Sir, It was suggested in your letters page (January 30) that the CTA log book will show skills and competence. As the design of these books is not yet known, this claim could be somewhat exaggerated.
Hopefully there will be a section for the manager/client to complete detailing the quality and safety of an operator's performance. If the logs merely record time on machine then they could be misleading.
As with risk assessments, method statements and even company health and safety policy, it is the implementation of the system that is important, and this can only be verified by monitoring. To do this we need to be able to include quality and safety as well as hours.
Reports suggest that an operator must achieve a total of 300 hours over five years to remain competent for each type of plant on the card. This is a very low target and could easily be accumulated in a couple of months at the end or beginning of the five-year period.
He could then do the same at the end of the next year spell, making a period of nine years and eight months in which he did not operate a particular type of plant.
I would much prefer to see the criteria include a requirement to operate a machine for the equivalent of one full week in every six months of the five years.
A plant hire company may hire out a machine plus operator for eight hours a day and, regardless of the hours actually worked, the operator will get paid for eight hours a day.
Will there be a need to differentiate between operating time and standing time?
Another disputed point is those sites where the dumper or JCB is used by every man and his dog for a few minutes each day. Do they all get one day recorded or will there be an attempt to divide machine time between all the operators? If the latter, how will this be done and verified?
How many pages will there be in a log book? Will we be able to allocate one page (or a set of pages) to each type of machine, making it easier to tot up the hours for each category, or will they all be lumped together?
Do we stop recording for a particular type of machine when 300 hours have been accumulated over the five years?
As a health and safety professional, I am all in favour of operator competency but we must be assured that there will be no cracks through which the unscrupulous and/or unsafe might slip.
Chas Fox, BEM Health & safety consultant Mervyn Lambert Plant Diss Norfolk