University Safety Policies
University Safety Policy ( update) - November 2011.
A pdf copy of the updated policy, as signed by Dr. M. Murphy, President of University College Cork is contained in the following link.
An overview of how Statutory EU safety law and Common law (duty of care) obligations apply to the University and its management, staff and students is contained in the sections following below.
University Smoking Restrictions Policy
As and from the 29th March 2004, under public health legislation, smoking is prohibited in all University buildings and enclosed workplaces including University vehicles. This applies to all persons.
The limited exceptions as specified in Section 47 of the Public Health Tobacco Regulations (current edition) also operates. Details are available from the Office of Tobacco Control and the Health & Safety Authority.
Note: This policy also covers e-vapour smoking/vaping.
UCC B&E SOP 18 Movement of Vehicles including MEWPS ( Mobile elevating Work Platforms)
As part of an legally binding agreement with the H.S.A relating to an undertaking for lifting a prohibition imposed by the HSA following a fatal accident involving a MEWP at UCC in 2013, the movement of MEWPS and specified categories of large vehicles and trailered vehicles on any / all UCC property/ UCC controlled sites is to be strictly controlled by a Permit to Work in accordance with provisions identical to that contained in B&E SOP 18 for the Movement of Vehicles ( at UCC).
When contractors are crossing any part of the campus that is not securely ring-fenced in advance for their use, then they are on UCC grounds and the UCC work permit scenario does apply.
Activities taking place within UCC subsidiaries, e.g. in the Student Centre, the Mardyke Arena, or Campus Accommodation, are subsidiary responsibilities. However, if subsidiaries or their servce providers are bringing equipment across any University controlled grounds on their behalf, then they need to work closely with Buildings and Estates in relation to the issuing of work permits, etc. A summary of the UCC required system is as follows:
The big emphasis is on advanced and complete Risk Assessment by the supervisor / manager, preplanning all aspects of the the route to and from, pre-planned movement zones, avoidance through use of vehicle mounted hoists as 1st choice as opposed to counter balanced MEWPS (the later have inherent blind spots), segregation/ delivery into a secure site out of hours, still using a banksman/signaller.
Seggregation of pedestrians, and vehicle/MEWP traffic. Signallers to not walk or stand in front of or behind the MEWP at any time
If the MEWP has to be moved then it should be at low tide times ( low footfall) and then from one secure zone to another securely cordoned off zone. Designated Signaller (or 2 signallers depending on risk assessment) to have a RED tabard. Use of radio controlled comms between signaller and MEWP operator/driver, confined to small trained team such as in B&E.
The UCC MEWP training course now has an add on vehicle signaller course.
Emphasis on driver to stop MEWP movement if he ever lose sight of signaller ( signaller should stand away anyway). Back up use of agreed hand signals (per SOP). MEWP driver wear to drive safely and slowly and with optimum vision, wearing all designated PPE including short lanyard attached to the hoist cage ( except when/if working over water). No mobile phones to be used. Pre use checks on the MEWP before use each day.
No driving of or delivery of MEWPS on Public roads external to UCC or between UCC sites.
Other potential vehicle signallers such as UCC ecurity and B&E operative have now separately completed a vehicle signaller course. ( sourced by UCC – delivered by an ex traffic Corp Garda)
MEWP movement and other high risk vehicle movements are to be under the additional control of a permit PTW ( which has inbuilt RA within the UCC PTW form already).
Large Vehicles and trailered vehicles - Enhanced Large Vehicle Safety Measures (Avoidance firstly)
As an additional UCC control, the delivery/movement of other large construction type vehicles or scheduled large vehicle deliveries, are now restricted at UCC AFARP. These are to operate via a UCC Permit to Work from the UCC department involved, with advance route planning for same, where these are controlled by UCC and especially where reversing may be envisaged. The big emphasis is on drive through routing and use of small vehicles.
As a parallel measure, General Services, has encouraged vendors and Procurement to require suppliers to use smaller vehicles for routine deliveries. The access of large vehicles, articulated trucks and high bodied trailered vehicles have been restricted to out of hours and early a.m. times, in areas where reversing may arise. In parallel with this, B&E have introduced removable flexible traffic barriers at the College Road vehicular entrance gate.
Note: The design of some sites such as WGB give more options for drive through routing for larger vehicles that are not available at the Main Campus. ( contact Local Facilities manager).
With the agreement of the NRA, the UCC commuter park and ride bus service no longer enters the Main Campus, eliminating the reversing risks associated AFARP. Open day school buses and tours operate similarly. This does not involve any road crossing for users.
AT UCC/ ON UCC PREMISES.
This responsibility for the foregoing rests with the management of the UCC Functional Area/College/School/ Department, Centre or Unit undertaking the work or engaging the vehicle/service
|Note: A general PTW IS REQUIRED FOR the movement of categories of large vehicles, MEWPS, trailered vehicles and large construction vehicles, forklifts and plant including associated deliveries.|
UCC Permit to work system (Update) - Feb. 2014
An Excel copy of the updated template for use by all Functional Areas\Colleges\Schools\Departments is contained in the following link. This includes both the General permit to Work and subsidiary permits such as Hot Work, Confined Space Entry. There are also B&E/ Facilities specific Working with High Voltage electricity and Fire Detector Masking Permits.
PTW requirements is understood by most discerning organisations as a long standing key facilities management/H&S / and EL& PL & Fire & property insurance liability related control for the variety of risk that contractors involved in physical works can bring to any organisation, our buildings and people and also an appropriate control for high risk work activities involving our own staff or controlled by our staff.
The University permit to work system is a formal written procedure used to control (a) the activities of all contractors undertaking work of a physical nature (with fire \ safety risk potential) and (b) College \ School \ Department \ Centre \ Unit staff engaged in certain type of works i.e. work which is identified as hazardous (high risk) and where special precautions are necessary to control these hazards. It should be used for all, contractor activities and for University employees, who may be involved in hazardous high risk work situations (whether routine or non-routine or primarily of a non-routine nature).
To summarise the UCC required system is as follows
1) A general PTW IS REQURIED at UCC FOR ALL CONTRACTORS UNDERTAKING PHYSICAL WORK AT UCC/ ON UCC PREMISES.
This responsibility rests with the management of the engaging UCC Functional Area/College/School/ Department, Centre or Unit.
The PTW is a means of regulating their entry and presence in a pre-agreed fashion/area to execute an agreed tasks in an area which is legally controlled by UCC ( not legally transferred to the contractor). The movement of MEWPS and specified categories of large vehicles and trailered vehicles on any / all UCC property/ UCC controlled sites is to be strictly controlled by a Permit to Work.
This PTW should only be signed off when the contractor fills in sufficient detail on our permit form to identify to us the risks they are bringing to UCC and only signed off/ UCC approved when we are happy with the UCC relevant impacts of the when and how of the job and we buy in to the timing and method of access and impacts on our premises and operations and people. Also how they satisfy insurance cover requirements plus our minimum risk control and H&S standards + will also meet SHWW law – contractors can have variable standards).
|2)A general PTW IS RQUIRED at UCC FOR HIGH RISK WORK ACTIVITIES INVOLVING UCC STAFF|
PTW issued for hazardous/high risk works undertaken directly by UCC staff , (whether routine or non-routine work) is also a long standing H&S requirement of the UCC Dept. Safety Statement work manual and long standing liability loss control mechanism in industry - particularly process industries.
All routine and non-routine high risk work undertaken by College \ School \ Department \ Centre \ Units or by Buildings and Estates direct staff/labour and /, shall be controlled by a permit to work issued and controlled by the relevant management ( duty holders for the work of their staff) following RA and application of appropriate risk controls to mitigate the risk and or reduced the exposed population.
|3)A general PTW IS RQUIRED FOR the movement of categories of large vehicles, MEWPS, trailered vehicles and large construction vehicles and plant including associated deliveries.|
As part of an agreement with the H.S.A relating to an undertaking for lifting a prohibition imposed by the HSA following a fatal accident involving a MEWP at UCC, The movement of MEWPS and specified categories of large vehicles and trailered vehicles on any / all UCC property/ UCC controlled sites is to be strictly controlled by a Permit to Work in accordance with provisions identical to that contained in B&E SOP 18 for the Movement of Vehicles ( at UCC).
When contractors are crossing any part of the campus that is not ring-fenced for their use, then they are on UCC premises and work permit scenario does apply.
Activities taking place within UCC subsidiaries, e.g. in the Student Centre, the Mardyke Arena, or Campus Accommodation, are subsidiary responsibilities. However, if subsidiaries are bringing equipment across any University grounds then they need to work closely with Buildings and Estates in relation to the issuing of work permits, etc.
4) At UCC subsidiary permits are required for activities such as:
Hot Work, and Confined Space Entry. There are also B&E/ Facilities specific Working with High Voltage electricity and Fire Detector Masking Permits
Irish/EU OHS & Civil law - We all have responsibilities!
Irish/EU Occupational H&S law (SHWW law), relates only to employed persons. This law applies to the work activities of UCC staff* (both f/t and p/t) at their place of work, both on Campus and off Campus. Occ. H&S duties arises for UCC and its executive management, w.r.t. staff research & teaching; in the upkeep of equipment, premises and grounds and in the use, by employees, of work equipment, plant and facilities.
Note*: U/G and P/G Students undergoing a course of study at UCC are not deemed to be employees of UCC, under SHWW law. [Reg 2(5) SHWW Act 2005) as far as their registered course of study and related supervisory experience activites are concerned. Separate common law duties apply to students and third parties. (see Common Law Context & UCC)
Irish Statutory Safety Law (Employment Law) : Under the provisions of Irish SHWW law, the 'controlling minds' of the University, e.g the UMT and each executive manager, who decide policy, control budgets/ resources, staff activities or otherwise control the delivery of services, at a Functional Area or at a School/Department level throughout the University, are responsible, in so far as is reasonably practicable (AFARP), for the occ. h&s of the employees under their control. (This includes compliance with the provision of all aspects of SHWW law that is relevant to the work activites and places of work under their control). Managers must make practical and financial provision for the relevant and appropriate training of p/t staff such as interns andstudent help within departmental budgets for the recruitement / engagement of p/t staff.
All employees (including managers), also have legal duties to co-operate with and generally assist their employer in complying with the requirements of SHWW law.
The obligations/duties under SHWW Law, (employment law) , whilst overlapping with the general obligations of common law (see below), apply only in the context of the work of employees, as conducted at their places of work.
Footnote: Breaches of statutory (SHWW) law can give rise to the prosecution of individual mangers/employees as well as the body corporate. (Assessment of risk and implementation of required controls/safety guidance and training is the best way to protect everyone).
The above is separate to the University's common law obligations, for further information please see Common Law Context & UCC below.
Common Law duties are separate to statutory (SHWW law) duties . Common law principles derive from the English & Irish legal system and determinations by Judges in civil law cases for compensation. ( This is in contrast to statutory SHWW law which enacts Irish/Eu social partnership legislation in order to PRO-ACTIVELY protect workers and the community at large).
In accordance with common law principles, UCC as a provider of educational/ research services and as an owner of substantial premises/ facilities, has separate general 'duty of care' obligations, (e.g. common law duties), to discharge to all persons who work or study at UCC, or who visit UCC. This is discharged by all UCC managers, lecturers and other staff delivering services.
(Common law duties apply to the provision, AFARP, of safe places, safe equipment and safe systems, competent persons & adequate supervision. Foreseeability is also a factor).
Footnote: Determination of any breach of common law safety duties only arise where an injury /illness compensation case is taken via the national PIAB system/the Courts. (As UCC is responsible for its employees and the manner in which they discharge their duties, UCC rather than individual employees would generally be the entity sued by 3rd parties in relation to any work accidents at UCC).