Monday, 1 February 2016


Welcome to our new feature:
RHSS Consultants out and about…snapping interesting sights from their weekly travels.
This week, Rob noticed this rubbish storage facility on a construction site!
 
 

Health and Safety in the news this week

New sentencing guidelines
The new sentencing guidelines for health & safety offences are in force from 1 February 2016.  They were intended to increase the level of fines, particularly for larger organisations.  However, unintended consequences of the way punishments are now calculated mean that judges will be forced to hand out very much greater fines than expected and send many more directors, managers and junior employees to jail for breaching health & safety laws.

The Four Inflations
For most health and safety breaches, the criminal law laid down by Parliament does not set an upper limit to the size of the fine, so it is left to judges and magistrates in Court to decide how the fine should ‘fit the crime’.  To help the Court set a fair, transparent and consistent tariff, the eminent judges and lawyers on the Sentencing Council have created a set of guidelines now coming into force.
Close inspection of the new sentencing guidelines shows that four inflationary factors are going to increase radically the level of fines, yet only one of these factors was intended.  Similarly, the threshold for imprisonment will be reached very much more easily than before.  Let’s look briefly at the four inflationary factors:
First Inflation
The sentencing guidelines introduce a structured approach that the court must follow.  This involves plugging ‘culpability’, ‘likelihood’ and ‘harm’ factors into a series of tables to reach recommended starting point fines, as well as ranges of fines above and below the starting points.  Similarly for imprisonment of individuals, the tables stipulate ranges of prison sentences above and below various starting points.
These tables were calculated by reviewing past sentences and then, particularly for larger companies, increasing the levels of fines.  This first inflation was intended.  It was designed to accommodate the Court of Appeal’s repeated view that health and safety fines have generally been too low and need to be increased sufficiently to send a message to directors and shareholders.  Indeed, the Court of Appeal envisages fines exceeding £100 million for the worst health and safety breaches by the largest companies.
But the Court of Appeal has not recommended massive increases across the board, even for less serious offences by smaller companies and by individuals.  Yet this will be the effect of the next three inflations.
Second Inflation
The sentencing guidelines switch from a mainly outcome based approach (what was the seriousness of the injury) to a risk based approach (how serious was the harm that was risked).  There are justifiable reasons for this switch but its inflationary effect on sentences was not factored into the calculations.  How does this second inflation work?
Suppose an object falls from a crane and crushes someone’s toes.  Traditionally, that would be prosecuted and sentenced very much more leniently than if the same object had hit someone’s head and caused a fatality.  Under the new risk based approach, the toe injury is seen as having involved a high risk of death or disability and is plugged into the computation at the level calculated for a fatality.
The majority of non-fatal incidents could have been more serious, so these will be inflated up to the level of fine corresponding to that more serious injury.
Third Inflation
If the offence exposed not just one but a number of people to the risk of harm, the Court is directed to ramp the punishment up to the next level.  As a seasoned health and safety defence lawyer, I struggle to think of a case where the breach only exposed one person to a risk of harm.  For example, if other people could have been hit by the object falling from the crane, this third inflation will apply.
Fourth Inflation
Finally, if there was actual harm (unless more minor than could be expected), the Court is also directed to ramp the punishment up to the next level.  Since most prosecutions arise after someone has been injured, this fourth inflation will almost always apply.
Summary
The combined effect of these last three unintended inflations will mean that criminal sentences will tend to converge at the higher end of a scale that has already been substantially increased by the first intended inflation.  The Court is given some discretion but not enough to depart materially from the stipulated calculations.
For example, it is going to be difficult for an individual convicted offender to escape a jail sentence if he or she was aware of a risk of being in breach, nobody suffered an injury but several people were exposed to a ‘medium’ likelihood of death or disability.  This is a very significant reduction in the threshold for imprisonment for health and safety offences. 
It has never been more important to bring the importance of health and safety to the attention of board members and senior executives.
 
HSE prosecution round up:

Major construction firm fined £1million after death of worker
Construction firm Balfour Beatty has been fined after a worker lost his life whilst repairing a central reservation barrier damaged in a road traffic collision.
Canterbury Crown Court heard how, on 1 October 2012, a team was sent out by Balfour Beatty Civil Engineering Limited, a subsidiary of Balfour Beatty PLC, to install temporary traffic management in order to repair barriers on the A2 at the location of a collision site.
The crew were trying to remove the footings of a post that had snapped off using a lorry mounted crane. The lorry mounted crane slipped from the concrete footing, and swung back towards the barrier, hitting the worker on the head. Larry Newman, aged 37, sustained severe head injuries and was pronounced dead at the scene.
Balfour Beatty Civil Engineering Limited, of Churchill Place, Canary Wharf, London, was fined a total of £1million, and ordered to pay £14,977 in costs after pleading guilty to offences under Section 2(1) and Section 3(1) of the Health and Safety at Work etc. Act 1974.
After the hearing, HSE inspector Andrew Cousins said: “This was an entirely preventable incident that could have been averted by simply creating and implementing a safe system of work. If a suitably sized excavator had been used to remove the footing mechanically it would have prevented this tragic loss of life completely.
“Employers have a responsibility to create safe systems of work for hazardous activities that their workers may be undertaking. The workers should be trained in safe systems of working and adequately supervised. Safety needs to be proactively managed and not just left to chance”. 

Firm fined for safety failings after worker fell four metres from scaffolding
A scaffolding company has been fined after a worker fell over four metres suffering severe injuries.
Colchester Magistrates’ Court heard how a 39 year old worker fell from the second lift of a scaffold while it was being dismantled. Mr Hemphill (39 years old) fell approximately 5m before striking the ground.  Mr Hemphill collided with the scaffolding twice before finally hitting the ground below.
He sustained nine broken ribs, a punctured lung, fractured skull and a fractured spleen. He spent five days in hospital and at the time of the accident was expected to have at least 3 to 4 months off work.
An investigation by the HSE into the incident which occurred on 23 February 2015 found that there were no guard rails on the area from where Mr Hemphill was working and he was not provided with a harness and lanyard to clip on with. As a result there was nothing to stop him from falling.
SP Scaffolding (East Anglia) Limited of Gosbecks Road, Colchester, Essex pleaded guilty to breaching Work at height Regulations 2005, regulation 6(3) and were fined £8,000 with costs of £3,003. 

Worker killed whilst assisting a reversing lorry
A company has been fined for safety failings after the death of an employee.
Mold Crown Court heard how Philip Ledward, aged 62, an employee of Arkenfield Stable Hire Limited (ASHL), was assisting one of the company’s lorry drivers when he was struck by a passing car and received fatal injuries.
An investigation by the HSE into the incident, which occurred in November 2011, at Boundary Garage, Ellesmere Road, Bronington, found that there was no safe system of work in place for controlling risks from workplace transport.
Arkenfield Stable Hire Limited, of Birch House, Back Lane, Coton, Whitchurch, was fined a total of £7,500 and ordered to pay costs of £5,000 after pleading guilty to an offence under Section 2 (1) of the Health and Safety at Work etc Act 1974. 

Haulage firm sentenced after HGV crushes worker to death
A haulage firm has been ordered to pay £90,000 in fines and costs after an employee was crushed to death by a runaway lorry.
Tony Schulze had been trying to connect a cab to a lorry trailer when the incident happened at Freight First Ltd’s premises on the Astmoor Industrial Estate on Goddard Road on 22 January 2011.
The company was prosecuted by the HSE after an investigation found the 49-year-old from Runcorn did not normally drive articulated vehicles, had not received training on coupling lorries, and there was no written procedure for the work.
Liverpool Crown Court heard that Mr Schulze had been working at the site at the weekend, and had been asked to line up the trailers in the company’s small yard so they could be used for deliveries and pick-ups on the Monday morning.
When Mr Schulze released the brakes on the trailer, it began to roll forwards on the sloping yard. He ran down the side of the trailer, in front on the cab and attempted to jump into the open door but the HGV struck another vehicle in the yard, crushing him between the door and cab frame.
Mr Schulze’s colleagues tried to rescue him before the emergency services arrived, but he died at the scene.
The HSE’s investigation found there was not a safe system of work for the coupling and uncoupling of vehicles, and that the handbrake in the cab had not been applied.
Although Freight First Ltd had prepared a general risk assessment in May 2010, it did not deal with the task of connecting cabs to trailers, or identify the risk of runaway vehicles.
The court was told that an external health and safety adviser had highlighted the lack of a risk assessment in December 2010 – a month before Mr Schulze’s death – but no action was taken.
Freight First Ltd, of Whitehouse Industrial Estate, Aston Fields Road, Preston Brook, Runcorn, was fined £90,000 and ordered to pay £67,500 in prosecution costs after being found guilty of a breach of Section 2 (1) of the Health and Safety at Work etc. Act 1974. 


 

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