To: Health and Safety Executive
Our Ref: DJB/HMC
14 January 2011
Classroom Risk Assessment
We are pleased to have the opportunity to comment on this draft classroom risk assessment. Voice represents both teaching and support staff in the education sector.
We support the aims and objectives of this project undertaken by HSE as we understand them. There is certainly room for development and improvement in school risk assessments and there are helpful observations made in Lord Young’s review. However, we have significant concerns about this tool in its current form.
We first of all question whether this is a risk assessment tool or a safety check-list? Is this tool ‘5 steps’ compliant? Where is the actual assessment of risk and the record of the assessment? Where is the record of control measures etc?
As already mentioned, we have both teaching and support staff members. An issue that immediately emerges is who carries out this risk assessment? Is it the teacher? If so, when, how and is the teacher health and safety competent? If it is a non-teaching member of staff, the same questions arise. Under school health and safety management procedures teaching and non-teaching staff report hazards or dangerous incidents and it is the responsibility of the management team to decide on and implement remedial action.
In terms of the practicalities of using this tool the key factor is that schools are not all the same and do not have the same health and safety environment. Schools do not have the same controlled and regimented environment as an office. There are no options to adapt this tool to a school’s particular circumstances and needs. One obvious example is special schools.
As regards substantive issues of content we have further concerns:
a. We are pleased to note the recognition of stress, hazardous substances and asbestos as significant health and safety issues. However, this is not a proper place for them. They each require specific audit and assessments. We are pleased to note that asbestos in schools needs to be managed through risk assessment. Our serious concern is that it is the last item in a simplified risk assessment in which it is described as "very low risk". We do not want asbestos management to become disproportionate, but this format is an inadequate assessment.
b. We have already identified confusion about whether this is a risk assessment for staff (employees) only, or staff and pupils (employees and "others"). Staff will want a clear assurance that this is intended to cover their duty of care for pupils. It appears to be staff focused. If the intention is to include pupils, what account has been taken of different ages, needs, disabilities etc?
Finally, we have received comments about the practicalities of using the tool and the general thrust of those comments is that the tool is not as easily navigated as one would expect.
In the light of these concerns we could not recommend to our members to use this tool. But, we would support this project going forward if:
- serious consideration is given to the replies to the questionnaire with a view to a substantial redesign;
- a pilot scheme is set up for further feedback from practitioners. As an employer, Voice has taken on the office risk assessment on a trial basis.
Further information (HSE)