Hurrah for Method Statements
“The Health and Safety Executive (HSE) is encouraging organisations to rely more on documents such as method statements instead of duplicating content in overly detailed risk assessment documents” IOSH Magazine January 2017.
It’s good to hear HSE promoting Method Statements, though they do point out that it’s not a legal requirement to prepare them. We can probably all raise a cheer for a well-constructed, thoughtful method statement, but then, for the experienced worker, a concise, suitable and sufficient risk assessment (the emphasis on concise) was also a very useful document. And then along came RAMS, the idea being to combine both Risk Assessment and Method Statement.
As with all documentation, it’s worth asking – who is it for? Many RAMS are prepared by contractors for clients, and while there is nothing to object to in that, it does beg the question, what is the document that the employer ( here the contractor ) prepares for his/her workers to serve as a written safe system of work ( a requirement under HSWA s2)? Some RAMS are definitely detailed and useable enough to serve the needs of both the client and the workers, but sadly, many are not.
Masses of detail in the risk assessment isn’t necessarily what makes it ‘suitable and sufficient’. MHSWR1999 Regulation 3 says that the level of detail should be proportionate to the risk, that is, should identify the really significant risks and ignore the trivial. COSHH risk assessments - “COSHH Assessments” are often not good examples of how this should be done, and frequently contain huge amounts of irrelevant ( and often questionable ) detail without actually identifying the main risk , e.g. “high risk of acute toxicity by inhalation” and not bother with the mundane, e.g. “low risk of slipping on wet floor”. So workers need a document that highlights the risks that are significant to them and their activity. The client, on the other hand, may need a more comprehensive overview to relate the activity in question to other work that follows, or takes place alongside it.
Method statements are often criticised for being “ too generic”, or for “ lacking detail”, others for being “ too long-winded”. It can seem as though there is no pleasing everybody. But ask the question again, - who is the method statement for? In a culture with strong standard operating procedures, and well-drilled safety arrangements, it is possible to use shorthand references to the requirements for user checks, first aid, clean-up, safe disposal, etc. in the knowledge that these are all parts of the workers’ skillset and competence, so even a brief reference can enable substantial procedures to be included.
But not all workplace cultures are like this, and even where they are, the task in hand may be so out of the ordinary that these standard procedures are hardly relevant. This is why the ability to create a method statement that meets the needs of new or relatively inexperienced workers is such an important part of a safety manager’s role. Method statements are not just a list of the various components of the job, but should combine all of the necessary steps in a logical sequence to enable somebody who has not done the job before (and in some cases, the job has never been done before) to carry out the task effectively and safely. Before we are tempted to list these components, it’s worth remembering that many jobs start and end with human interaction, so these could be included in the method statement. Also, let’s remember that flow charts are an excellent way of representing the steps in a process, and can be used to show the procedures to be followed where decisions must be made, or alternatives may be presented.
So, one of the things we need to include would be the description of the task in hand so that it could not be confused with any other, and this is not so obvious as it sounds. Let’s not forget that surgeons have removed the wrong kidney or amputated the wrong limb because of precisely this sort of error. We need to be as specific as possible and make use of any site-specific references, e.g. socket outlet number 45, or 3rd floor exit on SW wall, and the use of plans and drawings can certainly help here. A very important part of doing any task safely can be the order in which particular procedures (e.g. site inspection, access restriction,) are carried out, and while the procedures may be identified among the various control measures included in a risk assessment, their position in the order of activities may not be obvious. A method statement can overcome this problem by numbering the steps (or using a flowchart with arrows)
Another thing that can save a lot of time is to suggest alternatives, e.g. for the equipment to be used. Maybe a 230v tool can be used just as safely and effectively as an 18v tool in this situation, or maybe a 3m fibreglass ladder could be used instead of a 2.4 m aluminium stepladder. This approach also underlines the fact that when a piece of equipment is exactly specified, alternatives are not permissible.
If remote supervision is to be used for a task then there may be a number of appropriate persons who could be contacted in case of problems, not just one. The non-availability of a specific manager has held up many a task encountering a problem, and when there is no alternative source of advice, workers can sometimes be tempted to “go ahead anyway”.
One other thing to consider is this: - while the method statement may be completely logical in the mind of the person who created it, does it make sense to the workers who are going to follow it? It’s very easy to miss out the obvious, or to make reference to something that is not explained, or to make a simple error in terminology, or numbering. Method statements should always be checked by somebody else, and even though this can seem time-consuming, if the result is that work doesn’t have to be stopped while a supervisor is consulted, the very opposite will be the case. We rely on Method Statements to get the job right, so let’s start out by getting the Method Statement right.