Occupational Health, Safety & Welfare Policy

www.orkney.gov.uk

IMAGE: The cover displays the Orkney Islands Council crest above a panoramic view of an Orkney town, with the title “Occupational Health, Safety & Welfare Policy” and the website “www.orkney.gov.uk”.

Contents

• Contents — 2
• Occupational Health, Safety and Welfare Statement of Intent — 4
• 1. Responsibilities for Health and Safety — 5
     • 1.1 Elected Members — 5
     • 1.2 Chief Executive — 5
     • 1.3 Corporate Directors — 6
     • 1.5 Line Managers — 7
     • 1.6 Employees — 9
     • 1.7 Safety and Resilience Service — 10
• 2. Arrangements for Health and Safety — 12
     • 2.1. Risk Assessments — 12
     • 2.2. Training — 13
     • 2.3. Consultation — 14
     • 2.4. The Orkney Islands Council Safety Committee — 14
     • 2.5. Health and Safety Representatives — 15
• 3. Health and Safety Approaches — 16
     • 3.1 Acts of Aggression — 16
     • 3.2 Asbestos — 17
     • 3.3 Management of Premises — 17
     • 3.4 General Arrangements — 18
     • 3.5 Monitoring and Review — 18

IMAGE: A small aerial photograph shows a causeway crossing shallow blue-green water between low-lying Orkney islands. Text at the bottom reads “Images courtesy of Orkney.com”.

Occupational Health, Safety and Welfare Statement of Intent

IMAGE: The statement of intent is presented over a photograph of a worker in high-visibility clothing. A central circle reads “Our People”, surrounded by circles labelled “Promote Unity”, “Reduce Accidents & work-related ill health”, “Provide Occupational Health”, “Manage Risks”, “Trust through Talking”, “Safe Working Environment”, “Provide Protective Equipment”, and “Taking Ownership”. The image is signed “Oliver Reid Chief Executive, Orkney Islands Council 2025”.

Our Occupational Health, Safety and Welfare Policy will prioritise our people by enhancing our comprehensive safety and resilience practices at Orkney Islands Council (The Council).

This will be achieved through building trust by means of:

• Reducing accidents, incidents, and work-related ill health by keeping all Council employees safe at work.
• Promoting unity throughout the Council where we value everyone’s welfare.
• Identify, assess and providing adequate control of occupational health and safety risks arising from our work activities.
• Ensuring risks are managed sensibly, responsibly and proportionately to eliminate or minimise the hazards.
• Fostering trust among our staff by ensuring clear two-way communication regarding instructions and information, while actively listening to their health, safety, and welfare concerns.
• Providing suitable and sufficient training, risk assessments, and methods of work to create a safe working environment.
• Providing Personal Protective Equipment (PPE) and the maintenance in accordance with current regulations of all plant and equipment.
• Assuming responsibility for the implementation of emergency procedures related to fire safety, first aid, and overall resilience.

Oliver Reid

Chief Executive

Orkney Islands Council

March 2025

1. Responsibilities for Health and Safety

1.1 Elected Members

All elected members are responsible for supporting the policies and strategic direction of Orkney Islands Council on behalf of their stakeholders. They must uphold health, safety, and welfare for themselves and others while fostering a proactive approach to these areas in the workplace.

This can be achieved through:

• Actively demonstrating support for health, safety, and welfare in their roles as elected members.
• Designating an elected member with specific responsibilities for health and safety oversight.
• Ensuring sufficient resources are allocated to assist the Chief Executive with health, safety, and welfare matters, particularly in exceptional or urgent situations, such as when exercising the Chief Executive’s emergency powers.
• Reviewing corporate and directorate reports related to occupational health, safety, and welfare.

1.2 Chief Executive

The Chief Executive, as far as is reasonably practicable, is responsible for ensuring the health, safety and welfare at work of all Council employees and others who may be affected by the Council’s work operations.

This will be achieved by:

• Visibly demonstrating personal commitment to achieving a high standard of Occupational Health, Safety and Welfare performance.
• Assigning ownership for the implementation of the policy to Corporate Directors and promoting a proactive culture amongst the Senior Management Team.
• Ensuring that adequate resources are made available to enable the Council’s policy to be implemented and to address any exceptional and/or urgent issues that arise when Council Services have exhausted all avenues within their power.
• Appointing a Corporate Director to champion an initiative-taking health, safety and welfare culture as the Chair of the Safety Committee, placing our people at the centre of all we do.
• The formation and maintenance of health and safety management systems within Services, which will ensure the assessment of risks and the effective planning, organisation, control, monitoring and review of the preventative and protective measures necessary to control the risks.

1.3 Corporate Directors

Corporate Directors are, as far as is reasonably practicable, responsible for ensuring the health, safety and welfare at work of all employees in their respective Services.

They should:

• Visibly demonstrate a united positive approach to achieving a high standard of health and safety performance within their services and promote a positive approach to health, safety, and welfare among their colleagues.
• Prepare and revise as necessary, service management arrangements which set out the organisation and arrangements within the Service through which the Council’s Health, Safety and Welfare Policy will be implemented.
• Put into operation health and safety management systems within Services, which will ensure the assessment of risk and the effective planning, organisation, control, monitoring and review of the preventative and protective measures necessary to eliminate or control the risks. Where this is not possible Council services should engage with the Chief Executive for guidance.
• Build trust amongst their service sectors with robust communication channels to empower staff to work together to improve health, safety and welfare.
• Identify causes of work-related ill health, promote a positive work environment and ensure sufficient resources are available to support a healthy work environment.
• Support the Council’s Safety and Resilience Service Manager in all matters of evaluation and advise to ensure legal compliance of each Service.
• Aid the Council’s Safety and Resilience Manager to prepare a biennial plan targeting health and safety improvements within each service.
• Hold a centralized Risk Assessment Register for their Directorate that is maintained and kept up to date.

Corporate Directors must put into practice systems through service management teams to ensure that all adverse events (near miss, accidents and incidents) occurring in areas of their responsibility are recorded, investigate, reviewed and reported to the Safety and Resilience Team in accordance with the Adverse Event and Investigation Reporting Guidance.

1.4 Head of Service Responsibilities

Heads of Service are, as far as is reasonably practicable, responsible for ensuring the health, safety and welfare at work of all employees in their respective services.

They are/should:

• Be responsible for the implementation, maintenance and monitoring the Health, Safety and Welfare Policy arrangements and supporting their team at an operational level.
• Ensure suitable welfare facility arrangements for the employees in their respective sectors.
• Ensure key occupational health and safety risks related to their service delivery and work tasks are identified, eliminated, reduced or controlled.
• Represent management at health and safety committees and provide adequate periods for employee’s safety representation to attend safety committee meetings.
• Ensure the availability of accurate and accessible information on work-related near miss, accidents, incidents and occupational ill-health, with the setting of clear priorities, targets and strategies for their reduction.
• Ensure effective management of employee workload to ensure that an appropriate balance is struck between work and life outside of work.
• Ensure proper control, including management, of all visitors and contractors’ activities at premises under their responsibility.
• Identify managers of premises to co-ordinate and control legal requirements of safety matters for the premises. For example, but not limited to, fire and first aid provision.
• Ensure that all Adverse Events (near miss, accidents and incidents) are recorded, investigated, reviewed and reported to the Safety & Resilience Team in accordance with the Adverse Event and Investigation Reporting Guidance.
• Provide clear lines of communication with employees on matters pertaining to health, safety and welfare to build unity and trust. This should include workplace meetings with employees, feedback from Safety Committee meetings, safety performance and information provided on safety matters relevant to their sector.
• Undertake assessment of the effectiveness of health and safety management within their related service. Ensuring that compliance checks on the health and safety management systems are received and corrective action implemented.
• Keep all employees, contractors and visitors safe whilst on their premises of responsibility with suitable and sufficient risk assessments that are annually reviewed.
• Ensure that all Line Managers produce suitable and sufficient risk assessments that are recorded in the Directorate risk register.

1.5 Line Managers

Line Managers are, as far as is reasonably practicable, responsible for ensuring the Occupational Health, Safety and Welfare at work of all employees, contractors and visitors under their responsibility.

They are:

• Responsible for ensuring that appropriate health, safety and welfare arrangements are in place for all employees, contractors, and visitors, ensuring that any health and safety responsibilities delegated to staff within their area are clearly identified, relayed and undertaken.
• The first point of contact to support their team’s welfare, health concerns and safety matters.
• Responsible for ensuring that all significant hazards and risks posed to employees, contractors and visitors are identified and suitable risk assessment(s) produced.
• Responsible for ensuring that all equipment, vehicles and plant are to be maintained in accordance with manufacturing guidelines, the Lifting Operations & Lifting Equipment Regulations 1998 (LOLER) and the Provision Use of Work Equipment Regulations 1998(PUWER). New equipment should be marked UKCA or CE supplied with a declaration of conformity and instructions in English.
• Responsible for ensuring the safe handling, transportation and exposure to substances that cause ill health are controlled in accordance with the Control of Substances Hazardous to Health Regulation 2002 (COSHH).
• Responsible for conducting return-to-work interviews that identify work-related ill health should be reported to Safety and Resilience to help determine how the risks associated with work-related ill health can be eliminated or minimised.
• Responsible for ensuring all employees are to be trained, remain current in their qualifications, adequately supervised, and receive suitable instruction to ensure that they can perform their duties safely and competently.
• Responsible for ensuring that all Adverse Events (near miss, accidents and incidents) are recorded, investigate, reviewed and reported to the Safety & Resilience Team in accordance with the Adverse Event and Investigation Reporting Guidance.
• Responsible for monitoring working conditions and environment, undertake and arrange, where appropriate, referrals, provision of access and health surveillance through a competent occupational health provider in accordance with legal requirements.
• Responsible for implementing and monitoring employee attendance management, regularly review workload and working hours in line with legal requirements and corporate policy taking remedial action where necessary.
• Responsible for ensuring compliance with all relevant Council policies, guidance documents and procedures.
• Responsible for encouraging every employee to co-operate in near miss, accident and incident reporting and prevention.
• Responsible for motivating and empowering employees to work in a safe and healthy manner to encourage a positive attitude towards health, safety and welfare in the workplace.
• Responsible for ensuring effective discussion and communication of health, safety and welfare with employees in a fair unbiased open discussion to encourage employee interactions. Issues raised or concerns should be brought to Head of Service attention with feedback given to employees as a regular update.
• Responsible for undertaking assessment of the effectiveness of health and safety management within their related service delivery.
• Responsible for conducting Good Conversation meetings with individual employees to receive feedback on health, safety and welfare.

All risked assessments should be reviewed on change of process/annually. Risk assessments should be communicated to all employees that are at risk from the identified hazard(s) and recorded on the Corporate Risk Assessment Register.

1.6 Employees

All employees will be expected to co-operate in the implementation of the Council’s Health, Safety and Welfare Policy by:

• Acting in the course of their employment with due care for their own safety, avoid unnecessary risk and that of others, who may be affected by their acts or omissions at work.
• Co-operating, as far as is reasonably practicable, to enable the Council to perform its duty or to comply with any requirements, due to health and safety legislation and in compliance with Risk Assessments, Method Statements, Safe Systems of Work, etc. and as instructed by a line manager or other appropriate delegated person.
• Familiarising themselves with the Occupational Health, Safety and Welfare Policy and all other safety arrangements in their workplace.
• Operating all work items provided by the Council in accordance with the training, instructions, manufacture guidelines, Safe Systems of Work, Risk Assessments and any other administrative controls they receive to provide a safe working environment.
• Reporting all near miss, accidents and incidents, when safe to do so, to the employee’s line manager to ensure accurate recording of Adverse Events and to enable the Accident Folder to be kept current. Employees are requested to assist the employer in all investigations concerning Adverse Events to identify the cause and reduce the risk of re-occurrence.
• Reporting work-related ill health, issues of welfare, workplace hazards and risks of exposure to their line manager without prejudice.
• Informing the Council without delay of any work situation which might represent a serious or imminent danger.
• Notifying their line manager or other appropriate delegated person of any shortcomings in health and safety arrangements, even when no immediate danger exists, so that the Council can take remedial action if needed. This would include reporting any near-miss incidents.
• Not compromising the health and safety of persons working with or around them through negligent acts or omissions.
• Completing all the required online iLearn health and safety training modules, including refresher training at the appropriate intervals, as well as any other training required by the Council.
• Taking reasonable care of their own health and safety.
• Wearing personal protective equipment (PPE) as instructed and reporting any lost, damaged, ill-fitting PPE to their line manager prior to commencement of work.
• Making themselves aware that suitable and sufficient PPE and Respiratory Protective Equipment (RPE) will be provided by the employer free of charge.

1.7 Safety and Resilience Service

To fulfil this duty the Safety and Resilience Team will:

• Provide competent occupational health and safety assistance to the Chief Executive, Senior Management Team and other members of the Council with an open-door approach to all Council employees.
• Be the competent person providing advice to the Council and information on current legislation.
• Develop corporate policy, procedures and guidance that will ensure compliance with statutory requirements and applicable codes of practice.
• Co-ordinate, interpret, progress enquiries from enforcing authorities and support Directorates in addressing actions.
• Independently assess health and safety management system compliance and conduct Health and Safety Audits within the Council.
• Undertake proactive and reactive monitoring, analysis and evaluation of health and safety performance to check compliance and identify remedial actions.
• Prepare an annual corporate health and safety management report and a biennial improvement plan intended to ensure that safety standards are raised or maintained throughout the Council.
• Actively promote and develop an initiative-taking, positive health and safety culture within the organisation.
• Assist in the enhancement of the organisations occupational health and safety management system to improve health and safety performance within the organisation.
• Conduct investigations into RIDDOR reportable incidents and other Adverse Events that they deem necessary to identify the root cause(s) and reduce the risk of accidents.
• Hold and maintain the Accident Folder for the Council where all Adverse Events within the Council are recorded and held centrally.
• Promote resilience within Orkney Islands Council in accordance with the Contingency Act 2004.

Safety and Resilience provide a comprehensive health and safety service offerings designed to proactively manage risks, ensure compliance, and promote the well-being of all employees. Our activities include:

• Risk Assessment Programme: Conducting regular assessments to identify and mitigate potential risks.
• Safety Training Initiatives: Providing comprehensive training programs tailored to various roles within the Council.
• Incident Reporting System: Implementing a streamlined process for reporting and analysing incidents.
• Health Surveillance Programs: Monitoring and promoting employee health through targeted surveillance initiatives.
• Emergency Preparedness Plans: Developing and communicating emergency response procedures, including a dedicated 24-hour emergency response contact point.

Corporate Directors, Heads of Service, and Line Managers should support the Safety and Resilience Team in delivering their duties to all OIC staff. This collaboration ensures effective service delivery and strengthens the overall safety and resilience of OIC.

Safety & Resilience can be contacted by e-mail: health.safety@orkney.gov.uk

IMAGE: A graphic shows two overlapping grey “HEALTH & SAFETY REPORT” documents with black-and-yellow hazard stripes along their lower edges.

2. Arrangements for Health and Safety

2.1. Risk Assessments

The identification and assessment of risks associated with all activities of the Council with the aim of eliminating or controlling the risks, as far as is reasonably practicable shall be undertaken through the production of health and safety risk assessments.

Employees have first-hand knowledge and experience of the risks involved with their work and should be consulted in the creation of risk assessments.

Employees are to raise any hazards or risks they identify with their Line Manger and request suitable risk assessments before starting the work they are assigned.

Risk assessments should be reviewed annually and on change of procedures effecting the risk assessment.

Additional Information on risk assessment is available in the OIC’s Risk Management Policy and Strategy, as well as the Health and Safety Risk Assessment Guidance.

Arrangements

Line Managers are responsible for ensuring that suitable and sufficient risk assessments, with reasonable precautions, are in place before employees start work.

All risk assessments should be recorded in the appropriate Corporate Risk Assessment Register.

2.2. Training

Senior officials (e.g., the Health and Safety Elected Member, the Chief Executive, Corporate Directors, and Heads of Service) should receive appropriate health and safety training and refresher courses to understand and fulfil their organisational and personal health and safety responsibilities.

Managers and supervisors should undergo relevant health and safety training specific to their areas of work to ensure statutory compliance.

All staff should receive appropriate health and safety training related to the hazards and risks identified through risk assessments in their workplace.

All staff, volunteers, and subcontractors should complete suitable induction training before starting work.

Corporate Services are responsible for developing, implementing, and providing corporate health and safety training programs to staff.

Council services must ensure that service-specific specialist training is available to staff.

The following is recommended as a starting point criterion for general Health and Safety training at the Council:

Corporate Directors must ensure that their employees receive all necessary health and safety training to perform their duties safely. Appropriate arrangements should be made to keep remote workers' training up to date.

iLearn - All Employees should complete:

• Core Health and Safety and Welfare
• Fire Safety Awareness
• Protect Against Terrorism
• Manual Handling
• Job specific training as required by risk assessment
• Essential development as identified by Good Conversation.

iLearn offers an online standard of health, safety, and welfare training for all employees. Depending on an employee's role and responsibilities, more detailed and advanced training may be necessary to supplement iLearn. For instance, iLearn's manual handling training for the Care Sector might require in-person practical sessions to minimise the risk of accidents in the sector.

IMAGE: A screenshot of the Orkney Islands Council iLearn platform shows a welcome page with “Welcome to Orkney Islands Council iLearn”, learning pathway and events options, new course tiles, and resource sections.

2.3. Consultation

All management levels within Orkney Islands Council will regularly consult with staff through workplace meetings. Occupational health, safety, and welfare should be a standing agenda item, allowing employees to discuss their concerns without prejudice. Issues raised should be addressed and communicated to employees. If necessary, significant items can be escalated to the OIC Safety Committee through safety representatives or management.

2.4. The Orkney Islands Council Safety Committee

The terms of reference of the Safety Committee have been agreed and are contained within the constitution which is available in the health and safety section of the Council’s Intranet. The main duties will be:

• To study accidents, incidents, work-related ill health, and notifiable diseases, statistics and trends, so that reports can be made to management on unsafe and unhealthy conditions and practices, together with recommendations for corrective action.
• To examine safety audit reports on a similar basis.
• To consider reports and information provided by inspectors of the enforcing authority under the Health and Safety at Work Act 1974.
• To consider reports which safety representatives might wish to submit.
• To assist in the development of works safety rules and safe systems of works.
• To monitor the effectiveness of the safety content of employee training.
• To provide a link with the appropriate inspectorates of the enforcing authority.

In the interest of promoting cooperation on health and safety with a fair and balanced approach, the Council established the Orkney Islands Safety Committee, known as the Safety Committee. This forum allows both Union and non-union employee representatives to raise health and safety matters, discuss accident statistics, training, legislation, and other concerns.

Items raised by employees to their Line Managers that cannot be resolved by escalation through the management line of communication or require further discussion can be addressed by the Safety Committee.

The minutes of the Safety Committee meetings should be readily available to all employees in either electronic format or print.

2.5. Health and Safety Representatives

Health and Safety Representatives on the Safety Committee can be either union appointed or a non-union representative of employee safety. The council encourages the appointment of safety representatives to enhance the engagement of its fellow employees in all matters pertaining to health and safety. Union and non-union representatives are governed by separate regulations and have differing rights in law.

The Council will consult with all safety representatives appointed by employees regarding:

• Introduction of measures which may substantially affect the health and safety of employees.
• Arrangements for appointing competent health and safety advisers and persons to implement emergency procedures.
• Provision of health and safety information and training required under the relevant statutory provisions.
• The health and safety consequences of new technologies introduced into the workplace.

The Council will provide such facilities and assistance as safety representatives may reasonably require them to carry out their functions.

Safety representatives appointed by recognised trade unions will be allowed to inspect any statutory document, which the Council is required to maintain and will also be given on request any information necessary to conduct their functions.

3. Health and Safety Approaches

The Council is committed to maintaining a safe and healthy working environment for all employees. We encourage staff to actively participate in health and safety discussions and report any concerns without hesitation. Regular consultations and risk assessments are conducted to identify and mitigate potential hazards. By working together and following HSE guidelines, we aim to ensure the welfare of everyone in the workplace.

Adverse reporting provides comprehensive guidance on the procedures for reporting incidents and concerns. This ensures that all employees are aware of the steps to take when encountering any issues, promoting a culture of transparency and accountability. Detailed Adverse guidelines are available to help staff accurately document and communicate incidents, accidents and near misses ensuring that appropriate actions can be taken to address and resolve any problems effectively. Adverse guidance is available on the intranet, through line management, and from the Safety & Resilience team.

The line of communication for health, safety and welfare items should be from the employee to:

1. Line Manager
2. Service Manager
3. Head of Service
4. Corporate Director
5. Chief Executive
6. Elected Member

The Safety & Resilience Team operates an 'open door policy' for any concerns raised by Orkney Islands Council employees. They can be contacted through various communication channels regarding occupational health, safety, and welfare.

Where there is a risk of a Dangerous Occurrence, the work should be stopped immediately, and the incident reported to a manager with Safety and Resilience informed.

IMAGE: A stepped diagram shows the communication route from “Line Manager” through “Service Manager”, “Head of Service”, “Corporate Director”, and “Chief Executive” to “Elected Member”.

3.1 Acts of Aggression

The Council will not tolerate any form of violence towards its employees and will take necessary actions to protect its staff. This includes verbal or physical violence, such as spitting, online harassment, malicious damage, or any form of aggressive behaviour.

The Council will:

• Proactively encourage the reporting and recording of all acts of violence.
• Provide support and guidance to reduce aggressive behaviour towards its employees.
• Offer training to staff who are at risk of violence.
• Continuously work towards reducing the risk of violence against its staff.
• Prevent violence through appropriate risk assessments and communicate control measures to staff exposed to the risk of violence.

3.2 Asbestos

The Council is committed to minimising, as far as reasonably practicable, the exposure of employees to disturbed or exposed asbestos in buildings, materials, or equipment.

Exposure will be reduced by:

• Identifying all locations containing asbestos, warning people about it and keeping it safe.
• Conducting surveys in all council properties to identify the presence of asbestos.
• Record all findings in the council’s asbestos register.
• Controlling works that expose staff or contractors by ensuring that:
  • A method statement is in place.
  • People are suitably trained.
  • Suitable decontamination procedures.
  • Disposal of materials has been arranged.
  • All relevant documentation is available.

3.3 Management of Premises

It is the responsibility of the person regularly managing a premises “duty holder” to ensure that the building and surrounding area provide a safe working environment for employees, visitors, the public, and contractors.

The term 'visitors' also includes students, pupils, residents, and service users.

The person managing the premises must ensure that the Fire Risk Assessment, First Aid Needs Assessment, and both Generic and Specific Risk Assessments are current, adequate, and appropriate for the work conducted on the premises.

The premises manager must have:

• A current Fire Logbook that is completed in accordance with the Fire Scotland Act 2005 and Fire Safety (Scotland) Regulations 2006.
• Knowledge of any Asbestos Containing Materials (ACM) within the premises and of the Asbestos Survey Report if Asbestos has been identified on the premises in accordance with Control of Asbestos Regulations 2012.
• Awareness of the Control of Substances Hazardous to Health Regulation 2002 and any compliance required for the premises.
• A system in place for reporting and monitoring building faults, damage and maintenance using the Property Management System and liaison with their associated Building Inspector.

3.4 General Arrangements

The Occupational Health, Safety, and Welfare Policy is supported by additional Council policies, guidance, and procedures that should be read alongside this policy. These documents are available on the council’s intranet, website, and through the Safety and Resilience team. Further advice can be sought from respective management within each Directorate and the Safety and Resilience team. Each Directorate and area of responsibility will have specific needs that require further information to ensure employees are kept safe, appropriately trained, adequately informed, and legally compliant.

All Council employees are responsible for working safely and ensuring the safety of their colleagues. 'Ignorance is no excuse in the eyes of the law.' If there is any uncertainty regarding the welfare or safety of employees, advice and guidance must be obtained from senior managers.

3.5 Monitoring and Review

The Council utilises a thorough approach to performance monitoring for health and safety, incorporating a programme of performance metrics that includes the following measures:

• Quarterly Key Performance Indicators (KPIs): A regular report that tracks and reports on key metrics such as incident rates, training completion rates, and audit results on a quarterly basis.
• Annual Health and Safety Report: A comprehensive report each year detailing our health and safety performance and initiatives.
• Safety Committee Oversight: The Safety Committee is committed to continuous improvement, regularly reviewing performance metrics to enhance safety practices and identify new areas for development.

The effectiveness of the Occupational Health, Safety and Welfare Policy will be regularly monitored and reviewed to ensure it remains current and effective. This includes conducting periodic audits, gathering feedback from employees, and analysing incident reports. The policy will be reviewed every two years, and any necessary adjustments will be made to continuously improve our health and safety practices and to address emerging risks promptly.

Occupational Health, Safety and Welfare Policy for the Council sets out our overarching strategy to provide a safe working environment for all its employees, which works towards progressively reducing the exposure of risk to its employees and keeping them safe.