Chapter 4: Identify the hazards - include all the right people
4.1 Two directions
Although “who can be harmed” has been removed as a separate step in the HSE five steps, it is no less important. You can’t identify a hazard if you don’t know who can be harmed; you can’t assess the likelihood or severity of harm if you don’t know who might be harmed; you can’t work out the effectiveness of controls unless you know the audience expected to use them.
But considering the people does more than this – it gives us an extra tool for identifying hazards that we might otherwise not have included.
We are going to approach this problem from two directions (see Figure 4.1):
- Traditional direction: Think of a hazard, then think of who could be harmed by it.
- Reverse direction: Identify people, then think of hazards that could affect them.
To be confident you’ve identified all reasonably foreseeable hazards you might need to combine both approaches.
Figure 4.1: Working in both directions to protect everyone
4.2 Traditional: hazard, then who could be harmed
To identify who could be harmed for each hazard, consider which people might be more susceptible per hazard. Table 4.1 suggests some types of people who might be vulnerable for typical hazards. Reasonable adjustments or additional precautions might be sufficient in some cases, so this table is not a list of people to ban from certain tasks. See the HSE website for more detail about each hazard.
Table 4.1: How some people are especially vulnerable to some hazards
| Hazard | Who could be (more) harmed? |
|---|---|
| Substances Hazardous to Health (chemical, biological and physical) | Check safety datasheets, but consider: • People with asthma and other respiratory conditions • People with dermatitis and other skin conditions • Expectant or breastfeeding parents and their children. |
| Ionising and non-ionising radiation | Expectant or breastfeeding parents and their children. Young people who are still growing. People with pacemakers. |
| Vibration | People with pre-existing Hand Arm Vibration Syndrome (HAVS), Carpal Tunnel Syndrome (CTS) or primary Reynaud’s disease. People with pre-existing symptoms even if not diagnosed, or with poor circulation. Smokers take longer to recover from vibration-induced symptoms. Prolonged exposure to vibration during pregnancy can increase the risk of miscarriage, premature birth or low birth weight. |
| Noise | People with existing hearing loss or tinnitus. People with some mental health conditions might be more prone to anxiety in noisy environments, well below exposure limits. Prolonged exposure to excessive noise can increase blood pressure which can be dangerous during pregnancy. |
| Handling heavy loads | People with pre-existing musculoskeletal conditions, or other health conditions, or recent surgery. People who are stressed and smokers Hormones present during pregnancy and breastfeeding can make muscle injuries more likely. |
| Temperature extremes | A breastfeeding parent can be more prone to dehydration. Heat stress or heat exhaustion could be more harmful when pregnant. Workers near or during the menopause might need more control over the temperature and ventilation of their working environment. Someone with vibration-related or circulatory conditions can be more prone to suffer in the cold. |
More examples are provided in Appendix 2.
When creating your own version of Table 4.1, consider both individual members of staff, and ‘people in general’ who will be more susceptible to each identified hazard.
We’re already familiar with this idea for fire, where personal emergency evacuation plans (PEEPs) are prepared to describe how responsibilities for disabled individuals will be met. Organisations that are open to the public, such as shopping centres or theatres can’t have a PEEP for every individual who might visit, so they create general emergency evacuation plans (GEEPs) for the most common types of disability. For example, limited mobility, hearing impaired, sight impaired and learning difficulties. These are based on a risk assessment of the hazards that a person of each type might be exposed, and the controls that might be appropriate.
Ask yourself: PEEPs and GEEPs are now commonplace as part of fire safety plans. But what other hazards or hazardous events could you apply this approach to in your workplace?
For example, rather than starting from scratch with a DSE assessment every time someone with a back condition needs adjustments to their computer workstation, you could write a “generic DSE assessment for back problems” that could be modified. What about a “generic work at height assessment for people with health conditions” that considered what medication, illnesses or disabilities could impact safety when working at height?
4.3 Reverse the process: people first, then hazards
Instead of starting with the hazard you could start with the people who might be harmed.
Ask yourself:
In the previous section I said that PEEPs and GEEPs were used for the hazardous event of fire. What other hazards might be identified in an emergency evacuation plan?
While fire might be the hazard with the greatest consequence, the risk assessment behind an emergency evacuation plan starts with the person who might be harmed, and identifies many hazards other than fire. For example, moving people in an evacuation chair can create a manual handling problem for those handling the chair, and a risk of falling to the evacuee. To reduce the risk, a person with mobility limitations might be asked to wait in a temporary refuge with a buddy during the first stage of an evacuation. If there has been a false alarm, or the process is a drill, there is no need to risk moving a disabled person down the stairs unnecessarily. Refuges tend to be in stairwells, right next to a fire alarm sounder. The noise is a hazard, both because of its impact on hearing and tinnitus, and because it prevents communication with the evacuation co‑ordinator. In turn, this could expose rescuers, buddies and the disabled to fire, or it could lead to the evacuees moving away from the noise – and towards another hazard.
With a PEEP, the process of focussing on the person first, and considering the hazards they face can be very effective. But the same organisations ignore disabled people in relation to every other risk assessment in the organisation. It seems odd to ignore vulnerable people for most of the time, and then suddenly remember them when the fire alarm sounds. One charity shop chain I worked with had a process for considering the different abilities of each trained volunteer. However, few of the managers understood the process, and I saw assessment after assessment that included no comment that an 85-year old with severe arthritis should not climb a ladder, or that a 14-year old shouldn’t deliver large sums of cash to the bank. No one had ever explained to the managers that one purpose of the individual assessment was to identify hazards particular to each volunteer.
Individuals and groups
Providing a separate risk assessment for every individual, as well as premises and equipment risk assessments might be practical for a small organisation, but for a larger organisation, a different approach is likely to be more effective.
When people responsible for fire safety prepare GEEPs (as opposed to PEEPs), they consider types of disabilities people might have, and how this would impact their ability to evacuate. I had a great friend who had started to lose his sight as a teenager. He couldn’t drive, so he walked everywhere. He did karate. He was tall, strong and heavy. He regaled me with stories of turning up at airports on his own, having pre-booked support, and being met by diminutive members of staff with wheelchairs to get him from lounge to airplane. Sometimes the staff member would insist on struggling to push this large, very fit young man in the chair; other times, they had the sense to listen to Alex explain that he just needed a guide to walk ahead, and let him touch their arm.
The problem raised by Alex’s experience was the overly generic measures that the airports had in place. Properly thought through, GEEPs will have variations for different needs. Deaf people might need support for alerting, but can exit the building with everyone else; people with limited mobility might need a temporary (and hopefully not too noisy) refuge, or use of a fire-safe lift. Someone nervous about crowds might prefer to wait until everyone else has gone ahead, but can then evacuate normally.
4.4 Groups to consider
Do not make assumptions about what any individual is capable of, whether pregnant, older or younger, fit or disabled. It is not reasonable to insist someone can’t do a job unless you can demonstrate that they miss an ability which is critical to the job, and that reasonable adjustments are not possible.
However, you might need to consider hazards in more detail for some categories of people. In many cases, if you control the hazard adequately for the whole workforce, the hazard for the individuals should also be under control. Similarly, where you make a reasonable adjustment in workplace or job design for an individual, you might find that everyone benefits.
This is not a comprehensive list, but we’ll consider the following groups of people:
- Pregnant and post-natal workers.
- Older and younger workers.
- People with physical and mental health conditions.
- Stakeholders with different roles.
Pregnant and post-natal workers
“Women of childbearing age” is no longer a reliable term, albeit it is the one in the Management of Health and Safety at Work Regulations (Regulation 16). Girls younger than 10, women over 70, trans men and non‑binary people have had babies. If you expose any people to hazards that pose a risk to pregnant or breast-feeding parents and their children, consider how to eliminate exposure to protect everyone.
The EU directive “On the introduction of measures to encourage improvements in the safety and health at work of pregnant workers and workers who have recently given birth or are breastfeeding” (Council Directive 92/85/EEC) specifically lists certain hazards of greater concern:
- Ionising (eg X-rays) and non-ionising (eg UV) radiation
- Biological agents, such as toxoplasma and rubella virus
- Chemical agents which are mutagenic, carcinogenic, or toxic for reproduction or for organs. For example, mercury and carbon monoxide.
If you are using these agents you should understand the hazards, regardless of who is working for you. See Box 4.1.
Box 4.1: X-rays safe for all
I had a client with an x-ray machine in the post room, to check incoming deliveries. After I rewrote the procedures (see Chapter 12) I brought in a radiological protection advisor to check the equipment, and my revised procedures. He noted that I had said that everyone working in the post room should be informed of the hazards of x-rays to unborn children, and advised to stay away from the x-ray machine when it was in use if they knew, or suspected, they were pregnant. While an admirable sentiment, he said it wasn’t necessary. “If there was enough coming out of those machines to harm an unborn baby, I wouldn’t have passed them.”
The Council directive also suggests that expectant and breastfeeding parents should not do underground mining work or underwater diving if it involves hyperbaric pressures. You can read Table 4.1 from right to left to see other hazards typically considered to cause greater risk to people who are pregnant or breastfeeding. These include vibration, noise, heavy manual handling, temperature extremes, and awkward or sustained postures.
Underground mining and deep sea diving aside, since pregnancy-related risk varies between individuals, decisions should be based on personal circumstances. Some people experience significant fatigue and might need to reduce travel or adjust workloads. But others are brimming with energy and ideas, and keen to get ahead before their pregnancy leave. Some will find it uncomfortable to sit or to stand for long periods. But so might any worker who did too much gardening at the weekend. Have a process in place for someone competent to have a conversation with an employee when they notify their pregnancy. Identify adjustments needed and arrange regular catch-ups. Many organisations do this reasonably well during pregnancy, but forget to have the conversation when an employee returns to work. Forcing someone to lurk in the toilets to express milk, then hiding it in the team fridge might not be the best approach.
If moving away from the dated language in the legislation worries you, note that the title of the European Union Council Directive 92/85/EEC uses the inclusive term “pregnant workers and workers who have recently given birth or are breastfeeding.”
Older and younger workers
Age can bring wisdom or complacency, so assuming an attitude towards safety based on age is not useful. Evidence from the HSE (RR832: An update of the literature on age and employment) suggests that cognitive performance continues improving up to at least the age of 60, and then plateaus before declining from the age of 70. However, those still in the workforce at 70 might not fit this pattern since older people who still work (or volunteer) tend to be fitter and more alert than their same-age peers.
However, with an aging workforce it is worth the time to review your workplace to see if there are any hazards that could be worse for people with age-related conditions. Do any jobs require people to stand for long periods or to climb over ducts in a plant room? Can you reduce the extent to which safety when working at height relies on balance and postural stability?
Another HSE study (RR946: Age related changes and safety critical work) suggested that poorer visual acuity, contrast sensitivity, field of view and depth perception could cause concerns in occupations where vision is critical, such as driving and responding to changes in control systems.
An older HSE study (RR446: The development of a fatigue / risk index for shiftworkers) showed limited evidence that shift work can have a greater impact on more mature workers, but a review of whether your shift patterns follow best practice could be of benefit for everyone.
At the other end of their working lives, lack of experience in the workplace, and in life, can make younger people less risk aware. Alternatively, they might have a better attitude to hazard controls as these have been incorporated into their school science and technology lessons. Do not assume that all young people will be fit and strong. Over the last twenty years, evidence suggests that adolescents suffer from as much, if not more, back pain and other musculoskeletal complains as adults. Successively, television, videos, computer games and mobile phones have been blamed. Whatever the cause, the hazards of heavy or repetitive work on the development of young people who are still growing should be considered.
Physical and mental health conditions
Table 4.2 suggests a few ideas you can consider. Highlight the ones that are relevant to your workplace, and add any others you might need to think about.
Table 4.2: Relevance of physical and mental health conditions to hazard identification
| Condition | Hazards where this might be relevant |
|---|---|
| Phobias, such as fear of heights, or claustrophobia | While it’s unlikely that people with a fear of heights are going to end up as a steeple jack, do any escape routes involve balconies or external staircases? Or exits through tight spaces which could be dark? Work in confined spaces, or in low lighting, or in crowded workspaces might be a concern for people with claustrophobia. |
| Anxiety disorders | Psychosocial hazards, including workloads, short deadlines, workplace politics, lack of support, unclear goals, poorly defined roles and uncertainty about the future. |
| Mobility limitations | Trivial slip and trip hazards might become significant. Where a mobility aid (wheelchair, buggy, walking frame) is used, does this force the user into a route that takes them closer to a hazard? |
| Sensory disabilities | Hazards that rely on the senses for alerting, for example reversing vehicles using a sound alert, or flashing beacons providing a visual alert. |
Stakeholders, interested parties and roles
The categories suggested so far refer to something about a person that might make them more susceptible. However, another useful way to check that everyone who might be harmed has been considered is to look at each stakeholder or role.
In Chapter 1 I highlighted the failure of a cleaning contractor to consider the client staff. In another case a risk assessment for working on a shop front didn’t adequately consider the risk to pedestrians passing by.
To avoid this your written risk assessment process should include a checklist, tailored for your organisation, which reminds you to consider each type of person. When a new risk assessment (or an accident or incident investigation) identifies a type of person you hadn’t previously considered, make sure that it is added to the checklist.
ISO 45001 requires organisations to identify “interested parties”. If you have a list of interested parties, that’s a good place to start. Tailor the suggestions in Table 4.3 to your organisation. Include children if you are at a school, or even a building site if children can trespass, but not if you work for a laboratory with good security and no staff or visitors under 18.
Table 4.3: Considerations for interested parties
| Interested party | Considerations |
|---|---|
| Staff | Permanent, temporary, fixed contracts, freelancers treated like staff, homeworkers, lone workers, remote workers and mobile workers. |
| Contractors and consultants | Project contractors, such as those doing maintenance, servicing or refurbishment, and service contractors such as a health and safety advisor working with the organisation for a fixed period. |
| Delivery and collection staff | From the postal worker who drops mail at reception, to the courier who brings a van load of supplies into the stock room. Or the person who delivers pizza to employees working late. This also includes any workers who collect products from you to take elsewhere. |
| Suppliers | What impact do your requirements have on suppliers? Consider suppliers of services as well as physical goods. For example, an employee assistance programme provider might be impacted by organisational changes that increase demand from your staff. |
| Visitors, customers, clients and service users | Visitors might be signed in and escorted, directed to a specific location (such as in a theatre) or allowed to roam freely (in a shopping centre). Service users include patients at a hospital or GP surgery, a victim reporting a crime at a police station or people using recycling facilities. Don’t forget customers you can’t see. As demonstrated, it could be people remote from where the organisation operates, such as people buying a product, or making use of a product paid for by someone else. See Donaghue v Stevenson |
| Members of the public | Your occupational road risk assessments probably consider collisions with other vehicles, but what thought is given to pedestrians forced onto the roads by vehicles parked on pavements, or cyclists expected to ride in a pot-hole ridden gutter to make way for an oncoming vehicle on the wrong side of the road? See one court’s response to dangerous parking in R v Jenkins 2012 |
| Pupils or students | If you run a school or college, you will have considered these as customers or service users. But do you provide work experience opportunities, or allow parents to bring their children into work? |
Some of these categories might overlap for you, some won’t be relevant, and you might have additional categories to add. Develop your own checklist, and use it to test every risk assessment for completeness.
4.5 Conclusion
‘Identifying who could be harmed’ as a separate step suggested that people could be considered, and then forgotten about as you evaluated the risk, selected the controls, documented the risk assessment and reviewed it. But you need to consider people at every step.
Chapter 5 attempts to untangle two further steps which can’t be done one at a time – evaluation (or assessment) of risk, and control of risk.
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Appendix 1: Case studies by year
Appendix 2: Answers to questons posed in each chapter
Appendix 3: Lost HSE references