Cambridge University Reporter


REVIEW OF THE HEALTH AND SAFETY DIVISION (JANUARY 2006)

Executive summary and summary of recommendations

1. The Committee is satisfied that the Division has had considerable success in improving the University's health and safety arrangements over the last few years. The Director and the members of her staff can take credit for the fact that the profile and awareness of health and safety issues have been considerably raised in the University. This has been an important factor in the achievement of compliance throughout the University with rapidly changing health and safety legislation.

2. While it acknowledges that it is difficult for the Division to balance providing advice to institutions with monitoring compliance, the Committee is concerned that the prioritization of activities is not as effective as it might be.

3. Overall, the Committee feels that the Division's performance and achievements have been mostly adequate, but that, in some areas of strategic planning, leadership, quality control, value for money, policy development and training, improvements should be made as described in the following recommendations.

The Review Committee wishes to thank all staff in the Division for their ready co-operation and support in the review process.

Recommendation 1: The Division should urgently draw up a more robust strategic plan as to how its present and future activities can best deliver the features identified in the overall plans for the management of health and safety within the University. This plan should include a detailed operational plan, prioritized in line with sound risk assessment and, if necessary, identify the areas where additional resources may be required.

Recommendation 2: The Division should review its budgets with the aim of reallocating resources where they might be deployed more effectively.

Recommendation 3: The Division should review the number and level of staff posts and draw up a strategy to revise the staffing structure within the Division.

Recommendation 4: The Director should be given additional support by a designated senior colleague.

Recommendation 5: The training programme should be overhauled and consideration should be given to the proposals outlined in Paragraphs 25 and 26.

Recommendation 6: The audit programme should be reviewed to ensure that it is in the best interests of the University.

Recommendation 7: It is recommended that the circulation of annual questionnaires should take account of the audit programme and that all data collected should be methodically analysed to help the University monitor and alleviate potential risks.

Recommendation 8: The membership of the Health and Safety Executive Committee should be strengthened, and the administrative arrangements of the Consultative Committee for Safety should be reviewed.

Recommendation 9: Every effort should be made for the relationship between the Division and the professional departmental safety advisers to be strengthened as soon as possible.

Recommendation 10: It is recommended that options for the Occupational Health Service to be relocated nearer to the Division should be investigated as soon as possible.

Recommendation 11: The Division should be proactively engaged in monitoring effective management of health and safety in situations that involve collaborations between the University and non-University institutions/companies.

Recommendation 12: The Division should take more account of value for money considerations when deciding on appropriate methods for dissemination of information.

I. Introduction

Background of the review and terms of reference

4. As part of the rolling programme of reviews of the Divisions of the Unified Administrative Service (UAS), the Council, at its meeting on 24 January 2005, established a Committee to undertake a review of the Health and Safety Division. The Committee was given the following terms of reference:

To report to the Registrary on

Membership

5. Members of the Review Committee:

Procedure

6. The Committee used the following methods of investigation:

(i) written documentation on the national and University context, service delivery, organization and management systems, and external scrutiny, such as
  • (a) self-assessment submitted by the Health and Safety Division;
  • (b) information on the Division, for example, staff charts, financial summaries of accounts, statement of health and safety policy, and the staff development policy;
  • (c) selection of policy statements and guidance on various health and safety issues;
  • (d) internal audit report and follow-up report;
  • (e) programme of health and safety audits and feedback;
  • (f) feedback from members of the University and others;
(ii) interviews with
  • (g) the Director and senior staff;
  • (h) the Pro-Vice-Chancellor (Planning and Resources), the Registrary, the Administrative Secretary and the Consultant Occupational Health Physician;
  • (i) Departmental professional safety advisers and representatives of part-time departmental safety officers;
  • (j) staff from cognate Divisions in the Unified Administrative Service;
  • (k) representatives of the trades unions.

A list of people who provided written and/or oral evidence is attached in Appendix A.

II. Health and Safety Division

History

7. Before the Division was formed as part of the Unified Administrative Service, overall responsibility for health and safety at work used to rest with the Council and the General Board. The office of University Safety Adviser was part of the General Board Office, and the Safety Adviser was ex officio Secretary of the Committee for Safety and reported to the Secretary General.

Organization and structure

8. The Health and Safety Division is now one of the eight Divisions of the Unified Administrative Service, of which the Registrary is the Head. The Director of the Division is 'responsible for enhancing, promoting and maintaining an effective health and safety management system' (see Reporter, page 570, 22 March 2000).

9. Heads of Department and Chairs of Faculty Boards are responsible for health and safety at institutional level. Every institution has at least one designated safety officer; this role can be fulfilled by the Head of Department, a full-time professional safety adviser or a member of the institution in a part-time capacity. Some Departments (Chemistry, Physics, Chemical Engineering and Engineering) and two Schools (Biological Sciences and Clinical Medicine) have professional departmental safety advisers. Although not directly associated with the Health and Safety Division, the full-time professional safety advisers represent an important source of knowledge and expertise and make an important contribution to the management of health and safety within the University.

10. Cognate functions are organized as follows:

Resources

Staff

11. In 1999, the University Safety Adviser was supported by three officers, five secretarial/administrative staff and four technicians; he was also responsible for the Security Office (one officer and a secretary) and the Environmental Office (one officer and a part-time secretary). Since its inception, the number of staff employed in the Health and Safety Division has grown extensively and now encompasses nine officers, eight secretarial/administrative staff and five technicians; a total of 23 members of staff, including the Director. A copy of the staff chart is attached as Table 1 (p. 934).

Accommodation

12. The Division has recently moved into refurbished accommodation previously occupied by the Management Information Services Division on the Old Press Site, 16 Mill Lane. All staff of the Division are thus, for the first time, in one location. The Division is also responsible for the radioactive store at High Cross.

Funding and budgets

13. The overall annual recurrent budget of the Division, including chemical waste disposal, was approximately £869,000 in 2004-05, an increase of over 200% since 2000-01, when it was £423,592. It is likely that the budget for chemical waste disposal will have to be increased over the next few years; the Committee considered the question whether charges for this service should be devolved to departmental level. Various activities of the Division are funded on a non-recurrent basis.

14. Expenditure on health and safety within the University overall is, however, much greater, as the budget of the Division (Head 1(d) of the Estimates) does not take account of the salaries of the full-time departmental and Schools safety advisers, payments of departmental safety officers, and resources held by the Estate Management and Building Service for refurbishment work that is necessary because of health and safety requirements, nor do these accounts include the budgets for health and safety expenditure incurred by the Occupational Health Service and the Security Office.

Comparison with practice in other leading universities

15. It is difficult to compare the performance of the Division directly with other universities, since each university deals with health and safety in different ways. In particular, the Universities of Cambridge and Oxford are quite different to most other UK universities, because of their collegiate structure, which separates the responsibilities for the management of health and safety in practical teaching and research activities from student-based activities, including residential accommodation, sports and student unions. The Cambridge Colleges are individually responsible for all aspects of health and safety associated with their own College-based activities. In some universities, the safety office includes specialist advisers on biological safety, fire safety, occupational health and radiation protection, in others some or all of these specialities are separated. There is also a difference in reporting arrangements between universities: some report to the most senior non-academic (the Registrar or College Secretary), others report to the Human Resources section, and some report to the Estates Office.

III. Key issues

16. The Committee is satisfied that the Division has had considerable success in improving the University's health and safety arrangements over the last few years. The Director and the members of her staff can take credit for the fact that the profile and awareness of health and safety issues have been considerably raised in the University. This has been an important factor in the achievement of compliance throughout the University with rapidly changing health and safety legislation.

17. In accordance with its terms of reference, however, the Committee would like to draw attention to the following concerns raised during the review. Recommendations are made in specific cases where the Committee feels that improvements could be made that would benefit the University.

Management of the Division

Strategic plan and policies

18. The Review Committee was satisfied that the Division had been responsible for the development of appropriate strategic plans for the overall management of health and safety within the University. However, the Committee was unable to identify a sense of strategic direction for the internal management of the Division itself, targeted towards achieving the objectives set out in the overall plans. Consequently, the Division lacks a clear rationale for the setting of priorities. Specific policies on health and safety should be developed according to the needs of the University in a proactive manner and not as a reaction to matters identified by others. Too much of the work is reactive, with disproportionate time and resources spent on some activities rather than others that appear more urgent. The Committee feels, for example, that the amount of resources spent on auditing outweighs its possible benefit to the minimization of risk within the University. Similarly, the Committee is not convinced that the training programme has been drawn up according to a properly conducted risk assessment (Paragraphs 25 and 26). Furthermore, the Committee is concerned that there is insufficient strategic planning in the distribution of specialist areas covered by members of staff in the Division; thus, for example, the recent post in food and biological safety seems to have been devised without making full use of specialist knowledge already present in cognate areas outside the Division.

19. The Division should be clearly in charge of the development and execution of the University's health and safety policy and should, accordingly, draw up a risk-based strategy for its present and future activities. In doing so, it would be appropriate to consult with the professional safety advisers in the Departments and Schools and with the two central University committees on health and safety. Although there is now much high-quality guidance covering many subjects available in print and/or on the web, there is an urgent need for the production and dissemination of University-wide policies in several key areas, such as manual handling, electrical safety and risk assessment. The Committee understands that work in some of these areas has been in progress for some time, in some cases years, but is concerned that it has not been sufficiently prioritized in relation to other work undertaken in the Division.

Recommendation 1: The Division should urgently draw up a more robust strategic plan as to how its present and future activities can best deliver the features identified in the overall plans for the management of health and safety within the University. This plan should include a detailed operational plan, prioritized in line with sound risk assessment and, if necessary, identify the areas where additional resources may be required.

Resources

20. The Committee considers that the Division has sufficient funding at its disposal overall, but there is an urgent need for increased efficiency in the use of the available resources. There are no obvious criteria for the divisional allocation of resources: prioritization should be undertaken within the framework of a more robust strategic plan (see Paragraphs 18 and 19). Considerations of quality control, fitness for purpose and value for money should be given higher priority in various areas, for example training, where changes in the production and distribution of information, more efficient use of time and accommodation, and increased sharing of resources with other Divisions, might release funding for other issues. The Committee is, furthermore, concerned that the Division occasionally appears to be unaware of potential sources of funding within the University, for example, the budget held by the Advisory Group on Administrative Training.

Recommendation 2: The Division should review its budgets with the aim of reallocating resources where they might be deployed more effectively.

Staff

21. The Division should use the operational plan as a framework within which it considers whether job descriptions are appropriate, ensuring that there is no duplication (for example, with the activities of the professional departmental safety advisers) and that the methodology is based on value for money (see Paragraph 20). This review should include a thorough appraisal of all activities and might lead to reprioritization and/or outsourcing of certain activities. The Committee encourages the Division to ensure that there is increased co-operation with staff in cognate Divisions.

22. In comparison with other administrative Divisions and academic Departments and Faculties, the Division is overprovided with junior secretarial and clerical staff, but lacks a relatively senior administrative officer who would be able to exercise quality control for the various activities of the Division and advise on drafting documentation and preparing funding applications.

23. Table 2, attached at the end of the report, shows the staffing levels of safety offices within the Russell Group of universities. It is based on information obtained from the websites of the safety offices, and where the information was not available on the university website the relevant office was contacted by telephone. The table clearly demonstrates that Occupational Health services are usually separate from the Safety Office but that universities are fairly evenly divided between those where the Fire Office is part of the Safety Office or is located elsewhere. Only Edinburgh and Imperial identify a member of staff specifically dealing with audit. The Health and Safety Division in Cambridge has the highest number of staff within any university safety office despite the fact that the Division does not include fire safety or occupational health in the activities it covers. In addition, some specialist support, for example, for some aspects of biological safety, is not based within the Division but provided by a safety adviser located in one of the Schools. The most obvious difference between the universities is the higher level of clerical support at Cambridge.

Recommendation 3: The Division should review the number and level of staff posts and draw up a strategy to revise the staffing structure within the Division.

Director

24. The Director's remit includes a very wide range of duties and responsibilities, from administration of the Division, the oversight and control of all health and safety matters in the University, to liaison with external enforcement agencies. The Committee has come to the conclusion that it would be helpful to the Director if she had access to, on the one hand, enhanced senior administrative support from within the Division as outlined in Paragraph 22 and, on the other hand, high-level support and guidance from a senior colleague, for example, the Chairman of the Health and Safety Executive Committee or a designated deputy. The latter would provide the additional authority for the Director to fulfil her responsibilities to co-ordinate health and safety activities across the University. The Committee is aware that the Directors of two other UAS divisions, Personnel and Research Services, have direct access to and support from Pro-Vice-Chancellors.

Recommendation 4: The Director should be given additional support by a designated senior colleague.

Training

25. The amount of safety training provided by the Russell Group universities varies considerably, with the greatest level of training usually associated with the universities that have the larger safety office (Oxford is the main exception to this). Running approximately 100 courses per annum, the Health and Safety Division in Cambridge provides a large number of training courses across a broad range of topics and is therefore one of the leading universities in this field, measured in sheer quantity. Evidence gathered suggested, however, that the quality of training is varied, with some courses appearing to achieve little more than a general raising of awareness of health and safety issues. In some cases, doubts were expressed about whether some of the trainers had sufficient experience of the issues under consideration, and there was an overwhelming concern that training sessions were often not sufficiently tailored to the particular needs of the audience. The Committee itself is concerned that value for money is not fully taken into consideration when the programme is drawn up and that there may not be appropriate criteria for prioritization of best use of staff time at that stage. Training is clearly very important and it is therefore essential that the effectiveness of the sessions is monitored more systematically as a matter of urgency. Feedback forms are distributed and collected, but the information obtained does not appear to be processed in any strategic or comprehensive manner.

26. The Committee recommends that the whole training programme should be reviewed with the aim of developing a programme which is better focused on the needs of Departments and Faculties. The Division should set up a structured training programme for departmental safety officers, ranging from a basic one-day training course, such as the one developed by the Chartered Institute of Environmental Health, known as the CIEH supervisors course, and leading on to the National Examination Board in Occupational Safety and Health (NEBOSH) General Certificate Course. Departments with a high level of hazardous activities should have departmental safety officers qualified to NEBOSH Diploma level. As much as possible of the structured training programme (but not the NEBOSH Diploma) should be delivered by staff from the Division, and involving the professional departmental safety advisers where they have appropriate expertise. This would standardize the approach to health and safety across the University, and enable staff in the Division to learn more about local issues. The Staff Development Section of the Personnel Division should be involved in the advertising and booking arrangements, apparent computer incompatibility notwithstanding. The expansion of the training programme to include training for the NEBOSH Certificate and Diploma might well be beyond current budget provision and would certainly require additional commitment from post-holders. Otherwise, however, no additional funding should be necessary: it is the considered view of the Committee that sufficient money can be saved through reallocation of other resources to finance a revised programme.

Recommendation 5: The training programme should be overhauled and consideration should be given to the proposals outlined in Paragraphs 25 and 26.

Safety audits and annual questionnaires

27. The Division undertakes a comprehensive programme of safety audits throughout the University to monitor compliance with safety legislation and to reassure itself that appropriate controls are in place. In addition, the audit programme serves as another data and information gathering exercise. Based on the evidence presented, the Committee reached the conclusion that, ideally, the audit programme should have started off with a lighter-touch regime; in fact, it attempted to monitor systems before they had been properly implemented. There is criticism that the standards applied during the audits are inconsistent, which may be the result of too many different members of the Division conducting the audits. The Committee feels that it would be more effective if the audits were undertaken by fewer individuals. This would certainly make comparisons of the results easier and more valid. According to the Director, at least 30% of working time within the Division is spent on audits, and eight members of staff have been trained as auditors. The paperwork required appears to be out of proportion to the potential risks for the University, and the effort of preparing for and the conduct of the audits, both by the audited institutions and the auditors, does not represent value for money overall. It has been represented to the Committee that the process is much more preoccupied with the inspection of paperwork and ticking boxes than with inspecting potentially hazardous activities. There is substantial doubt as to whether local safety standards are actually improved by the current audit process. Given that the responsibilities for health and safety are devolved to the local head of institution, it would be entirely appropriate for staff of the Health and Safety Division to conduct detailed inspections of activities within an institution in addition to scrutiny of the related health and safety paperwork. Recommendations for action identified in audits often depend on co-operation between the institution, the Division and EMBS and/or the Occupational Health Office, but there is no rigorous mechanism in place to ensure that recommended actions have been put in place. Although many of the Departments and Faculties and other institutions have already been audited in the first round of the audit programme, the Committee suggests that the Division should undertake a review of the process to establish whether the way audits are currently conducted is appropriate and whether the balance between staff of the Health and Safety Division giving guidance to institutions and the same staff subsequently monitoring performance is appropriate.

Recommendation 6: The audit programme should be reviewed to ensure that it is in the best interests of the University.

28. Representations were made to the Committee that the data collection through the distribution of safety questionnaires was not value for money and partly represented duplication of effort by too much overlap with the audit programme. There should therefore be a closer correlation between a revised audit regime (Recommendation 6) and the circulation of safety questionnaires. All such data gathering exercises should be more clearly focused, and the time and effort expended both by the institutions concerned and the Division should be proportionate to the overall benefit to the University. The evaluation of all information collected should be done in a more analytical and risk-based way.

Recommendation 7: It is recommended that the circulation of annual questionnaires should take account of the audit programme and that all data collected should be methodically analysed to help the University monitor and alleviate potential risks.

Committees

29. Several committees deal with health and safety matters in the University. The main committees are (i) the Health and Safety Executive Committee, whose role it is to reassure itself that the structure, processes and broad policies relating to health and safety in the University are adequate, and to lend appropriate authority to all health and safety matters in the University, and (ii) the Consultative Committee for Safety, which fulfils the statutory role of consulting with the staff and unions. There are also five specialist sub-committees, relating to 'Ionizing and Non-ionizing Radiations', 'First Aid, 'Chemical Hazards', 'Safety, Education and Training', and 'Biological Safety'. These sub-committees draw upon the expertise of a number of academics and professional safety advisers. Conflicting representations were made to the Review Committee about the administrative arrangements and performance of the Consultative Committee, with considerable concern expressed by some that action points were often not followed up and that business was not always brought to conclusion, which may be a factor of it being a 'consultative' and not an 'executive' body. Most importantly, the Review Committee proposes that the Health and Safety Executive Committee should give further support to the Division by playing a more significant, advisory role, helping the Division to be more proactive and to communicate its mission more clearly throughout the University. This could be achieved, at least in part, by strengthening the membership of the Health and Safety Executive Committee through the appointment of two external members and the inclusion of a representative from the Occupational Health Service and a representative from the group of professional departmental safety advisers. The Review Committee further recommends (see Paragraph 24) that the Chairman or a designated senior member of the Committee should be available to give ongoing professional support to the Director and to help her co-ordinate health and safety activities more generally.

Recommendation 8: The membership of the Health and Safety Executive Committee should be strengthened, and the administrative arrangements of the Consultative Committee for Safety should be reviewed.

Relationship with professional departmental safety advisers

30. One of the main issues the Review Committee identified during the review concerns the relationship between the Division and the professional safety advisers in the Departments and Schools, which is in urgent need of improvement. There is a great deal of professional expertise among the departmental safety advisers and it would be prudent for this expertise to be available to the University in general. Departmental safety advisers have, for example, made substantial contributions to the production and content of the Division's booklets and to other health and safety guidance - often without any administrative support, and it is important that their contributions are properly recognized and appreciated. More effective co-operation is particularly important in this area, and it would be appropriate for the Division to consider how the review of its structure could provide administrative support to the departmental safety advisers who assist in the production of guidance and documentation. In order for health and safety controls in the University to operate efficiently, it is essential that communication channels are re-established as a matter of urgency; only then can effective co-operation be resumed. To achieve this, the Review Committee proposes that the Director should convene regular meetings between the two groups, with the Division taking the initiative rather than having alternating arrangements, as is currently the case. Representatives from EMBS, the Occupational Health Service and the Security Office should also be invited to join, and there should be regular agenda items, including updates on policy development and building projects, as well as items covering health and safety issues. The Review Committee suggests the inclusion of a representative of the group of departmental safety advisers on the Health and Safety Executive Committee (see Paragraph 29) and continued representation of members of this group on the Consultative Committee for Safety.

31. General guidance on health and safety matters should be issued by the Division, but it would be prudent for drafts to be produced in consultation with the professional specialists throughout the University.

Recommendation 9: Every effort should be made for the relationship between the Division and the professional departmental safety advisers to be strengthened as soon as possible.

Relationships with cognate Divisions and others

32. The relationships with the Fire Safety Office (EMBS), the Environmental Office (EMBS), the Security Office (Secretariat) and the Occupational Health Service (Personnel Division) are generally good, as is the relationship of the Division with the trades unions. Organizational problems can occasionally arise from unclear boundaries, but changing the current structure and location of responsibilities would not solve potential problems. Instead, it is essential that communication is fostered and that links are, wherever possible, strengthened. The move of the Division into one set of offices on the Old Press Site is a positive development, particularly as it has been possible for the Division to remain in close proximity to most of the cognate Divisions. One concern raised with the Review Committee is that the Occupational Health Service is still located some distance away from the Division. The Occupational Health Physician informed the Review Committee that there was an increased risk of stress amongst staff in higher education generally and that in Cambridge responsibility for this issue was shared by the Division, the Counselling Service and the Occupational Health Service. The Review Committee therefore recommends that the Occupational Health Service and the Division are co-located as soon as this is feasible and that the Service is represented on the Health and Safety Executive Committee (see Paragraph 29 and Recommendation 8). This would enable the Service and the Division to co-operate even more closely in the areas of mutual interest.

Recommendation 10: It is recommended that options for the Occupational Health Service to be relocated nearer to the Division should be investigated as soon as possible.

33. Effective links with institutions who share University accommodation, for example, the NHS and MRC on the Addenbrooke's site, are important now and are likely to become even more important with the increase of embedded laboratories throughout the estate and with the blurring of traditional organizational boundaries. It is essential that the Division is proactive in this area and that it takes a high-level strategic view on co-operation with such companies and institutions in the area of health and safety issues. At a more practical level, the Division should take a lead in ensuring that there are clear and robust agreements between the parties involved, detailing responsibilities and liabilities, and that there are effective channels of communication.

Recommendation 11: The Division should be proactively engaged in monitoring effective management of health and safety in situations that involve collaborations between the University and non-University institutions/companies.

Value for money

34. The Review Committee acknowledges that it is better value for money for University staff to undertake training and auditing than using external agencies.

35. Most universities maintain a website containing information on policies, codes of practice, guidance, training courses, and similar, relevant information. Access to these sites is sometimes restricted to members of the particular university, and it has therefore not always been possible to make direct comparisons. The Health and Safety Division in Cambridge produces a wide range of information most of which is available on request from the Division. The Review Committee commends the Division on the amount and range of information offered in Cambridge, which makes Cambridge one of the leaders in this field. The Review Committee is, however, not convinced that value for money has been a key factor in deciding what method should be used for the dissemination of information. Many leaflets cannot be downloaded from the website but need to be ordered, and some of the brochures are very expensively produced. The Review Committee recommends that the Division should, overall, take more account of value for money considerations in relation to dissemination of information.

Recommendation 12: The Division should take more account of value for money considerations when deciding on appropriate methods for dissemination of information.

H. A. CHASE, Chairman

10 January 2006

Appendix A

The following have kindly provided evidence for the review, in writing or through interviews with members of the Review Committee:

TABLE 1: The Health and Safety Division

This information is provided as a PDF file:

TABLE 2: Staffing levels of safety offices in Russell Group universities

UniversityTotal staffClericalBiologicalRadiationFireOccupational Health
Birmingham1431212.5
Bristol122P/T11Separate
Cambridge23814SeparateSeparate
Cardiff8?11SeparateSeparate
Edinburgh2241256
Glasgow911?2Separate
Imperial14323SeparateSeparate
King's7?1?1Separate
Leeds102111Separate
Liverpool31??SeparateSeparate
LSE1---SeparateSeparate
Manchester1021SeparateSeparateSeparate
Newcastle721Separate1Separate
Nottingham611?1Separate
Oxford142.5131Separate
Sheffield122123Separate
Southampton112 12Separate
UCL12?1SeparateSeparateSeparate
Warwick511?SeparateSeparate

Review of the Health and Safety Division: Response from the Registrary

1. I am grateful to the members of the Review Panel, and in particular to its Chair Professor Chase, for their hard work and thoroughness. In accepting the Report for my part, and subject to my comments below, I would also wish to record my appreciation for the open and constructive way they went about their work.

2. I have discussed the Report with the Director of the Division and set out my comments, below, against the Report's recommendations.

3. First however, I would wish to underline the comments at paragraph 1 of the Report. The Division was created following a review that in turn followed an unfortunate incident that had resulted in the prosecution of the University over wide-ranging management issues. The Division's origins were in an office which was smaller and less well resourced than the Division. I am glad that the Review has recognized that the Division, through its staff, has achieved much over the last five years. Clearly there is more to be done but it is the case that overall the University's performance and reputation in this area is much enhanced, not least with the regulatory authorities. The Division has played a significant part in those achievements.

COMMENTS (in italics after the recommendations, reproduced from the Report)

Recommendation 1: The Division should urgently draw up a more robust strategic plan as to how its present and future activities can best deliver the features identified in the overall plans for the management of health and safety within the University. This plan should include a detailed operational plan, prioritized in line with sound risk assessment and, if necessary, identify the areas where additional resources may be required.

A strategic plan currently exists, drawn up on risk assessment principles. Progress against targets is reported to the Health and Safety Executive Committee. These existing arrangements can be developed along the lines suggested by the Review (but see below (Recommendations 2, 4 and 8)).

Recommendation 2: The Division should review its budgets with the aim of reallocating resources where they might be deployed more effectively.

It is accepted that it is timely to review budgets within the Division; indeed work to this end had already begun last term given that resources in the Division have been under budgetary pressure in recent years. There is only limited scope for redistribution of funds within HSD. There may be some scope for redistribution of funds within the UAS budget overall. It would seem sensible and appropriate for the Health and Safety Executive Committee to receive an annual report on the Division's budget and expenditure plans. One particular issue has been a concern for several years, which is the position within the Division of the budgets for hazardous waste disposal and first aid training, expenditure against which is not in practice under the control of the Director.

Recommendation 3: The Division should review the number and level of staff posts and draw up a strategy to revise the staffing structure within the Division.

Agreed. However, whilst a functionality and structural review would be potentially beneficial, it will necessarily raise issues about the working relationships and respective responsibilities of other safety professionals in the University. There is nevertheless a need, which is accepted, to ensure that the staffing arrangements within the Division are optimal.

Recommendation 4: The Director should be given additional support by a designated senior colleague.

Agreed in principle. To be considered within the review under Recommendation 3.

Recommendation 5: The training programme should be overhauled and consideration should be given to the proposals outlined in paragraphs 25 and 26.

The current programme is drawn up on risk assessment principles, responding to the needs of Departments. There are however options for change and for the rationalization of administration which will be followed up when the Assistant Director (Staff Development) is in post within the Personnel Division.

Recommendation 6: The audit programme should be reviewed to ensure that it is in the best interests of the University.

Agreed. However, the regulatory authorities place significant reliance on the audit programme and decisions about its future must be clearly risk assessed. The Director and I had initiated reconsideration of the pace of the audit programme, and thus of its annual cost to the HSD budget, prior to the Review Report.

Recommendation 7: It is recommended that the circulation of annual questionnaires should take account of the audit programme and that all data collected should be methodically analysed to help the University monitor and alleviate potential risks.

Agreed.

Recommendation 8: The membership of the Health and Safety Executive Committee should be strengthened, and the administrative arrangements of the Consultative Committee for Safety should be reviewed.

As the Report acknowledges, these are matters that fall outside the normal scope of a review. The membership of the Executive Committee, in particular, is a matter for the Council and the General Board to whom the Committee reports. It may perhaps be appropriate for the Council to invite Dr Pretty, Pro-Vice-Chancellor, to take this matter into her consideration of the governance arrangements for non-school-institutions. Dr Pretty chaired the earlier review that gave rise to the present arrangements and the Report raises questions about the relationship of the Division to other sections of the administration and other Departments.

Recommendation 9: Every effort should be made for the relationship between the Division and the professional departmental safety advisers to be strengthened as soon as possible.

Welcomed and agreed. A progress report will be made to the Health and Safety Executive Committee in six months' time.

Recommendation 10: It is recommended that options for the Occupational Health Service to be relocated nearer to the Division should be investigated as soon as possible.

Agreed in principle. In practice this recommendation needs to be considered in the context of the University's plans for accommodation for the central administrative offices including the UAS. A paper relating to the Old Press Site redevelopment will be presented to the Planning and Resources Committee this term. The Old Press Site is specified as the eventual location for the administration in the University's Estate Strategy.

Recommendation 11: The Division should be proactively engaged in monitoring effective management of health and safety in situations that involve collaborations between the University and non-University institutions/companies.

Agreed. The Division is already active in this area and were contributors to, and in part instigators of, the recent internal audit report on embedded companies.

Recommendation 12: The Division should take more account of value for money considerations when deciding on appropriate methods for dissemination of information.

Agreed, subject to statutory requirements. Specific customer/user feedback will be sought on the current publications. The Report's comments also imply that the UAS should develop an integrated policy for its publications. This will be considered when the recently commissioned review of the University website has reported.

T. J. MEAD
January 2006