection manuals sufficiently well to enable them to discharge this function diligently and competently in most circumstances. They are also expected to understand the limits of their obvious competence and to seek expert advice as appropriate. (e.g. when dealing with complex scaffolding structures)

Scaffold Inspections

All scaffolding inspection should be carried out by a competent person whose combination of knowledge, experience and training is appropriate for the type and complexity of the scaffold he is inspecting.

As a guide to competence, unless there is evidence to the contrary through the work they have conducted, the following are an acceptable means by which to determine competency:

General Scaffolding

Relevant card holding under the Construction Industry Scaffolders Registration Scheme (CISRS):

o Hold a relevant CISRS Scaffold Inspection card; o Hold a relevant CISRS Scaffolder card or Advanced Scaffolder card;

CISRS Scaffolders are deemed competent to inspect the types of scaffold they have erected – provided they are erecting scaffolding within the scope shown on their CISRS Card and CISRS guidance.

Scaffolders should be trained in relation to the type of scaffolding they are to erect. Scaffolders trained in tube and fitting scaffolding only should not therefore erect or inspect system scaffolds and vice versa.

Please refer to the CISRS Poster ‘Have you got the right card’.

A non-scaffolder who has passed a suitable scaffold inspection course (i.e. CITB Scaffold Inspection Training – (SIT)) AND has the necessary background knowledge and experience (e.g. a site manager) would be considered competent to inspect a scaffold with a ‘basic configuration’.

Alloy Tower Scaffolding

Valid Prefabricated Access Suppliers’ and Manufacturers’ Association (PASMA) card holding.

Formal statutory scaffold inspections are required to be conducted and recorded:

Before first being brought into use; o See 2.3.2 above – The Hand-over Certificate is, if all supporting documentation

is provided, acceptable as a record of this inspection.


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After any significant modification or alteration;

After any adverse conditions or events which may have affected the scaffold’s integrity;

At periods not exceeding 7 days.

These formal statutory inspections may be carried out by any competent person.

AS A SUPPLEMENT TO, OR INCORPORATED AS PART OF, THESE STATUTORY INSPECTIONS, ROBERTSON CONSTRUCTION GROUP REQUIRES AN INDEPENDENT SCAFFOLD INSPECTION TO BE CARRIED OUT AT PERIODS NOT EXCEEDING 7 DAYS.

An ‘Independent’ scaffold inspection, for the purpose of this procedure, means an inspection carried out by someone independent of:

o Robertson Construction Group; o The scaffolding contractor who erected the scaffolding.

This independent inspection will normally be used as the statutory weekly inspection.

This requirement does not apply to alloy tower scaffolds.

The scaffold inspection report should note any defects and corrective actions taken, even when those actions are taken promptly - as this assists with the identification of any recurring problems.

Scaffold inspection reports should take two forms:

Report on RCG Report Form HS/1-12A; o Retained by site management.

Scaffold tag system (e.g. Scafftag). o Attached to scaffolding or independently referenced sections of scaffolding as

identified and reported upon within RCG Report Form HS/1-12A. (e.g. single tower scaffold, elevations of scaffolds, single loading bay, etc.)

Access to incomplete or unsafe areas should be prevented by suitable physical means and appropriate signage posted.

Scaffold Erection

All scaffold erection should be carried out by a competent person whose combination of knowledge, experience and training is appropriate for the type and complexity of the scaffold he is erecting.

As a guide to competence, unless there is evidence to the contrary through the work they have conducted, scaffolders are deemed competent if they hold a relevant card under the Construction Industry Scaffolders Registration Scheme (CISRS) or Prefabricated Access Suppliers’ and Manufacturers’ Association (PASMA) to the following extent:

General Scaffolding

Advanced Scaffolder: o May lead or partake in all types basic and complex scaffolding operations

subject to suitable training and endorsement in the type of scaffolding they are working with. (e.g. ‘tube and fitting’ or specifically endorsed ‘system’ scaffolds.)

Scaffolder: o May lead or partake in scaffolding operations covered by their training and

assessment to date – including in relation to the type of scaffolding they are working with. (e.g. ‘tube and fitting’ or specifically endorsed ‘system’ scaffolds.)


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Trainee Scaffolder: o May work as part of a scaffold gang under the direct supervision of a CISRS

Scaffolder or Advanced Scaffolder. Similar ‘tube and fitting’ and ‘system’ scaffold endorsements appear on the Trainee Scaffolder’s CISRS card as the others - and they may only work on relevant systems.

Basic Access System Erector (BASE): o For non scaffolding operatives who may be required to erect dismantle or alter

simple system scaffold structures. These cards are valid only: Up to a maximum height of 6m; In areas where there is no public interface.

Scaffolding Labourer: o May not erect, dismantle or alter scaffold structures in any way.

Scaffolding Supervisor: o Unless they also hold a relevant CISRS card as a scaffolder may not erect,

dismantle or alter scaffold structures in any way.

Alloy Tower Scaffolding

May only be erected by someone holding a valid Prefabricated Access Suppliers’ and Manufacturers’ Association (PASMA) card.

Scaffold Access

Wherever reasonably practicable scaffold access should be by staircase rather than by ladder.

Where the scaffold is generally sheeted with debris or other netting - any area that is to be used as an emergency escape route should have the netting omitted from that area to prevent a possible build-up of smoke and effect the easiest possible access for emergency services for evacuation of personnel.

Loading Bay Platforms

All loading bay platforms above ground level should be fitted with ‘up and over’ style gates.

The safe working load of the platform should be clearly identified and brought to the attention of those using the loading bay.

4.3.3.15. Excavations Temporary Works design All excavations are temporary works and should be safe by design. Reference should be made to RGN 01 Temporary works designs – Trenches and excavations to establish what is deemed to be adequate in terms of temporary works designs. Safe digging practice All such works should be managed under Form HS/1-14A - Permit to Work – Groundworks. Personnel planning Safe Systems of Work associated with ground-works, earthworks, excavations, trench-works etc. should follow the guidance published within HSE publication HSG 47 - Avoiding danger from underground services.


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Reference should also be made to HSE publication GS6 – Avoiding danger from overhead power lines. Both publications are free to download from the HSE website. Should additional information or guidance be required personnel should contact their Regional SHE Manager or the SHEQ Dept. Inspection & reporting Excavations are defined within the CDM regulations as including any earthwork, trench, well, shaft, tunnel or underground working. These are required to be inspected:

before being brought into use for the first time;

at the start of every shift in which work is to be carried out;

after any event that is likely to affect its strength or stability; and

after any materials falls or is dislodged within it. Unless there is a deficiency or defect found during inspections these need not be recorded on HS/1-12B Inspection Register – Excavations other than at weekly intervals. Weekly inspections should be recorded on that form. 4.3.3.16. Lifting Operations Lift Plan All lifting operations must be managed under a suitable Lift Plan. The complexity of Lift Plans will vary depending on the complexity of the lifting operations to be undertaken and should address the foreseeable risks involved in the work and identify the appropriate resources, including people, necessary for the safe completion of the task. The suitability of a Lift Plan should be established through use of the Lift Plan Checklist HS/1-13 . Correct use and completion of this checklist effectively forms a "permit to work" for lifting operations and should ensure these operations are effectively planned and managed. RGN7 Lifting Operations – Cranes provides further guidance on simple and complex lift planning and how they may be controlled. Inspection and reporting The definition of lifting equipment is specified within the Lifting Operations and Lifting Equipment Regulations (LOLER) and means work equipment for lifting and lowering loads - including any lifting accessories and attachments used for anchoring, fixing or supporting the equipment. Lifting equipment and lifting accessories are required to be thoroughly examined and inspected at specified frequencies. These are specified on the reverse of HS/1-12C Statutory Inspection Reports – LOLER. Records of thorough examination should be provided by the owner/provider of lifting equipment when it is supplied to our sites. Unless records of thorough examination are present, in date, and demonstrate the equipment is free from any defect likely to affect the integrity of the equipment then the equipment should not be used. All lifting equipment, whether formally required to be inspected or thoroughly examined before first being used on site, should be inspected as part of routine checking prior to use, and formally inspected weekly. Records of inspection should be recorded on HS/1-12C Statutory Inspection Reports – LOLER. 4.3.3.17. Permits to Work


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RCG operates strict Permit to Work systems in relation to certain high risk activities as follows:

Form HS/1-14A Permit to Work – Groundworks;

Form HS/1-14B Permit to Work – Confined Space Entry;

Form HS/1-14C Permit to Work at Height – RGN 4;

Form HS/1-14D Permit to Work – Hot Works;

Form HS/1-14E Permit to Work – General;

Form HS/1-11 Temporary Works – Authorisation to Proceed;

Form HS/1-13 Lift Plan Checklist. The ‘Appointed Person – Site Safety’ shall ensure that suitable arrangements are made for the administration of the permit to work systems on site – including, as appropriate, appointing competent personnel to act as ‘Issuer’ of the various permits. All such appointments shall be discussed with the relevant personnel and details of appointments recorded within the Construction Phase Plan. Details of administrative requirements for each individual permit are contained on those permits – however as a general rule the core requirements are as follows:

RCG shall be the ‘Issuer’ of all Permits;

The ‘Holder’ of a Permit shall ensure the safeguards identified within the SSoW are in place before seeking the issue of a Permit;

The ‘Issuer’ of the Permit shall check that all safeguards are in place prior to the issue of the Permit;

Both the ‘Issuer’ and the ‘Holder’ shall sign the Permit. During the work activities the ‘Holder’ shall retain the original – with a copy being held by the ‘Issuer’;

The ‘Holder’ shall return the Permit once its period of validity has expired – usually at the end of the work, the end of the shift, or the end of the day - whichever is sooner;

Prior to the close of the Permit the ‘Holder’ shall ensure the work area has been made safe;

Prior to the close of the Permit the ‘Issuer’ shall check the work area to ensure the area has been made safe;

The ‘Issuer’ and ‘Holder’ shall jointly sign and close the Permit;

The ‘Issuer’ shall destroy the copy of the Permit and retain the original on record.

4.3.3.18. Plant and Equipment Plant and equipment The selection, maintenance, inspection and use of work equipment are governed by the Provision and Use of Work Equipment Regulations (PUWER). PUWER applies to all work equipment, including mobile and lifting equipment. The scope of ‘work equipment’ is extremely wide and covers almost any equipment used at work, including:

‘tool box tools’ such as hammers, knives, handsaws etc;

single machines such as drilling machines, circular saws, dumper trucks etc;

lifting equipment such as hoists, lift trucks, elevating work platforms, lifting slings etc;

other equipment such as ladders, pressure water cleaners etc;

scaffolding or similar access equipment - except where the Construction (Design and Management) Regulations 2007 impose more detailed requirements.

The HSE’s Approved Code of Practice and guidance document, L22 – Safe use of work equipment, which is free to download from their website, provides detailed information in relation to how to ensure compliance with statutory requirements.


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These are supplemented by industry specific publications under the HSE’s Construction Information Sheet (CIS) series of publications. These are the standards to be applied on Robertson projects unless alternative arrangements or requirements are specified elsewhere within HS/1, RGN’s, Safety Alerts, Safety Information Sheets, etc. or any other supplementary Robertson publications. Inspection and reporting The purpose of an inspection is to identify whether work equipment can be operated, adjusted and maintained safely and that any deterioration (for example defect, damage, wear) can be detected and remedied before it results in unacceptable risks. The extent of the inspection required will depend on the potential risks from the work equipment. Inspection should include, where appropriate, visual checks, functional checks and testing. Where the safety of work equipment depends on the installation conditions we should ensure it has been installed correctly and is safe to operate. To secure this we should ensure it is inspected:

After installation and before being put into service for the first time; or

After assembly at a new site or in a new location. To ensure health and safety is maintained and that any deterioration in work equipment can be detected and remedied in good time, equipment exposed to conditions causing deterioration liable to result in dangerous situations should be inspected:

At suitable intervals; and

Each time that exceptional circumstances which are liable to jeopardise the safety of the work equipment have occurred.

The person who carries out the inspection should have sufficient knowledge of the equipment to:

enable them to know what to look at (know the key components);

know what to look for (fault-finding); and

know what to do (reporting faults, making a record, who to report to). These inspections should normally be no greater than one week apart and be recorded on HS/1-12D Statutory Inspection Reports – PUWER. Inspection does not normally include a pre-use check that an operator may make before using work equipment. Pre-use checks should not therefore normally be recorded. An exception to this within Robertson Construction is the pre-use checks associated with use of ride-on mobile plant. Pre-use checks should be carried out daily and recorded on HS/1-15 Daily Vehicle Pre-operational Checklist. 4.3.3.19. Asbestos Premises built prior to 2000, or brownfield sites have the potential for Asbestos Containing Materials (ACMs) to be present. Where there is a possibility of ACM’s being present and works are likely to disturb any such material then a ‘Refurbishment and Demolition’ survey should be available prior to any work commencing. Guidance on surveys is contained in RGN15. Where any material suspected of being an ACM is uncovered during work activities, work in the area should be immediately stopped and investigations, and as appropriate sampling and testing,


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undertaken to establish the nature of the material. Any such incident should be immediately reported to the Regional SHE Manager or the SHEQ Department. Further practical guidance is available in HSE publication EM1 Asbestos Essentials - What to do if you uncover or damage materials that may contain asbestos. Where ACM’s are identified in a work area they should be removed, encapsulated or otherwise made safe by a licensed asbestos removal contractor. Where such a contractor is engaged to undertake work on a Robertson Construction project form HS/1-16 Asbestos checklist should be used by site management to establish that appropriate safeguards are to be deployed prior to work commencing. Where there is any doubt about the adequacy of arrangements surrounding the management of asbestos removal works advice and guidance should be sought from the Regional SHE Manager or the SHEQ Dept. 4.3.3.20. Electrical Safety Electricity on Construction Sites Electricity is inherent on almost every project that Robertson Construction Group Companies are involved with. On all projects where electricity is present there will be Low Voltage (LV) Single Phase 230v and Three Phase 400v supplies. The term Low Voltage (LV) applies to all supplies up to 1,000v A.C. The term High Voltage (HV) applies to all supplies above 1,000V A.C. Electricity can be fatal at Single Phase LV supplies of 230V and below. Tragically this is the reality on a number of UK Construction Sites every year. All Electrical Contractors (this may include Sub Contractors working under the Mechanical Contractor) must have current valid registration with NICEIC and/or ECA (SELECT in Scotland). It is incumbent upon all Registered Electrical Contractors to have in place a Method of Safe Working Practices for Electrical Systems. These systems should take cognisance of the guidance provided within the following documents (non-exhaustive and as amended):

Health and Safety at Work etc. act 1974

The Electricity at Work Regulations 1989

HSG 85 Electricity at Work Safe Working Practices

BS 7671: Requirements for electrical installations (IEE regulations)

HSR 25 Memorandum of guidance on the Electricity at Work Regulations 1989.

The Electrical Safety, Quality and Continuity Regulations 2002.

Management of Health and Safety at Work Regulations 1999

Electrical Safety Council – Guidance on Safe Isolation Procedures for Low Voltage Installations

HSE – Electrical Safety and You

Department of Health – Health Technical Memorandum 06-02: Electrical Safety Guidance for Low Voltage Systems.

Department of Health – Health Technical Memorandum 06-03: Electrical Safety Guidance for High Voltage Systems.


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Every project where electricity is present or will be present, requires a written procedure which clearly identifies the methods of “Safe Working Practices” for Electrical Systems which will be employed on that particular site. This written procedure should identify:

The ‘Duty Holder’. This is the person(s) who has the responsibility for the electrical systems.

On projects where the client is still in some form of occupation, they will initially be the Duty Holder and may wish to be the Duty Holder throughout our works (i.e. ASDA). This is acceptable as long as they provide a specific written procedure which identifies their Safe Working Practices for Electrical Systems. This procedure would be reviewed and either accepted or rejected by our Electrical Sub Contractor. When the client does not wish to retain duty holdership we must request in writing from them that they wish to pass over this responsibility to our Electrical Sub Contractor. On Projects where there is no resident client, we initially assume the responsibility for Electrical Systems Safety as the Principle Contractor. On appointment of the Electrical Sub Contractor we should ensure that they have demonstrated their ability to implement and control a ‘Safe Working Practices for Electrical Systems’ procedure. Once the Electrical Sub Contractor is on site they assume the role of Duty Holder.

Authorised Person(s) – This is the Duty Holder and is the only person(s) who can issue Permits to Work. Note that Permits are never issued for equipment which is live. The Permit is issued to definitively state that the systems and equipment listed are safe to work on.

Method Statement detailing the Electrical Control System to be employed. This will clearly identify the procedures to be followed by the Electrical Sub Contractors Authorised Person for making safe the electrical equipment and circuitry to be worked on.

Safety Measures to be applied.

Procedures to be followed in the case of an emergency.

4.3.3.21. Portable Appliance Testing (PAT) The ‘Appointed Person – Site Safety’ shall ensure that suitable arrangements are made for monitoring that portable electrical appliances operated on site are subject to appropriate periodic testing to monitor their electrical integrity. Appropriate evidence shall be in the form of:

Evidence that the equipment is less than 1 year old;

Durable test records attached in such a way that they may be readily checked in situ (e.g. PAT

label); or

Durable identification tags that they can be traced back to a relevant test record. For equipment hired by RCG, the hire company shall provide the above evidence at the point of delivery. Where it is not provided the appliance shall be returned unused. 4.3.3.22. Health Screening and Health Surveillance All Robertson site based personnel are subject to a health surveillance programme operated and administered by the Robertson Group HR Dept.


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Additional personnel may undergo health surveillance based on individual work patterns and exposures to hazardous substances. 4.3.3.23. Hand-arm Vibration (HAV) Guidance

This document sets out how Robertson Construction Group companies will manage the occupational health risks associated with hand-arm vibration. It incorporates details of our risk assessment process and how we will manage the risk through application of our hand-arm vibration prevention programme. This document is supplemented by documentation and processes related to our occupational health surveillance programme. Full training on our management arrangements and the prevention programme will be provided by the SHEQ Dept.


HAV Risk Assessment Flowchart

Notes: 1. Whilst individual employers have responsibility for their own personnel it is RCG’s responsibility, where we are Principal

Contractor, to take reasonably practicable steps to ensure that all works on site are conducted safely. 2. Regardless of whether we are Principal Contractor or not - where works are subcontracted by us we must similarly take

reasonably practicable steps to ensure that all works undertaken under our subcontracted packages are conducted safely.

3. It is the responsibility of RCG site management to ensure HAV hazards and risks are appropriately addressed prior to works involving use of hand-held vibrating tools commencing. Where advice or guidance is required they should consult their Regional SHE Manager.

4. There is no single source of reference material prescribed for use when conducting a HAV RA. Many sources are available which will facilitate adequate assessment of HAV risk. The key is that personnel are (i) familiar with the RCG HAV RA calculator and form (HS/1-17 HAV Risk Assessment Calculator + RCG Notes); (ii) familiar with the HSE HAV ‘Ready reckoner’; (iii) they apply the hierarchy of control where a HAV risk exists; and then (iv) implement appropriate control measures where appropriate. Site management will be trained in relation to all aspects of this.

5. Practical HAV Hierarchy of Control:

Eliminate the use of hand-held vibrating tools wherever we reasonably can;

Where we cannot eliminate their use then we must control the risk by substituting the harmful with the less harmful:

o Use of tools that provide lower individual vibration exposures to complete the task. Discussion with tool-hire companies such as Speedy Hire, the use of the Hilti tool selector, interrogation of the OPERC database or use of vibration monitoring equipment may be useful for this;

Use administrative controls to minimise individual exposure: o Rotation of the workforce undertaking the task;

Work may involve use of hand-held vibrating tools

Apply HAV hierarchy of control

N

Work involves use of hand-held vibrating tools

Y

N

S/C responsible for

HAV RA

RCG Employee

Task covered by existing

RCG HAV RA

Source / select appropriate vibration magnitude data

(At discretion of person conducting the HAV RA.)

Y

N

Ensure S/C presents HAV

RA which references vibration magnitude & uses an appropriate assessment tool. (e.g. HSE HAV calculator or

‘Ready reckoner’)

Determine HAV exposures / safe

working limits using the RCG HAV RA calculator or HSE ‘Ready

reckoner’ & record, as appropriate, on RCG HAV RA Form.

Y

Operational action

HAV controls required

Send any completed HAV RA to Regional SHE Manager

Administrative actions

Ensure controls applied

Y

Regional SHE Manager to: Review HAV RA; Liaise with site team where there

are queries; Publish the HAV RA to the

database of HAV RA’s on Conject / BIW.

N

Ensure personnel undertaking the works are briefed re relevant: Hazards Risks Control measures Supervisory arrangements related to

their works.

Maintain records of briefing


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Provide information, instruction and training to those undertaking the task; o Provide toolbox talks and the briefing described above in relation to hazards, risks, control measures and supervisory arrangements.

Provide health surveillance where the EAV is routinely exceeded. o RCG provide HAV related surveillance within their general health surveillance provisions to all our operatives

Hand-arm Vibration Prevention Programme Introduction The generic hazards and risks associated with the use of vibrating tools and equipment are well documented. The Robertson Construction Group (RCG) Hand-arm Vibration Prevention Programme has been developed to facilitate management of that risk across the range of our undertakings. The programme sets out:

1. The hazards and the risks. 2. Health effects. 3. Exposure ‘Action’ and ‘Limit Values’. 4. Typical hazardous activities. 5. Employer’s responsibilities. 6. Hierarchy of control. 7. HAV risk assessment. 8. Information, instruction and training.

1. The hazard and the risks Work involving the use of hand-held vibrating tools or equipment represents a vibration hazard. The degree of risk is principally determined by the:

Acceleration rate / magnitude of vibration presented by the use of a tool for a given task - in a given environment; and

Length of exposure. In addition, the following factors have a bearing on the degree of risk presented:

The tightness of grip applied on the tool by the operator;

The degree of force applied by the operator whilst using the tool;

The maintenance regime for the tool;

Sharpness of the tool bit;

The toughness of the material being worked on;

The length and frequency of rest period;

Extraneous factors affecting blood circulation (e.g. smoking); and

Individual susceptibility. 2. Health effects

Hand-arm vibration can cause a range of conditions collectively known as hand-arm vibration syndrome (HAVS). The best known is vibration white finger (VWF), but vibration also links to specific diseases such as carpal tunnel syndrome. For some people symptoms appear after only a few months of exposure but for others it may take years. The symptoms are likely to get worse with repeated exposure and can lead to permanent damage and disfigurement. They can severely limit the jobs that someone is able to do, as well as affect family and social activities.


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The symptoms include any combination of:

Tingling and numbness in the fingers; Not being able to feel things properly; Loss of grip strength in the hands; and/or Fingers going white (blanching) and becoming red and painful on recovery - particularly in the cold and wet, and probably only in the tips at first.

The effects of these symptoms on people include:

Pain, distress and disturbed sleep; Inability to do fine work (e.g. assembling small components) or everyday tasks (e.g. fastening buttons); Reduced ability to work in cold or damp conditions (i.e. most outdoor construction work) - which is likely to trigger a painful finger blanching attack; and Reduced grip strength - which might affect the ability to work safely.

3. Exposure ‘Action’ and ‘Limit’ values Vibration magnitudes are measured in terms of m/s2. The daily exposure ‘Action’ and ‘Limit’ values are calculated based upon average exposure over an 8 hour day and are expressed in terms of m/s2 A(8). The daily Exposure Action Value (EAV) is 2.5 m/s2 (A8). Health surveillance is required where personnel are regularly exposed at or above this value. The daily Exposure Limit Value (ELV) is 5.0 m/s2 (A8). Personnel must never be exposed at or above this value. 4. Typical hazardous activities Though numerous construction activities involve the use of vibrating tools, not all will be liable to require use of hand-held tools at, or approaching, the EAV of 2.5 m/s2 (A8). Typical activities which would be liable to do so involve the use of:

Percussive hammers

Concrete breakers Concrete pokers

Disc cutters Needle guns Scabblers

Vibratory compactors

Hammer drills Grinders

Sanders

5. Employer’s responsibilities The Control of Vibration at Work Regulations 2005 requires the company to prevent or reduce risks to health and safety from exposure to vibration at work. In particular, we must:

Assess the vibration risk to our employees; Take action to reduce vibration exposure that produces those risks - by applying the hierarchy of control; Decide if employees are likely to be exposed above the:

o EAV of 2.5 m/s2 (A8) - and if they are, introduce a programme of controls to eliminate risk, or reduce exposure to as low a level as is reasonably practicable;


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o ELV of 5.0 m/s2 (A8) and if they are, take immediate action to reduce their exposure below the limit value;

Provide information, instruction and training to our employees on health risks and the actions we are taking to control those risks; Carry out health surveillance where there is a risk to health - particularly where there is regular exposure at or above the EAV; Consult our employee representatives (or trade union safety representative) on proposals to control risk and to provide health surveillance; Keep a record of our risk assessment and control actions; Keep health records for employees under health surveillance; and Review and update our risk assessment as appropriate.

6. Hierarchy of control General principles of prevention The principles of prevention set out at Schedule 1 to the Management of Health and Safety at Work Regulations 1999 form the basis of our control strategy. These principles are reproduced below for clarity:

Avoid risks; Evaluate the risks which cannot be avoided; Combat the risks at source; Adapt the work to the individual, especially as regards the design of workplaces, the choice of work equipment and the choice of working and production methods, with a view, in particular, to alleviating monotonous work and work at a predetermined work-rate and to reducing their effect on health; Adapt to technical progress; Replace the dangerous by the non-dangerous or the less dangerous; Develop a coherent overall prevention policy which covers technology, organisation of work, working conditions, social relationships and the influence of factors relating to the working environment; Give collective protective measures priority over individual protective measures; and Give appropriate instructions to employees.

Practical HAV hierarchy of control In practical terms we must assess the HAV risks and take reasonably practicable steps to control those risks in line with the following hierarchical framework:

Establish the need for the work to be undertaken and avoid wherever we reasonably can;

Assess the risks associated with alternative means of undertaking the work and adopt the least risky option;

Wherever we reasonably can - avoid the need to use hand-held vibrating tools;

Where they have to be used – use tools which will minimise individual exposure to complete the task; (See Note 1)

Minimise the force required to use the tool by ensuring the equipment is well maintained and any tooling is sharp;

Reduce the length of individual exposure through job rotation;

Educate those undertaking the work through the education strategy detailed below;

Provide health surveillance to those identified as being at risk. (See Note 2)


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Notes: 1. Note that a tool with a lower vibration magnitude may take longer to complete the task than one with higher vibration magnitude which will facilitate doing the task much quicker. The key is to evaluate individual exposure for the task. This will form part of the risk assessment process. 2. RCG provide health surveillance to all operatives. Line managers should ensure that surveillance is being delivered.

7. HAV risk assessment When conducting a HAV risk assessment it is important that we consider both the needs of the individual sites and the wider needs of the business as a whole – both of which are inter-related. To facilitate easy management of the HAV risk at site level it is important that appropriate risk assessments are both conducted and stored on BIW / Conject for others to refer to and use as appropriate. The greater the databank of risk assessments we have in place the fewer we will have to undertake afresh in the future. HAV risk assessments have been, are being, and will be conducted to cover a range of work packages and specific activities. These have been, are being, and will be conducted whilst making reference to a number of different measurement tools and reference documents to determine the magnitude of the vibration. All risk assessment must however:

Contain specific reference to the source of the vibration magnitude data (m/s2 (A8) value) being used; (e.g. OPERC database, Hilti product selector, Speedy Hire vibration data sheet, Havmeter reading etc.)

Be recorded on HS/1-17 HAV Risk Assessment Calculator & Guidance Notes;

Where complete processes associated with a day’s work are being assessed (e.g. Erect partitions secure to concrete floor soffit and wall (drill fix) timber) then all tools associated with the process should be included and their respective partial exposures included.

Where a risk assessment is being undertaken for use of a single tool which doesn’t give rise to exposures at or approaching the EAV then the risk assessment need not be formally recorded and uploaded to BIW / Conject. Simple reference to, and discussion of, the ready reckoner during the task briefing will be sufficient. Where the use of a number of vibrating tools is required during the day then the cumulative vibration exposure needs to be determined. The risk assessment needs to be formally recorded where the cumulative vibration exposure is likely to approach or exceed the EAV or the activity is a common activity for which no formal risk assessment is available within the database of HAV risk assessments. The formal risk assessment or the ready reckoner findings will need to be discussed, as appropriate, during the task briefing. 8. Information, instruction and training Site management will be provided with information and training related to:

Sources of hand-arm vibration;

The health effects of hand-arm vibration;

Factors which affect the risk (e.g. the magnitude of vibration, daily exposure duration, regularity of exposure over weeks, months and years);

Ways to minimise risk including: o Changes to working practices to reduce vibration exposure; o Correct selection, use and maintenance of equipment;


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o Correct techniques for equipment use, how to reduce grip force etc; o Maintaining good blood circulation at work by keeping warm and massaging fingers; and, if possible, cutting down on smoking.

The requirements of this HAV programme;

How to use HS/1-17 HAV Risk Assessment Calculator & Guidance Notes;

How to publish HAV risk assessments; and

How to use the HSE’s ‘Ready reckoner’.

All employees who work with equipment that creates a risk of exposure to hand-arm vibration will be provided with information and training related to:

Sources of hand-arm vibration; The health effects of hand-arm vibration; Whether they are at risk from HAV, and if so whether the risk is high (above the ELV), medium (above the EAV) or low;

o General training will provide information associated with typical tasks and activities we know to give rise to significant risk. o Task specific briefings, delivered at the workplace, will provide information and instruction in relation to HAV risks associated with tasks about to be undertaken and include details associated with the hazards, the risks, the control measures and the supervisory arrangements in place.

Factors which affect the risk (e.g. the magnitude of vibration, daily exposure duration, regularity of exposure over weeks, months and years); How to recognise and report symptoms; The importance of health surveillance – including:

o How it can help them remain fit for work; o Arrangements for its provision; o How we use the results; and o The confidential nature of the results;

Ways to minimise risk including: o Changes to working practices to reduce vibration exposure; o Correct selection, use and maintenance of equipment; o Correct techniques for equipment use, how to reduce grip force etc; o Maintaining good blood circulation at work by keeping warm and massaging fingers; and, if possible, cutting down on smoking.

Where an individual’s exposure is routinely likely to be at or above the EAV, or is likely to be at or above a level specified by a qualified medical practitioner as being a controlled exposure level, a record of weekly exposure to hand arm vibration shall be kept using form HS/1-18 Weekly Individual HAV Exposure Record. This record shall be retained on Conject under the relevant project area saved by the employee’s name. The need for refresher training will be reviewed at least annually, and update training provided as necessary. Exposure points system and ready-reckoner The extract below is taken directly from the HSE website and may help you understand, in simple terms, whether there may be a significant HAV risk presented by use of hand-held vibrating tools. The hierarchy of control should always be applied to ensure any use of hand-held vibrating tools is either eliminated or the risk controlled and minimised to the extent we reasonable can.


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The table below is a ‘ready reckoner’ for calculating daily vibration exposures. All you need is the vibration magnitude (level) and exposure time. The ready-reckoner covers a range of vibration magnitudes up to 40 m/s2 and a range of exposure times up to 10 hours. The exposures for different combinations of vibration magnitude and exposure time are given in exposure points instead of values in m/s2 A(8). You may find the exposure points easier to work with than the A(8) values:

Exposure points change simply with time: twice the exposure time = twice the number of points; Exposure points can be added together, for example where a worker is exposed to two or more different sources of vibration in a day; The exposure action value (2.5 m/s2 A(8)) is equal to 100 points; The exposure limit value (5 m/s2 A(8)) is equal to 400 points.

HSE Exposure Points Ready Reckoner

Vibration magnitud

e (m/s

2)

40 800

30 450 900

25 315 625 1250

20 200 400 800

19 180 360 720 1450

18 160 325 650 1300

17 145 290 580 1150

16 130 255 510 1000

15 115 225 450 900 1350

14 98 195 390 785 1200

13 85 170 340 675 1000 1350

12 72 145 290 575 865 1150 1450

11 61 120 240 485 725 970 1200 1450

10 50 100 200 400 600 800 1000 1200

9 41 81 160 325 485 650 810 970 1300

8 32 64 130 255 385 510 640 770 1000 1200

7 25 49 98 195 295 390 490 590 785 865

6 18 36 72 145 215 290 360 430 575 720

5.5 15 30 61 120 180 240 305 365 485 605

5 13 25 50 100 150 200 250 300 400 500

4.5 10 20 41 81 120 160 205 245 325 405

4 8 16 32 64 96 130 160 190 255 320

3.5 6 12 25 49 74 98 125 145 195 245

3 5 9 18 36 54 72 90 110 145 180

2.5 3 6 13 25 38 50 63 75 100 125

2 2 4 48 16 24 32 40 48 64 80

1.5 1 2 5 9 14 18 23 27 36 45

1 1 1 2 4 6 8 10 12 16 20

15 m 30 m 1 hr 2 hr 3 hr 4 hr 5 hr 6 hr 8 hr 10 hr

Daily Exposure Time

Guidance on use of the ready reckoner is provided below.


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Using the ready reckoner: 1. Find the vibration magnitude (level) for the tool or process (or the nearest value) on the

grey scale on the left of the table. 2. Find the exposure time (or the nearest value) on the grey scale across the bottom of the

table. 3. Find the value in the table that lines up with the magnitude and time. (e.g. For a

magnitude of 5 m/s2 and an exposure time of 3 hours - the exposure corresponds to 150 points.)

4. Compare the points value with the exposure action and limit values (100 and 400 points respectively). In this example the score of 150 points lies above the exposure action value but is unlikely to reach the exposure limit value and is therefore shaded yellow.

The colour of the square containing the exposure points value tells you whether the

exposure exceeds, or is likely to exceed, the exposure action or limit value:

Above Exposure Limit Value (ELV)

Likely to be above the Exposure Limit Value (ELV)

Above the Exposure Action Value (EAV)

Likely to be above the Exposure Action Value (EAV)

Below the Exposure Action Value (EAV)

5 If a worker is exposed to more than one tool or process during the day, repeat steps 1 – 3 for each one, add the points, and compare the total with the exposure action value (100) and the exposure limit value (400). 6 The exposure limit value must never be exceeded.

4.3.3.24. Noise The Control of Noise at Work Regulations These regulations require us to prevent or reduce risks to health and safety from exposure to noise at work. We are required to:

Assess the risks to our employees from noise at work; Take action to reduce the noise exposure that produces those risks; Provide our employees with hearing protection where we cannot reduce the noise

exposure enough by using other methods; Make sure the upper exposure action limits on noise exposure are not exceeded; Provide our employees with information, instruction and training;Carry out health

surveillance where there is a risk to our employees health. Noise levels - Action levels We are required to take specific action at certain action values. These relate to the:

Levels of exposure to noise of our employees averaged over a working day or week; and

Maximum noise (peak sound pressure) to which our employees are exposed in a working day.

The values are:

Lower exposure action values:


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o Daily or weekly exposure of 80 dB; o Peak sound pressure of 135 dB;

Upper exposure action values:

o Daily or weekly exposure of 85 dB; o Peak sound pressure of 137 dB.

Where noise exposures are between the lower and upper exposure action values we should provide our personnel with hearing protection if they ask for it. Where noise exposures exceed the upper exposure action value we should:

Provide our personnel with hearing protection and make sure they use it. Identify hearing protection zones where:

o The existence of the zone is adequately communicated to relevant personnel; o Appropriate signage is prominently posted; o The use of hearing protection is compulsory; o Use of hearing protection in those areas is rigorously policed.

Provide our personnel with instruction, training and information on how to use and care for the hearing protection;

Where guidance or assistance is required to establish noise levels in an area personnel should consult their Regional SHE Manager or the SHEQ Dept. Noise levels - Action levels and Limit values There are also levels of noise exposure which must not be exceeded. These are called exposure limit values:

Daily or weekly exposure of 87 dB; Peak sound pressure of 140 dB.

Practical management of noise exposures We should ensure hearing protection is being used effectively by:

Making sure the hearing protection provided gives enough protection - aim at least to get below 85 dB at the ear;

Selecting hearing protection which is suitable for the working environment – including other PPE being worn;

Providing a range of hearing protection so that employees can choose ones which suit them;

Providing instruction and training in its use. Practical maintenance of hearing protection We should ensure that suitable facilities are provided and that personnel are instructed and trained to ensure hearing protection works effectively. This should include ensuring that they can check that:

Hearing protection remains in good, clean condition; Earmuff seals are undamaged; Tension of headbands on ear muffs is not reduced; There are no unofficial modifications; Compressible earplugs are soft, pliable and clean.

Where contractors activities on site give rise to a risks of noise exposures then we should ensure they are managing the risk to their employees in line with the core requirements above.


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Where those activities give rise to risks to others Robertson site management should ensure that those site-wide aspects are appropriately managed and co-ordinated. 4.3.3.25. Tool Box Talks The ‘Appointed Person – Site Safety’ shall ensure that suitable tool box talks are planned and delivered to personnel working on the live areas of the site. These will normally be delivered weekly by the employer of those being put to work and cover a topic related to ongoing, or upcoming, work activities. For RCG employees the tool box talk content shall be based on information contained within the Toolbox talks section available on Conject. For RCG employees form HS/1-19 Toolbox Talk / Task Briefing Register shall be completed to record each session held and those attending. Where sub contractors do not have their own Attendance Register then form HS/1-19 Toolbox Talk / Task Briefing Register shall be completed. All sub contractor records of tool box talks delivered on site shall be provided to Robertson Construction Group on a weekly basis. 4.3.3.26. Worker Involvement - Consultation Forums & Reporting of Safety Issues RCG seeks the active participation of all personnel in the planning, supervision and management of health and safety on site. Whilst RCG encourages worker involvement it is recognised that implementing effective worker involvement forums can be challenging. The ‘Appointed Person – Site Safety’ shall, however, ensure that suitable arrangements are in place to facilitate effective worker involvement on site wherever that can be achieved. This shall ideally follow the principles and outline for forums described within the UKCG Worker Involvement Toolkit – and shall be detailed within the Construction Phase Plan. An example tool for worker involvement is the Head Up For Five (HUFF) HS/1-20. As a minimum the following three elements shall be implemented on all sites:

An open door policy - where workers may freely speak to members of the supervisory and management teams about health and safety matters without fear of reprisal.

SHE matters shall either form an agenda item at weekly meetings with contractors or they shall be the subject of a specific weekly meeting. In either case discussions and the recording of Minutes shall be in accordance with HS/1-21A SHE Weekly Agenda & Minutes – Weekly Site Meeting. If no separate SHE forum for direct involvement of the workforce is available – that weekly meeting shall, wherever practical, involve representatives from the workforce as well as supervisors and/or management.

o Ideally part of this weekly meeting shall incorporate a tour of the site by the managers and supervisors – incorporating a review of work practices and SHE standards, and interaction with the workforce.

Where the workers wish to have a designated health and safety representative then RCG shall help organise, as appropriate, for a suitable election to take place.

o Where such an election takes place the ‘Appointed Person – Site Safety’ shall ensure that the forms of consultation, and the contact details of any recognised safety representatives, are prominently posted on the site safety notice board.

4.3.3.27. Notice Boards


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Notice boards shall be available at each site to publish relevant health & safety information. These notice boards shall incorporate any elements which may from time to time be stipulated as mandatory within the Robertson Branding Manual or any associated manual – such as the Corporate Site Signage manual. 4.3.3.28. Enforcing Authority Visits (i.e. HSE / EA / SEPA / Environmental Health) The ‘Appointed Person – Site Safety’ shall ensure that form HS/1-22 – Enforcing Authority Visit is completed immediately following every site visit by an officer from an enforcing authority. All significant matters discussed shall be recorded and details of any official enforcement action taken or proposed highlighted. Details of any Notice of Contravention issued by the HSE shall be noted and a copy of the Notice of Contravention appended to form HS/1-22 – Enforcing Authority Visit. Copies shall be posted on Conject and distributed to:

The Regional MD;

The Regional Operations Director;


The Head of the SHEQ Department. 4.3.3.29. Personal Protective Equipment (PPE) Appropriate standards of PPE have been selected via a risk assessment process and incorporated within the standard lists of PPE available through the buying teams. Additional items of PPE, typically associated with task specific activities, should be selected on the basis of risk assessment. PPE should therefore be selected and worn in accordance with site rules and supplemented, as appropriate, on the basis of task specific risk assessments. Gloves should be selected on the basis of the glove selector contained within RGN 11 – Hand Protection and should be of a suitable hand size to allow finger dexterity during use. A record of PPE issued shall be kept on form HS/1-23 Record of Issue of PPE. 4.3.3.30. Health and Safety Records Upon contract completion certain SHE related records require to be available for future reference. The ‘Appointed Person – Site Safety’ shall ensure that the following information has been electronically stored on Conject during, or upon completion of, the contract:

BI 510 Accident Book entries for the site (entries required for both RCG and sub-contractor injuries);

All accident information gathered as a result of any RIDDOR Reportable accident, Dangerous Occurrence, or case of a reportable disease;

Scaffold Handover Certificates;

Scaffold Inspections – scaffold register;

Excavation Inspections – excavation, cofferdam & caisson register;

Cofferdam & Caisson Inspections - excavation, cofferdam & caisson register;

Thorough Examination Certificates - for lifting equipment and work equipment;


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Lifting equipment inspections – LOLER register, report on statutory inspection report HS/1-12C;

Work equipment inspections – PUWER register, report on statutory inspection report HS/1-12D;

Waste movements - consignment notes.

Personal Protective Equipment (PPE) record – complete HS/1-23 Record of Issue of PPE.

Hand-arm vibration syndrome (HAVS) – report on HS/1-18 Weekly Individual HAV Exposure Record.

4.3.4. Selection and Management of Contractors, Designers & Suppliers 4.3.4.1. Overview The selection of competent contractors, consultants, designers and suppliers – hereafter collectively referred to as vendors – underpins our ability to deliver excellence in the built environment. Working closely with our design teams to design out health and safety risk during the construction phase - and design in health and safety features within the built environment – lies at the heart of our approach to design management. Effective co-ordination between, and management of, vendors on site forms the foundation for our delivery of exemplar health and safety performance on site. Establishing the health and safety competence of vendors forms only part of the selection process. The operational, commercial and SHEQ teams all have input to the selection and ongoing management of vendors - and all bear some responsibility for their initial selection during procurement. 4.3.4.2. Assessment of Health and Safety Competence The health and safety competence of vendor shall be assessed as part of a two stage process as follows:

Stage 1: Shall comprise of an assessment of the vendor’s organisation and arrangements for health and safety to determine whether these are sufficient to enable them to carry out work safely and without risk to health.

Stage 2: This shall comprise of an assessment of the vendor’s experience and track record to establish that it:

o Is capable of doing the work planned; o Recognises any limitations on its ability to undertake the proposed works; o Recognises how any such limitations will be overcome; o Appreciates the risks associated with the work; and o Understands how these should be tackled.

The above process reflects the approach required by CDM.

4.3.4.3. Stage 1 Assessment – Health and safety considerations only

All vendors shall have a Stage 1 health and safety competence assessment conducted prior to being placed on the RCG vendor database. Health and safety competence of vendors at Stage 1 shall be determined in one of the following ways:


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Through the vendor having passed an assessment under one of the schemes within the Safety Schemes in Procurement (SSiP) forum;

Through the vendor having passed an assessment under the Achilles competence assessment scheme;

Through the vendor passing the RCG competence assessment process. (This is the

least preferable option as it uses internal resource to undertake a process which can more efficiently be undertaken by competent third party accreditation bodies.)

Where a vendor has passed a competence assessment under either a scheme within the SSiP, or Achilles, they shall be deemed to be competent to ‘Approved Vendor’ status for works within the scope of the accreditation provided under those schemes. Where the initial Stage 1 assessment is to be carried out under the RCG competence assessment process - the project quantity surveyor shall administer the flow of documents between the vendor and RCG. All documents related to assessment of the health and safety competence of a vendor shall be provided to the Quantity Surveyor by the vendor – and only when all documents are available shall they be forwarded to a SHE professional for evaluation. SHE professionals shall not assess the health and safety competence of any vendor unless all required documentation is provided. Where documentation has been provided the SHE professional shall assess the health and safety competence of the vendor in accordance with the assessment process currently in place for the relevant business and inform the relevant Quantity Surveyor. The status of a vendor shall remain valid until either their Stage 1 assessment is due for review or their performance on site is so poor that it suggests that their status should be reviewed. Where there is poor performance this shall be highlighted to the relevant Managing Director by the project management team. Dependent upon the circumstances leading to the poor performance, and the scope of the works being undertaken across RCG, this may result in a number of alternative courses of action being taken – the final resolution of which shall be determined by the Managing Director of the business with which the original Action Plan was agreed. Where an amendment to status is warranted the regional Managing Director of the business within which that poor performance has been identified shall liaise with other regional Managing Directors for whom the vendor works, agree a course of action, and instruct the local vendor database administrator to make any necessary amendments to the vendor’s status or rating. On completion of the contract the performance of the vendor shall be evaluated by the site management team and recorded on the relevant form within the Quality Management System. Timescales within which to conduct a Health & Safety Competence Assessment SHE professionals shall be given a minimum of 15 working days within which to assess the health and safety competence of a vendor. It shall be the responsibility of the relevant Quantity Surveyor to:

Request the relevant submissions from the contractor at the earliest opportunity; and


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Provide those submissions to the relevant SHE professional at the earliest opportunity - and a minimum of 15 working days - before a decision is required.

4.3.4.4. Stage 2 Assessment – Health and safety considerations only All vendors shall have a Stage 2 competence assessment conducted prior to award of every contract. Stage 2 assessments shall be carried out by the ‘Appointed Person - Site Safety’ and shall establish that the vendor has the experience and track record to undertake the proposed works. The assessment process may take many forms but shall establish that the vendor:

Is capable of doing the work planned;

Recognises any limitations they may have in relation to undertaking the proposed works;

Recognises how any such limitations will be overcome;

Appreciates the risks associated with the work; and

Understands how these should be tackled. 4.3.5. Health and Safety File Information 4.3.5.1. Overview

The Health & Safety File is a document required under the Construction (Design & Management) Regulations (CDM) for projects which have involved more than one contractor. The purpose of the file is provide a comprehensive information source for the "end-user" of the premises or structure to enable it to be operated and maintained efficiently and safely. The information it contains should alert those responsible for the structure and equipment in it of any significant health and safety risks that will need to be dealt with during subsequent:

Use of the premises;

Cleaning of the premises;

Maintenance works;

Structural modifications;

Decommissioning or demolition.

The CDM Regulations places legal duties on various members of the project team including clients, contractors and designers. One of these duties is the provision of relevant information to the principal designer so that they may produce or update the Health and Safety File. The client is responsible for ensuring that the principal designer regularly updates, reviews and revises the health safety file to take account of the work and any changes that have occurred. If the principal designer’s appointment finishes before the end of the project, the principal designer must pass the health and safety file to the principal contactor, who must take on the responsibility for the file. Though the principal designer has the responsibility to produce or update the Health and Safety File, RCG, as principal contractor, will normally be in a good position to co-ordinate the preparation and submission of the required documentation to them, and may ultimately be responsible for the file as described above, and must pass the file to the client at the end of the project. In this case, RCG must ensure the client understands the structure and content of the file and its significance for any subsequent project. Where appropriate we should co-ordinate the provision of information for the file from our supply chain.


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4.3.6. Requests for Information

Each design consultant, sub contractor and supplier should be informed of the need to supply information relating to design, materials supplied and/or works packages completed at the appointment stage of the project. Where RCG are co-ordinating the supply of information from our supply chain to the principal designer, the required information should be identified and requested from each party at the earliest possible opportunity. Note: It becomes increasingly more difficult to obtain information from contractors or suppliers who have left site or have completed delivery of materials.

4.3.7. Distribution of Information Once this information has been received it should be passed to the principal designer for incorporation into the Health & Safety File. Design / contract review meetings should be used as a means of monitoring the provision of information. A record of the receipt and distribution of all information associated with the Health and Safety File should be maintained. A record of documentation forwarded to the principal designer, including any Operating and Maintenance Manuals, should be stored within the relevant workspace within Conject.

4.4. Safe Systems of Work (SSoW) 4.4.1. Overview All works on site are required to be properly planned, managed, supervised and executed in a safe manner. For activities giving rise to significant risk this is initially addressed through the risk assessment process, the preparation of Method Statements, and the overall provision of a Safe System of Work. This procedure recognises the difference between high risk activities and routine, low risk, activities - and distinguishes between how they should be managed. Details of our arrangements for ensuring safe systems of work are planned and implemented for all activities are detailed below. 4.4.2. Routine, Low Risk, Work Activities Routine, low risk, work activities shall be planned, managed, supervised and executed in a safe manner. Such works shall not require a Safe System of Work, within the context described below, to be developed. In particular the requirement for documentary evidence of risk assessments, method statements etc. shall not be applied. It shall nevertheless be the responsibility of the ‘Appointed Person – Site Safety’ to ensure that such works are appropriately planned, managed, supervised and executed. 4.4.3. Activities Giving Rise to Significant Risk


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A common sense approach should be taken to identification of activities deemed to give rise to significant risk. Where activities would give rise to significant risk if no safeguards or controls were in place - they shall be subject to development of a SSoW which governs control of those elements of the activity giving rise to that risk. A SSoW is effectively a plan and associated arrangements and controls for delivery of a work package or task in a safe manner. A SSoW is not a document but represents the resultant approach to a task or work package based on the evaluation of the hazards and risks associated with the work to be undertaken – and their presentation within documentation aimed at management of risk. (e.g. Temporary Works Designs, Risk Assessments; Method

Statements; COSHH Assessments; PPE Assessments; HAV Assessments; Noise Assessments etc.) The SSoW may be relatively straightforward or complex – dependent upon the type of work to be undertaken. The SSoW shall be determined by the organisation responsible for carrying out the work. The SSoW shall identify how works are to be carried out, any safety critical elements associated with them (e.g. sequencing of operations, rescue / emergency arrangements etc), any control measures/safeguards to be adopted and supervisory arrangements. It shall be based on supporting documentation including risk and associated assessments – and may be incorporated within a Method Statement. (Note – A Method Statement does not contain only health and safety

related information – it is important that key health and safety related information is prominent within such documentation. The health and safety information should be clear, concise, and target the key points.) Most work packages will involve an element of work which involves significant risk and an element of work which does not. The purpose of any health and safety elements within documentation provided to RCG should be the clear identification of:

Safety critical elements associated with proposed work activities (e.g. sequencing of

operations, rescue / emergency arrangements, etc.) The associated control measures / safeguards to be adopted; and

The supervisory arrangements.

Any supporting documentation should be succinct. This will ensure that critical information is not lost amongst unnecessary information. Where there is a health and safety related element within documents provided for other reasons (e.g. a Method Statement) - the health and safety section or elements should be clear, concise, and target the key points. Where appropriate the key elements may be taken from that document and reproduced, in succinct form, for presentation to RCG site management and briefing to personnel undertaking the work. All personnel undertaking work under a SSoW shall be briefed in relation to the hazards, risks, control measures and supervisory arrangements prior to the commencement of the work activity.

The ‘Appointed Person – Site Safety’ shall ensure that suitable, robust, arrangements are in place for ensuring briefings take place both for those undertaking the works themselves and those who may be affected by them.

The documentation / information required to be prepared or reviewed by RCG in relation to any proposed SSoW shall include:


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The task risk assessment – including the measures identified to eliminate or mitigate the risk of harm. Consideration shall be given to reducing the risks according to the following hierarchy:

o Elimination; o Substitution; o Engineering controls; o Signage / warnings and / or administrative controls; o Personal Protective Equipment;

Any ancillary assessments (e.g. COSHH, Noise, Vibration etc) - including the measures identified to eliminate or mitigate the risk of harm;

Defined methods of undertaking and sequencing works – as stated within the task Method Statement and related documentation; (e.g. Lift Plan)

Defined control measures to be implemented – including administrative and physical safeguards to be adopted;

Supervisory arrangements.

The key RCG monitoring document is form HS/1-24A Safe System of Work Checklist. Generic documents are an acceptable means by which to evaluate generic hazards, risks, control measures, safety critical sequencing, supervisory requirements etc. usually associated with a task – however these must be accompanied by appropriate supplementary supporting documentation where there is any significant deviation from the provisions within the generic documentation or particular site specific reference is required to a control measure. (e.g. (i) where a range of generic control measures are specified within a method statement to manage an

identified risk – supplementary documentation should specify the specific control measure to be adopted on site; (ii) where a generic control for an area is for it to be demarcated and personnel excluded from entering it during works – supplementary documentation should specify what is to be used for demarcation, where it is to be placed, how exclusion is to be achieved etc.).

4.4.4. Risk Assessment (For general guidance please refer to GE700 Section A05 – Risk assessments &

method statement)

Good risk assessment provides the platform upon which good control of site hazards is established. Though all hazards have to be considered during the risk assessment process only the significant findings, and those affected by them, need to be recorded. The risk assessment process shall be used to identify specific hazards and evaluate the risks during construction works. This will be managed by addressing risk assessment in relation to work packages. The general process is detailed in GE 700 – Section A05, which identifies salient points which must be considered by all contractors. Form HS/1-24B - Risk Assessment / Method Statement Programme shall be used to identify and track:

Who is responsible for delivery of the respective: o Risk and associated assessments; and o Supporting documentation … for each work package;

When the work is programmed to commence;

When the relevant documentation is required by;

When the relevant documentation was received;

The status of authorisation to commence work.

Where RCG are to record the findings of a risk assessment this should be undertaken on Form HS/1-26.



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A dynamic Point of Work risk assessment can be carried out to risk assess tasks which have not been identified and assessed generically on form HS/1-25 Point of Work Risk Assessment & SSoW Planner. Where RCG are to record the findings of a supplementary assessment (e.g. vibration assessment etc.) for work involving our own personnel then reference should be made to the supplementary procedures associated with those processes. Where a contractor is to record the findings of a risk assessment this should be undertaken on a risk assessment form which is clear, concise, understandable and acceptable to RCG site management.

Both RCG and contractor risk assessments are likely to be non site specific / generic in the first instance - as the details of peripheral hazards and ongoing adjacent works are not likely to be known at the time of initial writing. This is acceptable provided the generic risk assessments can reasonably be applied to the work being undertaken and they demonstrate an understanding of the hazards, risks, control measures and supervisory arrangements likely to be required.

Where site specific risk assessments are being submitted these should address the hazards and risks associated with the work in the specific location at the time the work is undertaken – or they should be treated as generic assessments with the safeguards re supplementary documentation and briefings etc. described below being applied.

When reviewing risk assessments they should not be reviewed as an academic exercise but should reviewed to determine if the significant hazards, appropriate risk control measures and supervisory arrangements have been identified. Results of the review process should be recorded on form HS/1-24A Safe System of Work Checklist.

As construction is a fast moving dynamic environment daily pre-start briefings, and as appropriate task pre-start briefings, should be used by RCG site management to ensure that effective co-ordination of site-wide and local work area elements takes place. 4.4.5. COSHH Assessment (For general guidance please refer to GE700 Section B07 – Control of

Substances Hazardous to Health (COSHH))

There are many hazardous substances either encountered or used on construction projects, or generated during construction related tasks and activities. There is a hierarchy of control to be followed when considering materials selection and methods of control of exposure. This basic hierarchy of control is as follows:

1. Eliminate the use of a harmful product or substance and use a safer one. 2. Use a safer form of the product. (e.g. a paste rather than a powder) 3. Change the process to emit less of the hazardous substance. 4. Enclose the process so that the product does not escape. 5. Extract emissions of the hazardous substance near the source. 6. Have as few personnel in harm’s way as possible. 7. Provide PPE which is fit for the task and fits the wearer. 8. Ensure personnel have been adequately trained and briefed in relation to the

hazards, risk, control measures and supervisory arrangements associated with their work activities.

When considering the appropriate control measures to introduce an overall risk assessment should be conducted to ensure the introduction of a single or number of COSHH related control measures does not increase overall risk to health and safety.



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Where the appropriate solution includes a number of the elements highlighted in the control hierarchy above the risk should be managed by ensuring they all work effectively together. Where appropriate COSHH Assessments should be provided by our supply chain as part of their proposed safe system of work and should be evaluated as part of our overall evaluation of their proposals for safe working on site. When RCG site management are considering the management of RCG activities giving rise to health hazards they should consider the volume and nature of the hazardous substances being encountered or generated, and the environment in which that is happening. If, having applied the hierarchy of control, they determine that a COSHH assessment is required then they should reference the existing COSHH Assessments held within the Conject database for COSHH Assessments to determine if a suitable COSHH Assessment is available. Where an existing COSHH Assessment is not available then they should:

Obtain the relevant data associated with the health hazards associated with the product. (e.g. Hazardous Substances Data Sheet)

Forward the document, along with details of the work environment, to either a Regional COSHH Coordinator or the Regional SHE Manager.

The Regional COSHH Coordinator or Regional SHE Manager will input the relevant data to the appropriate sub-module within the overarching Risk Module of ASSURE. The Regional SHE Manager will:

Conduct a COSHH Assessment based on the information entered within this module using the COSHH Assessment module / tool within the overarching Risk Module of ASSURE.

Forward the completed COSHH Assessment to: o The relevant RCG project manager. o The Regional Conject administrator for upload to the workspace for COSHH

Assessments within Conject. Where there is any doubt surrounding control of exposure to hazardous substances advice and guidance should be sought from the Regional SHE Manager. 4.4.6. Method Statements A Method Statement is a description of how work is to be carried out in a logical sequence and manner which is safe and without risk to health or the environment. Whilst Method Statements should ideally be succinct – it is possible that complex operations will require a complex and detailed Method Statement to be produced.

The organisation undertaking the works shall be responsible for compiling the relevant Method Statement – though liaison may be required between various parties to ensure that interfaces with others are appropriately taken into account and co-ordinated.

RCG site management should avoid personnel being asked to sign that they have understood the content of lengthy, complex and detailed Method Statements. Where Method Statements are lengthy, complex and detailed they should ensure that either:

Key health and safety related points are extracted from the full Method Statement - and personnel undertaking the work are briefed on those; or


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Separate health and safety related briefings are conducted for distinct elements of the works.

Where Method Statements are to be prepared by RCG personnel then form HS/1-27 shall be used. Where Method Statements are to be prepared by contractors then their suitability should be assessed on form HS/1-24A Safe System of Work Checklist. 4.4.7. Review of SSoW Where Risk Assessments, Method Statements and other related assessments which form the SSoW are to be reviewed - this should be undertaken by competent personnel. The RCG site manager should ensure that any person designated responsibility for this review has passed the Site Managers Safety Training Scheme course and that that course is in scope. (i.e. The 5 day course or 2 day update has been passed within the last 5 years).

Where such a person is undertaking a review of a SSoW they shall be expected to do so only within the sphere of their competence. (i.e. They shall not be expected to understand or comment upon

complex technical issues associated with specialist works. They shall, however, be responsible for ensuring that the fundamentals have been addressed.)

Where specialist guidance is required assistance should be sought from appropriate sources either within RCG (e.g. Senior operational management team, SHE professional etc.) or external consultants. The findings of the review should be recorded on form HS/1-24A Safe System of Work Checklist. Where the check indicates the need for revision, this shall be undertaken by the originator and subjected to re-checking prior to work commencing. The RCG site manager should update HS/1-24B - Risk Assessment / Method Statement Programme to ensure there is clarity in relation to the status of documentation forming support to the SSoW. 4.4.8. Communication with the workforce Ideally personnel undertaking activities and tasks giving rise to significant risks will have been involved in consultation surrounding how those tasks or activities are to be undertaken and the control measures to be adopted. Regardless of whether this has been achieved or not - personnel shall not be put to work on such activities or tasks unless the hazards, risks, control measures and supervisory arrangements associated with those activities or tasks have been effectively communicated to them. It is the primary responsibility of the person putting a person to work to ensure that they are competent to undertake the work and have had a suitable briefing as described above. As the person responsible for ensuring co-operation and co-ordination between contractors and others affected by our undertakings - it is the primary responsibility of the ‘Appointed Person – Site Safety’ to ensure that:


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Personnel at work, who are affected by the work activities of others on site, are made aware of how those works may affect them – and any control measures required, or that are in place, to secure their health or safety;

Where work activities are controlled under a permit to work - that a suitable briefing has taken place before works are permitted to commence.

Where a pre task briefing takes place that shall be recorded on form HS/1-19 Toolbox Talk / Task Briefing Register. 4.5. Communication of General Health and Safety Information 4.5.1. Overview RCG regards communication as an essential part of good management. Appropriate methods, consistent with RCG’s management and departmental structures, shall be used to communicate relevant occupational health and safety information to staff and contractors. 4.5.2. Internal Communications The best method(s) shall be decided by the person responsible for carrying out the communication, but may include:

Publication via Amplify, Conject, Safety Alerts or e-mail;

Posting of publications on notice boards;

Staff briefings;

Toolbox talks.

The person carrying out the communication shall ensure that it is timely, clear, relevant and comprehensive.

4.5.3. External Communications – Corporate Level Relevant communication from external parties (e.g. the HSE, Local Authorities, SEPA, the EA etc.), which is not specific to a particular project, shall be dealt with at Robertson Group level by the Chief Operating Officer in consultation with the head of the SHEQ Department. The head of the SHEQ Department shall be responsible for ensuring records are maintained of all such communications - including the incoming communication, any acknowledgement of receipt and any formal response.

4.5.4. External Communications – Project Level Relevant communication from external parties (e.g. the HSE, Local Authorities, SEPA, the EA etc.), which is project specific, shall be dealt with by the regional Managing Director in consultation with the head of the SHEQ Department. Where communications are received from such external parties the regional Managing Director shall inform, by the quickest practicable means:

The Robertson Group Chief Operating Officer;

Head of the SHEQ Department. The head of the SHEQ Department shall be responsible for ensuring records are maintained of all such communications - including the incoming communication, any acknowledgement of receipt and any formal response. 4.5.5. Management Information Systems


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The main platform for the communication of our OHSMS requirements is Conject. Responsibility for the maintenance and publication of OHSMS on these platforms lies with the head of the SHEQ Department. SHE inspections and audits undertaken by the SHE professionals are recorded on-line via Conject. This system utilises the task management function within Conject to allocate tasks to individuals where non conformances and opportunities for improvement are recorded. Individuals are notified of tasks allocated to them via email and the tasks are then closed-out via the task management process. Tasks allocated, and their status, can be monitored on-line within Conject. 4.6. Office Health and Safety 4.6.1. Overview All office related work is required to be properly planned, managed, supervised and executed in a safe manner. Planning for the safe undertaking of work activities at all our offices is addressed through the office safety plan. This plan may take a number of titles but shall cover the management of health and safety related matters within the premises. The plan will be prepared by the company holding responsibility for the premises, RCG will maintain such records as are within their scope of operations with regard to the building. 4.6.2. Appointment of Competent Persons The Regional Managing Director shall appoint a suitably experienced and competent RCG employee at each regional office as the “Appointed Person - Office Safety” to be responsible for the overall implementation of health and safety management. The competence of personnel shall be determined on the basis of knowledge, experience and training. Form HS/1-02E Appointed Person - Office Safety shall be used to notify and record this appointment prior to work commencing on site. 4.6.3. Office Safety Plan It shall be the responsibility of the ‘Appointed Person – Office Safety’ to ensure that a suitable office safety plan is prepared prior to the occupation of the office and that its requirements are monitored. The plan may include other relevant additional requirements - including any specified landlord requirements - that may be identified and shall incorporate emergency arrangements. Advice with the preparation and content of any aspect of office safety plan may be obtained from the SHEQ Department. 4.6.4. Delegation of Health and Safety Responsibilities


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The ‘Appointed Person – Office Safety’ may delegate health and safety duties to competent members of the office team. The competence of personnel shall be determined on the basis of knowledge, experience and training. A suitable record shall be maintained of any duties delegated, the persons to whom they were delegated, and that persons’ acceptance of that delegation. 4.6.5. Health and Safety Induction 4.6.5.1. Personnel based at an office All personnel based in a RCG office shall undergo an office specific health and safety induction as specified below. Office Specific Induction - Minimum Core Content The ‘Appointed Person – Office Safety’ shall ensure that an office induction is produced which covers the topics detailed below - plus any topics that are additionally relevant to their office environment.

Identification of the ‘Appointed Person – Office Safety’;

Consultation arrangements & forums;

Arrangements for reporting accidents and incidents;

Emergency arrangements – including: o First Aid personnel; o First Aid post; o Fire Alarm; o Fire Marshals; o Emergency evacuation routes; o Emergency Muster Points;

Toilet, canteen and welfare arrangements;

Waste management arrangements;

Housekeeping rules;

Portable appliance testing requirements;

Visual Display Units – workstation assessments.

A record of this induction shall be maintained on HS/1-01 - Induction Record. Where appropriate guidance may be sought from the SHEQ Department. 4.6.5.2. Personnel Visiting an Office All personnel visiting the office shall be required to read the core Office Induction Notice at reception and sign the Visitors Book. Whilst a visitor is within the office the person hosting them shall ensure that they are escorted to safety in the event of an emergency. 4.6.6. Visual Display Unit (VDU) Assessments 4.6.6.1. Overview


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Where employees have to use VDU’s for extended periods of time the employee’s line manager shall organise their work, so far as possible, so that breaks away from the VDU are possible (i.e. provide a change of routine to undertake other department duties). Where employees nevertheless have to spend a significant proportion of their working day (i.e. more than 4-5 hrs per day) using a VDU then that person’s line manager shall ensure that the employee completes a VDU workstation assessment using form HS/1-28 VDU Workstation Assessment and that a further assessment is undertaken whenever the workstation set-up is significantly altered. All assessment reports shall be reviewed by the person’s line manager, and, where there is any doubt concerning the actions required to be taken to manage the risk, consultation with the SHEQ Department shall take place. Actions required to be undertaken shall be agreed with the line manager and implemented. A copy of the assessment shall be retained with the employees training records. 4.6.6.2. Eyesight Tests and Examinations Notwithstanding the requirements of Section 6.6 of the Human Resources Policy and Procedures Manual – which specifies the RCG eye care policy - where a VDU assessment indicates that an eyesight test and examination is appropriate to establish the need for corrective lenses for VDU work then this shall be considered by the Head of Department. If they deem it appropriate the Head of Department shall authorise the eyesight test and examination. If approval for an eyesight test and examination is obtained the employee shall liaise with the Human Resources Department and arrange for the test and examination to be undertaken at Specsavers – who administer the RCG VDU eyesight testing scheme. Vouchers for the test and examination are available only from the Human Resources Department. Specsavers shall identify whether corrective lenses are required for VDU work and indicate the recommended period to the next eyesight test and examination. Where the employee requires corrective lenses solely for VDU work (i.e. Where the eyesight problem is in the range 50cm – 60cm), Specsavers shall issue the employee with a pair of single vision glasses from a specified range. Where an employees’ normal prescription is suitable for DSE work RCG is not responsible for the provision of frames or corrective lenses. 4.6.7. Portable Appliance Testing Portable electrical appliances operated within the office are required to be subject to periodic testing to monitor their electrical integrity. No such appliances shall be permitted to be used where they are over 1 year old and have no Portable Appliance Test (PAT) record. Equipment subject to PAT shall either have durable test records attached in such a way that they may be readily checked in situ, or be so identified that they can be traced back to the relevant test record / testers’ records.


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For hired equipment, the hire company shall provide the above evidence at point of delivery. Where it is not provided the appliance shall be returned unused. Where an appliance is presented as being exempt from PAT requirements on the basis that they are less than 1 year old suitable documentary evidence of that must be provided. Where no documentary evidence is available the equipment shall not be used. 4.6.8. Accident Reporting and First Aid All accidents or incidents involving injury to a RCG employee or visitor are required to be immediately reported to RCG. Injuries shall be attended to by an appropriately qualified first aider – either fully trained or an Appointed Person. Offices shall have the extent of their first aid provision determined by risk assessment. Whilst large offices are likely to have a fully trained first aider(s) small offices may determine that an “Appointed Person” may be sufficient to take charge in a medical emergency. Details of the accident and treatment administered are required to be recorded. This is usually done either by the first aider themselves or someone else dealing with the accident and shall be recorded in a BI 510 Accident Book. Details recorded must include:

Date, time and place of the accident;

Name and job of the injured or ill person;

Details of the injury / illness and what first aid was given;

What happened to the person immediately afterwards (e.g. went back to work, went home, went to hospital);

Name and signature of the first aider or person dealing with the accident. Accidents shall be investigated by an appropriate person and to the extent warranted by the potential consequences of the incident. Where appropriate guidance should be sought from the SHEQ Department.

4.6.9. Notice Boards Notice boards shall be available at each office to publish relevant health & safety information. Minimum elements to be posted are as follows:

Health & Safety Law – What You Should Know Poster;

Certificate of Employers Liability Compulsory Insurance;

Details of First Aiders;

Details of Fire Wardens;

Emergency arrangements in case of fire;

Emergency contact details and Crisis Communications Protocol;

Details of employee representatives & consultation forums – where available. 4.6.10. Health and Safety Records All SHE related documents are required to be stored within the relevant folder structure within Conject and are automatically retained and archived for future reference.


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4.7. Legal and Other Requirements To facilitate compliance with legal and other requirements related to occupational health and safety, RCG maintains a legal register and provides access to key industry guidance. Personnel have access to these via Conject and the internet. Whilst these documents may be used as reference documents by personnel managing risk, the legal register forms part of our Construction Phase Plans and our office safety plans.

Compliance with legal and other requirements is monitored during inspections and audits. Management arrangements governing inspections and audits are provided at Section 5 – Checking and Corrective Action, below. 5.0 IMPLEMENTATION AND OPERATION 5.1. Overview Our organisational and work planning processes are developed to ensure we effectively deliver our policy objectives. The efficacy of these processes shall be routinely monitored and their application reviewed to ensure we continue to work within an effective organisational structure for the business - and apply appropriate procedural, administrative and physical control within our workplaces. To this end RCG shall ensure an organisational structure is in place which takes into account the following factors:

Competence of individual personnel;

Effective allocation of roles & responsibilities;

Allocation of sufficient resources. Development of an appropriate organisational structure within RCG shall be the responsibility of the RCG Board. Development of an appropriate regional organisational structure shall be the responsibility of the Regional MD. 5.2. Individual Competence Personnel should be trained in line with the guidelines contained within form HS/1-29 - SHE Training Matrix. Any person intending to allocate a health or safety related role or responsibility should ensure that the person to be allocated that role or responsibility is competent to do so. Persons allocating roles or responsibilities should not allocate those roles or responsibilities to personnel who have not been suitably trained. Courses within the shall be used as guidelines to determine suitable training. Competence shall be determined on the basis of knowledge, experience and training. Ensuring an individual’s health and safety training is organised and delivered shall be the responsibility of that person’s line manager.


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Any person, on being notified of the allocation of a health or safety role or responsibility for which they have not been trained or feel they are not competent to fulfill, should notify the person allocating that role or responsibility of their lack of training or competence. No change to, or cancellation of, a health and safety training course shall be permitted without the prior written authorisation of the relevant Regional MD or business head. An email shall be an acceptable form of written authorisation. The Regional MD or business head shall ensure that effective arrangements are in place for monitoring that personnel within their business are being trained in accordance with the SHE Training Matrix guidelines. The head of the SHEQ Department shall ensure a suitable SHE Training Matrix is published for the business. 5.3. Roles, Responsibilities & Resources The nature of our business, with vastly different project sizes and scopes of work, dictates that individual job titles, and their meaning, is variable across the business. Function specific roles and responsibilities at project level shall be defined within the Schedule of Individual Management Responsibilities contained at Section 2 of the project Construction Phase Health and Safety Plan. Responsibility for ensuring that this has been done shall lie with the ‘Appointed Person – Site Safety’ – who has overall responsibility for health and safety on the project.

In general terms personnel shall be deemed to have the roles and responsibilities defined below. Where an individual’s job title is not indicated then the roles and responsibilities shall be deemed to be those of the most similar job title. Key health and safety roles and responsibilities are as follows: 5.3.1. RCG Board The RCG Board provides strategic direction and leadership to group companies and takes collective responsibility for decisions made. The RCG Managing Director (Scotland) is the nominated health and safety champion for the businesses within the sphere of their responsibility and reports to the Robertson Group Chief Operating Officer on health and safety matters. The RCG Managing Director (England) is the nominated health and safety champion for the businesses within the sphere of their responsibility and reports to the Robertson Group Chief Operating Officer on health and safety matters. Members of the RCG Board have health and safety responsibilities as follows: 5.3.1.1. Collective Responsibilities Ensure a suitable Health and Safety Policy is in place for RCG. Ensure an appropriate organisation and arrangements are in place to secure:

The health and safety of RCG employees;


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The health and safety of others who may be affected by how RCG employees conduct their undertakings;

The RCG health and safety policy commitments;

Any health and safety commitments specified by Robertson Group. Monitor that there is a sufficient allocation of competent personnel and resources, within a suitable organisational structure, to secure Robertson Group and RCG aims, objectives and statutory obligations. Monitor that any subsidiary company / business under their control has an appropriate policy, organisation and arrangements in place to secure:

The health and safety of their employees;

The health and safety of others who may be affected by how they conduct their undertakings;

The RCG health and safety policy commitments;

The Robertson Group health and safety policy commitments. (Note – Where a subsidiary company / business under their control can operate effectively under the RCG policy then they may do so provided it is relevant to their business and a suitable organisation and arrangements are in place and communicated to their workforce.)

Provide clear health and safety related direction and leadership to subsidiary companies of RCG – including inclusion of health and safety related Key Performance Indicators (KPI’s) within business plans. Monitor health and safety performance both in general terms and in terms of specified KPI’s. Monitor that a review of all elements of the policy, organisation and arrangements takes place on an annual basis and make any amendments deemed appropriate. 5.3.1.2. Individual Responsibility Discharge specific duties set out within supporting documentation and their job description. Demonstrate a personal commitment to health and safety by example and encourage others to do likewise. Ensure the person in charge of health and safety in any workplace is made aware of changes in circumstances which they believe significantly compromises the efficacy of the organisational structure or set of arrangements in place to secure delivery against:

Health and safety related statutory provisions;

Commitments within the RCG Health and Safety Policy. 5.3.2. RCG Managing Directors Overall responsibility for health and safety within the elements of RCG activities within their sphere of influence. Reporting to the Robertson Group Chief Operating Officer with specific responsibility to:

Ensure policy commitments and other requirements specified by Robertson Group are implemented within RCG;

Endorse the personal and organisational commitment to health and safety by co-signing the RCG Health and Safety Policy;


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Ensure a sufficient allocation of competent personnel and resources, within a suitable organisational structure, to secure the Robertson Group and RCG aims and objectives;

Report on health and safety matters to the Robertson Group;

Demonstrate a personal commitment to health and safety by example and encourage others to do likewise;

Discharge specific duties set out within supporting documentation and their job description.

5.3.3. Regional Managing Directors Delegated responsibility for health and safety within their Region and any businesses within their sphere of influence. Reporting to one of the RCG Managing Directors with specific responsibility to:

Ensure a suitable Health and Safety Policy is in place within their Region. (Whilst this will

usually be the Robertson Construction Group Health and Safety Policy – particularly for the construction businesses – that general policy may be supplemented, as appropriate, at individual business level.);

Ensure a sufficient allocation of competent personnel and resources, within a suitable organisational structure, to secure Robertson Group, RCG and Regional aims and objectives;

Ensure the Region, and any businesses under their sphere of influence, have access to competent health and safety advice;

Make suitable arrangements for the monitoring, review and improvement of health and safety performance across the Region;

Make suitable arrangements for the investigation of accidents and incidents across the Region;

Attend the Directors SHE Forum.

Ensure a regional health and safety forum operates within their Region;

Delegate responsibility for management of health and safety at each workplace to competent personnel;

Ensure their RCG Managing Director and the head of the SHEQ Department are made aware of changes in circumstances which they believe significantly compromises the efficacy of the Regional organisational structure or set of arrangements in place to secure the RCG aims and objectives;



5.3.4. Head of Department - SHEQ Delegated responsibility for health and safety within RCG. Reporting to the Robertson Group Chief Operating Officer with specific responsibility to:

Provide a lead and focus on SHE matters across the business;

Ensure the relevant elements of the Safety, Health and Environment Management System (OHSMS and EMS) are accredited under the requirements of ISO 14001 and BS EN 18001 respectively;

Ensure SHE performance across the business is monitored;

Report on SHE matters to the Robertson Group Chief Operating Officer;

Monitor that a suitable organisational structure and arrangements are in place to secure aims and / or objectives set at Robertson Group and RCG levels;


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Ensure suitable policy statements are in place in relation to (i) Health & Safety and (ii) Environmental Management respectively;

Ensure the RCG Managing Directors and the Robertson Group Chief Operating Officer are made aware of changes in circumstances which they believe significantly compromises the efficacy of the organisational structure or set of arrangements in place to secure the Robertson Group and / or RCG aims and objectives;

Review the content of health and safety related policies, procedures and documents, and make any amendments or updates considered necessary;

Ensure prompt dissemination of any new requirements following revision of Robertson Group or RCG health and safety policies, procedures or related documents;



5.3.5. Quality Managers Delegated responsibility for health and safety within RCG. Reporting to the Head of Department – SHEQ, with specific responsibility to:

Publish the OHSMS on the supporting IT platforms;

Manage SHEQ related audits across the business;

Ensure the relevant elements of the Safety, Health and Environment Management System (OHSMS and EMS) are accredited under the requirements of ISO 14001 and BS EN 18001 respectively;



5.3.6. Group SHE Manager Delegated responsibility for health and safety within RCG. Reporting to the Head of Department - SHEQ with specific responsibility to:

Provide a lead and focus on SHE matters across the business;

Liaise with senior management across and within RCG to ensure, so far as is reasonably practicable, that the SHEQ Department delivers a level of service that meets the needs and aspirations of the regional businesses and RCG.

Manage the workload of the Regional SHE Managers in line with those needs and aspirations;

Ensure SHE performance across the business is monitored;

Report on SHE matters to the RCG Managing Directors;

Monitor that a suitable organisational structure and arrangements are in place to secure aims and / or objectives set at Robertson Group and RCG levels;

Ensure that site visits are undertaken by health and safety professionals, or other competent personnel, at a frequency which reflects the hazards and risks associated with work activities – and no less frequently than once per month;

Attend the Directors SHE Forum;

Ensure suitable policy statements are presented to the RCG Managing Directors for approval in relation to (i) Health & Safety and (ii) Environmental Management respectively;


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Ensure a suitable SHE Training Matrix is published for the business;

Monitor & review the content of the SHE Training Matrix to ensure that it remains relevant to the needs of the business;

Ensure the RCG Managing Directors and the Robertson Group Chief Operating Officer are made aware of changes in circumstances which they believe significantly compromises the efficacy of the organisational structure or set of arrangements in place to secure the Robertson Group and / or RCG aims and objectives;

Review the content of health and safety related policies, procedures and documents, and make any amendments or updates considered necessary;

Ensure prompt dissemination of any new requirements following revision of Robertson Group or RCG health and safety policies, procedures or related documents;



5.3.7. SHE professionals providing services to RCG Delegated responsibility to provide health and safety advice to, and support, personnel across the business - with primary responsibility to do so within specified geographic areas. Reporting the Group SHE Manager, with specific responsibility to:

Provide advice, guidance and support as required by personnel within RCG as directed by the Group SHE Manager. Primary responsibility shall be to the businesses operating within the geographic area within which they are based – however the provision of services to others may be required as directed by the Group SHE Manager.


Carry out visits to sites, and investigate accidents, incidents, near misses and dangerous occurrences - and prepare reports on the same;

Monitor that health and safety policies are being adhered to, that prescribed procedures are being followed, and that legislative requirements are being met;

Monitor the efficacy of existing arrangements for the management of health and safety;

Report on findings of monitoring activities via prescribed reporting tools;

Report on findings of investigations in the manner prescribed within the relevant procedures;

Ensure that site visits are undertaken at a frequency which reflects the hazards and risks associated with work activities – and not less than once per month;

Identify and report improvement opportunities;

Ensure the Regional MD and Head of Department – SHEQ are made aware of changes in circumstances which they believe significantly compromises the efficacy of the organisational structure or set of arrangements in place to secure the Robertson Group, RCG or Regional aims and objectives;

Report to the Regional MD and Head of Department – SHEQ re Regional performance; serious incidents; and matters which may have implications for Region, RCG, or others within the Robertson Group;

Monitor that personnel are being trained in accordance with the SHE Training Matrix guidelines and report non compliances to the Regional MD and Head of Department – SHEQ;


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Report on health and safety matters to the Regional MD and Head of Department – SHEQ using the prescribed reporting mechanisms and tools;


5.3.8. Senior Managers Note: These are personnel in positions above the site management team.

Delegated responsibility for health and safety at projects or workplaces under their control. As the size and nature of workplaces or projects is variable then so the organisation and arrangements required to secure the Regional, RCG and Robertson Group aims and objectives is required to be variable. Senior Managers have specific responsibility to:

Ensure a sufficient allocation of competent personnel, within a suitable organisational structure and set of arrangements, to secure the aims and objectives at the workplace;

Ensure that appropriate control documents – including, but not necessarily limited to, the Health and Safety Plan, a Traffic Management Plan and a Fire Plan HS/4 - are in place prior to commencement of work activities at the workplace;

Ensure site responsibilities for health and safety related matters have been clearly and appropriately designated to competent personnel prior to commencement of work activities at the workplace;

Ensure the Regional MD is made aware of changes in circumstances which they believe significantly compromises the efficacy of the organisational structure or set of arrangements in place to secure health and safety at the workplace;



5.3.9. Project / Site Managers Delegated responsibility for health and safety during site operations. Will normally have overall responsibility for health and safety at their project / site. Where there is more than one Project / Site Manager on a project one of them will be nominated as the ‘Appointed Person – Site Safety’. The ‘Appointed Person – Site Safety’ may delegate duties, but not overall responsibilities, for specific elements of health and safety management on site. Project / Site Managers have specific responsibility to:

Manage workplace activities to the extent delegated by the Senior Manager;

Ensure the Senior Manager is made aware of changes in circumstances which significantly compromise the efficacy of the organisational structure or set of arrangements in place to secure health and safety at the workplace;

Ensure relevant procedures set down within the OHSMS are followed;




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5.3.10. Site Supervisors Delegated responsibility for specific site related operations by the ‘Appointed Person – Site Safety’. Site Supervisors have specific responsibility to:

Supervise site activities to the extent delegated by the ‘Appointed Person – Site Safety’;

Ensure the ‘Appointed Person – Site Safety’ is made aware of changes in circumstances which significantly compromise the efficacy of the organisational structure or set of arrangements in place to secure health and safety on site;



5.3.11. ‘Appointed Person – Office Safety’ Note: This applies to non site-based offices only. Office safety on site is the responsibility of the ‘Appointed Person – Site Safety’.

Delegated responsibility for office safety. ‘Appointed Person – Office Safety’ have specific responsibility to:

Ensure that appropriate control documents (e.g. building manuals, fire safety plans, emergency evacuation plans, electrical portable appliance testing) and arrangements are in place and kept up to date;

Ensure safety matters related to office personnel and equipment have been addressed;


Discharge specific duties delegated within supporting documentation and their job description.

5.3.12. All Employees Specific responsibility to:

Take reasonable care both of their own safety and that of those who may be affected by their acts or omissions;

Co-operate with RCG, as their employer, with respect to any matters relating to safety, health and welfare, and to take care of and not abuse any property provided for this purpose;

Notify any person allocating a role or responsibility to them, if they feel they are not competent to discharge that role or responsibility, of that lack of competence;

Discharge specific duties delegated within supporting documentation and their job description.

6.0 CHECKING AND CORRECTIVE ACTION 6.1. Overview The monitoring and measurement of health and safety performance, and use of appropriate corrective actions and controls, are a critical elements in our management processes and form the basis upon which improvement plans are based.


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Performance measurement takes various forms and is aimed at either:

Health and safety performance;

Health and safety compliance; or

Exposure to a hazardous substance or occupational health hazard. Performance monitoring takes various forms, both formal and informal, and non-compliances give rise to the use of various forms of intervention and control measures. These may be used to benchmark performance or establish if a prescribed standard has been met. 6.2. Performance Measurement 6.2.1. Measurement of Health and Safety Performance & OHSMS Compliance Performance measurement against legal and OHSMS requirements is undertaken formally during the following processes:

Site/workplace inspections undertaken by SHEQ professionals;

Site/workplace inspections undertaken by directors and senior managers;

Workplace internal audits;

Review of sub-contractor performance at package completion;

Considerate Constructors Scheme (CCS) monitors’ visits. Formal measurement of overall site performance is undertaken via:

The scoring mechanism defined within the HS/1-30 SHE Inspection Report used by SHE professionals, directors and senior managers;

The percentage compliance with legal and OHSMS requirements derived during internal audits;

The scoring mechanism defined for the evaluation of sub-contractors overall performance on site;

The scoring mechanism within the CCS reporting tool. SHE Inspection Report scores are derived on the basis of the observers evaluation of where, within the range of potential scores detailed below, a site is performing over a number of topic areas – with a discretionary adjustment in the overall score of plus or minus 5% to facilitate adjustment for overall impression of a project’s performance. Topic and overall project scores shall be provided in the following ranges:

>79% = Highly Satisfactory;

70 - 79% = Satisfactory;

41 - 69% = Unsatisfactory;

0-40% = Highly Unsatisfactory Scores allocated shall be at the sole discretion of the person undertaking the inspection. The Group SHE Manager shall ensure that a suitable audit programme is developed to ensure all live sites are audited at least once during their duration. These audits shall incorporate use of the audit question sets which are valid within RCG at the time of the audit. The ability to demonstrate compliance or otherwise in response to the applicable question sets shall be used to derive a percentage compliance score for the project.


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The ‘Appointed Person – Site Safety’ shall conduct an ongoing review of the performance of the sub-contractors working on site which incorporates a specific section for measurement of health and safety performance. Measurement of performance under the CCS shall be the one specified by CCS and shall be at the sole discretion of the CCS monitor. 6.2.2. Measurement of Exposure to a Hazardous Substance Characteristics measurement is used to determine either the presence of a hazardous substance or the level of exposure to a hazardous substance. Where characteristics measurements are to be carried out the ‘Appointed Person – Site Safety’ shall ensure that:

Any characteristics measurement is carried out by personnel who are competent to do so. Competence being determined on the basis of knowledge, experience and training.

Monitoring equipment is appropriately calibrated.

Where external bodies are to carry out characteristics measurement - that written verification is obtained which demonstrates that those organisations are, as appropriate, properly accredited. (e.g. by UKAS)

Appropriate records shall be maintained within Conject of all characteristics measurements undertaken.

6.3. Performance Monitoring Performance monitoring is undertaken both formally and informally. Informal monitoring is undertaken routinely by sub-contractor and RCG supervisors and managers during co-ordination and supervision of work activities and work planning. The findings of these monitoring activities do not have to be formally recorded unless they give rise to matters which require formal intervention. The frequency and nature of formal monitoring is subject to review within the scope of the overall risk profile for the business – however in general terms it is undertaken by the personnel identified below, at the frequency specified and using the tools prescribed. The forum for initial review of findings are as specified below. Formal monitoring, and where appropriate a review of their findings, is undertaken via the following means. 6.3.1. Inspection and audits by SHE professionals Visits by SHE professionals may be for the purposes of either inspection or audit. 6.3.1.1. Inspection A construction site inspection shall be carried out on all live sites with significant works ongoing - a minimum of once per month, recorded on form HS/1-30 - SHE Inspection Report and posted within Conject. An office inspection shall be carried out a minimum of once every 12 months, recorded on the SHE Inspection Report and posted within Conject.


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Where form HS/1-30 is available as an on-line, direct input, form within Conject that medium should ideally be used to record the findings of such an inspection. A review of close-out of the matters raised at the previous inspection shall be conducted as part of the current inspection. A review of significant matters raised during inspections shall be undertaken at monthly management meetings at regional (HS/1-21B SHE Meeting Agenda & Minutes – Monthly Regional Meeting) and RCG levels (HS/1-21C SHE Meeting Agenda & Minutes – Directors SHE Forum). 6.3.1.2. Audit

A construction site audit shall be conducted a minimum of once per project and recorded on the audit report within Conject. An office audit shall be conducted a minimum of once every 12 months and recorded on the audit report within Conject. A review of significant matters raised during audits shall be undertaken at monthly management meetings at regional and RCG levels. A review of close-out of the matters raised at the previous audit shall be conducted as part of the current audit.

6.3.2. Inspections by regional directors and senior managers Visits by regional directors and senior managers shall be for the purpose of inspection. Every site shall be inspected by one of the regional senior management team a minimum of once every 3 months, recorded on form HS/1-30 - SHE Inspection Report and posted within Conject. A review of close-out of matters raised at the previous inspection shall be conducted as part of the current inspection; A review of significant matters raised during inspections shall be undertaken at monthly management meetings at regional and RCG levels. 6.3.3. Inspections by site management A weekly inspection shall be carried out by site management, recorded on form HS/1-31 - Site Managers SHE Checklist and posted within Conject. A review of close-out of matters raised at the previous inspection shall be conducted as part of the current inspection. A review of significant matters raised during inspections shall be undertaken at the weekly project review meeting. In addition function specific monitoring by the site management team shall be undertaken in line with duties specified within the Schedule of Individual Management Responsibilities at Section 2 of the Construction Phase Plan.


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A review of significant matters raised during function specific monitoring shall also be undertaken at the weekly project review meeting. Arrangements for the annual, strategic level, performance review is contained at Section 6. 6.3.4. Protocols surrounding monitoring activities 6.3.4.1. Inspections Site or office inspection visits by a visiting SHE professional, director or member of the regional senior management team may be either by arrangement or unannounced. Where such an inspection has taken place the person conducting the inspection shall:

Before leaving the site or office – discuss the findings of the visit with the most senior site representative on site or within the office at the time – usually the ‘Appointed Person – Site Safety’ or the ‘Appointed Person – Office Safety’ – and will include details of:

o Overall performance; o Good practice noted; o Significant non-compliances noted; o Non Conformance Reports (NCR’s) and Opportunities For Improvement

(OFI’s) which are to be raised.

As soon as practicable after the inspection raise those NCR’s and OFI’s on Conject;

As soon as practicable after the inspection post an inspection report on Conject - with notification to appropriate personnel;

Follow up any NCR’s and OFI’s raised in relation to the inspection to monitor that they are closed out.

o Where NCR’s and OFI’s are not closed out to their satisfaction they shall be raised by the inspector with the region’s senior management team.

The ‘Appointed Person – Site Safety’ or ‘Appointed Person – Office Safety’ shall ensure that the matters raised within the inspection report are rectified and any NCR’s and OFI’s are closed-out on Conject. Where appropriate they should liaise with the inspector to ensure the matters have been closed-out to the inspector’s satisfaction. Senior management personnel who have been issued with a copy of the inspection report shall be responsible for:

Making appropriate enquiries to ascertain the immediate, underlying and root causes which led to the significant non-conformances arising;

Taking appropriate steps to address any shortcomings which are within their powers to address, to minimise the likelihood of a recurrence.

6.3.4.2. Audits

Overview The audit process shall provide the means of periodic monitoring and evaluation of regulatory and OHSMS compliance. OHSAS 18001 system audits shall be planned and carried out in accordance with the schedule contained within the SHE Business Plan. Audit visits shall be announced in advance and follow the protocols set out below. Audit Protocol The auditor shall:


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Make an appointment with auditee – usually the ‘Appointed Person – Site Safety’ or ‘Appointed Person – Office Safety’ – and agree when the audit will be undertaken;

Conduct an introductory meeting to ensure the auditee understands the audit process;

Carry out the audit by way of seeking evidence that the matters raised on the audit checklist - which is prescribed for that purpose by RCG – have been complied with to the satisfaction of the auditor;

Hold a close-out meeting with the auditee at which they shall inform them of: o The audit score; o Any non-conformances noted; o The tools are to be used to highlight the non-conformances; (e.g. What NCR’s and

OFI’s are to be issued, to whom, and when they require to be closed out.)

o How they may be closed out;

As soon as practicable after the audit issue any NCR’s and OFI’s via Conject in accordance with those described in the close-out meeting;

As soon as practicable after the audit prepare an audit report and publish on Conject – with notification to appropriate personnel;

Follow up any NCR’s and OFI’s raised in relation to the audit to monitor that they are closed out.

o Where NCR’s and OFI’s are not closed out to their satisfaction that shall be raised by the auditor with the region’s senior management team.

The ‘Appointed Person – Site Safety’ or ‘Appointed Person – Office Safety’ shall ensure that the matters raised within the audit report are rectified and any NCR’s and OFI’s are closed-out on Conject. Where appropriate they should liaise with the auditor to ensure the matters have been closed-out to the auditor’s satisfaction. Senior management personnel who have been issued with a copy of the audit report shall be responsible for:

Making appropriate enquiries to ascertain the immediate, underlying and root causes which led to the significant non-conformances arising;

Taking appropriate steps to address any shortcomings which are within their powers to address, to minimise the likelihood of a recurrence.

6.3.4.3. Non-Conformances Non-conformances and opportunities for improvement may be raised by an inspector or auditor during either an inspection or an audit. ‘Tasks’ within Conject may be raised as a ‘Non Conformance Report - Major’ (NCR - Major); ‘Non Conformance Report - Minor’ (NCR - Minor‘); or an 'Opportunity For Improvement’ (OFI). Circumstances where these shall be raised are as follows: NCR - Major An NCR - Major shall be raised when, in the opinion of the inspector or auditor, there has been a significant non-conformance with RCG standards or requirements. The inspector or auditor is the sole arbiter of whether a non-conformance is major or minor. As RCG requirements have been developed to at least meet the minimum legal requirements – an NCR - Major should typically be issued where there is:

A significant breach of health and safety related legislation; or

A lapse in compliance which places personnel at risk of significant injury or harm. A lapse in compliance which places personnel at risk of a major ill health effect -

either in the long or short term; (e.g. exposure to airborne asbestos fibres, regular prolonged exposure to

noise or vibration, regular prolonged exposure to lead, regular prolonged significant exposure to carcinogens etc)


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Matters giving rise to a significant risk of serious environmental pollution. (e.g. fires on site

giving rise to air pollution, discharge to watercourses, major spillages of hazardous materials, major noise pollution outside agreed hours, major air pollution through dusts blowing off-site etc).

A significant breach of published RCG requirements. (e.g. Robertson Guidance Note

requirements, procedural requirements specified within this document, emailed or other published instruction related

to SHE standards etc.) or NCR - Minor An NCR - Minor shall be raised when, in the opinion of the inspector or auditor, there has been a noteworthy minor non-conformance with RCG standards or requirements. The inspector or auditor is the sole arbiter of whether a non-conformance is major or minor. An NCR - Minor should be issued for any noteworthy non-conformance which does not constitute an ‘NCR – Major’. OFI An OFI shall be raised when, in the opinion of the inspector or auditor, the current safeguards being adopted or proposed meets the current RCG standard or requirement – but there is an opportunity to apply a potentially higher or improved alternative standard:

Than is currently being adopted; or

That is proposed for planned future work activities. An OFI may therefore act as a tool by which to highlight improvements in current good and best practice. Where an OFI is issued by an inspector or auditor - detailed guidance shall accompany it. A recommendation within an OFI does not have to be followed by an ‘Appointed Person – Site Safety’ or ‘Appointed Person – Office Safety’ – however they should liaise with senior management to discuss the possible application of the recommendation and close out the OFI on Conject accordingly. 6.3.4.4. Close-out of NCR’s & OFI’s Monitoring the close-out of NCR’s and OFI’s forms an integral part of our management process. The status of tasks linked to the closure of NCR’s and OFI’s within Conject may be monitored by anyone who has ‘access’ rights to run those reports. Access is typically granted to senior management personnel, but may be allocated to anyone who the Regional MD wishes to have access, and is administered by the regional Conject administrator. It shall be the responsibility of the ‘Appointed Person – Site Safety’ to monitor tasks allocated to personnel at their workplace and ensure that they have been actioned and closed out within the specified timeframes. It shall be the responsibility of any person allocated a ‘task’ within Conject to ensure that:

The ‘task’ is suitably actioned. (i.e. NCR - Action is taken to remedy the non-conformity identified within

the ‘task’ or OFI - the suggested OFI is to be implemented.)

The status of action taken to close out the ‘task’ is recorded within the task management system and appropriate personnel are notified via Conject notification. (i.e. The status of corrective action taken should be modified timeously to highlight whether remedial actions have been ‘Actioned’ or are ‘Verified and Closed’. Where a non-conformity associated with a ‘task’ may require some time to rectify - but the remedial action has been actioned - then the status should be recorded as ‘Actioned’. Where actions are quickly remedied ‘Verified and Closed’ supporting evidence such as photographs should be attached.)

The ‘task’ is closed out within the specified timeframes.


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It shall be the responsibility of the line manager of the ‘Appointed Person – Site Safety’ to:

Monitor tasks allocated to the site;

Make enquiries where there are significant failings;

Take appropriate remedial actions to rectify any shortcomings;

Raise the matter with the Regional Director as appropriate. It shall be the responsibility of the Regional Director to:

Take appropriate action where matters are brought to their attention;

Periodically monitor tasks allocated to personnel within their Region;

Make enquiries where there are significant failings;

Take appropriate remedial actions to rectify any shortcomings. It shall be the responsibility of the Head of Department – SHEQ to monitor tasks allocated across the Regions, make enquiries where there are significant failings and recommend remedial actions to rectify any shortcomings. 6.4. Control Control shall be exercised through a combination of the use of management system tools and direct personal intervention. The main forms of control shall involve:

Compliance with the requirements of the OHSMS;

Direct intervention;

Use of appropriate management system tools – including use of the disciplinary system.

Control shall be exercised, in the first instance, through compliance with the requirements of the RCG OHSMS. Control should then be exercised by the person supervising the work activity, or others as appropriate, directly intervening where non compliances are encountered. Details surrounding empowerment of individuals to intervene wherever they encounter unsafe acts or unsafe conditions are detailed within the RCG Induction. Where serious non compliances are encountered, or personnel involved in work are ignoring an intervention, then these matters should be brought to the attention of the RCG supervisory or management team. Where appropriate RCG shall exercise control through use of the disciplinary system. 7.0 MANAGEMENT REVIEW 7.1. Overview Health and safety performance review forms an integral part of the management process and takes place at several levels within the business. This section identifies the key review forums and processes and explains how they fit within the overall health and safety management structure of the business.


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7.2. Management review On-going review of SHE matters shall be maintained through the Directors SHE Forum. The Directors SHE Forum shall normally meet every 2 months to:

Review matters raised at previous meetings;

Review SHE performance across the business;

Share good practice;

Receive, review and approve updates to internal documents and policies. The standard agenda for the Directors SHE Forum is contained on form HS/1-21C SHE Meeting Agenda and Minutes – Directors SHE Forum. Where the Directors SHE Forum feels that the company would be exposed to risk through a failure to effect an update to the OHSMS, or other published material, the Directors SHE Forum shall require amendment to the OHSMS or that other published material. The Head of Department – SHEQ shall be responsible for enacting any change to the OHSMS. Where, between the Directors SHE Forum meetings, the Head of Department – SHEQ feels the company is exposed to risk through a failure to effect an immediate update to the OHSMS or other published material then the Head of Department – SHEQ shall ensure that an appropriate update is published. Minutes / Action Points of the Directors SHE Forum meetings shall record:

Any ‘actions’ required;

Those responsible for taking those ‘actions’;

Timescale within which ‘actions’ shall be taken; The format associated with any ‘action’ (e.g. RGN, procedural change, new procedural document etc.)

A formal management system review shall be carried out at least once in every 12 month period. This shall be chaired by the Head of Department – SHEQ and be attended by members of the senior management team.

7.3. Monthly Reports Each month a SHE professional, nominated by the Head of Department – SHEQ, shall compile a Regional SHE report on a prescribed format and forward it to:

Head of Department – SHEQ;

Regional MD. The report shall be submitted within 3 working days of the start of the next reporting period. From these reports, the Head of Department – SHEQ shall prepare a consolidated monthly report on a prescribed format for the:

Robertson Group Chief Operating Officer;

RCG Managing Director (Scotland);

RCG Managing Director (England). The report shall be prepared in accordance with the timetable prescribed by the Robertson Group Chief Operating Officer. 7.4. Annual Reports


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At the end of the reporting year the Head of Department – SHEQ shall produce a report which consolidates SHE performance over the reporting year. This report shall be provided to the:



RCG Managing Director (England). The Annual Report shall be discussed as an item at the next Directors SHE Forum meeting following its publication.

7.5. Continuous Improvement Mechanisms for achieving continuous improvement are reviewed as part of the management review process. SHE objectives and targets shall be drafted by the Head of Department – SHEQ, included in a draft SHE Business Plan and presented for approval to the:



RCG Managing Director (England). The objectives and targets within the Plan shall be consistent with the requirements of the Health and Safety Policy and the Environmental Policy respectively. Targets shall be measurable and quantified wherever possible, and may be expressed as SHE Key Performance Indicators (KPI's) All methods of monitoring, measuring and reporting performance, along with time-scales for achievement, shall be documented. The Plan shall be published by the Head of Department – SHEQ once it has been approved by:



RCG Managing Director (England).

7.6. Review of Legislative Requirements & Good Practice RCG uses the CITB publication GE 700 and access to online information systems to provide standard reference material in relation to legislative requirements and good practice. Supplementary guidance material is also made available through a variety of sources as detailed below. The Head of Department – SHEQ shall ensure that:

Pollution Prevention Guidelines are downloaded from the SEPA or EA website and made available to personnel via the IT platform which houses the OHSMS;

Robertson Guidance Notes (RGN’s) are developed and published either within the OHSMS or via the IT platform which houses the OHSMS.

In addition RCG periodically publishes topic specific procedures which supplement the general requirements of this procedure. (e.g. Scaffolding, Fire safety etc.) Where such procedures are produced the Head of Department – SHEQ shall ensure that they are published as part of the OHSMS.


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In order to ensure RCG is aware of SHE legislative requirements, and incorporates good practice into our working practices, the Head of Department – SHEQ shall:

Monitor forthcoming health, safety or environmental legislative changes;

Monitor the publication of ACoP's, guidance and best practice;

Recommend actions, and associated timeframes for implementation to ensure continued legislative compliance, to the:

o Robertson Group Chief Operating Officer; o RCG Managing Director (Scotland); o RCG Managing Director (England); o Directors SHE Forum.

Ensure that any update of RGN’s, or other guidance material, is published within the OHSMS timeously and relevant personnel are made aware of the updates.

7.7. Change Management 7.7.1. Overview RCG seeks the continuous improvement in the efficacy of our OHSMS and encourages and empowers our personnel to actively engage in its further development. The Head of Department – SHEQ may at any time update any element of the OHSMS to reflect:

Minor changes required as a result of: o The findings of an accident or incident investigation; o The findings of monitoring activities; o Suggestions from OHSMS users.

Legislative changes;

The result of an annual review;

Changes directed by the: o RG Chief Operating Officer; o RCG MD (Scotland); or o RCG MD (England).

Potential changes to any element of our OHSMS which may have significant implications - whether to a new or existing procedure, document or form - may also be instigated by anyone in the business via the process outlined below. All proposals shall, in the first instance, be agreed within the region or business before being formally drafted for submission and consideration by the wider business. 7.7.2. Stage 1 – First Draft The originator of a potential new or updated procedure, document or form shall:

Discuss their proposal with the lead SHE professional for their region or business. This discussion shall consider whether any proposed amendment will secure / continue to secure compliance with RCG requirements, legislative requirements and/or good practice.

o The SHE professional shall, where appropriate, discuss the proposal with the Group SHE Manager before providing definitive advice to the originator;

Taking those discussions into account - submit an outline proposal for change to their regional SHE forum for discussion and agreement.

Following agreement within the regional SHE forum – prepare a first draft of the proposal which reflects the considered view of the region.


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Forward the first draft to member of that regions’ team on the Directors SHE Forum. That member to be nominated by the Regional MD.

The nominated member of that regions’ team on the Directors SHE Forum shall act as the sponsor of that change on behalf of that region – and shall:

Circulate the first draft to all members of the Directors SHE Forum for comment – providing a schedule for when responses from other regions are required by.

o The minimum time allowed for comment is that which allows each region time to circulate to members of their respective SHE forums for consideration before that forum meets - and facilitates them being able to provide a considered and consolidated view as an outcome from that region at their SHE forum.

That feedback shall be provided to the sponsor by a nominated Directors SHE Forum member from each region. That member shall be nominated by the Regional MD.

7.7.3. Stage 2 – Second Draft The sponsor of the change shall then:

Ensure consideration is given to the input from other regions and produce a second draft for discussion and potential endorsement by the Directors SHE Forum.

Endorsement by the Directors SHE Forum shall be either: o On the basis of circulation and agreement of the second or subsequent drafts

by members of the Directors SHE Forum; or o Final amendment and endorsement taking place at a Directors SHE Forum

meeting. 7.7.4. Implementation within OHSMS On final agreement across the Directors SHE Forum the proposal shall be submitted to the Head of Department – SHEQ, who shall submit it for ratification to:

RG Chief Operating Officer;

RCG MD (Scotland); and

RCG MD (England). These executives shall:

Determine whether the proposed change is to be ratified;

Determine the timescale for implementation across the business;

Direct the Head of Department – SHEQ in relation to the above. If ratified for inclusion within the OHSMS, the Head of Department – SHEQ shall:

Ensure the proposal is appropriately named and numbered within the suite of OHSMS documents;

Ensure the proposal is published as part of the OHSMS;

Ensure the business is notified of any implementation timetable associated with the update.

8.0 DOCUMENTATION 8.1. Overview All forms and any associated guidance and procedures are available via the on-line facilities within Conject


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8.2. Forms, Supplementary Procedures, Documents & Guidance 8.2.1. Procedures within the Occupational Health and Safety Management

System (OHSMS) The following are the procedures within the OHSMS.

HS/1 Core health and safety procedure – this document

HS/2 Health and Safety Policy, Organisation and Arrangements

HS/3 Construction Phase Plan

HS/4 Fire Plan

8.2.2. Documents & Template Forms within the Occupational Health and Safety

Management System The following are standard template forms or documents for use across RCG. To return to the section in the document you were viewing press ALT and the left arrow key on the keyboard.

HS/1-01 Induction Record

HS/1-02A Appointed Person – Site Safety

HS/1-02B Appointed Person – Lifting Operations

HS/1-02C Appointed Person – Temporary Works Manager

HS/1-02D Appointed Person – Temporary Works Co-ordination

HS/1-02E Appointed Person – Office Safety

HS/1-03A Yellow Card

HS/1-03B Yellow Card – Letter to employer

HS/1-04A Red Card


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HS/1-04B Red Card – Letter to employer

HS/1-05A Incident Reporting Flowcharts

HS/1-05B Near Miss Report

HS/1-05C Incident Report – Operations Team

HS/1-05D Incident Report – SHE Professional

HS/1-05E Witness Statement Form

HS/1-06 Temporary Works Flowchart

HS/1-07 Temporary Works – Work Experience Matrix

HS/1-08 Schedule of Temporary Works – Pre Construction

HS/1-09 Schedule of Temporary Works – Construction

HS/1-10 Schedule of Temporary Works – Specific Design

HS/1-11 Temporary Works – Authorisation to Proceed

HS/1-12A Inspection Register – Scaffolding

HS/1-12B Inspection Register – Excavations

HS/1-12C Inspection Register – LOLER

HS/1-12D Inspection Register – PUWER

HS/1-13 Lift Plan Checklist

HS/1-14A Permit to Work – Groundworks


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HS/1-14B Permit to Work - Confined Space Entry

HS/1-14C Permit to Work - RGN4

HS/1-14D Permit to Work - Hot Works

HS/1-14E Permit to Work – General

HS/1-15 Daily Vehicle Pre-operational Checklist

HS/1-16 Asbestos Checklist

HS/1-17 HAV Risk Assessment Calculator & Guidance Notes

HS/1-18 Weekly Individual HAV Exposure Record

HS/1-19 Toolbox Talk / Task Briefing Register

HS/1-20 Heads Up For Five (HUFF)

HS/1-21A SHE Meeting Agenda & Minutes - Weekly Site Meeting

HS/1-21B SHE Meeting Agenda & Minutes - Monthly Regional Meeting

HS/1-21C SHE Meeting Agenda & Minutes - Directors SHE Forum

HS/1-22 Enforcement Authority Visit Report

HS/1-23 Record of Issue – PPE

HS/1-24A Safe System of Work Checklist

HS/1-24B Risk Assessment / Method Statement Programme

HS/1-25 Point of Work Risk Assessment (PoWRA)


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HS/1-26 Risk Assessment

HS/1-27 Method Statement

HS/1-28 VDU Workstation Evaluation

HS/1-29 SHE Training Matrix

HS/1-30 SHE Inspection Report

HS/1-31 Site Managers SHE Checklist

8.2.3. Robertson Guidance Notes

RGN 01 – Temporary works designs – Trenches and excavations

RGN 02 – Site holiday shutdown

RGN 03 – Fully qualified workforce

RGN 04 – Alternatives to ladders, traditional stepladders and tower scaffolds

RGN 05 – Wind borne materials

RGN 06 – General housekeeping

RGN 07 – Lifting operations – Cranes

RGN 08 – Safety in lift shafts

RGN 09 – Site supervisors joint monitoring tours

RGN 10 – Site transportation of steelwork


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RGN 11 – Hand protection

RGN 12 – Safe use of quick hitches

RGN 13 – Rigging of safety nets

RGN 14 – Safe use of concrete pumps

RGN 15 – Asbestos Surveys

8.2.4. Robertson Group documents

Crisis Communications Protocol

8.2.5. External documents

HSE Publication - EM1 Asbestos Essentials

HSE Publication – HSG47 – Avoiding Danger from Underground Services

HSE Publication – GS6 – Avoiding Danger from Overhead Powerlines

HSE Publication – L22 – Safe Use of Work Equipment