Health & Safety Policy

Statement of Intent

The Managing Director of Pagoda Security Training limited, Mr Lee Craig recognises and accepts the responsibilities as an employer, and will conduct the Company’s affairs in such a way that the Health and Safety of Employees, and others who may be affected by the operations of the Company will not, so far as is reasonably practicable, be put at risk.

PS will make every endeavour to meet their legal obligations under the Health and Safety at Work Act 1974 and any other relevant legislation. It will ensure, insofar, as is reasonably practicable, that all their responsibilities are met by paying continuous attention to all aspects of health and safety at work. They will, so far as is reasonably practicable, take action to:

  • Promote the effectiveness of this policy & define areas of responsibility for health and safety
  • Provide adequate and appropriate training for all levels of management and employee.
  • Extend the protection of this policy to employees engaged in external activities, and to those persons who are not employees but are attending any premise under the control of the Company.
  • Provide the necessary resources to enable this policy to be carried out effectively and comply with current health & safety legislation and or regulations.
  • Ensure safe conditions of work are provided, without detracting from the primary responsibility of managers and supervisors.
  • Take all reasonably practicable steps to provide competent technical advice on health and safety matters where this is necessary to assist managers and supervisors.
  • Fully co-operate with clients, contractors, and any other person to achieve and maintain healthy and safe workplaces

Lee Craig,
Managing Director
7 April 2022

1. Responsibilities & Duties

1.1 The Company

Pagoda Security Training limited provides a range of security services under contract to clients. Throughout this document “PS” means Pagoda Security Training Ltd. Below is set out the Health & Safety responsibilities within PS.

1.2 The Managing Director

The Managing Director has the overall responsibility to provide safe working environments, procedures, management systems, advice and training for all employees.

To ensure the effective implementation of this policy, he will ensure:

  • Periodic appraisal of the policy; annual review of risk assessments; a summary of accidents reported; Health & Safety training matters and any other relevant issues, by way of standing item at regular Management meetings. The minutes covering these areas will be retained in the Health & Safety File
  • There is an effective health and safety management system, including appropriate and adequate risk assessments and working procedures provided for all aspects, as far as is reasonably practicable, of the Company’s operations.
  • Provision of adequate facilities to meet health and safety requirements, including liaison with clients to facilitate shared welfare and emergency arrangements, including:
    • Any known hazard that may affect the service or health of employees,
    • The location of asbestos, welfare, first aid fire information and facilities.
  • Provision of effective and appropriate training for all employees, including new entrants.
  •  That due regard is paid to health and safety in the procurement and use of materials, vehicles, personal protective equipment, equipment and substances/chemicals.
  • Ensure that all work equipment hired or purchased (including personal protective equipment (PPE) and uniforms) is suitable and appropriate for the purpose for which it is to be used.
  • Ensure that safety advice and information is understood, so far as is reasonably practicable, and acted upon.
  • Managers and supervisors are trained to understand their responsibilities to manage the staff under their control.
  • Act as focal point for compliance with the duties and requirements for the operation of the Company, including liaison with the enforcement authorities.
  • Ensure all duty holders under the control of the Company are competent and aware of their responsibilities and duties.
1.3 Health & Safety Manager

To assist the Managing Director, a ‘competent person’ will be appointed as the Health & Safety Manager, who will undertake the following:

  • Ensure the effective implementation and management of the Company’s Health & Safety Policy in the provision of safe working environments, procedures, management systems, advice and training for all employees, as set out in section 1.2 above.
  • For the purposes of Regulation 7, Management of Health and Safety at Work Regulations 1999, undertake the role of ‘Competent Person’ for the Company, and:
    • Keep up-to-date files of all information appertaining to this policy and their duties, which will be freely accessible to all managers and employees.
    • Distribute, as appropriate, any information or guidance to supervisors and or employees as appropriate.
    • Conduct a sample of site Health & Safety audits annually.
    • Ensure training details are recorded on personal files, including information of; dates, description of training/competency audits, instructor/trainer details and retraining/further competency audit dates.
1.4 Contract or Operations Managers

The Contracts Managers will manage those employees under their control and ensure appropriate and effective liaison with site management, in their role of maintaining safe environments on site they will be required to:

  • Prepare, agree and issue documentation for the effective management of all sites under their control, ensuring they are up to date & sufficient, including:o Site surveys,
    • Assignment instructions,
    • Health & Safety risk assessments.
  • Supervise staff to ensure they are operationally competent.
  • Liaise directly with the client site management, to ensure employees comply with their health & safety policy or risk assessment, and formally document any local agreements.
  • Ensure employees are:
    • Made aware of surveys, instructions & risk assessment control measures and working arrangements agreed with the client, including any local hazards or problems associated with the contract site.
    • SIA trained (as a first step to operational competence); have received an on-site induction and are fully aware of and understand the site specific Assignment Instructions (AI’s) and all relevant risk assessments & have signed the AI’s to this effect.
    • Advised of their responsibilities and functions in regard to accident reporting, and site first aid, welfare, fire precautions or local agreements, and complete documentation effectively to enable the client to achieve their legal and licence requirements.
    • Trained in the operation of equipment and or tools, and that site safety, surveillance, communication and monitoring equipment is operational, fully functioning and appropriate to the service provided.
    • Wear and maintain uniforms and or personal protective equipment in good condition.
    • Instructed to maintain all clients’ equipment, welfare facilities and arrangements provided for their health safety clean and in good condition.
  • Investigate any incident involving employees and liaise with the client to prevent recurrence, compile appropriate records/reports and advise the Health & Safety Manager.
  • Ensure all vehicles are roadworthy and that drivers are appropriately trained with current licences.
1.5 Supervisors

Where appointed supervisors are required to manage those employees under their control in a manner that encourages safe working, they will:

  • Assist the Contracts Managers to undertake risk assessment, investigate accidents, liaise with clients’ management and maintain high professional and personal standards of health and safety.
  • Take appropriate action to maintain the health & safety and security arrangements at their site and advise the Managers as soon as is practicable.
  • Ensure all employees undertake their duties in a professional and safe manner, complying with all local rules and agreements.
1.6 Employees

All Employees have the responsibility to ensure they undertake their duties, with due regard to their own Health and Safety, their colleagues and those affected by their actions. They are required to: –

  • Wear and maintain uniforms and or personal protective equipment in good condition.
  • Make themselves familiar with, and conform to, all relevant safety instructions and agreements.
  • Co-operate with their manager or supervisor by observing instructions and or advice on health, safety and security matters.
  • Immediately report to their supervisor any health & safety concerns, situations that provide a hazard, and or any medical condition caused by work activities (hearing, sight, and or physical disability, however minor).
  • Wear approved personal protective equipment and uniforms and wear their SIA badge at all times when on Company business (with the exception of ‘Non-frontline activities’).
  • Never interfere with, or misuse anything provided in the interests of health, safety and welfare.
  • Report any incidents, however minor, that have led to or may lead to injury or damage, and assist with any investigation.
  • Maintain any facility or equipment provided for their well being, health & safety or for the security service including personal protective clothing/uniforms in good condition, and report any defects.
1.7 Business Support Manager

As part of their duties, the Business Support Manager will undertake the following:

  • Ensure health, safety and fire risk assessments are undertaken for all office based activities, and employees/managers are advised accordingly.
  • Receive all incident information relating to accidents, collate details and provide appropriate statistics, and advise the enforcement authorities as required by the Reporting of Injuries and Dangerous Occurrence Regulations 1995.
  • Ensure all PPE and Uniforms are purchased, available and that they conform to current British or European standards.
  • Arrange for all vehicles to be maintained, serviced, MOT tested, and insured.
  • Ensure annual checks /inspections of driver licensing are carried out, to ensure they are valid and current.
  • Ensure sub-contractors details are recorded.

2. Organisation & Arrangements

2.1 Disciplinary Procedure

Any Employee, and or person working on behalf of the Company, irrespective of position, who interferes with or misuses anything provided in the interests of health, safety and welfare, or fails to comply with this policy in any way, will be subject to disciplinary action.

Such offences may be regarded as gross misconduct and may lead to dismissal, and or termination of contract.

2.2 Health& Safety Management – Risk Assessment

These are one of the most important elements of health and safety, forming the basis of safe systems of work, control measures arising from them must be built into Assignment Instructions. It is a requirement of The Management of Health and Safety at Work Regulations 1999 that employers make a written record of risk assessments for all significant risks, in addition to the process below, this will be monitored by the Health and Safety Manager and where appropriate reported back to the monthly Management Meeting for action.

The Health & Safety Manager will draft standard risk assessments for approval by the Managing Director. Once approved, they will be incorporated into AI’s and issued to any new staff as a part of their induction procedure. Any significant changes will be brought to the attention of all relevant employees.

All new sites and functions will have an initial site survey provided by the Contracts Manager or Managing Director. This will be will detail (i) The nature of the site/role; (ii) The specific functions to be performed; (iii) A site survey noting any hazards, together with suggested control measures; (iv) Details of whether First Aid provision, Fire Policy and welfare provision are adequate; (v) The reason our services are required, e.g. if it is a new function what has caused the request, or if we are taking over from another provider, why is this being discontinued. A copy of the client’s Health and Safety Policy, Risk Assessments, accident reporting procedures, Public liability Insurance Certificate must be obtained to be retained on file. On completing this form, consideration must be given as to whether the standard risk assessments are sufficient, in which case the person completing the form can sign off the AI’s & risk assessments, or an addition or variation needs to be conducted, in conjunction with the Health & Safety Manager (which must be completed before services are provided).

The Contracts Manager together with the Health & Safety Manager will conduct an annual desktop review of existing sites/AI’s to ensure the risk assessments are appropriate. A note of this review will be added to client files & a record of the overall procedure kept in the Health & Safety file.

A copy of all relevant risk assessments and Assignment Instructions must be given to the client and a copy of these, signed by the client to be kept in the site file. If an employee has a concern over the suitability of control measures, this should be raised via their line manager, who if unable to reassure the employee will pass the matter on to the Health and Safety Manager, who may in turn refer to the Managing Director if appropriate.

2.3 Training and SIA Information

All employees will be trained by PS and or be required to provide proof of previous training to ensure they are competent to undertake their duties. As a minimum, operations staff must be SIA licensed.

All employees will undergo a Company Induction Training, followed by on Site Induction Training. Annual refresher training on company health & safety policy, procedures and risk assessments will be given.

2.4 Consultation

The Managing Director in association with the Health and Safety Manager and Contracts Managers will consult with employees directly, over any change or alteration to working conditions or practices. All comments received from employees or supervisors will be formally recorded and considered at the monthly Management Meeting.

2.5 Sub-contractors Policy

Any sub-contractor employed to undertake work, provide services, or goods will be required, within the contract document to operate to standards of safety, not less than those set out in this policy.

They will be required to supply copies of their:

  • Company’s Health and Safety Policy (or Statement of Intent if they employ less than 5 persons).
  • Safe working procedures and appropriate risk assessment documentation (if they employ more than 5 persons).
  • Details of Insurance.
  • Competency/work references

No contractor will be permitted to work on behalf of the Company until these checks have been undertaken.

Any member of staff observing contractors placing persons at risk of injury must notify their Operations Manager or Supervisor immediately, to enable action to be taken.

2.6 Company Health & Safety Policies
2.6.1 Accident& Incident Reporting

Any accident or incident involving PS staff, whereby someone is or could have been injured must be recorded in the PS Accident Book, wherever it takes place (even if reported in a client’s Accident Book). Following a reported accident/incident the staff responsible for actions are:

  • Ensuring it is recorded – Contracts Managers
  • Investigating and taking remedial action to prevent recurrence – Contracts Managers for minor instances & Contracts Managers with the Health and Safety Manager for more serious matters. The Health and Safety Manager is responsible for ensuring the adequacy of these actions.
  • Risk management documents reviewed or revised – Health & Safety Manager
  • The monthly Management Meeting is advised accordingly – Health & Safety Manager

The Health & Safety Manager will record/provide incident statistics and where necessary, ensure incidents are reported to the Health and Safety Executive as required by the Reporting of Injuries, Disease and Dangerous Occurrence Regulations 2013 (RIDDOR). Any incident occurring on sites under the control of another employer must be formally reported to that person.

2.6.2 First Aid

PS will provide a first aid risk assessment in accordance with the Health & Safety (First Aid) Regulations 1981 and ensure that first aid boxes are available within:

  • PS vehicles, (It will be the responsibility of all drivers to maintain first aid boxes fully stocked, at all times.)
  • Offices; The Business Support Manager will undertake the role of the appointed person will maintain a first aid box fully stocked & available, at all times
  • Sites; The client will be requested to provide first aid cover for all Company employees, with details provided for those persons working at the site
2.6.3 Welfare

In PS controlled locations the Company will ensure, as a minimum, appropriate welfare facilities are provided as required by the Workplace (Health & Safety at Work Regulations and Construction (Health, Safety and Welfare) Regulations 1996. In those sites under the control of another employer, agreement will be made with them for the shared use of welfare facilities. Details of these facilities are sought during the initial site survey and included in the AI’s.

2.6.4 Personal Protective Equipment (PPE)

The Company will provide appropriate, adequate and comfortable PPE and uniforms and ensure it is worn by all employees whilst on Company duties where a risk assessment concludes that this is necessary. It will be purchased in accordance with the Personal Protective Equipment Regulations 1992, and conform to the “CE” mark or British Standard.

The provision of PPE will be dictated by the hierarchy of control measures and risk assessment. All staff will ensure they are in possession of the correct complement of PPE and a record of signature is placed on the personnel file and kept at PS Head Offices.

PS will also maintain a policy in relation to other equipment that although not PPE, may in certain circumstances be beneficial or reduce risks to its employees or members of the public, e.g. stab-proof vests or handcuffs.

2.6.5 Working at Height

PS employees will not generally be permitted/required to work at height. If a requirement is identified, a site/role specific risk assessment will be conducted and appropriate training provided. All training must be carried out by a competent manager and all training records are to be placed on the employee’s personnel file at PS Head Offices.

2.6.6 Electrical Safety

PS will conduct Portable Appliance Testing on all relevant equipment over two years of age & repeat this process every year. Labels will be attached to each item tested by the competent person appointed to do this.

2.6.7 Chemicals and Substances

All substances and or chemicals used by the Company should be safe and not dangerous (as specified within the Control of Substances Hazardous to Health Regulations 2002). If this aim cannot be achieved, the Health & Safety Manager will obtain the chemical or substances technical data sheet (TDS), which will be used to advise employees on the storage, use, and safe handling, etc.

Any necessary work with new materials or substances rated as hazardous will not commence until the necessary information has been obtained or the material has been analysed, and an assessment made of the risks involved in the operation. Where appropriate, clients and others likely to be affected by the work will be provided with a copy of the TDS/assessment and its significant findings, together with details of the method of work.

2.6.8 Fire Safety

PS will ensure that all premises and sites under the control of the Company are assessed in accordance with the requirements of the Fire Regulatory Reform (Fire Safety) Order 2004, and the Construction Regulations.

This will include the provision of:

  • Written emergency evacuation procedure that is practised by staff at regular intervals
  • Adequate means of escape in the event of a fire
  • Ensuring that escape routes are kept clear
  • Induction training in fire prevention and escape procedures for new staff
  • Installation and maintenance of ‘early warning’ fire detection equipment
  • Provision of appropriate extinguishers/fire blankets and the like if required
  • Existing escape routes and emergency vehicle access routes will be identified and safeguarded, etc.
2.6.9 Manual Handling Operations

PS’s primary objective is to avoid manual handling that will cause harm, where reasonably practicable, and to provide appropriate advice, training and guidance to all employees. Where operations contain a specific hazard to health associated with lifting and carrying, it will be subjected to a specific risk assessment.

It is recognised that the nature of work undertaken by PS is such that occasionally it may be necessary to physically restrain or detain a person. All staff are trained in Conflict Management as part of their licence linked training, this should reduce the frequency of these instances. Door Supervisors are now all required to undergo ‘Physical Intervention Training for the Security Industry’ which takes into account the ‘manual handling’ elements of such interventions.

2.6.10 Lone Working Procedures

PS recognises that by the nature of security operations employees may be required to work alone (company definition – where the person has no site contact with any other employee and or client’s employee). These circumstances are considered hazardous in consequence telephonic/physical contact will be made with their Operations Manager or Supervisor at:

  • Commencement of the working day,
  • End of the working day, and or when leaving their workplace to return directly home’
  • Or, as appropriate to the service provided as set out in the Assignment Instructions.

All details of ‘lone working control’ will be specified within the site survey and agreed with both client and employees concerned.

2.6.11 Visual Display Units

In accordance with the Health & Safety (Display Screen Equipment) Regulations 1992, all members of staff who continually use a DSE for more than two consecutive hours, and or it is an essential aspect of their work performance that they use a DSE then they will be designated a ‘User’.

All designated users will be:

  • Given assistance with eye tests.
  • Given assistance to purchase workplace spectacles.
  • Required to undertake a workplace risk assessment at least once every two years. A record of this will be kept in the person’s HR file.

Risk assessments will be completed by the ‘user’ using a simple guide /checklist, on completion it must be forwarded to ‘users’ direct line manager who will be required to ensure all appropriate control measures are satisfied.

2.6.12 Violence Towards Staff

All staff engaged in such a role where violence and aggression may be present must have been trained in conflict management and be current with their physical intervention skills. The relevant SIA license must be current and all training up to date for frontline duties.

Staff are advised not to engage in physical intervention or contact with customers or the public unless necessary. Any such action must be reasonable, justified and proportionate in the circumstances.

Before engaging to either conduct your lawful duty or to defend yourself, where possible ensure that a colleague, manager, mobile support unit or police have been called and notified as to the situation developing so that additional resources can be deployed to assist.

Single, unaccompanied (by other staff or Police) staff are not to enter insecure sites or buildings for the purpose of looking for intruders. The principle of this operation is to observe and report.

For further information and control measures please refer to our Risk Assessments – PS724 v2 2020-04.

2.6.13 Training

PS may provide training courses to its staff, clients and members of the public. The lead trainer is required to conduct a general risk assessment to ensure that the premises are suitable and safe for all concerned. Where the course content requires a more detailed risk assessment, e.g. Physical Intervention Training or Handcuffing, a course-specific risk assessment will be conducted and a written copy kept in the training file.

Compiled by: Simon Errey
Business Support Manager
7 April 2022

Agreed by: Lee Craig,
Managing Director
7 April 2022

This Policy was first issued in August 2015, it was reviewed, and became effective as version 3 on 20th July 2020.

Appendix 1 Training Needs Analysis

The following is a guide to the minimum standards of evidenced training in relation to Health & Safety. Where the member(s) of staff do not meet these criteria, they should be actively working towards this and encouraged to achieve this by PS.

Managing Director – HABC Level 3 Award in H&S in the Workplace

Health & Safety Manager – The IOSH Managing Safely Qualification

Contracts Managers – A Level 3 Health & Safety Qualification

Supervisors – A Level 2 Health & Safety Qualification

All staff – Contents of SIA Licence linked Award, company and site induction.

First Aid, Any person required to be first aid trained due to first aid risk assessment or other requirements – minimum of Emergency First Aid at Work (QCF).