So I went up to Caerphilly to meet with representatives of National Britannia (including their divisional managing director, James Ostler) to discuss the curfuffle I have created over our SafeContractor renewal.
I was actually quite impressed: National Britannia have put a lot of thought into what I have said, and took my concerns very seriously. Broadly speaking, this was the outcome of the meeting:
1. NatBrit agree that overloading people with information is counter-productive
2. Our risk assessments are very good, and do a good job of communicating information to our handymen
3. They would prefer to see more paperwork documenting the work we have done to produce those risk assessments (i.e. why we have chosen those risks not others; our process for identifying new risks, etc.)
This is also what the HSE hinted at: that the paperwork we issue to handymen is excellent, but we should have more 'back-office' paperwork to back it up.
NatBrit are going to re-audit our application and issue a revised list of additional things they'd like to see. I doubt if producing this extra paperwork will make our business any more safe, but it probably won't make it less safe (assuming, that is, that they don't ask us to issue more bumf to our handymen, just have it filed away for occasional review in the office) Once I know what new paperwork they would like to see, I will decide whether it is commercially worth the extra time and effort needed to produce it.
One question I did pose, which to their credit they did consider very carefully (and, I suspect, discussed further after I left) was this: "would you ever reject a risk assessment because it was too long-winded?". If one really does believe that over-loading people with excessive information is counter-productive, then it follows that you must reject some risk assessments for being too long. A 2,500 word document about, say, using a Stanley knife is unlikely to be an effective document and should be rejected. NatBrit didn't think they had yet rejected anything for ticking too many boxes, but maybe they will start doing that now?