{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Risk Assessment and Risk Management Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} maintains a consistent, systematic and effective approach to identifying, assessing, controlling, monitoring and reviewing risks arising from its activities as an employment business supplying temporary healthcare workers to clients in England. {{org_field_name}} does not provide or manage regulated care services and does not assume the client’s responsibility for the management of care, the premises, equipment, care plans, clinical governance or local systems of work. However, {{org_field_name}} recognises that it retains legal and contractual responsibilities for matters within its knowledge and control, including worker selection, suitability checks, communication of placement information, training, escalation of concerns and co-operation with clients.

Risk management is essential to protecting temporary workers, the agency’s internal staff, clients, service users and other persons who may be affected by the agency’s activities. This policy establishes the arrangements for assessing placement-related and organisational risks, obtaining and communicating relevant information, responding to incidents and concerns, and co-operating with clients to ensure that risks are controlled so far as is reasonably practicable.

This policy has been prepared with regard to the Health and Safety at Work etc. Act 1974; the Management of Health and Safety at Work Regulations 1999; the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013; the Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended; the Agency Workers Regulations 2010; the Personal Protective Equipment at Work Regulations 1992, as amended; the Control of Substances Hazardous to Health Regulations 2002; the Manual Handling Operations Regulations 1992; the Equality Act 2010; the Data Protection Act 2018 and UK GDPR; and other health and safety legislation applicable to the activities being undertaken. Where workers are supplied to a CQC-regulated client, they must comply with that client’s lawful policies, procedures and regulatory arrangements, but {{org_field_name}} does not represent that it is itself a CQC-registered care provider.

2. Scope

This policy applies to:

• all directors, employees, consultants and other personnel working within {{org_field_name}};
• all temporary workers supplied by {{org_field_name}}, including registered nurses, nursing associates, healthcare assistants, support workers and other healthcare personnel;
• all proposed and current placements arranged by {{org_field_name}};
• risks arising from the agency’s office, recruitment, onboarding, payroll, worker-management and placement activities;
• risks relating to worker suitability, competence, occupational health, safeguarding, lone working, manual handling, infection exposure, violence and aggression, fatigue, working time, stress, data protection and information security;
• information received from clients concerning the workplace, role, service users, equipment, qualifications, training, health surveillance and control measures; and
• incidents, near misses, complaints and concerns reported to {{org_field_name}} in connection with a placement.

This policy does not replace a client’s health and safety policy, clinical governance arrangements, care plans, risk assessments, safeguarding procedures or emergency arrangements. The client remains responsible for matters under its management and control, including the safety of its premises, equipment and local systems of work. {{org_field_name}} will nevertheless take all reasonably practicable steps within its control and will co-operate and exchange relevant information with the client.

3. Related Policies

This policy should be read with the following policies and procedures:

• Health and Safety Policy;
• Placement and Client Suitability Procedure;
• Recruitment, Selection and Vetting Policy;
• Agency Worker Handbook;
• Safeguarding Adults Policy;
• Safeguarding Children Policy, where workers may work with children;
• Incident, Accident and Near-Miss Reporting Procedure;
• Whistleblowing and Raising Concerns Policy;
• Infection Prevention and Control Policy;
• Lone Working Policy;
• Manual Handling Policy;
• Violence and Aggression Policy;
• Personal Protective Equipment Procedure;
• Occupational Health and Fitness to Work Procedure;
• Stress and Worker Wellbeing Policy;
• Equality, Diversity and Inclusion Policy;
• Pregnancy, Maternity and New or Expectant Mothers Risk Procedure;
• Data Protection, Confidentiality and Information Security Policy;
• Business Continuity and Emergency Planning Policy; and
• Staff Training, Competence and Professional Registration Policy.

4. Policy Statement

{{org_field_name}} is committed to preventing injury and work-related ill health and to managing risks so far as is reasonably practicable. It will:

• maintain suitable and sufficient assessments of risks arising from matters within its control;
• obtain sufficient information from each client before introducing or supplying a worker;
• assess whether the proposed worker has the qualifications, experience, competence, health status and other attributes required for the assignment;
• provide workers with comprehensible information about known placement risks, required skills, training, health surveillance, emergency arrangements and control measures before the assignment begins, or as soon as reasonably practicable where genuinely urgent circumstances apply;
• co-operate and co-ordinate with clients and other duty-holders;
• ensure that workers are not knowingly supplied to unsafe or unsuitable placements;
• suspend or withdraw a worker where there is a serious or uncontrolled risk;
• investigate incidents and use the findings to improve systems;
• consult workers on health and safety matters that affect them;
• make reasonable adjustments for disabled workers where required;
• protect workers who raise genuine health, safety, safeguarding or public-interest concerns; and
• review risk-control arrangements following relevant legal, operational or organisational changes.

5. Responsibilities

Directors and Health and Safety Lead

The directors have overall accountability for the agency’s health and safety and risk-management arrangements. They will:

• appoint a competent person to assist the agency in meeting its health and safety duties;
• ensure that suitable resources, systems and authority are available to manage risk;
• approve and review this policy;
• maintain oversight of the agency’s risk register;
• ensure that client and placement suitability checks are completed before workers are supplied;
• ensure that identified risks and control measures are communicated to affected workers;
• ensure that workers’ qualifications, professional registration, competence, training and occupational health information are verified where relevant;
• establish procedures for emergencies, serious and imminent danger and out-of-hours escalation;
• ensure that incidents and concerns are investigated proportionately;
• determine, with the client, who is responsible for any required RIDDOR report;
• monitor trends in incidents, complaints, safeguarding concerns, cancelled placements and client feedback;
• take prompt action where a client fails to provide required information or maintain adequate controls; and
• ensure that records are retained securely and for the applicable legal or organisational retention period.

Recruitment, Compliance and Placement Staff

Recruitment, compliance and placement staff will:

• obtain sufficient information from the client about the role, location, hours, duties, experience, qualifications and training required;
• identify any known health and safety risks and the measures taken by the client to prevent or control those risks;
• confirm whether the role requires occupational health clearance, vaccination, health surveillance, PPE, manual-handling competence, clinical competence or other role-specific checks;
• ensure that the worker is suitable for the role and that required checks have been completed before supply;
• provide the worker with accurate assignment information;
• record material information received from the client and provided to the worker;
• escalate incomplete, inconsistent or concerning information to a director or the Health and Safety Lead;
• refrain from supplying a worker until material safety concerns have been satisfactorily resolved; and
• record any decision to decline, suspend or terminate a placement on health and safety grounds.

Clients and Hirers

Before a worker is supplied, the client will be required to provide accurate and sufficient information concerning:

• the identity and location of the client;
• the proposed start date, duration, hours and nature of the work;
• the duties the worker will perform and any duties the worker must not perform;
• the experience, training, qualifications, professional registration and authorisations required;
• known workplace and role-specific health and safety risks;
• the steps taken to eliminate or control those risks;
• induction, supervision and emergency arrangements;
• manual-handling requirements and the equipment available;
• infection risks, COSHH information and required PPE;
• any required health surveillance, occupational health clearance or vaccination evidence;
• lone-working, violence, aggression or behavioural risks;
• arrangements for rest breaks, welfare facilities and reporting incidents;
• the name or role of the person responsible for day-to-day supervision; and
• any material change to the assignment or risk profile.

The client is responsible for the day-to-day control of the work, safe premises, safe equipment, local induction, local supervision, emergency arrangements and placement-specific risk assessments. The client must inform {{org_field_name}} promptly of incidents, restrictions, concerns or material changes affecting a supplied worker.

Temporary Workers

Temporary workers must:

• take reasonable care of their own health and safety and that of others who may be affected by their acts or omissions;
• co-operate with {{org_field_name}} and the client on health and safety matters;
• provide accurate information about their qualifications, competence, experience, professional registration, training and fitness to undertake the proposed role;
• read and follow assignment information, local induction, risk assessments, care plans, emergency arrangements and safe systems of work;
• undertake only duties for which they are competent, authorised and properly supported;
• use equipment and PPE correctly and report defects, loss or inadequate provision;
• report hazards, incidents, injuries, near misses, safeguarding concerns and material changes immediately to the client and {{org_field_name}};
• stop work and move to a place of safety where they reasonably believe that there is serious and imminent danger;
• contact {{org_field_name}} promptly where the client asks them to undertake unsafe, unlawful or unauthorised work;
• disclose any condition or change that may require a risk assessment or reasonable adjustment, without being required to disclose more medical information than is reasonably necessary;
• attend required training, induction and health surveillance; and
• preserve confidentiality and comply with data protection requirements when reporting incidents.

6. Principles of Risk Assessment

All risk assessments completed by or on behalf of {{org_field_name}} must be suitable and sufficient, proportionate to the nature of the risk and completed by a person with appropriate knowledge and competence. The assessment process will:

1. identify hazards;
2. identify who may be harmed and how;
3. evaluate the likelihood and potential severity of harm;
4. identify existing controls;
5. apply the hierarchy of controls by eliminating risks where reasonably practicable and otherwise reducing them through substitution, engineering controls, safe systems of work, training, supervision and PPE;
6. identify further action, the responsible person and completion date;
7. record significant findings and communicate them in a comprehensible form to affected persons;
8. verify that agreed controls have been implemented; and
9. monitor and review the assessment.

Risk assessments must be reviewed where:

• there is reason to suspect that the assessment is no longer valid;
• there has been a significant change in the work, worker, client, equipment or working environment;
• an incident, near miss, complaint or safeguarding concern identifies a possible deficiency;
• a worker reports pregnancy, recent childbirth or breastfeeding and a relevant risk may arise;
• a worker is under 18 years of age;
• a disability, medical condition or reasonable-adjustment requirement is identified;
• new information about a hazard becomes available; or
• legislation, official guidance or accepted practice materially changes.

A routine review date does not remove the obligation to review an assessment sooner when any of these circumstances arise.

7. Types of Risk

Risks relevant to the agency’s activities may include:

• slips, trips and falls;
• manual handling and moving and handling of people;
• sharps and needlestick injuries;
• exposure to blood, bodily fluids, infectious diseases and hazardous substances;
• inadequate PPE or respiratory protective equipment;
• unsafe premises, equipment or systems of work;
• fire, evacuation and emergency risks;
• lone working;
• violence, aggression, harassment and sexual harassment;
• fatigue, excessive working hours, insufficient rest and travel-related risks;
• stress, burnout and poor mental wellbeing;
• medication, clinical and record-keeping risks where the worker is authorised to perform such duties;
• safeguarding concerns, abuse, neglect, exploitation and modern slavery indicators;
• inadequate induction, supervision, competence or staffing levels;
• risks affecting pregnant workers, new mothers, breastfeeding workers, young workers and disabled workers;
• data protection, cyber-security and confidentiality risks;
• failures in professional registration, occupational health or employment checks;
• business interruption, system failure and loss of essential records;
• reputational, contractual, financial and regulatory risks; and
• risks arising from unclear allocation of responsibility between the agency and client.

8. Risk Assessments Undertaken by {{org_field_name}}

{{org_field_name}} will maintain or arrange risk assessments appropriate to its activities, including:

• office and general business operations;
• display-screen equipment for relevant office and home-based workers;
• fire and emergency arrangements for premises under the agency’s control;
• lone working;
• work-related stress and wellbeing;
• pregnancy, new motherhood and breastfeeding where relevant;
• young workers, where any person under 18 may be employed or supplied;
• disabled workers and reasonable adjustments;
• data protection and information security, including data protection impact assessments where required;
• business continuity;
• worker travel where the agency controls or requires particular travel arrangements;
• client and placement suitability; and
• any activity, equipment, substance or hazard under the agency’s control.

A documented placement suitability assessment must be completed before the first supply to a new client or new type of assignment. It must be reviewed when the duties, location, service, working conditions or known risks materially change. The assessment must record the information supplied by the client, outstanding information, control measures, responsible persons, approval decision and review date.

Where {{org_field_name}} does not control the workplace, it will not attempt to replace the client’s workplace risk assessment. It will obtain, evaluate and communicate sufficient information to decide whether the placement and proposed worker are suitable and whether further clarification or controls are required.

9. Risk Assessments in Client Settings

Before starting an assignment, workers must receive or be given access to relevant placement information, including local induction, emergency arrangements, reporting procedures, role boundaries, material risk assessments and applicable safe systems of work.

Workers must:

• follow the client’s lawful risk-control measures;
• check that they understand the duties, supervision and escalation arrangements;
• undertake only work for which they are competent, authorised and appropriately supported;
• report missing, unclear or inadequate controls immediately;
• record observations and actions in accordance with the client’s authorised documentation procedures; and
• contribute to care plans or client risk assessments only where this falls within their role, competence and professional scope of practice and the client has authorised them to do so.

Where a worker identifies a serious deficiency, the worker must notify the client and {{org_field_name}} without delay. {{org_field_name}} will assess whether the worker should remain at the placement, be temporarily withdrawn or be reassigned.

10. Placement Information Before Supply

{{org_field_name}} will not introduce or supply a worker unless it has obtained sufficient information to determine that the worker is suitable for the position. The information sought from the client will include:

• the type of work;
• the location and working hours;
• the anticipated duration;
• the experience, training, qualifications and professional registration required;
• any legal or professional requirements;
• known health and safety risks and the measures taken to control them;
• required PPE, occupational health clearance or health surveillance;
• induction and supervision arrangements;
• the duties and limits of the role; and
• any reason known to the client why the proposed worker may be unsuitable.

Material information will be provided to the worker in a durable and comprehensible form before the assignment begins. Where information changes, the worker will be informed promptly and the suitability of the placement will be reassessed.

Where the client fails to provide sufficient information, the placement must not proceed until the information has been obtained and any material concern resolved.

11. Dynamic Risk Assessment and Serious or Imminent Danger

Dynamic risk assessment is a continuous process used when circumstances change or an unexpected hazard arises. It does not replace a suitable formal risk assessment.

A worker who encounters an unexpected risk must:

• pause and assess the immediate danger;
• avoid undertaking any task outside their competence or authority;
• apply available control measures only where it is safe and appropriate to do so;
• obtain assistance from the client’s responsible person;
• move to a place of safety and stop the activity where there is serious or imminent danger;
• contact emergency services where necessary;
• report the circumstances promptly to the client and {{org_field_name}}; and
• make an accurate record as soon as practicable.

No worker will be instructed to resume work until the risk has been adequately assessed and controlled. A worker who leaves or refuses to return to a situation they reasonably believe presents serious and imminent danger must not be subjected to retaliation for raising the concern in good faith.

12. Incident, Accident, Near-Miss and Concern Reporting

Workers must report accidents, injuries, exposure incidents, near misses, dangerous conditions, safeguarding concerns and work-related ill health promptly to both the client and {{org_field_name}}, using the applicable reporting systems.

{{org_field_name}} will:

• ensure that immediate welfare and medical needs are addressed;
• obtain and preserve relevant factual information;
• notify the client and any other relevant duty-holder;
• investigate matters within its responsibility and co-operate with the client’s investigation;
• identify immediate and underlying causes;
• record corrective actions, responsible persons and completion dates;
• assess whether the worker should remain at the placement;
• share relevant lessons while protecting personal and confidential information; and
• review affected risk assessments, training and procedures.

For a potentially reportable event under RIDDOR, {{org_field_name}} and the client will establish without delay which organisation is the “responsible person” required to submit the report. The decision and supporting reasons must be documented. Where {{org_field_name}} is the responsible person, it will make the report within the statutory timescale. Where the client is responsible, {{org_field_name}} will obtain confirmation that the matter has been considered and will co-operate by supplying relevant information.

Safeguarding referrals will be made to the relevant local authority, police, professional regulator or other appropriate body in accordance with the Safeguarding Policy. {{org_field_name}} will notify the CQC only where it has an applicable legal duty or is specifically providing information in support of a CQC-regulated client’s notification. The agency must not imply that it is itself a CQC-registered provider.

13. Risk Register

The directors will maintain an organisational Risk Register containing, as a minimum:

• a clear description of each risk;
• the persons, services or objectives potentially affected;
• existing control measures;
• an assessment of likelihood and impact before and after controls;
• required further action;
• the named risk owner;
• action deadlines;
• the date of the most recent review;
• the next review date;
• relevant incidents, complaints, audit findings or trends; and
• the status of the risk, including whether it has been accepted, reduced, transferred, escalated or closed.

High or critical risks must be escalated to a director immediately and must not wait for the routine quarterly review. The Risk Register will be formally reviewed at least quarterly and whenever a significant new or changed risk is identified.

14. Training, Competence and Information

{{org_field_name}} will ensure that workers and internal staff receive information, instruction and training appropriate to their responsibilities and the risks they may encounter.

Training requirements will be determined by:

• the worker’s role and scope of practice;
• the client’s stated requirements;
• the placement risk information;
• legal and professional requirements;
• the worker’s qualifications, experience and assessed competence; and
• lessons from incidents, complaints and audits.

Depending on the assignment, training and competence requirements may include:

• health and safety;
• incident and near-miss reporting;
• safeguarding adults and children;
• infection prevention and control;
• moving and handling;
• fire safety;
• basic or immediate life support;
• medication management;
• lone working;
• violence and aggression;
• COSHH;
• sharps safety;
• PPE and respiratory protective equipment;
• information governance;
• equality and human rights;
• Mental Capacity Act awareness; and
• role-specific clinical competencies.

Training records must show the subject, provider, completion date, assessment outcome where applicable and expiry or refresher date. Expired or unverified training must not be treated as current. Workers must not be supplied to duties requiring competence that has not been verified.

Placement-specific induction remains the client’s responsibility, but {{org_field_name}} must obtain reasonable assurance that appropriate induction and supervision arrangements exist.

15. Personal Protective Equipment, Equipment and Health Surveillance

The placement assessment must establish what PPE, equipment, fit testing, health surveillance or occupational health controls are required and which organisation will provide them.

Where {{org_field_name}} is legally responsible for providing PPE, it will provide suitable PPE free of charge, together with appropriate information, instruction, training, storage, maintenance and replacement arrangements. Where the client provides PPE because it controls the task and workplace, {{org_field_name}} will obtain reasonable assurance that suitable PPE will be available without charge to the worker.

PPE must be suitable for the risk, task, environment and individual worker. Workers must report missing, defective, poorly fitting or unsuitable PPE immediately and must not be required to undertake a task where necessary protection is unavailable.

Where health surveillance is required by law, the responsible organisation must ensure that suitable arrangements are in place. Relevant information about any required health surveillance must be provided to the worker before duties commence.

16. Pregnancy, New Mothers and Breastfeeding

A worker is encouraged to notify {{org_field_name}} in writing as soon as reasonably practicable if she is pregnant, has given birth within the previous six months or is breastfeeding, so that relevant workplace risks can be assessed.

On receiving notification, {{org_field_name}} will:

• handle the information confidentially and in accordance with data protection law;
• consult the worker about relevant risks and any support required;
• notify the client only to the extent necessary to protect health and safety and, where appropriate, with the worker’s knowledge;
• obtain or require a review of the relevant workplace risk assessment;
• consider risks including manual handling, infectious diseases, hazardous substances, radiation, night work, fatigue, violence and prolonged standing;
• co-operate with the client to adjust working conditions or hours where required;
• consider suitable alternative work where necessary and legally applicable; and
• document decisions and review the arrangements as circumstances change.

A worker must not be subjected to unfavourable treatment because of pregnancy, maternity or a related health and safety requirement.

17. Young Workers

{{org_field_name}} will not employ or supply a person under 18 unless a specific assessment of risks to young persons has been completed and the proposed work is lawful and suitable.

The assessment must consider the young person’s lack of experience, maturity and awareness of risk; exposure to physical, biological or chemical agents; work equipment; work organisation; training; supervision; working hours; and the nature and degree of any unavoidable risk.

A young worker must not be supplied to work beyond their physical or psychological capacity or to prohibited or unsuitable duties. Enhanced instruction, training and supervision must be arranged where necessary.

18. Communication and Worker Consultation

{{org_field_name}} will provide health and safety information in a form that is accurate, timely, comprehensible and appropriate to the worker’s role.

The agency will:

• provide relevant placement risk information before work starts;
• use plain language and explain technical terms where necessary;
• consider language, literacy, disability and communication needs;
• provide accessible formats or reasonable adjustments where required;
• maintain a reliable out-of-hours contact and escalation route;
• communicate material changes promptly;
• consult workers or their representatives on health and safety matters that affect them;
• invite workers to contribute to risk assessments and reviews where appropriate; and
• record significant safety information supplied to and received from clients and workers.

A worker who does not understand the information provided must seek clarification before carrying out the affected task.

19. Person-Centred Practice and Client Care Plans

{{org_field_name}} recognises that workers supplied to health and social care clients may be required to support lawful, person-centred decisions involving a balance between safety, autonomy, dignity and choice.

The client is responsible for assessing and documenting service-user risks, care plans, capacity decisions and best-interests decisions. Temporary workers must:

• follow the current authorised care plan and client risk assessment;
• respect the individual’s rights, dignity, preferences and lawful choices;
• act within their competence, role and professional obligations;
• apply the Mental Capacity Act 2005 and client procedures where relevant;
• report any concern that a care plan is absent, outdated, unsafe or inconsistent with the person’s current needs; and
• not make or authorise significant changes to a care plan, restriction or risk decision unless authorised and competent to do so under the client’s governance arrangements.

Where immediate action is necessary to prevent harm, the worker must take proportionate action within their competence and report and document the circumstances without delay.

20. Refusal, Suspension or Withdrawal of a Placement

{{org_field_name}} may refuse to commence, suspend or terminate a placement where:

• sufficient placement information has not been provided;
• required induction, supervision, equipment or PPE is unavailable;
• the worker lacks the required competence, qualification, registration or occupational health clearance;
• the client materially changes the role without prior assessment;
• a serious or uncontrolled health and safety risk is identified;
• the worker is instructed to perform unlawful, unsafe or unauthorised duties;
• safeguarding concerns are not being addressed appropriately; or
• the client fails to co-operate with a reasonable risk-control requirement.

The decision, reasons, immediate safeguards and required follow-up action must be recorded. Where withdrawal could affect continuity or safety, {{org_field_name}} will communicate promptly with the client while ensuring that the worker is not required to remain in serious or imminent danger.

21. Monitoring, Assurance and Policy Review

The directors will monitor the effectiveness of this policy using:

• incident, accident and near-miss trends;
• safeguarding concerns;
• complaints and whistleblowing reports;
• worker and client feedback;
• training and competency compliance;
• placement suspensions and refusals;
• audit results;
• professional registration and occupational health exceptions;
• RIDDOR events;
• sickness absence and wellbeing indicators where appropriate;
• data breaches; and
• overdue risk-control actions.

This policy will be formally reviewed at least annually and earlier where:

• legislation, official guidance or regulatory arrangements materially change;
• the agency introduces a new service, role, client type or working method;
• an incident, audit, complaint or legal claim indicates that the policy may be ineffective;
• there is a material change in the agency’s organisation or responsibilities;
• a client or worker identifies a significant omission; or
• there is reason to believe that an associated risk assessment is no longer valid.

22. Definitions

For the purposes of this policy:

Regulated activity means an activity requiring registration under the Health and Social Care Act 2008 regulatory framework. {{org_field_name}} supplies temporary workers and does not itself carry on a regulated care activity unless its operating model is formally changed..

Agency worker means an individual supplied by {{org_field_name}} to work temporarily under the supervision and direction of a client or hirer.

Client or hirer means the organisation or person to whom a worker is introduced or supplied.

Employment business means a business that supplies persons to work temporarily for and under the control of another person.

Hazard means anything with the potential to cause injury or ill health.

Risk means the likelihood that harm will occur and the severity of that harm.

Suitable and sufficient risk assessment means an assessment proportionate to the nature of the work and risk, capable of identifying significant hazards and the measures required to control them.

Dynamic risk assessment means an immediate assessment made in response to changing or unexpected circumstances; it does not replace formal assessment.

Serious and imminent danger means a situation presenting a real and immediate risk of serious harm.

Competent person means a person with sufficient training, knowledge, experience and other qualities to assist in managing the relevant health and safety matter.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.