Policy Name ICS HEALTH AND SAFETY POLICY

Purpose Of Document

To set out ICS’s approach to health and safety management and outline health and safety arrangements within the organisation.

Target Audience All workers within all ICS companies: PULSE, Frontline, TNS, SNG, NLS, UMR and Pioneer.

Version V2.1

Author Karen Matthews-Shard Date of Approval May 2012

Published Date 18/05/2012

Lead Director Karen Matthews-Shard

Review Frequency Annually

Last Reviewed November 2016

Next Review Date November 2017

Risk And Resource Implications

Training

Associated Strategies and SOPs

Risk Management Strategy Transporting a Client SOP Driver Handbook Risk Assessment SOP PULSE/NLS Reporting and Grading Incidents SOP TNS/SNG Reporting Incidents SOP

Equality Impact Assessment (EIA) Form

EIA completed by the author of this policy and attached as Appendix A

ORG 03

√

2

Document History

Version Date Changes made/comments By whom

Draft v 1 27/06/11 First draft KMS

Draft v 2 29/06/11 Developed single policy for ICS KMS

Draft v 3 27/07/11 Removed all semi colons. Corrected font and terminology.

KMS

Draft v 4 28/07/11 Changes made following review by KMS KMS

Draft v 5 23/08/11 Changes to format KMS

Draft v 6 29/08/11 Revised format to meet new agreed format as per the policy drafting and review policy.

Inserted a document history sheet. Developed one single policy for ICS (PULSE) and

one for TNS/SNG.

KMS

Draft v7 01/09/11 Seen by KMS. Changes to bold format. KMS

Draft v 8 draft

05/09/11 KMS comments included: uniform bold headings. Returned to KMS as draft v8

KMS

Final Draft 18/10/11 All changes made. Final draft. KMS

Final Version

18/05/2012 Work station assessments will take place when employment commences or when a significant change to the station takes place as opposed to annually.

KMS

Final Version

18/05/2012 Completed individual company profiles within the ICS Group

KMS

Final Version

04/08/2013 Yearly review KMS/KNF

V 2.1 01/09/2014 Yearly review Welsh regulations added

KNF/KMS

V2.1 October 2015

Annual Review KNF/SJ

V2.1 February 2016

Introduction of New Sentencing Guidelines for Safety Offences added

KNF/SJ

V3 November 2016

Reviewed by Quadriga and KMS, additions added as requested. Reference made to the Control of Electromagnetic Fields at Work ]

KNF/SJ

3

Table of Contents Section Contents Page No. 1. Policy Standards 8 2. Definitions 8 3. Roles and Responsibilities 9 4. Supporting National Policies, Guidance and

Legislation 11

5. Health and Safety Policy: Arrangements to Manage Health and Safety

13

Equality and diversity 13 Health and safety objectives 13 Managing risk assessments 14 Management across organisations 14 Quadriga Health & Safety Ltd (Quadriga) 14 Risk assessment 15 6. Health and Safety Policy – Ensuring a Safe

Workplace 16

Ensuring a safe workplace - preventing accidents

16

Safe use of substances/Control of Substances Hazardous to Health (COSHH)

17

Manual handling and ergonomics 17 Safe use of medical devices 18 Display screen equipment 18 Lone working 19 Driver and road safety

First aid Worker-related ill health Fire safety Sharps Instruments in HealthCare Incident reporting

19 19 19 20 20 20

Incident investigation Contractor Control Arranagements

21 21

7. Training 22 8. Implementation Plan 22 9. Associated Policies 23 10. References 23 Appendix A

Equality Impact Assessment Form 25

Appendix B

Health and Safety at Work Policy Statement 26

4

About Independent Clinical Services (ICS) Group

ICS consists of a number of trading companies, each providing services within core niche areas of the health and social care industries. Therefore, as this document is a Group Policy, the Policy herein applies to all trading companies detailed below:

Pulse Staffing Limited (Pulse) Pulse recruits health and social care professionals for temporary and permanent jobs in the UK and abroad. Pulse is the UK’s leading independent provider of staff bank management services and provides specialist care packages to individuals in their own home or community setting. As an approved supplier to the NHS, Pulse holds contracts with NHS trusts, private organisations and local authorities nationwide. Pulse also works with hospitals globally, specifically within in Australia, New Zealand, North America, the Middle East and across Europe. Pulse places candidates - medical, scientific and nursing staff, allied healthcare professionals, social workers, support workers and carers - in posts appropriate for their training and experience. Pulse Staffing consists of a number of Pulse brands delivering staffing solutions and health and social care services globally, with a UK branch network and overseas offices, key brands include;

Pulse Community Healthcare – Management of packages of care to support/ enable individuals to live independently

Pulse Nursing & Care, Pulse Critical Care, PULSE Specialist Nursing, Pulse Theatres, Pulse@Home - provision of all categories and grade of nursing & midwifery staff

Pulse Doctors – Provision of all specialty and grade of doctor including Psychiatry, Acute and GP

Pulse Allied Health & Health Science Services – Provision of all categories and grade of AHP & HSS staff (including Physiotherapy, Radiography, Speech and Language Therapy and Pharmacy)

Pulse Staffing Partners, incorporating end-to-end management of complete staff banks Pulse Social Care – Provision of all categories of unqualified social care staff Pulse Social Work – provision of all specialty of qualified social work staff

Frontline Staffing (FL) FL is a dedicated division of PULSE, committed to managing short-notice and hard-to-fill vacancies on both a temporary and permanent basis across the spectrum of health and social care categories of staff

5

Thornbury Nursing Services (TNS) Established in 1983, TNS is one of the UK’s leading independent nursing agencies. Providing skilled nurses on a temporary or permanent basis to NHS Trusts and private sector clients throughout England and Wales. The TNS mission is simple: “To provide the best professional solution to meet the requirements of each of our clients whilst recognising and rewarding the exceptional skills and efforts of our nurses.” TNS delivers an exceptional service to both patients and clients by ensuring every nurse represented meets the most rigorous professional standards. TNS’ team of specially trained recruiters (themselves qualified nurses) personally interview and select nurses across the country using a strict method of competence-based assessment, ensuring that every nurse meets the highest expectations – in terms of professional accreditation, competency, attitude and personality.

Scottish Nursing Guild (SNG) Established in 1995, SNG, as part of Independent Clinical Services Ltd, is one of Scotland’s leading independent nursing agencies, providing skilled nurses on a temporary basis to major NHS Trusts and private sector clients throughout Scotland and Northern Ireland. SNG’s ability to respond promptly to staffing needs makes the service a invaluable resource in maintaining effective nursing coverage, with unparalleled commitment to providing nurses who meet the highest professional standards. SNG provides appropriately skilled health care assistants, operating department practitioners and qualified nursing staff to cover staffing shortages – both short-term and ongoing. SNG provides temporary nursing staff to both NHS Trusts and private sector clients throughout Scotland. SNG’s procedures and standards fully conform to or exceed the regulatory requirements in each territory.

Thornbury Community Services (TCS) Thornbury Community Services (TCS) is part of Thornbury Nursing Services, which was first established in 1983. Thornbury Nursing Services is a large independent nursing agency providing commissioned and staffing solutions, covering the whole of England and Wales. TCS supply Registered Nurses (RNs) and Health Care Support Workers (HCSWs) to Clinical Commissioning Groups (CCGs), case managers and private individuals providing care for clinically complex patients in their own homes.

6

Hobson Prior Hobson Prior International is an award winning provider of staffing services for the medical device, drug discovery and clinical development community in Europe. Since 2002, we have been working exclusively within the life sciences industry, supporting organisations seeking to engage with exceptional professionals within the functional disciplines of clinical operations, medical affairs, pharmacovigilance, quality assurance and regulatory affairs. All our consultants specialise in a specific life sciences discipline and combine in-depth industry knowledge with an ethical and proactive sourcing approach to deliver the right solution for each client.

Asclepius Asclepius is the only healthcare recruitment consultancy in the UK to give you access to six distinct, expert companies to best serve every medical specialty, along with managed services, under one roof. We’re committed to helping improve patient care within the NHS by offering truly extraordinary temporary and permanent recruitment services to our clients and candidates.

Maximma Maxxima is an established recruitment agency operating under two successful brand names; Labmed Recruitment and Swim Recruitment. Maxxima operates predominantly within the Healthcare and Social Services sectors. As well as offering traditional recruitment solutions to their clients, Maxxima runs a number of successful Master Vendor contracts, providing the NHS with a robust Vendor Managed Solution able to provide large scale cost savings whilst still retaining the expert knowledge and attention to detail associated with more specialist agencies in the market.

7

ICS Health & Wellbeing (ICS H&W) Pulse H&W is one of a few organisations in the UK offering a fully integrated health and wellbeing service that can be tailored to suit the needs of individuals and local communities. We have extensive experience of providing large-scale health improvement services for public and private sector organisations. By creating an approach that incorporates innovative technology, strong operational management and effective engagement, we use our expertise and wide range of skills, to provide a high quality and efficient solution for commissioners and long-term health benefits for individuals. Commissioners can choose to work with us across all, or a selection of our four core elements:

1. Health and wellbeing hub and interventions 2. Community outreach 3. Training 4. Social marketing campaigns

8

1. Policy Standards 1.1 As an employer, ICS is committed to providing their workers with a safe place

of work, safe equipment, safe systems of work, safe substances and competent fellow workers, along with adequate information, instruction, training and supervision.

1.2 All workers must take reasonable care of their own health and safety and that

of others who may be affected by their acts or omissions. The workforce has a duty to cooperate with their employer or any other person to enable legal obligations to be met.

1.3 The organisation assesses risks and takes positive measures to promote

health and safety at work. 1.4 The organisation sets a goal of zero accidents in the workplace supported by

strategic objectives and measurable targets to prevent accidents and ill health in the workplace in order to comply with applicable legislation and to continually improve its health and safety management system.

1.5 The Sentencing Council UK introduced new guidelines for Safety Offences in

February 2016 which sets out new details of organisational fines for Culpability, Harm, Health and Safety, Corporate Manslaughter and Food Safety and Hygiene. Details of these can be found online at The Sentencing Council UK’s website - www.sentencingcouncil.org.uk

2. Definitions 2.1 Definitions relevant to this policy are set out in Table 1. Table 1: Definitions

Topic Definition Risk Risk is the chance that an event will occur. It is measured in terms of

likelihood (the frequency or probability that an event will happen) and severity (the consequence or effect of the event happening). In the context of the company’s activities, risk encompasses anything that has an impact on the care of a client/client or which impacts upon the ability of ICS to fulfil its objectives.

Risk management

The term applied to a logical and systematic method of establishing the context and identifying, analysing, evaluating, treating, monitoring and communicating risks associated with any activity, function or process, in a way that will enable organisations to minimise losses and maximise opportunities. Risk management is as much about identifying opportunities as avoiding or mitigating losses.

9

Risk management systems

Supports the identification, evaluation, control and reduction of all levels of risks which may adversely affect meeting ICS objectives. Risk management must form an integral part of all daily activities so that all types of risk are systematically identified, managed and recorded.

Risk assessment The process used to determine risk management priorities, by evaluating and comparing the level of risk against predetermined acceptable levels of risk.

3. Roles and Responsibilities 3.1 While ICS acknowledges that risk management is the responsibility of all

employees of the organisation, Table 2 sets out the organisational accountability and the structures in place to effectively manage health and safety. The roles and responsibilities of the organisation as a whole are set out in the Policy for Drafting, Approval and Review of Policies and Standard Operating Procedures (SOPs). The key responsibilities that relate to health and safety are set out in Table 2.

Table 2: Key roles and responsibilities related to health and safety

Post Role and responsibility Chief Executive Has overall responsibility for health and safety and is

accountable for ensuring that effective systems of health and safety management, and internal control, are in place, to enable an effective health and safety system. Responsible for ensuring there are adequate resources available for meeting statutory requirements relating to health and safety. The signed Health and Safety at Work Statement is in Appendix B.

Governance Committee

Responsible for providing support to the Senior Management Team and ICS workers in identifying, assessing and controlling health and safety. This includes the requirement to review the establishment and maintenance of effective systems of internal control, and health and safety risk management.

Clinical Director Has delegated responsibility for health and safety. Responsibilities include: ensuring that systems are in place to continually improve

the health and safety management system providing a framework for implementing health and safety,

which results in suitable and sufficient risk assessments being carried out, and is supported by adequate health and safety training

chairing the Governance Committee and ensuring that issues regarding incidents and complaints are documented in the appropriate risk register

providing briefings to the Board, Senior Management Team and Governance Committee on trends in incidents, accidents and health and safety issues, which may constitute a risk to the organisation

10

working and liaising with the enforcing authorities and the external health and safety consultancy

notifying the Health and Safety Executive of any reportable incidents that fall under the remit of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).

Line managers/ appropriate other

Day-to-day responsibility for all managers including: provision and maintenance of a safe and healthy working

environment provision and maintenance of safe equipment provision of information, instruction and supervision of all

workers ensuring all workers are competent to undertake their

tasks prevention of accidents and cases of work-related ill

health. Individual workers

Every member of the workforce, whether permanent or temporary, has a personal responsibility to take reasonable care of their own health and safety, and for the safety of other people who may be affected by their acts or omissions.

Contractors ICS recognises and respects the independent contractor status. It will support the process of health and safety management development and implementation across the different disciplines. Independent contractors are employers in their own right and therefore should ensure that they have health and safety processes and management arrangements in place. All risks associated with their contract with ICS must be notified to ICS. The specific roles and responsibilities of independent contractors are set out in more detail within each contract.

3.2 Non-compliance with health and safety arrangements

Any worker contravening the provisions of the Health and Safety at Work Act 1974, deliberately ignoring this policy, or other policies and SOPs, or regulations intended to ensure health and safety at work, and acting so as to endanger others, may face disciplinary action. Alleged breaches will be judged against ICS’s disciplinary rules. Serious contravention of policies and/or regulations may lead to dismissal. Failure to notify any danger to the line manager/appropriate other will be viewed as endangering the health and safety of others.

11

4. Supporting National Policies, Guidance and Legislation 4.1 The following Acts and regulations support this Health and Safety Policy:

Acts/national policies/guidance

Explanation

Health and Safety at Work Act (HASAWA) 1974 and associated legislation

Defines the fundamental structure and authority for the encouragement, regulation and enforcement of workplace health, safety and welfare within the UK.

HASAWA 1978 and associated legislation, Northern Ireland

Similar to above, for Northern Ireland.

Health and Safety at Work (Amendments) 1998, Northern Ireland

As above, amended for Northern Ireland

Management of Health and Safety at Work Regulations 1999

The main requirement of the Management of Health and Safety at Work Regulations is that employers must carry out risk assessments to eliminate and reduce risks. Employers with five or more employees need to record the significant findings of a risk assessment and any group of his employees identified by it as being especially at risk

Management of Health and Safety at Work (Amendment) Regulations 2003

As above, with amendments.

Manual Handling Operations Regulations 1992

These regulations require employers to minimise the health risks associated with manual handling activities which involve lifting, carrying, moving, holding, pushing, lowering, pulling or restraining an object or person by hand or bodily force

Manual Handling Operations Regulation 1992, Northern Ireland

As above, amended for Northern Ireland.

Control of Substances Hazardous to Health Regulations 2002, Northern Ireland, amended 2003

These regulations require employers to assess and prevent (or at least adequately control) the risks to health from the use of any hazardous substances used in the workplace.

Control of substances Hazardous to Health Regulations 200

As above, with amendments

Reporting of Injuries Diseases and Dangerous Occurrences Regulations 2013

Under these regulations, certain serious workplace accidents are reportable by law to the Health and Safety Executive (HSE)

12

Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1997, HSE Northern Ireland

As above, amended for Northern Ireland.

Provision and Use of Work Equipment Regulations 1998

These regulations set out the minimum standards for the use of all equipment at work.

Provision and Use of Work Equipment Regulations 1998, Northern Ireland (1999)

As above, amended for Northern Ireland

Health and Safety (Display Screen Equipment) Regulations 1992

These regulations oblige employers to assess the work stations of staff who use display screen equipment. The work station is the equipment itself, its accessories and the surrounding work environment.

Health and Safety (Display Screen Equipment) Regulations 1992, Northern Ireland

As above, amended for Northern Ireland.

Workplace (Health, Safety and Welfare) Regulations 1992

These regulations deal with physical conditions in the workplace and require employers to meet minimum standards in relation to a wide range of matters.

Workplace (Health, Safety and Welfare) Regulations Northern Ireland 1992

As above, amended for Northern Ireland.

Control of Asbestos at Work Regulations 2012

Places specific duties on employers, owners and those in control of buildings to manage the risks from asbestos fibres that may be released when building or maintenance work takes place.

Electricity at Work Regulations 1989

These place a duty on employers to assess all foreseeable risks associated with work activities involving electricity.

Health and Safety (First Aid) Regulations 1981

Requires the employer to provide: adequate and appropriate first aid

equipment and facilities an adequate number of qualified first-

aiders an appointed person if the first-aider is

absent to take charge of the first-aid arrangements.

Regulatory Reform (Fire Safety) Order 2005

The responsible person in the workplace is required to take general fire safety precautions to ensure the health and safety of staff and others.

Health and Safety information for employees

Health and Safety information for employee’s

13

(amendment) regulations 2009 Health and Safety (sSharp Instruments in Healthcare) Regulations 2013

Guidance for employers and employee’s regarding the safe use of sharps in the healthcare setting procedures on how to respond to a sharps injury and training requirements

The Control of Electromagnetic Fields at Work (CEMFAW) Regulations 2016

Governs the use of EMF in the work place, setting acceptable levels, management of EMF, risk assessments and training.

The Electromagnetic Fields (EMF) Directive HSE 2016

The guidance explains the duties as an employer under the Control of Electromagnetic Fields at Work Regulations 2016.

5. Health and Safety Policy: Arrangements to Manage Health and Safety 5.1 Equality and diversity

Under the Race Relation (Amendment) Act 2000, ICS has a statutory duty to ‘set out arrangements to assess and consult on how their policies and functions impact on race equality’; in effect to undertake Equality Impact Assessments (EIA) on all policies and SOPs. The Equality Act October 2010 demands a similar process of EIA in relation to disability. An EIA must be completed by the author of this policy using the checklist provided in Appendix A. See also the ICS Equality and Diversity Policy.

5.2 Health and safety objectives

To ensure, as far as is reasonably practicable, the health, safety and welfare of all workers, and of all those visiting ICS premises or using services provided by the organisation.

To ensure that the workforce is competent to undertake the tasks required.

To comply with all current health and safety legislation, regulations and codes of practice.

To provide safe and healthy conditions of work, plant and systems. To ensure safe handling and use of hazardous substances. To raise the level of knowledge of all the workers on health and safety

through the provision of education and training programmes. To consult with the workers on matters affecting their health and

safety. To ensure that audit systems are in place and that monitoring of work

practices takes place according to relevant policies and SOPs.

14

To assess and manage risks in all working and client/client environments to ensure that all risks are identified and minimised as far as is reasonably practicable.

To review this policy annually and revise as necessary in light of guidance, new policy and legislation.

5.3 Managing risk assessments

5.3.1ICS believes that the key to better health and safety is risk assessment, carried out as close to the actual task or operation as possible, by local workers that understand and have background knowledge of the specific area of work.

5.3.2 ICS believes there is a need to closely monitor and carry out periodic spot

checks centrally to confirm that sufficient and adequate assessments are being carried out. Spot checks should be carried out by trained officers based in the central team and community healthcare.

5.3.3 Risk assessments will be carried out by line managers/appropriate others or

by suitably briefed workers to which work can be delegated. Delegating work does not alleviate the responsibilities of managers. See ICS Risk Assessment SOP.

5.3.4 Management across organisations

Risk is often at its greatest at the interface between organisations and it is here that clarity on responsibilities and accountability is difficult to ascertain. ICS works with other organisations in order to identify and manage health and safety risks and prioritise them within the ICS risk register. Joint action plans between organisations must clearly identify responsibility for delivering each action, the method for reporting exceptions and the mechanism for dealing with exceptions or disputes. Examples of other organisations include:

those with which ICS jointly delivers services those with which ICS jointly commissions services those with which ICS shares premises other healthcare organisations social services the police statutory bodies, charities and voluntary organisations client/client representative groups local authorities.

5.4 Quadriga Health & Safety Ltd (Quadriga) Quadriga act as health and safety consultants and:

provide advice and support on health and safety issues monitor any changes in health and safety law and notify ICS of the

change assist ICS to conduct risk assessments and develop policies and safe

systems of work assist ICS to conduct investigations of accidents

15

provide additional information and instruction where applicable advise on training requirements.

5.5 Risk assessments 5.5.1 It is a statutory requirement for line managers/appropriate others to attend risk

assessment training and to undertake the role of risk assessor for their area of responsibility. All line managers/appropriate others are responsible for ensuring that risks are eliminated or, where this is not possible, they are reduced to the lowest level that is reasonably practicable. See also ICS Risk Strategy, Clinical Risk Management Policy and the Risk Assessment SOP. Risk assessments must be communicated with relevant workers, contractors and temporary workers. Risk assessments must be reviewed on the following occasions:

occurrence of an incident recommendations from audits/inspections updated safety information change of working methods change of health and safety legislation.

Specific risk assessments must also be conducted for the following:

Manual handling Display Screen Equipment (DSE) Personal Protective Equipment (PPE) Asbestos Control of Substances Hazardous to Health (COSHH) Noise. Fire EMF Pregnancy

(Please note that this list is not exhaustive)

5.5.2 Risk assessments:

are undertaken by line managers/appropriate others take into account the workplace, activities and individuals exposed to

the hazards take into account workers, clients/clients, contracted organisations and

anyone else affected by the activity

Findings from risk assessments should be reported to the relevant Director who:

takes action required to remove or control risks is responsible for ensuring that the action required is implemented checks that the implemented actions have removed or reduced the

risks.

16

Quadriga provide support and advice on the risk assessment process where required. Risk assessments are to be reviewed every year, or when the work activity changes, whichever comes first.

5.5.3 Five steps to risk assessment: 5.5.4 Risk assessing activities and the workplace

The risk assessment process will cover all activities conducted by ICS and all work areas in which ICS workers operate. Where ICS workers are working in another employer’s workplace, risk assessments are requested from them.

5.5.5 Additional information on risk identification and analysis is in the ICS Risk

Management Strategy, the Clinical Risk Management Policy and the Risk assessment SOP

6. Health and Safety Policy - Ensuring a Safe Workplace 6.1 The Health and Safety at Work Policy Statement, signed by the CEO, is in

Appendix B. 6.2 Ensuring a safe workplace – preventing accidents

Many accidents at work are avoidable. To prevent accidents ICS workers should:

ensure good housekeeping at all times to reduce potential accidents work to a simple ‘clean as you go’ policy, keeping the working

environment clean and tidy at all times ensure the provision of good storage and good housekeeping in order

to prevent accidents occurring by reducing the chance of slips, trips and falls.

6.2.1 Preventing slips, trips and falls

All activities that could potentially result in someone slipping, tripping or falling are assessed through a risk assessment. Controls must be in place to ensure that slips, trips and falls do not occur. As all buildings are different, a general risk assessment of each building must be undertaken in order to prevent accidents. All workers must ensure they are aware of trip hazards. Accidents caused by slips, trips and falls may be reduced by 90% if floor space is kept clear, object and obstruction free.

Step one: Identify hazards and the extent of risk. Step two: Decide who might be harmed and how. Step three: Evaluate the risks and decide on precautions. Step four: Record findings. Step five: Review the assessment and update if necessary.

17

6.2.2 Equipment All work equipment provided will be ‘fit for purpose’. ICS will ensure that work equipment supplied is suitable for the purpose is and maintained in good working order and in good repair. The line manager/appropriate other is responsible for identifying and maintaining all equipment.

6.2.3 Personal Protective Equipment (PPE)

Workers are provided with, and when not under direct control and supervision, instructed to use, the appropriate PPE necessary to undertake their role safely. This includes the use of an apron, gloves, goggles and masks etc, when required.

6.2.4 Electrical items Portable Appliance Testing (PAT) is conducted on all electrical items owned or controlled by ICS. The frequency of inspection and testing of equipment within the offices is established by the Quality and Compliance Team, and arrangements are in place for annual testing. Workers are not permitted to bring in their own electrical appliances unless they have been electrically tested.

6.3 Safe use of substances/Control of Substances Hazardous to Health

(COSHH) 6.3.1 Where substances are to be used, for clinical and non-clinical purposes, by

ICS workers, risk assessments are completed which document the correct handling, storage, transportation and disposal of these substances. Training is provided by ICS on the use of hazardous substances. ICS ensures that no work is undertaken which exposes any worker to substances hazardous to health.

6.3.2 Compressed gas Where compressed gases are used, ICS will ensure the correct handling, storage, transportation and disposal of these gases. Any workers involved in using compressed gases will receive suitable training to enable them to do so safely.

6.4 Manual handling and ergonomics 6.4.1 All manual handling tasks are assessed according to the task, individual, load,

environment, and control measures implemented accordingly. All handling activities such as lifting, pushing and pulling must be conducted using good manual handling principles. Information, instruction and training are provided by ICS. See also ICS Manual Handling Policy.

6.4.2 Assessment of risk and planning are integral to manual handling, and ICS workers will be expected to contribute to these processes. Assessments must be undertaken in relation to the client/client requiring movement, the load or the person(s) who needs to undertake the manual handling activity, or a

18

combination of all factors. Where significant risks are identified, an action plan may need to be developed and actions taken to reduce the likelihood of the incident occurring or recurring if it has happened before. The aim should be to minimise the likelihood of an incident so that it is in the lowest possible category.

6.4.3 Clinical and professional judgement must be used and the following rules apply:

Where able, clients/clients should be encouraged to move independently, with guidance from ICS workers as required.

Operations involving the manual lifting of clients/clients, where reasonably practicable, should be reduced by: o encouraging clients/clients, where able, to move independently o clients/clients being assessed for, and provided with, aids to mobility

and taught correct use of the equipment o teaching ICS workers involved in clinical contact with clients/clients

appropriate handling techniques o ensuring that risk assessments are carried out and reviewed

regularly or when there is a change in the client/client’s level of mobility or underlying health condition

o making suitable equipment available to staff, and ensuring they are trained in correct checks and use of equipment.

6.5 Safe use of medical devices When ICS workers are working on non-ICS sites they should:

follow the Medical Devices Policy for that particular client site ensure that all equipment is fit for purpose use the device only if they have been trained to use that device. If no

training has been received, they should not use the device report any damage to a medical device to the host client organisation.

When working in the community, the rule is ‘If the ICS worker has not been trained to use the medical device, it should not be used’.

6.6 Display screen equipment

The line manager/appropriate other will: ensure that the workstations located within their area of responsibility

are designed so that individuals can work comfortably ensure that assessments are undertaken when a new member of staff

starts work within ICS, to assess work station requirements, assess the work being done, plan workload, and assess the special needs of individuals

ensure an assessment also takes place if a significant change to the work station takes places, such as an office move

give information and instruction to the workers to ensure good working practices are in place to reduce the hazards and associated risks from the use of display screen equipment

19

arrange free eye tests for those defined as users (if an assessment highlights the need for glasses to be worn, for computer use, ICS will pay a contribution).

6.7 Lone working

‘Lone workers’ are defined as those who work by themselves without close or direct supervision. Lone workers include workers based at other buildings not under the control of ICS, including domestic premises. A risk assessment will be undertaken to manage the risks arising from lone working. Controls are then implemented by the line manager/appropriate other to minimise the risks. ICS workers must inform the line manager/ appropriate other of any illness or medical condition that could affect their work. See also the Lone Worker SOP.

6.8 Driver and road safety 6.8.1 In order to maximise the safety of workers who drive on company business, a

number of measures are in place, which are detailed in the Driver Handbook. Those workers undertaking long journeys are able to take breaks and book overnight accommodation where necessary. Journey scheduling must allow sufficient time for drivers to take account of reasonably foreseeable weather and traffic conditions, and to comply with speed limits.

6.8.2 In addition, car drivers must obey road safety law, which includes not driving

under the influence of alcohol and/or drugs and not using hand held mobile phones. Drivers must have proper control of their vehicles at all times. The police will prosecute for driving while using a hand held mobile phone. Using a hand held mobile phone is a specific offence and it is an offence for the company to cause or permit such use. In accordance with the Department for Transport guidance, when contact with a worker is necessary while they are driving, hands-free equipment has been provided, with voicemail or call-divert facilities (although it is acknowledged that this is still distracting). Workers are encouraged to stop and check for messages, and then return calls. ICS discourages workers from taking calls whilst driving. If contact is unavoidable, the driver must explain that they are driving and keep conversations brief. Regular checks will be carried out on employee driving licences, MOT certificates, insurance and servicing records. See also the Driver Policy.

6.9 First aid

The line manager/appropriate other is responsible for organising first aid cover for their area of responsibility. The offices are generally low-risk areas so trained emergency first aiders at work have been appointed. A first aid kit is provided at each site. The line manager/appropriate other is responsible for organising a first aid kit for their department/ location. It is the responsibility of the first aiders to ensure kits are checked on a regular basis and that they are fully stocked. Information on where the first aid kit is located, and who to contact, is provided on the notice board in each location controlled by ICS.

6.10 Work-related ill health

A pre-employment health questionnaire is issued to new workers in accordance with the requirements of the Equality Act 2010. It is the

20

responsibility of the worker to make ICS aware of any existing health conditions. ICS will, where necessary, organise continued health surveillance during the term of employment. If during the course of employment a worker contracts an illness or an injury that affects their work, they will need to report this to their line manager/appropriate other. All workers must report any work-related ill health issue.

6.11 Fire safety

The following general fire arrangements are in place: A Fire Risk Assessment is undertaken for each area that is controlled or

occupied by ICS. The Fire Risk Assessment is undertaken by someone who is competent

to do so. The findings of the Fire Risk Assessment are reported to the Clinical

Director and Governance Committee. Action required to remove or control the risks is the responsibility of the

line manager/appropriate other, they are also responsible for ensuring the action required is implemented.

The line manager/appropriate other will check that the implemented actions have removed or reduced the risks, and update the Governance Committee via the Clinical Director.

The Fire Risk Assessment is reviewed at least annually unless there are significant changes prior to that date.

There are trained fire wardens in all offices.

Fire procedures are in place for all ICS buildings. Where there is shared occupancy in buildings, there is cooperation and coordination with the landlord and other occupiers resulting in an agreed common procedure. It is the responsibility of the line manager/appropriate other to ensure all workers are aware of the procedure to follow in the event of a fire. Where ICS workers are working at another employer’s premises, or within a private dwelling, they are made aware of the procedures that they must follow.

6.12 Sharp instruments in Healthcare The health and safety executive published guidelines in 2013 which assists healthcare employers and employees to understand their legal obligations. Sharp instruments remain essential tools for effective healthcare however we should only use them if necessary. Safer sharps which incorporate protection mechanisms are not available for certain devices.

6.13 Incident reporting Incidents include accidents, near misses and any other untoward event that may have a detrimental effect on workers, clients/clients, visitors, contractors, and property. If a worker has an accident, it must be reported as soon as possible to enable an investigation to be carried out. All accidents, near misses and cases of work-related ill health must be recorded. ICS requires that all incidents are accurately and appropriately reported. All workers have a duty to read and understand the Incident Reporting Policy. The Clinical

21

Director reports any accidents or major incidents that occurs to the HSE enforcing authority, under the Reporting of Injuries Diseases and Dangerous Occurrences Regulations 2013.

6.14 Incident investigation

All incidents must be investigated, in accordance with ICS incident policy. The line manager/appropriate other is responsible for carrying out the investigation. The level of investigation required will depend upon the severity of the incident, i.e. the greater the severity, the greater the time allocated to the investigation. The investigation report should identify root causes of the incident, as well as short- and long-term action required to prevent a recurrence. All incidents will be logged onto DATIX.

6.15 Contractor Control Arrangements Where contractors are engaged to undertake minor work on ICS premises, they will be required to work in accordance with ICS requirements for work by contractors and local rules implemented by the landlord/managing agent of the premises. All “construction works” must be carried out in compliance with the Construction (Design and Management) Regulations 2015 (CDM). Note that “construction” is a broad term incorporating many types of alteration, maintenance and repair such as decorating, rewiring and more. When construction is to take place “pre-construction information” will be issued in accordance with the regulations. The contractor will be required to provide a construction phase plan for all works, and other than for minor repairs, will be asked to provide a risk assessment and method statement. For larger projects, or any work involving hazardous materials, building alterations, demolition work, roof work, or work involving scaffolding, fork lift trucks, cranes, lifting equipment, or powered access equipment, ICS’s health and safety consultancy will be asked to assist in ensuring that ICS’s CDM responsibilities are fulfilled. For all construction projects involving more than one contractor ICS will appoint a principal designer and principal contractor as soon as is practicable, and in any case before the construction phase begins. The principal designer will be required to prepare a health and safety file containing essential information about the completed works for use during future construction works.

6.16 Where work equipment generates electromagnetic fields, this would only occur for workers working in hospital settings. Management of electromagnietic fields would be the responsibility of the trusts where workers are supplied. Any workers who have concerns regarding the management of electromagnetic fields must report into their relevant incidents and complaints teams within ICS.

22

7. Training 7.1 Information on health and safety is provided to all workers through:

briefings the intranet notice boards, which are displayed in each workplace that ICS

manages and will contain: o the most recent Health and Safety Law Poster o Employers Liability Insurance details o Health and Safety Policy Statement o emergency arrangements o up-to-date monthly briefings.

It is the responsibility of the line manager/appropriate other to ensure the notice boards are kept up-to-date.

7.2 Competency for tasks and training

The first step towards ensuring a safe working environment is to ensure that everyone working for ICS has appropriate training with which to provide high-quality care/service.

Training Organised by

Training needs to be identified, arranged and monitored

Line manager/appropriate other

On-job training HR/Quality and Compliance departments

Specialist training for first aid and fire

Organised using external service providers

As training covers a variety of different activities, there is a Training Policy.

7.3 Consultation with workers Consultation with ICS workers is through the Workers Forum, where health and safety is a permanent item on the agenda. ICS also operates an ‘open door’ policy where issues can be discussed with their line managers, so any health and safety issues that cannot be resolved by the worker may be reported verbally.

8. Implementation Plan 8.1 The flowchart for the drafting and revision of policies and SOPs sets out the

process of consultation, communication and dissemination of a policy, and is in Appendix C of the Policy for Drafting, Approval and Review of Policies and SOPs.

8.2 For ratification for the revision or creation of policies and SOPs, see Appendix

C of the Policy for Drafting, Approval and Review of Policies and SOPs.

23

8.3 Dissemination This policy will be implemented as part of the review of governance mechanisms and policies in ICS during 2011. The Clinical Director will ensure the dissemination of this policy across the organisation. Any updates will be disseminated across ICS.

8.4 Audit and monitoring The Clinical Director will monitor compliance with this policy. Internal and

external inspections are used to highlight problems and assess their risks before accidents occur. No activities are completely risk-free, as equipment wears out, conditions and people change, and people are not perfect. Quarterly inspections of each of our premises are conducted by the internal auditors. Internal audits for health and safety are conducted in conjunction with the Quality and Compliance Department. Regular worker surveys are conducted by ICS and the Workers Forum, and are used to identify and assess the Health and Safety Policy and any issues arising.

9. Associated Policies 9.1 Specific policies are designed to meet the health and safety statutory

requirements. It is essential that all workers make themselves familiar with the following policies: Clinical Risk Management Training Incident Reporting Equality and Diversity

10. References

Health and Safety at Work etc Act (HASAWA) 1974 and associated legislation

Health and Safety at Work Act (HASAWA) 1978 and associated legislation

Northern Ireland Health and Safety at Work (Amendments) Northern Ireland 1998 Management of Health and Safety at Work (Amendment) Regulations

2003 Management of Health and Safety at Work Regulations 1999 Manual Handling Operations Regulations 1992 Manual Handling Operations Regulation Northern Ireland 1992 Control of Substances Hazardous to Health Regulations 2002 as

amended Control of Substances Hazardous to Health Regulations 2002 Northern

Ireland amended 2003 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations

2013 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations Health and Safety Executive (HSE) Northern Ireland 1997

24

Provision and Use of Work Equipment Regulations 1998 Provision and Use of Work Equipment Regulations 1998. Northern

Ireland 1999 Health and Safety (Display Screen Equipment) Regulations 1992 Health and Safety (Display Screen Equipment) Regulations Northern

Ireland 1992 Workplace (Health, Safety and Welfare) Regulations 1992. Workplace (Health, Safety and Welfare) Regulations Northern Ireland

1992 Health and Safety (sharps instruments in healthcare) Regulations 2013

Health and Safety Offences, Corporate Manslaughter and Food Safety

and Hygiene Offences February 2016

25

Appendix A: Additional paper to be completed as part of the ratification process: Equality impact assessment (EIA) checklist for the Health and Safety Policy. To be completed and attached to any procedural document when submitted to the appropriate committee for consideration and approval.

Yes/No Comments

1. Does the procedural document affect one group less or more favourably than another on the basis of:

Race No

Ethnic origins (including gypsies and travellers) No

Nationality No

Gender No

Culture No

Religion or belief No

Sexual orientation including lesbian, gay and bisexual people

No

Age No

Disability - learning disabilities, physical disability, sensory impairment and mental health problems

No

2. Is there any evidence that some groups are affected differently?

No

3. If you have identified potential discrimination, are there any exceptions valid, legal and/or justifiable?

No

4. Is the impact of the procedural document likely to be negative?

No

5. If so can the impact be avoided? N/A

6. What alternatives are there to achieving the procedural document without the impact?

N/A

7. Can we reduce the impact by taking different action? N/A

If you have identified a potential discriminatory impact of this procedural document or need advice please refer it to the Clinical Director, together with any suggestions as to the action required to avoid/reduce this impact.

26

Appendix B: Health and Safety at Work Policy Statement We, the Board of Directors of ICS, accept our responsibilities under the Health and Safety at Work Act 1974 and the Management of Health and Safety at Work Regulations 1999 for ensuring the health and safety of all ICS workers, clients/clients and any other people affected by our work activities. It is ICS policy to provide a safe and healthy working environment for our workers, clients/clients, visitors and contractors. We are committed to developing a health and safety conscious organisation, which will lead to an improved environment for the benefit of ICS workers and clients/clients, greater efficiency and higher standards of care. We will seek to achieve health and safety excellence through statutory compliance, effectively managing our health and safety risks, and making continuous improvements to our health and safety performance. To achieve our goal we have implemented a formal safety management system which will ensure health and safety risks are effectively managed across our organisation. We will seek progressive improvements by consulting with our workforce on health and safety, and ensuring that all ICS workers are trained and supervised in safe systems of work. Implementation of our Health and Safety Policy is a management responsibility and accountability will be fixed at every level. Every ICS worker also has a personal responsibility to take reasonable precautions to ensure their own health and safety, and that of others. Health and safety excellence will therefore be achieved through the collective responsibility and cooperation of our managers and ICS workers. All ICS workers must work together to develop and maintain a positive health and safety culture. Where temporary or contract workers are working for us, we will provide the same health and safety standards for them as we do for our own workers. We rank health and safety equally with other objectives and we will routinely monitor and review our health and safety performance. Where we enter into partnership agreements with other organisations to deliver services, we will establish that there is adequate coordination of health and safety arrangements between the partnership organisations. This policy will be reviewed at least annually, and at any other time when there are significant changes, to ensure that it remains relevant and appropriate to our organisation. We accept that all accidents are preventable. In our view ‘success is no accident’. This policy is endorsed by our CEO. Signed:

Richard MacMillan

Chief Executive Officer

Date: November 2016

Date for review: November 2017