On the 23^rd of June this year Dairy Crest Limited was fined £1.52 million (the largest amount ever awarded following an Environmental Agency conviction in the South-West) after pleading guilty to 21 charges relating to the company’s management of liquid waste, odour and environmental reporting. While the damage caused to the surrounding area is horrifying, what was additionally disappointing was that these failings were down to systemic cultural behaviour within the organisation – Judge Carr commented that he “felt like there was never a time without a problem” at the company, and he identified poor middle management culture as a contributing factor.

So how can we ensure that our own middle management are not only aware of their responsibilities in regards to health and safety, but are also encouraged and empowered to speak up?

As ever, change starts from the top – if the owners, directors and board members take ownership of their responsibilities then it’s far more likely that your staff will speak up when they have concerns. In addition, it’s vital to ensure that your managers and supervisors understand the role they play and how to escalate when needed.

Speaking generally, managers and supervisors will have responsibility for both complying with your health and safety policy and for enforcing it in the workplace. We’ve broken down what this includes for quick reference below:

• To organise and co-ordinate all work with minimum risk to health and safety
• To ensure that all employees are competent to perform the tasks to which they are assigned
• To ensure agreed methods of work, codes of practice, risk assessments, method statements are adhered to and all registers and records are kept up to date
• To ensure that employees are given precise instructions in respect of health and safety
• To ensure that the storage of materials and substances are safe and comply with statutory requirements
• To maintain welfare facilities in a clean and hygienic state
• To ensure that all work equipment is used for the purpose designed, properly maintained and safe to use
• To ensure the requirements of the First Aid Regulations 1981 are met
• To ensure the rules with regard to personal protective equipment are observed and to set a good personal example
• To implement reporting procedures for all accident and dangerous occurrences and record all injuries in the accident book
• To appoint a competent person to take charge during their temporary absence
• To rectify defects notified by the Health & Safety Advisor, or HSE Inspector
• To ensure that adequate induction training is given
• To closely supervise young persons and ensure risk assessments in respect of them have been produced and available
• Ensure that a fire risk assessment is completed; a fire plan produced and complied with.

These tasks set out by the HSE are an excellent place to start, but we should also look deeper into the communication and escalation side of each of these. Without an effective free flow of information and support between employees and management, it is incredibly challenging to manage and control risk. If staff and management do not feel like they’ll be listened to when they raise concerns or feel like they will be ignored and dismissed rather than be investigated, then they simply won’t speak up.

Ultimately, middle management are responsible for obtaining feedback from employees and escalating to upper management and to health and safety representatives.  They are also responsible for effective and efficient communication in the opposite direction from upper management to all employees.

When was the last time you held training for your management level employees to upskill them in this area? And when was the last time you spoke to your ‘boots-on-the-ground’ staff about how they can report their concerns?

A good way to get staff by-in is by providing them with interactive training covering the responsibilities that they hold relating to safety. We can provide a range of training options, either in person, online or via Zoom.