Hull: The city of health and safety culture

Any play-centre operator worth their salt must consider the health and safety of their customers a top priority, and the very best tell us they work closely with the environmental health team at their local authority to help ensure this. So Indoor Play spoke to Julia Deighton (JD) and Khaled Choudhury (KC), health & safety officers at Hull City Council to find out more about their role in indoor-play safety including a recent initiative to reduce accident rates after a child was left hanging by his neck due to a loose piece of twine in one play centre in the city

So what does the health and safety team in Hull do and what is your relationship with the Health and Safety Executive (HSE)?

KC: The two main bodies that enforce health and safety legislation are the HSE and local authorities, normally through environmental health functions. Who enforces what depends on the main activity of the business. But for indoor play centres, it is local authorities (excluding county councils) that enforce health and safety law. This page on the HSE website makes it clear Our scope is broad, and includes investigating workplace concerns by anyone, investigating accidents, and delivering health and safety initiatives in the city, for example our indoor-play-centre initiative in 2016. We also provide advice and support to existing businesses as well as those that are just starting up.

What health-and-safety powers do you have?

JD: We have the right of entry to any premises that we enforce health and safety on; we can talk to anyone in the workplace to help fulfil our role; we can detain and seize items in the workplace. Where we find that there is an immediate serious risk of injury, we can issue a Prohibition Notice, and can issue an Improvement Notice on other risks that need addressing. Prosecutions can also be taken on the most serious cases.

Using an indoor play centre as an example, if we had serious health and safety concerns on play equipment or a play area and we were of the opinion that there was a risk of serious injury, we could issue a Prohibition Notice. This could mean that all or part of the play centre would have to stop operating, or taking a specific equipment out of use, so we do have strong powers to deal with matters which present a serious risk if necessary.

How do you use these powers in practice?

KC: In practice, we are pleased the vast majority of health and safety concerns are resolved to our satisfaction without the use of these powers. We find that when we investigate the concern, the majority of businesses respond positively to advice and informal action and address the concerns within a reasonable time period. We make the business aware that we can take formal action if they fail to address the concerns.

Of course, there are situations when we have to take formal action and concerns that we have dealt in indoor play centres include hygiene and cleanliness issues such as human excrement, mice droppings, damaged play equipment, lack of supervision, inadequate checks and electrical safety risks.

Why did you carry out the initiative on indoor play in Hull?

JD: We reviewed our RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) incident notification for the year 2015-16 and noticed that accidents to children accounted for over 10% of the reportable accidents to members of the public in the city.

At the same time, a concern was received from a member of the public, who happened to be a Hull City councillor. They had taken a child to an indoor play area and was concerned about the premises being dirty and poorly maintained, with holes in netting and equipment. This was the same centre where the child was left hanging.

What were the aims of the initiative?

KC: The aims were threefold:

• Improve awareness and management of health and safety risks

• Improve levels of compliance

• Promote good practice within the sector including awareness of industry guidance and good practice

How did you carry out the initiative?

JD: We visited 11 premises in the city with children’s indoor play equipment, ranging from small areas in the corner of a pub to purpose-built play centres and trampoline parks between June and August 2016. It was physically quite demanding; crawling through tunnels and rollers, climbing up netting, going down slides, parting matting, reaching through netting to see if anything not involved with the play area could be touched.

We also reviewed centres’ risk assessments for the play centre, as well as their in-house maintenance procedures, and methods of recording and dealing with maintenance defects. It is the responsibility businesses themselves to produce risk assessments and the guidelines to follow to identify risks are what’s required under the Management of Health & Safety at Work Regulations 1999.

What did you find?

KC: We found some recurring issues during the physical tour of the play areas. These were:

• Many lengths of unravelled twine long enough to wrap around a child’s neck.

• Holes in netting big enough to get a child’s leg through, some of these at a high level too.

• Small objects that could cause choking to small children such as sweets, lolly sticks, money.

• The possibility that children could reach electrical equipment and other potential hazards through the netting.

• Filthy play areas. Between mats inside playframes and in ball pools we found hair, sweets and wrappers, money, dust, hairclips and bobbles, lolly sticks, till receipts, dummies and small toys.

We found that although businesses had systems in place to ensure maintenance and safety checks were carried out, the effectiveness of these systems varied. For example, the amount of time allocated to pre-opening checks, and the quality of checks generally, were inadequate in some establishments.

How were the issues resolved?

JD: For some of the problems we encountered, where we felt someone could get injured, we had to ask staff to deal with them immediately. For example, lengths of twine had to be re-fixed or cut as appropriate, larger holes that a child could fall through or get limb stuck in had to be re-knotted.

We found some damaged play equipment that had very sharp metal edges which were accessible and the equipment wasn’t working properly which may have encouraged someone to try to release it themselves when it got stuck so causing cuts and trapping. The management in this instance closed that particular area until it was safe to re-use it, and we did not have to require them formally to close it with a Prohibition Notice.

The same play area had a double-slide that had the packing missing from between the two slides, where a child could have become trapped and again access to this area was prevented until the packing was repositioned and this was done before we had left the premises.

Some centres had equipment or furniture too close to the play structure so that if a child ran or fell against the netting, they would injure themselves by coming into contact with the equipment or furniture. We asked staff at the time of the visit to move these.

An Improvement Notice was issued on the play centre where the near strangulation occurred. And all play centres were sent letters requiring them to take action to address the concerns.

We did revisit the play centres following the initial visit, and found that the vast majority of concerns had been addressed by the businesses.

What else did you find out?

KC: We found that the smaller play centres often lacked a good understanding of the health and safety risks and controls. And while larger play centres had identified the risks and controls as part of their risk assessment, they were not putting their own measures in place effectively.

What do you feel this initiative achieved?

JD: We can be confident that the initiative has raised awareness, improved standards and helped promote good practice in Hull, in line with our three broad aims. For example, more thorough checks are now carried out internally in play centres; independent inspections by external bodies are now being carried out periodically; the staff and management that are running the play centres are now more skilled and know what issues to look for; and risk assessments have been reviewed.

We have certainly noticed a reduction in the number of incidents notified to us and of any concerns, relating to indoor-play centres being reported to us.

What do you think is the key to successfully managing health and safety risks in indoor play centres?

KC: There are number of key ingredients. However, from experience, there needs to be good leadership on health and safety from the top of the organisation. This, along with developing a good health and safety culture across the organisation, should make managing health safety risks easier for everybody.

Where can indoor-play centres find advice and guidance on health and safety?

JD: As well as the HSE website which has up-to-date general information, there are a number of more detailed industry specific standards that are also available, for example BS 8409:2008 - Fully Enclosed Play Facilities. In addition, play centres can also contact their local council’s environmental health department for advice.

And what’s next for your team at Hull?

KC: The play-centre sector is constantly changing, and businesses are exploring new opportunities, for example, indoor trampoline centres are increasing in numbers. We would like to do a similar project in the future and also share the findings and good practices with the industry.