Inside Track

The saga of the European Union EMF directive continues with the European Commission beginning to show its hand on what a final directive might look like.  Changes proposed could be key for anyone carrying out processes such as metal and plastics welding and induction heating.  

EEF has for a decade been at the forefront of the campaign to prevent a directive that brings little if any benefit, whilst imposing significant costs on business.  The European Commission has consistently failed to produce evidence of harm from workplace exposures in all but a very few specialist circumstances.  For a quick synopsis of the position and how we got to be where we are, read our policy paper.

At the tale end of August I met with the EC official in charge of work on the directive.  And last week the EC working party charged with advising the Commission on EMF met – EEF’s own Gary Booton was there as the UK employer member.  The EC shared a draft for discussion.  Whilst it is not a formal draft proposal it does indicate the direction the EC is taking.  The key feature is the introduction of a zoning system as in the schematic below. 

Most workplaces would fall in the green zone and need take no action. 

In the yellow zone, measures would need to be taken to ensure safety. Some industrial processes, such as arc and resistance welding may fall into this zone.  In practice it may be possible to check and use a standard risk assessment.

The interesting point is what would happen in the red zone.  Straying into this zone ( at least for lower frequencies) would not be an offence in itself.  It would be permitted if justified by a risk assessment that identified measures to ensure safety.  This might be important for a few industrial processes such as extremely high current manual arc welding.

As to medical MRI scans, the proposal is to simply exempt them from the zoning system and values altogether.  Whilst this resolves the important issue for MRI, it does beg a question – if exposures are considered safe in medical settings, why are they not in industry?  

We are promised a draft directive by the end of 2010, though this may be missed.  In the meantime, advice is to keep managing health and safety on the basis of risk.  Unless you have workers coming very close to equipment that emit extremely high levels of EMF (eg climbing live transmitter masts) don’t be lured into spending large amounts of money on consultancy and equipment.

So another voice has been added to the many that are calling for the CRC Energy Efficiency Scheme to be simplified. However, this is not just any voice, but the influential voice of the Committee on Climate Change (CCC). Its report published today, echoes what various groups, including EEF, have been saying for sometime now, that the scheme is "very complex". The first casualty could be the intended ‘cap and trade’ element, which the CCC recommends should be scrapped. This is music to my ears, as I believe this part of CRC will merely add unnecessary costs and complexity burden onto businesses without significant reductions of carbon emissions. Indeed increased costs to manufacturing companies that are still struggling out of a deep recession.

Government must not under estimate the importance of combining a carbon tax with Greenhouse Gas reporting, in driving change within organisations. There should be a greater focus on the reporting element of the scheme, centred on Defra’s carbon reporting guidelines, published last year. This should not be a wasted opportunity for Defra to promote a uniformed reporting methodology across sectors.

The CCC calls for a splitting the League Table into public and private sectors. Of course this is a step in the right direction, but doesn’t go far enough. The government must enable companies to highlight the positive steps they are taking to reduce emissions. This good news narrative must be positioned at the forefront of the table, rather than a focus on absolute emissions. The current narrow focus of the League Table will lead to false results and will not acted as a driver for organisations to become more carbon efficient throughout their operations.

A simple change that government must make as soon as possible, one that would reduce the administrative burden significantly, would be to remove the requirement for organisations not caught by the scheme, to positively prove that they are exempt.

This is certainly one to keep watching and I am pleased to see that the voice of manufacturing is being heard within this debate in today’s Telegraph.

Are you interested in promoting your company at a Department for Business (BIS) low carbon exhibition?

BIS is holding an exhibition at its headquarters in London to promote low carbon products from UK manufacturing companies. The exhibition runs from 11th - 22nd October. Unfortunately, there is a short deadline of informing BIS that you are interested in exhibiting, which is Monday.

If you are interested, please contact Tony Mills at BIS on 020 7215 4729 tony.mills@bis.gsi.gov.uk

Further details of this opportunity from BIS are below:

An exhibition of cutting edge products has been unveiled by Business Minister Mark Prisk at the Department for Business, Innovation and Skills (BIS) to encourage a new generation of innovators.

The Government is committed to promoting manufacturing as it is critical to economic growth with responsibility for 53 per cent of UK exports and 2.8 million jobs.

With new business opportunities, such as low carbon products, emerging all the time BIS wants to work with the manufacturing industry to encourage new talent and attract new businesses to the sector.

The exhibition is the first in a planned rolling programme of themed displays demonstrating excellence in British design, engineering and manufacturing.

Business Minister Mark Prisk said:

“Britain is a world leader in manufacturing but if we are to inspire future generations we must do all we can to promote UK excellence.

"As a signal of our intent we have invited shining examples of British design, engineering and manufacture to showcase their products at the department.

To help illustrate the theme the exhibits will be displayed so that visitors from the business community can follow the supply chain through the displays in the main reception and lift lobby areas.

This exhibition will also help to raise awareness of manufacturing in the build up to the launch of a new manufacturing framework in the autumn which will detail specific plans for encouraging growth in this sector.

Resource efficiency is quite simply a win-win approach, with benefits for both business and the environment.  It is for this reason that WRAP is relaunching their highly successful Rethink Waste campaign from September-November.  And it is why EEF is continuing its long-standing relationship with WRAP to deliver this campaign to as many manufacturers as possible. 

But don’t delay!  You have until Tuesday (September 28^th) to sign up for this free initiative from WRAP to help improve your resource efficiency and save money.

Last years campaign connected with over 1500 manufactures of all sizes and sectors within the UK, helping to implement no-cost or low-cost measures which enhanced profits by the equivalent of 1% of turnover and in some cases as much as 3%.  With such an overwhelming business case to take action we hope to realise savings for an even greater number of manufacturers this year.

The best thing about the Rethink Waste Campaign, besides being free, is that it provides a simple structured approach to resource efficiency, helping businesses to: Understand how much waste they produce; understand the total cost of waste; identify simple ways to start reducing waste, and save money; and, measure the waste and cost savings made.

The course is delivered in a three-staged format through September-November, and is packed with advice on developing a methodical step-by-step approach to reducing waste within business.  The modules are also supported with a variety of information, from PowerPoint presentations, a virtual tour of business premises, an advice line, guides, and video case studies.

With so much attention on climate change one might think that waste is a secondary environmental issue for manufacturers – That is simply not the case.  EEF’s Environment Survey 2008, and 2009, both cited waste as the priority environmental issue for manufacturers.

Rethink Waste, therefore, provides an excellent opportunity for manufacturers to realise potentially significant financial and environmental benefits for their organisation.  By capitalising on what is an already established and successful resource efficiency programme, with engagement from industry experts and fellow peers, the experience should prove only positive. 

Climate change has taken a battering this year due to the email scandal surrounding the University of East Anglia’s Climatic Research Unit and the somewhat iffy data sources used by the United Nations Intergovernmental Panel on Climate Change. 

A report from Cardiff University in June illustrated that attitudes to climate change had changed. The report showed 78 percent of the 1,822 people surveyed thought the world's climate was changing compared to 91 percent in 2005, while 40 percent of people thought the seriousness of climate change was exaggerated. And less than a third believed climate change was purely a result of human activity.

In an attempt, no doubt, to stem the conversion of climate believers-climate sceptics the government has launched a new website which explains the science behind the headlines on climate change.  The website was launched by Government Chief Scientific Adviser Professor Sir John Beddington.

The website presents an overview of some of the most important areas of study in climate science, to help anyone wishing to get beyond the day-to-day headlines to gain a deeper understanding of the fundamental scientific issues involved.

For those uncertain about the state of scientific knowledge, the web resource attempts to explain both where evidence is well established and where findings and projections remain subject to greater uncertainty.  I would welcome your comments on whether the website achieves these objectives and if it has changed your attitude towards climate change.

The government is keen to now move away from the furore which dominated the climate change agenda earlier this year and back to the task of furthering domestic and international action.  Climate change remains a priority issue for the coalition and it wants to be seen as a leader on the world stage. 

Speaking to civil servants at the Department of Energy and Climate Change, having only been in office a few days, David Cameron pledged that his coalition party would “be the greenest government ever”.

He also went on to reassure civil servants that the environment was a top priority for him. "There is a fourth minister in this department who cares passionately about this agenda and that is me, the prime minister, right. I mean that from the bottom of my heart."

An update for those of you wondering what happened to Lord Young's report which was expected on 8th September.  The review has been completed and the report written but there have been some hold-ups with publication and it's now expected in mid October.  Lord Young has a wide remit from David Cameron to review the way that health and safety law works with a view to stopping excessive risk-aversion and unnecessary bureaucracy.

Initially there some minor delays in clearing the report with others in government - very much par for the course.  But then a further delay occurred.  I understand that David Cameron himself is keen to be involved in the launch and with the serious illness and then death of his father he obviously had other immediate priorities.  The latest word is that the report will be out after parliament returns from the party conference recess on the 11th October.  That said there's a good chance there will be some mention of the issues during one or both of the coalition's party conferences.

Whilst nothing is formally confirmed, it appears that Lord Young will not recommend immediate legislation to 'license' those providing health and safety advice (see my earlier blog, 'Accredit to the profession'), but will give the voluntary agreement reached by HSE and the professional organisations time to work before reviewing the position.  This would be a very good outcome - keeping pressure on the parties involved whilst avoiding a knee-jerk reaction that could backfire and cost business a great deal. 

I am also expecting some interesting developments in terms of civil law (compensation claims, rather than regulation).  This could not only focus on the burden of proof and documentation required, but if it's more ambitious also consider whether some breaches of regulation should be civil matters rather than criminal offences.  That would certainly start a lively debate!

I'll keep you posted on developments

We had a meeting this week with Gregory Barker, the Minister of State for Climate Change within DECC. It was a refreshing meeting and a welcome change from the last administration. I am coming round to believing my earlier view that this government seems to accept that the climate change policy landscape is crowded, confused and overlapping. This is something that we highlighted in our recent report on UK climate change policy. The report called on the coalition government to reduce the burden of climate change policy by simplifying the mismatch landscape that has grown over the last ten years.

Simplification was high on the Minister’s agenda and in line with the recommendations set out in our report. Again in line with the EEF position, the Minister was receptive to the concerns of manufacturers on competitiveness and carbon leakage. There was a real acceptance that industry, even carbon intensive industry, is vital to the UK economy and particularly to the emerging low carbon manufacturing sector.

However, all my positive views might change come 20 October, when government publishes its Comprehensive Spending Review and with it, detailed climate change policy intension. Of importance will be how it intends to reform the Climate Change Levy into a potential carbon tax. During our meeting with Gregory Barker, we were at pains to point out that although we support moves for a carbon tax, we do not wish to see an increase in the overall climate change policy cost burden to manufacturers resulting from such a move.

Finally, the Minister stated he wanted his department to work closely with industry rather than at length, via consultations. The test here will be whether government consults with us ahead of any formal announcement in October. I know that we would be keen to work with his department on how to change the CRC Energy Efficiency Scheme into something more workable and business friendly. This will be high on the agenda when we meet with DECC later today.

Today EEF's Regulation Task Group publishes its major report:  'Reforming Regulation, improving competitiveness, creating jobs'.  Le'ts be clear, regulation has a place in a civilized society - it helps protect employees, consumers and the environment.  At its best it can allow businesses to compete without being pressured to compromise their ethics.  However, where it is excessive, ill-conceived or poorly implemented, it can impose significant cost on individuals, businesses and the wider economy with little or no benefit. 

Over the past two decades businesses have been promised reductions in costs imposed by regulation, only to see them rise year on year.  A telephone survey of 300 EEF members found that regulation was rated as the second worst aspect of the UK business environment behind taxation.  More than half of those surveyed identified regulation as an obstacle to growing their business. 

The coalition government has promised to reduce regulation and set out a bold 'one-in, one-out' approach where the costs imposed by new regulation must be matched by removing existing regulation imposing similar costs.  We welcome the ambition and priority given to the issue, but do have some concerns about how this will work in practice. 

For example it seems that EU-derived regulation will be excluded from the one-in, one-out system.  In one sense that seems reasonable - why should the UK government be held responsible for regulation it didn't want?  However, a thousand pounds of cost resulting from new regulation affects a business exactly the same, wherever the regulation emanates from.  And excluding EU legislation will mean that it falls off the radar; with most climate change, health and safety legislation coming from Brussels that is a huge issue.  We could once again have a situation where government can claim to have made savings and cut costs when we all know that the total cost has actually gone up.

What we need is openness and transparency, with all the cards on the table, that is why the report calls for one-in, one-out to be a stepping stone to regulatory budgets where departments are set a binding limit for the regulatory costs they can impose.  As appropriate, some can allow an increase, some require a decrease.

Another key issue is how the government engages with the European Commission and Parliament.  This is the major driver in health, safety and environment.  In recent years we have seen layer upon layer of climate and environment directives that have created a confused and ever-changing framework.  There have also been some really poor pieces of health and safety legislation, for example the Optical Radiations Directive, which the Health and Safety Executive concluded would 'bring no additional health and safety benefits in Great Britain'. 

The report urges government to build on work carried out earlier this year that started building a coalition of member states calling for reform of the Commission's approach to regulation.  It's a slow game, but vital.  Whilst the Conservatives are currently rather marginalised in Europe, the Liberal Democrats are part of the major ALDE political grouping which could be very effective in building an alliance.

The report also welcomes the role of the Regulatory Policy Committee in providing a robust challenge to regulatory proposals.  It's job is to check that the policy makers have proved the case for regulation, showing that the benefits outweigh the costs and that regulation is the only way of achieving the desired outcome.  Such a body needs to have teeth so its findings can't be ignored as well as being genuinely indpendent and able to speak out.  Under the last government it was truly independent, but had no teeth.  The coalition is certainly giving it teeth - but at the cost of independence.  We're calling for that to change.

Creating a more competitive regulatory environment will be one of EEF's major campaigns over the coming year.  We will be using the report as a constructive basis for advancing our arguments on a range of regulatory proposals, from simplification of UK waste regulation to negotiations on the Electromagnetic Fields Directive.  As ever our health, safety and environment services are there to help EEF-members and non-members cope with regulation and protect the environment, their workforce and their profitability.  Contact your local EEF office to find out more.

Altogether the report includes 10 recommendations focussed on controlling costs imposed by regulation and changing the culture amongst policy makers.  Click here to read the report or the two page position paper. 

With just days to go until the registration deadline for the Carbon Reduction Commitment Energy Efficiency Scheme (CRC) at the end of September, Gregory Barker, the climate change minister is calling for radical reform of this much maligned scheme.

This is welcome news, that the new government can plainly see the scheme is far too complex and costly and Gregory Barker is bold enough to consider making significant changes in order to achieve the aims of the scheme, but with much less burden on firms, as they continue to recover from the recession.

I hear from the Department for Energy and Climate Change (DECC), that the whole scheme is up for review, but there may be a particular focus on simplifying the way in which an organisation defines itself and making it easier for those organisations to opt out of the scheme, if some of their sites are caught by other climate change legislation.

Another simple change the minister should consider is not requiring firms that aren’t even in the scheme to pay nearly a thousand pounds, just to confirm this. That is without the administrative burden that this un-necessary task imposes on those organisations.

If this is the way that DECC is moving, then perhaps we are closer now to a climate change policy landscape that is cost effective, that aims to achieve realistic goals at least cost and does not undermine the competitiveness of UK/EU manufacturing sectors. Something that EEF has been calling for and I hope that now, something that government is alive to.

In absentia  

In the latest edition of Occupational Health at Work, the editor John Ballard casts some doubt over the quality of the underpinning data for the CBI’s Absence survey. Here this is contrasted with EEF’s own survey.

He is particularly concerned, as he says in the feature ‘Absent Minds,’ that the ‘CBI’s absence data, which is consistently used as a benchmark, is based on less than 4% response and probably weighted towards ‘better performers’’.

In contrast, EEF’s Sickness Absence and Rehabilitation Survey 2010, which has now been conducted nationally for seven years, is based on a 20% response rate.

There are a number of other comparisons worth making.

There are huge variations in reported findings for the CBI survey. ‘In 2009, long-term absence (spells of 20 days or more) was said to account for 22% of lost working time (36% in the public sector). This is half what it was in 2006 (43% overall and 52% in the public sector).’

‘The CBI surmises that illness or injury can have a bigger impact on workers’ ability to carry out physically demanding jobs, but says that this does not explain the two-day difference in average absence between white and blue-collar workers. This it attributes to “likely greater acceptance of absenteeism and lower levels of employee engagement”’ 

In contrast, the EEF survey clearly identifies that the biggest fall in sickness absence ‘was among manual workers who have reduced their absence rates from 3.8% in 2007 to 2.7% in 2009’.

The EEF survey also identifies a number of positive aspects, for example: ‘15% of companies achieve sickness absence of 1% or less’, and ‘on average, 44% of employees had no absence at all in 2009, continuing an improving trend since 2007’.

For further details and issues around presenteeism, the fit note and the NHS see EEF’s Sickness Absence and Rehabilitation Survey 2010.  For a quick summary visit the recent web story.

EEF also provides comprehensive training on Sickness Absence issues as part of its NEBOSH Management of Health, and Wellbeing at Work course.