Building a risk assessment policy

A risk assessment is the first step towards managing risk in an organisation. This will cover issues such as vehicles, journey tasks, drivers and uncover any problems or hazards, which gives a focus for employers, says Nicola Smith

Case Study – ICI Dulux

Article in full

The level of risk assessment that an organisation needs to carry out will depend largely on its size and nature of its business. The law states that adequate risk assessments should take place, and while this phrasing is slightly ambiguous, there are three fundamental areas that need consideration.

Roger Bibbings, occupational safety adviser at the Royal Society for the Prevention of Accidents (Rospa), explains: “The most appropriate in many organisations would be a generic risk assessment, looking at vehicles, journey tasks and drivers, and identifying where there are problems in those three areas.” The first step set out in the Health and Safety Executive’s (HSE) 2003 publication Driving at work: managing work-related road safety is looking for hazards. This could involve identifying if any cars are being used for unsuitable jobs, such as transporting goods that should be travelling in specially-adapted vehicles, or whether any cars have recurring problems. Hazards relating to journey tasks might involve having to transport goods or documents against the clock, or over a long distance.

Drivers that present hazards, meanwhile, are likely to include those with speeding points or who cover excessive miles. The second recommended step is to decide who might be harmed and consider if any groups are particularly at risk, such as newly-qualified drivers. Step three is then to evaluate the risk and decide if existing precautions are sufficient, based on how likely it is that each hazard will actually cause harm. Risk assessments can then become more precise. “If journey tasks are specific or predictable tasks such as deliveries, companies can look in detail at the routes taken, the time of day the journey is carried out and look in detail at what alternatives are available,” says Bibbings. This allows employers to eliminate or control the risk by avoiding or changing certain situations.

Andy Price, head of motor fleet services at Zurich Risk Services, explains: “Some companies incentivise their drivers to make so many calls in a day, which might tempt them to break speed limits for example. By changing the way that the company pays those employees, it can immediately eliminate an area of risk.” Organisations with five or more employees are legally bound to record the findings of risk assessments in order to document that a proper check has been made, that staff who might be affected have been consulted, and that obvious hazards have been dealt with. But Price advises companies to look, not just at the risk inherent in everyday activity, but at proven risk as well.

“Quite often, companies have some great data from their insurance company or accident management company relating to why collisions have occurred, yet the information is all too often filed away in a filing cabinet.” This information can be used to identify which drivers are having the most collisions, or the nature of collisions, and enable employers to target measures at specific individuals or departments. “If the data proved that most accidents involved reversing, they could heighten awareness of reversing safely or look at fitting sensors,” he adds. Theoretical risk is also important, particularly in identifying which drivers are the most at risk of having an accident and why. “A lot of drivers come out [as] high risk because of the mileage they travel and, in those situations, we recommend that the mileage be changed by altering the area that a driver covers, or by changing the way they work.”

But while employers may be clear about what areas they need to address in a risk assessment, many are unsure exactly how to go about doing it. One area of uncertainty concerns who should conduct a risk assessment. While the law simply says that a competent person should be employed, there are several schools of thought. “Generally speaking, we advise against the idea of bringing in people from outside [an organisation] because decisions about this need to sit in the management line, and should be part of the line manager’s skills. It’s a question of really getting an inside track from the people doing the work, and getting them to agree what needs to be tackled and how,” explains Rospa’s Bibbings. He believes this allows for a more effective dynamic risk assessment, aimed at empowering employees to understand and think through the risks for themselves.

For example, making the decision about whether to stop overnight due to fatigue instead of continuing with a journey. Zurich Risk Service’s Price agrees that responsibility needs to be taken by the whole company. “The fleet manager will need to be responsible for company-owned or company-leased cars, and there’s quite often a whole range of other drivers (such as opt-out drivers or private vehicle drivers) who the fleet manager will have no control over.” He believes that where it is working successfully is when the manager of health and safety carries out the assessment. Gavin Jones, proact and rental services account specialist at Interleasing, takes this one step further. “It is important that it isn’t one sided. Organisations should partner with an expert in the field. Risk specialists can then work with the HR team, who know the organisation from the top down but won’t necessarily know the legislation.”

This view is backed up by David Faithful, partner at law firm Clarke Willmott, who states that the best line of defence employers have in terms of an incident is to say they have not only taken action, but have also worked with an outsourced agency. “If it all goes wrong one day, you can say you have addressed it. You’ve had a risk assessment by a professional body and you did all a reasonable [organisation] would do.” But while awareness is growing of the legal requirement for road risk assessments, Jones believes many companies are still unaware of the benefits. Driving licence validation, for example, is a common problem that would be eliminated by a good risk management procedure.

“There’s so much administration involved in checking and recording the information that many HR people just put it on the back burner.” Specialist risk assessment firms have an automated validation service that cross-checks licences with the DVLA, which removes the admin burden and the potential liability. Jim Kirkwood, managing director of driver training firm Drivetech, explains: “If an employee is involved in a road accident, the penalty is personal not corporate. So if a guy on the road doesn’t have a valid licence, the responsibility lies with someone in the company for not carrying out the check.”

A sound risk management strategy means that licences will be checked on a regular basis. New employees will have theirs checked for validity and penalty points as a matter of course, and existing employees will have a responsibility to inform their employer if they receive points. As Jones points out, it is a question of not only identifying risk, but having an appropriate policy in place if issues arise. “If someone gets points on their licence, do they need to continue driving? If they don’t, you can eliminate the risk of an employee being banned from driving by adapting their role.” Good risk management means other policies will also be formalised to reduce the risk of accidents, such as regular MOT and insurance checks, as well as driver medical checks.

It is a complex area but carrying out a risk assessment is crucial for any company, large or small. And while some of the benefits might not be impetus enough for employers to take their responsibility seriously, the financial aspects alone provide a wake-up call. Zurich estimates that in the region of 5%-6% of a company’s turnover goes towards funding the cost of collisions. “If the financial director saw the figures on their balance sheet, businesses would have done this years ago,” says Zurich Risk Service’s Price

Five steps to risk assessment

  • Look for hazards.
  • Decide who might be harmed.
  • Evaluate the risk and decide whether existing precautions are adequate or if more should be done.
  • Record your findings (for organisations with five or more employees).
  • Review your assessment and revise it if necessary.

Case Study: ICI Dulux

Between May 1999 and May 2000, ICI Dulux Trade Paints UK (Commercial Operations), part of the multi-national ICI Group, recorded 28 blameworthy accidents involving cars.

The fleet is located nationwide with home-based sales representatives clocking up an average of 29,000 miles a year. The division began working with driver training firm Drivetech in May 2000 and between January 2004 and January 2005 has clocked up 6.2 million miles with just two blameworthy accidents.

Across the entire fleet of ICI Dulux Trade Paints UK (Commercial Operations), which is composed of 245 cars, there were just 15 culpable accidents. All staff who drive on business – around 600 employees in total – complete a half-day individual driver training course as part of their two-week corporate induction programme. That is followed by a refresher training course every three years, while high-mileage drivers also complete a training workshop after 18 months on the road.

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Every accident – both blameworthy and non-blameworthy – as well as near misses, is investigated by ICI and, if deemed necessary, employees receive counselling and may undergo additional training programmes. The company is now considering utilising Drivetech’s e-learning speed awareness module in its training schedule as well as the company’s driving licence check service.

Jim Kirkwood managing director of Drivetech, says: “The results are compelling and have significantly reduced driver risk – and costs – within the business. In the five years we have been working with the company, the number of miles driven by staff has increased 11%. However, the number of culpable accidents per 100,000 km has reduced from 0.42 to 0.09 and the number of non-culpable accidents from 0.34 to 0.19.”