Health and Safety Prosecutions and Litigation in UK Schools

A Head Teacher's Safety Management Toolkit2003 for which records are available in HSE's
ArticleDatabase, nonenominated the Headteacher as the
HEALTH AND SAFETY PROSECUTIONS ANDdefendant. In all of them an LEAor other
LITIGATION IN UK SCHOOLSEmployer/Contractor was the defendant. The
Introduction:picture forthe make up of breaches is given
This article sets out some of the backgroundbelow.
some and examples ofprosecutions and litigationHSC/HSE says exactly what they mean and are
against UK schools.transparent. Theyalso produce masses of clearly
Whilst Scottish Law and its' Legal System differswritten information free.
from that inReferences are given to a large selection of these
England and Wales the writ of the enforcing andwhich arerelevant. No one has ever been
regulating bodythe Health and Safetyprosecuted for following goodpractice. You may
Executive(HSE) runs across the bordernot have the formal documentation but if
andmatters are decided in the Criminal Courts.youhave taken care that you have records this
Litigation takes place in the Civil Courts and, in thealways helps.
case ofYour school must be safe "so far as is reasonably
Health and Safety usually revolves around aspectspracticable"
of the LEA.This simply means that you cannot work miracles
Owner, school and teachers' duty of care toand that safetyhas to be judged against what is
children. Almost allof these cases are civil actionsachievable. However, lack ofmoney is not an
taken by parents on behalf ofthe child foradequate excuse if a Risk Assessment shows
damages for injuries subsequent to accidents.thatsomething needs to be done. But it does
Prosecutions:mean that if the costs ofprotecting completely
The Health and Safety Commission is the actualagainst a particular risk is too expensivemeasured
agency of whichagainst possible outcomes or not possible, then
HSE is the executive branch have published anyou havea defence. However, all of this a
Enforcement Policywhich sets out very clearly thejudgement and must be measuredagainst good
parameters for, and circumstancesin, which thepractice. Unilateral decisions about what is or isnot
HSE should take action to enforce the Health andreasonably practicable should be guarded against.
Safety Law and Regulations.Take adviceor at least research the matter.
Enforcement of H&S law in the past targetedYou can aim for perfection over a measured time
"Directors" andscale. It alldepends on the base that you are
"Company Secretaries" and clearly this had astarting from. HSE generallyaims to encourage and
business andcommercial bias.advise. They generally prosecute only inextreme
The current HSC Enforcement Policy appears tosituations.
be targetingenforcement action against managersLitigation
as well as Directors and nowseems to be focusedA good Safety Management System protects
on both the public and private sectorsequally. Thisyou from Litigation andalso ensures any HSE is a
is also clarified in the Guidance to thevery remote possibility.
Managementof Health and Safety at WorkThe courts are far more frequently used
Regulations which talks aboutnowadays but even if youare involved in an action
"organisations" being schools, colleges, voluntaryif you have taken the prior precautionof having a
bodies,councils etc.as well as companies. Personaldocumented system the chances of success of
liability toprosecutions under the safety law hasanyclaimant are much reduced.
been extended to person whoexercise a similarLitigation in the courts has demonstrated that
role to directors and company secretaries.teachers and theschool/employer cannot be held
This would certainly include Heads as the CEO ofresponsible for every accident inschool hours, or
their schoolsbut could also be interpreted to meanat any time that the children are in the controlof
Directors/Assistantschools e.g. during educational visits. The courts
Directors, or those persons in the schoolacceptthat some accidents happen no matter
employer's organizationdirecting and organising thehow much care is taken orhow well planning and
H&S function.supervision is carried out.
In short any person or any organisation can beWhere an accident happens in such cases, the
liable toprosecution under H&S laws andteacher/schoolcannot be held liable.
regulations for a range ofoffences.Good Practice is a defence and the Headteacher's
Staff, or others can be liable for putting the healthSafety Toolkitprovides you with proof of your
and safetyof others at risk by acting negligentlygood practice and guidance onwhat is acceptable.
or interfering withsafety equipment. Others canSome important points flowing from thefollowing
be liable for advising orconniving to promotecases which can give a good general guide to
unsafe acts.theheadteacher are:
However,the main area where a cold chill runs-Is an accident "foreseeable" or not ?
down the spine forteachers and schools is the-Is the risk very low and are the costs of
potential for a child to be killedand a manslaughtermitigating the riskreasonable and proportionate?
charge to be brought.-In ny accident involving games or "horseplay"
Three points here are worth considering:there is consentand it needs recklessness or a
1. All the manslaughter charges so far made havehigh degree of carelessness tobreach the duty of
been on thebasis of gross negligence.care.
2. HSE does not bring this charge it has a protocol-Does the school have systems in placeto reduce
with thepolice where both of them run TWOrisk and is it following good or accepted practice ?
investigations side by side andthe police hand a-Was the activity leading to the accident "play" or
completed file to the DPP or the Procurator. Insomethingelse.
England and Wales it is the DPP who makes anyAreas most frequently addressed by the court
charge ofmanslaughter and gross negligence isduringlitigation include:
acknowledged by lawyers tobe difficult to prove.-Checks on staff competence and training
3. An old lawyer's adage adopted by H&S-Assessment of what is generally accepted as
professionals is that noone has ever beengood practice
prosecuted for following good practice.Followgood-Cross checking that suitable preparations and
practice and you will be secure.precautions beenput in place.
Almost all the manslaughter charges made againstThe following are a few important court
teachers havebeen involved with offsite visits.Icasesregarding good practice and duty of care in
estimate about 1-2,000,0000school visits haveH&S matters whichmay, by example illuminate
been made over the same period that theresome of the matters decided in thecourts.
havebeen about 6 prosecutions for mansalughter.Court Cases:
HSE actions are much more ikely to be for2003 Simonds v Isle of Wight LEA A five yearold
breaches of the law andregulations.returning to school from lunch at home went to
Primary Schools and breaches of the H&S law.playunsupervised on swings in the school grounds
The actual numbers of prosecutions from 1999and broke his arm.
-2003 are actuallyvery small only about 25 in totalThe LEA/school won and the judge held that :
are recorded as relating to-there was no "causative event" for the accident.
Primary Schools on the HSE Database. The-the child was playing alone and that the schoolhad
following is a breakdownof what thesean adequate way of managing the swings.
prosecutions were for:-no playground could be free of hazard and it was
Breach AgainstNumber 1999 -2004asunreasonable for the school to lock the swings
HASAWA 8as it was to ropeoff trees in a playing field.
Electricity Regs 3-since the mother had not delivered the child
Manual Handling Regs 2backinto the care of the school there was no
Management HSW Regs 5breach of duty on thepart of the school.
Construction1997 Wilson V the Governors of the Sacred
Design Regs 3Heart RC Primary School
Work Equipment 3A child going home at end of school day was
Other 3struck in the eye by anotherchild's coat .
So you can see that the main features ofThe Governors won and the judge held that:
prosecutions is foroffences under the Act itself-Whilst the school supervised at break and
and for breaches of the Managementof Healthlunchtimes it was notcommon practice for children
and Safety at Work Regulations. An importantto be tightly supervised at end ofday.
aspect isthat many of these breaches involved-The accident could have happened just as easily
contracts, so it is clearthat your control of theseoutsidethe school gates
needs to be secure.-The school had not breached it's duty of careor
If you are visited by an inspector they will notacted negligently.
generallyprosecute immediately. Though they say1998 Mullin v Richards
that they do useprosecution as an important leverTwo children had a "swordfight" with plastic rulers.
to help drive the HSC's targetsforward.One of the rulers broke entering a pupil's eye and
Inspectors are much more likely to give advicecausingpermanent damage. The claimfor damages
and information orin the case of breaches to issuewas dismissed on the basis that:
improvement or prohibitionorders-There was insufficient evidence to prove that
Good news about enforcementthe accidentwas foreseeable in what had been no
Out of 75 breaches prosecuted by HSE in Primarymore than a childish game.
Schools 1997 -