A New Series on Health and Safety in Design

By Paddy MacNeill, B.Arch, FRIAI, CMIOSH

Risk Assessment For Designers
Regulation 15 (SHWW Construction (SHWW Construction Regulations 2006) requires designers, when carrying out work related to the design of buildings, to “take account of the Principles of Prevention”. Designers must therefore recognise the significance of the Principles of Prevention.

The Principles of Prevention is a hierarchical approach to the prevention of accident and ill health in the workplace and is found in Schedule 3 of the SHWW  Construction Act 2005. The hierarchy outlines and emphasises the priority of integrated safety systems or collective protective measures over personal protective measures in relation to risk management. Designers are obliged to apply the Principles of Prevention hierarchically – that is from the top down. Thus integrated / collective protective measures must be applied in favour of personal protective measures as far as is reasonably practicable.

When preparing a design, designers must eliminate hazards and reduce risks taking account of the Principles of Prevention (POP). This is what’s known as Risk Assessment and involves:

• Identifying hazards
• Eliminating hazards where possible
• Assessing the risk from remaining hazards
• Implementing a design intervention (control) to mitigate the risk to an acceptable / manageable level
• Identifying Residual, Particular and other Significant risks
• Identifying who will be affected by these risks
• Providing information on these risks to the relevant affected persons

The acceptable and manageable level to which risks must be reduced is that level at which a competent contractor can foresee and manage those risks on the construction site. When hazards cannot be eliminated or where risks cannot be reduced to an acceptable and manageable level, the resultant is known as a residual risk. When residual (or Significant / Particular) risks remain, it is necessary to provide information on these risks to those who will be affected so that the necessary controls can be put in place to ensure for their protection. Information on these risks is usually given via Preliminary Safety Plan and via the Safety File if the risks still remain after construction.

What Hazards and Risks are designers responsible for?
Eliminating hazards or reducing risks to an acceptable / manageable level is the key requirement – at this level it is expected that a competent contractor will have the means of safely managing the construction works. In simple terms, management of the construction site for the foreseeable and normally anticipated range of risks expected – albeit some of these of high level – is the contractor’s sole responsibility. It is not therefore required of the designer to assess all foreseeable risks expected on a construction site. 

Designers must, on the other hand, assess Significant / Particular risks, those risks which may not be readily foreseeable to the contractor and those risks aggravated by the brief or by the design. These might include but are not limited to:

• Particular Risks – Schedule 1 of the SHWW (Construction) Regulations 2006.
• Significant Risks – Non-standard risks or particularly difficult construction processes, working near traffic
• Site hazards – Particular ground conditions, water table levels, utility services, contamination
• Risks aggravated by the Design – Unstable structures, fragile roofs
• Risks aggravated by the Brief – Working in an occupied premises, time constraints, access constraints

Hazard Elimination and Risk Reduction
Hazards should be eliminated and risks reduced by the following measures in descending order of effectiveness:

• Elimination – remove the hazard / risk at source – Eg. Isolate / relocate underground services, relocate the building away from contamination
• Substitution – substitute with a lower risk activity / process- Eg. Fabricate at ground level and lift rather than fix components at height
• Isolation- isolate people from the hazard / risk- Eg. Specify low maintenance materials; locate plant at low level rather than at roof level
• Engineering controls- use of technical solutions to protect people from the hazard / risk- Eg. Use of mechanical lifting equipment in lieu of manual handling
• Systems of work-incorporate systems of work that protect people from the hazard / risk- use of pre-cast components rather than complicated in situ masonry
• Personal Protective equipment – last and weakest line of defence since it relies on human behaviour in a generally poorly controlled industry. Should only be used as a last resort in conjunction with the provision of training and information for operatives or where the risk is relatively low

It must always be remembered, however, that hazards don’t happen in isolation or in sequence and that many hazards interact with others and with those of other disciplines – a compelling argument for collective design team assessments! One must also consider other outside variable influences, such as weather and work sequencing.

Keeping of records
Designers should be aware of Section 81 of the SHWW Act 2005, which places the onus of proof on the accused to demonstrate how he / she satisfied the duty or the requirement in the event of legal proceedings under the Act. Records of assessments must be transparent, auditable and maintained. It must however always be remembered that too much paperwork is as bad as too little – the useless hides the important. The aim must always be to produce relevant information that is proportionate to the project and its risks and hence of maximum benefit to the other duty holders.

Article as seen in Architecture Ireland issue 252

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AI Team