Comments on the HSC Discussion Document:

Managing Stress at Work

The Discussion Document is to be greatly welcomed as is the Health and Safety Executive's intended campaign on Stress at Work due next year ie in the year 2000.

The following are responses to individual questions:

Question 1 It is useful to draw a distinction between the "exposure" that causes lack of well being, and the lack of well being itself. The reason for this is obvious - the control measures have to be directed at the "exposure". I do not think that "pressure" is the right word - since people can be stressed as a consequence of qualitative or quantitative underload, as well as overload.

One can accept that stress is not necessarily an illness. However psychological stress or distress can be part of a continuum of lack of well being which can include overt illnesses such as anxiety and depression.

Question 2 First line - Yes. Second line - Undoubtedly a lot needs to be done generally to tackle stress at work.

Question 3 The size of the problem is manifestly obvious from surveys conducted by the Health and Safety Executive, eg those based on the General Household Survey, as well as other work commissioned by the Health and Safety Executive or published elsewhere and which focuses on specific occupations or types of work places.

Question 4 The Government and its agencies needs to do more to educate, inform, and begin to apply pressure in the shape of an approved code of practice.

Employers need to manage the problem in the same way as they manage other health and safety issues. Employees and occupational health professionals also have an essential role to play in assessing and reducing the risks.

Question 5 Stress at work can be an important health safety and welfare issue.

Question 6 In as much as stress can be caused by work it is therefore a health and safety issue. If this results in a lack of well being, whatever its origin, it is also a welfare issue. Since the consequences of stress can in some instances impinge on the safety of others it is therefore a safety issue for this reason as well.

Question 7 It is of course not easy to define a threshold. But as in other potential health safety and welfare issues a risk assessment should be able to give a guided judgment as to whether or not it is a health safety and welfare issue in a particular workplace.

Question 8 In occupational health one deals with health safety and welfare problems which have a multifactorial aetiology all the time. These could range from back pain to dermatitis, to asthma and also to stress. Each of these could be caused by workplace factors, non-workplace factors or a combination of both. Each of these can have consequences in the workplace. Individual decisions need to be made on the merits of individual situations, as well as on the setting of a general workplace risk assessment to determine the workplace contribution.

Question 9 Undoubtedly education, partnership and guidance notes are essential. However in my judgment there is a case for an approved code of practice - see below.

Question 10 The sort of approved code of practice in Annex 2 would be worthwhile and Annex 2 is a reasonable start. However considerable improvement is necessary, and of course a consultation process for the approved code of practice would be needed. If the approved code of practice in draft form were to be produced to coincide with the intended stress campaign next year - these two issues could publicise and reinforce each other.

Question 11 In relation to those key causes of stress on which a lot of work has been done, eg issues of control of one's own work, uncertainty, and so on, these should be clearly highlighted. However as in other health and safety guidance and approved codes of practice one should also include an umbrella provision to cover grey areas to a degree.

Question 12 The Health and Safety Executive state that there are various models of stress and it is not easy to rank the causes of stress - since different workplaces may have different rank orders, which should be revealed by their risk assessment. Thus causes could include:
 

• Organisational constraints
• Management style
• Overload and conflicting demands on time
• Role conflict and ambiguity
• Uncertainty and lack of information about change etc
Question 13 It is accepted that the points raised in paragraph 39 present significant challenges. However, the situation is not radically dissimilar from health and safety concerns of moving and handling for example, where courts of law often have to make judgments as to what a reasonable employer would have done. Thus a large employer who did not have a policy to address the issue, whose staff had multiple ambiguities in their reporting system and in the organisational structure within which they worked, who had a high prevalence of manifestations of stress and so on could be proven to have fallen foul of a good standard of reasonable practice.

Question 14 The approach in paragraphs 43 to 46 is well worthwhile but this should not negate the need for an approved code of practice.

Question 15 The Society of Occupational Medicine (as well as the Faculty of Occupational Medicine) should be included in the consultation process.

At a more personal level wearing my academic hat I have published work on occupational stress in specific occupations, (e.g. Agius et al, Occupational and Environmental Medicine 1996). Many others like myself would be keen and willing to continue to identify, as we already have done, specific stressors which can then form the basis of a hazard identification and risk assessment, and thence control strategy.

Raymond Agius
July 1999