New Control of Dog Attack Health and Safety Standard

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LTB 463/10 - Royal Mail Letters - Introduction of New Control of Dog Attack Health and Safety Standard:

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No. 463/10
Ref P18
Date: 1 June 2010

To: All Postal Branches

Dear Colleagues
Royal Mail Letters - Introduction of New Control of Dog Attack Health and Safety Standard:

Introduction
With Dog Attacks on Delivery staff running at a constant 5000 - 6000 a year and the situation worsening the CWU "Bite-Back" Campaign was launched in 2008, aimed at firstly campaigning for the UK governments to introduce much needed Law changes and for improved dog attack risk control measures in Royal Mail Letters (RML). Representations were made to Royal Mail Letters (RML), calling for a review and overhaul of the Royal Mail Letters Dog Attack Policy and Guidance. RML agreed to a joint review and following a six-month period of preliminary work on reviewing and developing proposals for upgrading dog attack risk control measures in RML, two trial programmes were established to test the practicality of the upgraded recommendations in the field. The preliminary work included three months of RML-CWU-Unite/CMA Joint Working Groups, and three months of drafting and developing new documentation and materials with support from RML Internal Communications. Trials were then undertaken at Frome and Sheffield, representing two differently profiled Delivery Offices. The trial at Frome covered 15,000 delivery points, whilst the Sheffield programme was progressed over 76 delivery walks. Starting with the same drafted materials, developed from the findings of the Joint Working Groups, the Delivery Units amended their processes locally as deployment progressed, to ensure practical implementation and best impact. The contributions of the local DOMs (and DOM Support), Regional Safety Teams, and local CWU Safety Representatives were central to successful deployment and learning from the trials.

Work in the Joint Working Groups
In the initial phase, three Joint Working Groups (JWGs) were established involving RML and CWU. JWG1 reviewed risk assessment arrangements; JWG2 reviewed processes and practices; and JWG3 looked at hardware controls/dog deterrents. The outputs from JWG1 and JWG2 were developed by the respective JWG Leads and Internal Communications into drafted materials suitable for a trial. As part of this process, initial practicability tests were applied in producing the drafted documentation. For example, the separate WPQ assessment sheet produced by JWG1 specifically for dogs was refined for the trials, and ultimately integrated in to an amended WPQ1 form, thereby preventing proliferation of individual hazard assessment sheets for a range of individual hazards. JWG 3 was progressed independently of these trials due to the initial findings and outstanding questions.

Risk Assessment
JWG1 identified that the Walk Risk Assessment (WRA) process did not provide sufficient information to adequately assess the risk arising from individual dogs. In particular, more information was required around specific location, behaviour-attitude, and type of dog. Once gathered, this was to be backed up with specific incident experience, to refine the assessment. JWG1 developed a draft format to undertake the assessment. Taking the steer from the JWG findings, the trials found that obtaining this level of information was critical to improving the level of risk control, but that a significant investment in engaging delivery teams and driving the data gathering was required to achieve this end result. However, as a measure of success with the trials, the increase in the number of dogs identified on a walk was substantial, and in some cases by an order of magnitude. In order to achieve the level of engagement required to achieve this output, considerable effort was made by local management, Regional safety, and local CWU Safety Representatives to share and discuss the programme and importance to delivery staff. As a baseline, a WTLL and a supporting DVD was used to raise the profile, followed by dedicated sessions to explain the programme and materials. In one instance the creation of a scene-setting room with pictorial displays was used to heighten the impact, which was reinforced by a weekly update notice board. The use of hazard cards for delivery staff to record new or changed dog hazards identified whilst out on the walk, which could then be used as a basis for updating walk information upon return to the office was considered to be particularly beneficial. However, provision of a suitable card holder, and cards of a pocket size were found to be important requirements for maintaining use of the cards.

Process Controls
Having reviewed the existing procedural and process materials, JWG2 found that the materials were difficult to locate, inconsistently applied, and too focussed on reacting to incidents rather than identifying high risks and acting preventatively. A risk-based matrix of controls (including delivery suspensions) was developed, supported by process guides for managers and delivery staff, to shift the approach to a more preventative approach linked to the risk identification work arising from JWG1. Training was seen as key, reflected in the approaches described under "Risk Assessment". The risk-based matrix of controls has become well established in the programme following on from the trials, and has been evolved further. The feedback on the briefing packs and awareness raising materials was positive, although the manager and delivery staff guides, whilst containing good material, was thought to be too 'wordy' and vulnerable to being skimmed over by the end users. The use of frame inserts was developed ahead of the trials to tag mail at addresses with significant risk dogs; however, this was abandoned during the trials in favour of other options: paw stickers, a turned envelope, or a written 'D' on the first item of mail. Other means developed in the trials for flagging risk premises were: stickers on frames (although concerns were raised over the proliferation of stickers on frames), end of frame packs (with high risk premises cards, dog risk summaries and dog leaflets - seen as particularly useful for new starters and cover duties), and use of the WRAP tool to output dog risk summaries to carry out on a Walk. Work was also started on process tools but which were not taken in to deployment during the trials. These were a draft process map for managing dog attack risks and a recording system for temporary delivery suspensions. Finally, given the level of support required to advise the trial Units, it was recommended that a central support resource be identified for the roll-out.

External Engagement
The JWG2 review readily identified the need to change the public perception of dog attacks on Postmen and Women from being seen as a joke to a serious issue. Efforts were made during the trials to address this by: issue of letters from the DOM to premises considered high risk, refinement of USO suspension letters, and visits by the DOM and local CWU representative to high risk premises. (Leaflets have also been used in some RML Areas previously.) These activities were effective in many cases, with customers responding to the approach. However, it is also the case that some adverse customer reaction was experienced to the risk and USO letters, and to the use of paw stickers. It was evident that external materials need to be well worded and positioned.

Hardware Controls and Dog Deterrents
RML has made available for a number of years Dog Deterrents in the form of Dog Dazers (Ultrasonic sound device) and Bite-Back Spray (Aerosol peppermint spray). Efforts were made to gather information from the field on the effectiveness of these deterrents, but information returns were low, and those that did respond provided no assurance of a reliable impact on a range of dogs. Trials of deterrent devices took place in the Kent Area and resulted in a similar finding. It is evident that the issue of deterrents of this nature carries a clear risk of Postmen and Women putting themselves in a risk situation due to a false confidence in a deterrent device. As such, it is unclear as to the circumstances under which a line manager could formally adopt one of these deterrents as a control measure, as RML could not warranty their effectiveness at this stage. Consideration was also given to the use of pierce-resistant clothing, but this is bulky and unlikely to be worn by staff during in summer, or indeed at any time. The only hardware control which gave some level of assurance and usability was the "Post it Peg", which provides a specific protection for posting mail through a letter box behind which is a biting dog. Some of the feedback was not supportive, but this did not relate to effectiveness but rather the carrying of the tool.

Conclusions
The trials in Frome and Sheffield have built on the underlying work of the JWGs and the development team. Taken together with the investigations by JWG3 on hardware controls, it was possible to construct a new approach to controlling the risk of dog attacks, which has enhanced risk assessment and preventative-based control measures.

The Conclusions, Recommendations and Forward Plan:

1. Dog-specific risk assessment questions have been incorporated in to WRAP and recommended controls aligned in to the WRA Standard (SMS2A.1) and Appendix.
2. Briefing packs and awareness materials have been finalised based on the models used for the trials, with consideration given to materials to support a scene-setting display.
3. The format for hazard recording cards has been finalised, including provision of a suitable holder for use on delivery duties.
4. The risk-based control matrix has been refined to ensure a preventative approach, and the supporting process guides were simplified.
5. The formats for the specific risk flagging mechanisms have been finalised, to cover: end of frame packs, and 'D' marking of letters.
6. The risk summary outputs from WRAP tailored to fit with end of frame packs, and hazard card holders.
7. A specific central support for launch of the dog risk control programme.
8. The wording on the USO (suspension) Letters refined with input from RML Regulatory, and external awareness leaflets refined with input from External Communications.
9. Purchase of further active dog deterrents to be blocked; this to be subject to review should new evidence become available which demonstrates effectiveness.
10. Post-It Peg has been included as a recognised hardware control in the Appendix to the PPE Standard (SMS2.6) and included in WRAP.

The above final report has been compiled in conjunction with Ian Stockdale RML Head of Safety Management.

I would like to thank all the members of the Royal Mail/ CWU Joint working groups in particular the CWU Members Keith Franklin ASR, Darrell Bennett ASR, Ted Stead ASR, Bob Freeman ASR, John Nash ASR, Paul Fenton ASR. The JWG will be meeting again in the future to discuss any forward ongoing issues, monitoring and review of the above agreed new arrangements.

Yours Sincerely

Dave Joyce
National Health, Safety & Environment Officer


Attached:

· Dog Risk Assessment Control Matrix (App 1)
· Framework supporting Info v2
· Framework - Unit Sector Info Report
· Framework - Report Form - Office
· Framework - Report Form = Print
· Police Letter
· Control of Dog Attacks Risk
· Suspension after Warning Letter
· Dog Hazard Neighbouring Property Letter
· Dog Hazard Immediate Suspension Letter
· Dog Hazard Reinstatement Letter
· Dog Hazard Warning Letter
· WTLL Dog Attacks
· Hazard Poster - Dog
· Dog Attack Leaflet
· Advisory Dog Letter