Contrary to claims made by other Trade Associations that the HSE has ‘published’ new guidance on Plans of Work, this is not the case. The claim is in relation to the final draft of a piece of guidance that was given a limited circulation on the 25th September.
HSE has said that the plan is for the final draft to go to HSE’s Publications Governance Group this month (October) for permission to publish. It will most likely be published as an Operational Circular (OC), this means it will be internal instructions and guidance for HSE to use to carry out its operational work of inspecting, investigating, permissioning and enforcing. It will be transparent instructions to regulators.
HSE has said that it would be preferable if we didn’t distribute the guidance in its draft form to members, as in theory someone could still alter it or say there is no resource to publish. Until it goes through the complete permission process things remain uncertain, and HSE field inspectors cannot be fully briefed. If/when approved, HSE will have to decide if and when they have the resource to publish. HSE has said that if the permission process runs smoothly if should not be too long before publication.
ARCA has decided to ensure that the guidance is in its final form, that is, approved and published by HSE, before notifying our members, so in compliance with HSE’s wishes.