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2018/19 Annual Health & Safety Report Trust Board – in public Date: Thursday 29th August 2019 Agenda item: 5.1
Executive sponsor Mark Preston Director of Organisational Development & People
Report author(s) Jill Bartlett, Head of Health & Safety
Report discussed previously:
Health & Safety Committee (15th July 2019)
Executive Committee (31st July 2019)
Action required:
Approval () Discussion () Assurance (X)
Purpose of report:
The Trust Health & Safety annual report describes the Health & Safety performance for the Trust for 2018/19 Summary of key issues
The report provides an update on the activities and progress with Health & Safety activity during 2018/19 and identifies a set of objectives for 2019/20
Recommendation:
For the Trust Board to note the contents of this report
Relationship to Trust strategic objectives and assurance framework:
SO1: Safe – Deliver safe, high quality care and improving services which pursue perfection and be in the top 25% of our peers
SO2: Effective – As a teaching hospital, deliver effective and improving sustainable clinical services within the local health economy
SO3: Caring – Work with compassion in partnership with patients, staff, families, carers and community partners
SO4: Responsive – To continue to be the secondary care provider of choice for the people of our community
SO5: Well led – To be a high quality employer of choice and deliver financial and clinical sustainability around a patient centred, clinically led leadership model
Corporate impact assessment
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Legal and regulatory impact Meets NHSi requirements
Financial impact Identifies health and safety risks that may have a financial impact
Patient experience/engagement
Ensuring a safe environment for patients by identifying and mitigating risks
Risk and performance management
Identifies and mitigates risk in relation to health and safety
NHS Constitution/equality and diversity/communication
Meets relevant requirements
Attachments
2018/19 Annual Health & Safety Report
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Trust Health & Safety Annual Report 2018/19
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Table of Contents
Section Description Page
1 Executive Summary 3
2 Introduction 4
3 Legal Compliance - Overview 4
4 Objectives 5
5 Audit 5
6 KPI’s 7
7 Risk Assessment 7
8 Incident Reporting (DATIX Web) 7
9 RIDDOR 7
10 Work Related Absence 8
11 Benchmarking 9
12 Policies 11
13 Training 11
14 Health & Safety Executive 11
15 Health and Wellbeing 12
16 SEQOHS 12
17 Occupational Health Department 12
18 Flu Vaccination Campaign 12
19 Health & Safety Committee 13
20 Divisional Quality & Risk Governance Meetings 13
21 Conclusions 13
Appendix Description Page
A Health & Safety Key Performance Indicators (KPI) Dashboard 14
B Health & Safety Incident Rate 2018/19 15
C Health & Safety Incident Rate 17/18 & 18/19 Comparison 16
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1 Executive Summary
Purpose:
The purpose of this report is to:
Provide assurance on compliance with legislation and policies.
Provide an update on the activities and progress, in line with the implementation of the Trust's Health and Safety Policy statement and other policies, in the following departments:
Health and Safety
Occupational Health
Identify compliance and any gaps
Set objectives for 2019/20
Summary:
The gaps in identified compliance are:
Completion of audit actions by action owners at service level (see Section 5 & Appendix A). Management Regulations, Regulations 5. H&S Arrangements. Senior managers are on board to improve activity level. Revised Audit guidance protocol issued to Divisions.
Insufficient evidence of completion of suitable and sufficient risk assessments to address the significant risks of the business. Management Regulations, Regulation 3 Risk assessment, Control of Substances Hazardous to Health Regulations (COSHH) 2002, Monthly training programme now in place
The new audit tool has been rolled out across all Clinical areas. Compliance reporting occurs monthly to Divisional Quality and Risk meetings as well as Health and Safety Committee.
There has been an increase of 5 RIDDORs this year, to a total of 13. This year 3 RIDDOR’s were reported outside of the timeline required by the HSE.
Key Recommendations:
To note the contents of the annual Health and Safety Report for Surrey and Sussex Healthcare NHS Trust.
To note the activities and progress made with implementing Health & Safety arrangements.
Contributors:
Janette Barnes - Occupational Health & Safety Service Manager Jill Bartlett – Head of Health & Safety
Date: May 19
Review Date: April 2020
2 Introduction The Health & Safety report covers the period 1st April 2018– 31st March 2019. The annual report outlines key developments and the work that has been undertaken during this reporting period, and is an opportunity to consider work planned, and the objectives for the year(s) ahead.
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It reflects the Trust’s compliance with the Board of Directors approved ‘Statement of Intent’ and Health & Safety Policy Statement, which requires those responsible for health and safety within the Trust premises and during Trust activities to:
Comply with health and safety legislation;
Implement health and safety arrangements;
Comply with monitoring and reporting mechanisms appropriate to internal and external key stakeholders and statutory bodies;
Develop partnership working and to ensure health and safety arrangements are maintained for all
In progressing the management strategy of health and safety throughout the Trust, the Health and Safety Department continues to observe the HSG65 model “Managing for Health and Safety”. The key components of the Plan, Do, Check, Act (PDCA) framework can be summarised, as follows: Plan Determine policy, plan for implementation. Do Profile health and safety risks, organise for health and safety management, and
implement the plan. Check Measure performance, investigate accidents and incidents. Act Review performance, apply learning.
This framework directly maps with the SASH+ methodology, Plan, Do, Study, Act. To ensure that the health and safety agenda is not only embedded but embraced throughout the Trust using a variety of monitoring methods, including:
Health and Safety Committee (bi-monthly)
Divisional Quality and Risk (monthly) meetings
Workforce Committee
3 Legal Compliance - Overview
The table below outlines the main Health & Safety legislation and identifies the proactive work that the Trust has carried out in order to comply
Legislation Description of actions/compliance
Health & Safety at Work Act 1974
Compliant, Specific areas of assurance are: Competent persons in place to provide compliance advice. Health and Safety Committee held 6 times a year - well attended. Increased availability of induction training sessions for new
recruits, both induction and update sessions include reminders of the requirement to risk assess
Management of Health & Safety at Work Regulations 1999
Compliant, with exception of Regulation 3 where the deficit is subjective Action: more robust completion of risk assessments and process of review are required in order to be fully compliant with Regulation 3. In terms of other assurance:
Annual H&S Audit programme, all clinical areas audited, requires audit actions to be addressed at service level within given timescales in order to ensure full compliance
Risk assessment paperwork has been reviewed and now includes a requirement for role specific risk assessments, production of
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these is being monitored via the audit programme
Control of Substances Hazardous to Health (COSHH) 2005
Compliant, with exception of Regulation 6 where the deficit is subjective Action: more robust completion of risk assessments and process of review are required in order to be fully compliant with Regulation 6. In terms of other assurance:
COSHH policy has been revised with enhanced guidance on the risk assessment process
COSHH Risk assessment form simplified in order to improve compliance with Regulation 6
COSHH awareness included in all H&S Awareness training. COSHH storage reviewed in Ward areas
Display Screen Equipment Regulations 1992
Compliant, with exception of Regulation 2 where the deficit is subjective Action: more robust completion of risk assessments and process of review are required in order to be fully compliant with Regulation 2 In terms of other assurance:
New policy published with enhanced guidance on hot desking arrangements
The Occupational Health & Safety team have received training in DSE assessment to enable them to better support the workforce and improve compliance with the regulations
Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR)
Minor non-compliance with reporting timeframes Action: Reminders of reporting RIDDORS in a timely fashion are included in all H&S training sessions
77% (10) reported within the HSE’s timeline. In terms of other assurance:
Learning from all RIDDOR incidents is shared at the Divisional meetings and via the Trust Health & Safety Committee
Provision and use of Work Equipment Regulations (PUWER) 1998
Compliant, Specific areas of assurance are:
New policy published
Training and Maintenance programme in place
Health and Safety (Sharp Instruments in Healthcare) Regulations 2013
Compliant, with the exception of Regulation 5 - Use and disposal of medical sharps Action: Requires specific protocol on use, handling and disposal and administration of patient own insulin pens. In terms of other assurance:
Sharps Group has been reconvened and includes representation from all Divisions
Audit of all devices being used within the Trust is currently in progress to ensure that where available safety devices are being utilised and where it is not possible to utilise a safety device a risk assessment is completed
Health & Safety Information for Employees Regulations (Amendment) 2009
Compliant, Specific areas of assurance are: The H&S intranet page has been revised A revised Health & Safety handbook is now available H&S Coordinators and TU H&S Reps in place. Health and Safety Committee held 6 times a year is well attended
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Health & Safety Consultation with Employees Regulations 1996
by Managers, Trust Competent Persons, TU Reps and H&S Coordinators:
Reports on Audits, Action Plan progress, KPIs and Risk Register. Acts as consultative committee for H&S policies. Safety
Representatives and Safety Committees Regulations 1977
4 2019/ 20 Objectives
The primary objectives for the year are outlined at the end of the section to which they relate and are summarised in the table below, these objectives will be carried forward in order to embed performance improvements
Principle Objectives 2019/2020
1 Divisions to prioritise and focus on their Audit Action Plan compliance
2 100% of H&S annual audits to be undertaken and action plans to be issued to managers
3 Improving the three lowest audit compliance areas (Risk assessments, Work Related Stress, and COSHH) by a further 10% requiring additional focus by the Divisions
4 Trust-wide compliance with Health and Safety (Sharp Instruments in Healthcare) Regulations 2013
5 Health and Wellbeing initiatives launched within the Trust linked to CQUINs requirements (e.g. promotion of physical activity, mental health awareness, etc.)
6 Occupational Health to complete SEQOHS accreditation
5 Audit 5.1 Health and Safety Audits Auditing is a key function of the Health and Safety Department and a core component of the Trust’s health and safety management arrangements. 115 areas were audited in 2018/2019, compared to 46 in 17/18. 21 Corporate areas remain outstanding these will be completed by the end of June 2019. The audits undertaken by the Health & Safety Department include:
Visual inspection
Action Plan production
Compliance score The average compliance score for each Directorate / Division are as follows:
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Division 2017/18 2018/2019 Variance
Cancer & Diagnostic Imaging 95% 83% -12%
E&F 83% 77% -6%
Finance 91% 91% 0
HR 92% 85% -7%
Information Services 89% 89% 0
Integrated Governance 67% 67% 0
IT 76% 76% 0
Medicine 93% 81% -12%
Executive Nursing 63% 63% 0
Surgical 99% 87% -12%
WACH 91% 91% 0
The audit compliance levels have decreased since 17/18. The audit KPI’s shown in Appendix A identifies 314 late audit actions at year end an increase of 30 from the previous year. The main reason for the increase in late audit actions is due to a more robust audit tool that has generated more actions particularly in relation to completion of risk assessments, where there is also a training requirement and hence this is delaying the completion rate, until sufficient staff are trained. We are keen that this is reduced further. The lowest compliance areas:
Risk assessments have the lowest compliance - 37% of outstanding actions are in this category
Management Standards (Work Related Stressors) compliance accounts for 17.5% of outstanding actions
COSHH has replaced General H&S arrangements as the third highest category at 11.5% of the outstanding actions
Outstanding audit actions are highlighted in the monthly compliance reports that are issued at Divisional Quality and Risk Meetings. Support continues to be provided to the Divisions by the H&S Team, on the above to improve compliance.
Objectives 2019/20
1 To continue with the implementation of the new audit tool Trust-wide that will be system based
2 To load the audit tool onto Datix, to ensure easier access for the departments and allow for easier reporting
3 To ensure that all areas are audited within 2019/20
4 H&S department will continue to provide compliance reports to Divisional meetings
5 Divisional reports to the H&S Committee to include what steps are being implemented to ensure completion of outstanding audit actions
5.2 Safety Engineered Devices/Sharps safety Measures to avoid occupational exposure to blood borne viruses including prevention of sharps injuries must include; the safe handling and disposal of sharps, including the provision of medical devices that incorporate sharps protection where there are clear indications that they will provide safe systems of working for staff. This is a requirement of the ‘Code of Practice on
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the prevention & control of infections’ and ‘Sharps Instruments in Healthcare Regulations 2013’. SASH Infection Prevention and control antimicrobial stewardship IPCAS has liaised closely with the medical devices educator in ongoing work seeking to standardise safe sharps devices. IPCAS continue to educate, promote and monitor the safe use and disposal of sharps by completion of a regular programme of auditing Sharp safety The Sharps Group has been reconvened and will follow up on required actions.
Objectives 2019/2020
1 To continue with the Sharps Group meetings and ensure ongoing reporting to the Medical Devices Committee
6 Key Performance Indicators The following KPI’s are reported bi-monthly at H&S Committee:
Health and Safety training Health and Safety audit RIDDOR incidents and reporting timescales
Further information can be found in Appendix A. 7 Risk Assessment Delivery of Risk Assessment training continues. All areas are to have at least one trained Risk Assessor and this is monitored via the annual audit and the bi monthly KPI’s at the H&S Committee meeting. 51 employees received Risk Assessment training in 2018/19 however, 12 (24%) of these did not complete the ‘competency’ element. For future training courses we are making it much clearer at the outset that homework must be completed to demonstrate competency and if not submitted departments will be required to send an alternative representative. 8 Incident reporting (DATIX) There were 515 incidents recorded on Datix across the various Health and Safety categories. This was an increase of 1.6% on the previous year. A table of incident rates by category and Division is attached at Appendix B, and a chart showing year on year comparison is attached at Appendix C. The category with the largest year on year growth is Equipment; this requires further investigation in order to understand exactly what is being reported. The incidents were recorded as follows:
DATIX Category Number of Incidents
Harm – Physical 232
Harm – Psychological 9
Damage or Financial loss 13
No Harm 217
Near Miss 44
TOTAL 515
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49% of the incidents reported on Datix resulted in some level of harm or loss, this is a reduction of 16% on last year’s figures
Near misses account for only 8.5% of all reported incidents. Near misses can be used to identify safety system weaknesses.
9 Reporting of Injuries Diseases & Dangerous Occurrences Regulations (RIDDOR) 13 RIDDORs were reported in 18/19 - an increase on the previous year’s total of 8. Whilst there has been an increase, the Health & Safety Executive figures for health care advise 0.39 RIDDOR incidents per 100,000 employees - the Trust is currently at 0.31 so below the average but an increase on last year’s figure which was 0.19 per 100,000 The categories where the increases occurred were:
Slips, trips and falls Dangerous occurrences Manual Handling of objects
RIDDORS - 2018/19 Cancer E&F Medical Surgical WACH Corporate Total
Dangerous occurrence 1 0 0 0 0 0 1
Manual handling - Objects 1 2 0 0 0 0 3
Manual handling - People 0 0 0 1 0 1 2
Personal injury 0 0 0 1 0 0 1
Sharps 0 0 1 0 0 0 1
Slips, trips and falls 0 2 0 0 3 0 5
Total 2 4 1 2 3 1 13
Of all H&S incident reports, RIDDORs accounted for 2.5% in 2018/19, this is an increase on the previous year and can probably be attributed to better awareness of the regulations as a result of induction and update training:
14/15 15/16 16/17 17/18 18/19
1.8% 0.5% 0.9% 1.6% 2.5%
Managers are required to identify any staff injury/illness for RIDDOR reportable cases and are required to undertake and record their investigations following a RIDDOR incident.
Objectives 2019/20
1 Continue to raise awareness of RIDDOR Trust-wide, specifically the importance of timeliness of reporting
2 Continue to monitor investigation reports raised by managers, ensuring that these are completed within the timelines laid down in the Trust incident reporting policy
3 Promote the importance of reporting near miss incidents
4 To clarify exactly what incidents are being reported in the Equipment category and to confirm that these are genuine incidents and not operational issues
10 Work Related Sickness absence The H&S Department receive First Care reports whenever a member of staff reports that their absence is due to the workplace.
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2266 days were recorded as relating to work in 2018/19 which is a decrease of days lost from 2016/17 where 2840.25 days were recorded
Division Days absences % of total
Surgical 590 26%
Corporate 32.5 0.01%
Estates & Facilities 488.50 21%
Medical 429.25 20%
Cancer & Diagnostics 368 17%
WACH 357.75 15%
Absence Code Days absences % of total
Stress/Anxiety 1437.75 63%
Back injury 198.25 9%
Other MSD 237.50 10%
Injury/Fracture 204.00 9%
No consent 120.75 5%
MSK upper arm/neck 62.0 2%
Skin disorders 2.75 1%
Other 2.00 1%
Work Related Stress is significantly higher (63%) than the other absence codes, with 1437.75 days lost in total across all divisions; The Surgical Division reported the highest level of absences relating to stress.
Objectives 2019/20
1 To continue to promote the completion of the HSE Management Standards tool to ensure that all Divisions are identifying and acting on stressors within their Departments
2 To review options for electronic completion of the management standards tool
11 Benchmarking Benchmarking has not taken place this year, however it is planned that this will be re-introduced for the next annual report.
Objectives 2019/20
1 Reintroduce benchmarking for the 19/20 annual report
12 Policies In 2018/19, revised polices for Display Screen Equipment and the Provision and use of Work Equipment were published.
All Health and Safety policies are available on the Intranet.
Objectives 2019/20
1 Ensure all relevant Health and Safety policies are in date, meet national and local standards and highlight the use of ‘best practice’
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13 Training The Health & Safety training portfolio includes both Induction and Refresher training. The courses include:
Health & Safety Awareness Health & Safety Risk Assessment Health & Safety Coordinator & Reps
An e-learning package has been rolled out for the refresher training in addition to the class room based sessions. All training is reviewed regularly in line with legislation and SaSH incident trends.
Objectives 2019/20
1 To continue to promote the e-learning package and increase uptake
2 To introduce a Health & Safety responsibilities awareness document for Managers
14 Health and Safety Executive There has been no formal contact from the HSE during 2018/19 15 Health and Wellbeing The health and wellbeing strategy is being updated and reviewed continuously, to ensure that it aligns to current Trust initiatives and NICE guidance on wellbeing and work.
Objectives 2019/20
1 To update strategy in line with Trust initiatives and NICE guidance
2 To update monthly themes to support and educate staff
3 To develop a physiotherapy service that allows rapid access, back care training and
treatment for all SASH staff
4 To deliver a wellbeing day for all staff and to encourage them to ‘Take a Break’
16 Safe Effective Quality Occupational Health Service (SEQOHS) accreditation The Trust has uploaded all documents for the readiness assessment which are being assessed by the Faculty of Occupational Medicine.
Objectives 2019/20
1 To gain accreditation by October 2019
2 To enable access for all managers for on line referrals
3 To develop and deliver a comprehensive audit programme which can be
benchmarked nationally
4 To develop and update policies and processes
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17 Occupational Health Department Occupational health continues to utilise and maximise the benefits of the new Cohort system enabling the department to provide key performance data to the Trust. The pilots for on line referrals have now been completed, and roll out to the rest of the Trust for this service is scheduled to take place during June 2019, with the aim of being fully operational by July 2019. .
Objectives 2019/20
1 To develop surveillance policy and strategy to ensure all staff are invited to complete
their annual surveillance forms
2 To develop and deliver outcome data module for all contacts to the OH department via the Cohort system
3 To develop and update Occupational Health policies and processes
4 To audit against policies and processes (develop continuous improvement process)
18 Flu Vaccination Campaign The 2018/19 Flu campaign achieved a 67% take up rate for front line staff. Whilst the uptake was lower than last year, the actual number of vaccines delivered exceeded 3,200, which was significantly more than the previous year. Along with substantive staff, vaccines were also given to agency staff, honorary staff and contractors. The vaccine provided was the quadrivalent vaccine which provides an enhanced level of protection for our staff. The main reasons for non-take up of the vaccine was related to staff perceiving that the vaccine did not work and the fact that many people feel they get ill after receiving the vaccine. Planning for 2019 has commenced and the quadrivalent vaccine has been ordered for 3,500 staff.
Objectives 2018/19
1 To increase vaccine uptake for frontline staff for 2019/20 to 75%
19 Health and Safety Committee The H&S Committee continues to be held bi-monthly with 3 x agenda cycle. Audit and Action Plan progress and gaps, overdue risks and risk actions and incident statistics are standing agenda items. Reports from Estates & Facilities and the Manual Handling department continue to be included on the agenda. Membership consists of the Trusts ‘Competent Persons’, H&S TU Reps, H&S Coordinators and Managers, with the Director of Organisational Development & People as Chair. 20 Divisional Quality and Risk Governance Meetings
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Health and Safety continue to submit monthly reports, which include:
Incident trends and compliance
Audit and Action Plan gaps, progress and compliance
RIDDOR compliance
Risk Assessors and training courses 21 Conclusions The report highlights the significant amount of work that has been undertaken during 2018/19 to improve the management of health & safety in the Trust. The Health and Safety Team continues to embed a health and safety culture, with the revised audit and inspection programme and ongoing health and safety training. This will improve the application and awareness of health and safety throughout the Trust. The Trust’s Health and Safety Team continue to provide advice and guidance to managers and staff to ensure they are able to meet the needs of the Trust in its compliance with health and safety legislation, and continue to engage with other specialist services within the Trust to assist in the development of future strategies.
Both the audit programmes and incident reporting are fundamental to the Trust being able to identify, analyse and address its high risk areas. This relies on the involvement of all staff and managers and the H&S Team are working Trust-wide to deliver on this. Datix on-line continues to improve the efficiency of reporting for staff and should also improve the follow up and investigation of incidents by managers.
The 2019/20 objectives document the key pieces of work required to improve upon the identified issues and forms the work plans for various departments within the Trust. Progress against these objectives will be reviewed at Trust Health and Safety Committee and forwarded to the Workforce Committee for information.
The Occupational Health Department has used innovation and technology to develop the service in the past 12 months and the process of achieving the SEQOHS accreditation will further enhance the Occupational Health Service in 2019/20.
Both Health & Safety and Occupational Health aim to provide the Trust with pro-active services that support employees and the Trust as a whole in providing a positive and safe working environment.
Janette Barnes
Occupational Health, Safety & Well-Being Manager
May 2019
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Appendix A - SASH Health and Safety Key Performance Indicators Dashboard
Performance Dashboard 2018/2019
Indicator Strategy Key
Driver 1
Key Driver
2
Does not
meet goal
Meets Goal
Exc'ds Goal
Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar YTD
2018 2018 2018 2018 2018 2018 2018 2018 2018 2019 2019 2019 2018/2019
OBJECTIVE : Safety and Quality
Trained and competent Risk Assessment in ward/dept. = 10 people per quarter
Health & Safety HSE NHSLA
<8 per Q
>8 per Q
>10 per Q 13 0 20 0 5 0 8 3 0 3 8 0 51
Annual H&S audit undertaken = 123 Health & Safety HSE NHSLA <=8 9 >9 1 0 0 1 8 20 15 16 10 5 6 2 115
Late audit actions (rolling total) Health & Safety HSE NHSLA <0 0 NA 241 216 245 NA 158 183 171 199 397 382 383 314 314
Audit action completed on time Health & Safety HSE NHSLA <100% 100% >100% 0% 0% 0% 0% 0 0% 0% 0% 4% 35% 19% 27%
RIDDOR Incidents reported to HSE within 15 days
Health & Safety HSE NHSLA <90% 90% >90% 1 1 2 1 0 1 0 1 1 3 1 0 10
Trust RIDDORs reported to HSE Health & Safety HSE NHSLA - - - - - - - 13
Late RIDDORs - Surgical Health & Safety HSE NHSLA - - - - - - - 0
Late RIDDORs - Medical Health & Safety HSE NHSLA - - - - - - - 0
Late RIDDORs - WACH Health & Safety HSE NHSLA - - - - - - - 1 1
Late RIDDORs - F&E Health & Safety HSE NHSLA - - - 1 - - - 1
Late RIDDORs - Cancer Health & Safety HSE NHSLA - - - - - - - 1 1
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Appendix B – SASH H&S Incident Rates for 2018/19
Reported H&S incidents 18/19 Cancer E&F Medical Surgical WACH Corporate Total
Dangerous occurrence 7 1 2 7 3 0 20
Environmental incident 1 0 0 0 0 1 2
Equipment incident 14 6 14 28 19 6 87
Food hygiene 0 1 0 1 2 0 4
Hygiene issues 1 0 3 2 6 0 12
Ill health/disease 2 0 3 5 2 0 12
Manual handling - Objects 8 10 4 8 5 0 35
Manual handling - People 2 0 9 12 2 1 26
Non compliance with Health & Safety rules 7 9 7 13 3 1 40
Personal injury 8 6 5 21 7 3 50
Sharps 3 2 25 35 12 2 79
Slips, trips and falls 7 17 22 12 13 3 74
Trust infrastructure 2 0 1 2 1 0 6
Vehicle incident 0 0 0 0 1 0 1
Waste incident 1 6 3 6 4 0 20
Workplace environment 11 5 5 13 9 3 46
Capital projects (Environmental Safety use only) 0 0 0 1 0 0 1
Total 74 63 103 166 89 20 515
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Appendix C 17/18 & 18/19 Comparison Incidents by Category
0
10
20
30
40
50
60
70
80
90
100
17/18
18/19