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Individuals: Breach of duty of employer towards employees and non-employees/ Breach of duty of self-employed to others/ Breach of duty of employees at work/ Breach of Health and Safety regulations/ Secondary liability

Health and Safety at Work Act 1974 (section 33(1)(c)), Health and Safety at Work Act 1974 (section 33(1)(a) for breaches of sections 2, 3 and 7, Health and Safety at Work Act 1974 (sections 36 and 37(1) for breaches of sections 2 and 3 and section 33(1)(c)

Effective from 01 February 2016

Triable either way

Maximum: 2 years’ custody

Offence range: Conditional discharge – 2 years’ custody

User guide for this offence


Guideline users should be aware that the Equal Treatment Bench Book covers important aspects of fair treatment and disparity of outcomes for different groups in the criminal justice system. It provides guidance which sentencers are encouraged to take into account wherever applicable, to ensure that there is fairness for all involved in court proceedings.

Step 1 - Determining the offence category

The court should determine the offence category with reference only to the factors in the tables below. In order to determine the category the court should assess culpability and harm.

Culpability

Where there are factors present from more than one category of culpability, the court should weigh those factors in order to decide which category most resembles the offender’s case.

Very high

  • Where the offender intentionally breached, or flagrantly disregarded, the law

High

  • Actual foresight of, or wilful blindness to, risk of offending but risk nevertheless taken

Medium

  • Offence committed through act or omission which a person exercising reasonable care would not commit

Low 

Offence committed with little fault, for example, because:

  • significant efforts were made to address the risk although they were inadequate on this occasion
  • there was no warning/circumstance indicating a risk to health and safety
  • failings were minor and occurred as an isolated incident

Harm

Health and safety offences are concerned with failures to manage risks to health and safety and do not require proof that the offence caused any actual harm. The offence is in creating a risk of harm. 1) Use the table below to identify an initial harm category based on the risk of harm created by the offence. The assessment of harm requires a consideration of both: – the seriousness of the harm risked (A, B or C) by the offender’s breach; and – the likelihood of that harm arising (high, medium or low).

Seriousness of harm risked
Level A
  • Death
  • Physical or mental impairment resulting in lifelong dependency on third party care for basic needs
  • Significantly reduced life expectancy
Level B
  • Physical or mental impairment, not amounting to Level A, which has a substantial and long-term effect on the sufferer’s ability to carry out normal day-to-day activities or on their ability to return to work
  • A progressive, permanent or irreversible condition
Level C
  • All other cases not falling within Level A or Level B
High likelihood of harm Harm category 1 Harm category 2 Harm category 3
Medium likelihood of harm Harm category 2 Harm category 3 Harm category 4
Low likelihood of harm Harm category 3 Harm category 4 Harm category 4 (start towards bottom of range)

2) Next, the court must consider if the following factors apply. These two factors should be considered in the round in assigning the final harm category. i) Whether the offence exposed a number of workers or members of the public to the risk of harm. The greater the number of people, the greater the risk of harm. ii) Whether the offence was a significant cause of actual harm. Consider whether the offender’s breach was a significant cause* of actual harm and the extent to which other factors contributed to the harm caused. Actions of victims are unlikely to be considered contributory events for sentencing purposes. Offenders are required to protect workers or others who may be neglectful of their own safety in a way that is reasonably foreseeable. If one or both of these factors apply the court must consider either moving up a harm category or substantially moving up within the category range at step two overleaf. If already in harm category 1 and wishing to move higher, move up from the starting point at step two overleaf. The court should not move up a harm category if actual harm was caused but to a lesser degree than the harm that was risked, as identified on the scale of seriousness above. * A significant cause is one which more than minimally, negligibly or trivially contributed to the outcome. It does not have to be the sole or principal cause.

Step 2 - Starting point and category range

Having determined the category at step one, the court should use the corresponding starting point to reach a sentence within the category range in the table below. The starting point applies to all offenders irrespective of plea or previous convictions.

An adjustment from the starting point, upwards or downwards, may be necessary to reflect particular features of culpability and/or harm (for example, the presence of multiple factors within one category, the presence of factors from more than one category (where not already taken into account at step 1), or where a case falls close to a borderline between categories).

Starting points and ranges

Where the range includes a potential sentence of custody, the court should consider the custody threshold as follows:

  • has the custody threshold been passed?
  • if so, is it unavoidable that a custodial sentence be imposed?
  • if so, can that sentence be suspended?

Where the range includes a potential sentence of a community order, the court should consider the community order threshold as follows:

  • has the community order threshold been passed?

Even where the community order threshold has been passed, a fine will normally be the most appropriate disposal where the offence was committed for economic benefit. Or, if wishing to remove economic benefit derived through the commission of the offence, consider combining a fine with a community order.

Starting point Category range
Very high culpability
Harm category 1 18 months' custody 1 - 2 years' custody
Harm category 2 1 year's custody 26 weeks' - 18 months' custody
Harm category 3 26 weeks' custody Band F fine or high level community order - 1 years' custody
Harm category 4 Band F fine Band E fine - 26 weeks' custody
High culpability
Harm category 1 1 year's custody 26 weeks' - 18 months' custody
Harm category 2 26 weeks' custody Band F fine or high level community order - 1 years' custody
Harm category 3 Band F fine Band E fine or medium level community order - 26 weeks' custody
Harm category 4 Band E fine Band D fine - Band E fine
Medium culpability
Harm category 1 26 weeks' custody Band F fine or high level community order - 1 years' custody
Harm category 2 Band F fine Band E fine or medium level community order - 26 weeks' custody
Harm category 3 Band E fine Band D fine or low level community order - Band E fine
Harm category 4 Band D fine Band C fine - Band D fine
Low culpability
Harm category 1 Band F fine Band E fine or medium level community order - 26 weeks' custody
Harm category 2 Band D fine Band C fine - Band D fine
Harm category 3 Band C fine Band B fine - Band C fine
Harm category 4 Band A fine Conditional discharge - Band A fine

The tables below contain a non-exhaustive list of additional factual elements providing the context of the offence and factors relating to the offender. Identify whether any combination of these, or other relevant factors, should result in a further upward or downward adjustment. In some cases, having considered these factors, it may be appropriate to move outside the identified category range.

Factors increasing seriousness

Statutory aggravating factors

  • having regard to a) the nature of the offence to which the conviction relates and its relevance to the current offence; and b) the time that has elapsed since the conviction

Other aggravating factors include:

  • Deliberate concealment of illegal nature of activity
  • Poor health and safety record
  • Falsification of documentation or licences
  • Deliberate failure to obtain or comply with relevant licences in order to avoid scrutiny by authorities

Factors reducing seriousness or reflecting personal mitigation

  • Evidence of steps taken voluntarily to remedy problem
  • Good health and safety record
  • Effective health and safety procedures in place
  • Inappropriate degree of trust or responsibility

Step 3 - Review any financial element of the sentence

Where the sentence is or includes a fine, the court should ‘step back’ and, using the factors set out below, review whether the sentence as a whole meets the objectives of sentencing for these offences. The court may increase or reduce the proposed fine reached at step two, if necessary moving outside of the range.

General principles to follow in setting a fine

The court should finalise the appropriate level of fine in accordance with section 125 of the Sentencing Code, which requires that the fine must reflect the seriousness of the offence and requires the court to take into account the financial circumstances of the offender. The level of fine should reflect the extent to which the offender fell below the required standard. The fine should meet, in a fair and proportionate way, the objectives of punishment, deterrence and the removal of gain derived through the commission of the offence; it should not be cheaper to offend than to take the appropriate precautions.

Review of the fine

Where the court proposes to impose a fine it should ‘step back’, review and, if necessary, adjust the initial fine reached at step two to ensure that it fulfils the general principles set out above. Any quantifiable economic benefit derived from the offence, including through avoided costs or operating savings, should normally be added to the fine arrived at in step two. Where this is not readily available, the court may draw on information available from enforcing authorities and others about the general costs of operating within the law. In finalising the sentence, the court should have regard to the following factors relating to the wider impacts of the fine on innocent third parties; such as (but not limited to):

  • impact of the fine on offender’s ability to comply with the law;
  • impact of the fine on employment of staff, service users, customers and local economy.

Step 4 - Consider any factors which indicate a reduction, such as assistance to the prosecution

The court should take into account section 74 of the Sentencing Code (reduction in sentence for assistance to prosecution) and any other rule of law by virtue of which an offender may receive a discounted sentence in consequence of assistance given (or offered) to the prosecutor or investigator.

Step 5 - Reduction for guilty pleas

The court should take account of any potential reduction for a guilty plea in accordance with section 73 of the Sentencing Code and the Reduction in Sentence for a Guilty Plea guideline.

Step 6 - Compensation and ancillary orders

In all cases, the court must consider whether to make ancillary orders. These may include:

Remediation

Under section 42(1) of the Health and Safety at Work Act 1974, the court may impose a remedial order in addition to or instead of imposing any punishment on the offender. An offender ought by the time of sentencing to have remedied any specific failings involved in the offence and if not, will be deprived of significant mitigation. The cost of compliance with such an order should not ordinarily be taken into account in fixing the fine; the order requires only what should already have been done.

Forfeiture

Where the offence involves the acquisition or possession of an explosive article or substance, section 42(4) enables the court to order forfeiture of the explosive.

Compensation

Where the offence has resulted in personal injury, loss or damage, the court must consider whether to make a compensation order and must give reasons if it decides not to order compensation (Sentencing Code, s.55). The assessment of compensation in cases involving death or serious injury will usually be complex and will ordinarily be covered by insurance. In the great majority of cases the court should conclude that compensation should be dealt with in the civil courts, and should say that no order is made for that reason.

Step 7 - Totality principle

If sentencing an offender for more than one offence, or where the offender is already serving a sentence, consider whether the total sentence is just and proportionate to the offending behaviour in accordance with the Totality guideline.

Step 8 - Reasons

Section 52 of the Sentencing Code imposes a duty to give reasons for, and explain the effect of, the sentence.

Step 9 - Consideration for time spent on bail (tagged curfew)

The court must consider whether to give credit for time spent on bail in accordance with section 240A of the Criminal Justice Act 2003 and section 325 of the Sentencing Code.

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