Purpose

This task aims to develop a senior professional’s ability to identify errors, omissions and
weak reasoning within safety documentation. A strong safety culture depends on
accurate, compliant and evidence-based written controls. When documents contain
gaps or non-conformances, the entire organisation becomes exposed to significant
operational, environmental, and health risks. This task strengthens the learner’s critical
thinking by requiring them to examine a deliberately flawed document and correct it
according to UK legal duties, ethical expectations and best practice in strategic health
and safety leadership.

The flawed document reflects several areas covered in this unit: digital system use,
ecological protection, biohazard control, ergonomic engineering, chemical hazards,
biological outbreak management and accident causation. The learner must identify the
poorly written content, underlying risks, missing legal references, ignored environmental
aspects, and weak root-cause thinking.
This prepares the learner for real-world leadership roles where reviewing and correcting
documentation is a core requirement for maintaining trust, sustainability and
organisational resilience.

SECTION 1 – FAULTY DOCUMENT (INTENTIONALLY INCORRECT)

Document Type: Combined Risk Assessment & Non-Conformance Report
Work Activity: Mixed Waste Handling and Laboratory Support Operations
Assessor: “T. Smith”
Assessment Date: 2019
Review Date: “Every 5 years”
Location: “Warehouse + Lab + Yard Area”
Document Status: Incomplete, inconsistent, non-compliant

Extract from the Document (Incorrect Version Presented to the Learner)

1. Activity Description

“General work handling different waste types from the site area and doing support work
for chemicals in the lab. Workers move items and make sure the area stays clean.”

2. Hazards Identified

• “Some liquids”
• “Heavy stuff”
• “Bad smells”
• “Machines not working sometimes”
• “People walking around everywhere”

3. People at Risk

“Everyone.”

4. Existing Controls

• “Workers use PPE if they want.”
• “We have cameras in some rooms.”
• “Spills are usually cleaned quickly.”
• “Ventilation mostly works.”
• “Training is provided when needed.

5. Residual Risk Rating:

Low.

6. Non-Conformance Section (Incorrect Version Presented to the Learner)

NC Reference: Blank
Description: “There was a problem with waste storage. Someone put the wrong item in
the wrong bin.”
Immediate Action Taken: “Told worker not to do it again.”
Root Cause: “Worker mistake.”
Corrective Measure: “More attention required.”
Responsible Person: Not stated
Verification: Not completed

SECTION 2 – EXPLANATION OF ISSUES WITH THE DOCUMENT

The document contains multiple non-conformances, gaps and inaccuracies. This section
explains what an assessor would expect the learner to identify.

1. Digital Technology Failures (LO1)

The document gives no digital evidence despite describing a modern facility. A Level 7
leader is expected to note missing digital controls such as:

• sensor data for chemical storage
• digital waste-tracking system
• digital permit-to-work oversight
• CCTV integration with incident reporting
• absence of AI or IoT systems referenced in modern risk control

The review date of “every 5 years” is unacceptable under UK requirements for dynamic
digital monitoring, where high-risk operations require continuous oversight.

2. Biohazards Risk Assessment Failures (LO2)

The document mentions “bad smells” and “some liquids” without identifying exposure
routes such as:

• blood-borne pathogens
• contaminated swabs
• aerosol generation
• cross-contamination risk
• inadequate clinical waste control

There is no reference to UK controls including COSHH, Biological Agents Regulations
or safe segregation.

3. Ecological Risk Assessment Failures (LO3)

Environmental hazards are missing. The organisation handles waste and chemicals, yet
there is no reference to:

• storm drains
• groundwater protection
• spill run-off
• storage conditions
• UK compliance under the Environmental Protection Act 1990

The incomplete NCR does not consider environmental harm.

4. Ergonomic Engineering Controls Failures (LO4)

“Heavy stuff” is not an ergonomic hazard description. The following should have
appeared:

• mechanical lifting aids
• workstation design
• repetitive strain
• safe manual handling techniques
• PUWER inspection of lifting equipment
• engineering redesign for load transfer

The document avoids engineering solutions and leaves risks unaddressed.

5. Biological Outbreak Assessment Failures (LO5)

The document was created in 2019, predating major outbreak changes, showing no:

• cleaning regime detail
• social distancing expectations
• air quality monitoring
• ventilation system inspection
• hand hygiene protocols
• UK guidance under Public Health legislation

There is no outbreak assessment framework.

6. Chemical Hazard Failure Scenarios Missing (LO6)

The risk section does not include:

• mixing errors
• reaction escalation
• incompatible waste types
• temperature control hazards
• failure of ventilation engineering
• consequences such as thermal runaway or toxic exposure

There is no reference to COSHH or HSE chemical storage requirements.

7. Physical Hazard Accident Causal Analysis Missing (LO7)

The NCR root cause simply says “worker mistake”, ignoring:

• systemic influences
• leadership failures
• poor supervision
• inadequate training
• poor engineering layout
• task-pressure evidence

Models such as the Swiss Cheese Model or Domino Theory are not applied

SECTION 3 – SUMMARY OF ALL NON-CONFORMANCES THE LEARNER MUST FIND

General Structural Errors

• Incomplete dates
• Non-specific hazards
• Overly broad description
• No task breakdown
• Generic PPE statement
• No hierarchy of controls
• No legal references
• No evidence of UK compliance

Digital Safety Failures (LO1)

• No digital monitoring
• No data integrity checks
• No automated alerts
• No system reliability considerations

Biohazard Failures (LO2)

• No reference to waste categories
• No detailed exposure pathways
• Lack of control hierarchy for biological risks

Ecological Failures (LO3)

• No environmental receptors identified
• No pollution pathways
• No ecological impact controls

Ergonomic Failures (LO4)

• No mechanical aids
• No engineering controls
• No posture or force analysis

Outbreak Prevention Failures (LO5)

• No hygiene measures
• No ventilation assessment
• No PPE control

Chemical Failure Scenarios (LO6)

• No reaction risk
• No incompatible material assessment

Accident Causal Analysis (LO7)

• Root cause overly simplistic
• No cultural diagnosis
• No failure chain mapping

SECTION 4 – CORRECTED DOCUMENT (MODEL ANSWER)

This is the high-quality version learners should aim to produce after fixing the nonconformances.

1. Activity Description (Corrected)

The work involves handling and segregating hazardous and non-hazardous waste,
supporting laboratory sample transfers, operating mechanical lifting aids, and monitoring
digital systems that record temperature, volume, and waste classification. The activity
includes indoor laboratory work, outdoor storage areas, and mixed open-yard
environments where chemicals and biological agents may be present.

2. Hazards Identified (Corrected)

• aerosol-generating biological waste
• incompatible chemical waste mixing
• ergonomic strain from repetitive handling
• airborne contamination due to poor ventilation
• digital sensor failure leading to late detection
• ecological pollution via drains
• physical hazards from poor storage layout

3.People at Risk (Corrected)

• technicians
• cleaners
• contractors
• visitors
• delivery drivers
• environmental receptors (watercourses, soil)

4. Existing Controls (Corrected)

• COSHH assessments for all laboratory materials
• sealed colour-coded clinical waste bins
• digital IoT sensors tracking temperature and storage levels
• engineering controls including LEV systems
• spill kits and drain covers
• manual handling aids and height-adjustable platforms
• ventilation monitoring with digital alarms
• mandatory training refreshed annually

5. Residual Risk Rating

Medium (pending further engineering improvements)

6. NCR Section (Corrected)

Reference: NCR-2025-04
Description: Non-conforming storage of biological waste in a chemical waste bin due to
failed segregation and poor supervision.
Immediate Action: Waste removed, area disinfected, bin re-labelled, digital record
updated.
Corrective Action: Redesign of bin layout, installation of digital scanning points,
refresher training, weekly auditing, integration with digital sensors.
Responsible Person: Department Manager
Verification: Signed by competent assessor and uploaded to digital compliance
register.

LEARNER TASK

The learner must complete the following:

1. List all missing, inaccurate or incomplete items with explanation.
2. Give reasons based on UK legislation and recognised standards.
3. Use clear language, full risk controls, digital integration, and leadership-level
   justification.
4. Show how your improvements link to digital systems, biohazard control, ecological
   management, ergonomic engineering, outbreak prevention, chemical hazard
   scenarios and accident causation.
5. Describe how your approach supports a strong safety culture and long-term
   sustainability.