In this insight we discuss the impact of The Health & Safety Executive’s ten-year strategy which highlights the risks associated for businesses striving to achieve net-zero by adopting new technologies.
The Health & Safety Executive’s (HSE) ten-year strategy is a must-read guide for anyone involved in safety and risk management, reinforcing, not only the existing obligations of all stakeholders, but also new ones triggered by the Government’s ambition to achieve net-zero by 2050.
Launched halfway through 2022, Protecting people and places is the definitive guide to the themes, objectives, and priorities that will underpin the work of the HSE from now until 2032. These areas of focus are not just those of the UK’s national independent regulator for health and safety, however – they should be those of businesses as well.
A quick glance through the introduction of the strategy reveals a clear message that is reiterated throughout the 14-page tome: managing risks to health and safety remains the responsibility of the businesses and sectors that create them. “Those who fail to do so,” according to HSE chief executive Sarah Albon and board chair Sarah Newton, “will be held to account and will bear the cost.”
In commercial terms, this means reviewing both the risks inherent in a business’ sector or course of work, and the risks identified by the HSE as new and fast-growing priorities. There are few surprises here, but the Strategy’s explicit focus on new technologies – particularly those employed as part of carbon-neutral or Environmental, Social and Governance (ESG) initiatives – should give many businesses pause to consider how the adoption of environmentally-friendly products or processes is managed from a health and safety perspective.
According to one study, 51% of consumers are strongly interested in ESG issues, while two fifths would avoid a company’s products or services due to inadequate ESG practices. Such attitudes also extend to the investment community, with 80% of potential investors considering ESG as an important factor in their decision making.
Small wonder then, that nearly one third of the UK’s largest businesses have pledged to eliminate their contribution to carbon emissions by 2050, according to the Department for Business, Energy and Industrial Strategy.
Many ESG initiatives focus on the implementation of new technologies to enhance efficiencies, reduce waste, and use cleaner forms of energy. It is here that the HSE identifies risk, particularly where technologies or forms of energy are not yet widely researched or understood. “We have a significant part to play in the safe delivery of the Government’s commitment to achieve net zero greenhouse gas emissions by 2050,” it says. “Transitioning to a carbon neutral economy will see more innovative technologies and processes, which will present new risk.”
The HSE gives, as an example, the use of hydrogen, a clean alternative to natural gas and the most abundant chemical element in the universe. The UK Government’s Hydrogen Strategy estimates that hydrogen will cover 20 to 35% of the UK’s energy consumption by 2030, with millions invested into studies and projects researching the infrastructure required to fully harness hydrogen as a source of energy.
The novelty of using hydrogen for heat, power, and fuel, however, does present numerous risks, particularly concerning how it is transported, stored, and monitored. Liquid hydrogen (LH2), for example, ignites more easily than gasoline or natural gas and burns with an almost invisible flame. As such, current risk assessments for fire detection and storage may not adequately cover the enhanced risks of ignition, nor the difficulty of knowing when and where a hydrogen fire is present.
Existing materials used for storing fuel may also be insufficient, as some metals can become brittle when exposed to hydrogen, increasing the risk of leaks.
New technology, new risk
The strategy does not cover in detail the various risks of low and zero-carbon technologies, but it does highlight the importance of proactive engagement with, and regular review of, the relevant research. “We recognise that development of greener building and battery technologies will present challenges that businesses and society are less familiar with,” it says. “We will work to make sure that health and safety legislation doesn’t prevent innovation and progress”.
As such, while it may be tempting for businesses to invest in all the bells and whistles required to achieve net-zero status, a phased, risk-based approach is better. Businesses will need to analyse risk and, where possible, seek expert clarification and advice to ensure that all possible elements of risk to health and safety are either removed, reduced, or mitigated. If this is not possible, they must identify alternative technologies and processes.
The HSE also highlights expertise and aims to “apply our expert knowledge and capability to help businesses understand both known and unknown risk”. Indeed, the HSE has already completed numerous studies on mitigating hydrogen-related risks and outlines several potential safeguards on its website, such as special flame detectors, adequate ventilation, and leak detection systems.
Its focus on research should come as both a warning and a guideline for businesses wishing to invest in ESG-related technologies. Ignorance will be no excuse. Furthermore, while fully supportive of net-zero ambitions, the HSE does reiterate the focus on risk, highlighting that developments in technology should not come at the expense of health and safety.
It is arguably never more important for a business to ensure that it has the right expertise at its disposal when assessing the risks of new technologies, whether that expertise comes from a health and safety professional, or the latest research and development. Either way, companies wishing to go green need to get informed, or be responsible for the consequences.