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Question1: The description albeit ‘traditional’ is still valid as the core of occupational health, although it may need some widening (see below).
Question 2: The vision as worded is correct but rather narrow. Work should be fulfilling and accessible to all regardless of their health status.
Question 3: The most important of "other matters" is education and awareness of occupational health in society as a whole. This should be an integral part of school education in much the same way as sex and drugs education, and personal and social development. The HSE should seek to influence and work with the educational establishment, and therefore this should become a strategic aim (Question 4). One other tactic to support this aim would be for the HSE to use Information Technology, and especially the Internet as a resource not simply to publicise its own regulations but as an educational tool which schools and indeed even workplaces can access.
Question 4: See above (question 3)
Question 5: The role of the Safety Committee should be expanded either by statute or by guidance: if safety committees include amongst their functions, being a "user committee" for occupational health and safety services and debate their delivery, this should give employees as well as employers, more of an "ownership" in the methods of preventing work related illness.
Question 6: The Health and Safety Executive could greatly facilitate matters for small firms if it simply followed the policy of making all of its publications freely available on the Internet. Small firms would then not have financial or other inhibitions of accessing the information. Clearly this might mean less revenue for HSE Books, but surely the aim must be to make things as easy as possible for small firms in relation to health and safety rather than to claw back a few pennies for Government.
Question 8: Regulation on the basis of risk should not be taken to imply that regulations should be developed and/or applied merely to high risk situations.
Question 9: Yes targets should be set. However the aim "to reduce all work related ill health by 20% by 2010" is rather simplistic. Occupational ill health in specific areas is already being measured through the occupational physician reporting activity, which encompasses things such as SWORD etc. Some of these areas, eg occupational asthma could be used to set targets. It is true the targets will not cover the full range of occupational health, but they would serve as good surrogate indicators. Thus I do believe that if steps are taken to achieve one target, the improvement in practice would "rub off" and have generally beneficial effects on other aspects of health and work.
Question 10: The issue of competence has to be tackled in more depth by HSE - to make sure that sound professional advice is available at a specialist level. At a level below that of a specialist, the HSE must campaign to ensure that management trainees, nursing and medical students achieve a basic level of knowledge and understanding which will permit them to recognise the issues in which specialists can contribute and know how to seek and obtain that specialist advice.
Question 11: The response to this is tied into my Question 6 comment about availability of all legislation, approved Codes of Practice and guidance for free on the Internet.
Question 14: I agree that an early warning of new diseases would help. One might even argue that a precautionary principle should apply in which the level of certainty for action to be taken should be lower than currently the case. Thus one could institute prospective health surveillance on the basis of a ‘precautionary’ level of certainty. However, one must not lose sight of the fact that a lot of ill health - probably the majority - is caused by diseases or mechanisms that we already know about and which we know how to prevent, but this prevention is unfortunately not being implemented and/or enforced.
Questions 15 16, and 17: Training is essential not just at shop floor level but for management as well. In particular in relation to question 17 the point ought to be made that the manager is not properly trained unless he has essential elements of health and safety training including knowledge, skills and importantly attitude.
Question 18: I do not believe that so-called quality assurance as applied and interpreted at present fits the bill in relation to health and safety , and further debate is needed on this issue.
Question 20: As previously stated, a very important partner consists of the educational community starting at primary school level right through to higher and further education, and certainly the health community which is already being engaged as a partner needs further involvement.
Question 22: I believe that totally unregulated free trade can be a serious impediment. Regulated free trade as within the European Union is an advantage for health and safety because it requires a basic uniform standard throughout all the competing groups. However unregulated free trade outside the community would mean that people in the Third World suffer appalling conditions of health and safety for the purposes of making their bosses/company owners richer, while providing relatively cheap goods to western society. This would then either drive our workers out of a job, or militate against steps to improve their health and safety. The purchasing nations and markets have an obligation to ensure that the supplier meets agreed standards of health and safety. Britain must push for this in negotiations in world trade arenas outside the EU to the same extent as it has done within the EU.
On another subject, a positive influence would be that the insurance industry is increasingly having to meet the cost of litigation. They should apply differentials in their premiums and other pressure to ensure that companies fulfil their obligations regarding health and safety.
Dr Raymond Agius 1998
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