March 2010
Examiners’ Report NEBOSH National Diploma in Occupational Health and Safety - Unit D
Examiners’ Report NEBOSH LEVEL 6 DIPLOMA IN OCCUPATIONAL HEALTH AND SAFETY Unit D Assignment MARCH 2010
CONTENTS
Introduction
2
General Comments
3
Unit D Assignment
2010 NEBOSH, Dominus Way, Meridian Business Park, Leicester LE19 1QW tel: 0116 263 4700
fax: 0116 282 4000
email:
[email protected]
website: www.nebosh.org.uk
The National Examination Board in Occupational Safety and Health is a registered charity, number 1010444 T(s):exreps/UnitD/UnitD-1003
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JP/DA/REW
Introduction
NEBOSH (The National Examination Board in Occupational Safety and Health) was formed in 1979 as an independent examining board and awarding body with charitable status. We offer a comprehensive range of globally-recognised, vocationally-related qualifications designed to meet the health, safety, environmental and risk management needs of all places of work in both the private and public sectors. Courses leading to NEBOSH qualifications attract over 25,000 candidates annually and are offered by over 400 course providers in 65 countries around the world. Our qualifications are recognised by the relevant professional membership bodies including the Institution of Occupational Safety and Health (IOSH) and the International Institute of Risk and Safety Management (IIRSM). NEBOSH is an awarding body to be recognised and regulated by the UK regulatory authorities:
The Office of the Qualifications and Examinations Regulator (Ofqual) in England The Department for Children, Education, Lifelong Learning and Skills (DCELLS) in Wales The Council for the Curriculum, Examinations and Assessment (CCEA) in Northern Ireland
NEBOSH follows the “GCSE, GCE, VCE, GNVQ and AEA Code of Practice 2007/8” published by the regulatory authorities in relation to examination setting and marking (available at the Ofqual website www.ofqual.gov.uk). While not obliged to adhere to this code, NEBOSH regards it as best practice to do so. Candidates’ scripts are marked by a team of Examiners appointed by NEBOSH on the basis of their qualifications and experience. The standard of the qualification is determined by NEBOSH, which is overseen by the NEBOSH Council comprising nominees from, amongst others, the Health and Safety Executive (HSE), the Department for Education and Skills (Df ES), the Confederation of British Industry (CBI), the Trades Union Congress (TUC) and the Institution of Occupational Safety and Health (IOSH). Representatives of course providers, from both the public and private sectors, are elected to the NEBOSH Council. This report on the Examination provides information on the performance of candidates which it is hoped will be useful to candidates and tutors in preparation for future examinations. It is intended to be constructive and informative and to promote better understanding of the syllabus content and the application of assessment criteria. © NEBOSH 2010
Any enquiries about this report publication should be addressed to: NEBOSH Dominus Way Meridian Business Park Leicester LE10 1QW Tel: 0116 263 4700 Fax: 0116 282 4000 Email:
[email protected]
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General comments
The submission date for the NEBOSH National Diploma Unit D workplace based assignment was 10 March 2010. 551 candidates submitted their assignment and 391 passed giving a pass rate of 71%. The focus of the Unit D assignment should be the application of the knowledge and understanding developed in Units A, B and C to a real workplace situation. It provides opportunities for the candidate to carry out research appropriate to a level 6 qualification. Candidates are required to demonstrate their ability to carry out a range of activities that would be expected of a health and safety practitioner. The aim of the assignment is to produce an overall review of the health and safety management system of an organisation and indicate, through the application of risk assessment, the priorities for the organisation for the future. Before attempting the Unit D assignment it is necessary for candidates to be fully conversant with key elements of the syllabus for Units A, B and C. To facilitate this formative learning process it is essential that candidates hold regular discussions with their tutor(s) throughout the period of their studies, and complete the Assignment Log provided in the NEBOSH Unit D Candidate Guidance, which is available from the NEBOSH web-site. Candidates should visit www.nebosh.org.uk/students/currently_studying and then click on ‘2006 Specification’ before selecting the PDF document entitled ‘Unit D Candidate Guidance’. There is strong evidence to suggest that candidates who perform better in Unit D use the Assignment Log from the very beginning of their studies, and at appropriate points on their learning journey. Candidates who complete their Assignment Log retrospectively at the end of their studies will obtain little or no benefit, and may well struggle to perform well in Unit D. Course providers are requested to ensure that candidates use their Assignment Logs accordingly.
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Assignment
Assignment Brief The candidate is required to carry out a detailed review of the health and safety performance of a workplace or organisation and to produce a justified action plan to improve performance. The assignment will require the candidate to apply the knowledge and understanding gained from their studies of elements of Units A, B and C in a practical environment and to carry out critical analysis and evaluation of information gathered during the review. The level of work should be that expected of a competent occupational health and safety practitioner working within an organisation. The report should include:
an introduction that sets the scene by stating clear aims and objectives and a description of the methodology employed to carry out the assignment;
a description of the chosen workplace/organisation to set a context for the assignment. The candidate will need to consider the legal framework within which the workplace / organisation operates;
an overview of the current health and safety management arrangements in which the candidate should critically review the health and safety management system;
a survey of a wide range of significant hazards within the workplace. The candidate should prioritise the identified hazards and, depending on the nature and extent of identified hazards, for each of two of the hazards, one physical and one appropriate to health and welfare, carry out a risk assessment. This should include an evaluation of the effectiveness of the organisation in controlling the risk arising from the hazards identified and proposals to further control the hazard(s) and reduce risks;
conclusions which summarise the main issues identified in the candidate’s work together with justified recommendations for improvement;
a costed and prioritised action plan for implementation of the candidate’s recommendations in each of the two areas;
an executive summary of the report.
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Examiners’ Comments
Those candidates who performed well in this assignment were evidently following the detailed guidance (in the Guide to the NEBOSH National Diploma in Occupational Health and Safety and on the NEBOSH website) very closely. It was clear that they were using the requirements of the said guidance to structure their report, often using the guidance content to produce section headings in their work. It is disappointing, though, that far too many candidates are failing to follow the guidance provided by NEBOSH. It is particularly disappointing to see that many candidates are failing to follow the additional information provided in previous Examiners’ Reports, and that many of the common (and most easily avoided) problems are being repeated by candidates in successive sittings.
Executive Summary The executive summary should provide a concise overview of the important points arising from the work and summarise the main conclusions and recommendations arising from it that can be read in a short time to accommodate the schedule of a busy reader. To achieve this, candidates should use the allowed one side of A4 using single-spaced Arial font (size 11) and 2cm print margins. Some candidates provided half page executive summaries which failed to provide the comprehensive content required of findings or a summary of the main conclusions and recommendations. At least one full page is required to do justice to both – main conclusions and main recommendations. Some candidates still try to include more content by reducing the font size, which led to maximum marks not being awarded in some instances. There is a particular need for candidates to demonstrate their ability to write in a concise and persuasive manner when composing their executive summaries. Executive summaries were generally well done, although the highest marks were given to candidates who clearly and concisely gave an overview of the report and its conclusions and recommendations. Exemplary reports included well structured executive summaries, which were very persuasive and would have engaged the intended audience for such summaries – senior managers, directors, etc.
Introduction The introduction provides a foundation for the report and enables the reader to place the following information and judgements in context. Most candidates provided a good or satisfactory introduction, however, some omitted clearly stated aims and objectives and provided limited information on methodology. Properly written aims, objectives and methodology are the key to producing a good assignment. Valuable marks can be obtained in this section by candidates properly outlining what they intend to do and how they are going to do it. For candidates to set the scene Examiners were looking for a description of the chosen workplace/organisation and a brief description of the essential features of the legal environment within which the workplace/organisation operates. There is no need for candidates to spend vast amounts of effort on describing their chosen workplace in minute detail, and there is definitely no need for copious amounts of information on the chosen workplace, its history or its management systems to be included in the appendices. Better submissions kept the general description of the chosen workplace relatively short and concise and relevant to the assignment brief. It is important that working arrangements, work environment, shift patterns and peripatetic worker activities are covered in this section. A brief description of the principal legal (statute, common, civil and criminal) and other requirements within which the organisation operates should be included. Some candidates produced a list of various laws and regulations and only the better answers attempted to apply these legislative requirements to their workplace as required. Candidates are required to demonstrate their knowledge and understanding of relevant statutes, regulations, ACoPs, standards and guidance and outline these in the context of the development of an effective health and safety management programme. An exhaustive list of statutes, regulations etc. was not expected.
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Better submissions showed evidence of candidates putting a lot of thought into developing a clear and concise aim – explaining and justifying the purpose of the report. They also developed a set of meaningful objectives for the report, which could be used throughout the writing / preparation of the report to ‘sense check’ their own progress. Those candidates who then went onto explain their chosen methods, explaining and justifying basic principles as they did so, achieved good marks in this area. Clear statements of what research had been carried out, which models had been chosen and why, were most useful and evident in better reports. Many candidates outlined criminal law issues in the introduction, with some of the better submissions explaining the organisational context and the relevance of such acts and regulations to the chosen organisation’s activities. Those candidates who scored particularly well in this section ensured that they gave time and effort to identifying and explaining the relevant civil cases, giving clear and accurate references to carefully selected case law. Better submissions painted a balanced picture of the criminal and civil organisational context. Better submissions ensured that gaps and areas for improvement from the main body of the report were carried forward into the final part of the report. The conclusions should refer to things identified in the main body, and recommendations should be similarly rooted in things discussed earlier in the report. Recommendations should then be carried forward into the respective action plans, where consideration should also be given to priorities, costs, time scale and how and when progress against the plans would be reviewed.
Review of the Health and Safety Management System Candidates were required to give an overview of the current health and safety management system in their chosen workplace/organisation. Most candidates outlined or described a generic health and safety model (eg. HSG65) without making clear reference to their own management system, and could not therefore be awarded maximum marks. Candidates who did this were generally unable to produce an adequate critical review of the organisation’s health and safety management system. The brief required candidates to compare their current system with a recognised model and provide a clear systematic description of gaps and where no gaps exist, for all areas of the management system, identify priorities for improvement. Reports awarded the highest marks included sections which clearly demonstrated the writer’s understanding of chosen models for health and safety management systems. Better reports outlined the selected model before explaining the relevance of the models’ elements to existing policy, arrangements, etc. A good working knowledge of HSG65 (or a similar model) is essential for those candidates wishing to perform well. The gap analysis section requires candidates to assess their chosen organisation’s health and safety management systems against a recognised model such as HSG65. Better submissions clearly identified shortcomings in the chosen health and safety management systems against such a standard, carrying forward these identified gaps into the recommendations and action plans required later in the report. Better submissions summarised the gaps identified in tabular format, which is a useful technique and allows candidates to display the gaps, required improvements and priorities in a clear and concise manner.
Hazards and Risk Assessments Most candidates managed to outline 15 different hazards or more, a few falling short and only finding 11 – 12 or so. Several had 15 under each category – ‘Physical’ and ‘Health and Welfare’. A number of the candidates were confusing activities (particularly generic references to ‘Working at Height’) with hazards, which limited the hazards that were outlined (and marks awarded) and some failed to discuss the implications. Other candidates clearly took great care to ensure that they clearly differentiated between ‘Physical’ and ‘Health and Welfare’ hazards, using the Unit B and Unit C syllabus content as a way of correctly categorising their hazards.
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Many risk assessments were found to be satisfactory, but some candidates failed to describe their Company’s process and their company’s risk assessment methodology. Risk quantifications models were included without adequate explanation of their meaning / interpretation in relevance. Higher scoring reports were those where candidates demonstrated a clear understanding of the difference between the terms ‘hazard’ and ‘risk’. Better submissions took a methodical approach to breaking down and differentiating between work activities, hazards, risks and possible outcomes. Candidates must be able to demonstrate their understanding of risk assessment principles – they should clearly explain the risk assessment process being used, detailing how any ranking or scoring systems are used for comparison, prioritisation and consideration of improvements required. It is essential that candidates ensure that they select one ‘Physical hazard’ and one ‘Health hazard’ for closer assessment using a recognised risk assessment approach. Some candidates failed to score marks due to the selection of two Physical or two Health hazards rather than one of each. Many candidates adopted an approach to risk assessment based on the HSE’s 5 steps to risk assessment, which may be appropriate in many circumstances, but it cannot be stressed enough that in some situations this approach is not appropriate. The content of the diploma syllabus outlines more detailed and technical approaches to assessing risks that should be considered where an initial appraisal suggests risk may be significant. The classic examples include the failure by some to use specific risk assessment tools for manual handling, noise or hazardous substance assessments. The ‘5 Steps’ approach is not appropriate when carrying out a CoSHH assessment. Those candidates who recognised the requirement to use the correct risk assessment tool for the task in hand, and, as a result, demonstrated the required level of depth, did achieve good scores in this area. When using the ‘5 Steps’ approach candidates must ensure that they place sufficient emphasis and detail when identifying who might be harmed and how, rather than including generic headings of groups of people or stating “staff, contractors and visitors”. Candidates should avoid using their company’s risk assessment templates, without checking them for completeness and adequacy beforehand. Inclusion of risk assessments completed many months prior to the relevant submission date is not acceptable, particularly if there is evidence that such templates were not completed by the candidate. Risk assessments submitted for this assignment should be the candidate’s own original work.
Conclusions Some candidates did not refer back to aims and objectives when writing their conclusions. Many did not include their findings and failed to summarise them, whilst many others included recommendations and other suggestions for improvements in their conclusions. ‘Quality’ checks on the work done should be made including referring back to their aims and objectives and critically appraising their performance against those in their conclusion.
Recommendations and Action Plans Recommendations were generally good, and followed on from main conclusions, but many candidates still fail to provide a comprehensive prioritisation, justification and/or Cost Benefit Analysis to recommendations. Action plans 1 and 2 are on the whole good, with most providing tabulated formats with all the relevant headings considered. Too many still do not include any provisions for review.
Planning and Presentation Although the standard of presentation of many reports was generally fair, some candidates’ reports were ‘let down’ by some simple omissions and mistakes. Candidates should run a spelling check on their reports and ask an independent ‘lay person’ to read the report before submission. In some instances the reports were difficult to read, used too many unnecessary tables or inserted images. The inclusion of scanned copies of handwritten work or flip charts should be avoided. Some reports were poorly formatted, with headers and footers not included – some even failed to include pagination. 7
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It is important to remember that the intended audience for this type of report is senior managers, and, as such, should be clear, concise and well structured. Some reports were far too long with unnecessary or unrelated information included. Tutors should ensure that candidates carry out the required level of planning and preparation for the completion of their assignment reports, and that candidates complete their ‘learning logs’ at relevant points during their studies. Tutrors should provide ‘critical review’ of the work being done by their respective candidates and should ensure that information included in examiner’s reports is brought to the attention of all candidates.
References and Research Bibliography and references still remain poorly produced and many still don’t indicate any evidence of research done. Better submissions made reference to text books and ACoPs/HSE Guidance Notes, clearly citing the details of the reference (full title, ISBN number, date of publication, publisher, etc). Many simply opted to give an extensive list of legislation, which may well have been used from course notes, which should not be considered as a suitable primary source of reference in most cases. There is clear advice on the use of suitable referencing systems in the NEBOSH Guide, and tutors should ensure that all candidates are capable of using a tried and tested referencing convention.
Concluding Examiners’ Comments The information above should give some clear pointers to candidates and tutors regarding the successful completion of Unit D assignments. This information complements other published guidance from NEBOSH. The main points to remember are:
Write the reports in a clear and concise manner Use the mark scheme to help structure reports In the introduction state what is to be done and how Be clear about the differences between activities, hazards and risk Check that at least 15 hazards are identified Check that two ‘highest priority’ hazards are identified Ensure that two selected hazards are not both from the same syllabus unit (B or C) Use the most appropriate risk assessment tool for the two chosen hazards Include information on review periodicity and mechanisms Include cost benefit justifications for recommendations Support main recommendations with a persuasive argument for implementation Check accuracy and clarity of references.
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The National Examination Board in Occupational Safety and Health Dominus Way Meridian Business Park Leicester LE19 1QW telephone +44 (0)116 2634700 fax +44 (0)116 2824000 email
[email protected] www.nebosh.org.uk
