The cost of qualification
“Low cost or cheap is never the final price” – W. Edwards Deming.
The term “fit for purpose” is not new, but what does this mean to a business, its operations, and their health and safety responsibilities? What possible impact could it have, if this is not considered when purchasing, repairing, or modifying equipment in your fleet?
To illustrate this, I will recall a fatal truck accident that occurred several years ago, that was caused as the direct result of not considering if the modifications to a truck were fit for a short-term contract.
The driver was employed as a seasonal employee to transport wine from one area to a winery in another province. For the purpose of the contract, the trucking company had purchased several stainless-steel tanks and had them temporarily installed on the truck.
On his first delivery, the driver had changed down to safely negotiate a steep section of the highway, and when he was making a sweeping left-hand turn at the bottom of the incline, the wine swayed with the momentum of the turn, causing the truck to go out of control and tip over into a gully, killing the driver and badly injuring his accompanying learner driver.
During the investigation, it was identified that the primary cause of the accident was not the fault of the driver, but that:
1. No risk assessment had been undertaken prior to the installation of the tanks;
2. The tanks had been installed by an unqualified company engineer; and
3. No baffles had been installed to mitigate the risk of the displacement of the wine to prevent such an accident from occurring.
In effect, the installation of the tanks was not fit for purpose.
FIT FOR PURPOSE AND HEALTH AND SAFETY
What does fit for purpose mean to a business?
A dictionary definition: something that is fit for purpose is good enough to do the job it was designed to do. European law and now NZ law dictates that goods must be fit for purpose when sold.
A layman‘s definition:
- If you are prepared to pay the big dollars for a top line BMW or Rolls Royce, then you would expect the quality, safety features and performance that its manufacturers claim and it fits your purpose.
- If you are prepared to only pay X amount for a small Japanese import, you would also expect it to have its quality and safety features and perform to your expectations, and still be fit for purpose regardless of the price.
It‘s what you are prepared to pay for something to perform to your expectations of safety, quality and use. The same applies to all products, machinery, and equipment that you purchase for your business.
Vehicle modifications and business responsibilities.
This term and the associated responsibilities of businesses who design, manufacture, import, supply or install fixtures, fittings, substances plant or structures have now been clearly defined in the Health and Safety at Work Act 2015.
What is interesting is that these responsibilities had previously been set out in the 1995 H&S regulations. The reasons for this shift of emphasis were because of the Pike River disaster and the collapse of the CTV building in the 2011 Christchurch earthquake when 115 people lost their lives.
The goal posts have shifted – it‘s now all about accountability and responsibility, with the health and safety impacts and other considerations having to be built into all stages, from design through to installation modification and commissioning.
A PRESCRIBED PERSON
Who should carry out this work?
This is another new term in health and safety vocabulary and means that where a regulation requires that a “prescribed person” is to be used, they must be used. E.g. a qualified electrician, or a qualified or certified welder. You are also prohibited from using your employees to undertake any prescribed duties, if they are not qualified to do so.
This was emphasised with dire consequences when a Taranaki landlord self-installed a second-hand gas stove into one of his rentals, which resulted in his tenant being gassed and consequently dying.
Although this is a different event, the lesson to be learnt is that if you have a welding job that is critical for the safety, structure or integrity of your fleet, this will now require the expertise of a registered and competent welder.
For example, if a special locking pin or draw bar was broken, bent or damaged, can you just get out a gas torch, heat it up and then bend it back into shape?
The answer is, not any longer – as its certified structure is important for the safety of the driver, the vehicle, other road users and the client‘s goods.
If your business has its own repair workshop, my recommendation is to:
1. Check that your engineers or mechanics have up-to- date registrations or certification;
2. Check that your equipment is suitable and where required, has a current certification;
3. Or to hire in the skill.
If you do it yourself and it goes wrong, you as the PCBU or your business could face the consequences.
If you have any equipment in your business that has been changed or modified, have it checked against a known NZ Standard or ACOP to ensure it is safe and fit for purpose for what it was originally designed or intended to do.
If you are in the process of purchasing any second-hand equipment to save cost to your business, I suggest the following
? Carry a full risk/hazard analysis on the proposed equipment to determine that it is fit for purpose; and
? Include in your purchasing agreement that it is checked and/or surveyed by a qualified engineer prior to purchase and prior to transporting and to using it in your business operations.
Safe driving!
Gordon is the managing director of Hasmate Ltd of Napier. Since 1993 he has worked extensively in health and safety as an advisor, systems development, auditing and management training.
Gordon Anderson – Hasmate Ltd
