A1 Principles of H&S Management

Question 0

Ill health caused/worsened by work is a greater cause of harm to workers than traditional safety causes such as falls from height or machinery accidents.
Identify national data sources AND give examples of conclusions that have been drawn from these sources, which support the statement above. (8)

Answer 0

 HSE publish annual injury and ill-health statistics
 Labour Force Survey data (published by HSE) indicates scale of occupational ill-health;
 the above shows large numbers (approx 2 million) of people suffering from work related ill-health;
 some ill-health data from health service reporting;
 some ill-health data from occupational physicians;
 some ill-health data from RIDDOR;
 mortality and disease rates from the Office for National Statistics (ONS); Cancer/COPD deaths far greater in numbers than other causes like falls etc;

Question 1

An employee has suffered long-term lung damages from exposure to hazardous substances at his work. He has been moved to alternative work.

Outline the types of cost to the employer which may arise from this situation. (12)

Answer 1

 Compensation costs
 Legal fees
 Medical/treatment costs
 Loss of production
 Lost time for medical assessment
 Overtime costs for cover;
 Costs for new worker; cost for employee moved to new job;
 Investigation time;
 Clerical effort; fines/prosecution costs;
 Fee for intervention by enforcements;
 loss of expertise;
 loss of goodwill by customers/stakeholders;
 Reduced productivity by fellow workers; health screening by
other exposed workers;
 Increased insurance

Question 2

An organisation may move from a health and safety management system based on HSG65 to BS OHSAS 18001.
Outline possible advantages AND disadvantages of change.

Answer 2

Benefits:

• Easier Integration with other standards
• Generate publicity
• Perception of the organisation is improved
• 18001 is an internationally recognised standard;
• 18001 is easier to benchmark and audit;
• Can be externally verified and certified

Disadvantages:

• Change is time-consuming and expensive
• May require additional paperwork and skills for chance
• 18001 may not be appropriate for Small to Medium businesses (“over the top”);
• as HSG65 is the “official” standard used by the HSE it will still be the “reference point” for their inspection / audit / investigation;
• It can lose its identity and be audited by non specialists

Question 3

Outline ways in which a H&S practitioner could evaluate and develop their own practice.

Answer 3

Evaluate

• Health and safety performance levels of an organisation reviewing the impact of changes / recommendations / interventions they have made to a business;
• Setting personal objectives / goals / targets;
• Monitoring / reviewing their performance against Targets they set
• Benchmarking their performance against recognised professional standards (eg IOSH)
• Benchmarking against approved codes of practice
• Appraisal with managers
• Feedback from customers
• Reviewing failures / accidents
• Seek advice from other H&S professionals

Develop
*Develop (= improve / enhance) their own practice by:
Studying
Gaining a recognised qualification
Update Continual professional development
Attend IOSH meetings/conferences ensuring access to relevant up-to-date information
Going on placements for other organisations.

Question 4

Explain why organisations identify costs of health and safety control measures more easily than the costs arising from poor health and safety standards.

Answer 4

H&S control measures treated as “overhead” and the amount spent is easily calculated.
Costs from poor health and safety can take many years to show (Civil claims)
Some are indirect so not easily recognised—
Reputation damage
Cost of recourses
Poor health and safety culture
Loss of experience
Lost orders/contracts
The costs of resources expended following all of this up

Hard to calculate the savings made from GOOD health and safety as this is usually a negative—I.E ZERO accidents is hard to quantify

Question 5

Outline, with examples, the meaning of the terms `insured’ and ‘uninsured’ costs in connection with accidents and incidents at work and describe the relative size of these two costs in an organisation, as demonstrated by accident costing studies.

Answer 5

Insured costs are those costs / losses that are recoverable via an insur-
ance scheme eg
1. Employer’s liability (compensation / damages);
2. Public liability
3. fire insurance

Uninsured costs are those that are not recoverable via
an insurance scheme eg
1. FINES imposed for breaches of the relevant statutory provisions;
2. Damage to corporate image / reputation;
3. lost time; clean up costs

Uninsured costs may be between 8-36 times greater than insured costs
(Reduce risks - cut costs. INDG 355 2002)

Question 6

Regulation 7 of the Management of Health and Safety at Work Regulations 1999 requires that employers appoint persons to assist them in complying with their legal health and safety obligations.

(a) Outline the main requirements of this regulation. (4)
(b) Outline the key areas of strategic involvement of the health and safety professional with respect to developing and maintaining an employers’ health and safety management system.

Answer 6

Key legal requirements of MHSW reg 7:
H&S advisor must be competent;
Must appoint one or more persons as necessary;
Arrangements for cooperation if 2 or more are appointed;
The numbers of H&S Assistants and time available is to reflect organisation’s size and risk
Information on health and safety issues to be provided to external appointees;

Preference for internal appointment(s); information on temporary workers; exemptions for partnerships where one partner is sufficiently competent.

(b) Key elements of strategic role include:

Formulating and developing elements of the health and safety management system;
Developing/agreeing a suitable safety policy statement;
Developing plans for and accident investigation;
Involvement inspections and audits;
Developing plans to improve safety culture;
Organising and participating in reviewing the health and safety arrangements;
Managing relationships with HSE, Environment Agency and Council etc
Advising senior management on short and long-term targets for improvement

Question 7

The senior managers at your workplace participate in formal annual reviews of health and safety performance as part of the health and safety management system. Outline the types of information that should form the inputs to this review process.

Answer 7

Reactive/proactive performance measures with 2/3 specific examples of each.

Current site health and safety objectives; the extent to which these objectives have been met.
Results of internal/external audits.
Organisational changes that may have impacted on health and safety performance.
The results of employee participation and consultation.
Changes to law, external standards, expectations.
Benchmark information from other similar organisations or sites, national statistics.
Conclusions and actions from previous reviews.

Question 8

As the Health and Safety Adviser to a large organisation, you have decided to develop and introduce an in-house auditing programme to assess the effectiveness of the organisation’s health and safety management arrangements. Describe the organisational and planning issues to be addressed in the development of the audit programme. (20)

Answer 8

Staffing/time/resources and whether additional resources are needed time, money, expertise.
consider whether internal / external auditors should be used to administer the process;
if in-house consider training needs;
the need to consult with and obtain support from senior managers
nature of the audit procedure eg full audit - all H&S management issues across entire organisation;
horizontal audit - looking at a particular issue eg managing emergencies across the whole organisation;
vertical audit - focussing on H&S management issues in a particular department / section etc;
consider the scale / scope of the audit - all issues covered or certain issues targeted - eg policy documentation; frequency of auditing required (relative to levels of risk in the organisation);
the standards against which the management arrangements would be audited - BSEN / Trade Association standards
the need to identify the key elements of an audit process (such as planning, interviews, verification, feedback routes, etc); consider issues such as need for a system of scoring / rating performance - qualitative / semi-quantitative

Question 9

(b) Outline FOUR proactive (active) monitoring techniques which might be used to assess the organisation’s health and safety performance.

Answer 9

 Workplace inspection
 Safety survey
 Safety sampling -
 Review of documentation - policy, risk assessments,
 Job Safety Analysis - observation of work activities / behavioural safety assessment etc - compliance;
 Safety “climate” analysis - interviews / questionnaire / survey - staff attitudes;
 Review against 18001 or HSG65
 benchmarking against a validated internal or external standard OR other organisations
 Measuring if targets have been met which were set by the organisation

Question 10

A large public limited company has recently experienced a fire and explosion resulting in multiple fatalities and extensive environmental damage.
(a) Outline a range of consequences that may affect the company as a result of the incident. (5)

Answer 10

(a) Consequences of incident include:

1. Criminal prosecution and penalties
2. Civil claims
3. Clean up cost
4. lost production / orders
5. Time/Money on investigation,
6. Reputational damage
7. Higher insurance / difficulty in insuring
8. Damage to staff morale / confidence
9. Difficulty in retaining / recruiting staff
10. Restrictions imposed by regulators (licences / permissioning regimes)

Question 11

Explain the benefits of:

a) an integrated health and safety, environmental and quality management system. (10

Answer 11

(a) Benefits of an integrated management system can include:
1. Consistent format
2. lower overall cost
3. Avoids duplication of procedures, record-keeping etc
4. Broadening the benefits from good management systems in all areas
5. Encouraging closer working and equal influence amongst people
from each area;
6. encouraging the spread of a positive culture across all three
areas
7. Providing easy integration of other risk areas such as security or
product safety.

Question 12

Outline how safety tours could contribute to improving health and
safety performance AND to improving health and safety culture
within a company.

Answer 12

highlights compliance or non-compliance;

1. Provides an opportunity to challenge unsafe actions
2. Identifies patterns and trends and common organisational problems;
3. Raises awareness of Health & Safety issues;
4. Checks effectiveness of actions put in place;
5. Helps to prioritise actions and resource allocation

Safety tours can improve H&S culture by:

1. Demonstrating organisational / management commitment
2. engaging staff ;
3. Giving Ownership of health and safety;
4. raising awareness of H&S issues;
5. improving perception / attitudes / motivation / behaviour;
6. providing opportunities for consultation / communication;

Question 13

Outline the issues that should be considered when planning a health and safety inspection programme.

Answer 13

WHO: who is to be involved Composition & competence requirements of inspection team

WHAT: the scope of the inspection programme The range of activities / processes / to be covered by the inspection; employees / contractors

WHEN: planned programme or random / unannnounced;
The frequency and timing of the inspection to cover shifts, “out-of-hours” maintenance activities / shutdown;
more regular in safety-critical environments;
previous data - accident / ill-health records / trends

WHERE: the sites / locations to be inspected

HOW: the methods of recording data - checklists / observation / scoring / rating

The training needs of the inspection team; the equipment needs of the inspection team - PPE etc; the need for consultation and support / involvement of management / staff - team meetings / briefings / newsletters etc; applicable legal standards (COSHH R 9 LEV); industry standards / requirements of insurers;

Question 14

(a) Outline the strengths of using accident rates as a measure of health and safety performance (2)
(b) Outline the weaknesses of using accident rates as a measure of health and safety performance (8)

Answer 14

(a) Strengths;
1. measurable number with defined criteria,
2. easy to plot a trend, benchmark data may be available, represents categories of loss events which have actually happened, and which are
undesirable.

Weaknesses:

1. cannot predict future performance;
2. It measures previous not current safety measures effectiveness
3. accidents may not be reported
4. absence of accidents does not necessarily indicate that procedures are safe;
5. does not reflect chronic health issues;
6. different definitions of ‘accident’ / different treatment of part-time workers / contractors may make data and / or comparisons invalid.

Question 15

Your company employs 900 people at a warehousing and distribution site. Your site manager has asked for a set of summary information to be provided each month for its executive meetings in order to monitor the overall health and safety performance of the site. Outline the possible contents of that set of information.

Answer 15

Reactive:

1. numbers of accidents / ill-health / sickness absence / absenteeism /
2. staff turnover / near-misses / numbers of RIDDORs
3. Number of enforcement actions taken;
4. civil claims;
5. amount of property damage;
6. responses to staff surveys / questionnaires – levels of (dis)satisfaction.

Active:

1. numbers and outcomes of workplace inspections;
2. numbers of actions outstanding;
3. health surveillance data / records;
4. results of atmospheric / environmental monitoring; - air; noise etc;
5. H&S training records
6. tenders won where H&S standards / performance was a factor; l
7. level of maintenance carried out;
8. budget / resources allocated to Health and Safety;
9. progress in meeting H&S targets;
10. levels of hazard reporting;
11. extent of co-operation between staff & managers

Question 16

An employer wishes to build a new gas compression installation to provide energy for its manufacturing process. An explosion in the installation could affect the public and a nearby railway line. In view of this the employer has been told that a qualitative risk assessment may not be adequate and that some aspects of the risk may require a quantitative risk assessment.
(a) Explain the terms “qualitative risk assessment” and “quantitative risk assessment”.

Answer 16

1. Qualitative RA is a subjective evaluation of risk
2. its based on estimation of (likelihood) and severity
3. high / med / low OR 1-5 (subjective score / rating)
4. Quantitative RA = is a numerical evaluation of risk
5. Its based on verifiable data such as those used in Fault Tree Analysis and Event Tree Analysis,
6. Used in safety-critical environments

Question 17

Witness interviews are an important part of the information gathering process of accident investigation. Describe the requirements of an interview process that would help to obtain the best quality of information from witnesses.

Answer 17

 Interview ASAP (but allow delay for injury / shock);
 Allow adequate time for interview;
 interview one witness at a time; allow witness to be accompanied
by a colleague / union rep etc;
 establish rapport; put interviewee at ease; explain purpose of inter-
view (to gather info / evidence / facts; don’t allocate blame
 explain need to record interview - evidential basis;
 open questions / allow interviewee time to answer;
 listen carefully to responses and respond appropriately;
 don’t interrupt / don’t prompt / don’t draw unwarranted conclusions;
 allow use of sketches / photographs / plans etc to assist establish
facts;
 ensure suitable environment -private, quiet, comfortable, no
interruptions;
 summarise and check agreement at end; thank witness for assistance

Question 18

Explain the ‘domino’ and ‘multi-causality’ theories of accident causation, including their respective uses and possible limitations
in accident investigation and prevention.

Answer 18

Domino theory: Heinrich’s five-step model:
ancestry / social environment - fault of person - unsafe act / condition - accident - injury.
Subsequent developments of Heinrich’s model by Bird and Loftus: lack of management / organisational control – basic causes (personal / job factors) - immediate causes (unsafe acts / conditions) - accident - loss.
Bird and Loftus variant is an advance on Heinrich as it takes account of organisatiomal / management failures / underlying causation.
Uses: both theories provide a basis for structured accident investigations.
Limitations: both models encourage simplistic, sequential / straight-chain thinking that imply the removal of a single link can prevent accidents; as such tend to restrict the search for multiple accident causes; Heinrich model in particular encourages a focus on immediate causes (acts / conditions) rather than underlying causation (faults in planning / design).

Multi-causality theory: model developed by Prof James Reason - based on recognition of multiple underlying (organisational, cultural or managerial) failings that interact with each other and with local circumstances to produce accident events at unpredictable times and locations; each cause may have multiple causes of its own; characterised by randomness and complexity; emphasises the need for indepth accident investigation; provides a basis for systematic accident analysis techniques such as fault tree analysis / event tree analysis; provides a link between the number of underlying failings in an organisation and the probability of accidents occurring.
Limitations: complex / conceptually difficult; requires greater resource - expertise / time money; diffficult to define boundaries of investigation.

Question 19

A forklift truck is used to move loaded pallets in a large distribution
warehouse. On one particular occasion the truck skidded on a patch of
oil. As a consequence the truck collided with an unaccompanied visitor
and crushed the visitor’s leg.
(a) Outline reasons why the accident should be investigated. (4)
(b) The initial responses of reporting and securing the scene of the ac-
cident have been carried out. Outline the actions which should be tak-
en in order to collect evidence for an investigation of the accident. (8)

Answer 19

1. to identify breach of law, effectiveness of management
2. To obtain information for insurers, claim for damage to plant, possible civil claim, criminal defence;
3. Identify causes (immediate and underlying)
4. Prevent it happening again
5. To show management commitment, restore employee morale
6. To collect Data for accident costing
7. To Identify of trends
8. To Identify need to review risk assessment.
9. Photograph, sketch, measure relevant parts of accident scene, CCTV;
10. examine condition of FLT (brakes, steering, tyres, horn etc);
11. inspect maintenance records, defect reports (previous FLT oil leakages),
12. are daily check sheets used;
13. reason not used on this occasion;
14. inspect/examine loads carried (safe working load)
15. examine working practices, time pressures, overtime records
16. ; examine operating procedures, written instructions, visitors procedures, risk assessments;
17. View competence of operator training records;
18. interview relevant people examination of workplace/environment,

Question 20

An investigation reveals that there have been previous forklift truck
skidding incidents which had not been reported and the company
therefore decides to introduce a formal system for reporting ‘near
miss’ incidents. Outline the factors that should be considered
when developing and implementing such a system. (8)

Answer 20

1. The Definition of a ‘near miss’ should be defined
2. Should consult with employees
3. Provide Information, training for employees
4. No blame culture;
5. Make system easy to report
6. Ensure employees know who they report too
7. Identification, implementation of actions
8. Have a reporting back system to tell people what has been
   done once they have reported somehting
9. Collate reports on incidents
10. Define a person to implement it
11. Monitor actions that are put into place
12. Measure Cost of implementing it
13. What resources are needed

Question 21

Outline a range of external individuals and bodies to whom, for legal or good practice reasons, an organisation may need to provide health and safety information AND in EACH case, state the broad type of information to be provided.

Answer 21

1. Health and Safety Exec - accident reports / RIDDOR; H&S policy; risk assessments; accident book
2. Insurance companies - accident reports; H&S policy; risk assessments; SSW; PTW;
3. Courts - legal proceedings / statements / disclosure - criminal and civil;
4. Contractors - induction, site rules, PTW procedures etc;
5. Clients - during selection process - policy, risk assessments, enforcement record;
6. Customers - Health and Safety at Work Act Section 6 information re safety of goods, articles, substances;
7. Professional bodies - IOSH etc - in relation to campaigns / research
8. The emergency services - COMAH; emergency planning; stock of chemicals etc;
9. Training organisations - before sending people on work experience - H&S (Training for Employment) Regulations;
10. Employees - HSWA S2 & MHSWR - information on risks to their H&S etc. Also H&S (Information for Employees) Regulations - H&S at Work poster - specific info

Question 22

(a) Organisations are said to have both formal and informal structures and groups. Outline the difference between “formal” AND “informal” in this context.

Answer 22

Formal =

1. Hierarchical
2. well-defined structure,
3. roles and responsibilities, lines of communication
4. Organisation charts

Informal =

1. social and personal relationships or contacts
2. Is based on individual / personal influence;
3. less structural
4. can act so as to by-pass formal systems and procedures
5. Can be undermining to defined roles and responsibilites

Question 23

Outline how the H&S professional can help to develop and support the
arrangements for consultation with employees on H&S matters.

Answer 23

1. Initially, the health and safety professional might advise on the requirements of the Safety Representatives and Safety Committees
   Regulations and the Health and Safety (Consultation with Employ-
   ees) Regulations
2. Advise on the good and accepted practices to be followed both by
   safety committees and safety representatives;
3. Make proposals for local arrangements for formal consultation;
4. offer advice and support for the training arrangements of safety
   representatives and representatives of employee safety
5. arrange for the necessary resources to be provided to enable them
   to carry out their duties.
6. Encourage senior management to take an active part in both formal and informal consultation and to respond promptly to proposals made and concerns expressed during the consultation process.

Question 24

Explain the benefits of a separate health and safety, environmental and quality management systems.

Answer 24

(b) Benefits from retaining separate systems might include: One system may be more complex than the other areas For example safety is underpinned by legal requirements but quality is not The need for a complex system in safety module does not mean a complex approach is required for quality Existing systems may work well and the process of integration may use extra cost and extra resources Integration may affect their overall effectiveness; Separate systems might be clearer for external people to work with encourages a more detailed approach to auditing each individual system separate systems might be clearer for external auditors to work with Encourages a more detailed approach to auditing the standard in question.

Question 25

The HSE publication “Successful H&S Management” (HSG65) describes a model of H&S management in which the “organising” element requires control, co-operation, communication and competence. Outline using practical examples, what “co-operation” means in this context.

Answer 25

``` Co-operation involves: Consultation with workforce (formal & informal) staff discussion / team meetings staff surveys questionnaires  casual discussions; staff involvement / participation in: Risk Assessment , Safe systems of work  inspections,  monitoring,  audits,  investigations,  campaigns, receiving and delivering training ```

Question 26

Organisational change can, if not properly managed, promote a negative H&S culture. Outline reasons for this.

Answer 26

1. Change can result in lack of focus on H&S matters - other issues take priority; 2. loss of skills / competence (staff leave/move); 3. require people to take up new roles for which they lack competence; 4. uncertainty about future - redundancy etc results in a lack of confidence / mistrust of management 5. perception that H&S is not a concern; 6. increased outsourcing - contractors etc bring a different culture; 7. movement of staff breaks up units / groups and undermines established systems / culture; 8. breakdown in normal arrangements for consultation and communication with staff; 9. new relationships need to be established; 10. re-allocation of budgets; 11. New ways of working may result in unforeseen hazards / risks arising; 12. increase in accidents / ill-health due to disruption - 13. reduced morale; 14. staff resistance to change

Question 27

Health and Safety at Work Act presents a number of opportunities for individuals to be prosecuted for breaches of duties under the Act. Assuming that the individuals are employed within a large company, outline the circumstances under which they may be prosecuted for such breaches.

Answer 27

Section 7 - employees - 1. failure to take reasonable care of themselves and other s who may be affected by their acts / omissions at work; 2. failure to co-operate with employer Section 8 - any person - 1. interference / misuse of anything provided for a H&S purpose; Section 36 - offence due to act / default of another person - 1. eg supervisor / manager instructs employee to use unguarded machine Section 37 - offence committed with consent / connivance or attributable to neglect of Director, Manager, Secretary etc Section 33(1) - impersonating / obstructing an inspector

Question 28

Explain with reference to case law, the meaning of the terms `practicable' and `reasonably practicable' as they apply to health and safety legislation. (

Answer 28

'Practicable' means that there must be compliance with the duty as far as technical and practical feasibility allows; within current knowledge and invention; with no reference to cost; though not an absolute duty, “practicable” is of a higher standard than that of 'reasonably practicable.' Adsett v. K&L Steelfounders and Engineers Ltd (1953), Marshall v Gotham [1954] 'Reasonably practicable' requirements are those 1. A balance is made between risk and cost (in terms of money, time and trouble) 2. be met when the cost of further control is grossly disproportionate to any reduction in risk. Controls in proportion to risk. Edwards v National Coal Board [1949]

Question 29

(b) Outline a range of organisational issues that may act as barriers to the improvement of the safety culture of an organisation. (8) Remember barriers must be NEGATIVE

Answer 29

1. Lack of resources assigned to health and safety- money, time, effort 2. Lack of training / competence in Health & Safety expertise 3. Lack of trust and confidence of the workforce in the ability of management to manage safety 4. Lack of effective communication on Health & Safety matters; 5. Management setting a poor example; 6. Lack of commitment of management and / or of the workforce; 7. Low level of motivation (at all levels); 8. Inconsistent decision making; 9. Unclear priorities - production v safety conflicts; 10. Established negative culture - peer pressure, blame culture etc 11. Resistance of both management and the workforce to change (possible impacts on productivity / pay / bonuses) 12. High staff turnover - makes it difficult to establish a fixed “culture”; 13. Low status of H&S and of the H&S advisor / dept; 14. variations in cultures / language etc of workforce; 15. Lack of expertise in implementing cultural change; 16. Multi-sites different attitudes

Question 30

Outline the types of information that should be included in written safe systems of work.

Answer 30

1. Clear description of the activity / area to which the SSOW applies; 2. Significant risks/hazards involved in the task; 3. people involved in the activity 4. Anyone who should be excluded from the activity (eg young persons, etc); 5. level of training or competence required; 6. arrangements for supervision; 7. arrangements for control or co-ordination of the work; 8. detailed risk control steps to be taken; 9. description of any plant and equipment required for the work; 10. description of any PPE required; 11. requirements for any job-specific instruction or briefing for those involved; 12. arrangements for communication between personnel involved in the work; 13. emergency arrangements; 14. Whether a PTW is required; 15. arrangements for safe completion/withdrawal of precautions; 16. arrangements for communication with others working in the area/who might be affected; 17. formal approval/signature of authorising manager/date; 18. review date

Question 31

Armour v. Skeen 1977 “Personal Liability of Executives” 1. Detail points of the case 2. Detail the outcome 3. Detail the section of the Health and Safety at Work Act that was breached

Answer 31

 A workman fell to his death while repairing a road bridge over the river Clyde.  Mr. Armour was the director of Roads for the regional Council  He had a responsibility for supervising the safety of road workers  He had not produced a written safety policy for such work. He was prosecuted under Section 37(1) of the Health and Safety at Work, etc. Act 1974 which imposes personal liability on senior execu- tives.  Mr. Armours’ defence was that he was under no personal duty to carry out the Council’s statutory duties, one of which was the formulation of a detailed safety policy for the roads department.  This was rejected  This he had failed to do and was therefore found guilty of an offence.

Question 32

Edwards v. National Coal Board 1949 Reasonably Practicable

Answer 32

 A miner was killed when a section of the road on which he was travelling collapsed.  The section of the road concerned had no timber supports, although other sections were properly supported.  The Coal Board stated that the cost of supporting all roads was disproportionate in relation to the risk.  Lord Asquith, the judge in the case, said that a balance had to be made in deciding whether it would have been reasonably practicable to have taken the precaution of providing supports for the section of road which collapsed.  The balance was struck by weighing the level of risk involved (the danger of collapse and loss of life) against the level of sacrifice involved (the cost, time and trouble).  If there was a gross disproportion between the two and the risk was insignificant to the cost, there would be no requirement to take the additional precautions.  However, in this particular case the costs of making safe should have been applied.