Template: Example of guidelines for taking remedial action: Critical failure points and non-compliance

Transcription

1 Template: Example of guidelines for taking remedial action: Critical failure points and non-compliance This document provides an example of guidelines that an organisation may establish to inform the interpretation of audit reports and findings, as well as responses to some of the most common issues found. The document has been derived from approaches applied by procurement organisations. Critical issues: For the majority of the critical issues that are listed, if they were found in a prospective supplier s supply chain, the organisation would expect the corrective action to take place before a trading relationship was established. Critical issues are assessed to be fundamental and where they exist, pose significant financial and reputational risks to the supply chain and procurers. If the report relates to the supply chain of an existing supplier to the organisation, the corrective action should generally occur within the timeframe indicated (subject to mitigating circumstances). Engagement and progress are what is required, so whilst the issue may still be present for some of the critical issues, the supplier should not be penalised if they are genuinely working towards improvements. For the issues that have an immediate timeframe, it is assessed that the issue will be relatively easy to solve and the procuring organisation should expect this timeframe to be met, however remedial actions and timeframes should always be agreed by all parties and be realistic and proportionate.

2 Measure ETI Base Code section Finding Corrective action Time frame Critical Employment is Unpaid, forced, bonded Ensure all workers are able to leave employment Immediate freely chosen or trafficked labour and return any deposits or other money withheld. Critical Employment is Original IDs held Return all original IDs to workers, keeping only a Immediate freely chosen copy on file. Ensure all workers are able to leave employment Critical Employment is freely chosen Workers fined for not working overtime Ensure that all workers are able to refuse to work overtime. Workers must not be fined for not working over their standard hours. Steps must be taken to reduce the reliance on overtime, even during busy periods Immediate three months removal of fines and significant improvements re: reliance on overtime. Critical Employment is Prison labour found Ensure that all workers are working of their own Immediate freely chosen free will. This is especially important in China. No workers on site should be serving any form of custodial sentence Critical Health and safety Dangerous storage of production materials Development of safe system of storage away from production sites and accommodation significant improvement Critical Health and safety Locked fire exits Ensure all fire exits are unlocked at all times when workers are on site. This should also be true of fire Immediate

3 Critical Health and safety Only 1 feasible and useable fire exit Critical Health and safety Machinery poses a risk to the lives and/or limbs of those working with or around them Critical Health and safety Pregnant and breastfeeding workers doing dangerous or hazardous work Critical Health and safety Premises are not structurally safe exits in accommodation. Ensure that more than one fire exit is available and useable for each floor of the production site. This should also be true of fire exits in accommodation. Ensure that all machinery is safely operated and regularly maintained and cleaned, and that all moving parts have guards to protect workers. Where appropriate, machinery should be 2 button operated and have a working emergency stop button Pregnant or breastfeeding workers to be removed from dangerous or hazardous work areas and given work in areas which do not risk health and well being of the mother or the child. Away from heat, chemicals, dangerous machinery etc. Structural changes made following local law and regulations. Consultation made on completing three months significant improvement working towards structural changes significant improvement no further risk to life or limb, and guards in place. Operation and emergency stop buttons in progress Immediate Six months

4 structural work on entire site, and work completed on ensuring immediate risk is resolved. Critical Health and safety Accident compensation Workers should be provided with accident compensation if they are involved in a workplace incident or contract a work-related illness. All workers should be covered by any necessary state insurance for the provision of such compensation. Critical Child labour Children found working Confirm age and name of all children found. at production site Children removed from work and full remediation plan initiated. Children to be entered into school and wages paid to ensure that they have financial security to remain. No further recruitment of children and robust age verification system to be installed. Critical Working hours Workers working over Initiate work to improve productivity and production 350 hours per month planning to ensure that the number of working hours is reduced. Ensure that all workers have 1 day off per week. Ensure that workers pay is not reduced with the decrease in working hours all workers should be covered by state insurance scheme and accident compensation paid in all entitled cases. Immediate three months all confirmed children included in remediation work. No further recruitment of children movement towards legally compliant hours. Engagement in improvement

5 programme to reduce hours Critical Working hours 1 day off per week Workers to be provided with at least one day off (full period of 24 hours rest) every week. Linked to work on productivity and production planning production should not be planned over 7 day week, but over 6 day week to allow workers to have day of rest. Critical Discrimination Pregnancy testing used End the use of pregnancy testing as part of the for recruitment recruitment process. Workers to be employed based on merit, and not pregnancy status Critical Discrimination Jobs unavailable to Ensure that workers are permitted to return to work workers after maternity when they return from maternity or paternity leave. leave Workers should be able to return to the role that they were in when they went on leave. Any cover for this role while they are on leave should be temporary by agreement. Critical Harsh or inhumane Workers being End use of physical violence and/or punishment of treatment physically abused workers. movement towards provision of rest day. Engagement in improvement programme. Immediate all workers able to return to work. Production site should have written policy on maternity leave which is followed. Immediate

6 Major issues Major issues are assessed to be important areas for remedial action and pose financial and reputational risks to the supply chain and procurers. While important, it may be that remedial actions can be taken over a longer timeframe than Critical Issues. For suppliers (and their supply chains) that do not yet have a trading relationship with the organisation, Major issues should not normally prevent a relationship being established. However, if the production site does not demonstrate effective improvements on the issues raised, within the timeframes agreed, there would be cause to review or terminate any contractual agreement. If the report relates to the supply chain of an existing supplier to the organisation, the corrective action should generally occur within the timeframe indicated (subject to mitigating circumstances). Engagement and progress are what is required, so whilst the issue may still be present for some of the critical issues, the supplier should not be penalised if they are genuinely working towards improvements. For the issues that have an immediate timeframe, it is assessed that the issue will be relatively easy to solve and the procuring organisation should expect this timeframe to be met, however remedial actions and timeframes should always be agreed by all parties and be realistic and proportionate.

7 Measure ETI Base Code Section Major Employment is freely chosen Major Employment is freely chosen Major Employment is freely chosen Finding Corrective action Time frame Workers paying Ensure all workers are able to leave employment One month deposits and return any deposits or other money withheld. Workers not being paid Ensure that all workers are paid their final salary One month their final salary when when they have left the production site. This leaving should be paid at the normal time, and should include payment for all hours worked, including overtime. Significant limitation on Ensure that all workers are allowed to move freely One month workers freedom of around the site, within the bounds of safety, and movement (i.e. gate are able to leave the site at any time. passes, toilet cards, aggressive prevention of movement, intimidation) Major Freedom of Workers unable to Ensure that all workers have free and fair access association unionise to trade unions and are able to join if they so wish. progress made and any significant preventative measures halted

8 Major Freedom of No means for workers Ensure that workers are able to freely association to communicate with communicate with management. This may involve progress made and management the installation of a suggestion box, or the timeline in place for formation of a workers committee. continued work Major Freedom of Workers penalised for Stop all fines immediately. Ensure that all Immediate all fines association union or other penalising measures are stopped and historical stopped representational ones overturned where possible. Ensure that memberships workers have free and fair access to significant progress representational measures inside and outside the made on historical production site issues and access Major Health and safety Chemicals unsafe handling of chemicals Major Health and safety Chemicals unsafe use of chemicals Ensure workers and management are aware of safety issues for all chemicals and MSDS sheets are provided. All chemicals should be stored and handled in accordance with the safety guidelines. PPE must be provided and worn in accordance with guidelines. Ensure workers and management are aware of safety issues for all chemicals and MSDS sheets are provided. All chemicals should be stored and handled in accordance with the safety guidelines. PPE must be provided and worn in accordance One month training and awareness raising completed, and all workers safely handling chemicals One month training and awareness raising completed, all workers safely using chemicals

9 Major Health and safety PPE workers do not have the correct PPE for the work and chemicals and machines that they are using Major Health and safety Fire inadequate lighting Major Health and safety Fire escape routes are not clear Major Health and safety Fire inadequate numbers or types of fire fighting equipment Major Health and safety Fire no or inaudible fire alarm with guidelines. PPE to be provided and management to actively encourage its use at all times. Training to be given to workers to educate them about risks posed by chemicals and machinery, and the benefits of PPE Ensure that all emergency lighting is functioning and workers are able to safely evacuate the site during an emergency. Ensure that all escape routes on the site are clear from any obstruction, including work in progress. All fire fighting equipment must be adequate for the risks present, well maintained and be sufficient in number in all areas of the site. Ensure that a fire alarm is in place which can be activated and is audible in all areas of the site. Activation points should be clearly marked and workers should be aware of what the alarm sounds like One month training given and significant improvements in the use of PPE. One month One month Two months if installation of an alarm is required One month if improvements are required

10 Major Health and safety Housekeeping toilets are not hygienic Major Health and safety Housekeeping canteen and/or food storage not hygienic Major Health and safety Housekeeping no access to potable water Major Health and safety Machinery Guards on machines missing or damaged Major Health and safety First Aid Boxes not freely accessible Major Health and safety First aid no or limited access to medical attention when required All toilets should be regularly cleaned and maintained, with free access to clean water, soap and hand drying facilities at all times Ensure that all food storage areas and hygienic, and that workers have a place to hygienically store food should they bring it in. Canteens should have legally compliant facilities for cooking and storing food Workers to have access to potable water in all areas of the site (where it is safe to do so). Workers must be free to drink water at any time. All machines must have guards to prevent workers from being injured all moving parts must be guarded. Ensure that all first aid boxes are unlocked and workers are able to access them when required (this may be via a trained first aider). All boxes to be fully stocked with hygienic and in-date items Workers to have access to timely medical attention when required, either via a trained medic on site, or an arrangement with a local clinic One month One month Immediate One month One month One month

11 Major Children and Young workers A list of young workers to be compiled and One month young workers engaged in hazardous compared with job roles and hazardous working work areas. All young workers to be removed from hazardous work, and hazardous working environments. Major Children and Inadequate age All workers to have their age verified before young workers verification checks starting work at the production site. An age verification policy to be established, and enforced. No worker below the legal minimum working age should be employed, and where there are doubts more extensive checks to be carried out (i.e. medical) Major Wages Failure to pay minimum wage Major Wages No legal overtime premium paid Workers to be paid more, working up to the legal minimum wage where this is a significant improvement on the current wage, as a result of improvement work in productivity and profitability. Work must focus on allowing workers to benefit from improvements Workers to be paid legal overtime premiums as a result of improvement work on productivity and profitability. Staggered improvements working action plan in place and initial steps being taken. action plan in place and initial steps being

12 towards the legal premium should be in place where it requires significant improvements. Major Wages Late payment of wages Workers to be paid their full wage on time, to ensure regular and reliable income. Work to improve production planning and productivity should result in improvements with regular pay. Major Working hours Working hours exceed Working hours to be gradually reduced to bring 250 hours per month them into line with the legal maximum. This to be done in conjunction with improvements in productivity and profitability to ensure that workers are not paid less Major Working hours Compulsory overtime Workers to be allowed to say no to overtime. Improvements in productivity and production planning to be initiated to ensure that production is planned over regular hours and overtime is not required as often. Major Working hours Workers not given one Improvements in productivity and production day off per week planning to be initiated to ensure that workers are able to take one day off per week. Production to be planned over a regular working week of no more than 6 days. taken action plan in place and initial steps being taken action plan in place and initial steps being taken action plan in place and initial steps being taken action plan in place and initial steps being taken

13 Major Harsh or inhumane Workers being shouted Ensure that workers are not shouted at or verbally Six months where treatment at or verbally abused abused by supervisors, or any other member of significant issues are production site staff. All workers should feel safe present and comfortable at work where issues are more straightforward Major Harsh or inhumane Workers are fined for Ensure that any fines that are used as a fines treatment making mistakes disciplinary measure are phased out in favour of a stopped and more incentivised system. All inappropriate incentives being deductions to be stopped developed Major Regular No contracts given to All workers to be given contracts which have been employment workers explained and understood. Workers to be given a copy of the contract. Major Accommodation Inadequate living space Workers to be given adequate and legally compliant living space. Accommodation should be spacious and hygienic. Couples should be housed in their own private rooms, and wherever required family accommodation should be provided. Major Accommodation Unhygienic living All accommodation to be regularly cleaned and conditions maintained to ensure that it is hygienic and clean Six months where structural changes are required where re-allocation is required One month

14 Major Accommodation Inadequate hygiene facilities Major Accommodation No separate cooking facilities Major Accommodation Inadequate emergency lighting Major Accommodation Inadequate fire fighting equipment All accommodation to have appropriate hygiene facilities, separated by gender. All hygiene facilities to be regularly cleaned and maintained. Cooking facilities to be separate from living areas where they are required. All accommodation areas to be installed with working and well maintained emergency lighting. All escape routes to be fully lit and visible to workers during an emergency. All fire fighting equipment must be adequate for the risks present, well maintained and be sufficient in number in all areas of accommodation. Six months where structural changes are required One month where maintenance is required Six months where structural changes are required where re-allocation is required where installation is required One month where maintenance is required One month

15 Major Accommodation No or inaudible fire alarm Major Subcontracting Work subcontracted to other production site without notification to The organisation Group. Ensure that a fire alarm is in place which can be activated and is audible in all areas of accommodation. Activation points should be clearly marked and workers should be aware of what the alarm sounds like All production sites involved in the manufacture of The organisation Group products should be disclosed to The organisation Group and involved in the ethical sourcing programme. Visibility of supply for all products and suppliers should be assured and maintained. Two months if installation of an alarm is required One month if improvements are required Six months supply chain information provided for all regular and sporadic production sites. Any subcontracting disclosed to The organisation Group.

16 Concerns Concerns relate to identified areas for remedial action which need to be addressed as part of any improvement programme. Concerns are assessed to pose moderate financial and reputational risks to the supply chain and procurers. For suppliers (and their supply chains) that do not yet have a trading relationship with the organisation, concerns should not normally prevent a relationship being established. However, if the production site does not demonstrate effective improvements on the concerns raised, within the timeframes agreed, there would be cause to review or terminate any contractual agreement. If the report relates to the supply chain of an existing supplier to the organisation, the corrective action should generally occur within the timeframe indicated (subject to mitigating circumstances). Engagement and progress are what is required, so whilst the issue may still be present for some of the critical issues, the supplier should not be penalised if they are genuinely working towards improvements. For the issues that have an immediate timeframe, it is assessed that the issue will be relatively easy to solve and the procuring organisation should expect this timeframe to be met, however remedial actions and timeframes should always be agreed by all parties and be realistic and proportionate.

17 Measure ETI Base Code Section Concern Employment is freely chosen Concern Employment is freely chosen Concern Employment is freely chosen Concern Employment is freely chosen Findings Corrective action Time frame Security guards control Ensure that security guards are not preventing workforce people from leaving. Provide training and information to them on job responsibilities and how to address workers. Unreasonable Ensure that residents of the company dormitory restrictions on the are permitted to move about the premises, and the movement of dormitory only restrictions on their movement are necessary residents. for their safety or the safety of other residents. Post security requirements on notice boards so that workers are aware of them. Unreasonable notice Make sure that workers are allowed to leave Six months requirements or employment without penalty provided they have financial penalties for given the legally required notice. Any financial leaving penalties should be removed, and the company should ensure that workers are not restricted from giving notice. Delaying payments to Ensure that all workers are given their full final workers when they payment should they leave the production site. Any leave workers who are due money since leaving the

18 production site should be paid as soon as possible. Concern Employment is Restricted toilet or rest Phase out and stop the use of toilet cards or any freely chosen breaks other restrictions on workers going to the toilet. Ensure that workers are given the legally required rest breaks, during the working day and are free to go to the toilet at any time. Concern Employment is Use of extended Ensure that no worker has their probation period Six months freely chosen probation periods extended beyond the legal limit. Workers should be assessed and trained sufficiently to be able to do the job, and the probation period set to correspond to this amount of time. Workers should not have their probation periods extended unless absolutely necessary and this should never go over the legal limit. Concern Employment is No free employment Ensure that the production site has a written policy freely chosen policy on free employment, which sets out their standards and requirements. This should be in compliance with the law, and should adhere to best practice guidelines wherever possible/reasonable. Concern Employment is Monetary deposits for Ensure that unreasonable deposits are not taken 6 months freely chosen accommodation and those that have been are returned to workers.

19 Deposits should cover the cost of likely damage to the accommodation, although this should not include general wear and tear. Workers should have deposits returned to them when they leave employment, with only reasonable amounts taken from them to cover any unreasonable damage that they have caused. Concern Freedom of Inadequate facilities for Ensure that unions have access to adequate association union activities facilities in order to be able to speak to and represent workers. This may include office facilities and/or time with the workforce Concern Freedom of Worker representatives Ensure that all worker representatives are given Six months. association not given time off for activities adequate time off in order to conduct meetings and address issues in the workplace. Ideally this should be paid time off. Concern Freedom of Workers unaware of Make sure that there is an effective system in Six months association how to raise issues with management/unaware of who their reps are. place for workers to raise issues with the management, and that workers are aware of the system and how it works. Inform workers of who their reps are. Concern Freedom of Collective agreements Ensure that all collective agreements meet at least Six months

20 association fail to comply with local minimum legal standards. Ideally a collective law agreement should go over and above the minimum legal requirements. Concern Freedom of Company does not Ensure that collective agreements are in writing, Six months association comply with collective and that the company complies with their agreements or requirements. Collective agreements are legally agreement is not in binding on all parties, and should be followed as writing. such. Concern Freedom of Penalising or Ensure that the company does not penalise or Nine months association discriminating (directly discriminate against union members or or indirectly) against union/worker reps. This may involve training and union members, union interactive work to educate management about the reps or worker reps. value of worker representation. Concern Freedom of No parallel means for Make sure that there is an effective system in Six months association workers to raise issues place for workers to raise issues with the with management management, and that workers are aware of the system and how it works. Concern Freedom of No records kept of Ensure that all meetings between management association union or worker rep and union/worker reps are minuted, and that these meetings with minutes are kept on file and circulated amongst the management workforce.

21 Concern Freedom of Employer interferes Ensure that management/employer is removed Six months association with union decision from the decision making and election process for making or the election unions. of representatives Concern Freedom of Lack of regular Ensure that all union/worker reps are Nine months association elections for democratically elected at least every 2 years. worker/union reps. Ideally this should occur every year. Concern Freedom of Representative body Ensure that worker reps or the union are equipped Nine months association does not discuss key and able to discuss workplace issues, and raise issues. this with management. Representative body should not just discuss social issues, but should cover issues such as H&S, hours and pay. Concern Health and safety Electrical wiring Ensure that all wiring is safely secured and no One month exposed/inadequately wiring is exposed or frayed. secured Concern Health and safety Failure to comply with Ensure that the workplace has the required requirements of safety certification for all electrical appliances and wiring, inspections as well as other legal inspection and certification requirements such as hygiene and ventilation. Concern Health and safety Poor or inadequate Ensure that lighting is improved so that workers lighting in production or and other staff are able to adequately see the work

22 other areas on the production floor, as well as being able to safely move around the site. Concern Health and safety Inadequate ventilation Ensure that all areas of the production site are or air conditioning adequately ventilated or air conditioned to create a comfortable working environment. Concern Health and safety Premises require minor Ensure that all minor and major repairs undertaken repairs are completed, and a system is in place to monitor repair requirements moving forward. Concern Health and safety Fire extinguishers not Ensure that all fire extinguishers and other firefighting installed at correct height/other nonfunctional requirements not met equipment is installed to comply with legal requirements and optimise ease of use. Concern Health and safety Incomplete records Ensure that all evacuations of the site, whether from fire evacuation drills drills, false alarms or actual incidents, are adequately recorded. This should include nature of incident, number of workers on site and areas that are operational, time taken to evacuate, resulting work and risk assessments, and any other legally required information. Concern Health and safety No records of training Ensure that all training of fire evacuations is

23 for fire evacuations recorded. This should include information such as time spent in training, information covered, list of attendees, and list of people absent. Concern Health and safety No records of fire alarm Ensure that all fire alarm tests are recorded and One month. tests any required work recorded and acted upon. Concern Health and safety Failure to provide Ensure that there are a sufficient number of lockers adequate or secure or other secure storage units for workers to keep storage for workers their personal effects. This may include investing in personal effects new storage. Concern Health and safety Inadequate and/or Ensure that clean and functioning sinks are unhygienic facilities for available in washrooms or toilets, and that washing and/or drying sufficient soap and hand drying facilities are hands provided. Concern Health and safety No testing of water Ensure that drinking water is tested regularly to One month potability ensure that it is potable. Concern Health and safety Isolated failures to carry Ensure that all workers are given regular medical out medical checks, and that those who are working in examinations dangerous or hazardous situations, or working with chemicals, are given medical examinations to assess their exposure to risks and the effects of that every 6 months.

24 Concern Health and safety Lack of appropriate Ensure that all workers who are obliged to or likely equipment and/or to handle heavy loads are given manual handling training on safe training to ensure that they are able to do so handling of loads safely. Ensure that required equipment is available and well maintained where it is necessary to safely handle loads. Concern Health and safety Insufficient seating in Ensure that there is sufficient and adequate canteen/dining area seating available for workers to be able to eat and rest during breaks. May require purchasing new furniture, or staggering rest breaks to reduce the number of workers using the room concurrently. Concern Children and Isolated cases where All ID s to be checked for all workers to verify age, One month young workers ID is not present. and right to work status Concern Children and No formal policy on Written policy on child labour and the treatment of young workers child labour. young workers to be developed, in line with legal requirements. Concern Children and Young workers not All young workers to be registered with relevant young workers registered as per legal authority as per local law. requirements Concern Children and No risk assessments for Risk assessments carried out for each individual young workers young workers young worker, taking into account their job role and

25 proximity to hazards. Concern Wages Workers are not All workers to begin participating in all legally participating in all required benefits schemes. benefits schemes Concern Wages Disciplinary measures All disciplinary measures to be recorded and put in not recorded worker s personnel files. Concern Wages Workers moved to other Workers hours to be recorded and paid correctly Six months facilities to avoid paying regardless of which facility they are working in. All them for overtime hours worked for one organisation to be included in total hour calculations and paid according to legal or contractual requirements. Concern Wages Individual payroll Payroll to include all workers hours and wages, Six months records missing or and all aspects of pay and/or deductions. Payroll to incomplete be kept on file for a minimum of 3 years. Concern Working hours Inadequate time All working hours to be accurately recorded and Six months records used to pay workers accurately. significant progress and movement towards all records being complete Concern Working hours No clear policy on Policy on overtime working to be developed, in line overtime working with local law, and communicated to workforce.

26 Concern Working hours Overtime exceeds 12 hours per week, or relevant legal limit, in isolated cases Records of hours and overtime to be examined to determine trends in overtime work, and actions undertaken to tackle those trends. Where no trends are found, monitoring to occur to ensure that there are none in the future. Workers to be actively discouraged from working over 12 hours of overtime. Six months Concern Discrimination Evidence of All workers to be treated equally in all aspects of Six months discrimination in one or employment. Assessment of issues present and more aspects of work work done to address them. This may include on site (i.e. training training and capacity building for staff and and/or promotion) management. Concern Discrimination Lack of transparency Policies on all aspects of employment such as Six months on issues such as recruitment, training, promotion, remuneration, promotion, hiring, benefits etc to be developed and communicated to training etc workforce. Must be in line with local law, and strictly followed subsequent to dissemination Concern Regular employment Concern Regular Agencies charging fees to workers on site All fees to be stopped, and assessment of agency undertaken by company or commissioned organisation to assess practices. Six months Probationary workers or All employees to be paid an equal wage for work of Nine months

27 employment trainees not paid the equal value, regardless of qualification levels. same wage as permanent or qualified workers Concern Regular No communication of Working conditions and appropriate labour employment standards to agencies standards requirements to be communicated or other sub-contractors effectively to all labour providers and subcontractors used by the company. Concern Regular Unclear internal rules All internal rules and regulations to be clearly employment and/or regulations communicated to entire workforce. Information to be included in a handbook for all new employees/workers, and communicated to them upon starting at the production site. Concern Harsh or inhumane No discipline and/or Company to write policies and procedures on Six months treatment grievance procedures discipline and grievances and communicate them to the workforce. These must be in line with local law and followed wherever necessary. Concern Harsh or inhumane Discipline and/or All discipline and/or grievance procedures to be treatment grievance procedures clearly communicated to entire workforce. not communicated to Information to be included in a handbook for all workforce new employees/workers, and communicated to

28 them upon starting at the production site. Concern Harsh or inhumane No documentation of All discipline and/or grievance procedures initiated treatment discipline or grievance or undertaken within the company to be accurately procedures or reviews recorded and kept on file. that have been undertaken Concern Harsh or inhumane Management and/or Management and supervisors to be given training Six months treatment supervisors do not on the relevant procedures in place within the understand/follow the company, and performance monitored for use of discipline and/or the procedures. Records of the training to be kept grievance procedures on file. Concern Accommodation Incomplete records of All evacuations, be they drills, false alarms or Six months evacuation drills genuine incidents, to be recorded and kept on file. Information should include nature of incident, number of people on site, length of time to evacuate, any people missing or injured etc. Concern Accommodation Isolated failures in Records to be kept of all maintenance 6 months maintenance requirements and all maintenance undertaken. Management programme to be brought in to ensure that no maintenance issues are missed and not completed.

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