LTB:H&S reps Taking Photographs on Royal Mail Premises

[POSTMAN]

No. 913 /12

Dear Colleagues,
Re: Health & Safety Reps Inspections & Investigations - Taking Photographs on Royal Mail Premises - Royal Mail Group Code of Business Standards:


Following the recently published and circulated "Royal Mail Group Code of Business Standards", a number of Area Safety Representatives have contacted the Health, Safety & Environment Department regarding problems being experienced with some operational managers in relation to the taking of photographs on Royal Mail premises, as part of their legally enforced Safety Representatives functions.


The "Code" makes reference to restrictions on staff using personal cameras on Royal Mail sites or operations on page 35 and is obviously in relation to and in connection with employees not jeopardising business security and is certainly not in connection to a Safety Representative discharging his/her legitimate legally enforced functions as set out in the HSAW Act 74 and SRSC Regs 77. However, some managers who do not understand this and may be obstructive and attempt to place restrictions on a Safety Representative which could cause conflict and potentially be breaking the Law.



The use of a camera by a 'credentialed' CWU Area Safety Representative is a perfectly legitimate practice and is a tool used by our ASRs right across the UK for the benefit of improving the safety and wellbeing of Royal Mail employees. As such basic tool greatly benefits Royal Mail as an employer in dealing with clearly identified Safety issues found on Inspections and Investigation.



A camera is a very useful tool and the Health and Safety Executive (HSE) actually recommend that Safety Reps carry and use a camera on Safety Inspections and Accident Investigations. In most cases Management usually appreciate the provision of photographs from Health and Safety Reps to support Inspection and Investigation Reports. One good example was the photographs taken by our ASR following the Croydon IPS Sorting Frame Collapse incident and accident near miss. In this case the collapsed, wrecked Sorting Frame had been cleared up and repaired prior to the arrival
of Senior Managers sent to Investigate the incident and Inspect the Frame. The photographs taken by the CWU ASR were therefore invaluable and were used in a Nationally circulated Royal Mail Safety Bulletin. The Royal Mail HQ Senior National Delivery Manager stated in a communication to CWU/HQ Health, Safety & Environment Department "We needed to act swiftly. Thanks for your communication, photos and assistance which is hugely appreciated).






Additionally, the WCM OPL (One Point Lesson) safety system now being used widely in Royal Mail as well as the new Safe System Of Work (SSoW) format now includes the use and inclusion of lots of photographs, taken on Royal Mail sites.






The use of a camera is for example referred to in HSE Publication HSG246 " Investigating accidents and incidents: A workbook for employers, unions,
safety representatives and safety professionals".





The use of a camera is also included on training courses for both Safety Managers and Safety Representatives.







Photographs are now commonly and widely used by our ASRs which enhances their reports and benefits Royal Mail management when processing Inspection and Investigation Reports etc and we cannot have a situation where Safety Reps are obstructed in any way and we cannot have a situation whereby they have to seek permission on every occasion either as this would again cause obstruction, delays and enable recalcitrant managers to simply refuse in order to prevent issues being reported effectively.





The CWU can of course accept that business security must be respected and understand that Royal Mail wish to control 'social photography' which
can on occasion be misused if individuals act irresponsibly which is something we would not support however, a credentialed, authorised Health and Safety Rep going about his/her legal functions is entitled and encouraged to use a camera to capture issues, hazards, dangers, risks which subsequently form part of representations to Royal Mail at various levels for remedial action following Safety Inspections and Investigations etc.






In order to clear this matter up, discussions have taken place with Shaun Davies Royal Mail Group Director of Health & Safety. Mr Davies has subsequently sent the attached communication to the CWU Health, Safety and Environment Department that he is happy to support this message and reinforce the appropriate use of cameras by Safety Representatives.





Yours Sincerely
Dave Joyce
National Health, Safety & Environment Officer

[Sidley]

So the screws are 'misinterpreting' the restrictions on using cameras on RM premises to stop H&S reps acquiring evidence, under the guise of security? How does anyone expect us to trust any of the tw@ts enough to work with them even if they start behaving themselves, in light of their underhand lying cheating self serving fraudulent history?

[droopydrawers]

I recently had instance to take photos of a member of staff sitting on perstop trays. It sort of blew up and resulted in me having a talking to about not taking photos of people without their permission...... Err can I take a photo of you breaking guidelines??? I can take photos of the equipment because it doesn't complain!!

Told manager it would be a "he said she said" situation. In our place the HE would win!!

Thanks for this post as I now have the proof I need to continue (not that I was going to stop) taking photos.