Health & Safety Policy Manual - British Land/media/Files/B/British-Land-V2/downloads/... · HEALTH & SAFETY POLICY MANUAL . FOR . THE UK ... • to ensure that where we act as a client

HEALTH & SAFETY POLICY MANUAL

FOR

THE UK MANAGED

PROPERTY PORTFOLIO

Version 17 – October 2014

Document Control Within ISO 9001 Control: NO

Owner British Land Company PLC

Originator Ark Workplace Risk Ltd

Date Originated

12/12/2011

Copy Issued To Version Format Notes

1 British Land 17.0 pdf Amended OHS Policy statement following OHSAS 18001 stage 1 audit.

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Health and Safety Policy Manual – UK Managed Portfolio Version 16

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OUR ETHOS

1 Policy Statements and Management Responsibilities OUR GOALS

2 Successful Management of Health and Safety OUR EXPECTATIONS

3 Managing Agent Responsibilities


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INTRODUCTION British Land and its approach to health and safety This guide has been produced by British Land to communicate standards of health and safety management across our managed portfolio. Health and safety is a key focus for British Land. We are committed to providing safe working environments at our properties for the benefit of all users including our employees and contractors, our occupiers and their customers, visitors and members of the public. To do this effectively we have appointed managing agents who are specialists in property stewardship. They work with British Land to manage property on a daily basis. British Land has produced this document to ensure everyone understands the health and safety standards which we require at each of our assets. This highlights the minimum standards we require in health and safety management. We must not ignore the numerous costs of an accident and the legal obligation to ensure, wherever possible, that the risks to health, safety and the environment are minimised. 23rd October 2014 Signed:

Justin Snoxall Head of the Business Group

Signed:

David Tudor-Morgan Retail Property Management Executive

Signed:

Catherine Thomas Office Property Management Executive (City)

Signed:

Georgia Hogg Office Property Management Executive (West End)


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Policy Statements and Responsibilities

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HEALTH & SAFETY POLICY STATEMENT OF

THE BRITISH LAND COMPANY PLC British Land’s overall objective is to generate sustainable long-term total returns for our shareholders and we do this by creating places people prefer. As well as being a moral obligation, careful management of health and safety is a key component in providing properties where people want to live, work and shop for the benefit of our customers. In addition, it improves our operational resilience and enhances our attractiveness as an employer and partner of choice for investors, occupiers, suppliers and the local communities in which we operate. Together these factors make a significant contribution towards our overall objective and this policy sets out our approach. Our Health and Safety Mission • We are committed to providing safe and healthy environments for all users of the buildings

and places we manage, and to the wellbeing of our staff. • We aim to be a leader in our industry and set ourselves ambitious targets which we

monitor our performance against. • We are committed to continual improvement in health and safety management and

performance, including through our supply chain. Our Responsibilities Our base line responsibilities under the Health and Safety at Work etc. Act 1974 are, so far as is reasonably practicable: • to provide and maintain plant and equipment as well as systems of work that are safe and

without risks to health; • to make arrangements for the safe use, handling, storage and transport of articles and

substances; • to provide such information, instruction, training and supervision as is necessary to ensure

the health and safety of the users of our buildings and those involved in our head office activities;

• to maintain a safe means of access to and egress from our properties, including our head office;

• to provide and maintain environments at our properties, including our head office, which are safe and without risks to health; and

• to ensure that where we act as a client under the Construction (Design and Management) Regulations 2007 we discharge our duties.

We are committed to the prevention of injury and ill health to our employees and all users of our properties. We are committed to complying with all applicable legal health and safety requirements and other relevant regulation. Our Approach British Land has implemented a Health and Safety management system which is aligned to the requirements of BS OHSAS 18001 and is subject to ongoing review against the requirements of that standard. This management system governs: • the form and structure of management oversight and co-ordination of the company’s

response to health and safety risks; • the establishment and review of our health and safety objectives and how progress

against these is measured and monitored; • the use of risk assessments in each area of the business enabling us to respond to

identified health and safety risks and achieve continual improvement; • establishment and implementation of relevant policies and procedures; and • the approach to ensuring that all staff are aware of their responsibilities in respect of health

and safety and properly trained to be able to fulfil these responsibilities.


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Governance of this Policy This policy statement applies to all of our activities as both an employer and as an owner, developer and manager of property. It has been subject to Board review and is owned by the Executive Director with health and safety responsibility. This policy will be reviewed periodically and not less than once a year, to ensure that it remains appropriate and aligned with the activities, objectives and strategy of the company. This policy is made available to all staff within the staff handbook, available on the company’s intranet system. It will be covered in induction training for all new staff, and ongoing periodic health and safety training for existing staff where appropriate. This policy is published on the company’s website so that it can be accessed by all of our stakeholders and other interested parties.

Lucinda Bell Executive Director with Health & Safety Responsibility Dated -


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HEALTH AND SAFETY OBJECTIVES Our health and safety targets in the managed portfolio are:

1. At the annual risk assessment, 90% of all identified risks are deemed to be under control. 2. There should never be any intolerable risks identified on site. 3. All uncontrolled risks should be resolved within:

a. Intolerable – 1 week b. Substantial – 1 month c. Moderate – 3 months

4. All required health and safety site documentation is current or never remains out of date for more than a month.

5. All reportable accidents under RIDDOR should be investigated and an action plan developed so as to prevent recurrence.

6. All new properties introduced into the portfolio shall have a risk assessment undertaken within 15 working days of being brought under management if such a risk assessment is not available.

SCOPE This policy applies to all UK property interests for which British Land has management responsibility (‘British Land managed properties’), including those owned by its joint ventures and funds. For the avoidance of doubt it does not cover:

- single let properties (also known as ‘FRI properties’) where the occupier retains responsibility for health and safety;

- properties which are not located in the UK; these are covered by a separate policy; - development properties; these are covered by a separate policy.

This policy draws on relevant health and safety legislation, primarily the Health and Safety at Work etc Act 1974 and uses terminology consistent with that legislation. This legislation focuses primarily on workplaces (also referenced as ‘places of work’) and the interests of employees. In applying this legislation to British Land’s managed portfolio, workplaces and places of work are considered to be those parts of the properties under British Land’s management control, including common parts and vacant units. Similarly, this policy extends the consideration of the interests of employees under the legislation to cover the interests of all users of those parts of the properties which are under British Land’s management control, including employees, contractors and visitors of British Land and its agents as well and employees, contractors, visitors and customers of our occupiers. In respect of British Land’s managed residential portfolio, this scope extends to common areas within shared domestic premises and the occupiers themselves. At multi-let properties, responsibility for health and safety matters within occupied demises (including residential properties) falls with the occupier, but British Land, as manager, has certain responsibilities – as detailed in this policy – for liaising with occupiers to communicate health and safety policies and responsibilities and ensure that health and safety risks within their demises have been evaluated and properly addressed in order to ensure that the integrity of health and safety arrangements across the properties is maintained.


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HEALTH AND SAFETY MANAGEMENT STRUCTURE

The British Land Company PLC Board

Executive Director with H&S Responsibility

Lucinda BellFinance Director

Portfolio Under ManagementJustin Snoxall

Head of Business Group

Head Office Ade Onagoruwa

Head of Employee RelationsIan Davies

Head if IT and Facilities

Construction and DevelopmentRichard Elliott

Head of Construction

Health and Safety Management CommitteeJustin Snoxall – Chairman

David Tudor-Morgan – Retail UKCatherine Thomas – Offices City

Georgia Hogg – Offices West EndTom Linscott - Residential

Competent Advisor - Ark Workplace Risk Ltd David Sanchez – Retail Europe - Internos

Managing Agents

Building / Site Management

Teams

Competent AdvisorArk Workplace Risk Ltd

Secretary to the Risk Committee

Jonathan Rae

Figure 1 – British Land Health and Safety Management Structure

HEALTH AND SAFETY MANAGEMENT RESPONSIBILITIES The health and safety of all users of those parts of our portfolio for which we have management responsibility is a high priority and therefore British Land commits to ensuring that appropriate resources are set aside for the prevention of accidents, incidents and ill health in the managed portfolio. Health and Safety Policy Manual – UK Managed Portfolio Version 16

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Executive Director with Health and Safety Responsibility The Executive Director with Health and Safety Responsibility at British Land is the Finance Director, Lucinda Bell. This role is responsible for health and safety compliance at British Land and ensuring that all legal obligations are met. The Executive Director with Health and Safety Responsibility sets policy, monitors compliance and reports to the Board on health and safety. The Head of the Business Group – Justin Snoxall Reports to the Executive Director with health and safety responsibility, recommends policy, takes responsibility for management across the investment and residential portfolios and reports on levels of compliance and management to Executive Director with health and safety responsibility. His responsibilities include:

• Chairing the quarterly meeting of the Health and Safety Management Committee for the managed portfolio.

• Monitoring compliance and escalating where appropriate. • Providing adequate resources to meet all health and safety requirements. • Provides adequate management systems and support to ensure all standards are met. • Recommends policy for approval by the Executive Director with Health and Safety

Responsibility. • Communicating standards, requirements and providing updates on performance across the

portfolio. Property Management Executives Are responsible for:

• Attending the quarterly meeting of the Health and Safety Management Committee for the managed portfolio.

• Ensuring property management standards give due regard to legal and company requirements.

• Ensuring sufficient resources are available to enable managing agents to undertake their responsibilities effectively.

• Taking appropriate action to address health and safety issues which may arise. • Monitoring managing agent performance and compliance to standards and follow up where

necessary. Managing Agents Are responsible for:

• Providing adequate management systems and support to deliver British Land’s health and safety standards as set out in British Land’s Health and Safety Management Principles Document.

• Meeting occupational health and safety requirements as set out in the appointment documentation.

• Maintaining current risk assessment documentation on site or on QUOODA® which includes assessments of the physical environment, activities of staff and management interventions to minimise risk. See Section 3 of this document for guidelines on the frequency that risk assessments should be undertaken.

• Implement controls where risks have been identified and provide on-going comments of the actions taken and any outstanding items.

• Maintaining permits to work for all contractors working on site. • Maintaining a record of all accidents and incidents on QUOODA® in accordance with the

British Land guidelines and RIDDOR as set out in Section 3 below. • Maintaining all required documentation current on site and upload these onto QUOODA®. • Support the Competent Advisor with provision of information or management support to

enable the Competent Advisor to discharge their responsibilities.


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Competent Advisor As the “Competent Advisor”, Ark Workplace Risk Ltd (Ark) is responsible for:

• Advising British Land on all health and safety matters which relate to property management in the managed portfolio. At all times being mindful that all local legal requirements are met.

• Acting as the Secretary to the quarterly meetings of the Health and Safety Management Committee for the managed portfolio, providing minutes and actions agreed from the meeting, as well as a quarterly management report including appropriate safety management and governance reporting which is distributed to all members of the Health and Safety Management Committee as well as all managing agents.

• Undertaking annual risk assessments at each asset on site to review management compliance against legal and British Land requirements. Providing a report on QUOODA® within 10 working days of all actions to be undertaken to resolve any issues identified by the site risk assessment. Reporting on a timely basis to British Land on any issues identified.

• Monitoring accident reporting across the portfolio to ensure consistent reporting by managing agents in accordance with the British Land guidelines set out at below.

• Undertaking accident investigations and emergency planning when required to do so. • Initiate a review of this policy document on an annual basis.

MANAGEMENT REPORTING In line with Regulation 5 of the Management of Health and Safety at Work Regulations 1999 (MHSW) there is a general requirement to monitor and review preventive and protective measures with reference to health and safety. To monitor performance Ark will produce quarterly reports to Property Management Executives as well as providing a quarterly summary of performance to the Head of the Business Group. Review of Policy and Practices British Land recognises that health and safety policy may need to change as legislative requirements are revised. To this end the Competent Advisor will conduct a regular review (normally annually) of this document along with an annual review our own policies and procedures to ensure that these remain relevant and current.


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Successful Health and Safety Management

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SUCCESSFUL HEALTH AND SAFETY MANAGEMENT The major thrust of the enforcement of good health & safety practice is the utilisation of successful health and safety management systems.

British Land, in the UK has adopted the principles within both the Health and Safety Executive’s (HSE) HSG65 document; "Successful Health and Safety Management" and BS OHSAS 18001.

These sets out four key elements of health and safety management which include:

• Plan- determination of policy and plan for implementation

• Do – profile risks, organise for health and safety and implement the plan

• Check – measure performance (monitor before events, investigate after events)

• Act – Review performance and act on lessons learnt Any review of performance should focus on compliance with these principles, rather than an approach which focuses on simply physical preventative measures.

Figure 2 – HSG65 Successful Health and Safety Management Model Risk Assessment Risk assessment is the foundation of our safety management system. A risk assessment is carried out to identify the risks to the safety of any person arising out of, or in connection with, work or the conduct of British Land’s undertakings. It identifies how risks arise and how they impact on those affected. This information is needed to make decisions on how to manage those risks so that decisions are made in an informed, rational and structured manner, and the action taken is proportionate.


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The ultimate goal of any health and safety management system is to prevent injury and ill health in the workplace. Adequate workplace precautions and arrangements which are specific to the particular organisation need to be implemented and maintained in order to prevent harm to people at the point of risk. Managing agents shall ensure that all appropriate general and fire risk assessments are undertaken within 15 days of the property or site falling under management responsibility of British Land, resulting from either acquisition or development completion, where an existing general or fire risk assessment is either not available, is considered to not suitable and sufficient or does not reflect the management arrangements in place within the property or site. Where commercial sensitivities do not render it unfeasible, acquisition due diligence should incorporate a review of arrangements for health and safety risk assessment for the target property or site, and a review of the latest risk assessment where available. If this is not feasible then the investment appraisal should acknowledge this. Risks are created as the business undertakes daily activities in the provision of a service and appropriate risk control strategies are required at each stage of this process in order to prevent hazards from causing harm to employees and others (such as members of the public). Prior to the formulation of risk control strategies a process of hazard identification and risk assessment needs to be undertaken in order to establish what hazards affect employees and others within British Land and the degree of risk associated with each hazard. Once this process has been undertaken a judgement can be made as to how much resource is applied to reducing the risk in each specific case. Risk Control Strategies Having identified the risk, decisions about minimising the risk must be taken. British Land recognises the requirements of Regulation 4 of the Management of Health and Safety at Work Regulations 1999 in respect of its risk assessments and expects the Competent Advisor to recommend remedial action where a risk has been identified that in the first instance eliminates the risk. Where this strategy is not feasible or commercially appropriate it shall be for the managing agent, working with British Land, to determine, in consultation with the Competent Advisor the most appropriate method of reducing the risk. When deciding how risk is to be managed the appointed managing agent must invoke the general principles of prevention as required by Regulation 4 of the Management of Health and Safety at Work Regulations 1999. In determining appropriate risk controls the following issues are likely to need consideration:

• Eliminating the risk, • Avoiding the risks, • Evaluation of risks that cannot be avoided. • Combating risks at source. • Adapting work to the individual (i.e. workplace design, selection of work equipment

and working methods) with particular emphasis on alleviating monotony and predetermined work rates and their effect on health.

• Take advantage of technological progress. • Substitute hazardous substances or equipment with less hazardous ones. • Development of an overall prevention policy covering technology, organisation,

working conditions, social relationships and working environment-influencing factors. • Giving collective protective measures priority over individual protective measures. • Provision of appropriate instruction to employees. • Promoting a culture of safety.


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Risk Assessment Review British Land requires its managing agents to ensure that health and safety and fire risk assessments are conducted by its competent advisor at least annually for all premises. All risk assessments must be reviewed and actioned by the managing agents, to ensure that they remain suitable and sufficient. More frequent reviews should occur where the risk assessment is considered to be no longer valid for any reason, including:

• any change in legislation, guidance or approach adopted by the local authorities, • after a major accident or incident including a major fire, and • prior to or during refurbishment or other action that may substantively alter the risks

associated with the undertaking. Health & Safety Management The managing agent must ensure that they have a suitable health and safety management system in place in accordance with British Land’s Health and Safety Management Principles Document. Included within these principles is the requirement to have appropriate health and safety procedures in place for the management of risk on site. Managing agents must undertake regular audits of their health and safety management systems in accordance with British Land’s Health and Safety Management Principles Document to ensure that they remain appropriate. Where changes in legislation occur or where there are technological advancements it is incumbent on the managing agent to ensure their health and safety management system is updated accordingly.


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Managing Agent Requirements

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INTRODUCTION The managing agents have been contracted to manage property on behalf of British Land. In the majority of cases, managing agents will be responsible for managing health and safety within the common parts of the investment property only (this excludes the majority of FRI type properties). The exact boundaries of control between occupiers and the managing agent must be clearly defined within the occupiers’ leases. In all circumstances the managing agent has a responsibility to co-operate and co-ordinate with all occupiers on issues that affect any part of the building. This spirit of co-operation and co-ordination should run through all dealings between occupiers and managing agents, particularly where health and safety issues are concerned. This section provides an outline of the operational health and safety responsibilities of the managing agents as defined by British Land. This section does not seek to prescribe a definitive methodology. Section 3 merely sets out a minimum standard of health and safety management that is expected of all appointed managing agents. In addition to the guidelines detailed in the following section, the managing agent is required to implement its own policies, procedures and control measures in relation to work activities, physical, environmental or premises hazards, as is deemed appropriate to comply with the requirements given in legislation or guidance.

ACCIDENTS & DANGEROUS OCCURRENCES Legislative Requirements If an accident or incident is notifiable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 and the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), then it must be notified to the enforcing authority within the specified timescales. Application RIDDOR applies to all places of work including the common areas of residential blocks of flats. British Land Requirements

1. All accidents, specified injuries and reportable dangerous occurrences (including near misses) that occur within the common areas of the property for which the managing agent is responsible, whether they are notifiable or not under RIDDOR, must be recorded by the managing agent using the QUOODA® on-line health and safety management system.

2. Should an accident, dangerous occurrence or near miss occur within the common

parts of a British Land managed property the managing agent must undertake a thorough investigation in accordance with its documented accident investigation procedures. The findings of the investigation, including actions arising and status of their implementation should be recorded on QUOODA®.

3. The scope of any investigation will be dependent on the severity of the incident.

Where reasonably practicable, measures must be taken to prevent reoccurrence of


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any accident or dangerous occurrence and where necessary relevant risk assessments should be reviewed.

4. Any accidents or incidents occurring within an occupier’s own demise should be dealt

with as part of the occupier’s own accident reporting and investigation procedures.

5. Under the following circumstances the managing agent must report any incident/accident directly to the relevant property management executive by telephone or email:

• Any specified injury, dangerous occurrence or incidence of disease relating to

health and safety matters as defined by RIDDOR. • Any accident/incident that involves an investigation by the HSE, local

authority or the Environment Agency/ Scottish Environmental Protection Agency.

• Any incident relating to health and safety or environmental matters which in the opinion of the managing agent may cause specific concern to British Land, or our clients in respect of public perception of the incident or generally where the managing agent reasonably believes that the incident may have direct implications for British Land or our clients (such as legal proceedings).

6. Records of all accidents should be held for a period of at least three years. Accident

statistics must be reported to British Land monthly and reviewed quarterly as part of property management meetings.

7. An incident/accident which causes environmental damage or any state of affairs which poses an imminent threat of environmental damage may require reporting to the Environment Agency/ Scottish Environment Protection Agency or local authority under the Environmental Damage (Prevention and Remediation) Regulations 2009, the Environmental Damage (Prevention and Remediation) (Wales) Regulations 2009 or the Environmental Liability (Scotland) Regulations 2009, the Environmental Liability (Prevention and Remediation) Regulations (Northern Ireland) 2009 as appropriate. The managing agent is responsible for reporting any such incidents/accidents to the relevant authority and to British Land.

ASBESTOS Legislative Requirements The Duty Holder The Control of Asbestos Regulations 2012 (CAR) relates to asbestos containing materials (ACMs) within non-domestic premises. The managing agent must discharge British Land’s legal obligations and act as duty holder for the property. The duty holder is responsible for all the ACMs within the common parts and must co-ordinate all works on ACMs within the common parts of the property. Managing agents must also communicate to all occupiers their responsibilities for the management of asbestos within their own demise both with respect to British Land policy and relevant legislation. The duties under CAR will fall on both the appointed managing agent and all occupiers within a multi-occupied property. As identified elsewhere within this section, managing agents will be required to cooperate and coordinate with occupiers’ duty holders in order to comply with the law and this policy. Asbestos Survey / Register Regulation 4 of CAR requires all persons in control of repair or maintenance activities in non-domestic premises to inspect premises for the presence and condition of ACMs and


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thereafter, assess the risks of exposure and prepare a plan for future maintenance and management of asbestos risks. Management Plan In order to control exposure to asbestos, a detailed management plan must be drawn up for each building. This plan will outline the procedures for preventing or reducing the risks from asbestos materials, and should include:

• Procedures for reviewing and assuring the condition of asbestos materials. • Procedures for making others aware of asbestos materials located in the building,

including the emergency services. • Controlling access to asbestos and managing contractors. • Emergency plan and procedures for controlling accidental exposure to asbestos.

Application CAR applies to all places of work (non-domestic premises) including the common areas of residential blocks of flats. British Land Requirements

1. British Land acknowledges the health hazards arising from exposure to asbestos and managing agents must protect those occupiers and other persons who potentially may be exposed to asbestos so far as is reasonably practicable.

2. The managing agent must undertake asbestos surveys at all properties under their

control where said property was constructed prior to the year 2000. Where the property was constructed after 2000, unless you have information to the contrary, it should be sufficient to record that the date of construction indicates that there is no asbestos present.

3. The asbestos survey must incorporate all areas for which the managing agent has

responsibility and all asbestos surveys must be undertaken in line with guidance provided within the HSE’s guidance document HS(G)248. An asbestos survey should also be undertaken where new property is purchased or where property falls back within the responsibility of the managing agent when an occupier’s lease expires, for example.

4. The managing agent duty holder must hold and maintain an asbestos register for the

property. The duty holder must proactively provide an up to date copy of the asbestos register to all those who are likely to undertake work within the property or come into contact with asbestos. The asbestos register must also be made available to any other interested parties upon reasonable request.

5. As a minimum all properties containing ACMs must be inspected at least annually to

check the condition of the material.

6. All work that involves ACMs must be recorded on the asbestos register. To facilitate this, the managing agent must maintain a site specific logbook. The logbook must record all works on, and removal of, ACMs within the property. All asbestos removal/encapsulation works must be notified in writing to British Land.

7. Any works undertaken within the property, including within the demised premises,

which will affect or which are likely to affect ACMs or presumed ACMs must be subject to a risk assessment and appropriate contractor management processes to ensure that appropriate safe working procedures are followed. The party undertaking the works must notify the Health and Safety Executive at least 14 days prior to commencing work on any ACMs which are notifiable under Regulation 8 of CAR.


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8. British Land may require strategic monitoring information from managing agents in

order to check on the effectiveness of asbestos management throughout the property portfolio.

CONSTRUCTION WORK Legislative Requirements The Client’ as defined within the Construction (Design and Management) Regulations 2007 (CDM2007) is required to:

• Appoint the right people; • Allow adequate time; • Provide information to the construction team; • Ensure cooperation and coordination between parties; • Ensure management and welfare arrangements are in place; and • Ensure workplaces are designed correctly.

Projects which last longer than 30 days OR involve more than 500 person days of work are known as 'notifiable' projects under CDM2007. Application CDM2007 applies to all places of work including the common areas of residential blocks of flats. British Land Requirements 1. The level of responsibility taken on by managing agents during any construction work will

depend largely on whether British Land or the managing agent takes on the role of ‘The Client” under CDM2007.

2. Where the managing agent is acting as ‘The Client’ the following principles must be followed as a minimum whether the project is notifiable or not.

3. Prior to the appointment of any consultant (including an in-house project manager) for a project the managing agent shall advise British Land in writing of any construction or demolition project that is proposed or is in pre-planning associated with a premises managed on behalf of British Land.

4. During any construction project ‘The Client’ shall comply with all client duties as set out in the CDM2007 Approved Code of Practice (ACOP). These are summarised as follows:

• Ensure that all designers, contractors and others involved in the project are

competent, adequately resourced and appointed early enough for the work they are required to undertake.

• Ensure they allow sufficient time for each stage of the project. • Ensure they co-operate with others involved in the project as is appropriate to allow

them to comply with their duties under the Regulations. • Ensure they co-ordinate their own work with others involved in the project in order to

ensure the safety of those carrying out the construction work and others who may be affected by it.

• There are reasonable management arrangements in place throughout the project to ensure that the construction work can be carried out, so far as is reasonably practicable, safely and without risk to health.

• Ensure that contractors have made suitable welfare arrangements throughout the construction phase of the project.

• Any fixed workplaces that are to be constructed comply with any requirements of the Workplace (Health, Safety and Welfare) Regulations 1992.


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• Ensure that all relevant information is passed to designers and contractors to enable

them to carry out their work safely (e.g. asbestos registers).

5. Additionally for any notifiable construction project ‘The Client’ shall:

• Appoint a CDM Co-ordinator to advise and assist with their duties. The CDM co-ordinator must notify the HSE using form F10 and must provide a copy to the client who may be required to sign it to indicate that the client duties are understood.

• Appoint a Principal Contractor to plan and manage the construction work. • Ensure that the construction phase does not begin until the Principal Contractor has

prepared a suitable construction phase plan and made arrangements for suitable welfare facilities to be present from the start of work.

• Ensure that a health and safety file is prepared, reviewed and updated ready for handover at the end of the construction work.

• Provide the pre-construction information to the CDM Co-ordinator including all project-specific health and safety information needed to identify hazards and risks associated with the design and construction work.

COOPERATION AND COORDINATION WITH OCCUPIERS Legislative Requirements The Management of Health and Safety at Work Regulations 1999 along with the Regulatory Reform (Fire Safety) Order 2005, The Fire (Scotland) Act 2005, the Fire Safety (Scotland) Regulations 2006 and the Management of Health and Safety at Work and Fire Precautions (Workplace) (Amendment) Regulations (Northern Ireland) 2003 requires persons who share a workplace to co-operate and co-ordinate fully with each other in fulfilling their legal obligations and to provide and exchange information where responsibilities overlap. Application The requirements in relation to cooperation and coordination apply to all places of work including the common areas of residential blocks of flats. British Land Requirements 1. In the spirit of this co-operation, managing agents should provide occupiers with a basic

handbook detailing the safety arrangements for the property and any relevant responsibilities of the occupier. This shall, where possible, be verified during the risk assessment process.

2. Managing agents must also make available to all occupiers copies of risk assessments that have occurred within the property upon reasonable request.

3. Where considered appropriate the managing agent must develop relevant emergency procedures for the common parts of the property and should provide them to all occupiers for their reference.

4. It is incumbent upon all occupiers to ensure that their own emergency procedures and policies reflect those of the landlord to prevent confusion in an evacuation or emergency.

5. Furthermore, it is the occupiers’ responsibility to ensure that all relevant health and safety risk assessments are undertaken in respect to their own office/work areas and to notify the managing agent in writing of any substantive risks that may affect the building fabric, common parts, other occupiers or visitors. Managing agents must remind all occupiers of this requirement and request this information on a regular basis.

6. Occupiers must be made aware of all the health and safety policies and procedures that pertain to the property and should be made aware of their own responsibilities.


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Managing agents should issue all occupiers with guidelines preferably in the form of an ‘Occupier’s Handbook’ which clearly sets out occupiers’ responsibilities for health, safety and environmental management along with any site rules and emergency contact details. This shall, where possible, be verified during the risk assessment process.

DOCUMENTATION Legislative Requirements Section 40 of the Health and Safety at Work etc. Act 1974 states that; “In any proceedings for an offence under any of the relevant statutory provisions consisting of a failure to comply with a duty or requirement to do something so far as is practicable or so far as is reasonably practicable, or to use the best practicable means to do something. it shall be for the accused to prove (as the case may be) that it was not practicable or not reasonably practicable to do more than was in fact done to satisfy the duty or requirement or that there was no better practicable means than was in fact used to satisfy the duty or requirement.” This section effectively reverses the principal of “innocent until proven guilty” and requires those who are indicted to defend a position or course of action or inaction. Application Section 40 of the Health and Safety at Work Etc. Act 1974 applies to all places of work including the common areas of residential blocks of flats. British Land Requirements 1. Managing agents shall ensure that all required documentation which can be used to defend both the managing agent and British Land is maintained and is available for inspection as required. 2. Where a property or site is acquired the managing agent shall ensure that all required documentation is uploaded onto QUOODA within 14 days of such acquisition.

EMERGENCIES Legislative Requirements It is the responsibility of the appointed managing agent to maintain appropriate emergency procedures for each property in accordance with Regulation 8 of the Management of Health and Safety at Work Regulations 1999. Emergency procedures should cover all foreseeable emergencies and should be revised and updated as often as is necessary. Application Regulation 8 of the Management of Health and Safety at Work Regulations 1999 applies to all places of work including the common areas of residential blocks of flats. British Land Requirements


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1. Where the site is manned either by directly employed managing agent staff or by

contractors, copies of the site emergency procedures should be held at reception or the equivalent.

2. The procedures should include methods of dealing with the media and a master copy of the procedures should be held off site.

3. A clear chain of communications should be established as part of the emergency procedures. This should include informing British Land management personnel of incidents where appropriate. During any emergency situation British Land must be contacted by phone as soon as possible and made fully aware of the key facts of the emergency.

4. British Land is committed to business continuity and in the event of an emergency the managing agent must ensure that robust disaster recovery procedures are in place to ensure that occupiers are minimally affected during any emergency.

5. All emergency procedures along with any changes to them must be effectively communicated to occupiers. The managing agent will need to co-operate and co-ordinate with all occupiers to ensure that, so far as is reasonably practicable, employees and other building users who are less able bodied can be safely moved to a place of safety in an emergency.

6. Emergency procedures should be subject to routine testing as a way of identifying possible gaps in the procedures and training of both on site and off site property management staff in emergency preparedness.

FIRE SAFETY Legislative Requirements The Regulatory Reform (Fire Safety) Order 2005 (RRO) is the primary source of fire safety legislation now in force and extends to England and Wales only. The Fire (Scotland) Act 2005 and the Fire Safety (Scotland) Regulations 2006 apply to our properties located in Scotland and the Management of Health and Safety at Work and Fire Precautions (Workplace) (Amendment) Regulations (Northern Ireland) 2005 apply to our properties in Northern Ireland. The legislation covers ‘general fire precautions’ and other fire safety duties that are needed to protect ‘relevant persons’ in case of fire in and around most ‘premises’. The Order requires fire precautions to be put into place where necessary and to the extent that is reasonably practicable in the circumstances of the case. Responsibility for complying with the legislation rests with the ‘Responsible Person’ as defined within the relevant legislation detailed above. Application The requirements in relation to fire safety apply to all places of work including the common areas of residential blocks of flats. British Land Requirements 1. The person responsible for discharging British Land’s obligations with regard to its

premises is likely to be the Managing Agent.

2. The Responsible Person must ensure that a suitable and sufficient fire risk assessment is carried out on an annual basis or more often where there is reason to believe that the current assessment is no longer valid. The fire risk assessment must be undertaken by a suitably competent person and held on site where practicable. Where appropriate risk assessment recommendations should be implemented by the responsible person.


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3. The managing agent should provide, upon reasonable request, a copy of the fire risk assessment for the common parts of the building to interested parties. In turn managing agents should be informed, in writing, of any significant risks highlighted within occupiers’ risk assessments that may affect other occupiers, visitors or the building fabric. This information should be formally requested on a regular basis.

4. The managing agent must ensure that a suitable and sufficient assessment of the need for fire alarm, emergency lighting and fire extinguishing systems is undertaken within the common areas to ensure, so far as is reasonably practicable, that everyone within the premises can escape safely if there is a fire. The need for such systems shall be determined by the fire risk assessment or the Building Regulations as appropriate depending on the circumstances. Where, for any reason, recommendations made within the fire risk assessment cannot be implemented by the managing agent, said reasons must be reported to British Land so that necessary action can be taken.

5. The managing agent must ensure that all necessary maintenance of fire systems and equipment located within the common parts is carried out by competent contractors within the specified standard and timescale that may be required by legislation, relevant British Standards or best practice. Records of fire safety equipment maintenance should be held on site where possible within a dedicated fire safety logbook.

6. The managing agent must ensure that weekly fire alarm bell tests are undertaken and that full fire evacuation drills are undertaken on at least a 6 monthly basis. Occupiers will be responsible for ensuring the safe evacuation of their staff and roll call (if appropriate) at the designated assembly point.

7. The managing agent must develop a suitable written fire evacuation procedure and ensure that it is brought to the attention of all employees, occupiers, contractors and visitors as appropriate. Occasionally, more complex documented procedures may be required and the extent of these should be determined by the risk assessment. In all cases the managing agent should maintain documented fire safety arrangements as part of their overall health and safety management system.

8. For large properties such as shopping centres with fire engineered solutions the

managing agent must maintain and comply with an appropriate fire strategy for the property.

9. Managing agents through the process of risk assessment and routine inspection must ensure that adequate means of escape in case of fire are provided within the common parts and maintained so that they are available for immediate use at all times. It will be the joint responsibility of both the managing agent and occupier responsible persons to ensure that such escape routes are kept clear and available for use at all times.

10. Whether a site is manned either by directly employed staff or by a contractor the managing agent must ensure that such persons have received suitable and sufficient instruction and training to enable them to undertake a co-ordinating role during any evacuation.

FIRST AID Legislative Requirements The Health and Safety (First-Aid) Regulations 1981 require organisations to provide adequate and appropriate first-aid equipment, facilities and people so employees and others can be given immediate help if they are injured or taken ill at work. British Land Requirements


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1. The Managing Agent must ensure that a suitable first aid kit is provided on all manned

sites whether the site is manned by directly employed staff or by an external contractor subject to a suitable and sufficient first aid risk assessment. The kit must be routinely checked by on site staff and formally inspected at least 6 monthly by the managing agent as part of wider health and safety inspections.

2. Managing agents must ensure that on all manned sites, whether the site is manned by directly employed staff or by an external contractor that a basic level of first aid cover is provided subject to a suitable and sufficient first aid risk assessment. As a minimum the managing agent must ensure that an emergency first aider (appointed person) is available on site to take charge in the event of someone falling ill or becoming injured. The need for first aid training and equipment provision must be assessed subsequent to the risk assessment.

HEALTH & SAFETY RESPONSIBILITIES FOR SITE STAFF British Land Requirements 1. The appointed managing agent may be responsible for site management staff either

employed directly by the managing agent or by an external contractor.

2. The managing agent must ensure appropriate health, safety and welfare arrangements are implemented as required by the relevant statutory provisions for all site staff employed by the appointed managing agent or contractor staff under the control of the managing agent.

3. Where site contract staff are employed, the managing agent must consider the level of control exercised and implement appropriate health and safety arrangements either directly or via responsibilities allocated to the contractor. All on site staff must be appropriately trained for the job for which they are employed and have access to procedures for action in the event of an emergency.

4. The managing agent must maintain, on site in the case of manned properties, records of risk assessments, training and work equipment maintenance.

LEGIONELLA Legislative Requirements Managing agents have responsibility for the management of water services under the Health and Safety at Work etc Act 1974 and the Control of Substances Hazardous to Health Regulations 2002 (COSHH). Application COSHH applies to all places of work including the common areas of residential blocks of flats. British Land Requirements 1. Managing agents must carry out legionella risk assessments and annual reviews at all

properties where there are common water services that extend beyond mains water supply pipework direct to the tenanted demise. Such assessments must identify the risk of Legionellosis from all work activities, water sources and systems within the premises and identify any precautionary actions required.


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2. Legionella risk assessments must be reviewed at least annually (or more often where

required) and must be undertaken by a competent person. Where the assessment identifies a reasonably foreseeable risk a responsible person must be appointed to manage the risk. In practice, this is likely to be the Property Manager or equivalent. The responsible person should develop a written control scheme in conjunction with a competent person. The written control scheme should be stored within a site water hygiene logbook. Appropriate inspections, testing and sampling must be carried out as prescribed by the risk assessment or upon the advice of a competent person.

3. The suitability of the control scheme must be monitored annually by the responsible person and must be adjusted where necessary.

4. All persons with responsibility for water systems should have access to competent help from an external independent specialist contractor or consultancy (where this competency is not available in-house) who will advise on water treatment regimes, cleaning regimes and microbiological sampling as applicable. This is particularly important where cooling towers are in use.

Cooling Towers and Evaporative Condensers

5. Where cooling towers or evaporative condensers are in place on site the appointed managing agent will ensure that the local authority has been notified of their presence and operation in compliance with the Notification of Cooling Towers and Evaporative Condensers Regulations 1992. Such systems present a significant risk to health if not managed effectively and will be subject to detailed risk assessment on at least an annual basis. All those responsible for the management of cooling towers or evaporative condensers must be appropriately instructed and trained and must in all cases have access to further competent advice with respect to water treatment and risk assessment.

LIFTS AND LIFTING EQUIPMENT Legislative Requirements Under the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER), managing agents must ensure that all lifts, lifting equipment and accessories, such as eyebolts, are maintained in a safe condition by a competent contractor and that any inspections required by legislation are carried out promptly on a routine basis. Statutory Examinations Managing agents are responsible for ensuring that thorough examinations are undertaken by a competent person every six months for lifts and lifting equipment used for lifting persons and twelve months for goods lifts and other lifting equipment where these do not carry passengers. The managing agent must ensure that any remedial work identified within the thorough examination report is undertaken and where serious defects are identified consideration should be given to decommissioning the lift (or lifting equipment) until the work can be undertaken. Where deadlines for thorough examination have passed the lift or lifting equipment must be decommissioned until the thorough examination can be undertaken. Application LOLER applies to all places of work including the common areas of residential blocks of flats. British Land Requirements 1. Managing agents must arrange for all lifting equipment such as passenger lifts and

cradles to be serviced on a regular basis in accordance with the manufacturer’s instructions. Records of maintenance and thorough examination should be held by the managing agent and made available to relevant inspectors as required.


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2. The managing agent is responsible for ensuring that all lift alarms and emergency

communication equipment remains operational at all times.

3. The following applies to any passenger lift use;

• Lifts within any British Land managed property must not be utilised in the event of a fire unless the lift is a designated fire fighting lift.

• A safe working load must be identified on all lift cars and adhered to by all users. 4. Anchorage devices, such as eyebolts and latchway systems, must be subject to periodic

examination and testing at least once every 12 months by a competent person in accordance with the manufacturer’s recommendations as per BS7883. Those anchorage devices and accessories, such as harnesses, used for rope access purposes, such as abseiling, come under the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) and require the examination period to be every 6 months.

5. All lifting equipment must be marked with the safe working load and date of last inspection / examination. Lifting beams must also be marked to indicate that the beam must not be used until a thorough examination has been undertaken.

6. Escalators (which are not considered under LOLER) should be the subject of a separate Escalator Risk Assessment.

SECURITY British Land Requirements 1. The security provisions applied throughout the managed portfolio are likely to be

property specific and will depend upon the location and size of the site as well as the type of activities undertaken.

2. Managing agents should continually review the provision of security throughout the portfolio. Where necessary, managing agents should proactively implement increased security measures (such as mobile patrols) in response to a perceived or actual threat.

3. On occasions where a lapse in security occurs, an investigation should occur and security measures should be reviewed on a case by case basis in an attempt to prevent further incidents.

4. Where appropriate, measures should be taken to restrict unauthorised access to common areas of the property, both internal and external. The requirement for such measures is likely to be identified during the risk assessment process, routine inspections or subsequent to an incident.

SITE SAFETY Legislative Requirements Various HSE guidance documents have been issued which will provide managing agents with standards of workplace safety to be achieved such as the Approved Code of Practice to the Workplace (Health, Safety and Welfare) Regulations 1992. Application The Workplace (Health, Safety and Welfare) Regulations 1992 apply to all places of work including the common areas of residential blocks of flats.


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British Land Requirements 1. British Land expects all managing agents to comply with the above guidance as a

minimum in order to ensure the safety of all those using our property. In all cases the final decision on the level and type of measures to be implemented should be made as a result of site specific risk assessment by a competent person.

2. To ensure that all premises are maintained in a good state of repair and free from risk, all properties must be routinely inspected by the managing agent or a nominated competent person.

3. The frequency of inspections will vary dependent on the size and type of property. However, health and safety inspections must be undertaken at all properties on a routine basis and records must be held and provided to British Land upon request.

4. Full health and safety risk assessments should also be undertaken annually by a competent person and recorded on QUOODA. The results of these risk assessments must also be provided to British Land upon request.

5. Due to the large amount of property owned by British Land and managed by our managing agents there is likely to be significant variation in the site safety provisions that will be required on each individual site and therefore it is not practicable for all such expected measures to be documented here.

SMOKING Legislative Requirements All properties within the British Land managed property portfolio must be ‘No Smoking’ in accordance with the Smoke Free (Premises and Enforcement) Regulations 2006 (Applicable in England), Prohibition of Smoking in Certain Premises (Scotland) Regulations 2006 (Applicable in Scotland), The Smoke Free Premises etc. (Wales) Regulations 2007 (Applicable in Wales), The Smoke-free (Signs) Regulations 2012 (Applicable in England). Managing agents must ensure that compliant ‘No Smoking’ signage is applied to all building entrance points and that proactive steps are taken to prevent smoking within the property. Application The above regulations apply to all enclosed spaces including the common areas of residential blocks of flats.

THE CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH (COSHH) Legislative Requirements The Control of Substances Hazardous to Health (COSHH) 2002 (As Amended) requires that British Land protects its employees and other users of the properties from hazardous substances. Application COSHH applies to all places of work including the common areas of residential blocks of flats. British Land Requirements


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1. Managing agents must ensure that the storage and use of hazardous chemicals on site

is kept to a minimum. Where chemicals are stored and used on site it is the responsibility of the managing agent to ensure that material safety data sheets are available for use in an emergency such as a spillage or medical incident.

2. Access to all chemicals must be restricted to authorised persons only and chemicals must be stored in minimal amounts and in well ventilated areas away from sources of ignition. Where appropriate, chemicals must be stored in a bunded area to prevent accidental spillage or leakage into the environment or drainage system.

3. Wherever practicable the managing agent must ensure that chemicals are used on site by competent and approved contractors only and COSHH information should be gathered as part of the contractor management process.

4. Where managing agent staff are required to utilise hazardous chemicals on site it is the managing agent’s responsibility to ensure that a suitable and sufficient COSHH risk assessment is undertaken.

5. The assessment must identify the means by which the substance is to be used, any exposure limits and the protective equipment required. The assessment must be available on site. Those staff that are required to use chemicals on site must be provided with the appropriate Personal Protective Equipment (PPE) (subject to risk assessment) and instructed in its use.

6. Managing agents should ensure that all staff and contractors consistently review usage of chemicals on site to ensure that the least hazardous chemical available is in use. Wherever possible the use of chemicals should be avoided altogether.

UNOCCUPIED PROPERTIES British Land Requirements 1. Where an occupier’s lease has expired or has been broken the managing agent will have

the same legal responsibilities in respect of unoccupied areas of any property as for the common parts of occupied premises. Unoccupied properties or units may attract the attention of vandals, intruders, squatters and arsonists with potentially disastrous consequences. The managing agent should ensure that unless previously agreed in writing by British Land and/or by insurers, they implement the following requirements when dealing with unoccupied properties or units;

a) Gas supply to be turned off at the main. b) Water supply to be turned off at the main and the water installation fully drained

down. c) Electricity supply to be turned off at the main. If it is necessary for essential circuits to

be left on for intruder/fire alarm systems etc. or lighting for periodic security visits etc., it must be ensured that the wiring to those parts is in a safe and satisfactory condition. Non-essential circuits should be isolated, either by turning off at the main switch or by removal of fuses.

d) All letterboxes should be sealed to prevent insertion of flammable material. e) All combustible contents, especially waste, should be removed from inside and

adjacent to the premises. f) The premises must be made secure. At the very least we would expect:

i. good quality locks and bolts on all doors; ii. glazed areas, if accessible, i.e. ground and basement windows and upper floor

windows if accessible from flat roofs etc and glass in doors, should be boarded over using 3/8 inch plywood minimum;

iii. where intruder alarms exist, these should be used if possible, but bear in mind that dampness may affect reliability of equipment;

iv. if there is any form of perimeter site security, i.e. fencing and gates, these should be maintained in good condition.


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2. The premises should be visited at least fortnightly and a thorough inspection carried out internally (although it is appreciated that access to leased premises may not be possible) and externally. The frequency of visits may need to be increased, depending on the nature of the premises, its location and loss history. A log detailing times and dates of visits must be maintained.

3. The managing agent should endeavour to gather as much relevant health and safety

information from occupiers prior to the vacation of any property/part of property.

USE OF CONTRACTORS British Land Requirements 1. Managing agents should use only approved contractors on site who have been subject

to approval via a documented contractor management programme implemented by the managing agents. All sub-contractors used should also be approved by the managing agents prior to them undertaking work on site.

2. It will be the responsibility of the managing agent, as part of the contractor management programme to request a copy of the contractor’s written health and safety policy statement along with risk assessments and method statements for all work for which the contractor is being employed on site to undertake. Evidence should also be requested relating to the contractor’s Public Liability insurance.

3. The managing agent must conduct annual reviews of such information for contractors undertaking routine work, such as cleaners and landscape gardeners. Where a contractor is employed to undertake one-off works the managing agent shall request risk assessments and method statements for each job undertaken.

4. It will be the responsibility of the managing agent to review risk assessments and method statements, comment on their suitability and make adjustments where required to ensure that the health and safety of all parties is protected throughout the period of the work. Wherever possible the managing agent must ensure that risk is eliminated (e.g. by conducting window cleaning from ground level using reach and wash systems).

5. It will be the responsibility of the managing agent to provide all contractors with the necessary information that will be required to undertake the work safely. Such information may include but is not limited to: health and safety risk assessments, evacuation procedures, the building asbestos register etc.

6. It is the responsibility of occupiers to control the work undertaken by contractors acting on their behalf to ensure that it is carried out safely and in compliance with all relevant health and safety legislation. The managing agent should, however, communicate to all occupiers their responsibilities for the safe use of contractors on site.

Permit to Work 7. No hazardous works are to be carried out at British Land premises’ without the

completion of a valid permit to work. British Land consider the following works to be hazardous as a minimum: • Hot works. • Work within a confined space. • Certain work at height e.g. where such work involves the use of cradles, abseiling,

unprotected roof areas etc. • High risk electrical works.

8. All permits to work must be supported by a written risk assessment and method

statement that must be submitted in advance. It is the responsibility of the managing


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agent to authorise any permit to work or to nominate an appropriate and competent person to do so in their place.

9. No contractor is permitted to start any hazardous work without the authority of the appropriate signed and dated permit to work. All permits to work should be time limited and are valid only for the period stated on the document itself.

10. The managing agent must ensure that before the approved contractor’s employees leave the site: • The work area is free from obvious hazards. • There are no residual fire safety hazards. • All equipment that has been worked on has been re-commissioned and is operating

safely (or is safely decommissioned as is appropriate). • The permit has been signed off as completed.

UTILITIES British Land Requirements 1. Where possible and necessary given the circumstances of the property, a planned

preventative maintenance programme should be implemented for on site plant and utilities which utilises an approved contractor. Effective records of all maintenance should be held on site where practicable.

Electrics 2. Managing agents should ensure that all complex electrical work including electrical

repairs and all tasks involving systems above 230 volts, must be undertaken only by competent contractors who must have membership of The National Inspection Council of Electrical Institute of Contracting (NICEIC) or a similar body. Such contractors should also have been vetted by the managing agent’s contractor management system.

3. As a general rule all ‘live working’ is prohibited on British Land managed properties. It will only be permitted if all three of the following conditions are met;

• It is unreasonable in all circumstances for the system to be dead. • It is reasonable in all circumstances for the work to be carried out live. • Suitable precautions are taken to prevent injury.

4. Managing agents must ensure that a periodic inspection and test of electrical systems

within the common parts of the property is undertaken as recommended by the Institution of Electrical Engineers (IEE) Wiring Regulations.

5. The IEE Wiring Regulations (BS 7671) require that Periodic Inspection and Testing of electrical installations is carried out at such intervals as are consistent with the type of installation, its use and operation, the frequency of maintenance, and the external influences upon it. For commercial properties the maximum period between inspections will be 5 years.

6. All new installations, alterations and additions must be subject to inspection and testing to verify compliance as recommended by the IEE Wiring Regulations. All 415V distribution cabinets should be provided with adequate insulated matting. If such matting cannot be permanently provided to the front of the cabinet for any reason the managing agent should ensure that arrangements are in place for such matting to be made available when working on such systems.

7. Where portable electrical equipment is utilised within the common parts, and is under the responsibility of the managing agent, such equipment must be subject to routine portable appliance testing. The managing agent must maintain a register of all such equipment on


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site and ensure such testing occurs routinely, the frequency being determined by risk assessment. Where contractors store and use electrical equipment on site similar standards of maintenance should be expected.

8. The managing agent must undertake an annual inspection and test of any building lightning conductor utilising a competent contractor.

Gas 9. Where gas appliances, such as heating boilers, are located within the common parts of

the premises the managing agent shall ensure that such appliances are serviced at least on an annual basis by a competent contractor registered under the Gas Safe Register. Such contractors must also have been vetted by the managing agent’s contractor management system.

10. The managing agent must also ensure that all gas appliances, fittings, pipework and flues are maintained in a safe condition according to the manufacturer’s instructions or on the advice of a Gas Safe installer.

11. Any liquefied petroleum gas (LPG) used on site must be subject to maintenance and inspection by a competent contractor. All LPG cylinders should be stored in an upright position and in a manner so as to reduce risks of ignition, vandalism and explosion.

Pressure Systems 12. Any pressure systems associated with a gas system or any other system on site that

falls within the provisions of the Pressure Systems Safety Regulations 2000 must have a Written Scheme drawn up by a competent person. The managing agent must ensure that the system is routinely maintained and thoroughly examined at intervals recommended by the Written Scheme.

VISITORS British Land Requirements 1. Visitors to British Land managed properties will vary significantly depending on the

building and may include the general public. Managing agents must ensure, as far as is reasonably practicable, that the health and safety of visitors is managed as effectively as that of our occupiers. In accordance with this, visitors should be made aware of property safety arrangements and where appropriate, given the nature of the property and the visitor, should be accompanied and / or supervised at all times.

2. In all cases fire safety and health and safety arrangements for the property should take into account the needs of visitors who may not be familiar with the normal safety arrangements such as escape routes and assembly points. Again the arrangements should be appropriate for the building type and occupancy and the need for such arrangements is likely to be identified during the managing agents’ normal process of routine risk assessment.

3. With respect to less able bodied persons, managing agents can be considered to be a "controller of premises" under Part 4 of the Equality Act 2010 and as a “responsible person in relation to common parts” of the property. In relation to this, the managing agent has a duty to anticipate the needs of its customers or users of the services and facilities it provides. Managing agents should ensure that accessibility audits are undertaken at all managed property where they have a responsibility for the common parts. Where appropriate all reasonable recommendations should be implemented to deal with the issues raised by the accessibility audit.

4. Occupiers are responsible for auditing their own demise although the managing agent should consider any reasonable requests for adjustments made by them. Furthermore, in


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the spirit of co-operation and co-ordination managing agents are required to communicate to occupiers their responsibility to make arrangements for the evacuation of all staff and visitors from the building whether able bodied or not.

WORKING AT HEIGHT Legislative Requirements The Work at Height Regulations 2005, as amended by the Work at Height (Amendment) Regulations 2007 apply to all work undertaken at height where there is a risk of a fall liable to cause personal injury. They place duties on employers, the self-employed, and any person who controls the work of others (e.g. facilities managers or building owners who may contract others to work at height) to the extent they control the work. Application The Work at Height Regulations 2005 applies to all places of work including the common areas of residential blocks of flats. British Land Requirements 1. Working at height should be avoided where possible. Where work at height is essential

the appointed managing agent should, wherever possible, employ an approved contractor to undertake the work.

2. Where directly employed staff are required to work at height they must be appropriately trained and provided with the correct access equipment.

3. Any fixed ladders in place must be of sound and secure construction and where higher than two and a half metres must be provided with suitable safety hoops or fixed fall arrest systems as recommended by the Workplace (Health, Safety and Welfare) Regulations Approved Code of Practice.

4. Any non-fixed ladders provided on site by the managing agent must be for the sole use of directly employed managing agent staff. All ladders must be securely stored in a way that will prevent use by unauthorised persons such as occupiers and contractors. All ladders must be inspected prior to every use and must be subject to formal inspection on a 6 monthly basis by the managing agent during formal health and safety inspections. In order for this to be undertaken effectively the ladder should be entered onto a register and be appropriately marked to indicate the date of the last inspection. Any contractors ladders kept on a British Land site must be securely stored to prevent unauthorised use.

5. All ladders used on site must be kept in good condition and defective ladders must be immediately disposed of responsibly by the managing agent.

6. Where work is due to be undertaken at height the managing agent must ensure that the appropriate risk assessments have been undertaken and that recommended control measures have been appropriately implemented. Where necessary a permit to work should be used.

7. In all cases roof access doors and hatches must be kept locked with appropriate warning signage applied to discourage unauthorised access. Where necessary, subject to risk assessment, roof areas must be fitted with edge protection. Where edge protection is not fitted it will be the responsibility of the managing agent to ensure that appropriate safe access arrangements are in place and enforced, should work on the roof need to be undertaken.

8. Access to unprotected roofs should be controlled via a permit to work.

9. Appropriate signage should be applied to fragile roof areas.


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Documents

Health & Safety Policy Manual - British Land/media/Files/B/British-Land-V2/downloads/... · HEALTH & SAFETY POLICY MANUAL . FOR . THE UK ... • to ensure that where we act as a client