Applying the New Framework in Practice

At the time of writing the new OEL Framework is not yet in force. However, as the preceding pages have outlined, a LfK model for controlling the risks of hazardous substances at work that has developed over the past 20 years and in which the Framework sits is now well established. The role of OELs has 

See for example HSE Small Firms Strategy (http //www.hse.gov.uk/aboutus/hse/policy/ strategy.htm). Also Walters (2001) and James et al (2004) for a critique of these approaches. 

See for exanq)le the Consultative Document on this strategy (HSE 2004a) and the HSE statement on providing accessible advice and support , www.hse.gov.uk/aboutus/plans/ index/htm. 

This point is made in relation to small firms in Walters (2001 380-84) and in James et al (2004). A report commissioned by the HSE also points out that many of the new ways of accessing contacting and influencing employers are untested (Greenstreet Berman 2004). A study for the Centre for Corporate Accountability provides an extensive review of the international literature and strongly supports the role of enforcement, as does a more analytical Canadian study on the international literature which argues that there is strong evidence that enforcement action improves health and safety performance with better effect than other approaches ( Davis 2004 Tompa et al 2004). 

Equally important, there is little evidence that COSHH Essentials is used properly by the firms that have accessed it. Just as the application of good occupational hygiene principles rely on preconditions such as the availability of expertise, resources to support it and incentives that influence employers willingness to utilise it, there are preconditions that will determine the effective uptake of the current COSHH approach. They probably include  

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