7.3 Observation 174
7.3.10 Further Developments and Consultations 186
There followed numerous email exchanges on developing the Code. Some exchanges where as a result of conversations with other PEC members on aspects
of guidance. We also received additional feedback from IOSH Council members that is discussed further below. Other contributory information came in the form of conversations and correspondence between the EPM and members seeking advice on ethical issues. As an example an extract from an email between the EPM and me is given below in relation to an ethical issue raised by a member. The first part of the email contained confidential information and therefore is not included, however the issues were related to an employer not following the advice given and the member’s anxiety over what to do next and how this fitted in with the existing IOSH Code. An extract of my response is given below:
I've had time to read this now. This type of dilemma is I feel quite wide spread and I have experienced similar problems with clients. It is interesting that the consultant was conscious of the dilemmas and took the step of contacting you. It gives me confidence that the need for CPD in this area is real and for some desirable to help improve their professional practice. The advice given is useful and comprehensive. It reminds me of the grey issues advice sheets published on the CISI website on ethical dilemmas. I think we would be quite safe in publishing a few of these to encourage some engagement with the Code and wider ethical issues. I wonder whether Whistle-blowing is an issue we should also consider.
Email dated 22nd Oct 2010
The Public Interest Disclosure Act 1998 protects workers who 'blow the whistle' about wrongdoings. It applies where a worker has a reasonable belief that their disclosure tends to show one or more of the following offences or breaches: a criminal offence; the breach of a legal obligation; a miscarriage of justice; a danger to the health and safety of any individual; damage to the environment; or deliberate covering up. The Health and Safety Executive (HSE) supports measures that protect whistleblowers from any form of victimization (HSE 2000, p.5). The HSE has a complaints handling system to ensure that concerns about health and safety are dealt with effectively and efficiently. HSE and local authority staff indicate that they do all that they can to preserve the confidentiality of workers who raise concerns about health and safety. This prompted the inclusion of whistle blowing advice into the guidance. This had not been raised by the IOSH Council or the PEC previously but had come up in the
interviews. Unfortunately NEBOSH had removed its inclusion in their syllabus due to competition from other technical requirements. The inclusion into guidance therefore ensured that the issue of whistle blowing was not left out entirely and provided the opportunity for its inclusion in future CPD to compensate for its omission from the educational syllabus. This was not the first time whistle blowing had been mentioned, during interviews several participants made the point that as a last resort they would consider going to the HSE if the employer was ignoring their advice. Although no examples were given it is logical to assume that this has happened at some point and the advice provided by the HSE appear to corroborate this assertion.
We also resolved to further simplify the principle headings. We had also discussed the order of the principles and whether competence was the most important and should go first. I was reluctant to lose our acronym ‘CHRIS’ however logically Integrity would appear to be the highest-level principle from which all others follow. As Cox et al (2011) writes integrity is one of the most important and often cited virtues. It appears in virtually every professional Code and is included in many guides to Codes and is one of the most common values for liberal professions in the EU (CEPLIS 2007). We also discussed honesty at length. Honesty as a principle was limited to only two Code points made under it. Integrity would appear to encompass honesty as a principle and we therefore resolved to reduce the Code points from five to four and essentially kill ‘CHRIS”. This was not a clear decision and there was some doubt at first, ‘CHRIS’ was useful in assisting with creating a memorable IOSH Code. In the end we settled on the four Code points in agreed order of importance, Integrity, Competence, Respect and Service. An extract from an email between the EPM and myself capturing this point is shown below:
I really like what you have done. On Honesty I wondered whether we just put ‘Be honest’ under Integrity and reduce the standards from 5 to 4. It’s highly probable that this Friday I am being more irritating than unusual and doing a U-turn on previous discussions. Email Extract 20th Oct 2010
This allowed further simplification without losing content. The PEC was in agreement and we subsequently sent out a revised version with additional guidance to IOSH Council members.