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Risk Assessment: Whose Responsibility?
Question: We believe it’s important to involve all our staff in risk assessment and we’re therefore proposing to make every worker responsible for risk assessing their area/machine, etc. Our managers have struggled with risk assessment and this could save a lot of management time. Are we OK to go down this route of passing the responsibility onto them?
Answer: The Management of Health and Safety at Work Regulations 1999 require employers to carry out risk assessments and these must be ‘suitable and sufficient’. There are also risk assessment requirements in hazard-specific regulations, such as the Control of Substances Hazardous to Health (COSHH) Regulations 2002.
Your instinct to involve people is sound, as it is definitely good practice for assessments to engage with those directly doing the work, who, let’s face it, often know more about the detailed, in-depth, day-to-day operations than anyone else.
However, you cannot delegate the responsibility for risk assessment; it lies with you as the employer and, by extension, with your managers. The approach you are proposing was followed in one company I worked with, and they ended up with a huge shopping list of recommended actions that their managers then had to spend time checking and prioritising. They found there were widely varying views of what was ‘high risk’ and ‘low risk’ which, in turn, made it hard to allocate resource to the right place. And the employees resented doing work which they felt ill-equipped to carry out.
You say your managers have struggled with risk assessment – how much more so will your staff members! So, involve them and engage with them, absolutely, but the overall risk assessment work needs to be led by management. Legally, the buck stops with you as the employer, and whoever does the assessment, I recommend you provide them with training in the key principles of risk assessment and control.
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