It is an article of faith amongst the grumbling types that the European Union is the flag- bearer for everything that is wrong with modern bureaucracy. So stand by for another round of EU-bagging, courtesy of a joke that begins: How many men does it take to change a light bulb in a British church?
"Thanks to the European Union's "Working at Heights Directive" the answer is four -over three days at a cost of more than 1,300 pounds." This news courtesy of Reuters, who probably picked it up from this item in the Daily Torygraph.
For many years, Father Anthony Sutch of St Benet's Church in Norfolk had been getting a firm in to change the light bulbs high up in the walls of the nave. It took one man and a ladder couple of hours and cost about 200 quid.
But the one man and his ladder got a bit unreliable, so they tried a local electrical firm instead, who told them that a new set of government regulations had just come into force and they'd therefore have to do a full risk assessment before they got underway. And they'd have to use a scaffolding tower to do the job.
Result: two people took seven hours to put up and take down scaffolding to reach five light fittings.
Cost: 1300 pounds.
So what do we have here: another example of rampaging bureaucracy strangling the aspirations not only of right-thinking entrepreneurs and shareholders everywhere but now hapless parish priests as well?
Depends how relaxed you feel about people breaking their necks.
Consider this unhappy story from Iowa. A 17 year old working in a building supply store falls 18 feet from a fibreglass extension ladder. He was changing a light bulb when he dropped to the concrete floor. A few minutes earlier his boss had tried to change the bulb from the ladder without success and had decided instead to change it after work using a forklift.
You could say that job was just a matter of someone shinning up a ladder, as the Torygraph columnist grumbled about the church lights, but you don't have to fall very far to do yourself a hell of a lot of harm, and oddly enough, people seem to keep doing that.
There are two aspects to this that interest me.
The first is the matter of the language the authorities employ to deal with this kind of thing.
The other is the inordinate cost these days of getting a couple of blokes around to do a job of any kind.
Language first. Here's what a spokeswoman for the Health and Safety Executive had to say about these new rules. Their intention is to discourage people from using ladders from "working at height", or to quote a spokesperson:
"Schedule six of the regulations says that ladders can only be used if a risk assessment shows that the use of more suitable work equipment is not justified because of the low risk," she said.
"Risk assessment". There's a terrifyingly vague-sounding expression that connotes nothing so much as many pages of jargon and an expensive consultant or two clocking up the billable hours at your expense.
I do believe that bureaucracies everywhere would do themselves a huge favour by using plain language. In fact, they do, at the sharp end of the, er, client interface. The trouble is, it's often overly simplified, while one layer deeper into the bureaucracy, where you will inevitably find yourself going reluctantly with your application form in triplicate, there is a different breed of bureaucrat who has become familiar with the jargon and acronyms of their particular little corner of the bureaucratic universe and who will blithely pepper you with them in their impenetrable correspondence.
When someone in the organisation does actually decided to deploy that plain language, though, the sun fairly glows. Here: look what risk assessment means, according to Britain's HSE*
What is risk assessment? A risk assessment is nothing more than a careful examination of what, in your work, could cause harm to people, so that you can weigh up whether you have taken enough precautions or should do more to prevent harm. The aim is to make sure that no one gets hurt or becomes ill. Accidents and ill health can ruin lives, and affect your business too if output is lost, machinery is damaged, insurance costs increase, or you have to go to court.
You are legally required to assess the risks in your workplace. The important things you need to decide are whether a hazard is significant, and whether you have it covered by satisfactory precautions so that the risk is small. You need to check this when you assess the risks. For instance, electricity can kill but the risk of it doing so in an office environment is remote, provided that 'live' components are insulated and metal casings properly earthed. and self-employed people to assess risks in the workplace.
Applying this now to the church in Norfolk, I'd say the risk assessment should take, oh, five minutes? Maybe fifteen if it takes a while to write it down.
What you're looking for, surely, is a simple description that says how high up the lights are, how stable you'd be at the top of the ladder as you took the old light out and put a new one in, and how severely mashed your skull might be if you took a header. That sort of thing. You might tone it down a bit for the vicar. And of course, you should describe a means of doing it where no-one is likely to get hurt: does it warrant a scaffold or a platform or not, and if so, how do you do it?
I don't see that any of that should necessarily entail any significant complication of daily life. The discouraging part is coming to realise that: the bloody lights are too high up; that someone could get hurt changing them, notwithstanding that they've been doing it for years without incident; and, of course, that it will all cost money.
Which brings me to the second aspect: 1300 quid seems a bit stiff, you have to admit. But maybe it would be a good idea to be doing something about building design. It's not just the EU that's doing this nutty stuff; most OECD countries appear to be doing much the same thing. If you adopt safety requirements for working at height, it comes at a price. If you don't want to pay for the scaffolding and the cherry pickers and the like, you might want to look at your building plans and ask what you can do to mimimise the cost of that mid-air maintenance.
You could just pray nothing bad will happen, I suppose, but back at St Benet's, Father Anthony is taking things into his own hands and looking at ways of getting bulbs and fittings that last a bit longer and dropping the light fittings down so they are a little easier to reach.
* Health and Safety Executive. Just how much do those acronyms piss you off when you're not in the loop, though, eh?