My GENERAL concern here is that HSE inspectors, H&S professionals, insurance underwriters and others are allowing very significant "interpretation creep" into territory that they consider, for whatever reason, to be important.
Some time ago an FSB article by Chris Frankland likened this kind of thing to a class of children some of whom never did their homework. The teacher punished the whole class by setting extra homework. You guessed it! The naughty ones still did not do their homework and some of the good ones became so dispirited they also stopped doing any work.
Over regulation and more importantly hugely over zealous interpretation of regulation has the same effect as extra homework. It becomes a tax on the good guys and a reason to give up by the growing majority.
Interestingly in a meeting of senior H&S professionals this week a number agreed that the advice they give to clients who need to prequalify according to the industry schemes (CHAS, Safe COntractor, Achilles etc) is now to treat that as a commercial barrier to bidding and absolutely nothing to do with H&S management in practice.
Other H&S professionals in rail, offshore and nuclear risk management who are paid silly sums of money have said of any record of course that they can prove anything I ask of them. No one understands or is interested in the numbers or the complex words. They work backwards from the paying client desired answer.
These are practical examples of the fact that huge swathes of H&S are a waste of resource.
Derek provides us with an example of a niche specialist area where there is no specialist agreement. How on earth is the poor CDMC supposed to wend his/her weary way through it all?
As for the technical point I would put my money on the guys who do this day in day out and are really very keen not to hurt one of their colleagues while they are doing it. Bring them together and get a view on how to proceed with good sense and I say that works for me.