- Health and Safety Policy Statement
- Responsibilities and Arrangements for Health and Safety- Health and Safety Organisation Chart
- Detailed Policy and Guidance
- Specific Policies and Guidance
In accordance with its duty under Section 2 (3) of the Health and Safety at Work etc. Act 1974 and in fulfilling its obligations to both employees and the public who may be affected by its activities; the Board of Directors of Consolidated Timber Holdings Group Ltd (“CTHG”) have produced the following statement of policy in respect of health and safety.
The Board is committed to improving health and safety standards within CTHG and its subsidiary companies (“Group” or “Company” as appropriate) recognises its role in providing health and safety leadership and engaging the active participation of workers to achieve this.
It is our aim to achieve a working environment which is free of work-related accidents and ill-health and to this end we will pursue continuing improvements from year to year.
We undertake to discharge our statutory duties by:
• Identifying hazards in the workplace, assessing the risks related to them and implementing appropriate preventative and protective measures.
• Providing and maintaining safe work environment
• Establishing and enforcing safe methods of work.
• Recruiting and appointing personnel who have the skills, abilities and competence commensurate with their role and level of responsibility.
• Ensuring that tasks given to employees are within their skills, knowledge and ability to perform.
• Ensuring that technical competence is maintained through the provision of refresher training as appropriate.
• Promoting awareness of health and safety and of good practice through the effective communications of relevant information.
• To ensure all levels of management and employees understand their responsibilities for health and safety placed upon them by this policy.
• To ensure that appropriate insurance cover is provided and maintained.
• Furnishing sufficient resources needed to meet these objectives.
All employees on their part are encouraged to contribute actively towards achieving a work environment that is free of accidents and ill health. Employees are reminded that they are required to:
• Take reasonable care for their own health and safety at work and of those who may be affected by their acts or omissions.
• To cooperate with their employer to ensure that they comply with any duty or requirement for health and safety, imposed upon their employer by law and contained in this statement of policy and related arrangements and procedures.
• Not to intentionally or recklessly interfere with or misuse anything provided in the interests of health, safety or welfare.
• Inform their manager if they are not fit for work due to the influence of alcohol, drugs or prescribed medication.
Any employee who disregards his/her duties under health and safety law or Company rules may face disciplinary charges.
Our health and safety policy will be reviewed regularly to monitor its effectiveness and to ensure that it reflects changing needs and circumstances.
This statement is to be read in conjunction with the attached responsibilities, arrangements, procedures and guidance that together form the Health and Safety Policy for Consolidated Timber Group Holdings Ltd.
Consolidated Timber Holdings Group Ltd
The Board of Directors has appointed David Colman as their representative for Health and Safety to coordinate with the Managing Directors of each Company to ensure that:
1. The policy is effectively administered and monitored, and that necessary alterations are made to the policy to reflect changes in legislation or Company development;
2. Management are advised of relevant changes in health and safety legislation, codes of practice and recognised industry standards;
3. Contact is coordinated with relevant external organisations;
4. Regular meetings are held at which issues of health and safety can be discussed, objectives and plans reviewed and actions for continual improvement developed;
5. Health and safety assessment requirements are identified and advised to management;
6. Risk assessments are carried out and written instructions provided to establish safe working methods; regular reviews are carried out and any changes brought to the attention of staff affected;
7. Regular health and safety site inspections/audits are carried out to ensure that all staff and working conditions are in compliance with all mandatory legislation and site rules;
8. All reportable injuries, diseases and dangerous occurrences are reported to the relevant enforcing authority;
9. All accidents/incidents, ill health, dangerous occurrences and other issues concerning safety raised by anyone at work, are recorded and investigated such that effective controls can be implemented to help prevent recurrence.
10. Shared learning on health and safety issues is coordinated across Group companies.
The Managing Directors have nominated Health and Safety Coordinators/Department Managers within each Company who are responsible for ensuring that:
1. All employees understand the Company health and safety policy and understand their responsibilities;
2. They actively lead the implementation of the health and safety policy;
3. Adequate welfare facilities are provided and maintained in a satisfactory condition;
4. They communicate and consult with staff on issues of health and safety and encourage staff to report hazards and raise health and safety concerns;
5. Written instructions are provided through risk assessment and safe systems of work to establish working methods, to explain the sequence of operations, to outline the potential hazards and implementation of suitable risk controls;
6. Any hazardous substances are stored, transported, handled and used in a safe manner in accordance with manufacturers’ instructions and established rules and procedures;
7. All health and safety site rules are followed by all;
8. All plant and work equipment within the workplace is maintained in a safe condition, guarded in accordance with the relevant legislation and has the statutory certificates of inspection or examination;
9. Adequate supervision of staff is provided to ensure that they are working safely, including the provision of increased supervision for vulnerable employees (new starters, agency staff, young persons, persons with disabilities and pregnant women);
10. Contractors are effectively managed so their activities do not increase the risk of harm for employees or others who may be affected by their activities
11. Safety training requirements are identified for all members of staff under their control to ensure that those members of staff are competent to undertake their work in a safe manner;
12. Personal protective equipment is readily available and maintained, and relevant employees are aware of its correct use, storage and procedures for replacement; and
13. They set a good personal example by using the appropriate protective equipment whilst on site.
The above individuals will be supported by external Safety Advisors appointed by the Board of Directors. The external Safety Advisors will attend individual Company sites on a regular basis and will interpret new Health and Safety legislation and identify all safety related training requirements.
An Organisation Chart summarising the Group approach to Health and Safety is provided below.
DETAILED POLICY AND GUIDANCE
It is the policy of the Company that adequate Employer Liability and Public Liability insurance cover is provided and that a copy of the current Employers Liability Insurance certificate is available at each Company premises.
In compliance with the Regulatory Reform (Fire Safety) Order 2005, each site will complete a fire risk assessment to identify and ensure; the risks associated with the start and promulgation of fire on site are minimised, that suitable means of fire detection, fire suppression and raising the alarm are installed and maintained and that adequate fire emergency procedures are available and workers are trained to follow them.
1.3 FIRST AID
It is the Company policy that First Aid Provisions which comply with the requirements of the Health and Safety (First Aid) Regulations 1981 are provided for use on the Company premises, including suitably trained first aiders and first aid facilities or equipment. This will be assessed by a first aid risk assessment on each site.
The consumption of alcohol on Company premises, at any time is prohibited. Should any employee feel that they are still under the influence of alcohol, consumed prior to starting work (for instance the previous night) they are to inform their line manager who will evaluate their fitness for work and those in charge of machinery will not be permitted to start work.
It is also the Company’s policy that employees who are taking drugs or any form of medication, prescribed or otherwise, which may affect their ability to work safely, are required to inform their line Manager or in their absence their nominated deputy, immediately before starting work.
Failure to comply may result in disciplinary action being taken
1.5 INJURIES/ACCIDENT PREVENTION/INVESTIGATION
Employees are required to inform their Health and Safety Coordinator/Department Manager or, in their absence, their nominated deputies of any injuries or work related health issues, however sustained, that may affect their ability to work safely or where the work activities may exacerbate them. All such injuries/health issues are to be recorded.
It is the Company policy that all reports, however minor, are investigated and that suitable measures are taken to prevent a recurrence. The Safety Advisor will undertake Safety Audits and Inspections and submit written prioritised recommendations to the Health and Safety Coordinator and Managing Directors of each Company. Employees are required to co-operate fully with the Safety Advisor or their agents, whilst they investigate reports.
The following procedures apply:
a) Employees are required to report to their Health and Safety Coordinator/Department Manager or in their absence their nominated deputies, any concerns they may have concerning their health and/or safety whilst at work. The Health and Safety Coordinator/Departmental Manager will investigate workplace accidents/health issues and submit written recommendations on completing the investigation to the Managing Directors.
b) The Managing Directors will give due consideration to any concerns brought to his attention and may, at his discretion, enlist the assistance of the Safety Advisor.
c) At the discretion of the Managing Directors the Safety Advisor will review workplace accidents (individual reports and trends) and submit written recommendations on completion of the review.
d) The Managing Directors will give due consideration to the Safety Advisor’s recommendations and will take remedial action to eliminate the risks or, where this is not reasonably practicable, to reduce them to the lowest possible level.
1.6 ACCIDENT/INCIDENT AND RECORDING: (NON-RIDDOR)
It is the Company policy that all accidents and potentially dangerous occurrences, however minor they may seem, are reported and that a suitable record is made by the first aider providing treatment. Records will be kept securely in compliance with the General Data Protection Regulations (GDPR) for a minimum of three years. Accident reports will be clearly identified as either:
• Minor/first aid injuries
• Injuries resulting in more than three-day but less than than seven-day lost time
• Injuries that are RIDDOR reportable
1.7 REPORTABLE INJURIES/DISEASES / DANGEROUS OCCURRENCES
In compliance with the requirements of the Reporting of Injuries, Diseases and Dangerous Occurrence Regulations 2013 (RIDDOR), the Managing Directors or, in his absence, his nominated deputy, will ensure that the following procedures are followed:
a) In the event of a reportable injury, disease, or dangerous occurrence, as defined in the schedule of the Regulations, an investigation into the circumstances takes place and that a written account is kept.
b) That the scene of a serious accident or death is left undisturbed and that the Safety Advisor is immediately informed.
c) Notifying the enforcing authorities as appropriate as soon as possible.
d) The Health and Safety Coordinator and Departmental Managers will ensure that witness statements are taken and forwarded to the Managing Directors. The Managing Directors or his authorised deputy will ensure that a report is submitted to the enforcing authorities within the prescribed period.
1.8 TASK AND MACHINE BASED RISK ASSESSMENTS
In compliance with the Management of Health and Safety at Work Regulations 1999 the following arrangements exist for task and machine-based risk assessments (“Risk Assessments”):
The Safety Advisor in conjunction with the relevant Health and Safety Coordinator/Department Manager are responsible for:
a) Undertaking Risk Assessments.
b) Reviewing the validity of all Risk Assessments and carrying out new ones as required.
The Safety Coordinator/Departmental Managers will ensure that:
a) Employees are made aware of the hazards, risks and controls identified by Risk Assessments.
b) Copies or summaries of Risk Assessments are readily available to employees.
c) Changes to methods of work, introducing additional training and providing suitable items of PPE, are implemented as necessary following each Risk Assessment.
1.9 VULNERABLE PEOPLE
Vulnerable people include young persons, new and expectant mothers, night shift workers and anyone else who has health condition that could put them at greater risk (e.g. someone with asthma working in wood working environment). In compliance with the Management of Health and Safety at Work Regulations 1999 the Managing Directors and Health and Safety Coordinator/ Department Manager will take all reasonably practicable steps to ensure that the health, safety and welfare of vulnerable people is not put at risk as a result of the Company’s work activities. They will ensure, so far as is reasonably practicable, that Health and Safety Coordinator/Department Manager or in their absence their nominated deputies, or the Safety Advisor is tasked to undertake a suitable and sufficient Risk Assessment of the employee’s duties. So far as is reasonably practicable, the recommendations made by the Risk Assessment will receive due consideration and will, without undue delay, be acted upon.
Where we employ young persons (under the age of 18 years) on a full-time basis or on work placements we will carry out special risk assessments before they start work to take the following into account:
• The young person’s inexperience, lack of perception of danger and immaturity.
• Their workplace and workstation
• Any exposure to physical, chemical and or biological agents
• Any work equipment used
• The work activities and processes to be undertaken
• Any training provided and risks from specified agents, including ionizing radiation, carcinogens, temperature extremes, noise or vibration and processes
Following the Risk Assessment a copy of the Risk Assessment will be forwarded to guardians of the young person and a detailed briefing on the Risk Assessment given to the young person and their line manager.
1.10 COSHH ASSESSMENTS
In compliance with the Control of Substances Hazardous to Health Regulations 2002 where appropriate each Health and Safety Coordinator/Department Manager:
a) Will identify through the Risk Assessments all substances and articles that workers might be exposed to within the scope of COSHH
b) Is responsible for ensuring that all COSHH assessments are readily available to employees.
The Safety Advisor in conjunction with the relevant Health and Safety Coordinator and Department Manager are responsible for:
a) For carrying out and subsequently reviewing COSHH assessments.
b) For monitoring the COSHH programme and or making recommendations to the Managing Director on the use, control, and storage of substances and articles within the scope of COSHH.
Based on Risk Assessments and COSHH assessments each site/business must assess whether they need to implement health surveillance and document what is required and how it is to be managed.
Each site will arrange for an asbestos survey and assessment for any buildings constructed before 1999. They will develop the appropriate management plans and arrange for any recommendations in the asbestos assessment to be progressed and ensure the assessment is available to any person that may be exposed to asbestos as a result of their activities within the building.
Where workers are involved in activities that could result in exposure to asbestos, they will be given asbestos awareness training.
Each business unit where manufacturing takes place will complete a Dangerous Substances Explosive Atmospheres (DSEAR) assessment to comply with the Dangerous Substances and Explosive Atmospheres Regulations 2002, and the Managing Directors will be responsible for progressing and monitoring the completion of actions. As actions are completed the assessment paperwork will be updated to show the progress that has been made.
1.13 SAFE SYSTEMS OF WORK
The Health and Safety Coordinator/Department Managers, or in their absence their nominated
deputies, are responsible for ensuring, so far as is reasonably practicable:
a) That all work activities are undertaken in a safe and healthy manner and that only safe systems and methods of work are adopted and implemented.
b) Procedures contained in manufacturers operating manuals and instructions are to be followed.
c) All drivers comply with current Road Traffic legislation by training and qualification.
1.14 MAINTENANCE OF PLANT AND EQUIPMENT
In compliance with the requirements of the:
• Provision and Use of Work Equipment Regulations 1998
• Electricity at Work Regulations 1989
• Lifting Operations and Lifting Equipment Regulations 1998
• Pressure Systems Safety Regulations 2000
all plant and equipment is inspected and maintained by competent persons and in order to achieve this objective each Health and Safety Coordinator/ Department Manager, or in their absence their nominated deputies, will ensure that within their area of responsibility:
a) All items of mechanical plant and equipment are maintained in accordance with manufacturer’s recommendations and statutory requirements.
b) Suitable records of all maintenance activities are kept. Where improvements are required as a result of statutory inspection the required maintenance will be noted and kept by the Company.
c) A competent person checks all portable and fixed electrical equipment at least once a year (or a period deemed by guidance) and that test records are produced and kept for three years.
d) The newer machines have service contracts in place and are normally checked twice a year as part of the contract. Records of these visits are held with the invoice for the service contract/visit.
e) Any defective plant or equipment is removed as appropriate from service until such time as it is competently repaired or replaced.
It is forbidden for any employee to tamper with, adapt, repair, or maintain any item of plant and equipment unless they have been authorised to do so and have been assessed as competent
1.15 MAINTENANCE OF THE PREMISES
The Company is responsible for:
a) Ensuring that the condition of the premises and its boundary fences do not present risk to the health and safely of any person.
b) Taking such action as required to ensure that any hazards associated with the premises or its boundaries are removed without undue delay.
1.16 PERMITS/LOCK OFF FOR MAINTENANCE
Each site will implement a permits-to-work system to control non-routine work of significant risk e.g. hot work, work at height etc. where appropriate.
In order to prevent accidental re-activation or release of energy during maintenance, cleaning or adjustment of machinery, which is likely to result in severe personal injury, each business unit will implement a lock off procedure as appropriate.
1.17 CONTRACTORS WORKING FOR THE COMPANY
The Company will use competent contractors and ensue in all cases an assessment is completed fully before any work commences. The Company will ensure that it carries out pre-assessment of contractors to ensure they meet minimum standards. The assessment will include:
a) Evidence that the contractor has both the resources and ability to safely undertake the contract on offer.
b) Contractors have sufficient Employer and Public Liability Insurance cover and that the Expiry date of the cover extends beyond the estimated completion date of the contract.
c) Written health and safety policies and risk assessments relevant to the work they are going to complete
All relevant employees will be informed of the presence of contractors on the premises and of all the risks the contractor or his employees’ work activities may present to them before the work starts.
1.18 USE OF VEHICLES FOR COMPANY BUSINESS
Detailed guidance on Company procedures is provided in the CTH Staff Employee Handbook for Company car drivers and Driver Handbook for HGV drivers, however in summary:
a) Company vehicles are only to be driven by authorised employees who hold a full valid UK driving licence. Repairs to any of the Company vehicles must be undertaken only by the approved lease Company maintenance provider. It is expressly forbidden for any member of staff to carry out any repairs however minor.
b) It is the responsibility of each Company vehicle driver to ensure that the vehicle is available for servicing as required. Employees must not drive vehicles that are defective.
c) Authorised drivers are responsible for ensuring that on-going maintenance is undertaken on their own vehicle (water, oil, screen wash, fuel and tyre pressures/conditions).
d) All employees driving on company business are expected to drive safely and abide by Road
Traffic Law and to conduct themselves in a manner reflecting favourably on the Company.
e) For Company vehicle drivers notices of intended prosecution of any stationary or moving traffic violations must be reported to the fleet manager or their line manager as soon as
possible after the notice is received.
f) Each Company vehicle driver must complete a Drivers Declaration Form annually which will be maintained at a Company level and kept securely in line with GDPR.
g) The use of handheld mobile phones whilst driving is an offence under Road Traffic Law.
Employees are authorised to use hands free devices while driving on company business but should keep use of such devices to a minimum and should only do so when it is safe.
1.19 INFORMATION, INSTRUCTIONS AND TRAINING
In compliance with Section 2 of the Health and Safety at Work etc: Act 1974, it is the Company policy to provide relevant instruction, information, training and supervision for its employees. The Health and Safety Coordinator/Department Manager are responsible for ensuring that the following training is provided and the adequate training records are generated and maintained:
a) All employees receive a health and safety induction and specific health and safety training
relevant to their role to allow them to work safely.
b) So far as is reasonably practicable, employees are adequately supervised.
c) All information relating to risk will be passed onto employees via toolbox talks or suitable discussion/training/memos and the employee signs that they have received the information.
d) When this comprises considerable information then employees will be given a period of time to read the information before signing that they have read, understood and have no queries regarding its contents.
e) In the event of an employee not fully understanding, or having queries regarding the information, addressing any concerns or queries the employee may have.
1.20 PERSONAL PROTECTIVE EQUIPMENT
Items of Personal Protective Equipment (PPE) or Respiratory Protective Equipment (RPE), identified as necessary by Risk Assessment, will be provided free of charge to authorised employees.
It is Company policy that the wearing of PPE supplied to employees is mandatory. Failure to comply may result in disciplinary action being taken.
To implement the Company policy on PPE, the Health and Safety Coordinator/Department Manager, or in their absence their nominated deputies, will ensure that the following procedures are applied:
a) All items of selected PPE are suitable by design for the purpose for “which they are intended to be used”.
b) Records of the issue of PPE to employees are kept.
c) Adequate stocks of replacement items of PPE are maintained.
d) Monitoring the effectiveness of all items of PPE issued to their staff and for taking any remedial action required.
e) Employees are made aware of the daily checks they should carry out on their PPE, what
defects they should be looking for and how to report any defects in their PPE.
f) Keep PPE maintenance records as required.
1.21 FORK LIFT TRUCK OPERATIONS
Each business unit will develop specific instructions in relation to fork lift truck operations having regard to the nature of the operations and risks involved on that site. Only trained and authorised drivers as agreed under the individual site instructions will be permitted to operate the Company fork lift trucks. Each business unit will set and justify a minimum refresher training schedule for forklift truck drivers.
1.22 USE OF EMPLOYMENT AGENCY OR TEMPORARY STAFF
There may be occasions when the Company needs to employ Temporary employees. When this situation is deemed to be necessary the Employment Agency used must be contacted prior to first engaging the Temp and requested to complete the Company Employment Agency Agreement form.
The Agreement form must be returned to the Company fully completed before the Temporary employee member is allowed to start work. Each Temporary employee must undergo the Company induction procedure delivered by the Company authorised person for the area intended and for the proposed employment period.
Each Temporary employee is to be instructed on site hazards and any relevant risk assessments are to be acknowledged by the Temporary employee. Any deviation from the proposed work that the Temp is engaged for must be approved in conjunction with the Agency.
Where any claims of relevant work experience are indicated on an individual’s agreement form these must be produced, checked and copied by the Company. In the event of any Temporary employee arriving for work without the contractually agreed PPE the Company will not allow the Temp to commence work until they are suitably attired.
1.23 CONTROL OF VISITORS
Visitors will only be allowed on site once they have read the visitors induction document and completed the signing in procedure to confirm they have read and understood it. It is the responsibility of the host to assess the level of supervision each visitor requires.
For external drivers making deliveries or collections each site will provide clear signage on its site in order to control the movement of visiting delivery/collection drivers.
1.24 VISITING CUSTOMERS SITES
Where employees have to visit customer sites, they will at minimum comply with the site controller’s health and safety rules and attend any site health and safety induction available when arriving on site. They will also comply with Company rules where they exceed the site health and safety rules:
• Wear safety footwear if visiting a site where there is workplace transport or on construction sites
• Wear hi-viz jackets where there is workplace transport
• Use pedestrian walkways where they are provided
• Remain vigilant to hazards that may be present or may develop during the visit and take suitable precautions
1.25 DISCIPLINARY PROCEDURE
In order to effectively manage health and safety the Managing Directors and Health and Safety Coordinator/ Department Manager will without exception resort to the Company Disciplinary Procedure for breaches of health and safety.
SPECIFIC POLICIES AND GUIDANCE
2.1. WORK RELATED STRESS POLICY
It is the Company policy to address all work-related illnesses and in particular stress, and to control, reduce or eliminate them so far as is reasonably practicable. Each business unit will complete a stress risk assessment to identify whether the HR and management practices in place minimise the risk of work-related stress.
2.2 WORKING AT HEIGHT POLICY
Each business unit will through its task risk assessments identify any work at height involving significant risk and ensure that the risk is minimised to comply with the Work at Height Regulations 2005. Where work at height cannot be avoided:
• Suitable and appropriate work equipment (e.g. scaffolding, cherry pickers, stepladders with handrails etc) must be used
• The type of equipment to be used will be determined by the space, nature and duration of the work – together with the intended number of users and any associated risk of erecting any structures
• Collective protection measures priority over other measures (e.g. guardrails rather than safety harness)
• All work at height is properly planned and appropriately supervised
• All those working at height must be competent to do so
• The place where work at height is to be done must be assessed as being safe.
• The risks from fragile surfaces must be properly controlled
• Any equipment to be used for working at height must be suitably and properly inspected and maintained
• Weather conditions must be taken into account and all work is stopped if weather conditions endanger health or safety.
• Procedures must be in place to deal with any emergency rescue situations prior to the work starting
• Any existing structures to be used must be stable and able to support the weight of workers and the equipment or materials they may need
• Platforms must be footed on firm ground or on a stable structure to prevent them from moving. For example, scaffolding should generally be tied to an existing structure. Duckboards should be provided over fragile roofs and where people could fall through holes or openings in a platform floor guard rails, boards or other barriers such as toe boards should be erected
• All equipment being used must be removed from any platforms being used at the end of every working day and any power supplies being used must be switched off
• Consideration must be given to the risks of objects falling onto somebody or something below, including nails, pieces of wood, general debris, buckets and any handheld equipment including drills and hammers etc.
• Specific consideration should also be given to:
- Using close boarded and double boarded platforms with a polythene sheet in between the boards to prevent small items such as nails and bolts falling
- Using toe boards to prevent items being kicked off the edge of platforms
- Providing covered walkways
- Using mesh and netting on the underside of cradles, or mobile elevating working platforms etc.
- Using covered chutes as an aid to remove debris from work areas
- Attaching drills etc. to safety lines
Inspections of equipment
Access equipment and scaffolds must be inspected and tested on a regular basis and records kept of any such inspections and tests. All inspections should be carried out by a competent person on:
• The place where work is to be carried out before it is used
• The equipment after it is assembled or installed
• The equipment when it is in use (at suitable intervals)
2.3 DISPLAY SCREEN EQUIPMENT (DSE)
Each business unit will ensure that DSE users complete a DSE assessment and this is reviewed so the risks can be minimised. In accordance with the Health and Safety (Display Equipment) Regulations 1992 (as amended) the Company will pay for sight testing where users of display screen equipment request.
Consolidated Timber Holdings Group Limited
Dated January 2020