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Wed December 08 2021

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HSE recommended to keep FFI

5 Sep 14 A report produced for the Health & Safety Executive has concluded that its ‘fee for intervention’ scheme is a good thing and has not changed the behaviour of enforcement officers.

The report, described by HSE as ‘independent’, essentially concludes that the revenue-generating scheme should be retained as it works and there is no alternative.

The report was produced by a panel chaired by Alan Harding, professor of public policy at Liverpool University. Other participants were representatives of the GMB trade union, the Federation of Small Businesses and the Department for Work & Pensions.

FFI was introduced in October 2012 to take money off companies served with enforcement notices by HSE inspectors. The primary motive was to maintain adequate revenues at a time of public spending cuts. The rationale was ‘the polluter pays’ principle.

The scheme has been controversial because it seems the more faults that inspectors find on site visits, the more money the HSE makes. As previously reported, one in three sites visited generate an FFI invoice. (See previous report here.)

A review of the scheme in January 2014 concluded that the scheme should be scrapped because stakeholders felt it wrong that HSE should act as ‘police, prosecutor, judge and jury’. (See that report here.)

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The latest report, however, says that FFI has been effective and should stay.

According to the report’s authors, concerns voiced about FFI have not manifested themselves to any significant or serious extent and that ‘generally inspectors and dutyholders continue to work together in improving health and safety management’.

The report says fears that FFI would be used to generate revenue have proven to be unfounded. It acknowledges that it is not popular, even among inspectors, but concludes – critically – “there is no viable alternative that can achieve the same aims”.

The reviuew panel said that it “could find no compelling evidence to suggest that HSE is using FFI as a ‘cash cow’, solely to generate revenue. It is, however imperative that HSE continues to guard against this becoming, or being seen to become the case in future.”

The full report can be downloaded as a pdf at

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