Keeping colleagues safe is a first and fundamental moral responsibility. It’s also good for business. But as everyone who works in logistics knows getting health and safety right can be complex and time consuming. This is especially the case in a cold storage business. Running a safe cold store not only means putting in place all the best practice and thorough risk assessments required in a general warehouse but also a range of cold-specific policies like ensuring personal safety in a cold environment and managing risks associated with icy surfaces.
There is certainly no room for complacency. As we all know accidents can and do happen. Health and Safety Executive (HSE) statistics show that 147 workers were killed, and a further 581,000 reported injured in workplace accidents in 2018/19 (across all types of workplaces). Rightly, there are strict health and safety requirements with which businesses in all sectors must comply. Fines totalling £54.5m from prosecutions were issued as a result of investigations into incidents in 2017/18.
Cold store guidance
Until now, there has been no starting place for people looking for good guidance on management of health and safety specifically in a cold store. We believe that providing that basic framework is a core responsibility of the Cold Chain Federation, and I am delighted that this month we have published our new guide – Keeping People Safe in a Cold Store. The document brings together the key considerations anyone responsible for health and safety in a typical cold storage warehouse must bear in mind.
We developed this guide with the help of health and safety experts from within a number of the leading cold chain logistics businesses in the UK. It was a useful process for us all, a chance to review and challenge ourselves on what the main challenges are.
In setting out to do this we started from agreeing the purpose and role of external guidance in supporting businesses to do the job they need to do. What we agreed is that there are no short cuts. No outside authority, whether it’s a trade association, training provider or consultant, however good their guidance and advisory service is, can replace a business’ own in-house responsibilities. But we can help.
As our guide makes clear, the fundamental requirement of health and safety law is for a business to take ownership of managing health and safety for themselves. Risk assessments, which are the foundation of robust health and safety, can never be generic. They must be developed with due consideration of the building, the operations and the people that work in the business in that place and time. Good guidance acts as reassurance, a sense check that helps reduce the chance of something being missed and a source of ideas and best practice that makes the job a bit easier.
The other important role of guidance is giving businesses reassurance that they are doing things right. We talk a lot about the burdens of red tape and its impact on business. However, it is rarely the rule itself that is the problem, the problem is usually inconsistent enforcement and interpretation. A business can find that a policy that is implemented in one facility in one part of the country is viewed as good legal compliance, but the same practice delivered in another is not. That inconsistency is a major cost and disruption for business.
Primary authority partnership
That is the other key role a federation can play. The Cold Chain Federation provides its advice through a legally backed ‘primary authority partnership’. This is a partnership with a local authority that is recognised in law and must be respected by every other local authority officer in England. This means that if we develop a specific way of complying with a specific regulation you can rely on it. For example, our advice on safe management of ammonia refrigeration systems also published this month is ‘assured’. This means if you are a member and you follow our compliance approach no local enforcement officer will overrule or second guess what you are doing.
As well as issuing ‘assured’ guides, we are also here to deal with specific issues. Any member can submit questions about compliance policy to us. We will then seek an answer in from our Primary Authority Partner and issue ‘assured advice.’ That is then shared with the company in question and in an anonymous way with the rest of the membership. Once issued the guidance must be respected. Please contact the Cold Chain Federation Compliance team for more information or to submit a query.