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OHST 88-2023-A5 UNIAC Audit Report UoM - Health and Safety 2022-23 Final IA Report 10.07.14
OHST 88-2023-A5 UNIAC Audit Report UoM - Health and Safety 2022-23 Final IA Report 10.07.14
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1.2 Conclusion
Whilst the return to pre-Covid levels of health and safety related events was the underpinning rationale for this audit, it is clear that it is a multi-factorial issue.
In the process of analysing the possible contributory factors, we have reviewed health and safety structures and governance arrangements to identify gaps and
control weaknesses that may be contributing to increased levels of health and safety related events. In addition to our review of documentary evidence and audit
sample testing, we have considered qualitative feedback from staff. During the audit fieldwork we met with a total of 39 staff from across the University in a
variety of roles, including dedicated Health and Safety staff, technical staff, academics and PIs. We have triangulated all of the information gathered to identify
common themes which we have incorporated into the audit findings.
We conclude with limited assurance on the overall management of health and safety related risks. We have raised high risk findings in relation to the clarity of
roles and responsibilities for health and safety management and in relation to the management, recording and monitoring of mandatory health and safety
training to ensure that the University is meeting its statutory requirements. As the University operates a devolved structure for health and safety management,
there is a high degree of variation across faculties and departments. We have identified areas of good practice where controls are well designed, however there
are also some areas where improvements to the control framework are required. Specifically, level one lines of defence could be strengthened by ensuring that;
where possible, local arrangements are aligned with the organisational health and safety arrangements, that roles, responsibilities and accountability for health
and safety management are clear and well understood, that there is appropriate representation at local Health and Safety Committees and that there are
adequate controls in place to measure and report on health and safety staff training and competencies. Level two lines of defence could be strengthened by
enhancing the schedule of Central Safety Services inspections and more robust action tracking in relation to the follow-up of inspection recommendations.
There are opportunities to improve process efficiency and reduce duplication of effort for example, by implementing mechanisms to support cross-faculty
collaboration and joint-working. The University should also consider strengthening the third line of defence by considering where further external assurances
can be sought.
The University Health and Safety Policy and organisational arrangements set the framework for health and safety management across the University. We have
observed elements of deviation from the organisational arrangements in terms of job titles, job descriptions and line management for health and safety staff.
With the devolved arrangements for health and safety management, there is a risk that local health and safety arrangements may deviate further from the
organisational arrangements. The advent of Covid and hybrid working have also amplified the weaknesses in the health and safety management control
environment in terms of roles and responsibility and ownership. Furthermore, this audit has been conducted at a time when the University has experienced
significant organisational change. Continuity is an issue, with an unprecedented level of senior management changes across the University, voluntary
redundancy resulting in the loss of experienced staff and restructures of faculties, health and safety teams and technical staff. In the FSE, the moves connected
to MECD have also brought about significant changes in processes and ways of working. These changes have impacted on staff capacity, specialist knowledge
and the clarity of roles and responsibilities for health and safety.
There is an established governance framework in place to ensure health and safety management across faculties, schools and departments. The University
HSWC is supported and represented by a number of specialist Advisory Groups; Occupational Health, Safety and Training Advisory Group (OHSTAG), Radiation
Safety Advisory Group, Rose Safety, Environment and Security Committee, Fire Safety Advisory Group, Genetic Modification and Biohazards Safety Advisory Group,
Safeguarding Advisory Group, Resilience Advisory Group and Mental Health and Well-Being Advisory Group.
1. Roles, Responsibilities and Accountability. There is a need to improve the clarity of roles and responsibilities for health and safety management and
for improved accountability for academic staff. In some areas there has been a slight deviation from the University Health and Safety arrangements and
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a historical lack of two-way dialogue between the Compliance and Risk Directorate and faculties with regards to restructures, job descriptions and job
titles for health and safety staff. Staff feedback suggests that recent internal reviews of health and safety staff and technical staff have led to a lack of
clarity of roles and responsibilities. Staff feedback indicates that it is a challenge to ensure ownership and accountability of staff in health and safety
management roles. See finding 2.
2. Health and Safety Training. There is a need to clarify where health and safety training sits in terms of management and co-ordination, and to improve
the recording and reporting of mandatory and statutory health and safety training to ensure that the University is meeting its statutory requirements.
There is a gap in terms of the provision of specific line manager training in health and safety management and for a formal approach to identifying
training needs. See finding 6.
We also raise moderate findings in relation to health and safety governance and data recording and reporting, and one further low risk finding in relation to
Communication, Collaboration and Sharing Best Practice and Lessons Learned.
During fieldwork, concerns were raised regarding specialist RSU support, however, we did not meet with anyone from the Unit. Management advised that the
University is currently recruiting to two posts in RSU to increase the capacity and competence of the team. In order to provide a greater level of assurance around
radiation safety, the Director of Compliance and Risk requested UKHSA to do a third line audit of radiation safety compliance, which concluded that appropriate
arrangements were in place. The UKHSA action plan is being monitored through the Radiation Safety Advisory Group and reported to the University Health, Safety
and Wellbeing Committee (HSW). Assurance has also been sought for Uniac to review this more widely with an audit of the Carriage of Dangerous Goods
included in the 23-24 audit plan.
+ Monitoring Reports - School monitoring reports are reported quarterly to the Faculty Health and Safety Committees. Faculty Monitoring Reports are produced
annually and contain the Faculty Health & Safety Risk Profile and Risk Control Strategies. These annual Health and Safety Monitoring Reports are reported to the
Occupational Health, Safety and Training Advisory Group (OHSTAG) which reports to the University Health, Safety and Wellbeing Committee.
+ Reporting to Leadership Team Meetings – There is reporting of issues from School Health and Safety Committees into School Leadership Team Meetings.
+ Oversight of Risk Assessments – In the FSE and FoH, they are currently developing an online risk assessment approval process in SharePoint. The Risk
Assessment is uploaded and the supervisor approves and it thereafter goes to the safety team for verification. Whilst it is recognised that there will be a need for
some risk assessments to be more dynamic in nature, this is good practice in terms of consistency of review, oversight and for generating a central repository of
risk assessments.
Appendix A provides the risks and controls assessed within the scope of the review and Appendix C highlights findings by key assurance areas. During the
course of this audit, some health and safety related concerns have arisen that sit slightly outwith the audit scope. As we deem these issues to be potential risks
to the University, we have collated them into a separate appendix (Appendix E) for management. To help inform this audit, we contacted five Russel Group
universities to participate in benchmarking in relation to health and safety. Where relevant have weaved the benchmarking information into this report.
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2. Key Findings The findings from our review are below, see Appendix C for our Finding Grading Definitions.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
staff who are on site five days per week. Feedback also suggests
that prior to Covid, many academic supervisors were often off-
site due to work related travel and meetings. Academic
supervisors delegate supervisory duties to PHD students and
PDRA’s. During Covid there was reduced exposure to practical lab
work, meaning that the PHD students who are
training/supervising undergraduate students, are now less
experienced than they would have been pre-Covid. There are
pockets where the risk is higher and there is no formal
consistent approach for the delegation of supervisory duties to
ensure those being delegated to are clear on their roles and
responsibilities and are suitably competent. See proposed action
1.1.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
therefore it is crucial that appropriate support is provided to 1.3 The FSE should consider providing Central Faculty
ensure that health and safety requirements are clear and additional health and safety training Professional Level
understood. We were also advised that there are more students for students in monocultural labs Services
with non-chemistry first degrees doing PHDs in Chemistry and and for Chemistry students with
these students may not have had the same level of practical lab non-chemistry degrees and test their
exposure as students who have first degrees in Chemistry. See understanding of health and safety
proposed action 1.3. requirements. Owner: Chemistry Head of
Department
There has been a long term shift in practice towards the use of Date: April 2024
multi-disciplinary shared laboratories and workspaces. This has
been a gradual evolution which has led to a dilution and
deterioration of supervision in these environments which has
been amplified by the recent round of voluntary redundancy,
restructures and hybrid working. From our discussions with
staff, in some areas there appears to be a perception that
technical staff should take responsibility for shared lab areas. In
Engineering where there are the most shared labs, they have
been revising Health and Safety guidance and looking at
additional responsibilities such as lab manager responsibilities
to co-ordinate the shared labs. The Safety Compliance and Risk
Manager was involved in a number of conversations on the final
design of MECD and how the different spaces would work
operationally. It was specifically requested that there should be
policies around shared labs and ensuring supervision of spaces
in moving to smaller footprint had greater utilisation.
Management advised that they didn’t want to be too directive
and wanted to empower colleagues, however in some areas this
worked and in others it didn’t. In Engineering this is now being
looked at as part of the review of health and safety guidance.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
We were advised that for one multi-disciplinary shared area (the 1.4 The University should take a formal Central Faculty
dry lab within FSE), a community of practice was formed, approach to the management of Professional Level
involving academic leads and technical leads to work out health and safety in shared multi- Services
ownership and responsibilities. See proposed action 1.4. disciplinary laboratories and
technical spaces. This should
The University has lost a number of experienced staff through include forming Communities of
voluntary redundancy and new staff have joined the organisation Practice so that there is a formal Owner: Head of Planning
during and post-Covid. Staff advised that there has been a loss collective agreement on roles and Compliance and Governance
of organisational memory with previous arrangements not responsibilities for health and safety (FMBH), Head of Planning,
always being clear and documented. This has created gaps, management including supervisory Compliance and Special Projects
impacted on staff capacity and on the clarity of roles and duties and responsibility for (FSE), Head of Planning,
responsibilities. See proposed actions 2.4 and 2.5.Feedback from equipment. Compliance and Governance (FoH),
management provides that some areas have actively with support from the Head of
encouraged the reporting of near misses and minor incidents so Safety Services.
increases in health and safety related events may be linked to Date: August 2024
improved reporting practices, however it is difficult to evidence
this. There is variation in the safety cultures across disciplines
and departments and varying perspectives of who is responsible
for safety. See Finding 2.
Our audit testing confirmed that the job descriptions for safety
advisors broadly follow the model roles set out in the Health &
Safety Arrangements, however there are additional duties
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
There has been no consultation with the Compliance and Risk 2.3 There should be a formal collective Central Faculty
Directorate regarding these job titles or job descriptions for at discussion and/or annual review of Professional Level
least five years so this is an historical lack of consultation and any further proposed changes to Services
roles e.g., senior managers are now firmly embedded. This ensure they do not deviate from the
increases the risk of further deviation from the University University’s agreed arrangements.
arrangements. See proposed action 2.3. This should be covered by the annual
review of the Organisational Owner: Head of Planning
Arrangements discussed at the Compliance and Governance
There have been significant organisational changes that have
Health, Safety & Wellbeing (FMBH), Head of Planning,
impacted on staff capacity and the clarity of roles and
Committee. Compliance and Special Projects
responsibilities for health and safety as follows:
(FSE), Head of Planning,
The University has lost a number of experienced staff through
Compliance and Governance (FoH),
voluntary redundancy, including the Deputy Head of Safety
and the Head of Safety Services.
Services meaning that experience and specialisms have been
lost. In addition, some new staff with safety roles have also Date: February 2024
joined the organisation during and post-Covid. Staff advised
that there has been a loss of organisational memory with
previous arrangements not always being clear and documented. 2.4 Finalise the FSE review of the Health
See proposed actions 2.4 and 2.5. & Safety team structure, capturing Central Faculty
roles & responsibilities across the Professional Level
Safety and new Technical teams to Services
ensure that the models are realising
The Faculty of Science and Engineering (FSE) accounts for the planned benefits, any gaps are
largest proportion of health and safety related events across the suitably addressed and that
University; 38% (663) of total reported events between August specialist areas have appropriate Owner: Head of Planning,
2019 and April 2023. (See Appendix B). This is not surprising health and safety expertise available Compliance and Special Projects
given the profile of the faculty and the activities undertaken to support them. (FSE) with support from Head of
within the FSE in terms of laboratory and workshop related Safety Services.
activities. However, the FSE has seen the biggest relative Date: March 2024
increase in health and safety related events post-Covid, with
events in the faculty almost doubling between 2019/20 and
2022/23 (from 119 to 227). Management advised that at the last
OHSTAG it was reported that 30% of FSE reported incidents were
Estates related issues. Within FSE there has been a restructuring
of the faculty, an ongoing review of the health and safety
advisors, a technical review and changes connected with the
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
MECD bringing about changes to processes and ways of 2.5 The University should review Central Faculty
working. Feedback suggests that the combination of these organograms to clearly show the Professional Level
factors has given rise to a lack of clarity of roles and responsibilities for health and Services
responsibilities for health and safety management in the faculty. safety management at local level
See proposed action 2.4. and ensure they are communicated
appropriately.
In the FSE they are currently reviewing the structure of the Health Owner: Head of Planning
and Safety team in order to provide greater resilience. Compliance and Governance
Management advised that they are in the process of assigning (FMBH), Head of Planning,
the work. Safety Advisors are being brought in from the Schools Compliance and Special Projects
into a faculty safety team with specialist themes. Feedback from (FSE), Head of Planning,
staff is that this move may create greater distance between the Compliance and Governance (FoH),
safety advisors and the schools and departments. Management with support from the Head of
advised that the proposal is that each department/disciplinary Safety Services.
area will still have defined points of contact for health and Date: April 2024
safety. Structurally the teams haven’t moved, however before
MECD the staff were more spread out and physically based in a
departmental building so the moving to a central location may
have created a perception of a physical barrier.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
A technical review in FSE has resulted in significant changes for 2.6 The University should ensure that Central Faculty
technical staff who now cover multiple areas according to there are clear and formal arrangements Professional Level
disciplines/specialisms and are no longer dedicated to one or in place to provide visibility of who is Services
two areas. Staff feedback suggests that there are gaps from the responsible for the ownership of
transition of technical staff from old role to new role and areas buildings. Consideration should be
where nobody is picking issues up. Management advised that given to reinstating Building User
there is a triage process through general safety staff to respond Groups which report in to the Health Owner: Head of Safety Services and
to specialist queries. and Safety governance structures. Head of Estates in consultation
with Head of Planning Compliance
and Governance (FMBH), Deputy
The Technical Review has consisted of 4 phases (Cohorts 1-4). It
Director of Faculty Operations and
is now at cohort 4 (Cohort 1 was completed 2 years ago). FSE is
Head of Planning, Compliance and
further ahead than FoH with technical review and FBMH don’t
Special Projects (FSE), Head of
have as many labs. A scope is being drafted for an evaluation of
Planning, Compliance and
the technical review, however the evaluation metrics were not
Governance (FoH).
agreed at the outset so they are working on agreeing the baseline
and assessing what data is available. Date: April 2024
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
Health and Safety Committees are established and meeting at 3.1 The University should consider Central Faculty
faculty, school and department level. The Faculty Health and reviewing the remit and Professional Level
Safety Committees report into the Occupational Health Training membership of the Mental Health Services
Advisory Group (OHSTAG) which reports to the University Health and Wellbeing Advisory Group.
MHWAG
Safety and Wellbeing Committee (HSWC).
There may be a need to look at the role and remit of the Mental Owner: Chair of Mental Health and
Health and Wellbeing Advisory Group and how it fits into the Wellbeing Advisory Group. Terms of
HSW Governance Structure. The membership of the Mental Reference to be sent to HSW
Health and Wellbeing Advisory Group does not include Committee for review.
Occupational Health or Health & Safety representatives. From Date: February 2024
our review of the HSW minutes, we observed that the Mental
Health and Wellbeing Advisory Group did not meet between
3.2 Management should review the Central Faculty
March 2022 and February 2023. See proposed action 3.1.
standing agenda items for Faculty Professional Level
and local Health and Safety Services
The faculty committees are as follows: Committees to ensure there is
• FoH – Compliance Committee alignment with the organisational
arrangements and that key issues
• FBMH – Faculty Health, Safety & Wellbeing Committee such as health and safety training Owner: Head of Planning
(HSWC) and inspections are regularly Compliance and Governance
• FSE - Health, Safety and Wellbeing Committee (HSWC). included on agendas. (FMBH), Head of Planning,
Compliance and Special Projects
We reviewed agendas and terms of reference for the three (FSE), Head of Planning,
Faculty Committees and a sample of School level committees Compliance and Governance (FoH).
and identified the following: Date: January 2024
• At local level there is good coverage of standing agenda
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
items, however there could be better alignment with 3.3 Heads of Departments / Schools Central Faculty
University suggested agenda items and with agenda should communicate to all Professional Level
themes discussed at Faculty Committees to ensure a members of the Health & Safety Services
‘golden thread’ approach and that key items are not Committees that attendance at the
missed. See proposed action 3.2 meetings should be a priority.
• From our review of meeting minutes, we did not identify
any issues in terms of low attendance, however Owner: Head of Planning
management feedback suggests that attendance is not Compliance and Governance
always sufficient at local committees and there is a need (FMBH), Head of Planning,
to raise the profile of the meetings and make it a priority Compliance and Special Projects
for people to attend. See proposed action 3.3 (FSE), Head of Planning,
Compliance and Governance (FoH)
with support from Dean/Deputy
• We noted that Health & Safety Training and Inspections Dean/DoFO where required
were not included as standing agenda items on all
Date: December 2023
meetings and there is disparity in terms of how the local
and faculty level committees track actions and
improvement plans. See Finding 4.1. We would expect
Health and Safety Training to be regularly discussed at
Committees, however this may be linked to the reporting
issues highlighted at proposed action 7.1. 3.4 Management should take steps to
• The Terms of Reference (ToR) for the FMBH Faculty HSWC ensure there is appropriate Central Faculty
does not provide standing agenda items and states that Professional Level
technical/PI/Researcher
Services
the meeting agenda will be generated by the Compliance representation at Health & Safety
and Risk Senior Manager. Committees.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
feedback also suggested that there should be more 3.5 Engineering (FSE) should prioritise Central Faculty
researcher representation at the meetings as it is the finalisation of governance Professional Level
important there is representation from people who are reporting arrangements for health Services
working in the labs. See proposed action 3.4 and safety under the new structure
and ensure that any reporting gaps
are sufficiently addressed.
• There are local variations in terms of how Committees
are structured e.g., in FBMH there are 18 Divisional Health Owner: Head of Planning,
& Safety Committees reporting in to the Faculty level Compliance and Special Projects
meeting. In FSE the School of Natural Sciences has (FSE).
departmental Health & Safety Committees and all five Date: December 2023
institutes have their own Committees. In Engineering the
Committees at departmental level have been disbanded
and replaced with a new single School Health & Safety
Committee with sub-groups by discipline reporting into
the School Committee. Management advised that there
is still work to be done on the governance reporting
arrangements. They have gone from four departments to
seven departments and there is a challenge in terms of
how they get things reported to the School Committee
and to the departments under them. This has been
ongoing for the past year and needs to be worked out to
ensure there are no reporting gaps. See proposed action
3.5.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
2. MECD – Given a lack of clarity in relation to the original 3.6 Management should ensure that
business cases for MECD, implications for health and safety there is consideration /consultation
arrangements were not considered early in the decision Central Faculty
on health and safety issues built in Professional
making process. Management advised that a 3 year Level
to the decision making process for Services
evaluation programme for MECD will be launched this year to major projects and restructures,
ensure lessons are learned. The Steering Group for the and that these issues are picked up
evaluation starts in September with lessons learned being by Health & Safety Committee
fed into the Finance Committee and OHSTAG. agendas.
Owner: Head of Planning
Compliance and Governance
We would expect significant projects and restructures that (FMBH), Head of Planning,
impact on health and safety arrangements to follow a formal Compliance and Special Projects
business case approach and to flow through the relevant Health (FSE), Head of Planning,
and Safety Committee agendas. See proposed action 3.6 Compliance and Governance (FoH),
with support from the Head of
Annual safety inspections are carried out by Safety Advisors. The Central Safety Services.
methodology and scheduling approach for local health and Date: April 2024
safety inspections is not formally documented in procedures.
There is also no consistent approach to reporting outcomes and
3.7 Management should ensure that Central Faculty
actions to the School Health & Safety Committees and reporting
the scheduling/coverage of local Professional Level
of inspection activity and actions is not considered mandatory
inspections is risk based and Services
in all areas. See proposed action 3.7
arrangements for the reporting of
Safety staff have expressed concern around the robustness of inspection activity/actions through
the HASMAP self- assessment process. Feedback also suggests Health & Safety Committees is
this self-inspection approach can be viewed as a ‘tick box’ aligned with the Health and Safety Owner: Head of Central Safety
exercise and there are differing levels of engagement with the Committee Arrangements Chapter. Services
process across the faculties. From our review of HASMAP
evidence we noted that there is a lack of evidence in some areas Date: February 2024
to demonstrate why they have self-assessed as being 100%
compliant. See proposed action 3.7.
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# Finding Risk Proposed Management Action Management Response
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The Central Safety Services (CSS) team have a role in level two Central Faculty
assurance and there is a need for CSS to pick up a proportional 3.8 Central Safety Services should build Professional Level
amount of audits to provide level two assurance for the on and enhance the current Services
organisation. Competing demands and staff capacity challenges schedule of audit activity in order to
have recently impacted on the amount of proactive work provide increased coverage of level
undertaken by CSS. We confirmed that some audit activity has two assurance for health and safety
been carried out by CSS in respect of HASMAP self-assessments management. Priority areas should Owner: Head of Central Safety
and there is schedule of audit based on the University work plan be agreed with faculties and the Services
for a co-ordinated audit in each area. The Director of Risk and schedule should be communicated Date: February 2024
Compliance advised that they intend to develop this in the near at local level to increase visibility
future. See proposed action 3.8. and awareness.
4 Reporting, Recording, Tracking and Analysis Moderate 4.1 Consideration should be given to
The current approach to reporting and analysing incidents is implementing an online reporting Central Faculty
very manual and labour intensive and staff feedback suggests tool for health and safety related Professional Level
that this could potentially be a barrier to reporting. Currently events in order to remove barriers to Services
there is no online system for reporting incidents and they are reporting and improve efficiency.
reported on a form which is available on the staff intranet and This could include an automated
University website. The completed form is then attached to an dashboard to help enhance data Owner: Director of Compliance and
email to the Safety Services Team. In order to collate and insight, access to reports and to Risk
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# Finding Risk Proposed Management Action Management Response
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analyse health and safety event data, information is thereafter reduce duplication of effort. It could Date: December 2024
‘double-keyed’ into databases.. There Is duplication of effort as also include alerts and workflows so
the data is analysed by different people centrally, at faculty and that there is robust oversight of
at local level. During our discussions with staff it became event categorisation, actions,
apparent that reports in relation to the analysis of health and progress with investigations and
safety related events are not always disseminated at a local level. dissemination of lessons learned.
5 Communication, Collaboration and Sharing Best Practice and Low 5.1 We agree with the formation of the Central Faculty
Lessons Learned cross faculty operational forum. It is Professional Level
recommended that a clear Terms of Services
Due to the federated nature of health and safety structures in the
University, faculties and schools tend to work in a silo approach. Reference be developed for the
Opportunities to collaborate on solutions have been missed and group and that it has appropriate
faculties are tackling common issues in different ways and with ownership and membership,
different levels of resource. For example, work in relation to the including Central Safety Services Owner: Head of Planning,
development of local health and safety training and developing representation. We also recommend Compliance and Special Projects
SharePoint for managing risk assessments could have been that Health and Safety is a priority (FSE), Head of Planning Compliance
projects progressed in collaboration for a consistent approach standing agenda item on this group and Governance (FMBH), Head of
and to prevent duplication across faculties. Cross-faculty and that there are formal Planning, Compliance and
working (where possible) would help achieve efficiencies and arrangements for linking into the Governance (FoH) with the Head of
provide a mechanism for the sharing of best practice and health and safety governance Safety Services.
lessons learned. Management advised us that a cross faculty structure and for sharing best Date: March 2024
forum bringing together the faculty Senior Managers with practice.
responsibility for health and safety has recently been formed.
This is not a formally recognised committee and at the time of
the audit fieldwork, no terms of reference had yet been agreed.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
The approach to the dissemination of lessons learned varies 5.2 The faculties should consider Central Faculty
across schools and faculties. From our discussions with staff, implementing a formal process for Professional Level
some areas feel they do this well whereas others have nothing the sharing of lessons learned Services
formal in place to share lessons learned. There is a formal across faculties and schools.
process in place for sharing lessons learned via the OHSTAG,
however it has been identified that this is not operating as
effectively as it could be therefore OHSTAG has generated actions Owner: Head of Planning,
for schools to share information and a specific action for faculty Compliance and Special Projects
representatives to report back on what they have done around (FSE), Head of Planning Compliance
lessons learned.. Safety circulars are communicated in relation and Governance (FMBH), Head of
to serious events, however there is no formal mechanism in Planning, Compliance and
place to share lessons learned between schools and faculties. Governance (FoH) with the Head of
There is a risk that lessons learned are not being effectively Safety Services.
communicated at local level and that issues could reoccur
Date: March 2024
causing harm to students or staff. See proposed actions 5.1 and
5.2.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
6 Health & Safety Training and Competency Assessment High 6.1 Given the implications in terms of Central Faculty
potential non-compliance with Professional Level
It is currently very difficult for the University to demonstrate
statutory requirements and risks to Services
compliance with statutory and mandatory health and safety
training. There is no central learning management system for staff/student safety, the University
recording and reporting training completion, and the current should review options to implement
approach is that data is collated manually at a local level for the LMS to ensure that compliance
annual reporting purposes. A new Learning Management System with statutory and mandatory Owner: Escalation to PSLT through
has been purchased by the University, however it is on hold due health and safety training can be Director of Compliance and Risk
to IT resource capacity challenges. The delivery of the LMS is formally monitored. If there is to be and Head of Safety Services
critical in terms of ensuring role specific training requirements further delay with delivery of the Date: TBC
that are delivered and auditable. Safety leads don’t have access LMS, the University should ensure
to ongoing lists of who hasn’t completed mandatory training.. that robust interim arrangements
We also note that there is no clear policy in terms of what the are put in place to provide the
consequences are if the training is not completed therefore it is information until such time as the
challenging to mandate training. See proposed action 6.1. LMS is implemented. It is also
recommended that policies relating
to statutory and mandatory Health
Previously there was a Health and Safety Training Co-ordinator and Safety training clearly articulate
post in Learning and Organisational Development. This role no the sanctions if this training is not
longer exists and it is currently not clear where the responsibility completed.
for the central co-ordination and management of health and
safety training sits. See finding 6.2. Currently there is no clear
strategy for health and safety training and the University is 6.2 The University should ensure that
unable to measure training compliance(See proposed action 6.2. there is an appropriate lead role for
health and safety training.
Central Faculty
From our benchmarking exercise, all HE providers who Professional Level
responded are using a learning management platform for the Services
recording and reporting of mandatory health and safety training.
Probationary arrangements state that the line manager should
ensure that all mandatory induction training (including health
and safety) is completed by the probationer, however it is not Owner: Director of Compliance and
clear to what extent this is followed up. Reports on induction Risk, Head of Safety Services and
training are collated manually and provided to OHSTAG by P&OD (Neil Chamberlain).
Learning and Organisational Development, however these merely Date: April 2024
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
on the agenda dedicated to Health and Safety. There is no Owner: P&OD (Neil Chamberlain)
specific health and safety training for line managers (academic with Head of Central Safety
line managers, PI’s and PS line managers) and new academic Services and managed through
staff. Feedback provides that it is not clearly pointed out to them normal line management and
what they have responsibility for. For example, someone may appraisal system.
come in as a new academic or PI and complete a general health Date: August 2024
and safety induction but there is no training on what their health
and safety responsibilities are. See proposed action 6.5.
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# Finding Risk Proposed Management Action Management Response
Rating (including Action Owner and Date)
place. There is also an online training module owned by P&OD, Date: August 2024
See proposed action 6.7.
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Appendix A - Audit Background and Scope
A1. Scope
The contents of the following table provide a high-level overview of the key risks for the audit.
1 Appropriate and timely action may 1. Health and safety events Review the analysis of H&S 1. Reports containing trend analysis of
not be undertaken (in a consistent formal reporting process. related events reported to H&S related events are reported to
manner) to address the increase in 2. Analysis and reporting of OHSTAG and HSWC to confirm the Occupational Health Training
events. For example, the potential quarterly health and safety that it contains a robust analysis Advisory Group (OHSTAG). The
impact of students with less events data to OHSTAG and and explanation of possible root reports contain a detailed analysis of
awareness of health & safety HSWC. causes. H&S related events data. No matters
expectations, changing roles of PIs 3. Induction training and ongoing arising
and staff with technical support training for students and staff 1. Carry out an analysis of pre-and 2. Refer to Appendix B
responsibilities, and multi- (See Risk 4) post-covid health and safety 3. The FSE has seen the biggest relative
disciplinary labs and shared 4. Competency Assessment related incident data to identify increase in health and safety related
spaces. 5. Risk Assessments patterns and trends that may events post-Covid, with events in the
help explain the increase in faculty almost doubling between
events. 2019/20 and 2022/23 (from 119 to
227). Within FSE there has been a
restructuring of the faculty,
restructuring of the health and
safety advisors, a technical review
and the MECD which has brought
about changes to processes and
ways of working. Feedback suggests
that the combination of these
factors has given rise to a lack of
clarity of roles and responsibilities
for health and safety management in
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
2 Roles and responsibilities for 1. Health and Safety 1. Review the University’s Health 1. Roles and responsibilities are
managing health and safety may Policy/Arrangements and Safety Policy and documented in the University Health
not be clear leading to potential Chapters/Model Roles organisational structure to and Safety Policy within the
non-compliance, and risks to confirm that roles and Organisation and Arrangements
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
staff/student safety. 2. Statements of Intent responsibilities for health and Chapters. The Policy delegates the
3. Staffnet pages safety across the institution are responsibility for producing local
4. Job Descriptions clearly documented. policies to Deans of Faculty and
5. Competency Assessment (See senior managers. The H&S Policy
Risk 4) states that each Faculty/Directorate
should have its own H&S Policy
setting out the specific
organisational arrangements within
the Faculty/Directorate. At School
level, there should also be a local
H&S Policy/Statement of Intent with
the organisational arrangements for
each School/Unit. We confirmed that
Faculty and School level Health &
Safety Policies/Statements of Intent
are in place. No matters arising.
2. Feedback in some areas is that they
2. Interview key staff across the are unclear on who to contact for
three faculties to assess if their H&S advice. Feedback from staff is
roles and responsibilities are that responsibilities are only clear to
understood. those who know how the Health and
Safety network works, but they are
not clear to other staff. Job titles and
roles for safety staff are different
across faculties and some have
additional responsibilities meaning
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
3 Governance arrangements may not 1. Health, Safety and Wellbeing 1. The University Health, Safety &
1. Review the central and devolved
be clear or effective, resulting in Committee and Occupational Wellbeing Committee (HSWC) is the
governance framework for health
health and safety issues not being Health and Safety Training and safety. main decision-making body in
identified in a timely manner Advisory Group (OHSTAG) relation to health and safety issues
and/or not being adequately 2. Faculty, School and and is supported by a number of
addressed, leading to potential Department Health and Safety specialist Advisory Groups -
non-compliance, and risks to Committees Radiation, fire and biohazard
staff/student safety. 3. Annual Monitoring incidents are reported fully through
4. Faculty Risk Profiles their respective Advisory Groups. At
School level monitoring reports are
5. Central and devolved roles and
responsibilities reported quarterly to the Faculty
Health and Safety Committees and
6. Schedule of Inspection
issues can be escalated from
7. HASMAP
School level via the Faculty Health
8. Risk Assessment Review
and Safety Meeting and on to
9. Three lines of assurance
OHSTAG. No matters arising.
2. There is regular performance
monitoring of H&S related events,
KPIs and metrics by the
Occupational Health Training
Advisory Group (OHSTAG) and the
Health Safety and Wellbeing (HSW)
Committee. No matters arising.
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
Manager.
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
4 Processes for health and safety 1. Minimum health and safety 1. Speak with key staff to confirm 1. It is currently very difficult for the
may not be followed (due to poor training requirements detailed that staff health and safety University to demonstrate
engagement / training / in Health and Safety Policy training needs are identified, and compliance with statutory and
ownership) or may be poorly 2. Induction training appropriate training is provided mandatory health and safety
designed, leading to potential non- 3. Induction checklists and kept under review. training. There is no central learning
compliance and risks to 4. Ongoing and refresher health management system for recording
staff/student safety. and safety training and reporting training completion.
5. Monitoring of mandatory See proposed action 6.1.
training completion
6. Competency assessment 2. Supervisors need to be competent
7. Training needs analysis to sign off risk assessments. Risk
assessment training is not
consistent across the University.
Some areas have developed risk
assessment training (e.g., FBMH
have risk assessment training in
Blackboard) and some areas deliver
toolbox talks, whereas others have
nothing formal in place. See
proposed action 6.7. Annual
Compliance updates are provided
for senior managers e.g., Heads of
Schools. Heads of Departments),
with 20 minutes on the agenda
dedicated to Health and Safety.
There is no specific health and
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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# Risk Risk Management Approach (i.e. Test Objective Summary of Findings
Controls)
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A2. Key Stakeholders
We met with the following staff during the audit fieldwork:
Name Role
Dr David Barker Director of Compliance and Risk
Dr Patrick Seechurn Head of Safety Services
Mr Patrick Hackett R,S & COO
Prof Nalin Thakker Vice President/Chair of OHSTAG
Prof Martin Schröder Dean (FSE)
Prof Melissa Westwood Associate Vice President for Research
Prof Nigel Hooper Associate Vice President for Research
Local safety chair on behalf of HOS and
academic lead; also sits on HSW as Chair of GM
Prof Simon Turner Bio Advisory Group.
Head of Planning, Compliance and Special
Dani Murtagh Projects (FSE)
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Brent Collins School Compliance and Risk Manager (FBMH)
Lisa Grady School Compliance and Risk Manager (FBMH)
Assistant Director of Estates and Facilities &
Jon Ashley Head of Estates Support
Principal Estates and Facilities Health and
Martin Blake Safety Manager
Carl Jackson Health, Safety and Compliance Advisor (FSE)
Suzanne Raw School Compliance and Risk Manager (FBMH)
Michelle Jackson Technical Operations Manager (FBMH)
Prof Melissa Westwood Associate Vice President for Research (FBMH)
Sylvester Boon Health, Safety and Compliance Advisor (FSE)
Prof Nigel Hooper Associate Vice President for Research (FSE)
Craig Hopper Head of Technical Operations (FSE)
UCU Safety Representative and School Safety
Dr Nicola Hutchings Adviser (FSE)
FBMH - Local safety chair on behalf of HOS and
academic lead; sits on HSWC as Chair of GM
Prof Simon Turner Bio Advisory Group.
Kevin Gaskell-Clow Unison Safety Representative
Kevin Jackson Head of Technical Operations (FSE)
Health, Safety and Compliance Officer,
Sarah Gumusgoz Directorate for Student Experience
Kenneth Drury Unite Safety Representative
Vice Dean and Head of School, School of Natural
Prof Chris Hardacre Sciences, (FSE)
Prof Alice Larkin Head of School of Engineering (FSE)
Programme Director for Mechanical
Prof Lee Margetts Engineering (FSE)
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Prof Andy Weightman Associate Dean Teaching Academy (FSE)
Robert Jones Head of Operations, Dalton Nuclear Institute
The following staff will receive the draft and final audit report
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Appendix B – Analysis of Health and Safety Related Events
Analysis of Health and Safety Related Events Aug 2019 – April 2023
Post-Covid, the University has seen an increase in the number of reported health and safety related events. It could be expected that as
activity levels returned to normal following the lockdown period, that there would be a return to pre-Covid levels. There is a concern
however, that levels are continuing to increase and are now exceeding what they were pre-Covid. It can be seen in Chart 1 below, that the
number of recorded health and safety related events peaked during February and March 2023. Table 1 highlights that the number of
reported events per month during August 2019 – April 2023 is increasing year on year.
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Table 1: Average Health & Safety Related Events per Month (Aug 2019 – Apr 2023)
Where a cause was provided, the highest level of incidents were said to have been caused by Chemical/Laboratory (30%) and Equipment
(17%).
The number of RIDDOR reportable incidents have also increased indicating an increasing trend in more serious incidents.
Table 2: RIDDOR Reportable Health & Safety Related Incidents (Aug 2019 – Apr 2023)
The faculties with highest levels of health and safety events during April 2019 – April 2023 were:
• FSE
• Estates
• FBMH
• Student Experience
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FSE accounted for 38% of total reported events between August 2019 and April 2023. This is not surprising given the profile of the faculty
and the activities undertaken within the FSE in terms of laboratory and workshop related activities. FSE has seen a notable increase post-
Covid with health and safety related events in the faculty doubling between 2019/20 and 2022/23 (from 119 to 227). Table 3 below
highlights that there were significant increases in reported events in FSE during 2021/22 and during August 2022-April 2023.
Table 3: Total Events in FSE Aug 2019 – April 2023
The highest levels of events in FSE relate to Chemistry and Materials and during August 2019 – March 2023, the following buildings
accounted for over 50% of reported events in FSE:
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• Chemistry, Brunswick Street - accounted for 30% (197) of reported events in FSE
• Royce Hub Building (Sir Henry Royce Institute - accounted for 10% (64) of reported events in FSE
• Manchester Interdisciplinary Biocentre (MIB) John Garside Building – accounted for 8% (53) of reported events in FSE.
• MECD – accounted for 8% (53) of reported events in FSE.
• Estates – Increasing post-covid accounting for 20% (344) of total events between August 2019 and April 2023. The highest levels of events
attributed to Estates were building related, equipment related and fire related events.
• FBMH – Has seen a steady increase in events post-Covid, however not back to pre-pandemic levels. Accounts for 18% (314) of total events
between August 2019 and April 2023). The highest levels of events in FBMH related to equipment and chemical/laboratory.
• Student Experience – continued increasing trend post-covid. Relatively low numbers. Accounting for 16% (274) of total events between
August 2019 and April 2023.
Analysis of Reasons for the Overall Increase in Reported Health & Safety Events
During our audit fieldwork we met 39 staff from across the faculties and professional services. We discussed possible reasons for the
increase in health and safety related events, the level of management in place locally and how this was managed pre-covid compared to
how it is currently managed. From our analysis of data and meetings with staff, it is clear that there are a number of contributory factors
as follows:
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addressed before an incident occurs. The FoH laboratory areas have not been impacted by hybrid working to the extent of FSE and FMBH as
they are managed by technical staff who are on site 5 days per week.
Hybrid working is also impacting on the availability of supporting health and safety roles such as first aiders and fire evacuation marshals.
Post-Covid it has been difficult to recruit into these voluntary roles and where people are already in the roles, it is difficult to know when
they are on-campus due to hybrid working.
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advised us that for MECD the intention is to look to having an individual who has responsibility for co-ordination and checking day to day
that agreed activities are being carried out.
• An overall increase of 5385 students (13.3%) across the three faculties from 19/20 – 22/23. FBMH – an increase of 1244 students
(10.7% increase)
• FoH – an increase of 3117 students (18.4% increase)
• FSE – an increase of 1024 students (8.6% increase).
This highlights that both FBMH and FoH have had higher % increases in overall student numbers than FSE, however they have not had the
same level of increase in health and safety related events. This suggests that increased student numbers is not an overriding factor.
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Appendix C – Summary Findings Mapped to Assurance Requirements
The table below summarises the number of mapped to key assurance requirements:
Finding Ratings Internal Risk Governance Sustainability Data Value for Money OfS Conditions
Control Management
High 2 - - - - - -
Moderate 1 - 1 - 1 - -
Low 1 - - - - - -
Advisory - - - - - - -
4 - 1 - 1 - -
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Appendix D - Report Conclusion and Finding Definitions
# Conclusion Rating Risk Assurance Description Efficiency / Economy Description Benchmark Rating Description
1 Substantial We offer substantial assurance We offer substantial assurance that Sector Leading The University’s systems,
Assurance that the system of internal the system of internal control is processes and practices are
control and governance is efficient and economic (although ahead of other institutions and
designed adequately and is potential enhancements may have operate within best practice,
operating effectively. been identified) based upon Uniac’s judgement
Potential enhancements may at the time of the review.
have been identified.
2 Reasonable We offer reasonable assurance We offer reasonable assurance that Within Norm The University’s systems,
Assurance that the system of internal the system of internal control is processes and practices are
control and governance as efficient and economic, however the operating within the norm of
designed is adequate and is audit did identify some opportunities the sector, based upon Uniac’s
generally operating effectively, to improve the efficiency / economy of judgement at the time of the
however the audit identified the system of internal control review.
some opportunities for
improvement.
3 Limited We offer limited assurance The audit identified significant Behind Norm The University’s systems,
Assurance because the audit identified opportunities to improve the efficiency processes and practices are
significant opportunities to / economy of the system of internal operating behind the sector,
improve the adequacy and control based upon Uniac’s judgement
effectiveness of the system of at the time of the review.
internal control and governance.
4 Inadequate The design of the system of The system of internal control is not
Assurance internal control and efficient / economic
governance is inadequate.
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D2. Risk Rating Definitions
The Risk Rating category allocated to findings is defined in the below table to illustrate the potential risk of the finding and the suggested
urgency of the implementation response.
Suggested Implementation
Category Explanation
Responsibility and Timescale
The finding highlights our assessment of the adequacy and/or effectiveness of control, which we judge Governing Body/Accountable officer
could lead the University to high-risk exposure or the activity is not efficient or economic. level
This could have a significant impact on the operational objective and performance of the activity; a Action in 0-3 months to reduce risk
High significant breach of organisational policy (or an absent policy); a breach in compliance with legislative exposure
and regulatory obligations leading to significant sanctions (including financial); significant reputational
damage at national and international scale; a negative student experience, or a significant impact on
finances and financial reporting.
The finding highlights our assessment of the adequacy and/or effectiveness of control, which we judge Senior Management Team (cross-
could lead the University to moderate-risk exposure. It also highlights some opportunities to secure value departmental)
for money. Action in 3-6 months to reduce risk
Moderate Management response is necessary to mitigate the potential impact on the operational objective and exposure
performance of the activity; a breach in organisational policy; a breach in compliance with legislative and
regulatory obligations leading to sanctions or additional scrutiny; regional reputational damage; a
negative impact on the student experience; or potential for impact on finances and financial reporting.
The finding highlights our assessment of the adequacy, effectiveness, economy and efficiency of control, Departmental Management
which we judge could lead the University to an increasing risk exposure or enhancing the efficiency and Action in up to 12 months to reduce
economy of the activity. risk exposure
Low Although the control is designed and/or operating reasonably, there are opportunities for
improvement to further enhance the management of risk in the area/activity, that should be
implemented to ensure the risk is managed and continues to be managed within risk appetite.
We have identified further enhancements that would provide best practice development in the To be considered for
Advisory adequacy, effectiveness and economy of internal control for the activity under review. implementation by the
Departmental Management.
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Appendix E – Peripheral Issues Observed During the Audit
1. Legacy items – There is an ongoing issue with legacy items left in labs by former staff. These legacy items are creating estates utilisation and
health and safety issues. Whilst there is a process in place it doesn’t seem to be enforced. Lab clearance is often falling to the technical staff.
There is a need to define roles and responsibilities for this. Linked to Risk 2.
2. MECD Engineering Buildings Access Issue – The engineering building is open access with some areas (workspace/lab/research) restricted by
swipe card access. No security, no reception staff. Tailgating risk. Management advised they are introducing bright yellow lanyards and will
raise awareness with building users, however they don’t want to put turnstiles in the building. Whilst we recognise the broader community
civic responsibilities around the buildings, there are potential health and safety and security risks with the open access approach given the
size of the building. We were advised that the Head of Safety Services (the competent safety lead) recommended a reception desk be installed,
however this advice wasn’t followed.
3. Gas passport training – externally places for training are limited and there are long waiting lists. There are a handful of people designated to
fill the void but staff advised us that they are aware of incidents whereby people are not waiting for training and then having incidents with
gas (connecting up gas when they shouldn’t as they haven’t yet attended training).
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