Metropolitan Police Service (MPS) Health and Safety Policy Version 4.1 Summary

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1 Freedom of Information Act Publication Scheme Protective Marking Official Publication Scheme Y/N Yes Title Metropolitan Police Service (MPS) Health and Safety Policy Version 4.1 Summary MPS Health & Safety Policy complies with legislative requirements & statutory guidance. It outlines the overall health & safety management system including organisational structure, systems & procedures & responsibilities. (B)OCU or Unit, Directorate Safety and Health Risk Management Team - MetHQ Author Safety and Health Risk Management Team Review Date May 2018 Date Issued December 2020

2 Freedom of Information Publication Scheme Protective Marking: OFFICIAL Publication (Y/N): Y Title: Summary: Branch / OCU: Metropolitan Police Service (MPS) Health and Safety Policy MPS Health & Safety Policy complies with legislative requirements & statutory guidance. It outlines the overall health & safety management system including organisational structure, systems & procedures & responsibilities. Safety and Health Risk Management Team - MetHQ Date created: May 2018 Review date: December 2020 Version: 4.1 Author: Safety and Health Risk Management Team Metropolitan Police Service Corporate Health and Safety Policy Application When? This Policy applies with immediate effect. Who? All police officers and police staff, including the extended police family and those working voluntarily must be aware of, and are required to comply with, all relevant Metropolitan Police Service (MPS) policy and associated procedures. This policy will apply to: all MPS police officers; police staff; members of the Special Constabulary; other extended police family members irrespective of rank, grade or position (hereinafter designated "employees" for the purposes of this policy); contractors as appropriate. N.B. This list is not intended to be exhaustive. Specific roles and responsibilities are listed under the 'Organisation' section in the policy document. What? This Policy covers relevant MPS activities.

3 Policy Principles The Commissioner of the Metropolitan Police Service (MPS) is committed to ensuring the health and safety of officers, staff, contractors and the public who are affected by our activities. The MPS will provide a safe working environment, as far as is reasonably practicable, and promote a positive safety culture. To achieve this, the MPS will comply with the requirements of the Health and Safety at Work etc Act 1974, the Police (Health and Safety) Act 1997 and all other relevant statutory provisions and recognised codes of practice. The MPS seek the support of all officers, staff, contractors and volunteers in improving the standards of health and safety and, to this end, this policy promotes open communication and actively encourages suggestions that could lead to improvements in safety and health at work. The MPS require all employees and contractors working on behalf of the MPS to comply with the contents of this policy. The Health and Safety Policy comprises of the following documents: Statement of Intent Organisation Arrangements Monitoring and Review Purpose and Benefits The policy sets out the overall safety management system to achieve legal compliance, secure best working practices and promote a positive safety culture. This policy will promote and secure the health and safety of all our employees. This, in turn, will support the MPS in delivering a first class policing service to the public. Our focus is on improving health and safety performance by complying with all relevant legislation and associated guidance. Health and Safety Impact Statement The Commissioner is responsible for this policy and for ensuring its implementation. This policy was developed by the MPS Safety and Health Risk Management Team (SHRMT) following consultation with stakeholders. It was approved by the MPS Health, Safety and Wellbeing Board and ratified by the Commissioner. Detailed monitoring and audit arrangements are listed under the monitoring and review sections in the policy document.

4 The MPS Management Board and MOPAC/MPS Audit Panel will monitor the effective implementation of this policy. The policy document will be reviewed annually by the MPS Health, Safety and Wellbeing Board. Associated Documents and Policies This Policy will be supplemented by the MPS Health and Safety Guidance Manuals. Other aligned policies and associated documents include: First Aid and Emergency Life Support SOPs SHRMT, Occupational Health (OH) and Property Services sponsored support intranet pages and guidance; HSE Guidance note 65 (Managing for Health and Safety); Property Services Building Appointed Persons SOP; Other related policies, SOPs or guidance published by Business Groups or Specialist Operational Command Unit. Notices to be Cancelled / Amended This Health and Safety Policy replaces the 2016 policy document (version 4).

5 Statement of Intent

6 KEY RESPONSIBILITIES AND ACCOUNTABILITIES MOPAC/MPS Audit Panel 1. The MOPAC/MPS Audit Panel will receive periodic health and safety performance reports providing compliance assurance and ensure that there is: appropriate and effective MPS safety governance arrangements; governance arrangements are subject to periodic independent audit and review; annual assurance process statement by the Commissioner to the Deputy Mayor for Policing and Crime; effective arrangements for promoting and developing a positive health and safety culture. Commissioner 2. The Commissioner is responsible for the implementation and day-to-day operational management of health and safety in the MPS. 3. The Commissioner will ensure that as far as is reasonably practicable, adequate resources are allocated to meet both present and anticipated health, safety and aligned welfare requirements. 4. The Commissioner will also ensure that the MPS considers and, where necessary, acts upon any representations made or advice given by her Management Board, enforcing authorities, specialist advisors or committees. 5. The Commissioner's responsibilities include the need to: promote and maintain effective working relations between the Mayors Officer for Policing and Crime (MOPAC) / MPS and the statutory enforcing authorities; ensure a policy of open communication and consultation on health and safety issues; require managers to set in place appropriate measures to ensure compliance with health and safety standards and procedures; promote health and safety throughout the MPS, both within policing operations and the working environment; monitor the performance of the MPS by obtaining relevant information on all health and safety proactive and reactive indicators, including accident and ill-health statistics; the MPS Health, Safety and Wellbeing Board present an annual health and safety plan to the Management Board and embed it into the MPS systems of working; actively monitor the implementation of the policy through the Management Board; present to the MOPAC an annual statement of health and safety assurance concerning effective health and safety risk management systems, and obtain

7 similar assurances from Management Board members in relation to their responsibilities; advise the MOPAC, with regard to financial and other implications of compliance with current and forthcoming legislation; provide information and, as necessary, explanation to the MOPAC/MPS Audit Panel in order for the audit panel to discharge its responsibilities by way of strategic oversight. Management Board 6. Members of Management Board will collectively and individually promote and provide clear leadership and commitment to health and safety, and afford health and safety a level of visibility commensurate with its importance. 7. Members of the Management Board should be aware, understand and appreciate the hazards and risks encountered by their teams in their day-to-day activities. Each Board member will appoint a suitable and competent individual, who will deputise in their absence. 8. The Director of People and Change will act as the Board's lead member for health and safety matters (excluding estates) and will work closely with Board members and the Commissioner, to ensure that the structure for the management of health and safety is embedded within the MPS and is fully operational. However, other Management Board Members will retain primacy for health and safety within their own business areas. 9. The Director of Commercial and Finance will act as the Board's lead member for estates and fire safety matters and will work closely with other Board Members and the Commissioner to ensure the estate remains compliant with health and safety legislation. Board members will retain primacy for all activities carried out within and from buildings within the estate for their own business areas. 10. The Management Board's role is to: show clear leadership in promoting a positive health and safety culture; discuss and formulate health and safety policy; encourage all business groups to co-ordinate their health and safety activities; communicate and establish health and safety objectives; ensure effective communication, consultation and implementation of health and safety matters with employees, their representatives and accredited safety representatives; encourage collaboration and communication with employees by managers; encourage and lead development of a positive culture in support of the MPS maturity model; allocate the necessary resources to achieve agreed objectives and targets; consult all relevant stakeholders before making a final decision about any matters of strategic importance.

8 11. Each Board member has a responsibility to ensure the health and safety within their respective business group, which will include: each OCU and department produces and implements a local health and safety policy, organisational structure, and arrangements for the management of health and safety. Simplified safety management arrangements are available to low risk OCUs (as defined by the MPS Safety and Health Risk Management Team (SHRMT)). The Policy Statement of Intent is to be signed by the OCU Commander or Head of Department; allocation of duties and responsibilities for health and safety; risk assessments are completed and control measures (including safe systems of work) are implemented and communicated to staff; risk assessments are reviewed at regular intervals with amendments communicated to appropriate managers responsible for implementing changes; managers collaborate and communicate with employees and their representatives on health and safety matters including the Superintendents' Association, Police Federation, police staff associations and trade union representatives; managers undertake regular workplace inspections; provide an annual statement of business group health and safety assurance. 12. The Management Board will measure health and safety performance, using all relevant performance indicators, including: accident, incident and near miss records; inspection reports; audit results and other appropriate management information. 13. The Management Board will also: provide specialist safety teams with the appropriate information and statistics to enable them to discharge their responsibilities; ensure accredited safety representatives are given all necessary assistance to carry out their health and safety activities and/or inspections; ensure appropriate health and safety training is provided for all employees; ensure that sufficient time is afforded for employees to undertake health and safety training (this includes time for safety representatives training); ensure each OCU Commander, Head of Department or where applicable, Senior Building Lead (SBL) assumes responsibility for health and safety for the site and/or buildings under their control. OCU Commander, Head of Department and local Senior Leadership Team (SLT) 14. Each OCU and department is to produce and implement a local health and safety policy, organisational structure, and arrangements for the management of health

9 and safety. The Policy Statement of Intent is to be signed by the OCU Commander or Head of Department. Simplified safety management arrangements are available to low risk OCUs (as defined by the MPS SHRMT). 15. The OCU Commander or Head of Department is responsible for developing, implementing and maintaining a local health and safety policy, organisation and arrangements. These senior managers will: show clear leadership in promoting a positive health and safety culture and support of the health and safety culture maturity model; comply with all relevant legislative and statutory requirements; allocate SLT members specific responsibilities and safety roles, as appropriate, taking account of the OCU or department activity; implement the MPS health and safety management system, based on this policy and MPS guidance; ensure that risk assessments are completed and control measures (including safe systems of work) are implemented and communicated to staff; ensure that risk assessments are reviewed at regular intervals, with amendments communicated to appropriate managers responsible for implementing changes; ensure contractors operate and comply with all relevant safety requirements; appoint an SLT lead and SPOC for health and safety; where required, undertake the role of SBL, or appoint a person to undertake the role of SBL for each building / site within their area of responsibility; appoint a Premises Fire Lead (PFL) for fire safety for each building / site within their area of responsibility; ensure staff and visitors occupy and undertake their duties in buildings in accordance with all MPS policies and procedures; develop and maintain premises specific Emergency Plans and carry out / initiate, monitor and review emergency plan drills; Provide an annual statement of health and safety assurance. 16. The model for an OCU or department to achieve an MPS safety management system is contained in the Health and Safety support pages together with a local safety policy template. 17. The OCU Commander or Head of Department will chair the local Health and Safety Committee. This Committee includes representatives from all units and teams, Building Resource Officers, local safety representatives and other relevant stakeholders, and must be held at least quarterly. A clear record of these meetings should be retained. 18. Whilst overall accountability rests with the OCU Commander or Head of Department, the relevant SLT are responsible for the practical elements of the policy implementation. The SLT are collectively responsible for:

10 showing clear leadership in promoting a positive health and safety culture and implementation of the health and safety culture maturity model; effective integration of the local health and safety management system; setting of local objectives, improvement targets and performance monitoring; managing any health and safety issues devolved by the Management Board or the Business Group Management Board Member; promoting good working practices, including work / life balance; ensuring all staff are receiving suitable and appropriate training to ensure that they can perform their activity competently and safely; liaising, where appropriate, with other MPS departments or relevant stakeholders, to develop integrated health and safety systems between all stakeholders; promoting and facilitating consultation with representatives from the Superintendents' Association, Police Federation, police staff associations and trade unions; proactive monitoring to ensure compliance with safe systems of work, through audits and inspections; premises specific emergency plans are in place, monitored and tested; ensure contractors operate and comply with all relevant safety requirements; ensure staff and visitors occupy and undertake their duties in buildings in accordance with all MPS policies and procedures; attending their local Health and Safety Committee meetings. Local Health and Safety Information 19. Each OCU or department is to publish, via their intranet homepage, the OCU H&S policy including the signed statement of intent, safety risk assessments, committee minutes, record of local building inspections, appointed persons and health & safety plan. These are to be available to all OCU officers / staff and should be reviewed / updated (as appropriate) quarterly. Specialist Safety Support Safety and Health Risk Management Team 20. The Safety and Health Risk Management Team will provide the following: professional safety and health advisory risk management service (including a 24hr on call support service to all business portfolios, OCU s operational activity 1 ); health and safety assurance to the Commissioner; 1 HSE guidance 'Striking the Balance' between operational and health & safety duties in the police service dated September 2009.

11 maintain, update and audit of the MPS safety policy and governance arrangements in accordance with this policy, HSE guidance, and national policing standards; define the safety maturity process and support / deliver continuous safety improvement; benchmark MPS performance with other police forces and organisations with a similar profile; evaluate corporate health and safety compliance and report performance to the MPS Health, Safety and Wellbeing Board, Management Board and MOPAC/MPS Audit Panel; liaise with enforcing authorities including provision of investigation / incident reports for enforcing authorities and coroners etc. Property Services 21. Property Services are responsible for MPS Buildings. This includes:- duty holder for all building fixed assets / plant, services, infrastructure and fabric compliance / maintenance and legal compliance; this will be through the Facilities Management Integrator; building safety management co-ordination role in common areas at specific multiple occupancy HQ buildings; professional building safety and health advisory risk management service (including a 24hr on call support service to all business portfolios, OCUs); building related health and safety assurance to the MPS Health, Safety and Wellbeing Board, Commissioner and MOPAC/MPS Audit Panel; liaise with enforcing authorities on fire and building related matters including provision of investigation / incident reports for enforcing authorities; ensuring all building regulatory health and safety compliance is adhered to, including: Asbestos, Boilers, Building Fabric (internal / external), Cleaning, Drainage, Fire Safety Systems, Fixed Electrical Systems, Fuel Supply / Storage, Heating, Ventilation and Air Conditioning (HVAC), Lifts & Hoists, Lighting, Lightning Conductors, Maintenance, Pressure vessels, Sewerage systems, Working at Height Harness Fixings, Water Systems, Welfare Facilities; providing adequate planned maintenance; ensuring that suitable competent building contractors are employed; ensuring that any building related equipment purchased is suitable and safe for use; ensuring adequate and suitable construction design and compliance with MPS standards; auditing to ensure that building regulatory compliance is satisfactory and safe systems of work by Private Finance Initiative (PFI) partners and/or contractors are in place;

12 provision of instructions / guidance on building safety arrangements including appointed persons, HQ and multiple occupier sites; emergency and fire arrangements for HQ sites. Strategic Training Committee 22. The Strategic Training Committee is responsible for approving and monitoring MPS health and safety training standards. The Committee is to: Monitor training development and ensure appropriate knowledge and skills requirements are met including health and safety; Monitor and validate training delivery standards; Consult and where applicable collaborate with the MPS Health, Safety and Wellbeing Board on technical standards and related issues. HR Services 23. HR Services will provide monthly management information reports to all Business Groups, OCUs, departments and where appropriate business areas. These reports will include accident, near miss, working time, and training data (including basic summary trend information). Local Support Delivery Manager (LSDM) 24. LSDM and LSDM team will provide all admin and co-ordinate all local H&S processes less the provision of monthly health & safety reports provided by HR Services. The LSDM will maintain a close liaison with the Business Group safety lead, OCU Commander / Head of Department. All Managers and Staff 25. All managers, at all levels of the organisation, will be responsible and accountable for visible and proactive leadership in implementing this policy. 26. All employees have a responsibility to comply with health and safety policies and procedures, through taking care of themselves and their colleagues. They should also bring to the attention of their line manager health and safety concerns which may lead to an accident or injury. ORGANISATION HEALTH AND SAFETY COMMITTEES MPS Health, Safety and Wellbeing Board 27. The MPS Health, Safety and Wellbeing Board, chaired by the Director of People and Change, will include representatives from all business groups, Superintendents'

13 Association, Police Federation, police staff associations and trade unions. The Board will be responsible for the governance of health, safety and wellbeing within the MPS, direct action to address shortfalls and improvements in the safety management system, and provide a forum to discuss corporate health and safety issues. The Board will: identify and discuss high risk issues that arise from the corporate health, safety and wellbeing risk register, prioritise as necessary, and oversee their resolution; identify and discuss emerging issues that may arise from business / portfolio areas and other health, safety and wellbeing risk registers but remain unresolved, prioritising as necessary, and overseeing their resolution; maintain robust health and safety management systems within the MPS; preside over other concerns raised by: o o business groups; and the relevant staff representative associations; promote a positive health and safety culture and aligned model within the MPS; promote and support health, safety wellbeing related organisational learning; and establish and maintain working relationships with other key MPS Corporate Boards, MOPAC/MPS Audit Panel, and other relevant committees. 28. The Board will meet on a quarterly basis, but the Chairperson may, on occasion, require an extraordinary meeting to deal with emerging issues. Business Group Health and Safety Committees 29. Each Business Group will have in place a Business Group health and safety committee. The committee will be made up of the Business Group SLT, appropriate representatives for the B/OCUs or Departments, staff representative associations for both police officers and staff, where appropriate, a member of the PFI team, and, if required, specialist health and safety advisors. The committee will be chaired by the Assistant Commissioner / Head of the Business Group. The committee will be responsible for: recommending business group health and safety policy and performance objectives to the business group SLT; driving a positive health and safety culture and implementing the MPS health and safety culture maturity model; monitoring performance objectives, inspection and audit results; consulting staff, Superintendents' Association, Police Federation, police staff associations, and trade unions on the development and performance of health and safety in the business group; communicating corporate and business group health and safety issues to all employees; discussing business group health and safety concerns.

14 30. These committees must: convene at least six monthly; be recorded and actions noted; allocate actions noted to a specific manager; make outcomes known to all staff and relevant stakeholders. Local OCU or Department Committees 31. Each OCU or department will have in place a local health and safety committee. These committees will be made up of the SLT, LSDM, local safety representatives for both police officers and staff, where appropriate, a member of the PFI team, and, if required, specialist health and safety advisors. The committee will be chaired by the OCU Commander or Head of Department. The committee will be responsible for: recommending local health and safety policy and performance objectives to the SLT; driving a positive health and safety culture and implementing the MPS health and safety culture maturity model; monitoring performance objectives, inspection and audit results; consulting staff, Superintendents' Association, Police Federation, police staff associations, and trade unions on the local development and performance of health and safety in the OCU or department; communicating corporate and local health and safety issues to all employees; discussing local health and safety concerns; the review and monitoring of building and fire safety related issues; reviewing and recommending updates to the local health and safety intranet pages including maintaining an up to date appointed persons list. 32. These committees must: convene at least quarterly; be recorded and actions noted; allocate actions noted to a specific manager; make outcomes known to all staff and relevant stakeholders. 33. Where departments are spread over several sites, OCU site managers should hold local meetings, prior to the main OCU or departmental committee meeting. Low risk OCUs / Departments 34. Simplified OCU / department meeting arrangements will be available to low risk OCUs (as defined by the MPS SHRMT).

15 STAFF CONSULTATION Safety Representatives 35. Formal consultation with employees will be held in accordance with the Safety Representatives and Safety Committees Regulations 1977 and, as necessary, in accordance with the Health and Safety (Consultation with Employees) Regulations The Chief Police Officers Staff Association, Superintendents' Association, Police Federation, police staff associations and trade unions represent the interests of its members in all matters of health, safety and aligned welfare. 37. The recognised trade unions in the MPS are entitled to appoint safety representatives to consult with management in matters relating to health, safety and aligned welfare. The trade unions have agreed to extend their role to non-union members with regards to health and safety advice. Police Federation representatives will be treated for this purpose as if they were appointed trade union representatives. 38. Safety representatives will: have access to esafety or be provided with accident and incident records (including relevant statistical data); have access to all relevant safety related data; be consulted by Senior Managers concerning risk assessments, new systems of work, or any plans with health, safety and welfare implications, prior to implementation. ARRANGEMENTS 39. The MPS SHRMT and Property Services health and safety guidance is to be used to support the implementation of this policy by all employees. These provide guidance on: the implementation of the MPS health and safety management systems; compliance with specific legislative and statutory requirements; the actions necessary to ensure compliance with the relevant health and safety legislation; Property Services in relation to building, estate and fire safety matters. Risk Assessment 40. All work activity is required to be risk assessed in accordance with the guidance on the risk assessment process. This assessment will evaluate the significant hazards and implement control measures to eliminate, reduce or control the risks.

16 41. All corporate and local risk assessments are to be reviewed at regular intervals, at least annually, or when significant changes to operational processes are made. 42. Any amendment should be communicated to appropriate managers who are responsible for implementing changes. 43. Where hazards cannot be eliminated or adequately controlled, employees will be issued with appropriate personal protective equipment, as identified by the risk assessment, to support a safe system of work. Control of Contractors 44. It will be the responsibility of Procurement Services to ensure all contractors undergo an appropriate health and safety selection process, demonstrate that adequate competency and arrangements are in place to monitor, manage and if required sanction poor performance. 45. Contractors working on police premises will be supervised either by Property Services, PFI partners, Digital Policing, OCUs or departments to ensure that their activity / work complies with the minimum statutory provision for health and safety, and does not create significant hazards, which affect employees or others 46. In addition all relevant stakeholders who are involved with contractors' activities or their supervision will: cooperate to ensure compliance with current legislation; exchange safety information (including risk assessments), advising the OCU Commander as appropriate; ensure all contractors are aware of the action to be taken in the event of an emergency ensure that the contractor is provided with the MPS safety rules for contractors. Control of Visitors 47. The OCU Commander or Head of Department or SBL shall ensure that visitors to MPS buildings will: pass through a controlled entry point to prevent the security of the building being compromised; whilst in the building, be made aware of the necessary emergency procedures; ensure procedures are in place to record the visit. Fire arrangements and Emergency Procedures 48. Every MPS site / building is to produce, implement and maintain procedures for dealing with: fire;

17 medical emergency; bomb alert / terrorist attack; environmental hazards or other major incident. 49. Property Services will ensure that a fire risk assessment is in place in all permanent MPS buildings to ensure that: arrangements are in place for safe evacuation in the event of a fire; all employees, contractors and visitors are aware of those arrangements. 50. The emphasis of the above is to ensure proactive management of prevention by the removal of ignition sources and/or combustible materials and good housekeeping. 51. All employees and non-mps personnel within a building will comply with the emergency and fire evacuation plan. First Aid 52. All MPS buildings and operations will have suitable arrangements for First Aid, in accordance with the First Aid SOP. Local OCU and Department Arrangements 53. Each OCU and department is to develop and implement effective local health and safety governance arrangements to support their policy and provide, as far as is reasonably practicable, a safe work environment. All Buildings / Sites 54. The OCU Commander, Head of Department or SBL is to develop and implement local site / building arrangements to facilitate the collaboration and co-ordination of site / building safety arrangements for the sites they have responsibility for, including: the safety of communal areas including pedestrian and road safety; emergency plans; the control of visitors; the actions and behaviours of all visitors and staff to, and within the premises in accordance with all MPS policies and procedures; the control of contractor access. 55. This will be undertaken by Property Services for all HQ sites. Monitoring Performance 56. Management Board will monitor the effective implementation of this policy. 57. Management Board Members, OCU Commanders, Head of Departments and the Chair of the MPS Health, Safety and Wellbeing Board will report and account to the

18 Commissioner, as requested, on health and safety performance and other safety related issues. This will culminate in an annual assurance statement from the Commissioner to the Deputy Mayor for Policing and Crime. 58. The Director of People and Change will provide a regular report to the Management Board on corporate health and safety issues including fire and building regulatory compliance. 59. All OCU Commanders, Head of Departments and line managers will actively monitor the performance of their local health and safety policies. Local OCU and Department Proactive and Reactive Monitoring 60. All OCU Commanders, Heads of Departments, line managers will undertake proactive and reactive monitoring. This monitoring will be reviewed locally by the SLT and local Health and Safety Committee. This monitoring will include: local inspection and audit reports; accidents, dangerous occurrences and near miss investigations; the monitoring of accident and near miss statistics, including trends; performance against local H&S targets and action plans. 61. If monitoring shows that either corporate review or action is necessary, it should be brought to the attention of the MPS Health and Safety Board via the SHRMT. Audit, Review and Improvement Process 62. The MPS has three levels of audits as follows: self-assurance; re-assurance; independent. 63. OCU Commanders, Head of Departments and SBL will provide self-assurance audits by establishing their own inspection / audit programme. This is to review local management systems and key performance indicators and will inform the local response to the annual H&S Assurance Process. 64. Re-assurance audits of Business Groups, OCUs and Departments will be provided by the SHRMT. For fire and building / estate statutory compliance, this will be undertaken by the Property Services Compliance Team. 65. Independent audits will be directed by the Management Board and the MOPAC/MPS Audit Panel. These audits will be conducted by nominated external independent auditors or MOPAC Directorate of Audit, Risk and Assurance (DARA), as appropriate. Independent audit reports and findings will be reported to the Management Board and the MOPAC/MPS Audit Panel. 66. The Management Board, all OCUs and the Department SLT, strategic and local health and safety Board/committees will review performance on a regular basis, to

19 ensure that both corporate and local health and safety objectives are being achieved.