Preparing a Risk Assessment for your Shoot

A recent case reported in Shooting Times magazine highlighted the importance of health and safety on shoots. Seven hunt saboteurs were acquitted on 14th April of aggravated trespass because the shoot in question did not have a written health and safety policy.

A recent case reported in Shooting Times magazine highlighted the importance of health and safety on shoots. Seven hunt saboteurs were acquitted on 14th April of aggravated trespass because the shoot in question did not have a written health and safety policy. Any shoot with five or more employees is required by law to have a written health and safety policy and risk assessment. Getting this sort of administration done ahead of the 2008/09 season will mean peace of mind, and Countryside Alliance has developed a guideline to risk assessment on shoots to help avoid legal pitfalls. The risk assessment of the shoot is in line with the Code of Good Shooting Practice and the Game Shoot Standard Assurance Scheme.


Preparing a Risk Assessment for your Shoot

Every shoot owner or manager who employs five or more people is required by law to ‘prepare and as often as may be appropriate revise a written statement of his general policy with respect to the health and safety at work of his employees and the organisation and arrangements for the time being in force for carrying out that policy.’

This legal requirement extends not merely to those shoots which employ a number of full or part-time gamekeepers or other workers; it also encompasses those which employ people on a purely temporary basis, including beaters, loaders and pickers-up on shoot days. Moreover, such individuals may even be regarded as ‘employees’ if they receive only payment in kind. Thus there are few organised game shoots which are exempt from the need to prepare a written risk assessment.

Recent legal decisions have made it all the more important for shoot managers to fulfil their responsibilities under the Health and Safety at Work Act and if they do not do so, then their shoot may not be considered ‘lawful’ under other legislation.

What is a Risk Assessment?

Shooters are well used to dealing with issues regarding safety. Indeed, safety with firearms is the fundamental building block of shooting sports. But assessment of risk goes beyond understanding and adhering to a code of practice. The law does not expect you to eliminate all risk, but you are required to protect the people working on your shoot as far as ‘reasonably practicable’.
A risk assessment is simply a careful examination of what, on your shoot, could cause harm to those who work there, whether gamekeepers, beaters, loaders, pickers-up or even other assistants such as catering staff, so that you can weigh up whether you have taken enough precautions or should do more to prevent harm. The safety of others who share your workplace, such as farm, forestry or estate staff and contractors must also be considered, along with the safety of any members of the general public who may have access. Workers and others have a legal right to be protected from harm caused by a failure to take reasonable control measures.

Five steps to assessing and managing risk
Risk assessment is not rocket science. If you have been running and managing a shoot for more than a season then you will be well aware of the potential dangers involved, and you will almost certainly have taken steps to minimise them. A risk assessment is simply a formalising of this process. The Health and Safety Executive recommend a five point checklist:

1.    Identify the hazards
2.    Decide who might be harmed and how
3.    Evaluate the risks and decide on precaution
4.    Record your findings and implement them
5.    Review your assessment and update if necessary

Step 1: Identify the hazards

What is the difference between a risk and a hazard? 

·    a hazard is anything that may cause harm, such as firearms, vehicles, machinery, chemicals, electricity etc; 
·    the risk is the chance, high or low, that somebody could be harmed by these and other hazards, together with an indication of how serious the harm could be. 

Walk around your shoot and ask yourself what might reasonably be expected to cause harm. Talk to those who are involved in the day-to-day running of your shoot, such as the gamekeeper or underkeeper. They may have noticed things which are not immediately obvious to you.

The Health and Safety Executive (HSE) website provides useful guidance on identifying hazards associated with different industries.

Check the operators’ manuals, instruction books and data sheets of tools, equipment or chemicals which are used on the shoot. These will often assist you in assessing the extent to which such equipment or products may be considered hazardous.

Accident and ill-health records may often help to identify the less obvious hazards. 

Remember to think about long-term hazards to health, such as high levels of noise or exposure to harmful substances, as well as safety hazards. 

A list of potential shooting-associated hazards is given below. Not all may apply to your shoot, but remember also that this list is not exhaustive.

Step 2: Who might be harmed and how?
For each hazard, think about who might be harmed. It is not necessary to list everyone by name, but you should identify groups of people (eg. ‘loaders’ or ‘people walking on the footpath’) 

·    some workers have particular requirements, eg. new and young workers, elderly beaters and those with disabilities may be at particular risk. Extra thought will be needed for some hazards; 
·    visiting guns and guests, contractors, farm and forestry workers who may not be on the shoot all the time; 
·    members of the public who may be on the shoot, eg. walking or riding on public rights of way; 
·    if you share your workplace with farm or estate staff, then you will need to think about how your work affects them, as well as how their work affects your staff – talk to them; and 
·    ask your staff if they can think of anyone you may have missed. 

In each case, identify how they might be harmed, i.e. what type of injury or ill health might occur. For example, ‘loaders may suffer hearing loss from repeated exposure to sound of gunshots’.

Remember that there may be several different categories of persons directly involved in your shoot, for example:

·    Gamekeeping staff who are regularly employed either full or part time and who are likely to be familiar with organisation and procedures
·    Beaters, stops, loaders and other occasional staff who may not be familiar with safety precautions, and who will need to be briefed by the person to whom they are responsible (eg. head keeper)
·    Regular syndicate guns who are aware of the shoot’s procedures
·    Visiting guns and their guests who may be unknown to the shoot organiser or the estate (eg. on a commercial or let day), young or inexperienced guns
·    Members of the public passing through the estate who may be entirely unfamiliar with shooting and even unaware that it is taking place

Gamekeepers may have to deal with poaching or have responsibility for wider estate security. These tasks may incur particular risks.

Step 3: Evaluate the risks and decide on precaution
Having identified the hazards, you then have to decide what to do about them. The law requires you to do everything ‘reasonably practicable’ to protect people from harm. You can work this out for yourself, but the easiest way is to compare what you are doing with good practice.

So first, look at what you’re already doing and think about what controls you have in place. Then compare this with what is recognised as ‘good practice’ and see if there’s more you should be doing to bring yourself up to standard. In asking yourself this, consider:

·    Can I get rid of the hazard altogether? 
·    If not, how can I control the risks so that harm is unlikely? 

When controlling risks, apply the principles below, if possible in the following order:

·    try a less risky option (eg. switch to using a less hazardous chemical); 
·    prevent access to the hazard (eg. by storing cleaning agents securely); 
·    reduce exposure to the hazard (eg. rearrange drives to prevent shot fallout over public rights of way); 
·    issue personal protective equipment (eg. clothing, footwear, goggles etc to those using cutting equipment in the woods); and 
·    provide welfare facilities (eg first aid and washing facilities for removal of contamination). 

Particular risks are associated with shoot days, when there may be many different people present. It is the shoot organsier’s responsibility to ensure that everyone is provided with the means to look after his or her own safety and the safety of others on the shoot, and the best way of doing this is through one or more structured briefings.

On shoot days, beaters, stops and other temporary assistants who are not familiar with the shoot must be briefed, perhaps by the keeper, so that they are fully aware of any hazards (eg. stops or pickers-up moving from appointed positions during a drive)

Guns must be briefed on safety procedures before the start of the shoot by the shoot captain or organiser. The briefing should include:
·    Low birds
·    Ground game
·    Location of pickers-up, stops etc.
·    Loading and unloading procedures (eg guns to be loaded upon arrival at pegs and unloaded when the whistle/horn is sounded)
·    Guns to be in slips between drives
Special attention needs to be paid to new/young/inexperienced guns. If necessary, experienced loaders or instructors should be appointed to supervise novice guns.

Communication can alleviate risk. Consider providing key personnel with two-way radios or mobile phones

Emergency signals and procedures should be clearly explained, eg. in the case of an incursion by hunt saboteurs. These will include making safe all shotguns and gathering at a pre-arranged location.

Step 4: Record your findings and implement them

Write down the results of your risk assessment in simple terms, for example ‘Slipping on sleeper bridge: chicken wire fixed to bridge surface, staff instructed, annual check’, or ‘Falling from beaters wagon: tailgate latch fixed and regularly checked’.
The law does not expect a risk assessment to be perfect, but it must be suitable and sufficient. You need to be able to show that:

·    A proper check was made; 
·    You asked who might be affected; 
·    You dealt with all the obvious significant hazards, taking into account the number of people who could be involved; 
·    The precautions are reasonable and the remaining risk is low; and 
·    You involved your staff or their representatives in the process. 

If you find that there are quite a lot of improvements that you could make, big and small, don’t try to do everything at once. Make a plan of action to deal with the most important things first. 

A good plan of action often includes a mixture of different things such as:
·    a few cheap or easy improvements that can be done quickly, perhaps as a temporary solution until more reliable controls are in place; 
·    long-term solutions to those risks most likely to cause accidents or ill health; 
·    long-term solutions to those risks with the worst potential consequences; 
·    arrangements for training employees on the main risks that remain and how they are to be controlled; 
·    regular checks to make sure that the control measures stay in place; and 
·    clear responsibilities – who will lead on what action, and by when. 

Remember, prioritise and tackle the most important things first. As you complete each action, tick it off your plan.

Step 5: Review your assessment and update if necessary

Changes to the organisation of your shoot or the introduction of new equipment, substances and procedures could lead to new hazards. You should therefore keep what you are doing under review. Every year or so formally review where you are to make sure you are still improving, or at least not sliding back.

Look at your risk assessment again. Have there been any changes? Are there improvements you still need to make? Have your employees spotted a problem? Have you learnt anything from accidents or near misses? Make sure your risk assessment stays up to date.

During the year, if there is a significant change, don’t wait: check your risk assessment and where necessary, amend it. If possible, it is best to think about the risk assessment when you’re planning your change.

Shooting-associated hazards

Unsafe gun handling
Low birds
Ground game
Mixing different calibres of ammunition
Non-use of gunslips
Young/inexperienced guns
Shotguns/firearms in unsafe condition
Use of rifles for deer/predator management
Inadequate gun security
Safety/suitability of guns’ and beaters’ transport
Competence of drivers
Manoeuvreing in parking areas/yards etc.
Slow-moving shoot vehicles on public roads
Quad bikes/ATVs
Land rovers/4x4s
Use of trailers
Carriage of dogs
Carriage of guns and ammunition
Shoot equipment
Other power tools
Axes, knives 
Winches, hoists
Welding equipment
Gundog/terrier kennels
Ferret housing
Farm livestock
Inadequate hygiene
Dog bite
Ponds, rivers, streams
Tidal waters
Bridges and walkways
Gates and stiles
Steep slopes
Rocks, crags and cliffs
Severe weather
Poor ground condition
Chemical usage
Cleaning products in pens and larder
Faulty spraying equipment
Inadequate hygiene
Inadequate labelling
Shoot catering
Poor temperature control
Poor storage
Poor food preparation
Inadequate hygiene
General activities
Slip, trip and fall hazards
Cluttered working space
Ladders/high seats
Non-Shoot personnel
Members of public on rights of way
Demonstrators/activists/hunt saboteurs

Click Here to Download a simple dummy risk assessment giving a few worked examples of risks shoots might face It is not a definitive guide, but the format is HSE approved.

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