GRA Project meeting Ashdown House 1030 - 1600hrs 14th July 2009 Notes of meeting Present Peter Cowup Nick Smith Dave Sedman Jacquie Wills Richard Thomas Alan Bailey Bill Butchart Mick Mc Bride Jim Parrott Mark Bishop Mick Titchener Derek Clough London Fire Brigade London West Yorkshire Fire & Rescue Service Yorks & Humber Lincolnshire Fire & Rescue Se~wice East Mids Norfolk Fire & Rescue Se~wice East South Wales Fire & Rescue Service Wales Greater Manchester Fire & Rescue Service NorthWest Tayside Fire & Rescue Se~wice Scotland Durham & Darlington Fire & Rescue North East Fire Brigades Union FBU West Midlands Fire & Rescue Service West Mids London Fire Brigade London Oftice of the Chief Fire & Rescue Adviser CLG Apologies Jenny Morris Callum Bell Sarah-Jane French Dale Ashford Chris Moore HSE Buckinghamshire Fire & Rescue Service South East Wiltshire Fire & Rescue Service South West Northen Ireland Fire & Rescue Setwice North West Lincolnshire Fire & Rescue Se~wice East Midlands 1. Review of current GRA’s in the internal consultation phase. Asbestos: A discussion took place around the changes in legislation brought about by the implementation ofpa~ of the European Regulations for the Restriction, Evaluation, Authorisation and Restriction of Chemicals (REACH) The impact of this on the status of existing exemption certificates and existing arrangements for fire and rescue services is not entirely clear Richard Thomas has been in contact with Jenny Morris from the HSE to get some clarification of the current position (Please see note appendix A). It is hope the position will be clear by the end of October 2009 The committee agreed that till then the Drafi Asbestos GRA will not be published ACTION RT to continue to work with JM to clarify position Trench & Pit (T&P): The C~oup discussed the T&P GRA The group were of the view that the GRA was too long and contained material that although relevant to T&P rescue was not consistent with the agreed standard GRA template LFB00089298_0001 LFB00089298/1
Transcript
GRA Project meeting Ashdown House 1030 - 1600hrs 14th July 2009
Notes of meeting
Present Peter Cowup Nick Smith Dave Sedman Jacquie Wills Richard Thomas Alan Bailey Bill Butchart Mick Mc Bride Jim Parrott Mark Bishop Mick Titchener Derek Clough
London Fire Brigade London West Yorkshire Fire & Rescue Service Yorks & Humber Lincolnshire Fire & Rescue Se~wice East Mids Norfolk Fire & Rescue Se~wice East South Wales Fire & Rescue Service Wales Greater Manchester Fire & Rescue Service NorthWest Tayside Fire & Rescue Se~wice Scotland Durham & Darlington Fire & Rescue North East Fire Brigades Union FBU West Midlands Fire & Rescue Service West Mids London Fire Brigade London Oftice of the Chief Fire & Rescue Adviser CLG
Apologies
Jenny Morris Callum Bell Sarah-Jane French Dale Ashford Chris Moore
HSE Buckinghamshire Fire & Rescue Service South East Wiltshire Fire & Rescue Service South West Northen Ireland Fire & Rescue Setwice North West Lincolnshire Fire & Rescue Se~wice East Midlands
1. Review of current GRA’s in the internal consultation phase.
Asbestos: A discussion took place around the changes in legislation brought about by the implementation ofpa~ of the European Regulations for the Restriction, Evaluation, Authorisation and Restriction of Chemicals (REACH)
The impact of this on the status of existing exemption certificates and existing arrangements for fire and rescue services is not entirely clear
Richard Thomas has been in contact with Jenny Morris from the HSE to get some clarification of the current position (Please see note appendix A).
It is hope the position will be clear by the end of October 2009 The committee agreed that till then the Drafi Asbestos GRA will not be published
ACTION RT to continue to work with JM to clarify position
Trench & Pit (T&P): The C~oup discussed the T&P GRA The group were of the view that the GRA was too long and contained material that although relevant to T&P rescue was not consistent with the agreed standard GRA template
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DC asked members to provide feedback to the originating region via DS Return to be with DS by 14TI~ August 2009
A short discussion then took place around the consultation process and how it operates DC was asked to send out a flow chad/guide to the process
There was also a debate around the naming protocol for the risk matrix This centred on the name of the ’Risk’ column and whether it should be changed to ’outcome’ or
some similar wording The group thought this would give a better interpretation to the column
Action ALL returns to Dave Sedman by 114/8/09
Action DC flowchart/guidance to circulate, (please see Appendix B)
2. High Rise GRA
Following the recent fire in Cambel~vell London involving a High Rise residential block of flats, DC has been asked if the GRA review team could priorities a review of the current High Rise GRA
Following a group discussion and due to the ongoing investigation into the incident the follow was agreed
¯ To establish a review team ¯ London, East region and Scotland as the core team ¯ DC to speak to Eddie Meelan to get go ahead for East regions assistance ¯ Bill Butchart to seek regional commitment at CFOA meeting
NB No review work to start until DC gets clarity of position
Action DC to speak to Chris Boulton and Jon Webb to seek their views
3. Future health and safety guidance review
DC informed the group of the work that was proposed for a review ot~
¯ Volume 1 A guide for senior officers
¯ Volume 2 A guide for managers
¯ Volume 4 Training guide
¯ Dynamic management of risk at operational incidents
A brief discussion took place in which DC asked for views on how future guidance should look Also DC informed the group that he had been asked to organise a seminar at the FSC for late September early October It Was originally proposed that
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the seminar would predominately look and the Dynamic Risk Assessment process However DC hoped to include debate fiom key Fire Selwice stakeholders on the above areas also
Action Group, Any views to DC by 14~ August 2009
4. GRA programme review
DC sought clarity on the current position of the GRA within the review programme
The current poskion is as fbllows
Region Allocated and Start Date Generic Risk Assessment Contact Current position
]anuaQ¢-09 Introduction ;LG/OCFRA Publication July
]anuaQ¢-09 1.1 Turning out Nest Midlands =ublication July January-09 5.8 Flashover & Backdraft ~lorth West =ublication July
:ebruary-09 2.7 Working At Heights --ast (Laurie Booth) ,lational con July
:ebruao/-09 4.1 Roads ~lorthern Ireland 4ational con July
~larch-10 3.7 In Refuse Nest Midlands ~eady for regional consultation 17/7/09
~larch-10 3.9 Places Of Lawful Detention Scotland \pril-10 4.4 Madne ~larine Incident Group
kpril-10 4.5 Helicopters East Midlands ~ay-10 5.1 Electricity South East ~ay-10 5.6 Civil Or Local Disturbance ~lorth West
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Action All please update table where appropriate and return to DC
5. AOB:
JP from the FBU tabled two documents providing guidance to the FBU members engaged in the review of the GRA’s at a regional level (Appe~dix C and D)
The group then discussed the guidance briefly It was agreed that as the GRA process
was starting to follow a defined path that it would be of use to have specific guidance for those engaged in the review process
Committee members were asked to comment on the FBU guidance documents and on guidance in general to JP/DC with their thoughts by 14~1~ August 2009
6. Date and Time of Next Meetings
The following Dates were agreed for the next 4 meetings
September 24TI~ 2009
October 13th 2009
November 17~1~ 2009
December 17th 2009
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APPENDIXA
Information to stakeholders relating to The Control of Asbestos Regulations 2006
and REACH
Health and Safety Executive HSE
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Dear Sir
Health and Safety Executive- For Information:
Unintended effect on the import, supply or use of articles containing asbestos caused by the European Regulation for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
I am writing to you because you canb out activities sul~ject to a cerrificarc of exemption allowing tbe importation, supply or use &articles containing asbestos normally prohibited by past or c:dsting domestic legislation
Since you are still canna ng out tbese activities, and are likely to in tbe fi.tture, you will need to be aware of the unintended legislative consequences on them brought about by the implementation of part of the REACH regulations which take effect from 1st June 2009
The impact of this on the status of existing exemption certificates m~d existing arrangements is not entirely clear However, on the basis of the legal advice we have received and to remove doubt, we are working on tbe presumption tbat we need to reinstate tbe existing legislative frmncwork to allow the continuation of exemptions issued under past domestic legislation and tbe facility to issue new certificates as required Urgent work to achieve tbis is under way and it is currently planned to make tbe necessary," cbanges to recti~" tbe situation by the end of 2009 Further information explaining the issue in more detail is provided in the at~acbed background note
In practical terms tbe nature oftbe risk fi’om any activity in respect &which HSE has or would bavc grm~tcd m~ exemption certificate is unaltered As now, our primar? focus remains to ensure that where work is carried out which may present a risk of exposing persons to asbestos sucb activities are properly controlled and carried out in accordance with tbe requirements of the Control of Asbestos Regulations 2006 m~d related guidm~cc
We will keep you informed oftbe situation If you require fi.wtber information please contact me - details provided below
Samb M allagh Asbestos Unit Long Latency Health Risks Division Healtb and Safety Exectuive
IfI am unavailable please contact Helen Ratcliffe, helen ratcliffc a hse ~si gov uk, telephone
Health and Safety Executive - Background Note:
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Unintended effect on the import, supply or use of articles containing asbestos caused by the direct acting European Regulation for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
REACH is a direct acting European Regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals On Ist June 2009 REACH repeals the existing EU Marketing and Use Directive and replaces it with Annex XVII of REACH which deals with the restriction of substances which pose a particular threat and are deemed to require Community-wide action The text of this annex is relevant to the use, and placing on the market (supply and import/export) of asbestos, including asbestos in existing articles
The annex prohibits placing on the market and use of asbestos and of articles containing these fibres added intentionally, it then gives some relaxations under limited specific circumstances It allows member states to permit the use of articles which were installed or in service before 1 January 2005 until they reach the end of their service life but also allows Member States to further restrict or prohibit this flexibility
Due to a number of problems the European Commission has carried out a protracted review of the text relating to asbestos restrictions which has only just been confirmed in its final version The result is that the new wording of Annex XVII, in addition to the above, now allows Members States the option of the placing on the market (supply and import) of articles in their entirety containing asbestos fibres which were already installed and/or in service before 1 January 2005 (under specific conditions) This means that a system of controlled exemptions can continue
However, in order to meet the 1st June deadline legislative changes within Great Britain have already been put in place by the Lead Depa~ment (Defra) based on the earlier version of the text which did not make provision for Member States to make such exemptions The consequence of this is that the parts of the Control of Asbestos Regulations 2006 allowing exemptions from ~rohibitions within the regulations, including the issuing of exemption certificates will be repealed taking effect from 1~ June 2009
On the basis of the legal advice we have received and to remove doubt, we are working on the presumption that we need to reinstate the legislative framework to allow the continuation of exemptions issued under past domestic legislation and the facility to issue new certificates as required Urgent work to achieve this is under way but it will take time to rectify and legislation is will not be in place before REACH and the recently confirmed wording of Annex XVII takes effect It is currently planned to make the necessary changes by the end of 2009
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Appendix B
GRA Review Format
The Current 40 or so GRA, s contained in the 1998 publication ’A Guide to operational risk assessment’ Volume 3 will be reviewed under the following guide lines, to ensure uniformity in the review process
The GRA will consist of 5 Sections
I. Scope
This section will broadly set out the areas and persons covered by the specific GRA
The GRA should cover persons other than Fire Service personnel affected by our operations
Included in this section could be reference/signpost to any other GRA’s that would have an impact on the activity being carried out
To reiterate that Services have to use the GRA as the first step towards developing their own procedures the following paragraph should be included at the end of each Scope section
As with all GRAS this assessment provides a starting point for Se~w-ices to conduct their own assessments within the context of local conditions and existing organisational arrangements
An Example of scope is given below
This generic risk assessment examines the hazards, risks and controls that relate to Fire and Rescue Service staffand others who may be affected during the period in which they receive an emergency call and begin to respond to the emergency call
This GRA should be considered in conjunction with the contents of GRA 42 1 Working on Station Premises
As with all GRAS this assessment provides a sta~ing point for Services to conduct their own assessments within the context of local conditions and existing organisational arrangements
2. Significant hazards and risks (SHR)
This section is used to identify the SHR associated with the task/procedure
Where possible the section should be broken down into the key activities that make up the overall task and the risks associated with that activity
An example would be a GRA for lifts and escalators that could be broken down into key activities/risks
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¯ Gaining access ¯ Working near moving machinery ¯ Isolationofelectrical supplies ¯ Lifting and handling
3. Key control measures
This section provides the key control measures that should be put in place to reduce the risk to any persons affected by fire se~Mce operations to an acceptable limit
The paragraph below should be used at the start of this section (Your thoughts)
Fire and Rescue Se~Mces should consider how they control the hazards and risks described above Key measures are described below
4. Teclmical references
This section is for the inclusion of any reference material that the authors have used in the preparation of the GRA Or any other reference material that the authors may think users of the manual may find useful
The authors to ensure that they are current must audit any reference document included in the reference section.
NB Where possible direct reference to specific legislative or time dated
material should be avoid. This is to help maintain the GRA as a cmTent
usable docmnent for as long as reasonably practicable.
Please also note that throughout the docmnent where possible reference to specific standards, legislation codes of practice should be avoided
As an example the use of the sentence
PPE to BS 1234 should be worn by all personnel
Replaced by
PPE manufactured to the current accepted standard should be worn
5. A sttmmary produced in table form of the risk assessment
This should be produced in line with the table, matrix etc set out in the introduction to the GRA manual
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The GRA review process
Getting started
GRA review team working group identifies GRA’s to be reviewed
Working Group agree region to carry out specific GRA
H&S Regional Chair informed of review start date
Regional GRA review team working group member (our meeting) informs Rep bodies that they are starting the review
Rep bodies assign a representative to the review
The review
The period is 20 working days as set down in the project plan
The region car~?dng out the review should ensure that the representative bodies are included from the early stages And where possible should involve any other suitable body at this stage
At the end of’the 20 days the reviewed GRA should be returned to the Project Manager (DC) They will circulate it to the other regional teams, FBU (Jon McGee) other rep bodies for comments Comments must be returned to the region rep (GRA originator) within 5 working days
Region makes any changes that are deemed suitable and send GRA to CLG (me)
CLG will then send the GRA for consultation (20 working days days) with the identified key stakeholders
CLG in consultation with the original region carrying out the review make any amendments highlighted from the consultation process
GRA Publishing process
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Appendix C
CIRCULAR 2009H0C JM duly 2009
10th
To: Regional Health ~t Safety Coordinators
Dear Sister/Brother
GENERIC RISK ASSESSMENT REVIEW PROCESS (GRA’S)
At the meeting of Resionat Hea~th ~t Safety Coordinators hetd on the 9th Jury 09, I asreed to write up some 8uiding principtes for those involved in the GRA review process.
Ptease find attached a 8uidance note which you shoutd be aNe to use in any of the discussions on the review of the GRA’s.
Yours sincerely
John McGhee National Officer Health, Safety ~t Welfare
J/4/jr
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GENERIC RISK ASSESSMENT REVIEW - GUIDANCE NOTE
In discussion at NaUona[ tevet it has been agreed that each of the GRA reviews should be written and published in a consistent manner.
The principles to be followed are that each GRA should be broken into four s~cUons:
1. Scope 2. Significant Hazards and Risks 3. Control Measures 4. Technical References 5. GRA Template
In re[aUon to each of these sections we should seek to deal w~th them as follows:
1.1 Scope
The scope of the GRA should include reference to the Emergency Response Working Activities re[aUng to the specific subject.
GRA’s should not be dealing with issues relating to training.
There should not be any cross referencing to other GRA’s as this will be dealt with in the Introduction Section of the complete suite of GRA’s.
1.2. Significant Hazards And Risks
In every GRA we should argue to include as a significant Hazard and Risk "failure to properly implement agreed Command and Control procedures", and also " insufficient
These are two areas which we will need to have consistently raised as serious issues.
Focus should also be on separating Hazards and Risks from Control Measures e.g. do not include references to poor or insufficient training as a Hazard. Training should be a Control Measure.
It is crucial that the significant hazards identified from the task section are real hazards as in "A hazard is any physical and or psychological situation, process or object that has the potential to cause harm to persons, property or equipment." One task can have various hazards associated with it as depends upon the complexity (scope) of task, numbers of persons involved, location and time of day.
The actual harm that an individual is able to receive from the hazard i.e. Low risk such as a graze or short term diarrhoea.
Medium risk such as a broken bone or dermatitis.
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High risk such as death from impact or asbestoses.
GRA’s will concentrate on medium and high risks.
Using the National GRA as a template the local GRA needs to identif~ the sources of information (Key Performance Indicators) to allow correct measurement of risk to be identified.
These could be accident statistics, frequency of use, policy performance indicators, safety rep repots, RA review repots etc.
Specific hazards that the FBU has identified as generic to Standard Operating Procedures (SOPS)
Dynamic Risk Assessment (DRA) - FRS have developed the use of DRA away from the original guidance. The FBU believe it does not provide a safe system of work.
Speed & weight of response - evidenced research has proved that speed and weight of response have a dramatic impact on resolving emergency situations especially fire and road traffic accidents. Escalating incidents have the potential to increase risks to firefighters and the public. Insufficient resources especially on initial a~endance will also increase the risks to firefighters and the public. The FBU believes there is overwhelming evidence to support early intervention with the right resources, commonly referred to as speed and weight of response, saves lives and reduces the impa~ of emergencies. Even the government accepts that increased response times may have led to about 13 additional fatalities in dwelling and Other Buildings fires each year, possibly 65 additional deaths in Road Traffic Collisions (RTCs) and an £85m increase in Other Buildings fire damage (source Fire Research Report 1/2009).
1.3. Key Control Measures
The Key Control Measure sec~on should include 5 standard parasraphs on the fo[[owin8 headings:
1. Pre P[annin~ 2. Trainin8 3. Incident Command 4. Persona[ Protective Equipment (PPE) 5. Safe Systems of Work
The Key Control Measures should then be laid out in more detail, in the table (a sample is attached), cross referrin8 to the Hazards and Risks identified in Section 2 of the GRA.
We should arsue that in each GRA the first Control Measure should include reference to Incident Command System (ICS) and the provision of adequate resources.
FRS through the GRA process will need to investigate their current Safety management systems to ensure they remove hazards or reduce the risks to as low as reasonably practicable (ALARP). Through the GRA process FRS will need to identify that all foreseeable risks are considered and are prepared for. These will form safe systems of work by removing or limiting persons exposure to identified hazards.
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Supervision/management will limit the risk to persons who are carrying out the task. Training for risk will ensure these persons are competent to select the correct system of work, using suitable equipment and PPE. When looking at control measures it has to be under the all encompassing umbrella of HSG65. Control measures through Policy, Planning, Implementation, Monitoring performance and Review.
Dynamic Risk Assessment (DRA) will have to be removed as a control measure until an urgent review of this system is carried out and the hazards present from DRA are reduced to an acceptable level. Speed & weight of response - The way in which Fire and Rescue Services utilise their resources has developed over several decades resulting in what can be termed as Standard Operating Procedures (SOPs) i.e. the way in which a Fire and Rescue Service achieves successful conclusions for a variety of fires and other emergency incidents. Standard Operating Procedures should be constructed with the aim of ensuring that safe systems of work are pre panned and used at emergency incidents to ensure a safe and successful conclusion. FRS through the GRA process will need to investigate their current Safety management systems to ensure they remove hazards or reduce the risks to as low as reasonably practicable (ALARP). Through the GEA process FRS will need to identify that all foreseeable risks are considered and are prepared for. These will form safe systems of work by removing or limiting persons exposure to identified hazards. Supervision/management will limit the risk to persons who are carrying out the task. Training for risk will ensure these persons are competent to select the correct system of work, using suitable equipment and PPE.
When looking at control measures it has to be under the all encompassing umbrella of HSG65. Control measures through Policy, Planning, Implementation, Monitoring performance and Review.
Dynamic Risk Assessment (DRA) will have to be removed as a control measure until an urgent review of this system is carried out and the hazards present from DRA are reduced to an acceptable level. Speed & weight of response - The way in which Fire and Rescue Services utilise their resources has developed over several decades resulting in what can be termed as Standard Operating Procedures (SOPs) i.e. the way in which a Fire and Rescue Service achieves successful conclusions for a variety of fires and other emergency incidents. Standard Operating Procedures should be constructed with the aim of ensuring that safe systems of work are pre panned and used at emergency incidents to ensure a safe and successful conclusion.
1.4. Technical References
This should be a comprehensive list of technical documents which would be of assistance or essential to Fire and Rescue Authorities when producin8 their own Risk Assessments or Standard Operating Procedures.
2. GRA Template
template is divided into six co[umns~
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1. Ref No. 2. Task 3. Hazard 4. Potential Harm 5. Persons at risk without control measures 6. Control measures
use GRA TEMPLATE - FBU GUIDANCE JULY 2009 (attached)to poputate
